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 transportationthe 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 electricitysuch as concerns in many affected
rural areas that wind farms and extra pylons spoil areas of natural
beautycompare 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;
(c) "Wind Turbines, Noise & Health"
Dr Amanda Harry, UK, 2007;
(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 97The
Assessment and Rating of Noise from Wind Farms, Sept. 1996a
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:
This document describes a framework for the measurement
of wind farm noise and gives indicative noise levels thought to
offer a reasonable degree of protection to wind farm neighbours,
without placing unreasonable restrictions on wind farm development
or adding unduly to the costs and administration burdens on wind
farm developers and local authorities. (Summary S1).
ETSU-R-97 continues:
The recommendation of the NWG is that,
generally the noise limits should be set relative to the existing
background noise at nearest noise-sensitive properties ... We
have considered whether the low noise limits which this could
imply in particularly quiet areas are appropriate and have concluded
that it is not necessary to use a margin above background approach
in such low-noise environments. This would be unduly restrictive
on developments. (Summary S 11).
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 reportissued
in 2006repeats 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:
"`New report eases concerns over wind turbine
noise' trumpets the Government press release, then saying aerodynamic
modulation is `not an issue for the UK's wind farm fleet'. This
conclusion is not justified based on the report, and by halting
further research work without transparently monitoring the wind
farms subject to complaints will inflame, not ease concern of
objectors ... Only when the public can trust the Government and
wind farm developers on noise issues will there be a chance that
the public will accept them without a fight ..." (Noise
Bulletin, Issue 15, Aug/Sept. 2007 page 5).
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;
(iii) Hansard, House of Commons, written
answer 20457 (13 May 08, column 1442W) John Healey: Details of
the types of local council tax discount that were being awarded:
"Property affected by the proximity of electricity generating
wind turbine"; and
(iv) "Noise Radiation from wind turbines
installed near homes: Effects on health" (Frey & Hadden,
2007, AppendixProperty 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 Governmenta 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.
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