Waubra Foundation Comments on Proposed Queensland Wind Farm State Code & Guidelines

May 13, 2014

Hon Jeff Seeney, Minister for Planning
Hon Andrew Powell, Minister responsible for the EPA
Hon Lawrence Springborg, Minister for Health
Cc Hon Campbell Newman, Premier of Queensland

Comments re Proposed Queensland Wind Farm State Code and Guidelines

Dear Minister Seeney, Minister Powell, Minister Springborg and Assistant Minister Davis,

I am sure you would all agree that Governments and Ministers have a duty to ensure their legislation, regulations and guidelines do not cause predictable harm to the health of their citizens.I note that we sent the previous Queensland government ministers our Explicit Cautionary Notice regarding reported adverse health effects of wind turbines in June 2011.We would like to bring it to your specific attention, and ask each of you to read it carefully (http://waubrafoundation.org.au/about/explicit-cautionary-notice/ ).Our concerns have increased since June 2011.

The Waubra Foundation has been asked by concerned Queensland residents to comment on the proposed Queensland Wind Farm State Code and Guidelines, (draft guidelines) which have been put out for public comment.I have outlined our main concerns below.

Your government’s proposed draft wind turbine noise guidelines will ensure that predictable harm to human health will indeed inevitably occur to some residents if they are not substantially amended.

That could create liability issues for your government, and ultimately the Queensland taxpayers, if that predictable harm occurs, particularly if advice provided by Queensland Government Noise Experts to Queensland communities and Queensland Health is now being ignored.

Noise limits for audible noise (dBA) are above the current QLD Noise Policy

The guidelines, as they are currently written, will result in rural residents in Queensland being exposed to health damaging audible noise levels inside their homes when they are trying to sleep, which are above your current environmental noise pollution levels for audible noise in the current Queensland Noise Policy.

There is no justification for your current recommended levels in the current Queensland Noise Policy (aimed at ensuring the WHO recommended levels of 30 dBA inside bedrooms) to be exceeded, and there is no justification to deliberately discriminate against rural residents living near wind turbines.

The Importance of Sleep

Sleep deprivation is widely acknowledged and accepted to cause serious adverse health effects, particularly if it is chronic.Some relevant research and references are listed below:

http://waubrafoundation.org.au/resources/mansfield-et-al-sleep-loss-and-sleep-disorders-mja-oct-13/
http://waubrafoundation.org.au/resources/hillman-d-lack-l-public-health-implications-sleep-loss-community-burden-mja-oct-13/
http://waubrafoundation.org.au/resources/sleep-duration-predicts-cardiovascular-outcomes/
http://waubrafoundation.org.au/resources/jan-j-e-et-al-long-term-sleep-disturbances-children-cause-neuronal-loss/

Protection of sleep has been the justification for having nighttime noise pollution limits, and properly enforcing them.Where noise guidelines achieve this, and are properly implemented, public health is protected. Where noise guidelines do not ensure sleep is protected, such as in your draft guidelines, human health will be predictably and inevitably seriously damaged with chronic exposure to that environmental noise, regardless of the noise source.

Sleep deprivation has been clearly identified in the recent 2014 NHMRC’s systematic literature review as one of the health problems identified by the research into wind turbine adverse health effects which met the NHMRC’s inclusion criteria.

Sleep deprivation is the commonest complaint of wind turbine neighbours in Australia and internationally.

Unfortunately the sleep of rural residents is not currently protected anywhere in the world with current wind turbine noise regulations, because those regulations :

are universally inadequate, because the allowable noise levels indoors at night are too high and do not protect sleep, and
exclude certain frequencies, especially infrasound and low frequency noise;and
are not properly and transparently policed with availability of all the relevant noise, weather, wind and SCADA data to all stakeholders allowing independent compliance audits to occur, and
do not provide for automatic or immediate shut off of the offending wind turbines when breaches are occurring or can be predicted to occur, based on wind and weather conditions.

Copying another jurisdiction’s current noise pollution guidelines, where there is evidence of serious noise related sleep and health problems and home abandonments resulting from a “compliant” wind development, is unwise.

