House of Lords - Economic Affairs

The Economics of Renewable Energy - Economic Affairs Committee Contents

Memorandum by Mr Peter Hadden

SUMMARY

This Paper considers the economics of renewable energy in the context of rural communities and the potential violation of their Human Rights as a result of current BERR policy.

For the past two decades, the UK energy policy has basked in the security provided by North Sea oil and gas, and the security of electricity supplied from nuclear, coal and North Sea gas-fired power stations. Only recently has the Energy Minister appeared to realise that the flow of North Sea oil and gas will decline, that ageing nuclear power stations will start to shut down, that coal burning is incompatible with Kyoto. Our cities and towns and villages, our hospitals and schools and homes and industries and farms and transportation—the UK's entire economy relies upon a reliable, predictable, and secure flow of electricity.

Global warming has come to the rescue of the Energy Minister by emphasising the need to reduce carbon emissions, which has coincided with the `off the shelf' availability of wind turbines. The Energy Minister has embraced the wind turbine as the saviour of UK energy needs and has invested the weight of BERR in support of wind turbines, irrespective of the cost to rural communities and families. Enlisting the direct help of the wind turbine industry, Environmental and Planning laws have been re-engineered to smooth the passage of industrial wind energy schemes through the Planning system. Indeed, Minister John Healey has said that some of the changes proposed by Infrastructure Planning Commission are intended to ease the Planning approval of onshore industrial wind turbine arrays.

Other submissions to the Select Committee will show that wind energy does not provide the reliable and secure flow of electricity vital to the economic wealth of the UK. This Paper provides a focus on the public awareness of the lengths the Energy Minister has gone to circumvent informed public opinion, community objection and the human suffering of families when wind turbines are built too close to their homes. This is a single-minded drive to achieve visually an answer to the renewable energy quota, but failing to provide the vital need for a reliable and secure flow of electricity to our economic infrastructure. Another uneasy result includes the erosion of the economic security of the UK, and City of London Investment Houses are asking when the power cuts will start. However, this Paper focuses on rural communities and identifies why they adamantly object to industrial wind turbines when built too close to homes.

RESPONSE TO CALL FOR EVIDENCE: ISSUE NO 6

— How do the external costs of renewable generation of electricity—such as concerns in many affected rural areas that wind farms and extra pylons spoil areas of natural beauty—compare with those of fossil fuels and nuclear power?

— How should these be measured and compared?

— Is the planning system striking the right balance between all the different considerations?

INTRODUCTION

The concerns of rural communities against onshore wind power are expressed in the large number of objections raised by communities when a wind array is proposed in their locality, close to family homes. The planning system identifies the need to strike the right balance but Government Planning Guidance is heavily weighted in favour of wind energy development and therefore fails to strike the right balance. The cost to rural areas of Government's failure to protect basic Human Rights of the family has resulted in a serious erosion of civil liberties and confiscation of family wealth.

The primary reasons for local objection to wind turbine developments are:

A. noise from the turbines and their potential serious health impact on family life;

B. material financial loss to a family's lifetime savings held in their home;

C. economic impact on the community; and

D. perceived disregard by Government and its Agencies, for the opinion of rural communities.

A. NOISE FROM THE TURBINES AND THE POTENTIAL SERIOUS HEALTH IMPACT ON FAMILY LIFE

1. During the past few years, reports of wind turbine noise and its adverse health impacts have emerged internationally as more and larger wind turbines are built as close as 400 meters to homes. Clinical evidence is recent and medical research just beginning to address this specific issue. However, there is evidence in the following documents:

(a) The French National Academy of Medicine, March 2006;

(b) "Wind turbine Syndrome", Dr Nina Pierpont, USA, 2006-08;

(d) A preliminary study: "Respiratory pathology in vibroacoustic disease", Prof N Castelo Branco, et al, Portugal, 2007; and

(e) A review: "Noise Radiation from wind turbines installed near homes: effects on health", Section 5, Health effects, Frey & Hadden, USA & UK, 2007.

2. The noise guidance for developers of wind arrays is provided by the Dti (now BERR) in the form of "ETSU R 97". This document was drawn up in 1996 under the Chairmanship of the Dti, which convened a Noise Working Group (NWG) to investigate a group of small wind turbine arrays that were creating noise problems to those living nearby. This NWG produced ETSU R 97—The Assessment and Rating of Noise from Wind Farms, Sept. 1996—a document providing information and advice to developers and planners on the environmental assessment of noise from wind turbines. The NWG membership was weighted in favour of representation from the wind turbine industry, largely acousticians and engineers. However, there is no evidence that qualified medical or epidemiological experts were consulted to offer guidance on how the technical acoustic data might translate into any adverse impact on human health.

