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Review Report of Concerns Identified In Arran Wind Energy Project Draft Project Description Report As Submitted to the Director, Environmental Approvals Branch Ontario Ministry of the Environment Identified as: Report No. 09-1112-6081 Dated April 2010 Prepared by: Golder Associates For Arran Wind Project ULC Report Signed: For Golder Associates Ltd. by: Ian Callum, Golder Project Manager and Danny da Silva, Associate, Golder Project Director For Arran Wind Project ULC by: Joanna Szarek, Development Officer, Leader Resources Services Corp. and Charles Edey, President, LRS Corp This Review Report dated July 2010 Prepared by: William K.G. Palmer P. Eng. TRI-LEA-EM RR 5 Paisley, ON NOG 2N0 [email protected] Copies Sent to : Joanna Szarek, Leader Resources [email protected] Ian Callum, Golder Associates [email protected] Director EAAB, MoE Ontario [email protected] Duncan Moffett, Golder Associates [email protected] Mayor and Council Saugeen Shores c/o Town Clerk [email protected] Mayor and Council Arran-Elderslie c/o Town Clerk [email protected]

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Page 1: Report Signed: For Golder Associates Ltd. byontario-wind-resistance.org/wp-content/uploads/2010/07/palmer... · noise, all of which are outlined in section 4.9 of the Golder Associates

Review Report of Concerns

Identified In

Arran Wind Energy Project

Draft Project Description Report

As Submitted to the Director, Environmental Approvals Branch

Ontario Ministry of the Environment

Identified as:

Report No. 09-1112-6081

Dated April 2010

Prepared by: Golder Associates

For Arran Wind Project ULC

Report Signed:

For Golder Associates Ltd. by:

Ian Callum, Golder Project Manager

and Danny da Silva, Associate, Golder Project Director

For Arran Wind Project ULC by:

Joanna Szarek, Development Officer, Leader Resources Services Corp.

and Charles Edey, President, LRS Corp

This Review Report dated July 2010 Prepared by:

William K.G. Palmer P. Eng.

TRI-LEA-EM RR 5

Paisley, ON NOG 2N0

[email protected]

Copies Sent to:

Joanna Szarek, Leader Resources [email protected]

Ian Callum, Golder Associates [email protected]

Director EAAB, MoE Ontario [email protected]

Duncan Moffett, Golder Associates [email protected]

Mayor and Council Saugeen Shores c/o Town Clerk [email protected]

Mayor and Council Arran-Elderslie c/o Town Clerk [email protected]

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Background:

On June 29, 2010, an advertisement was posted in he Shoreline Beacon of Saugeen

Shores and other area newspapers of a “Notice of Public Meeting and Proposal to Engage

in a Renewable Energy Project” titled, “Arran Wind Energy Project.” The advertisement

stated, “A written copy of the Draft Project Description Report will be made available at

the Municipality of Arran-Elderslie and the Town of Saugeen Shores municipal offices

… on July 5, 2010.” The Clerk at both Arran Elderslie and the Deputy Clerk at Saugeen

Shores stated that the report was not made available to them until the afternoon of July 6.

Initially a copy of the report was reviewed at the municipal offices in Saugeen Shores.

The clerk stated that specific instructions had been given by representatives of Leader

Resources that a citizen was only allowed to read the report, and no copies were to be

made of the report. At the same time, an e mail request made to Golder Associates

returned a .pdf copy of the report within less than 10 minutes, an interesting discrepancy

in availability for citizens to be able to study and comment on the report.

Scope of This Review Report:

The Draft Project Description Report itself is a very general report. Although it opens in

its first line to state, “This Project Description Report has been prepared to provide

details of the Arran Wind Energy Project,” the report barely provides a rudimentary

sketch of the project. Nowhere does the report provide specifics as to the location of the

turbine generators, it only identifies that the project will consist of 46, 2.5 MW General

Electric wind turbine generators located “in Saugeen Shores and Arran-Elderslie.” The

“Project Location Map” (Figure 2, on page 44) only locates the project boundaries, but

not the turbine locations. One might make a judgment that the turbines will be located in

the white areas of the map, as they are not identified as a “constraint setback area” but it

leaves the reader wondering. It makes it very difficult to provide specific comments on

the document.

In the description of noise (section 4.6) the report states, “The operation of the wind

turbines and the Project substation will generate noise. As required by O. Reg. 359/09

turbines will be located at a minimum of 550 metres from receptors.” The Project

Description which states it will provide “details of the project” provides no details of the

sound power levels for either the source turbines, or the transformer station, nor locations

of either. The report only states, “Predictive modeling will be provided in the Project‟s

Noise Assessment Report, and will demonstrate that the operation of the project complies

with the MOE noise guidelines.” The report goes on to state categorically, “Through

adherence with to MOE Noise Guidelines, operations-related noise that may be perceived

to nearby residents will not represent a significant adverse effect.” Will Golder

Associates please provide a detailed justification of their statement? Neither the

MOE “Noise Guidelines for Wind Farms” (October 2008) nor the Project Description

demonstrate any evidence to prove that an A-weighted sound level limit for the cyclical

sound of a wind turbine which has a significant low frequency component, (as found at

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other Ontario wind power developments) “will not represent a significant adverse

effect.”.