Your draft guidelines are based on the South Australian EPA’s Wind Farm Noise Guidelines, guidelines which are clearly inadequate if a wind development is judged by the SA EPA to be “compliant” but the sleep of significant numbers of the residents is still regularly disturbed by operating wind turbines.This is the situation at Waterloo wind development, where the SA EPA conducted an acoustic survey in 2013 after significant community and public pressure was applied to the SA EPA.They subsequently reported it was “compliant”.

At Waterloo Wind Development in South Australia, the characteristic sleep disturbance of “repeatedly waking up at night in an anxious frightened panicked state” described around the world by residents and their treating doctors (http://waubrafoundation.org.au/resources/dr-sandy-reider-testimony-calls-for-moratorium-wind-farms/ ) and strongly suspected to be caused by peaks of infrasound pulses, has been reported by residents out to at least 10km from the nearest wind turbine, with predictable correlation with wind and weather conditions.The Federal Coalition has promised research to investigate these reported health and sleep problems, and the first priority is to determine which sound frequencies at which “doses” are directly causing the sleep disturbance and physiological stress episodes described consistently by the residents, known as “annoyance” symptoms.

Acousticians such as Emeritus Professor Colin Hansen and Steven Cooper report the resident’s reports of sleep disturbance are consistent with their full spectrum acoustic measurements of wind turbine noise, which include infrasound and low frequency noise.(eg http://waubrafoundation.org.au/resources/prof-colin-hansen-writes-victorian-dept-health-recent-wind-farms-health-doc/ and http://waubrafoundation.org.au/resources/are-wind-farms-too-close-communities/ )

Queensland based Psychoacoustician and wind turbine noise acoustics researcher Dr Bob Thorne has illustrated the severity and range of reported adverse health effects, and confirmed detrimental effects on sleep, mental health and quality of life particularly.His detailed case series was presented to the Federal Senate Inquiry in 2012, and contained both acoustic and health indicator data, together with comparative data from population norms which confirmed that the study group of wind turbine residents from two reportedly “compliant” Victorian Wind Developments were indeed very unwell when compared to those population norms.His study can be accessed here: http://waubrafoundation.org.au/resources/wind-farm-generated-noise-and-adverse-health-effects/ .

Neurophysiologist Professor Alec Salt has demonstrated in laboratory studies with guinea pigs that the “alerting response” is activated with infrasound stimulation, especially in quiet background noise environments, providing strong supporting evidence for this hypothesis from animal studies that wind turbine generated infrasound is directly causing these sleep disturbance episodes via disturbance of the vestibular system in the inner ear even when the wind turbines may not be audible.(http://waubrafoundation.org.au/resources/salt-n-lichtenhan-j-t-how-does-wind-turbine-noise-affect-people/ )

Mrs Mary Morris’s population survey at Waterloo was the only Australian study included in the recent NHMRC commissioned systematic literature review, and it confirmed the adverse effects on sleep out to 10km for some households.(http://waubrafoundation.org.au/resources/waterloo-wind-farm-survey-2012/)I reiterate that chronic sleep disturbance is well known and accepted to be very damaging to human health, and is the major predictable health complaint from residents living near existing wind turbines.

Waterloo Wind Development in South Australia – “compliance” with current SA EPA Wind Turbine Noise guidelines does not protect sleep, and therefore will predictably harm human health with chronic exposure.

The survey diaries kept by the neighbours during the 2013 SA EPA wind turbine noise acoustic survey showed consistent reports of intrusive noise, sleep disturbance and other characteristic symptoms from wind turbine noise, despite the claims by the EPA that the wind development was “compliant”.

Shortly after the acoustic survey concluded, the residents of Waterloo had a reprieve from the wind turbine noise for a week, because of a “cabling fault” and for a week the residents slept well and had none of the symptoms and sensations they had come to associate with exposure to operating wind turbines.However the symptoms and sleep disturbance recommenced when the turbines started operating again.Some of that evidence has been collated by Mrs Mary Morris and is available here: http://waubrafoundation.org.au/resources/morris-m-waterloo-case-series-preliminary-report/

The objective evidence from the residents reports and their diary records makes it abundantly clear that either the wind turbines are not in fact compliant with the SA EPA Wind Turbine Noise guidelines and / OR the guidelines are inadequate to protect sleep and health.

