McPherson, Geoff. Writes to ACNC in support of Waubra Foundation

To ACNC Commissioner from Geoff McPherson, Marine Fisheries Acoustic Consultant

There is consistent agreement with all sides of the wind farm debate that human responses such as annoyance, lack of sleep, irritability for instance occurs with some people sited at a distance from Industrial Wind Turbines. What is the point of debate is whether those sorts of symptoms can be called a disease, a syndrome or even ill health in other words a semantic debate but the symptoms remain.

Dear Commissioner Pascoe

I apologise for the rushed nature of these comments relating to the 2014 ACNC decision that the Waubra Foundation was not a Health Promotion Charity. The Cairns region has experienced extremely heavy rain over the past two days, 450 mm in my gauge in the hills behind Cairns, and there have been many at home issues that need urgent attention.

While I make no claim to understand how organisations achieve any form of tax/charity status I do have strong concerns about the basis for the 2014 ACNC decision that the Waubra Foundation was not considered as a Health Promotion Charity primarily on the basis that “there has been no rigorous independent scientific evidence that finds that the ill health complained of is caused by the physiological effects from wind turbines nor that there are human diseases called “wind turbine syndrome” or ‘vibroacoustic disease”.

I wish to comment from two perspectives,

  1. That the ACNC conclusion is totally in error with respect to a claim for an absence of science evidence on Industrial Wind Turbines.
  2. That the tax decision is seemingly inconsistent in that
    • tax benefiting organisations currently operate in Australia funded by large resource / habitat using corporations, with no known education or scientific capability yet have open access to young school children where the material provided is not only selective to suit the industry stance (hence fraudulent) and given the information provided has received criticism from a recent Senate Review into the Great Barrier Reef.
    • yet Waubra Foundation, a non industry funded representative of local communities that offers expertise based information to adult communities on a non profit basis does not achieve any tax benefit.


1. SCIENTIFIC EVIDENCE


ACNC noted
.…. no rigorous independent scientific evidence that finds that the ill health complained of is caused by the physiological effects from wind turbines .

This is not the place to document all the scientific evidence. I do wish to point out that there is a major difference between accessing as much information as is necessary to understand a problem as distinct from making sure the information was not found. In some sectors, including noise from Industrial Wind Turbines, it is referred to as setting Terms Of Reference to be so narrow as to not find anything controversial.

I noted in my Submission to NHMRC on wind farms that the literature review on which the Australian Medical Association based its recommendations was a direct result of a pre-determined null finding as a direct result of using literature search words that were intended not to find the evidence that would demonstrate a link between close sited Industrial Wind Turbines and ill health from a variety of annoyance, stress type impacts.

The Draft NHMRC Review Table 2 Search strategy and criteria for selecting evidence to inform Background included the keywords

  • noise/adverse effects, systematic, noise injury, clinical trial, controlled clinical trial, controlled study, longitudinal study, prospective study, randomised controlled trial, humans and English.

The NHMRC Review Table 3 Search terms to identify evidence to inform the systematic review questions included keywords

  • wind, turbine, farm, tower, energy, technology, energy generating resources, electric power supplies, wind turbine syndrome and wind power.

However, if the NHMRC Review would have been entirely different if it had permitted the inclusion of more expansive keywords namely,