The “details of the Arran Wind Energy Project” do not even clearly describe the size of

the turbines. Table 5 of the “Turbine Technical Specifications” in section 3.4 of the report

fails to even identify the most fundamental and obvious fact, the wind turbine tower

height. It is only by careful reading of the “Site Layout Considerations” (Section 3.2) that

one learns the turbine tower height will be 100 metres when the report states this will be

the minimum turbine setback to non-participating property lot lines. Conducting a web

search for details of the GE 2.5 MW XL wind turbine generators shows the options for

tower hub height are 75m, 85m, and 100m, confirming that the tip of the 100 metre rotor

diameter turbine blades will be some 150 metres above grade. Will Golder Associates

please ensure the “details” of the Wind Energy Project are actually provided?

The main scope of this review report is the issue of public health and safety, as well as

noise, all of which are outlined in section 4.9 of the Golder Associates – Arran Wind

Energy Project Draft Project Description Report.

Detailed Comments Related to Public Health and Safety:

a) Setbacks

It is curious that the Golder Report refers to the County of Bruce Setback

Requirements for Wind Turbines in section 4.7.3, and to the Municipality

of Arran-Elderslie Zoning Bylaw in section 4.7.4, but fails to recognize

that the Saugeen Shores Official Plan and Zoning ByLaws as put in place

following an appeal to the OMB (decision PL 060733 dated December 7,

2007) required minimum setbacks from wind turbines to any receptor of

650 metres, and from a wind turbine to a lot line or road equal to the

height of the wind turbine tower plus the blade length (150 metres for the

turbines in this proposal.)

b) Ice Throw

The Golder report lists a number of references related to ice throw:

Seifert, Weserheiling, Kroning (2003) Risk Analysis of Ice Throw from

Wind Turbines, paper presented at BOREAS, 2003

Wahl, Giguere (2006), Ice Shedding and Ice Throw – Risk and Mitigation,

by GE Energy (the manufacturer of the turbines proposed for the Arran

Wind Energy Project)

Morgan, Bossanyi (1996) Wind Turbine Icing and Public Safety – A

Quantifiable Risk? (early work from the Wind Energy Production in Cold

Climates) – The text refers to a report by Morgan et al of 1998, but does

not list the reference.

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Garrad Hassan Canada (2007) Recommendations for Risk Assessments of

Ice Throw and Blade Failures in Ontario (prepared for the Canadian Wind

Energy Association.)

Using these references, the Golder Report comes to conclusion without showing

the justification, that states, “the turbines have a minimum setback from sensitive

Points of Reception of no less than 550 m and 60 m from roads, which

considerably reduces the risk of injury from ice throw or falling ice.”

Please provide a detailed assessment for the justification that a setback of 60

metres from roads considerably reduces risk of injury from ice throw or

falling ice. This request is made since the cited references show a different story:

Wahl, Giguere “Ice Shedding and Ice Throw” the recommendation of the

manufacturer states categorically, “GE suggests that the following actions,

which are based on recognized industry practices, be considered when

siting turbines to mitigate risk for ice prone project locations.” It goes on,

“Locating turbines a safe distance from any occupied structure, road, or

public use area. Some consultant groups have the capability to provide

risk-assessment based on site specific conditions that will lead to

suggestions for turbine locations, in the absence of such as assessment,

other guidelines may be used. Wind Energy Production in Cold Climates

provides the following formula for calculating a safe distance, 1.5 x (hub

height + rotor diameter). While this guideline is recommended by the

certifying agency Germanischer Lloyd as well as the Deutsches

Windenergie- Institut (DEWI), it should be noted that the actual distance

is dependant upon turbine dimensions, rotational speed and many other

potential factors.”

The referenced paper by Seifert, also shows the same simplified formula

of 1.5 x (hub height + rotor diameter) and concludes “as a general

recommendation, it can be stated that wind farm developers should be

very careful at ice endangered sites in the planning phase and take ice

throw into account as a general issue.”

The referenced paper by Garrad Hassan shows that at the Bruce

Information Centre, located in the same climatic region as the proposed

wind energy project, during monitoring during early operation of the

demonstration Tacke TW600 wind turbine, with a 50 metre tower and 21

metre blades, icing of the turbine blades was detected on at least 13

occasions over a survey period from 1995 to 2001, with pieces of ice up to

12 inches by 2 inches by 2 inches found at a distance of up to 100 metres

from the turbine base, and pieces up to 5 inches by 2 inches by 2 inches

scattered up to 100 metres from the tower on another occasion, when it

was estimated that 1 ton of ice was found on the ground.

The Garrad Hassan referenced paper also shows that for the generic 2 MW

turbine, with an 80 metre hub height and an 80 metre rotor diameter (a

blade tip height of 120 metres) “From these results it would appear that

there is a critical distance of approximately 220 metres from a turbine …

the critical distance can effectively be regarded as a safe distance …”

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That calculated 220 metre “safe distance” is comparable to the 1.5 x (hub

height + rotor diameter) value estimated by the Wind Energy Production

in Cold Climates recommended by the manufacturer, referenced above

which would be 1.5 x (80m + 80 m) = 240 metres.

