An impressively researched and well written letter to the Roanoke County Board of Supervisors by Jim & Karen Scott.
March 22, 2010
Roanoke County Board of Supervisors 5204 Bernard Drive, SW
Suite 400 - F
P. O. Box 29800 Roanoke, VA 24018-0798
RE: Proposed Wind Turbines on Poor Mountain Request to Revise County Noise Ordinance
Members of the Board,
Recently, Bent Mountain residents were made aware of an industrial wind turbine project proposed by Invenergy, LLC, on Poor Mountain. The site plan map displayed at the March 3, 2010, meeting showed several wind turbines in close proximity to our property. We began to research what it would be like living so close to industrial turbines from testimony of others living near existing facilities. We are alarmed by the magnitude of the noise related problems associated with the placement of such industrial turbines too close to neighbors. Many of these communities we read about have had to react to these problems by enacting local wind turbine ordinances to provide some measure of protection from the noise created by these industrial machines.
The current Roanoke County noise ordinance does not appear adequate to deal with wind turbine noise issues. In fact, the Virginia Supreme Court recently ruled that the Virginia Beach noise ordinance was "too vague". The Roanoke County noise ordinance appears similar in its vagueness. Thus we believe that it would be particularly prudent to revise the Roanoke County noise ordinance as soon as practicable, in light of the above wind turbine proposal and the numerous residents that appear to be exposed to noise impacts from these turbines.
Noise problems associated with industrial turbines sited too close to residents in rural communities appear commonplace. Wind turbine related lawsuits are pending in many states. The Wall Street Journal (March 2010) reported that rural residents in Texas, Maine, Pennsylvania, Oregon, New York, Minnesota, Wisconsin, Canada, New Zealand, Australia, France and England have been complaining about the noise from wind turbines, particularly about sleep deprivation. The article notes that 'Ontario-based orthopedic surgeon Dr. Robert McMurtry has been researching wind turbine noise for the past 18 months. Dr. McMurtry, a fellow of the Royal College of Physicians and Surgeons of Canada, counts more than 100 people in Ontario he believes are experiencing adverse effects from turbine noise. "It has compromised their health," he says.' This former Dean of Medicine at the University of Western Ontario, has repeatedly asked the provincial government to stop approving wind power projects until a full epidemiological study has been completed, notes "People are leaving their homes. Some people have had to be admitted to hospitals with hypertensive episodes". Dr. McMurtry also takes issue with the violation ofa fundamental public health principle, stating "the actions of this government have turned the precautionary principle on its head"
Roanoke County Board of Supervisors Proposed Wind Turbines on Poor Mountain Request to Revise County Noise Ordinance March 22,2010
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Many localities are acting quickly to mitigate impacts from industrial wind turbine projects by establishing turbine setback distances, noise decibel limits, maximum tower heights, or some combination thereof. It is evident from a review of personal testimonies, that the 'wind industry' standard setbacks are inadequate to protect communities from excessive noise impacts. Even the wind industry's own promotional information, while declaring that wind turbines are quiet, note "Exceptions to quiet operating turbines can occur in some hilly terrain where residences are located in sheltered dips or hollows downwind from turbines, turbine sounds may carry further and be more audible." The 'exception' above describes our situation exactly.
The current Invenergy, LLC, proposal has 6 of these giant 2.5 MW turbines sited within 2800 feet (~1I2 mile) of our property (8 within 1 mile). One is situated an estimated 1300 feet (~1/4 mile) from our property. Such setbacks are not even sufficient to protect again the safety hazard from "ice throw" from turbines (Matilsky, 2005). Several turbines are situated along the ridges above our hollow which drains to our house, magnifying the negative noise impacts on us. It has been demonstrated that "noise from multiple turbines Similarly, distant from a residence can be noticeably louder than a lone turbine simply through the addition of multiple noise sources. Under steady wind conditions noise from a wind turbine farm may be greater than noise from the nearest turbine due to synchrony between noise from more than one turbine" (van den Berg, 2005). In addition, Kamperman and James (2008) demonstrate that "sound from 10 2.5 MW turbines (acoustically) centered 2 km (1 y" mile) away and with the nearest turbine 1 mile away will only be 6.3 dB below the sound ofa single turbine at 1000feet (0.19 mile}". These-researchers proposed noise based standards that would result in a minimum turbine setbacks of 1000 meters (>0.62 miles). Invenergy proposes 6 of these 2.SMW industrial wind turbines within that distance. There are many researchers studying these issues, but all seem to come to the same conclusion - the wind industry siting criteria is insufficient to protect nearby residents, and the setbacks need to be increased.
