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NHMRC Draft Information Paper: Evidence on Wind Farms and Human Health submission

ID: 
20
This submission reflects the views of
Organisation Name: 
Department of Environment Regulation (WA)
Please identify the best term to describe the Organisation: 
Government department – State / Territory
Personal Details
Questions
Q1. Is the draft Information Paper presented and written in a manner that is easy to understand?: 

Yes

Q2. Does the draft Information Paper clearly outline how the evidence was reviewed and interpreted by NHMRC?: 

Yes, however the Department of Environment Regulation (DER) wishes to raise some concerns with the accuracy of the conclusions that have been reached. 

Noise emissions from wind farms in WA constitute an emission under the Environmental Protection Act 1986, and are directly regulated under the Environmental Protection (Noise) Regulations 1997.  The Department's interest in this topic is that of a regulatory authority with concern that best practice is applied to the assessment and control of wind farm noise; DER also needs to be in a position to address community concerns about possible health effects from wind farms.  This requires a good understanding of potential health and health-related effects of wind farm noise and as a result, whether precautionary measures may need to be taken.

In section 7.2.2 of the draft Information Paper it is suggested that there is only 'limited evidence' for associations between noise and health conditions such as blood pressure and heart attack.  However a wider review of current literature would indicate that the evidence in relation to blood pressure and heart attack would now be considered to be stronger than 'limited'; see for example the World Health Organisation's 2009 Night Noise Guidelines for Europe, and recent papers by authors such as Wolfgang Babisch.

Section 7.2.2 goes on to state that 'there is no evidence that health or health-related effects from wind turbine noise would be any different to those from other sources at similar levels. Based on the studies referred to above, wind turbines would be unlikely to cause any direct health effects at distances of more than 500 m.'  This conclusion ignores the fact that there is also no evidence that the health effects of wind turbine noise are the same as for transportation sources. 

Furthermore, the experience of regulatory agencies such as DER is that there are significant differences in the noise impacts between transportation noise and continuous industrial noise sources, especially when the latter exhibit characteristics common in wind farms, such as a pulsating time history and significant low frequency energy.  Regulations for industrial noise apply adjustments for the noise character: in Western Australia, those adjustments include tonality, modulation and impulsiveness.  As a result, the regulatory noise levels for industrial noise emissions tend to be set at lower levels than the transportation-based noise levels that indicate health effects. 

It is therefore DER's view that the suggestion that there are no direct health effects from wind farms beyond a distance such as 500m may pose risks to wind farm developers, regulatory authorities and the community, in that wind farm noise levels may well exceed regulatory criteria and may cause significant noise impacts at distances of the order of 500m.

DER would respectfully request that the Reference Group reviews the wording of Section 7.2.2 and related sections of the draft Information Paper with a view to rewording the conclusions in a manner that recognises differences in community responses to industrial and transportation noise, and that takes into account regulatory criteria in Australia.

Q3. Is there additional evidence on any health or health-related effects specifically related to distance from wind turbines or exposure to emissions from wind turbines?: 

Not that the Department of Environment Regulation (DER) is aware of

Q4. Is there additional evidence on the likely level of exposure to emissions produced by wind farms at nearby residences? : 

Not that DER is aware of

Q5. Is there additional evidence on whether it is plausible that noise, shadow flicker and electromagnetic radiation (of the type and at the levels produced by wind farms) might affect healthy functioning of the human body?: 

The following article did not appear to have been included in the systematic review by the University of Adelaide:

Salt, A.N., Kaltenbach, J.A., Infrasound From Wind Turbines Could Affect Humans, Bulletin of Science, Technology and Society 2011 31: 296,

http://bst.sagepub.com/content/31/4/296

The Department comments that it appreciates that the process of the systematic review has been comprehensive, and that it answers a numbers of questions.  However, it notes that there are questions that have not yet been answered in the Draft Information Paper in terms of regulating noise from wind farms.  While it is recognised that these questions go beyond the Terms of Reference for the current work, they are restated here in the interests of retaining a focus on issues relevant to regulatory agences and others (these were included in a letter from the Director General of the (then) Department of Environment and Conservation - now DER - on 30 March 2012):

  1. Is there a plausible mechanism by which low frequency sound or infrasound at levels below the hearing threshold can have an effect on health, such as that suggested by Salt and Kaltenbach?
  2. Is the effect of such an interaction likely to be exacerbated by the presence of pulsations in the low frequency sound or infrasound such as may be encountered with wind farm noise emissions?
  3. How, and to what extent are any such effects likely to manifest themselves in humans?
  4. If there is a significant potential for such health effects, then what form should a ‘precautionary’ approach take in order to ensure that the likelihood of such effects is minimised?

In DER's view, the small number of studies ultimately reviewed for the Draft Information Paper makes the base of the study quite narrow, raising the possibility that some suspect health-effect claims being made in literature not reviewed by the Reference Group will continue unchecked.  DER notes and agrees with the general thrust of the Areas for Further Research in Appendix C, however DER would respectfully request that the Reference Group rethink its response to Item 2(b) of the Terms of Reference in light of the paucity of usable studies, and examine some of the more common claims about health effects using the knowledge gained in this present study, and commenting on their potential veracity.  That may have the effect of removing some of the more radical claims from the debate, and focusing attention on relevant research areas rather than the more general approach outlined in Appendix C. 

Q6. Is there additional evidence of health and health-related effects observed from other sources producing noise, shadow flicker and electromagnetic radiation of the type and at the levels produced by wind farms? : 

DER does not possess data on other noise sources that produce pulsating low frequency noise or infrasound of the type produced by wind farms.

Page reviewed: 11 February, 2015