I note that Emeritus Professor Colin Hansen has explained in some detail in his submission on the draft guidelines how residents may still be subjected to intrusive sleep and health damaging levels of noise when the wind development is “compliant” because the guidelines are inadequate to protect sleep and therefore health.His peer review comments on the SA EPA acoustic survey are well worth reading carefully, (http://waubrafoundation.org.au/resources/hansen-c-h-comments-sa-epa-waterloo-wind-farm-environmental-noise-study-2013/ ) as is Mrs Mary Morris’s analysis of one of the resident’s noise diary during a shut down, (http://waubrafoundation.org.au/resources/morris-m-comparison-wind-turbine-acoustic-measurements-analysis/ ) where it is clear the resident was able to perceive the change in the acoustic environment, a fact which seems to have escaped the SA EPA Acoustic survey report authors and acoustic data and diary analysers.

I also note that peer review comments of the SA EPA Acoustic Survey by international acousticians from the USA including acousticians who have worked closely with the wind industry (Hessler, Schomer and Walker) dismissed the SA EPA’s assertion that “infrasound was not an issue” (http://waubrafoundation.org.au/resources/hessler-george-comments-south-australian-epa-study-at-waterloo-wind-farm/ )

Direct Causation of Symptoms Including Sleep Disturbance From Infrasound and Low Frequency Noise

Chronic severe sleep deprivation caused directly by exposure to wind turbine emissions, both audible and inaudible, is the commonest complaint from residents living near wind turbines in Australia, and internationally.

In particular, it has been known to the wind industry since the US NASA and Kelley research from the mid 1980’s that wind turbine noise below 200 Hz, specifically infrasound and low frequency noise (ILFN), can directly cause sleep disturbance, especially if the frequencies are amplified by resonance within buildings.

Our Explicit Warning Notice outlines the Kelley research and its implications, and was sent to the state and Federal governments including the Queensland government last year (http://waubrafoundation.org.au/2013/explicit-warning-notice/ ).We strongly suggest you read, it if you are not familiar with it.

The evidence based recommended limits of chronic exposure developed by Dr Neil Kelley and his team in 1985 have been universally ignored, despite the fact that the wind industry moved quickly to change the design of wind turbines to upwind bladed turbines specifically to reduce the generation of these frequencies – there was clearly an acknowledgement that the research was valid and accepted by the US government and the wind industry, and that infrasound and low frequency noise generated by wind turbines were of concern.

This lack of inclusion of the recommended exposure limits for infrasound and low frequency noise, or even mention of the generation of infrasound and low frequency noise in government noise pollution regulations until recently is hardly surprising when it is realized that the wind industry favoured acousticians have written or had substantial input into the guidelines internationally, including your recent draft wind turbine noise guidelines.

The wind industry is well aware of the threat infrasound related adverse health effects including sleep deprivation pose for their industry, because of the large distances impulsive wind turbine generated infrasound can travel, and its penetration and amplification inside certain building structures which increase the “dose” of infrasound to the residents inside, demonstrated by Dr Neil Kelley et al’s research in 1985.

So it is no surprise that the efforts by the wind industry to keep measurement of infrasound out of government noise guidelines have been sustained, and so far successful.This occurs when acoustical consultants are acting in the best interests of their long term well financially resourced clients, rather than the protection of public health.Such behaviour appears to be contrary to the provisions of the various ethical codes of conduct of acousticians and engineers to “protect the health and safety of the public”.http://waubrafoundation.org.au/resources/acoustic-organisation-codes-conduct/ .

How Far Does Wind Turbine Generated Infrasound Travel?

NASA research by William Willshire demonstrated in 1985 that wind turbine generated infrasound could travel 10km, (http://waubrafoundation.org.au/resources/nasa-long-range-down-wind-propagation-low-frequency-sound/ ) and more recently acousticians in Australia (Cooper, Huson, and Hansen) and Canada (Andy Metalka) have measured wind turbine generated infrasound inside homes out to 10km from the nearest wind turbine.

Les Huson presented acoustic evidence to the Cherry Tree Court case in Victoria (http://waubrafoundation.org.au/resources/huson-l-expert-evidence-at-vcat-cherry-tree-hearing/ ) demonstrating that wind turbine infrasound from the two Hepburn Wind community wind turbines was measured 32 km away, and that there was no attenuation out to a distance of 6.4 km from the nearest wind turbine at Macarthur, indicating that the wind turbine generated infrasound was likely to travel for very large distances, and therefore could potentially have a health damaging impact well beyond the 10km previously reported at Waterloo.