In March, 2006, the French National Academy of Medicine issued a report on the repercussions of wind turbine operation on human health. The Academy made recommendations to address the possible harmfulness of wind turbine noise on humans, recommending that public authorities immediately take measures to address the problem, adding, "as a precautionary measure, suspend the construction of wind turbines whose parks have over 2.5 MW of power when they are located within 1500 m from homes" - roughly 1 mile.
The Acoustic Ecology Institute Fact Sheet: Wind Energy Noise Impacts (11/17/09) stated that
" .. noise can be a significant issue in at least some situations when turbines are within about a half mile of homes, with impacts occasionally occurring up to a mile away. Some acousticians and health professionals are encouraging setbacks of 1.5 miles (roughly Zkm) or even a bit more. In the Us, it is quite common to have setbacks defined as a multiple of turbine height; for example, 5 times the turbine height from a home (which would equate to 500mfor a 100m turbine). It appears to AEI that a half-mile (800m) setback is marginally acceptable if the goal is to minimize impacts on residents, though we would prefer a one-mile (1.5/em) setback, which would offer near assurance of avoiding noise issues."
Roanoke County Board of Supervisors Proposed Wind Turbines on Poor Mountain Request to Revise County Noise Ordinance March 22, 2010
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In her testimony before the New York State Legislature Energy Committee, March 7,2006, Nina Pierpont, MD, PhD, stated "data from a number of studies and individual cases document that in rolling terrain, disturbing symptoms of the Wind Turbine Syndrome occur up to 1.2 miles from the closest turbine. In long Appalachian valleys, with turbines on ridge-tops, disturbing symptoms occur up to 1.5 miles away. In New Zealand, which is more mountainous, disturbing symptoms occur up to 1.9 miles away. In New York State, with its mixed terrain, I recommend a setback of 1.5 miles (8000 ft.) between all industrial wind turbines and people's homes or schools, hospitals, or similar institutions. This setback should be imposed immediately for turbines not yet built. The legislature might want to set up a panel of clinicians to review the data and medical information I refer to here, but until this happens, and as research continues, a moratorium on all wind turbine construction within 1.5 miles of homes would be appropriate.
To recapitulate, there is in fact a consistent cluster of symptoms, the Wind Turbine Syndrome, which occurs in a significant number of people in the vicinity of industrial wind turbines. There are specific risks factors for this syndrome, and people with these risk factors include a substantial portion of the population. A setback of 1.5 miles from homes, schools, hospitals, and similar institutions will probably be adequate, in most NY State terrain, to protect people from the adverse health effects of industrial wind turbines."
Dr. F. Owen Black (Director ofNeurotology Research, Balance & Hearing 'Center, Legacy Health System. Portland, OR), an internationally known neurotologist and human vestibular physiologist recently testified in support of Dr. Pieport's findings. In a May, 2009, affidavit, Dr. Black states "I have recently reviewed Dr Nina Pierpont's study entitled "Wind Turbine Syndrome, "which I understand will be published shortly, .. Based upon my review or Dr. Pierpont's report, I believe this study is an important initial contribution to understanding the effects of low frequency pressures on the inner ear and other organs.
As an expert in vestibular disorder research, it is my opinion that the symptoms reported and described by Dr. Pierpont in her Wind Turbine Syndrome study are consistent with symptoms I see as part of my work with disorders of the inner ear, including sleep disturbance, headache, tinnitus, ear pressure, dizziness, vertigo, nausea, visual blurring, tachycardia, irritability, problems with concentration and memory, and panic episodes associated with exposure to low frequency, high amplitude, ambient pressure fluctuations.
I am familiar with studies conducted by the United States Navy relating to low frequency sound pressure patterns, which report symptoms similar to those reported by Dr. Nina Pierpont in her Wind Turbine Syndrome study. In my opinion, based upon the similarity between Dr. Nina Pierpont's study, the Naval studies, and patients with otic capsule defects that produce similar symptoms, the hypothesis that low frequency sound pressure patterns emitted by commercial wind turbines cause the symptoms outlined above needs to be investigated further.
Roanoke County Board of Supervisors Proposed Wind Turbines on Poor Mountain Request to Revise County Noise Ordinance March 22, 2010
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Dr. Michael Nissenbaum recently conducted medical interviews with the families of Mars Hill, Maine, who live within 3600-feet ofturbines. Dr. Nissenbaum stated that "Far and away the major symptom that people complained about was sleep disturbance and that was present in fourteen out of the fifteen people who I interviewed. The fifteenth person, interestingly, was hard of hearing, and that was not an issue for him". He also indicated a dramatic increase in medications being taken by these nearby residents.