For the turbines proposed for this case, with a 100 metre hub, and a 100

metre rotor diameter, the estimated “safe distance” would be 1.5 x (100m

+ 100m) = 300 metres. The Golder Associates conclusion that a setback of

60 metres from roads “considerably reduces risk of injury from ice throw

or falling ice” is not consistent with the referenced documents. For Golder

Associates to come to this conclusion rather than openly admitting the

facts shown in the references used is a significant concern.

Figure 1: Ice Throw Distances, Known, Recommended by Manufacturer, and Proposed

Elsewhere, the Golder Report also states the mitigating measure of placing

fencing and/or warning signs. Please explain exactly how will a warning sign

protect the public traveling on the public highway, given that the report shows

that a minimum setback to roads of 60 metres will be used, or how will the sign

protect a non-participating neighbour, for a minimum setback to lot lines of 100

metres? The proposal is increasing the risk on roads or on the property of

neighbours above the risk identified by the references quoted. Following this

criteria of “posting signs” results in the situation shown in Figure 2, where signs

placed alongside a highway warn the public to stay at a distance of greater than

305 metres during potential icing conditions, even though the sign is at the road

setback of 120 metres in that case, or will be at a setback of 60 metres in the case

of the Arran Wind Energy Project.

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Figure 2: Sign on roadside warning road traffic to stay back 305 metres.

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Yet further on, the Golder Report notes the recommendation for deactivating the

turbines when ice accumulation is detected. Figures 3 and 4 show actual examples

on GE turbines in Ontario that this recommendation does not occur consistently.

These photos were taken January 19th

, 2010 in the Melancthon Wind Power

Development. They show a school bus passing down the highway between two

turbines that have ice on the blades. The turbine on the left (T18) is stopped, as

shown by the “furled” blades. The turbine on the right (T22) was still running at

normal speed. No stop signal had been given as the blades are not “furled.” Yet,

figure 4, a close up of the blades of the turbine on the right (T22), shows that the

blades were clearly ice crusted, and further show evidence that some ice had

already fallen from the blades. In yet another example, citizens living on Bruce

Township Concession 8 in the Enbridge Wind Power Development stated that in

the winter past, on a night that icing conditions were occurring (they were having

difficulty driving due to ice accumulation on their car windshield) the turbines

near their home continued running, and in fact were making more noise than they

had ever heard. Ice (or other roughness) on the moving blades produces a

significant change in acoustical noise, a well known fact. It is clear that turbine

deactivation does not occur consistently when icing conditions exist.

Figure 3: A School Bus passing between Melancthon Turbines T18 and T22, Jan. 2010

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Figure 4: Melancthon Turbine T22 in January 2010 – Operating with ice on Blades

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The Golder Report goes on to identify restrictive actions to protect maintenance

staff (not providing public safety protection) that restricts access to a setback

greater than the setback recommended for public safety.

It is incredible that the Golder Report identifies that the 60 metre setback from

roads “considerably reduces risk of injury from ice throw or falling ice” given the

overwhelming evidence that the manufacturer recommends larger setbacks for

public protection, for maintenance staff protection, and evidence that turbines

continue to operate with ice on the blades.

c) Catastrophic Failure

Section 4.9.2.2 of the Golder Report admits that “Any tall structure has the potential

to collapse. There is also a limited potential for blade detachment during severe blade

conditions.” However, the next statement is made without justification, “Although

both of these scenarios are highly unlikely … “ Please provide a detailed

justification for the statement that these scenarios are “highly unlikely”

compared to the probability of accident considered to be acceptable for other

generating system accidents.

Appendix 1 provides a listing of known wind turbine failures in 2008 and

2009 showing at least 35 known cases of accidents resulting in turbine blades

on the ground due to either a tower collapse or a blade loss. The 35+ known

blade failures that resulted in blades on the ground occurred over a world

wind turbine experience exposure of about 160,000 wind turbine years of

experience. It is noted that many countries with numerous wind turbines do

not report turbine failures, such as India or China. However, even assuming

this list constitutes all failures, it is a failure rate of 219 x 10-6 failures per

turbine year of operation.

To the end of 2009, Ontario has seen two incidents in about 1200 turbine

years of operation where portions of a wind turbine blade have fallen to the

ground. One on a GE turbine the Port Burwell Wind Farm reported by A

Channel News in April 2007, and the second also on a GE turbine at Prince

Wind Farm reported by the Sault Star in January 2008. There was also one

blade failure at a wind turbine at Belwood, ON, in Sept 2006 where a failed

600 pound blade traveled 100 metres, which is not counted in these failure

figures. 2 failures in Ontario‟s total 1200 turbine years of experience is a

failure rate of 1700 x 10-6 failures per turbine year, considerably higher than

the world average.