3. In 1996 existing wind arrays in Cornwall and Wales were between 49-59 metres high and 0.4-0.6 mw installed capacity. Today's proposed wind arrays are 120+ metres high and 2+ megawatts installed capacity. Among its recommendations, the NWG stated that ETSU R 97 might need revisiting and recommended revision within two years, with reviews at regular intervals because of changes in wind turbine technology. There is no evidence to show that the Dti revisited ETSU R 97 despite wind turbines and schemes becoming dramatically larger than those on which ETSU had been based, and despite the newer World Health Organisation Guidelines for Community Noise 1999 being materially updated, and despite Parliament enacting the Human Rights Act 1998.

4. ETSU R 97 states:

without placing unreasonable restrictions on wind farm development or adding unduly to the costs and administration burdens on wind farm developers and local authorities

ETSU-R-97 continues:

recommendation

This would be unduly restrictive on developments

5. In 2004 Planning Policy Statement 22 (PPS22), "Noise" was introduced by the ODPM, and section 22, states that "The 1997 report by ETSU R 97 for the Dti should be used to assess and rate noise from wind energy developments". Planning Officers and Inspectors at Planning Appeals feel an obligation to consider noise only under ETSU R 97.

6. There is material evidence available to show that ETSU R 97 has failed to provide a reasonable level of protection to family homes from unbearable noise pollution where wind turbines are located too close to homes. Symptoms include sleep disturbances and deprivation, sometimes so severe that families are forced to evacuate their homes in order to stabilise well-being and to resume normal family life. This is a worldwide phenomenon where wind turbines are located too close to homes.

7. An example of this in the UK is the Davis family, who presented evidence of their plight to the Second International Meeting on Wind Turbine Noise [Lyon, France, September 2007]: "Living with amplitude modulation, lower frequency emissions and sleep deprivation". On 29 May 2007, the Lincolnshire Free Press reported: "A family whose lives have been blighted by wind turbine noise have abandoned their ... home". Mrs J Davis has indicated that the acousticians "Hayes McKenzie", who were on the original NWG that prepared ETSU R 97 and who consult extensively in advising wind turbine developers, visited the home of Mrs Davis. After measuring the noise, Hayes McKenzie reported that the scheme complied with ETSU R 97, and therefore the Planning Condition on noise levels was satisfied. The Commission for Local Administration in England [17 March 2008], commented to Mrs Davis, "It is not possible to establish definitively whether a breach has taken place because no background checks were taken at your property. In order to measure background levels now, a shut down would be required. While ETSU R 97 contains the methodology for what should be done in the event of a complaint it does not give the Council any powers to impose a shut down".

The Davis family appear to be without redress. Ironically, the Davis family supported the landowner and developer's wind turbine application, as they believe in renewable energy and accepted the developer's assurances that noise would not be problematic.

Additional reports on family suffering can be found in section 3 of "Noise Radiation from wind turbines installed near homes: effects on health", (Frey & Hadden). This document also reviews medical research that establishes links between noise and its adverse impacts on health. [see www.windturbinenoisehealthhumanrights.com].

8. The character of the noise is not the hum that is experienced by those living near a busy road or motorway. It is not the intermittent, every 1.5 minutes interruption for a period each day of an aeroplane landing at Heathrow airport. The noise from a wind turbine array is very different: It has a pulsating character, and it has a low frequency character, which acousticians from the wind industry would have us believe is not a health problem. Yet neurologists, epidemiologists, and the World Health Organisation warn of potential serious medical impacts where low frequency noise is present. The constant throbbing, pulsation, continues to be delivered to the family home within the affected zone, without respite, 24 hours a day for as long as the wind blows above 4 m/s (metres per second). It has been referred to as "a living torture of a family".

9. In 1999, The World Health Organisation published its "Guidelines for Community Noise". These Guidelines incorporated important changes to the previous WHO Guidelines of 1980, 1993, and 1995, particularly in setting maximum noise limits in a bedroom where noise with a pulsating and low frequency character are present. Despite the WHO 1999 Guidelines, ETSU R 97 was not updated to reflect these changes.