In addition to the testimony of medical professionals describing the 'effects' of wind turbine noise, it is also beneficial to read physicists describe the 'cause' ofthe noise. Dr. John P. Harrison, Professor Emeritus, Queens Univ., Kingston, ON, recently presented a talk on the "Inadequacy of Wind Turbine Noise Regulations and Their Application" (October 2009-copy attached). His very well researched studies call for a minimum setback of 1.5 km. In his conclusion he stated:
"Regulations for wind turbine noise presently in force are inadequate to protect rural residents from annoyance and, in many cases, health problems resulting from operating wind turbines. The typical noise limit of 40 dBA needs to be reduced to 35 dBA. There needs to be a 5 dBA penalty for amplitude modulation. There needs to be an analysis of turbulent inflow noise, for both atmospheric and wake turbulence. The uncertainty of noise prediction codes must be included. Together, these essential upgrades to regulation will push setbacks to the 1.5 km range ... "
Dr. Terry Matilsky, Professor of Physics at Rutgers University, when requested to testify at the Vermont Public Service Board concerning matters of wind turbines prepared another useful document (attached). His analysis contained several principles which are pertinent to our situation, including topographic effects, radiative cooling, the 'tonality' of multiple turbines, and the coherence effects (adding multiple sources of sound) - to which he adds "are precisely the case with wind turbines". He notes that "At 104 dB, the wind turbines are producing more than the noise equivalent of a jet flying overhead at an altitude of 1000 feet."
In his discussion on the 'coherence' phenomenon he states "Even at Rhede, (a very small installation of 1 0 turbines) the excess sound "did not decrease with distance, but even increased 1 dB when distance to the wind farm rose from 400m to 1500m. Thus, we can expect significant impact from this phenomenon at distances in excess of one mile from the nearest turbines. He noted the impact "will be exacerbated" by the "clusters" of turbines, "which will have the effect of having multiple turbines adding phases coherently, with little dirninuation as a function of distance. Those who visit a wind turbine in daytime will usually not hear this and probably not realize that the sound can be rather different in conditions that do not typically occur in the daytime." He also evaluated a computer model the wind industry submitted for predicted noise impacts for a proposed wind turbine project and found it was full of erroneous assumptions, leading to a gross underestimate of the 'predicted' noise impacts. These underestimates lead to the problems being experienced in rural communities such as ours.
As might be expected, concerns over noise are being discounted by the wind industry. The Canadian and the American Wind Energy Associations, both of which lobby for, and promote the
Roanoke County Board of Supervisors Proposed Wind Turbines on Poor Mountain Request to Revise County Noise Ordinance March 22, 2010
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wind industry, quickly contracted with several "experts" to produce a document to refute this rapidly increasing body of evidence which confirms the problems nearby residents of industrial wind turbines are experiencing. The document they produced concluded there is no 'proof that noise from these machines causes disease, but they do admit that some people can be "stressed" and "suffer sleep deprivation" as a result of wind turbine noise. Interestingly, the document notes that no studies have been done to prove or disprove that the noise from turbines can cause health problems, but then concludes that there is no problem, after just stating that they lacked that very information. Please note that we do consider 'sleep deprivation' a serious 'harm', and think reason would compel others to think likewise.
In a concise critique of the wind industry 'paper', Dr. Nissenbaum and Dr. McMurtry noted "The weakness of the CanWEA/AWEA white paper is that it admits there may be annoyance -but then goes on to say that annoyance is not a pathological entity. Here, they are wrong, because if annoyance leads to sleep disturbance (and it does) then sleep disturbance leads to a whole range of health issues." Adding, "The presence of industrial wind turbines is having a direct effect on peoples' health, well-being and quality of life. The symptoms reported are consistent around the worldfrom Japan to New York State to Australia to France to Ontario. "
Kamperman and James (2008), commented on the wind turbine industry's response to questions about the noise problems occurring at many projects. They note that the "industry response is spurious and misleading. The answer does not address the question. It states that the turbines will be located so as to produce sound levels of 45 dBA. The tone and context imply that 45 dBA is fully compatible with the quiet rural community where they plan to host the WTi. No acknowledgement is made of the dramatic change that will occur for near-by families when a WTi is producing 45 dBA outside their home with the potential for it being 24 hours a day, 7 days a week, and 365 days a year. No mention is made of how the sounds from the WTi will raise evening and night time background sound levels from existing background levels from the traditional range of 20 dBA to 30 dBA up to 45 dBA once the wind project is operating on a regular basis." The authors continued "There is no disclosure of the considerable low frequency content to the WTi sound; in fact, there are often claims to the contrary. Yet, modern home construction techniques used for most wood frame homes result in walls and roofs that cannot block WTi low frequencies from penetrating into the interior." [Note: Decibels are 'log scale' measurements. A sound of 20dB is 10 times louder than a sound of 10dB and a 30dB sound is 100 times louder than a 10dB sound. Therefore, in the above example, the >20 decibel increase above 'regular' background noise is »100 times louder.]