The Golder Report continues, “In the highly unlikely event of structural

collapse or blade detachment, equipment will fall within a very small diameter

due to the weight of the equipment (over six tones for the turbine blades). In

addition, the turbines have been sited away from roads and residences

(minimum distance of 60 metres from roads and 550 metres from noise

receptors).” This statement is not consistent with the referenced reports in the

Golder Report. The Garrad Hassan report acknowledges, “Documented blade

failures and distances were reported in the handbook (Dutch handbook

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covering experience to 2001) with a maximum distance reported for an entire

blade as 150 m and for a blade fragment 500 m.” Similarly, evidence

documented for losses of blades or part blades in 2008 and 2009 (Appendix 1)

show part blades traveling 150 m, 200 m, and up to 500 metres. Given the

conflict between the material in the reference quoted by Golder Associates,

and the evidence of actual failures at a failure rate of up to 1700 x 10-6

failures per turbine year in Ontario, please provide a detailed explanation of

how the Golder Report comes to a conclusion that a 60 metre setback to

roads and a 100 metre setback to lot lines provides public safety

protection. Making statements such as the Golder Report does without

justification is a significant cause for concern when the unjustified statement

is not consistent with either the quoted reference or actual experience

observed.

d) Electric and Magnetic Frequencies

Section 4.9.2.3 of the Golder Report presents arguments that “The generation of

electrical fields from underground transmission lines from the Project will be shielded

by the wire‟s insulation and the surrounding ground but will still generate magnetic

fields.”

However, section 3.4 of the report identifies as a Project Component “34.5 kV

gathering lines, underground on agricultural land “ yet Table 6 of Section

3.5.1.3 identifies “The collection system will be a mixture of approximately

93 km of overhead lines and underground generator lines and will be

constructed using standard utility poles and Aluminum Conductor Steel

Reinforced (ACSR) conductors.” Since the overhead ACSR conductors are air

insulated, it is clear that the statement in section 4.9.2.3 regarding shielding of

the generation of electrical fields will not apply to the collector lines

constructed using standard utility poles.

The Manufacturer‟s literature for the GE 2.5 MW XL wind turbines states

“the electrical system design of the 2.5 MW wind turbine consists of a

permanent magnet generator and full power conversion. In the lower tower

section, the power module efficiently converts the energy from the permanent

magnet generator into power that provides frequency and voltage control

required by transmission system operators.” Field measurements conducted

near the overhead conductors of the General Electric wind turbines of the Port

Burwell Wind Power Development, which also incorporate a power

conversion module, show that this configuration generates a significant radio

frequency interference signal that is carried and transmitted by the collector

lines. For example, the radio frequency interference completely overwhelms

even strong AM radio signals in the standard broadcast band, and show

continuous high noise from below 200 kHz to over 2 MHz.

It is unacceptable that the Golder Report comments on the shielding of

electrical fields from underground collector lines on the agricultural portions

of the project, but is completely silent on shielding of electrical fields on the

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majority of the project where overhead collector lines are proposed to exist, in

particular since the report is silent on the fact that the GE 2.5 MW XL turbines

incorporate a power conversion module, when similar GE 1.5 MW turbines

are shown to produce very high level of Radio Frequency noise from below

200 Hz to over 2 MHz.

Please provide a rationale as to why the Golder Report failed to review

the lack of shielding of electrical fields on the majority of the project

overhead collection lines, and the radio frequency interference shown to

overwhelm broadcast communication frequencies, in contravention of

Industry Canada regulations.

The report summarizes that “Levels of EMF from all Project components will

be significantly below this voluntary provincial guideline (of 3 kV/m in

Ontario). Please provide an assessment of what is meant by the term

“significantly below this voluntary provincial guideline” in particular for

members of the public with homes adjacent to the overhead 34.5 kV

collector lines.

e) Shadow Flicker

Section 4.9.2.4 of the Golder Report discusses “shadow flicker” and makes the

statement “The closest receptor to the turbines is located no closer than approximately

550 m in the project area, therefore the effects of shadow flicker would be

negligible.”

Please provide an assessment of what is meant by saying the effects of

shadow flicker would be negligible. The fact that the Danish Wind Industry

Shadow Plot Calculator shows significant shadow at 550 metres from a

turbine with a 100 m hub height and a 100 m rotor can exist for any sunny day

for every month of the year except June. (See attached printouts in Appendix

2, for the months of June, through December – the first 6 months of the year

will be similar.) Additionally since the turbines will be located at a setback of

as close as 60 metres from roadways, the calculator outputs shows that

shadow flicker at a distance of 60 metres from the tower can exist of hours

every month of the year, impacting drivers on roadways.

f) Wind Turbine Syndrome and Acoustic Effects

Section 4.9.2.5 of the Golder Report lumps the issues of noise, shadow flicker,

annoyance, and adverse health effects together into one section. The comments I will

provide on this section will principally be focused on the technical aspects of the

question, and the subject of health effects will only be discussed to the extent of

quoting reports of those individuals qualified to comment on that subject.

The Golder Report opens the section with the statement “„Wind Turbine

Syndrome‟ has been identified as symptoms that are the same as those seen in

the general population due to stresses of daily life.” Curiously, this statement

is made without defining either the source of the term “wind turbine

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syndrome” or without making any specific reference to the fact that the term

was extensively described by Dr. Nina Pierpont MD, PhD in the publication

“Wind Turbine Syndrome, A Report on a Natural Experiment” (available

from Amazon.com) published in 2009. The book notes review comments by:

Robert M. May, PhD, President of the Royal Society (2000-

05), Chief Scientific Advisor to the United Kingdom

government (1995-2000).

F. Owen Black, MD, FACS, Senior Scientist and Director of

Neuro-Otology Research, Legacy Health System, Portland,

Oregon.