  • medical, psychoacoustic or acoustic type keywords relevant to noise impact from turbine (ie turbines and other sources with the same noise characteristics) impact on definable proportions of the population of close sited humans.and medically relevant
  • Keywords should have been included such as stress, annoyance, heart (with qualifiers), disease, misophonia (the selective sound sensitivity syndrome which has no present medical issue being accepted as a current psychiatric disorder), psychoacoustic (integrating the pulsing sounds that annoy people), headaches, nausea, dizziness, nosebleeds and sleep disturbances/deprivation, low frequency effects, infrasound effects, vibration effects and even acoustic torture (not that many documents remain in the public domain) then the result would have been totally different.
  • The NHMRC inclusion of the keyword English may have stifled acceptance of even more relevant information usually partly in English but including Dutch, German, Swedish, Danish, Polish, Japanese and Korean.
    • Failure to accept foreign languages may have represented by the NHMRC literature restrainers an inability to handle foreign languages, an arrogance that only reputable science occurs in English or just as likely as the former, a deliberate intention to filter scientific evidence that did not suit their argument.
  • A Canadian researcher in 2014 conducted the same type of review as NHMRC however, as the intention was to find information as against not uncover any such as the NHMRC Review he included search words such as ‘stress’ and many medical words and funnily enough did find significant evidence to warrant medical concern.
    • The Canadian review may well have been conducted to determine haw many science papers were available.
    • However, it clearly did highlight the deliberate under reporting of literature by the NHRC which in any basic consideration is defined as (medical) scientific fraud.

The NHMRC specifically chose to ignore Review articles in its review.

  • Using the same NHMRC logic the NHMRC Review should not be used in any further assessments of Industrial Wind Turbine impact on close sited humans and indeed animals in general.
  • That was almost certainly a deliberate tactic by NHMRC,
    • in order not to have to reference bone fide scientific papers and reports that they may have missed through their use of deliberately constrained search words.
    • In addition as not all non recent material have been digitised it offered an additional opportunity to not find even more research material.
    • Comparing the NHMRC list of referenced documents demonstrated this was an effective tactic by NHMRC, yet not an ethical scientific process.

Finally the NHMRC Review claimed to be based on a systematic review and restricted itself to a tight time frame and did not allow for any incorporation of upcoming work. Perhaps that would include the mid 2014 systematic review from the Departments of Clinical Research, Audiology, Ear/Nose/Throat/Head & Neck Surgery and the Faculties of Health of a range of Danish Universities that concluded there were clear associations with wind turbines and health in some circumstances in the literature and others not. To suggest as ACNC does that there is no evidence to suggest health issues caused by Industrial Wind Turbines in the literature.

Wind turbines emit noise, including low-frequency noise, which decreases
incrementally with increases in distance from the wind turbines. Likewise, evidence
of a dose-response relationship between wind turbine noise linked to noise
annoyance, sleep disturbance and possibly even psychological distress was
present in the literature. Currently, there is no further existing statistically-significant
evidence indicating any association between wind turbine noise exposure and
tinnitus, hearing loss, vertigo or headache.

The above authors from Danish Universities relied on another review about some aspects of infrasound impact on humans based on a single review that found no health links. However, given that authors has now been roundly condemned to be associated with the wind industry the value of that review in turn has to be questioned.

  • The value of a Review is therefore often based on who commissioned, funded and wrote it. The Danish authors found evidence for strong bias in wind farm reviews including those regularly relied upon by wind industries to demonstrate there are no health impacts from close site wind farms.
  • The scientific evidence including standardised acoustic metrics is what should be relied upon to determine if there are health effects and Reviews should be considered on how they address the scientific information.

The Australian Health Minister at the time noted my NHMRC submission in early 2014, the Minister sent it to AMA noting to AMA that is should not only heed my comments about the deliberately fraudulent nature of the NHMRC literature review that found ‘no evidence’ but also indicated to me that they would at least include my comments.

I work now on the impacts of underwater ship noise on marine organisms. The published data is unequivocal with an increasing number of papers clearing showing that short exposure of some noise types, namely shipping as distinct from natural noise, clearly shows communication masking impacts reproductive success at a population level but also includes growth, blood chemistry and now immune response impacts in fish and invertebrates. The human literature indicates similar noise impacts (stress etc) irrespective of what the noise source is even if it is inconvenient for some when the source proves to be from close sited Industrial Wind Turbines.