Conflicts of Interest With Wind Industry Acoustic Consultants

There is an obvious financial conflict of interest, which is generally not disclosed to the public by either government or the acousticians concerned when these government wind turbine noise guidelines are developed by acousticians who also work for the wind industry.

The same conflict of interest issues have tainted the most recent 2014 NHMRC systematic literature review, which the Waubra Foundation and others have publicly expressed serious reservations about.Our critique of the NHMRC systematic literature review is here: http://waubrafoundation.org.au/resources/waubra-foundation-open-letter-nhmrc-re-systematic-literature-review/ and the critical comments of others are accessible here: http://waubrafoundation.org.au/resources/responses-nhmrc-draft-information-paper-systematic-literature-review/

In brief, important medical epidemiological research was deliberately omitted by in two instances misclassifying the studies as “case studies” and then excluding all “case studies” from consideration.This resulted in the exclusion of

a case series by Dr Amanda Harry (rural GP in the UK),
a population survey by the first Australian Doctor to blow the whistle about the adverse health impacts of wind turbine noise in 2004, (Dr David Iser, from Toora in Victoria) and
a case series crossover study, conducted by a rural Paediatrician who also had a PhD in science (behavioural ecology), Dr Nina Pierpont.

These studies would normally be included in such a literature review, according to the NHMRC’s own guidelines. There was no explanation for this decision from any members of the Literature Review Advisory Panel, handpicked by the NHMRC.

There are other concerning deliberate exclusions of important evidence from the NHMRC systematic literature review, including the important information that as the size and power of wind turbines increases, the sound energy shifts down towards the lower frequencies, and therefore predictably increasing annoyance symptoms for the residents. Annoyance includes repetitive sleep disturbance. All animal research was also excluded, yet animal research is vitally important in understanding how and why disease processes occur.

The sole acoustician on the NHMRC advisory panel is a senior consultant with SKM, a firm which does a significant amount of work with the wind industry globally and locally. The consultant himself had done work at a number of wind developments where serious noise related health problems have subsequently occurred (eg Toora, Waterloo) resulting in property buy outs with non disclosure agreements, and voluntary home abandonments where residents have walked away from their now unlivable homes and farms.

It is therefore unfortunately no surprise that the acoustic information in the NHMRC commissioned systematic literature review was biased, failed to include mention of the criticisms of the limited wind industry associated acoustic research cited, and failed to include results of independent acoustic research contrary to the cited research’s findings and conclusions which could harm the wind industry’s interests.

This serious conflict of interest within the NHMRC Panel (and other conflicts of interest or misleading advice given by a panel member) have now been highlighted in Federal Parliament by Senator Chris Back, Liberal Senator for Western Australia, (http://waubrafoundation.org.au/resources/senator-chris-back-questions-evidence-from-vested-interests-at-planning-review-hearings/ ) and Senator John Madigan, Democratic Labor Party Senator for Victoria (http://waubrafoundation.org.au/resources/nhmrc-ceo-prof-anderson-questioned-about-draft-review-by-senate/ ).

Low Frequency Noise

Whilst your guidelines do mention low frequency noise, I note Emeritus Professor Colin Hansen’s concerns that your suggested low frequency noise regulations do not go nearly far enough to protect the community from their known adverse health effects.Studies listed in the 1995 Community Noise literature review by Berglund and Lindquist make it clear that knowledge about the damage to health from low frequency noise exposure is not new, even if it is still ignored by some(http://waubrafoundation.org.au/resources/berglund-b-lindvall-t-community-noise/ )

Infrasound measurement and recommended chronic exposure limits

We note that infrasound is not mentioned in your guidelines.

This is unacceptable, given longstanding and recent acoustic and biomedical research which have clearly established that infrasound and low frequency noise can cause sleep disturbance and a range of other adverse health impacts in humans, together with the mounting evidence from animal studies (all excluded from the NHMRC literature review).Brief details of some of the most important research are outlined below.

The excuse that the NHMRC did not include this research in their literature review (and by inference it can be ignored) is not valid, given the major problems identified with the conduct of the NHMRC commissioned systematic literature review we have outlined above. As Professor Hansen has pointed out the draft information statement of the NHMRC is a draft, and has not yet incorporated expert reviewers comments, nor have the NHMRC yet responded to the criticisms of the systematic literature review, which require detailed explanations as to why those decisions were made, and who made them.