Christopher Hanning, MD, FRCA, MRCS, LRCP. Recently

Retired Director of the Sleep Clinic and Laboratory at

Leicester General Hospital, one of the largest sleep disorder

clinics in the United Kingdom.

Robert Y, McMurtry, MD, FRS (C), FACS. Former Dean of

Medicine and Dentistry at the Schulich School of Medicine and

Dentistry, University of Western Ontario.

Please explain the clinical reviews that Golder Associates used to

identify that the cluster of symptoms identified by Dr. Pierpont

which appeared when the individual was first exposed to wind

turbines, which disappear if the person leaves the environment of

the wind turbines, and which reappear when the person is re-

exposed to wind turbines are the same as those seen in the general

population due to stresses of daily life?

The Golder Report quotes from the literature review conducted by the

AWEA / CANEA Panel which did not actually investigate by speaking

to any of the individuals reporting adverse effects. It is thought

provoking that by choosing to not actually speak to any of the

individuals who are reporting adverse effects, the panel were able to

conclude “there is no evidence that the audible or sub-audible sounds

emitted by wind turbines have any direct adverse physiological

effects.” At the same time, researchers like Dr. Nina Pierpont, Dr.

Amanda Harry, and Dr. Michael Nissenbaum have each concluded

after examination or interview of individuals who reported adverse

effects after they were exposed to wind turbines that these was a link.

The Golder Report quotes from the CANWEA / AWEA Panel report,

that “The sounds emitted by wind turbines are not unique.” However

the Golder Report fails to reference the HGC Engineering Document,

“Wind Turbines and Sound” Review and Best Practice Guidelines”

prepared for CANWEA, which identifies, “The frequency content (or

spectrum) is the property we perceive as pitch, which gives a sound its

unique character.” That report goes on to note, “The character of a

sound (does it buzz, rattle, hum, whine, swoosh or thump) can also

significantly affect the audibility and potential annoyance.”

What we find is one CANWEA report stating that the sound from

wind turbines is not unique, while another CANWEA report identifies

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that the factors of a sound (such as „swoosh‟) which can “significantly

affect the audibility and potential annoyance” and give the sound its

unique character.

Similarly reports such as the “Environmental Noise Assessment for the

Pubnico Point Wind Farm” prepared by HGC Engineering for

NRCanada repeatedly describes the “characteristic” sound that wind

turbines make as on page 15 which begins, “In summary, the

measurements and observations can be described as having the

characteristic „swoosh‟ sound typical of wind turbine generators.”

Elsewhere the same HGC Report states, “The „swoosh‟ makes

identification of the wind turbine sound fairly easy,” suggesting that

they certainly are “characteristic.”

Figures 5 and 6 on the next 2 pages compare the frequency content (or

spectrum) of the sound levels outside homes in a similar environment

of Bruce County located near to wind turbines, and distant from wind

turbines. By comparison, a number of observations can be made.

Sound levels at frequencies of 150 Hz and less (generally

considered as low frequency) are between 10 to 30 dB higher

at the home near turbines (as turbines go from very low power

to high power).

Even at about 250 Hz (“middle C” on a piano is 256 Hz ) on

the same night, with the same ambient wind conditions, and

turbines at a moderate power level of about 25% the sound

level at the home near wind turbines is about 17 dB higher than

the sound level at the home distant from wind turbines.

The low frequency sound level at the home over 5000 metres

from wind turbines increases as the turbines increase in output

above the value measured when turbines are at low power.

Sound levels at higher frequencies of about 8000 Hz are similar

near and distant to turbines, as high frequencies are more

attenuated in propagation through the atmosphere than low

frequencies.

While the CANWEA/AWEA Panel report states that sounds

from wind turbines are “not unique,” the measurements show

that the sound levels at homes near wind turbines are distinctly

different as the low frequency sound levels are remarkably

higher.

The charts of sound level and frequency do not show the

characteristic cyclical repetitive “swoosh” heard near the

turbines, which is recognized even by the HGC Engineering

Best Practices for Wind Turbines prepared for CANWEA as,

which can “significantly affect the audibility and potential

annoyance.”

Considering the facts presented, would Golder Associates please

comment on their choice of the statement “the sounds emitted by

wind turbines are not unique?”

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Figure 5: Sound levels outside homes distant from (top) and near to (bottom) wind turbines.

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Figure 6: Sound levels on log scale (top) and low frequency linear scale (bottom)

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The Golder Report makes several statements regarding annoyance from wind

turbines attributed to studies by Pedersen et al, relating annoyance to noise and

shadow flicker, and concludes that shadow flicker is not of concern. This

conclusion fails to accurately extract from the Pedersen “annoyance” works that

show repeatedly that three factors are in play, noise, flicker, and the constant

movement of the blades. For example quoting from the Pedersen, Hallberg, Waye

report “Living in the vicinity of wind turbines – a grounded theory study”

published in the Journal Qualitative Research in Psychology ,“The informants

were, to different extents, affected by the swishing noise, flickering light, and

constant movement of the turbines‟ rotor blades.” Would Golder Associates

please explain why they chose to report only on noise and shadow flicker,

excluding the issue of the constant motion of the turbines’ rotor blades, since

clearly the annoyance by shadow flicker depends on the relative siting of the

turbine and the observer’s position relative to the sun’s position in the sky. Making conclusions based on only partial information is a concern.

