Dr Bruce Rapley Writes to the ACNC in Support of the Waubra Foundation

Dr. Bruce Rapley, BSc, MPhil, PhD.
Principal Consultant: Acoustics and Human Health,
Atkinson & Rapley Consulting Ltd. Palmerston North, 4412,

Friday, 6 February, 2015

Commissioner Susan Pascoe

Dear Commissioner Pascoe,

I have recently been made aware of the ACNC decision of December 11, 2014, regarding the ruling that the Waubra Foundation is not a Health Promotion Charity. I understand that Assistant Commissioner David Locke stated that:

to date 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”.

As a consulting scientist in the area of acoustics and human health I write to advise you that I am appalled at the ignorance of your organisation’s staff.

I have worked closely with a number of people who have been affected by living in close proximity to industrial wind turbines and can personally attest to the considerable adverse health effects they suffer from.

I request to be advised of the qualifications of Assistant Commissioner David Locke together with an explanation of how he could possibly come to such a ludicrous conclusion. Having worked in this area for some years and possessing a PhD in acoustics and human health I take it as an absolute insult to me, my profession and my academic qualifications that such a nonsensical finding could be promoted. I can only conclude that there is some more sinister, political agenda that underpins the ruling.


Assistant Commissioner Locke displays his considerable ignorance of such illnesses as Vibroacoustic Disease and Wind Turbine Syndrome. Further, that he chooses to focus on “physiological effects” at the expense of the complex interactions between environmental variables and human reaction beggars belief.

The condition known as Vibroacoustic Disease has been well-established for more than a decade and is underpinned by a vast plethora of good, clinical and physiological evidence. There are numerous papers in the scientific literature if only Assistant Commissioner Locke would take the time to read them. To deny the existence of VibroAcoustic Disease is an egregious insult to the many scientists and clinicians who have worked for more than two decades on this research.

Assistant Commissioner Locke further displays his appalling ignorance of biology and medical science by selectively ignoring the wealth of information regarding stress-related conditions including sleep deprivation. In doing so he insults hundreds of international scientists and clinicians who have spent their lives studying such phenomena and providing appropriate treatment.

If Assistant Commissioner Locke had the appropriate academic qualifications and expertise to evaluate the scientific literature I am certain he would be amazed at the vast number of scientific and medical articles that abound on the physiological effects of sleep deprivation. That it can affect the human immune system, the digestive processes, the musculo-skeletal system and cognitive function of an individual makes a mockery of the pseudo-scientific mumbo-jumbo he is spouting. My own research has highlighted how the acoustic environment can affect not only hearing but also cognition and physical function. I take it as a gross insult that Assistant Commissioner Locke should choose to speak on topics of which he clearly has no knowledge.

Industrial wind turbines on the scale now in production are a relatively new phenomenon. With the increase in size, so the environmental acoustic hazard increases. It is basic physics. Perhaps Assistant Commissioner Locke would benefit from studying some basic science before he enters into making such ridiculous claims. Indeed his findings make a mockery of not only your organisation but its process that is clearly flawed.

The effects of environmental noise have been known for decades. There are even scientific journals dedicated to the topic, but as with all things bureaucratic, legislation lags behind the science. Environmental noise is a well-known pollutant and is even noted as such by the World Health Organization (WHO). The WHO produce guidelines for acoustic levels in residential areas with specific reference to sleep disturbance. Again Assistant Commissioner Locke is showing great ignorance that can surely only be underpinned by some ulterior motive or political agenda. Does he have connections with the wind industry?

Another salient point that Assistant Commissioner Locke appears to be blissfully unaware of is that the acoustic emissions from industrial wind turbines are unique, and cannot be compared to similar levels of other acoustic emissions, particularly in the low-frequency and infrasound regions. There are numerous scientific papers in the literature that make this precise point, although wind industry executives still continue to live in the land of false hope, burying their heads in the sand, hoping that science will not catch them out. Well, unfortunately for them, it has.


There is significant new research, for example, the work of Steven Cooper at Cape Bridgewater, that clearly correlates human health effects and physiological responses to wind turbine immissions. While this work of Mr Cooper’s appears new and exciting, in fact it is only providing conformation of what many of the scientists in the area have been saying for years. His work is, if you like, simply another piece of the puzzle vindicating the work of many of scientists that have gone before him. The work of Kelly springs to mind.