The five most important general research findings with respect to infrasound causing damage to health, and confirmation of its emission from upwind bladed wind turbines are listed below. Had this information been included, the NHMRC draft information statement and systematic literature review would have been completely different, and would have confirmed there was research evidence of

evidence of direct causation of severe chronic sleep disturbance in humans and
biological markers of physiological stress (in animal and human studies),
a range of predictable serious adverse health effects in people with recognized susceptibilities, and
long term tissue damage to a variety of organs with chronic exposure

all resulting directly from chronic exposure to infrasound and low frequency noise.

a) The Kelley / NASA research from the 1980’s, funded by the US Department of Energy

Adverse sleep and health impacts (annoyance symptoms) which result from acute and chronic infrasound exposure have been established for nearly thirty years by the Kelley research, detailed in our Explicit Warning Notice.(http://waubrafoundation.org.au/2013/explicit-warning-notice/ )

Evidence based exposure guidelines were developed by that 3 year detailed acoustic survey. Those exposure limits are below:

“the joint radiation levels (expressed in terms of acoustic intensity and measured external to a structure) in the 8, 16, 31.5 and 63 Hz standard (ISO) octaves should not exceed band intensity threshold limits of 60, 50, 40 and 40 dB (re 1 pWm –2) more than 20% of the time. These figures compare favourably with a summary of low-frequency annoyance situations by Hubbard.”

The wind industry and the Clean Energy Council have claimed that this US Department of Energy funded major research project with fifteen different research institutions including two branches of NASA is “not relevant” or is “outdated” because it was conducted on a single downwind bladed wind turbine, but acousticians independent of the wind industry and the Waubra Foundation do not agree.

Firstly, upwind bladed wind turbines DO generate and emit infrasound (see below – known since 1989) and secondly, the human dose response information obtained in this 1985 study is consistent across different noise sources – including not only wind turbine noise but also military aircraft generated noise.In other words the Kelley research has scientific integrity and compares well with previous research into military aircraft noise and its human impacts by Harvey Hubbard. (http://waubrafoundation.org.au/resources/hubbard-h-1982-noise-induced-house-vibrations-human-perception/ )

b) Upwind Bladed Wind Turbines Generate Infrasound (especially if too close together)

NASA research by Kevin Shepherd and Harvey Hubbard in Hawaii in 1989 demonstrated that even small upwind bladed wind turbines (eg 600 kW) can produce infrasound (and low frequency noise), and do so under conditions of inflow turbulence, or “dirty wind” (http://waubrafoundation.org.au/resources/shepherd-k-hubbard-h-noise-radiation-characteristics-westinghouse-wwg-0600-wind-turbine-generator/ ).This inflow turbulence in downwind and upwind bladed wind turbines results in additional outflow turbulence which lasts for large distances, and is well illustrated by the photo taken at Horns Rev, a maritime wind development in Europe (https://www.wind-watch.org/pix/displayimage.php?pid=556 ) This situation also occurs when wind turbines are sited too close together, because that also increases the inflow turbulence to the wind turbines located downwind.

Australian locations where the separation distances between wind turbines do not always comply with either the manufacturer’s specifications or the international standard IEC 61400 include Waubra, Waterloo, Cullerin and Macarthur.These are also locations where residents have reported serious wind turbine noise and infrasound related chronic sleep disturbance and adverse health effects out to distances of at least 10km (Waterloo http://waubrafoundation.org.au/resources/waterloo-wind-farm-survey-2012/ and Macarthurhttp://waubrafoundation.org.au/resources/macarthur-wind-energy-facility-preliminary-survey/ ) and 7.5km in the case of Cullerin (http://waubrafoundation.org.au/resources/cullerin-range-wind-farm-survey-august-2012/ and http://waubrafoundation.org.au/resources/schneider-p-cullerin-range-wind-farm-survey-follow-up-july-august-2013/ ).