An analysis of the inadequacy of ETSU R 97 to protect people when wind turbines are built too close to homes was prepared by NWG member Mr D Bowdler (in "ETSU R 97: Why it is wrong", July 2005).

10. The problem has also been highlighted outside the UK. GP van den Berg, acoustic engineer and member of the WHO Community Noise 1999 working committee, produced a paper, "The beat is getting stronger: the effect of atmospheric stability on low frequency modulated sound of wind turbines" (Journal of Low Frequency Noise & Vibration 2005:24:1-24).

Prof Ffowcs-Williams, Emeritus Professor of Engineering, Cambridge University, one of the UK's leading acoustical experts and an advisor to REF (Renewable Energy Foundation), commented on the van den Berg Paper:

"Van den Berg's paper adds weight to the criticisms frequently offered of the UK regulations covering wind turbine noise, ETSU R 97. The regulations are dated and in other ways inadequate. It is known modern, very tall turbines, do cause problems, and many think the current guidelines fail adequately to protect the public".

11. Following public concern after a published article noted "... that wind turbines at a Cornish wind farm was giving rise to health problems associated with low frequency noise emissions ...", the Dti (now known as BERR) appointed acousticians "Hayes McKenzie" to investigate. In August 2006, the Dti published the Hayes McKenzie report, "The Measurement of Low Frequency Noise at 3 UK Wind Farms". Although the acousticians prepared the report without any apparent or acknowledged contribution by medical or epidemiologic experts, the report for Dti included in its conclusions, [p 66] the following quotation from a WHO Community Noise Report as a summary of its findings:

"Community Noise, WHO `there is no reliable evidence that infrasound below the hearing threshold produce physiological or psychological effects'".

12. This Hayes McKenzie Dti report—issued in 2006—repeats this quotation on pages 2, 10, 46 and 66 of the report. However, this quotation appears in the superseded "WHO Community Noise Paper 1995". The implication is that the H-M/Dti report appears to ignore the World Health Organisation Guidelines for Community Noise published in 1999, which superseded the 1995 document.

This is significant because the WHO Guidelines for Community Noise 1999 clearly states in section 3.8:

"The evidence on low frequency noise is sufficiently strong to warrant immediate concern".

"Health effects due to low frequency components in noise are estimated to be more severe than for community noises in general (Berglund et al 1996)".

And from section 4.4 "WHO Guidelines, 1999, Values":

"It is not enough to characterise the noise environment in terms of noise measures or indices based on energy summation (eg LAeq) because different critical health effects require different description. ... For indoor environments, reverberation time is also an important factor. If the noise includes a large proportion of low frequency components, still lower guideline values should be applied".

The "WHO 1999, Guidelines, Critical health effects" for sleep disturbance, sets a limit of total noise in the bedroom at night at 30dBA, before additional reductions are applied to reflect the presence of LFN and the pulsating character of the noise.

Section 3.8 of WHO 1999, clearly states, "Many acoustical environments consist of sounds from more than one source. For these environments, health effects are associated with the total noise exposure, rather than with the noise from a single source (WHO 1980b). In contrast ETSU R 97 allows noise levels to rise to 5dB(A) above background, to a maximum of 43dB(A) at night.

13. Merely as illustration to show a pulsating noise and the presence of low frequency noise, Appendix 1, first chart, is an acoustic recording of wind turbines taken in the first floor bedroom of the Davis family home. The pulsating character may be readily seen (5 July 2007 measured by Mr M Stigwood, Acoustician and qualified Environmental Health Officer). The second chart illustrates an analysis of low frequency noise from a 1.3 MW wind turbine in 2004 by Dr G Leventhall, Acoustician. The low frequency noise appears between 0Hz-20Hz. Although inaudible to most humans, low frequency noise may still impact a person.

14. The 2006 Hayes McKenzie/Dti Report concluded on page 66 that:

"... infrasound associated with modern wind turbines is not a source which will result in noise levels which may be injurious to health of a wind farm neighbour".

No evidence has been found that the authors of this report have any medical qualifications to make this statement, nor is there any evidence in the report that medical experts were consulted. There is no substantive epidemiological or physiological evidence in the Dti report to support this conclusion.