The unique acoustic signature of industrial wind turbines is providing scientists and clinicians alike with a number of unique challenges. The specific nature of that interaction is only now being studied to reveal the fascinating mechanism of interaction. There are numerous urgent calls for more scientific work to be carried out so that the ‘i’s can be dotted and the ‘t’s crossed. As industrial wind turbines are a relatively new addition to the landscape, it takes time for the science to work out the answers, although much of the picture is becoming quite clear now.

The landmark work of Professor Alec Salt in the USA is one such example of how clinical research and the use of animal models can help to unlock the puzzle of why this sort of acoustic exposure can and does affect the organism. Neural pathways are now being discovered that makes yet another mockery of the ignorance of Assistant Commissioner Locke. Neuroanatomy and physiology are now showing us how this type of energy can cause such great havoc in the human body. While science at this level is very complex, requiring considerable academic training and experience, something Assistant Commissioner Locke appears to lack, I might be able to offer a more simple analogy as to how exogenous energy can have such significant effects on a living organism.

There are only 26 letter in the English alphabet, but the number of words that can be created from them seems almost limitless. Just pick up a Greater Oxford Dictionary and prepare to be amazed by its contents. These words, simply a jumble of 26 different, unique elements, when in the appropriate order can convey great meaning.

Even at the level of words, the effect is not complete. Rather it is the combination and order of the selected words that ultimately conveys meaning. The point is, it is the meaning to which humans respond, not simply the energy quotient. In terms of physics, the written or spoken word has little in the way of energy to offer. But, like a biochemical enzyme and its substrate, this ‘lock and key’ system provides an avenue for the generation of biochemical cascades that are the very process of life itself. Get the order right and the response is good. Get the order wrong and it can be a harbinger of death. Take the example of a love sonnet; appropriately written and delivered, it can bring two people together in a state of emotional and physiological bliss. Get the order of the words wrong and it can be a declaration of war! As the British playwright, Stoppard said: “Words, words, it’s all we’ve got to go on!”.

The reason for using this simplistic analogy is for it to be the introduction to the biochemical language of science, notably biochemistry and human biology. The complex blueprint of human DNA is composed of only four ‘words’ (adenine, guanine, cytosine and tyramine) yet their complex interwoven structure is sufficient to grow and command every living cell in every person on this planet. (Obviously the same is true for plants, animals and bacteria.) The order of these biochemical sentences is a complex system, the language of which we have only just begun to understand in the past few decades. The point is, it is not the energy that is important, it is the information quotient of the sentences.

To explain the process of biochemical words even further, it may come as a shock to learn that the human body (and all animals as well) works on digital nerve impulses. Not analogue impulses but digital impulses. There is no hard or soft, quiet or loud nerve impulse. Every nerve impulse is the same as any other, and yet by their balletic dance they are able to convey every piece of meaning in every organism on the planet. (In order to function, the brain must be, and is, a difference engine.) It is these ‘digital words’ that make us what and who we are and how we function. It is these basic biochemical interactions (‘languages’) that are so important in understanding the interaction of environmental sound and the effects it has on living organisms.

What Assistant Commissioner Locke clearly does not understand is that this information pathway is the very reason that the acoustic (including infrasound) immissions of wind turbines can be so deadly to human organisms. They are ‘speaking’ in a ‘strange language’ directly to the human body, a language that we are only starting to comprehend. But in the absence of a more full understanding of the mechanism, what we do have is ‘cause and effect’. What clinicians refer to as ‘patient history’.


It may come as a further surprise to those not involved in the sciences or medicine, that in fact, much of medical diagnosis and treatment is based on ‘hearsay’. That is, what a patient reports. In the absence of a complete understanding of the biochemistry, physiology and neurobiology, clinicians are left with the dilemma of interpreting reported symptoms and making a diagnosis that will lead to treatment. By comparison, even with its vast arsenal, clinical medicine still has relatively few tools with which to ‘scientifically diagnose’ a problem. X-rays, MRIs and biochemical tests may confirm what a patient reports, but at the end of the day, it is what the patient reports that is of the greatest fundamental importance.

To ignore the symptoms reported by a patient is to commit a potentially fatal mistake and is in direct opposition to the Hippocratic oath that all doctors aspire to. Indeed, it could well constitute a case of medical misconduct, without even considering the potential disastrous results for the patient. It should be remembered that we learn from such patient testimony and this is how new disorders are discovered.