I was invited to provide evidence to the Australian Senate Hearing on the state of the Great Barrier Reef, specifically noting the impact of underwater noise pollution. I did so as the only invited individual. The Senate noted the quality of available evidence demonstrating impact of specific, but not all noise, on marine organisms.

  • They noted my evidence that Government Departments associated with shipping industries that cause this internationally and legally recognised form of marine pollution clearly showed a reluctance to make any reference to noise pollution from shipping ranging up to 320 m in length bulk carriers where the majorly of generated noise is from cavitating propellers.
  • The Senate report made 2 of 26 overall recommendations noting underwater noise as an ecosystem pollutant, recommending that relevant Government departments accept the scientific evidence and not ignore the references simply to be able to indicate they were unaware of underwater noise pollution.
    • The Senate appeared to suggest to the Government Departments were simply providing lip service and that subsequently proved to be the case as the Senate Recommendation was partly ignored.

As a former Queensland public servant of 38 years standing I recognised that the Government departments were simply stonewalling the available noise impact evidence in order not to have to act on what was clearly apparent especially given the close relationship between the industry and the Government Department involved..

  • The same appears to be occurring in the Industrial Wind Turbine debate especially with the move to remove the tax benefit from Waubra Foundation that would eventually financially benefit the wind industry.

The claim of the ACNC .… that there was no rigorous independent scientific evidence that finds .…. is no different it would seem to the lack of willingness to accept the impact of underwater noise from shipping in Australian waters where it would seem ships are whisper quiet in Australian waters and suddenly a major source of ocean pollution as soon as they depart Australian waters.

  • International industry accepts noise pollution and are taking steps to mitigate and manage the pollution.

ACNC noted .…. nor are there are human diseases called “wind turbine syndrome” or ‘vibroacoustic disease”..

The ACNC claim is simply semantic drivel.

Wind turbine impact (however defined) and vibroacoustic syndromes/effects etc have been documented in the scientific literature for decades.

  • Its true that a term wind turbine syndrome was coined to describe an emerging problem associated with Industrial Wind Turbines but like other emerging medical problems the original name may be altered but that does not in any way change what is happening.
    • The syndrome is merely a label and it may well in the course of time be renamed Nina Pierpont Disease after the doctor who first started defining it (a very common practise in medicine).
  • Vibroacoustic impacts in animals, including humans, have been associated with cell aberrations during mitotic and meiotic cell division with total life history impacts to more localised damage of cells due to mechanical vibration. There may be some arguments at the semantic level over the use of the word disease but that does not alter the symptoms experienced.
    • The claim that vibroacoustic disease, or whatever name is associated with the symptoms, does not exist cannot be substantiated by ACNC.

 

2. THE TAX DECISION IS INCONSISTENT

As I understand it Waubra Foundation provides a medically capable/qualified base for dissemination of scientifically appropriate material to people with concerns about close siting of Industrial Wind Turbines. It is true that the wind industry would not be supportive of appropriate scientific information being made publicly available. The ACNC has stated that there are no health issues to be concerned about therefore there is no need to have the tax benefit.

Despite the NHMRC attempt at Industrial Wind Turbine noise evidence obliteration the NHMRC did find evidence for problems that required further research from their perspective — its in the report but rarely quoted. Wind turbine noise does have a medical basis recognised in the scientific literature, as that encompasses psychoacoustics, the science of noise impact on organisms,

For ACNC to claim there is no evidence for noise impact on some individuals at least predisposed to Industrial Wind Turbines within a to be determined radius is clearly a gross error from a scientific perspective.

After providing evidence to the Australian Senate on the Great Barrier Reef I became aware of a charity organisation that claims to provide an environmental / scientific service to Australian schools (primarily early school years) on how safe the shipping industry is to the environment,

  • The company was listed in Senate Evidence.
  • The company was formed by shipping, Port Corporations and the Commonwealth Department charged with shipping interests to provide data to schools that shipping was a safe and environmentally responsible activity without making a single reference to the strong basis in science that shipping noise is a recognised environmental pollutant to the Great Barrier Reef.
  • The company has consistently failed to document that the UN’s International Marine Organisation has recently issued Guidelines for shipping noise reduction on environmental grounds.
  • Therefore this environmental company with no documented capability in either education or science has total unfettered access to schools to provide funds for teacher conferences and deliberately incomplete educational information (which is by definition scientific fraud) enjoys tax status .