Therefore the proposed QLD wind turbine noise guidelines should include a provision that the IEC recommendations for turbine separation distances of 5 – 8 rotor diameters MUST NOT be decreased.

c) Recent Findings of Acoustic Surveys (eg the Shirley Wind Project Wisconsin Survey in the USA)

The conclusions of the four acoustic firms (including acousticians who worked predominantly for the wind industry) in the Shirley Wisconsin Cooperative Survey 2012, were that infrasound and low frequency noise was “a serious issue, possibly affecting the future of the wind industry”.(http://waubrafoundation.org.au/resources/co-operative-measurement-survey-analysis-low-frequency-infrasound-at-shirley-wind-farm/ )One of the acousticians involved was Dr Paul Schomer, an extremely highly regarded acoustician, and Director of Acoustic Standards in America.

Dr Schomer then used data from wind developments in the USA, Canada and Australia together with information about a subset of people who were immediately severely adversely impacted by exposure to wind turbine noise at those three locations, to demonstrate that the chance of the wind turbine noise not being related to their symptoms was less than 2 in a million.In other words, his work demonstrated supportive evidence for the direct causation of their symptoms from wind turbine emissions in the infrasound range.(http://waubrafoundation.org.au/resources/schomer-et-al-wind-turbine-noise-conference-denver-august-2013/ )

d) Physiology of the Inner Ear, and Induction of “Meniere’s Disease Symptoms” from Infrasound

Professor Alec Salt and his team in the USA have led the way with their research in this area, which is nicely summarized in a recent article in Acoustics Today, http://waubrafoundation.org.au/resources/salt-n-lichtenhan-j-t-how-does-wind-turbine-noise-affect-people/ and in Professor Salt’s letter to the Victorian Health department http://waubrafoundation.org.au/resources/prof-alex-salt-expresses-deepest-disappoint-victorian-dept-health-report/ .

Professor Salt was disturbed to find that the Victorian Health Department was erroneously stating that there was no evidence that infrasound could exert a physiological effect, and concluded his letter with the statement that reinforced the Health Minister’s obligation to ensure the protection of the health of the community.

Professor Salt has suggested that one of the surgical treatments (grommets) for Meniere’s disease sufferers could be used to alleviate identical symptoms in residents severely impacted by wind turbine noise, in other words a surgical intervention could be required to help them live in their own homes without distressing symptoms of nausea and vertigo. However this solution will not prevent the development of vibroacoustic disease (see below) and has its own risks.

e) Vibro Acoustic Disease (VAD)

There is a 30 year body of human pathological, and animal laboratory research by Portuguse researchers pathologist Dr Nuno Castelo Branco and Professor Mariana Alves Pereira into a condition which has been given the name of Vibro Acoustic Disease (VAD), which has a range of non reversible and serious adverse health consequences for those who develop this condition after exposure to prolonged chronic infrasound and low frequency noise and vibration.

Professor Alves Pereira and Dr Nuno Castelo Branco were recognized in Portugal for their contribution to scientific knowledge and improving public health in this field. References to some of their experimental work and their responses to criticism by wind industry advocates not trained in either acoustics or medicine are listed below:

Review articles:

http://waubrafoundation.org.au/resources/alves-pereira-et-al-vibroacoustic-disease-response-biological-tissue-low-frequency-noise/http://waubrafoundation.org.au/resources/vibroacoustic-disease-biological-effects-infrasound-alves-periera-castelo-branco/

Responses to criticism

http://waubrafoundation.org.au/resources/alves-pereria-m-castelo-branco-n-ltr-australian-new-zealand-journal-public-health/http://waubrafoundation.org.au/resources/alves-pereira-m-castelo-branco-n-scientific-arguments-against-vibroacoustic-disease/

Details of work relating to wind turbine noise effects

http://waubrafoundation.org.au/resources/low-frequency-noise-presentation/http://waubrafoundation.org.au/resources/follow-up-study-family-exposed-low-frequency-noise/

VAD has been reported in wind turbine residents and their animals in Portugal, at a location where the Portuguese Superior Court subsequently recently ruled that four of the wind turbines should be taken down because of the adverse health effects. http://waubrafoundation.org.au/resources/portugese-supreme-court-orders-four-wind-turbines-removed/portuguese-supreme-court-orders-4-wind-turbines-removed/

VAD is increasingly being recognized by others as a potentially serious public health problem (eg the military http://waubrafoundation.org.au/resources/castelo-branco-n-low-frequency-noise-major-risk-factor-military-operations/ , the aviation industry http://waubrafoundation.org.au/resources/effect-low-frequency-noise-echocardiographic-parameter-ea-ratio-chao-et-al-2/ ). Symptoms and irreversible health problems consistent with VAD have been reported by residents in Germany (http://waubrafoundation.org.au/resources/windwahn-story/ ) and Australia, who have been exposed chronically to wind turbine generated infrasound and low frequency noise.