What we know is that, in the absence of a full understanding of the mechanism, patients are reporting the same type of symptoms related to living in close proximity to industrial wind turbines across the world. The work of Steven Cooper, while only one small step in the journey of discovery, is still one big and important step for scientific understanding of this issue. Using as he did, a case series crossover design, which is, in and of itself, a powerful experimental protocol, he was able to demonstrate the cause and effect relationship between environmental input and human physiological response.

To put this work in perspective, what Mr Cooper has done is join the dots. He has managed to link the phenomena to the reaction, using environmental monitoring and a case series crossover design, an experimental technique that is supported by Emeritus Professor Alun Evans. Other epidemiologists agree, but I see that Assistant Commissioner Locke intends to insult these eminent scientists as well with his ludicrous ruling and unscientific process.

The process of science is a journey of epic proportions. Only by combining millions of individual pieces of the jigsaw can the picture finally begin to emerge. Mr. Cooper’s work is the most recent important step along that journey. The point is that, as we put together more pieces, the picture is beginning to emerge, and that picture shows us that the unique acoustic emissions of industrial wind turbines can and do affect humans (as well as other animals – of course). The process by which that effect is created is not through vast energy transfer, ‘using a sledge-hammer to crack a nut’; rather it is by interfering with the complex and delicate structure on internal biochemical, neurophysiological pathways: The Nervous System.

The nervous system responds to the environmental input from industrial wind turbines by way of what can best be described as the function of a biological filter. That is, when a certain signature is detected, a particular chain of events is set in motion. That chain of events involves the outer hair cells of the cochlea, as well as the entire vestibular system (and possibly the gravisensors of the gut). Together, this ‘acoustic’ (that includes infrasound) energy that is detected by the human system that initiates a biochemical cascade. In the last handful of years, we have managed to get a handle on some of the neural pathways and how the brain interprets this unique input. The fact that the parabrachial nucleus is involved, as is the amygdala, is a significant finding. The end result is that one effect of the acoustic immissions so detected is to switch the autonomic nervous system into what is known as sympathetic dominance. In this state, a range of very important physiological changes occur.

The circulation of the blood is redistributed, digestion all but stops, sweat glands produce copious amounts of sweat and the pupils of the eyes dilate – to name but a few. Adrenalin floods the body and a state of heightened cognitive awareness dominates brain function. If this situation is not reversed in a matter of minutes or hours, severe physiological consequences can result leading to reduced cognitive function, reduced immune function and ultimately myocardial and respiratory failure. Yes, it can kill you. In shorter time frames it can be likened to torture, and such methods are well known and have been used for prisoner interrogation for decades prior to the second world war.

Indeed, sleep deprivation has been used for hundreds of years. The Italian lawyer, Hippolytus de Marsiliis (1451 – ) introduced it as a new tool for use in the Catholic Inquisition. The idea soon gained widespread acceptance. It is still used today, see “How the CIA tortured its detainees”. The globalisation of this phenomenon was demonstrated by revelations in 2008 that a study of Chinese Communist torture techniques was being used as training material for interrogators based at Guantanamo Bay. Animal studies show that too much sleep deprivation causes death. How much more of a physiological connection does Assistant Commissioner Locke need exactly?

As Assistant Commissioner Locke is obviously unaware of the consequences of sleep deprivation, here is a brief list of some of the known effects:

❖ Irritability

❖ Cognitive impairment

❖ Memory lapses or losses

❖ Impaired moral judgement

❖ Severe yawning

❖ Hallucinations

❖ Symptoms similar to ADHA

❖ Impaired immune function

❖ Increased risk of Type II diabetes

❖ Increased heart rate variability

❖ Risk of heart disease

❖ Decreased reaction time

❖ Tremors

❖ Aches

❖ Suppression of growth

❖ Increased risk of obesity

❖ Decrease in body temperature and regulation

 Is that enough of a physiological connection for Assistant Commissioner Locke?


May I suggest that your organisation familiarise itself with “Why Sleep Deprivation Is Torture”. There are many good, scholarly articles available on the internet using Google Scholar. There are in excess of 409,000 general articles on the topic and some 34,000 in the scientific literature.

It may seem outrageous to mention torture, however, I am not the first to do so. There are many other scientists and experts who have reached the same conclusion, and if you care to look in the scientific literature, you will actually find it. The reality is that living in close proximity to industrial wind turbines can be the same as torture, which explains why so many people are unwillingly leaving their homes in a desperate attempt to preserve their health and save their own lives. This is in no way hyperbole, making the position taken by Assistant Commissioner Locke all the more reprehensible.