15. Public concern is reflected in the questions on the issue of wind turbine noise and its adverse impact on health that have been brought to the House of Commons. Referring to Hansard 15 June 2007: column 1418W, House of Commons:

Mr Geoffrey Cox, QC, MP:

To ask the Secretary of State for Trade and Industry pursuant to the answer of 14 May 2007, Official Report, column 1003W, on turbines: health hazards, what qualifications Hayes McKenzie possessed in relation to infrasound emitted by wind turbines; and what role medical experts played in the production of the report. (142509)

Malcolm Wicks:

The Hayes McKenzie report for the Dti "The measurement of Low Frequency Noise at three UK wind farms" investigated the levels of low frequency noise and infrasound emitted by wind turbines, it was not within the remit of the study to undertake new medical analysis.

However, the study did refer to the document prepared for the World Health Organisation "Community Noise", which states that: "there is no reliable evidence that infrasounds below the hearing threshold produce physiological or psychological effects".

It also referenced work undertaken for DEFRA on low frequency noise and its effects. Dr Andrew McKenzie and Malcolm Hayes are acoustic experts with between them over 45 years experience. They have conducted work in relation to wind turbines at over 400 proposed, consented or completed sites in the UK and overseas.

Mr Cox:

To ask the Secretary of State for Trade and Industry what research his Department has carried out on the numbers of individuals and households adversely affected by infrasound emitted by wind turbines (142510).

Malcolm Wicks:

Dti and Defra have recently commissioned a report by Salford University one of the objectives of which is: "to establish the levels and nature of the noise complaints received across the UK relating to noise issues from wind farms, both historic and current, and determine whether Aerodynamic Modulation (AM) is a significant effect".

16. The 2006 Hayes McKenzie Dti report referred to "Amplitude Modulation" (AM) as the underlying noise problem. In August 2006, the NWG recommended that the Dti should commission a further study to better understand the extent and cause of AM. Defra, Dti and DCLG commissioned the study.

17. Dr Andrew Moorhouse and his team at Salford University were instructed to undertake the study with Hayes McKenzie. In April 2007, Ms Zoe Keeton of Dti led the NWG in evaluating the report. At the meeting, Ms Keeton advised the NWG that the Dti had released a statement in November 2006, "Advice on findings of the Hayes McKenzie report on noise arising from Wind Farms". Ms Keeton also reminded the NWG that their role was advisory to Dti, solely to provide expert technical advice and guidance on issues surrounding AM (Amplitude Modulation). The NWG advised the Dti additional work should be undertaken. Ms Keeton advised that a meeting would take place with Defra and DCLG to discuss funding.

18. In July 2007, when Salford University/Hayes McKenzie published their Report, Chris Tomlinson, of the British Wind Energy Association (BWEA) and a member of the NWG, apparently circulated a letter to the members of BWEA thanking Zoe Keeton of Dti (now known as BERR) "for her efforts in driving through the work on this issue with such a great result and a robust Government statement".

NB: In 2002, Ms Keeton joined Npower, but since 2006, Ms Keeton has been on secondment to BERR (Dti), co-ordinating activities to address the planning and aviation issues that hinder wind farm development.

(see http://www.all-energy.co.uk/Biographies_aviation.html)

19. The ETSU 1997 committee was heavily weighted by experts from the wind industry. The report on LFN was prepared by acoustic consultants to the wind industry. The most recent NWG was weighted in favour of experts from the wind industry and indeed led by a person seconded to the Dti from the wind industry. The Salford University/Hayes McKenzie report was influenced by acousticians and engineers from the wind industry.

20. It is reasonable to wonder, in the light of the conflict of interest found by the NAO when it investigated HIPS (Home Information Packs), whether the NAO would find a similar conflict with the BERR appointments.

21. On 2 August 2007, Dick Bowdler, an acoustician and member of the NWG, resigned from the Noise Working Group. This highly unusual step was taken because, as his letter states:

"I have read the Salford Report and the Government Statement. As a result I feel obliged to resign from the Noise Working Group.

The Salford Report says that the aims of this study are to ascertain the prevalence of AM from UK wind farm sites, to try to gain a better understanding of the likely cause, and to establish whether further research into AM is required. This bears little relation to what we asked for which clearly set out in the minutes of the meeting in August 2006. We all knew then (as was recorded in the original notes of the meeting) that complaints concerning wind farm noise are currently the exception rather than the rule. The whole reason for needing the research was that `The trend for larger more sophisticated turbines could lead to an increase in noise from AM'.