Ignorance about this condition is still widespread in some circles, especially amongst members of the medical profession, however the increased personal liability of managers in various jurisdictions for breaches of Occupational Health and Safety Legislation is resulting in an increased interest in this problem from some people, particularly in the military.

The general ignorance of the Australian medical profession with respect to harm to health from infrasound and low frequency noise is illustrated in the recent AMA position statement about wind turbines and health effects. The response to this ignorant statement was immediate and international, from medical professionals, acoustic professionals and others who have first hand knowledge of the serious nature of the adverse health impacts, and the research literature which the AMA ignored, which included even aspects of the NHMRC’s own recent (albeit flawed and inadequate) literature review, which did at least find that sleep deprivation, impaired quality of life and annoyance symptoms were being reported in the research literature. The responses and the AMA position statement itself can be accessed from our website here: http://waubrafoundation.org.au/resources/ama-statement-responses-concerned-professionals-citizens-impacted-residents/ .

It would therefore be unwise of the Queensland government to ignore the known research that infrasound does indeed cause direct pathological and physiological impacts, and that the sleep disturbance can be a problem for a significant number of people out to 10km and even beyond under specific wind and weather conditions. This is being confirmed with the acoustic field survey evidence from the independent acousticians currently conducting the field studies in Australia whom the residents trust to act ethically and in accordance with the acousticians code of ethics, namely Emeritus Professor Colin Hansen, Dr Kristy Hansen, Steven Cooper, Les Huson, and Dr Bob Thorne.

Full Acoustic Spectrum Measurements Must be Conducted (ie including infrasound)

Professor Salt and Professor Lichtenhan’s recent article published in Acoustics Today mentioned previously (http://waubrafoundation.org.au/resources/salt-n-lichtenhan-j-t-how-does-wind-turbine-noise-affect-people/ ) contained the following warnings about how misleading it is to measure wind turbine noise without including measurement of infrasound:

“We were surprised that objective full-frequency measurements showed that wind turbines generate infrasound at levels capable of stimulating the ear in various ways. Under such circumstances, A-weighting measurements of turbine noise would be highly misleading.”

Professor Salt went on to say that in future full spectrum acoustic measurements must be conducted, and that the role played by acousticians and acoustic professional bodies to protect the wind industry at the expense of public health was regrettable. He stated:

“One area of concern is the role that some acousticians and societies of acousticians have played. The primary role of acousticians should be to protect and serve society from negative influences of noise exposure. In the case of wind turbine noise, it appears that many have been failing in that role. For years, they have sheltered behind the mantra, now shown to be false, that has been presented repeatedly in many forms such as “What you can’t hear, can’t affect you.”; “If you cannot hear a sound you cannot perceive it in other ways and it does not affect you.”; “Infrasound from wind turbines is below the audible threshold and of no consequence.”; “Infrasound is negligible from this type of turbine.”; “I can state categorically that there is no significant infrasound from current designs of wind turbines.” All of these statements assume that hearing, derived from low-frequency-insensitive IHC responses, is the only mechanism by which low frequency sound can affect the body. We know this assumption is false and blame its origin on a lack of detailed understanding of the physiology of the ear.”

We note that an American acoustician Mark Bastach is now being personally sued for negligence, (http://waubrafoundation.org.au/2012/residents-sue-noise-engineer-for-negligence/ ) and that an American court at Falmouth in the USA has ordered that wind turbines be turned off at night in order to ensure the residents nearby get a good night’s sleep, in order to prevent irreparable harm to physical and psychological health (http://waubrafoundation.org.au/2013/judge-rules-wind-turbines-cause-irreparable-harm-health-issues-immediate-injunction/ ).

In view of all these factors it would seem unwise of the Queensland Department of Planning to ignore Professor Salt and Professor Hansen’s advice about infrasound, even if so far the Victorian Government has so far chosen to do so.The Victorian government is well aware of the serious nature of the adverse health problems reported in Victoria since 2004 by Dr David Iser.I note that the Health Minister in Victoria has however offered to contribute $100,000 to the Federal Health Minister, towards the cost of the promised wind turbine health research.