I suggest that if Assistant Commissioner Locke is to draw such bizarre conclusions, he should be made personally liable for the physical and mental suffering that his ruling will cause. Perhaps then, and only then, might he realise that he has made an egregious error of judgement. Similarly, your own organisation should shoulder the responsibility of their actions and be financially liable for the human suffering caused by its ruling.

In conclusion, the ruling made by Assistant Commissioner Locke and your organisation is an egregious error of judgement and you should all be held, collectively and corporately, liable. The science is pointing the way to a clearer understanding of the dangers of environmental sound, much of which has been acknowledged for decades. In arriving at this interim ruling, Assistant Commissioner Locke insults me, my work, my qualifications and experience. Further, he insults the vast number of scientists who are working in this area, many of them for decades and are now trying to get the science in front of legislators before more human tragedy results.

It is my recommendation that Assistant Commissioner Locke and your organisation be held to account and the case tested in a court of law with regard to the ruling of December 11, 2014. I further suggest a class action suit be taken against the ACNC by those whose money will have been misappropriated by this ruling if it remains in place. The current course chosen by the ACNC has aimed the ship towards the iceberg and if a real human tragedy is to be averted, that course needs to change now. If you fail to undertake this maneuver it is only a matter of time before that fateful collision occurs.

You have the chance of turning away from this ludicrous decision that is not only an insult to scientists around the world but also endangering the lives and well-being of countless residents who have committed no other crime than to allow industrial wind turbines built too close to their homes. For these unfortunate people, whose lives have been destroyed, there should be some recompense and your organisation needs to shoulder some of the responsibility for the consequences.

I wonder how brave Assistant Commissioner Locke would be if he were to be made personally liable for the potential adverse health effects of his misinformed ruling?

An important consideration that you must take heed of is that the Waubra Foundation is NOT just about the adverse health effects from industrial scale wind turbines. Rather it is concerned with the adverse effects of noise from ALL INDUSTRIAL SOURCES. In point of fact, I have referred people in New Zealand to the Waubra Foundation as I know from experience that they will get good-quality health information regarding the problems they are experiencing with infrasound and low-frequency noise from a variety of industrial sources.


The focus of my work, like the Waubra Foundation, includes ALL sources of environmental acoustics that have human impact. In point of fact, my PhD thesis on the effects of occupational noise in the New Zealand military is consequently embargoed because of issues affecting national security. Noise can have far-reaching effects, even affecting a country’s security!

The point about adverse health effects experienced by those living in close proximity to industrial wind turbines is that in the vast majority of cases they were not aware of the potential hazards and openly welcomed the development. It is only after commissioning that the awful truth began to emerge. Many of these people have had to flee their homes as a consequence, often at great financial loss. The concept of the ‘nocebo effect’ is a red herring and fails on first principles. It is based on a misunderstanding of the concept of placebo/nocebo.

In my professional work I have found that I can rely on the Waubra Foundation as a valuable source of health information that is of great benefit to those who seek it. The work of the Waubra Foundation is to provide a source of information on how to deal with the effects of industrial noise and as such is a very valuable service. That they are also focussed on promoting research in the area that is vitally needed world-wide is an added benefit.

One final point: The consequences of your organisation’s ruling is tantamount to misappropriation of funds. Hundreds of people have donated money to the Waubra Foundation, in good conscience, well-informed of the aims and objectives of that organisation. To rule that the Waubra Foundation is not a charity predicated on dissemination of health information and facilitating research related to industrial noise problems is to deny the reality of the situation and smacks of some sinister, political agenda. The consequence is that the money given in good faith will be misappropriated for some other purpose. This is what we call theft in New Zealand. And your organisation, as it stands, is solely responsible for that.

Please be advised that as I have been asked to provide expert testimony to the Senate Enquiry in Canberra later this month. I fully intend to provide them with all information regarding your organisation’s actions in respect of the Waubra Foundation. The implications are considerable.

Yours faithfully.

Dr. Bruce Rapley, BSc, MPhil, PhD.
Principal Consultant: Acoustics and Human Health,
Atkinson & Rapley Consulting Ltd.
Palmerston North, 4412,

Download Dr Rapley’s letter→