It was not the intended purpose of the study to establish whether more research was required. We all agreed at the August 2006 meeting that such research was needed. That was precisely the outcome of the meeting. The prime purpose of what eventually became the Salford Report was to identify up to 10 potential sites which could be used to carry out objective noise measurements. The brief for the Salford report, which was never circulated to the NWG, completely ignored the NWG views.

Additionally, I find it entirely unacceptable that we are not to be told the names of the wind farms listed in the Salford report. So the only part of the report of any value to assist future research is inaccessible to those of us who would like to progress matters further.

Looking at the Government Statement it is clear that the views of the NWG (that research is needed into AM to assist the sustainable design of wind farms in the future) have never been transmitted to government and so the Statement is based on misleading information".

22. The Editor of "Noise Bulletin", where Mr Bowdler's letter appeared, commented:

Noise Bulletin

23. It is important to note that modern wind turbines are controlled by remote computer. It is possible, for example, to remotely slow the revolutions per minute of the blades. In theory, having in mind the field research on noise from wind turbines undertaken on behalf of BERR (Dti) was undertaken by acousticians working in the wind industry, it is quite possible for the wind turbine owners to slow the revolutions when on site noise measurements are taken by any acousticians. There is no evidence that this has happened but in future for the benefit of transparency and data analysis, noise should be measured against wind speed and rpm (revolutions per minute) of the blades. It is the rpm that directly influences the pulsating character of the noise.

24. A House of Commons debate 5 July 2007 (1078-1081) addressed wind turbine noise:

Mr John Whittingdale

"... if he will review the noise limits for onshore wind farms" (147642)

Malcolm Wicks:

We continue to support the approach set out in PPS 22 renewable energy ..."ensure that renewable energy developments have been located and designed in such a way to minimise increases in ambient noise levels" ... I do not consider that a review of that guidance (ETSU R 97) is justified at present.

Mr Whittingdale:

Is the Minister aware of the growing evidence that people who live in close proximity to wind turbines suffer significant risks of adverse health effects? Will he give urgent consideration to increasing the minimum separation distance from large turbines to at least 2 km? ...

Malcolm Wicks:

No, I am not aware of such evidence, and I do not believe it exists. A Government commissioned Hayes McKenzie study published 2006 concluded that there was no evidence of adverse health effects from wind turbines ...

Sir Patrick Cormack:

May I support my hon Friend's general point and ask the Minister whether he will conduct an assessment of the environmental impact of these monstrous things and their effects on our tourism reviews. (HC Deb 5 July c 1085)

25. By encouraging the wind industry to design and set its own standards on an acceptable noise level from wind turbines measured at nearby homes, the BERR (Dti) has legalised, in Town Planning terms, noise levels that can be so disturbing to family life that some families are forced to abandon their homes or suffer sleep deprivation. It has set a standard that might easily be manipulated to the benefits of developers by comparing noise levels with background noise levels, which in most instances are measured by the developers and not checked by Local Councils because of lack of resources. BERR (Dti) has made no efforts to investigate, with independent health researchers and experts, the reported serious health consequences to some families where wind turbines are built too close to homes. Instead, BERR (Dti) has unreasonably asked acousticians to give an opinion on health issues and astoundingly, BERR (Dti) has acted on that opinion.

26. By carefully promoting the development of onshore wind energy as Government Policy and by promulgating wind energy as the vital part of the provision of future UK energy supply and therefore in the national interest, BERR (Dti) has virtually denied families their rights under Article 8 of the Human Rights Act: Article 8 provides:

(A) Everyone has the right to respect for his private and family life, his home and his correspondence.

(B) There shall be no interference by a public authority with the exercise of this right except as in accordance with the law and as necessary in a democratic society in the interests of national security, public safety or the economic well- being of the country, for the prevention of disorder or crime, for the protection of health or morals, or for the protection of the rights and freedom of others.

It is clear that some families, who suffer sleep deprivation and consequent health problems, have had their right to respect for their private and family life violated. However, by setting high levels of allowable noise from wind turbines operating 24/7, Planning permission has been granted because developers have provided assurance that the ETSU R 97 noise guidance would be met.

In a speech to the Human Rights Lawyers Association in London, 29 September 2006, the Lord Chancellor stated: "We in Government will campaign passionately and defiantly for human rights for everyone in Britain. Because we believe it is the foundation of both our security and our prosperity".

