Sannikka, M ERM’s Incorrect Isopleth Data, Wellington’s Proposed Gas-Fired Power Station
Dear Mayor Rod Buhr 12 May 2015
Re: ERM’s incorrect isopleth data for Wellington’s proposed Gas-Fired Power Station
I am disappointed that as an elected representative, you (and ERM) have chosen to try and intimidate me through a series of press articles, expecting that the messenger will eventually shut up. Your unfair, and very public criticism, has only spurred me on to discover even more of ERM’s incorrect noise data.
This time please see attached Figure 9-7 from the Environmental Assessment (“EA”). This isopleth is the source of the original incorrect data, from which most of the subsequent incorrect data is produced. This original incorrect data has been used as reference, from which the so called “improvements” have been deducted.
The noise impact isopleth shows that Cadonia subdivision is in a wrong location approximately 2600m from the sound source, instead the correct distance of 1600m. There are two symmetrical sections of the rings of 4dB(A), each of which increase the Original configuration noise level from 26.5dB(A) to 34.5dB(A). I wonder if Parsons Brinkerhoff (“PB”) was confused with the nearby located Jail, the Wellington Correctional Facility, that is close to the designated location of the Cadonia subdivision. No doubt the undisclosed infrasound will reverberate inside the cells, causing serious health problems such as cardiovascular disease, severe depression and anxiety, and immunosuppression resulting in serious chronic infections and cancers. These serious predictable health problems will result from chronic sleep deprivation and chronic psychological stress, in some of the long term inmates. They will be unable to escape to protect themselves.
Unfortunately ERM’s incorrect scaling of the distance for the Cadonia Subdivision wastes so much area on top of the isopleth, that the entire Wellington Township has been left out at the bottom of the isopleth. I have included the location of Council Chambers for reference. Perhaps this was a deliberate omission??
The other important incorrect location on the isopleth is Nanima House, which is shown approximately 900m from the sound source instead of the correct distance of 700m. The symmetrical section of the ring of 4dB(A) increasing the original condition noise level from 43dB(A) to 47dB(A).
Therefore ERM’s first claim that the MOD1 offending noise at Nanima House inside the noise barrier is 35dB(A) has failed as 47 – 8 (noise barrier reduction) = 39dB(A). This is clearly noisier than the Compliance goal 35dB(A).
ERM’s second claim that the proposed 2 turbine noise of MOD2 at Nanima House is less than 40dB(A) has also failed, as 47 – 5 (improvement due to “quieter” turbines being only 5dB(A) instead of incorrectly claimed 7dB(A) = 42dB(A), resulting in forced acquirement of heritage listed house. This error was pointed out to you in my “fruit salad” letter of 27 April 2015.
The problem with ERM is that they designed the Uranquinty fiasco using wrong turbines like Mars 100 for modelling, yet admitting that their preferred supplier is Siemens. ERM also grossly under estimated the frequency of temperature inversions, resulting massively incorrect adverse conditions.
For Wellington, at least ERM got the supplier’s name, Siemens right. However, the weather data was measured at the wrong height resulting in a temperature inversion penalty of 1.5dB(A). When the corrected Neutral conditions are subtracted from corrected Adverse conditions the implied corrected temperature inversion is up to 5.5dB(A). This is yet another material difference which operates yet again in the proponents favour and against the protection of the residents of Wellington, this time of 4dB(A).
The problem for Wellington Council is self-inflicted. I would suggest that Council supported this Project unconditionally from the outset, and implied to the NSW Department of Planning that they were comfortable with the noise figures ERM submitted to them in the EA and MOD1. It seems to me that the Department did not evaluate these figures, for had they done so with any competence and due diligence, they would have spotted the incorrect data in the 20 instances that I have spotted so far. Parsons Brinkerhoff despite their international reputation has made mistakes and demonstrable incompetence everywhere in their Wellington data.
It is no wonder that PB has failed to produce correct data, because ERM would not disclose the total sound power level at the source even to them, and not to the NSW Department of Planning, the Wellington Council or to me.
Wellington Council has now a unique opportunity to prevent what will be a public health disaster from predictable severe noise nuisance, affecting the township of Wellington and the surrounding properties – employ someone like Steven Cooper and reject the nonsense that is peddled and advise the NSW Department of Planning that the current Council do not support this development at this site – it is too close to Wellington and MOD2 should not be approved at this site.
To make the noise intrusion appear artificially quieter and less annoying ERM and PB have used the following tricks:
- Weather data was measured at the wrong height and in the wrong location resulting in temperature inversion of only 1.5dB(A) in the EA.
- Over estimating the effectiveness of the noise barrier with seven assumptions in the PB Noise Barrier Investigation.
- Adding only 3dB(A) instead of 5dB(A) as low frequency noise penalty in PB MOD2 Memo.
- Subtracting 7dB(A) instead of 5dB(A) as improvement for Proposed 2 turbines version.
- Locating the four nearest residences up to 1000m too far on the isopleth to make the results appear to be quieter.
- Totally disregarded the contribution of infrasound in all of the models.
- Introduced the plant as peaking plant to be operated only 4% of the time.
- Not disclosing the total sound power level at the source making it impossible to determine any further away noise readings.
- Attempted to intimidate and shut up the messenger of ERM’s incorrect data news.
The NSW Department of Planning do not care about the proposed site, alternative sites or Wellington’s sufferings. They have inappropriately trusted the infallibility of PB’s status and blindly approved the initial application. Wellington Council has no noise expertise, but you have now been warned by me and others of the predictable unavoidable public health and legal disasters which will ensue, and for which you and your councillors and council staff will be responsible. I have advised you repeatedly to obtain independent expert acoustic advice – Mr Steven Cooper is willing and able to work for you and he is only a single phone call away for an initial contact.
In addition to employing Mr Steven Cooper, the Council should encourage the Deputy Premier and Member for Dubbo, Hon Troy Grant MP to keep his pre-election promise of a review into this project proposal. That review should include scrutiny of the actions of the NSW Department of Planning, both with respect to the noise issues, but also with the failure of the NSW Department of Planning to support their claims of substantial commencement or more importantly physical commencement. This was promised to the former Minister for Planning, Minister Goward, Hon Andrew Gee MP, Nat Barton, myself and others at our ministerial meeting in Sydney on 3 February 2015 but has never materialised.
Yours sincerely,
Martin Sannikka