Concluding remarks

Your proposed guidelines need to be substantially amended if they are to adequately protect public health, based on our current knowledge.There needs to be an explicit acknowledgement that there are gaps in our current knowledge, particularly with respect to the severity of the adverse health impacts of chronic exposure to infrasound and low frequency noise, and that therefore the guidelines will need regular revision as more information becomes available, for example from the Federal Coalition’s promised wind turbine health research.

Your draft guidelines should be amended as follows, to better protect the health of Queensland citizens. They need to:

1. Explicitly acknowledge the need to maintain 30 dBA as the indoor noise limit to protect residents from sleep disturbance resulting from audible noise above 200 Hz. This limit is currently in the Queensland Noise Policy, and is the recommended level indoors by the World Health Organisation.

2. Include the evidence-based guidelines developed by the Kelley 1985 Acoustic Survey field research for preventing harm to health from chronic exposure to wind turbine generated impulsive infrasound and low frequency noise.These guidelines are repeated below:

“the joint radiation levels (expressed in terms of acoustic intensity and measured external to a structure) in the 8, 16, 31.5 and 63 Hz standard (ISO) octaves should not exceed band intensity threshold limits of 60, 50, 40 and 40 dB (re 1 pWm –2) more than 20% of the time.

3. Include an explicit caveat that the guidelines in (2) above will be subject to change depending on the results of the Federal Coalition’s promised wind turbine noise health research and other credible national and international research, which withstands peer review by acousticians and others demonstrably independent of the wind industry’s influence.

4. Measurements of wind turbine noise MUST include the full acoustic spectrum (ie infrasound and low frequency noise), and be conducted using equipment which is capable of collecting accurate measurements, with particular attention to noise floors and capability of microphones.

5. Where residents are complaining of noise nuisance indoor and outdoor full spectrum acoustic measurements MUST be collected and shared transparently with all relevant parties, preferably streamed in real time over the internet.This is currently done in some locations for airport noise via the WEBTRAK system.

6. Where vibration is reported to be perceived by the resident(s), vibration also needs to be assessed with equipment sufficiently sensitive to do so accurately. There are concerns from experienced acoustic consultants and international researchers that in some locations the Australian standard for whole body vibration may be being exceeded, especially when people are perceiving vibrations through the bed whilst lying horizontal in their beds at night.This is of particular concern with respect to increased risk of developing vibro acoustic disease, which can occur regardless of whether resident’s perceive the ground vibrations.

7. The noise pollution regulations MUST be enforced in a timely fashion, with automatic and immediate shut off for exceedences, in order to prevent the regular and repetitive sleep disturbances which some residents are reporting.

8. Where breaches of the noise regulations or the characteristic sleep disturbance are occurring consistently, in predictable weather conditions and wind directions, automatic shut downs of the wind turbines responsible should be programmed in to occur automatically to prevent these predictable occurrences of noise nuisance.

9. Explicitly acknowledge that the current International Standard with respect to turbine separation distances, (IEC 61400) MUST be adhered to, and the development MUST be signed off by an Australian Structural Engineer both pre and post construction to certify that this has specifically been checked, with those two documents signed by an Australian based structural engineer being made publicly available to any interested parties.

The authors of and contributors to your draft guidelines need to be asked explicitly to justify in writing why they have ignored the existing research evidence of damage to health directly caused by infrasound and low frequency noise.

The public (taxpayers) and you as responsible Ministers in relevant portfolios, should know how the professionals you have employed and paid to conduct this work can justify that decision with evidence which overrides the research I have listed above.

We strongly suggest that you as responsible Ministers do your own due diligence on this issue.We suggest you obtain formal peer review of your guidelines from acousticians with expertise in measuring wind turbine noise who are independent of the wind industry, who are also well aware of the serious nature of the health problems being experienced by the residents at existing wind developments in Australia, and the distance of adverse sleep and health impacts, and that you do not allow the careful advice of your government noise experts who are knowledgeable in this area to be ignored.

If you require further information, please do not hesitate to get in contact with me. This letter will be provided to interested parties including Queensland residents who have sought our advice and assistance.

Yours sincerely,
Sarah Laurie, Waubra Foundation CEO

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