27. Clearly, in a desperate effort to ease the Planning process to allow the building of large numbers of industrial wind turbines in well-populated rural communities, BERR (Dti) has had to support excessively high noise level standards in order to squeeze wind turbines close to family homes. There is no evidence BERR has considered the health implications on the families, and no evidence BERR has considered the basic rights of families under Article 8 of the HR Act 1998.

28. It is inspirational that in Dennis & Dennis v M.O.D. (2003) EWHC 793, Mr Justice Buckley found an interference with the convention rights of the claimants whose enjoyment of their home (and its value) was impaired by the noise: "I believe it is implicit in the decision S v France, that the public interest is greater than the individual private interests of Mr and Mrs Dennis but it is not proportionate to pursue or give effect to the public interest without compensation for Mr and Mrs Dennis ... in my view, common fairness demands that where the interests of a minority, let alone an individual, are seriously interfered with because of an overriding public interest, the minority should be compensated".

29. A number of acousticians and health experts have called for a minimum distance of 2km between wind turbines and homes. The wind industry calls foul because it claims such a minimum distance would reduce the number of sites available. It could be argued that if a small number of homes within the 2km zone would stop the site being developed, then it is the recourse of normal property developers (whether commercial or residential) to buy out those homes at market value to allow the scheme to proceed. Another argument is that there are huge land resources offshore that could accommodate all the Government's wind energy aspirations, and that allowing developers to make greater profit margins by developing onshore close to homes on marginal sites at the expense of ordinary families is a violation of basic Human Rights. Allowing wind array developers to make higher profits at the cost of individual families is repugnant and contrary to the stated intention of Parliament to protect basic Human Rights for citizens of the UK.

30. The people of the UK have no confidence in the way the BERR (Dti) has managed the problem of noise from wind turbines. The only way to restore and build confidence is to:

— First, set a 2 kilometre zone on all industrial wind turbine sites where turbines of over 0.6MW and 50 metres high are proposed: No industrial wind turbine should be within 2 kilometres of a dwelling.

— Second, there should be an independent working party of acousticians and medical experts to fully explore the problems of wind turbine noise and the health consequences.

— Third, the NAO should be appointed to ensure that there is independence during the process and that there are no conflicts of interest. The Equality and Human Rights Commission should be appointed to ensure basic Human Rights are respected during the whole process of setting new standards for control of noise and setting new Planning Guidance.

B. MATERIAL FINANCIAL LOSS TO A FAMILY'S LIFETIME SAVINGS HELD IN THEIR HOME

31. For most British families the largest investment they are likely to make in their lifetime is their family home. Many families when reaching retirement will consider downsizing their home to release capital, allowing them to enjoy their later years. An "Englishman's home is his Castle" still applies, and when their lifetime savings are unreasonably taken by actions of the State, families are understandably upset and often without financial recourse.

32. There is substantial evidence from around the world that homes within 2 kilometres of a wind array suffer material loss of value. The greatest decline in value is at circa 500 metres, but the rate of decline decreases out to about 3 kilometres. The UK housing market is a free market dependent upon a willing seller and a willing buyer entering into contract to complete a deal. Usually, the willing buyer has a number of properties to consider within a price range, accommodation size, and geographical location. Because most wind turbine arrays are in countryside locations, an important factor influencing choice is "environment", particularly in terms of noise. The visual aspect from a home is also important in the countryside. A property enjoying a pleasant view in a quiet location is attractive to a prospective purchaser. If a single, slender, radio communication mast 120 metres high and 1.5 kilometres distant is located within that view, there would be a modest reduction in value, but if the property had other strong attributes including a much sought after location, the reduction would be minimal.

33. However, if every time the occupier looked out of the windows, the view was of 120-metre high revolving blades, filling most of the view at a distance of say 1.5 kilometres, the impact on value would be a material decline. Not many families would choose, if alternatives were available, a home where every time a family member looked out a window, their gaze would be captured immediately by "giant mobiles" reaching high into the sky, filling the view. Additionally, if the main rooms of the house faced east, south, or west, a serious problem of flicker will occur on sunny days as the sun's elevation in the sky falls behind the revolving blades of the wind turbines. (Wind turbines, flicker, and photosensitive epilepsy; characterising the flashing that may precipitate seizures and optimizing guidelines to prevent them, Harding et al, Neurosciences Institute, Aston Univ & Dept Psychology Essex Univ, April 2008; and "Evaluation of Environmental Shadow Flicker, Analysis for Dutch Hill wind project", R Bolten, January 2007). The Bolten review also commented on the impact at night by a rising and setting moon, with the flicker from the blades playing on windows while families try to sleep. By far the most serious negative influence on value is the impact of noise, discussed in Section 1 of this Paper.