Considering that the Golder Report refers to 3 papers by Dr. Eja Pedersen, (the

reference list actually double lists one paper) and 1 paper by Dr. Kristen Persson-

Waye all on the subject of annoyance from wind turbines, it is indeed curious that

the Golder Report chooses as it‟s “bottom line” for a long paragraph beginning

“attitudes toward the visual impact of the turbines were related to the level of

annoyance reported,” to quote from an early 2003 paper, “there is no scientific

evidence that noise at levels created by wind turbines could cause health

problems other than annoyance.”

o This was a curious choice, since anything beyond a cursory inspection of

the other referenced reports, would have found that the 2007 quoted report

includes statements such as “Compared to other sources of community

noise such as road traffic, where respondents were seldom annoyed at A-

weighted sound pressure levels below 40-45 dB, many respondents in this

study unexpectedly reported annoyance with wind turbine noise at A-

weighted sound pressure levels below 40 dB. For example, 20% of 40

respondents living in an area exposed to noise of 37.5 to 40 dBA stated

that they were „very annoyed‟ by the wind turbine noise on a five-point

scale, ranging from „do not notice; to very annoyed‟” The report went on

to note that because of the small sample size – since few people were

actually exposed to that level of noise, the 95% confidence interval was

fairly large. The Arran Wind Power Project may expose more people to

sound levels above 37.5 dBA just by itself, compared to all the individuals

surveyed in Sweden.

o The 2007 quoted report recognized that wind turbines were unique, in that

the noise is a relatively continuous condition in the environment, and went

on, “The sound from wind turbines is amplitude-modulated, which means

that the sound varies rhythmically in intensity with the rotor blade

movement. Wind turbines are typically placed in a rural environment with

low background sound pressure levels. They are also very large objects,

which impact on the landscape. All of these facts make wind turbines

atypical objects.”

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o The report did not dismiss the fact that wind turbines created annoyance,

and thus might impact health effects, and the penultimate paragraph in the

report begins, “Little is known of the long-term consequences on health of

low-level ambient stressors, such as those described in this study.” The

last line of the conclusions notes, “Future studies should concentrate on

how further wind power developments do not intrude into peoples living

environment and lead to unnecessary adverse effects.”

Had the Golder Associates study progressed beyond their conclusion of the “no

scientific evidence” line, they would have found that the Doctoral Dissertation for

Dr. Pedersen, titled “Human Response to Wind Turbine Noise” from 2007 begins

in its introduction to state, “The probability of adverse reactions to wind turbine

noise in relation to noise levels, with all it’s implications, should carefully be

taken into account in the planning process.” In the conclusion of that document,

Dr. Pedersen states, “In this work, wind turbine noise induced annoyance at

SPLs below those known to be annoying for other sources of community noise,

The noise was easily perceived due to the special sound character but probably

also due to the moving rotor blades demanding visual attention, making it

difficult to ignore the noise. The audible and visual exposure from wind turbines

was experienced as an intrusion of the private sphere and therefore evoked severe

reactions, among them noise annoyance, The results indicate that wind turbine

noise could reduce possibilities of psychophysical restoration, and adverse effects

on health and well-being can therefore not be excluded.”

A review beyond the conclusion chosen by Golder Associates in their report

would have found that while the researchers were unable to “put a finger” on

exactly how all of the special characteristics of wind turbines interact to produce

annoyance, adverse reactions, and possible adverse effects on health and well-

being, they do not dismiss the cluster of effects as trivial.

Considering the more recent evidence available from the same researcher,

Dr. Eja Pedersen, calling for more study since “adverse effects on health and

well-being can therefore not be excluded”, please comment on why the Golder

Associates report chose to use as it’s “bottom line” words from this

researcher documented 7 years ago that there was no evidence that wind

turbines could cause health problems other than annoyance.

The Golder Report chooses to state, “An independent review report prepared from

the Ontario Ministry of the Environment found the noise associated with the wind

farms does not contain significant LFN and/or infrasonic components.” A search

of the entire “Wind Turbine Facilities Issues Report” prepared for the Ontario

Ministry of the Environment, (Ramakrishnan, 2007) shows that nowhere are the

terms “LFN and or infrasonic” used. Nowhere can any statement be found that

wind farms do not contain significant low frequency noise and/or infrasonic

sound. Since the independent review report appears to have made no

statement that wind farms do not contain significant LFN and/or infrasonic

components, and that report was made without actually doing any

measurements, in light of the information regarding low frequency noise

differences near and far from wind turbines shown on the previous pages,

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would Golder Associates please provide specific references for the statement

in your report?

The Golder Report chooses to note from the discussion paper published by

Leventhall in the journal Canadian Acoustics “that modern wind turbines are

associated with insignificant levels of infrasound and low levels of LFN under

normal conditions,” yet fails to accurately note the key point of that report about

the cyclic sound from wind turbines, since quoting from the abstract of that paper,

“Statements on infrasound from objectors are considered and it is shown how

these may have caused avoidable distress to residents near wind turbines and also

diverted attention from the main noise source, which is the repeating sound of

the blades interacting with the tower. This is the noise which requires attention,

both to reduce it and to develop optimum assessment methods.” Will Golder

Associates please explain why the material extracted from the paper by

Leventhall failed to even mention what Leventhall describes as the main

noise source? It is a concern when the Golder Report fails to even mention the

main point in quoted reports.