In February, 2010, Dr. Pierpont, sent a letter of support to the Vermont legislature for a bill recently introduced there (H677). That letter was co-signed by other medical professionals, and had ~ 10% of the legislature patron the bill. Attached, please find a copy of that letter and the referenced Vermont Bill. The bill calls for a 1.25 mile setback to residents if elevation difference is less than 500 feet, and 2 miles if elevation difference is over 500 feet.
Roanoke County Board of Supervisors Proposed Wind Turbines on Poor Mountain Request to Revise County Noise Ordinance March 22, 2010
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Invenergy, LLC, salesman (Don Giecek) has visited our property to discuss our concerns. He was told that several of the turbines appeared too close to our property, and also that the sun would set behind a gang of turbines just behind our house. He noted that his team of noise experts had determined that we would not be able to hear the turbines, and that he felt confident that the shadow-flicker issue could be resolved. He was told that we can clearly hear a single ATV riding along the same road that several of these turbines are proposed, noting that an ATV emits less noise (~ 90dB) than a wind turbine (> 1OOdB), and is also on the ground, not towering above the trees, over 400 feet in the air. This demonstrates the problem with the wind industry computer modeling and 'standard setbacks'. The Invenergy noise experts are obviously wrong in this case, and highlight why there is such a problem with noise from these turbines when sited according to wind industry 'noise predictions' .
The Roanoke County noise ordinance does currently recognize industrial zone 'noise', but requires such noise to cease at night, protecting residents from interrupted sleep. This is not possible for wind turbine sites, where only distance can mitigate the noise problems. In an area that has always known quiet nights, the potential noise impacts from this project need to be better evaluated, and safeguards enacted that would protect the health and well being of the residents of this community. There are numerous other 'non-participating' residences and at least as many unimproved building sites within a mile of a least one turbine.
Therefore, we request the Board of Supervisors consider an immediate moratorium on the installation of industrial wind turbines (> 1 MV) within 1.5 mile of a non-participating property (with waiver option for abutting property owner), while further research can be done to develop an appropriate and safe noise ordinance for industrial wind turbines in Roanoke County. A well researched and defendable noise ordinance may take some time to develop. Therefore, it is important to establish a temporary stay on construction of such industrial turbines within this setback distance to ensure that the intent of the current noise ordinance is met while the final county ordinance is developed, and prior to the submittal of the permit application for the proposed wind turbine project on Poor Mountain. This action would also allow the planning of the project to move forward after relocating several turbines to more remote sites, which, after reviewing the site map, appear to be readily available (roads already being proposed to get to Turbine #14 - the most 'remote' turbine -for example).
This letter seeks your cooperation in assuring that the residents of this area are afforded noise protections from these proposed turbines in the spirit of the current noise ordinance policy. The Invenergy proposal as presented does not provide sufficient turbine setbacks according to all the information we have reviewed. We encourage you to act soon while the Poor Mountain project is still early in the planning phase. Attached are several excerpts from wind turbine ordinances from communities that have recently dealt with this issue. We trust that we can learn from their experiences.
Roanoke County Board of Supervisors Proposed Wind Turbines on Poor Mountain Request to Revise County Noise Ordinance March 22, 20 lO
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The information we have reviewed thus far indicates the likelihood of irreparable harm to our property and the well being of our family from this cluster of turbines. The source documents for the information contained in this letter are attached. Additional information we found useful in our brief survey into understanding the turbine noise issue is also attached for your review and consideration. As noted, we have had only a few weeks to study this issue, but we believe there is sufficient evidence available to warrant implementation of immediate protections in the form of a temporary enforceable setback, based on the 'precautionary principle' of public health protection.
Thank you for your prompt attention to this matter.
Sincerely,
James & Karen Scott
Attachments