34. The low frequency noise emitted from a wind turbine delivers a particularly penetrative character, comparable to "sonar". While Acousticians can measure the technical delivery of low frequency noise, it must be for the medical experts to advise on how that delivery impacts on the human torso. An investigation for the MOD by Keele University, (Microseismic & Infrasound Monitoring of LFN & Vibrations from Windfarms) concluded in July 2005, "This analysis allows us to define an exclusion zone of 10 kilometres within which No windfarm/turbine development is acceptable ... Beyond 50 kilometres, we do not anticipate that Any reasonable wind farm development will have an impact on the detection capabilities of Eskdalemuir". While this investigation was considering a very sensitive military ground listening station, it nevertheless provides evidence of the existence of ground vibration within the 2 kilometre zone. Even minute ground vibration will affect the human torso [Appendix 1] (see also Section 5.0 Health Effects, Noise Radiation from wind turbines installed near homes: Effects on health, Frey & Hadden, 2007, www.windturbinenoisehealthhumanrights.com)

35. It is not surprising that a family trying to sleep in a bedroom, with the window slightly open and just a thin layer of slate, roofing felt, thermal insulation and plasterboard, between them and the delivery of pulsations at night, find it difficult to sleep. Few families would choose to buy such a house, and a special purchaser, if one could be found, would clearly demand a substantial reduction on normal open market value.

36. A limited scope study by Oxford Brookes University, which looked at the impact on property values of two early wind arrays in Cornwall, with turbines of about 0.4MW and much lower in height than to-day's giant turbines, found that the thought of turbines made a greater impact on value than when the turbines were in position. However, to-day's giants have a huge impact on value as is evidenced by property experts active in the residential market, for example:

(i) Valuation, April 2008, of "The Farm House", Grays Farm, North Drove, Spalding, Lincs., by Valuers "Munton & Russell";

(ii) Valuation, July 2005, of "... sample of properties inspected near a proposed wind farm at Esgairwen Fawr, Nr Lampeter, by RE/MAX,`The Estate Agency Leaders'", Carmarthen, Wales;

Hansard

(iv) "Noise Radiation from wind turbines installed near homes: Effects on health" (Frey & Hadden, 2007, Appendix—Property Values, P Hadden FRICS).

It is no wonder that families are adamantly opposed to wind turbines being located close to their homes.

C. ECONOMIC IMPACT ON THE COMMUNITY

37. The economic impact of industrial wind turbines on a community is a generally subjective problem, but there are economic ramifications where the area is dependent on tourism and holiday homes to provide employment in an otherwise agricultural community. It is not difficult to produce an opinion poll in the West Country that suggests most people support renewable energy and therefore, wind energy. One only has to walk along the beaches at Newquay, St. Ives, Bude, or Paignton, and holiday visitors will gladly cast their votes. This, though, is a deeper question, vital to an area largely dependent on agriculture to sustain communities. Staying with the West Country, farms are generally small and normally can just sustain the basic family unit. Children often go on to further education and follow careers away from home. Those not so inclined discover that local job opportunities are more difficult to find. An agricultural area will be able to sustain only a small number of contract tractor drivers. Job opportunities are limited and incomes are low. It is difficult for young couples to buy a home in competition with those seeking retirement homes. Villages lose young people who move to towns for employment.

38. It is of vital importance to encourage inland tourism and keep the countryside open to visitors who enjoy holidays, not only at the seaside, but also in quality countryside. Projects including the construction of cycle routes along country lanes and disused railway tracks are popular. Hikers have an abundance of routes that are well charted. As a result, small hotels and holiday cottages have built up repeat clients and farms have diversified into converting barns to holiday cottages. Visitors from towns and cities welcome the opportunity to enjoy short breaks in the countryside, and pensioners find the area attractive for a lifestyle based on rural communities and outdoor activities. Restaurants and Pubs providing quality food have flourished. Shops and the service sector thrive and revitalise towns and villages as a result of the increased trade. These small businesses have provided job opportunities to local people, some working part time, from cleaning, cooking, and serving at tables to working in shops and offices. Builders are provided with work maintaining accommodation and reconstructing old barns. Consequently, the local economy builds upon itself and new investment takes place creating further job opportunities. A countryside, which might have been facing a slow slide into deprivation, has an economic future.