The Golder Report makes the statement, “High levels of LFN and/or infrasound

may cause physiological health effects, but to-date, there has been no definitive

proof in peer-reviewed journals or information provided by governments that

indicates high levels of LFN and/or infrasound can be associated with wind farms.

Epidemiological studies, in conjunction with acoustic studies, would be necessary

to definitely confirm a link between these physiological effects and wind farms.”

This is a very interesting statement, in that while it states the link between LFN

and health effects, it questions the link between LFN and wind farms. In light of

the information provided on the previous pages showing the increase in low

frequency noise at homes near wind turbines, would Golder Associates please

comment on the apparent conclusion that your statement would lead to?

As a logical progression, would Golder Associates please comment on the

request for an epidemiological study, which has repeatedly been made by

medical doctors, and the desirability to proceed with development of more

wind power developments before such a study is conducted? Such a request

was made by Dr. Robert McMurtry to the Standing Committee of the Ontario

Legislature where he stated, “Authoritative guidelines must be developed, and the

only way to do that is a well designed epidemiological study conducted by arm‟s

length investigators, mutually agreeable to all sides. That must be done – as well

as check for low frequency noise. In the meantime, let us listen to and help the

victims. Anything else would be an abandonment of responsibility by the

government.”

Summary of Questions to Golder Associates, re the Arran Wind Project Description:

1. The Golder Report states categorically, “Through adherence with to MOE Noise

Guidelines, operations-related noise that may be perceived to nearby residents

will not represent a significant adverse effect.” Will Golder Associates please

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provide a detailed justification of their statement? Neither the MOE “Noise

Guidelines for Wind Farms” (October 2008) nor the Project Description

demonstrate any evidence to prove that an A-weighted sound level limit for the

cyclical sound of a wind turbine which has a significant low frequency component

(as found at other Ontario wind power developments) “will not represent a

significant adverse effect.”

2. Will Golder Associates please ensure the “details” of the Wind Energy

Project are actually provided?

3. Please provide a detailed assessment for the justification that a setback of 60

metres from roads considerably reduces risk of injury from ice throw or

falling ice.

4. Please provide a detailed justification for the statement that these scenarios

are “highly unlikely” compared to the probability of accident considered to

be acceptable for other generating system accidents.

5. Please provide a detailed explanation of how the Golder Report comes to a

conclusion that a 60 metre setback to roads and a 100 metre setback to lot

lines provide public safety protection.

6. Please provide a rationale as to why the Golder Report failed to review the

lack of shielding of electrical fields on the majority of the project overhead

collection lines, and the radio frequency interference shown to overwhelm

broadcast communication frequencies, in contravention of Industry Canada

regulations.

7. Please provide an assessment of what is meant by the term “significantly

below this voluntary provincial guideline” in particular for members of the

public with homes adjacent to the overhead 34.5 kV collector lines.

8. Please provide an assessment of what is meant by saying the effects of

shadow flicker would be negligible.

9. Please explain the clinical reviews that Golder Associates used to identify

that the cluster of symptoms identified by Dr. Pierpont which appeared when

the individual was first exposed to wind turbines, which disappear if the

person leaves the environment of the wind turbines, and which reappear

when the person is re-exposed to wind turbines are the same as those seen in

the general population due to stresses of daily life?

10. Considering the facts presented, would Golder Associates please comment on

their choice of the statement “the sounds emitted by wind turbines are not

unique”?

11. Would Golder Associates please explain why they chose to report only on

noise and shadow flicker, excluding the issue of the constant motion of the

turbines’ rotor blades, since clearly the annoyance by shadow flicker

depends on the relative siting of the turbine and the observer’s position

relative to the sun’s position in the sky?

12. Considering the more recent evidence available from the same researcher,

Dr. Eja Pedersen, calling for more study since “adverse effects on health and

well-being can therefore not be excluded”, please comment on why the Golder

Associates report chose to use as it’s “bottom line” words from this

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researcher documented 7 years ago that there was no evidence that wind

turbines could cause health problems other than annoyance.

13. Since the independent review report appears to have made no statement that

wind farms do not contain significant LFN and/or infrasonic components,

and that report was made without actually doing any measurements, in light

of the information shown regarding low frequency noise differences near and

far from wind turbines shown on the previous pages, would Golder

Associates please provide specific references for the statement in your

report?

14. Will Golder Associates please explain why the material extracted from the

paper by Leventhall failed to even mention what Leventhall describes as the

main noise source? 15. The Golder Report states, “High levels of LFN and/or infrasound may cause

physiological health effects, but to-date, there has been no definitive proof in

peer-reviewed journals or information provided by governments that indicates

high levels of LFN and/or infrasound can be associated with wind farms.” In light

of the information provided showing the increase in low frequency noise at

homes near wind turbines, would Golder Associates please comment on the

apparent conclusion that your statement would lead to?

16. Would Golder Associates please comment on the request for an

epidemiological study, which has repeatedly been made by medical doctors,

and the desirability to proceed with development of more wind power

developments before such a study is conducted? Your report states,

“Epidemiological studies, in conjunction with acoustic studies, would be

necessary to definitely confirm a link between these physiological effects and

wind farms.”