I cannot understand why this company maintains its educational tax status when Waubra Foundation with medical/scientific capability and not funded by self interest corporations is to lose its tax status.

3. CONCLUSIONS

There is no basis in science to support the contention of ACNC that,

“there has been no rigorous independent scientific evidence that finds that the ill health complained of is caused by the physiological effects from wind turbines nor that there are human diseases called “wind turbine syndrome” or ‘vibroacoustic disease”.
If the judgement is based on the early 2014 NHMRC Review it has to be noted,

  1. that the Review did indicate that more research was required to attain the clear understanding the NHMRC would consider unequivocal.
  2. the Review was conducted to sample research data over a given time frame and it is fair to say that more data have become available since the selected data cutoff date that received considerable questioning in the first place — perhaps NHMRC and the wind industry knew what was coming?

As the statement has not been substantiated, there is no certainty that the statement was not based on non scientific information provided by an industry group that receives lucrative subsidies from the Australian Government. If this was the case there would be no basis for the ACNC claim.

There will always be some areas of uncertainty about the nature of noise impact (the science of psychoacoustics) and in that context I would agree with the NHMRC that more research is required.

  • Given that NHMRC agrees that more research is needed to understand the problem it clearly reinforces the fact that there is at least a basis for a common agreement that there is some kind of issue that needs to be further investigated.
    • Simply on that basis the ACNC statement is in error, there is an issue.
    • The semantic comments of rigorous and independent can best be met by the science that has investigated the issues of noise and those comments are readily available in Journals with titles including acoustics, noise, industrial health, neuroscience, psychoacoustics, psychology, renewable energy, science & technology etc and conferences on wind turbine noise. .
  • That research may not always be able to be conducted in neat little experimental boxes, which the ACNC seems to allude to as being essential, given
    • the difficulty of establishing controls.
    • the fact that some individuals are more genetically pre-disposed to suffer pressure imbalances than others.
    • the fact that people receiving financial benefit from IWT’s can cope better (as they aren’t forced to listen to the noise they are responsible for and they get paid anyway) and those recipients forced to endure the sounds and being totally unable to do anything about it.

There is consistent agreement with all sides of the wind farm debate that human responses such as annoyance, lack of sleep, irritability for instance occurs with some people sited at a distance from Industrial Wind Turbines. What is the point of debate is whether those sorts of symptoms can be called a disease, a syndrome or even ill health in other words a semantic debate but the symptoms remain.

  • People having to put up with Industrial Wind Turbine noise not due to their choice may complain of being stressed to the limit by incessant turbine noise.
  • In the wind turbine debate that response is not permitted as a health effect by the wind industry but in any other walk of life would be placed under the banner of stress management with a recommendation to limit the stress exposure.
    • this of course cannot be achieved if ones home is being impacted by the noise and one cannot move without suffering serious financial loss.
    • Perhaps the increasing number of legal payouts to those impacted by wind turbine noise in North America should be instructive to ACNC.
      • A January/February 2015 legal settlement in favour of people impacted by wind farm noise has not prevented the person winning the law suit against explaining how he was impacted by wind farm noise, and he is taking that opportunity.

I do not see that ACNC can deny a tax status to Waubra simply on the basis that non qualified individuals cant see a scientific basis for while the isolation of Waubra for this treatment highlights significant disparities to industry bodies receiving tax benefit getting direct access to school system with absolutely no qualification.

Geoff McPherson
Marine Fisheries Acoustic Consultant

February 10, 2015

Download the document→