39. One then has to ask what happens when giant 120-metre wind turbines are introduced into the community. The landscape will take on an industrial character, and holiday units near the turbines will suffer the same environmental pollution described previously. Will people return to holiday units that suffer from the pulsating throbbing noise at night, will walkers and cyclists return to an area where the turbines monopolise the views as giant perpetual-motion mobiles in the sky? Pensioners do not rely on the local economy for income, though they support a variety of services, businesses, and trades; with a portable income, pensioners can vote with their feet, removing another building block important to the success of the rural economy.

40. A report produced by the Small Business Council (February 2006) in Recommendation 6 stated, "The effects on the rural economy of onshore wind development should be a material consideration in the determination of the applications for development and should constitute part of the cost benefit analysis ..." Wind array developers argue that their schemes bring prosperity to a community. However, although some short-term jobs are created when construction work takes place, once the turbines are in place, computers hundreds of miles away can control them. Maintenance is normally monitored by an Engineer managing a number of arrays. The landowner may enjoy a large increase in income, but there is no evidence that this money is reinvested in the community.

D. PERCEIVED DISREGARD BY GOVERNMENT AND ITS AGENCIES, FOR THE OPINION OF RURAL COMMUNITIES

41. While Government often pronounce the importance of listening to the people, rural communities feel excluded from this policy when it comes to onshore wind turbine development. A proposal to build an array of nine 2MW wind turbines 120-metres tall in well-populated rolling countryside just east of Okehampton, Devon, was met with strong local opposition and reflected in the local Council's refusal to grant Planning permission. The developers appealed and the local community mounted a strong Rule 6 Party presentation of the community's views supported by nearly 3,000 letters of objection and about 200 letters of support. Objections included noise, negative impact on property values, potential violation of Human Rights, and REF (Renewable Energy Foundation) tabled a well-argued case that wind energy onshore failed to provide the benefits to the national interest that were claimed by developers. The Planning Inspector allowed the Appeal.

42. The community were so opposed to the scheme that they raised nearly £30,000 to take their case to Judicial Review and the Court of Appeal. While it is accepted everyone is entitled to develop their own land, provided it is legal, where a proposal involves huge scale industrialisation of a rural community, producing environmental noise pollution, at questionable benefit to the nation, it is not surprising that the rural community asks whether public consultation is merely a nuisance for Government—a process that has to be seen to be done, with a "rubber stamp" result.

43. Part of the problem is that communities must raise large sums of money to employ experts to argue their case, often to no avail. Any objections on grounds of noise are brushed aside by placing a standard Planning Condition citing noise control under Guidance ETSU R 97.

44. Developers assure residents living near new wind arrays that there will be no noise disturbance from the site, yet in many instances where the present generation of wind turbines are built within 2 kilometres of homes, there is a noise disturbance. The BWEA have issued "Myths" of wind turbine objectors (A rebuttal for seekers of the truth of the BWEA top myths about wind energy) and labelled objectors as Nimbys. This shows a lack of sympathy and understanding for communities of human beings who have genuine and well-researched objections to wind turbines being located too close to their homes. In north Devon, a developer issued an information leaflet stating that their scheme will not have a negative impact on property values. The leaflet was sent to the "Advertising Standards Authority", which replied, "We will ask them to amend their advertising to remove" that statement (Batsworthy Cross).

CONCLUSION

45. Because electricity produced by wind energy fails to meet the key objective of Government energy policy, that is, to provide a reliable and secure flow of electricity, it is not possible to justify allowing wind energy to claim status as being in the national interest. As a result, wind energy schemes should be treated in Town Planning terms, on equal footing with any other proposal to industrialise areas of the countryside. Impact on families, communities, visual intrusion, and landscape degradation would then be considered by decision makers unfettered by the straightjacket of BERR. Ironically, BERR instead promotes permissive considerations in favour of developers.

46. Thus, onshore wind turbines built within 2km of homes offer no benefits and should not be part of a plan to provide the UK with a viable, secure, predictable supply of electricity. Indeed, onshore wind turbines ensure an unpredictable energy supply, by the very nature of the wind, with a long list of adverse impacts that diminish their supposed usefulness. Other renewables, such as solar and hydropower, offer more options and more predictability, especially combined with the still necessary (and technologically advancing) conventional sources of energy.