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Appendix 1

Known Industrial Size Turbine Failures – Resulting in Blades on the Ground

Jan2008 to Dec 2009 (24 month period)

List Compiled From Public Records

Dec. 2009, all blades are removed from 25 Gamesa 2 MW turbines in the

Kumeyaay Wind Project due to damage. Photos show one-third to one-half of

some blades lost. California USA (counted as only 1 failure due to lack of detail.)

Dec 2009, 1.5 MW GE wind turbine in New York State (Fenner Wind Farm)

collapses after loss of power. Cause under investigation. USA.

Nov 2009, 2.1 MW Suzlon wind turbine at Siif Energies Praia Formosa

development “exploded” loosing a blade, Brazil.

Nov 2009, 1.5 MW turbine at Acciona – Aibar Wind Development, nacelle,

blades, and top third of prototype concrete tower collapse, Spain.

Nov 2009, Vestas V47 turbine failure one blade lands on path used by hikers,

(Falkenberg) Sweden.

Nov 2009, Wincon turbine in Denmark (Esbjerg) – defective axle causes all

blades of 40 m high turbine to come loose, one hit a power transformer – article

notes that since 2000, Denmark has had 27 incidents of wind turbines loosing

blades,

Oct 2009, Vestas V90 turbine failure, braking fails in winds of 30 metres/sec,

Sweden.

Sept 2009, blade failure, second in 15 months, 56 m turbine, Sheffield U, UK.

July 2009, GE 1.5 MW turbine looses blade after lightning strike, Montana, USA.

Jul 2009, Vestas V80 turbine looses blade after lightning strike, broken blade

parts travel 150 metres, Germany.

Jun 2009, GE 1.5 MW turbine blade failure following lightning strike, MO, USA.

May 2009, Wind turbine blade falls off and onto highway A6, Lelystad, the

Netherlands.

May 2009, Vestas turbine overspeeds and collapses, North Palm Springs, CA,

USA.

April 2009, wind turbine failure, and collapse, CA, USA.

Mar 2009, GE 1.5 MW turbine blade failure in Illinois, USA.

Mar 2009, GE 1.5 MW turbine collapses at Noble Environmental NY State site

when blades spin out of control, USA.

Feb 2009, turbine collapses at Waverly Idaho when under construction as blades

spin out of control, USA.

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Jan 2009, Enercon turbine looses one 20 m blade (bolt failure) and second blade

damaged, UK.

Dec 2008, Vestas V90 turbine blade damage - pieces travel to home 490 m away,

PEI, Canada

Oct 2008, 42 m long blade breaks off turbine, Illinois, US.

Oct 2008, turbine blade contacts tower, buckles it, collapses VT, US.

Jun 2008, blade failure, 2 months after in service, 56 m turbine, Sheffield U, UK.

May 2008, blade failure Vestas V47 turbine - full 23 m long blade broke off,

passes over road, the Netherlands.

May 2008, Suzlon turbine fire, blades come off in fire. Minn, USA.

Apr 2008, 2 turbines each loose 37 m long blades in storm, Japan.

Mar 2008, 10 metre section breaks off wind turbine blade, flies 200 metres, Italy.

Mar 2008, Lagerway turbine collapse, the Netherlands.

Feb 2008, Vestas turbine looses blade - travels 100 m, Denmark.

Feb 2008, (another) Vestas turbine blades contact tower, tower collapses, blade

pieces travel up to 500 m Denmark.

Feb 2008, Nordex turbine blade failure Norway.

Feb 2008, Vestas turbine looses blade, travels 40 metres – Sweden.

Feb 2008, turbine collapse, Island of Texel, Northern the Netherlands.

Jan 2008, GE 1.5 MW blade failure in winter storm - Prince Wind Farm, ON,

Canada.

Jan 2008, Vestas turbine collapses, Cumbria, UK.

This list does not tabulate turbine fires in the same period, unless they resulted in blades

falling to the ground. Tabulated fault data shows at least 15 wind turbine fires have

occurred in the same period, which can result in falling burning fiberglass and oils.

The 35+ known blade failures that resulted in blades on the ground occurred over a world

wind turbine experience exposure of about 160,000 wind turbine years of experience. It is

noted that many countries with numerous wind turbines do not report turbine failures,

such as India or China. However, even assuming this list constitutes all failures, it is a

failure rate of 219 x 10-6 failures per turbine year of operation.

Ontario has seen two incidents in about 1200 turbine years of operation in this period

where portions of a wind turbine blade have fallen to the ground. One on a GE turbine

the Port Burwell Wind Farm reported by A Channel News in April 2007, and the second

also on a GE turbine at Prince Wind Farm reported by the Sault Star in January 2008.

There was also one blade failure at a wind turbine at Belwood, ON, in Sept 2006 where a

failed 600 pound blade traveled 100 metres, which is not counted in these failure figures.

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2 failures in Ontario‟s total 1200 turbine years of experience is a failure rate of 1700 x

10-6 failures per turbine year, considerably higher than the world average.

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Appendix 2

Shadow Flicker for June 21 through Dec 21 for a plot 1100 metres by 1100 metres.

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