Submission to the Scottish National Planning Framework 4 consultation with particular regard Environmental Noise 31ST March 2022
The amended Town and Country Planning (Scotland) Act 1997 directs that the National Planning Framework must contribute to a series of six outcomes: improving the health and wellbeing of our people; increasing the population of rural areas; meeting housing needs; improving equality and eliminating discrimination; meeting targets for emissions of greenhouse gases; and securing positive effects for biodiversity.
My focus and concern is:
(b) improving the health and wellbeing of people living in rural Scotland
I have direct experience that the health and wellbeing is NOT protected in planning when it comes to windfarm applications as currently ‘Net Zero’ is being allowed to usurp negative evidence demonstrated by councils, their experts and third party objectors and their experts against planning consent for wind turbines. This includes the current noise planning guidance ETSU -R-97 which allows councils, reporters and Scottish Ministers to grant consent to operate wind turbines far too close to homes.
Through working closely with experts on noise emissions from wind turbines and through participating in public inquiries into large scale planning applications into industrial wind turbines we have identified and demonstrated that ETSU -R- 97 does not protect the health and wellbeing of windfarm neighbours.
The process the government recommend is used to manage wind turbine noise is still ‘ETSU-R-97 The Assessment and Rating of Noise from Wind Farms’ and its associated ‘Good Practice Guide’. The medical profession were not involved in the development of this process and ETSU-R-97 itself actually confides that its veracity and accuracy are questionable.
Regardless, since ETSU-R-97 was orchestrated 25 years ago, wind turbine size and generating capacity has exponentially increased from 60 metre high machines with a generating capacity of under 1MW, to the current turbines being consented in Scotland of up to 260m high with a generating capacity of up to 5.6MW.
The UK Government Department for Business, Energy and Industrial Strategy recently undertook a scoping review of current UK onshore wind turbine noise assessment guidance.
The FINAL–Scientific_Commentary_on_DBEIS_Scoping_Survey 08-02-2022 (002)(IARO)[i] illustrates the flaws and limitations of the DBEIS scoping review of current UK onshore wind turbine noise assessment guidance.
How can the UK Government and the Scottish NPF4 continue to permit the use of ETSU-R-97 to manage wind turbine noise when its ramifications for public health are unknown?
‘Scientific Commentary on the UK Government’s Department of Business, Energy and Industrial Strategy (DBEIS)’ is a ‘Scoping review of current onshore wind turbine noise assessment guidance.’ (Document number IARO21-6 December). Critical issues, relevant for the well-being of the Scottish population are discussed in this report, which need to be addressed before NPF4 is fit for purpose.
The IARO21-3 White Paper on the Harmonic Prominence Measure v4 March 2021[ii] explains why dBAs are not a suitable means of measuring wind turbine noise.
The increasing negative health impacts on affected residents is already steadily developing into a Public Health crisis across Scotland and it is in this context that I submit the attached Report on Harmonic Prominence and Correlation Dochroyle Pharm Report v11[iii], Ferter Pharm Report v6iv] and Shalloch Well Pharm Report v5b[v] which were part of the noise evidence presented at the Clauchrie Public Inquiry in South Ayrshire. (WIN-370-3)
As demonstrated through the DETERMINATION – DECISION LETTER 16 November 2021 Redacted Determination – PI Report – dated 3 August 2021[vi] to consent Arecleoch Extension (Case reference: WIN-370-2): The Reporters state:
The Scottish Government online policy advice 41 on onshore wind turbines says that ETSU-R-97: “should be followed by applicants and consultees, and used by planning authorities to assess and rate noise from wind energy developments, until such time as an update is available. This gives indicative noise levels thought to offer a reasonable degree of protection to wind farm neighbours, without placing unreasonable burdens on wind farm developers, and suggests appropriate noise conditions.”
“5.91 The online advice also highlights the Good Practice Guide, which is accepted as current industry good practice. We note that the online advice dates from May 2014. Some of the evidence from Ms Crosthwaite predates this, but much of it is from after this date. Nonetheless, the advice remains extant, and Ministers have not, to date, elected to update or amend it. We note the concerns about the deficiency of an approach using ETSU-R-97, but that is the approach that the Scottish Government currently advises should be taken. It is therefore the approach we follow.”
I would ascertain that the time for an update should be part of NPF4 as the only course of action in order to protect public health and wellbeing. How can the planning process be fit for purpose if it allows its rural citizens to be subjected to noise pollution which leaves some families with no alternative but to seek refuge in a camper they drive to a location sufficiently far away from the WT’s so as to be able to have a peaceful night’s sleep. Others have opted to sleep away from their home one night per week (either at friends’ or relative’s homes, or at a local inn or hotel). This is particularly important for the people who already have some prior illness.
Sleep deprivation, headaches, tinnitus, nausea and other digestive ailments, nose bleeds, feelings of constant anxiety are all symptoms reported and recorded by those forced to live in the close proximity of industrial wind turbine developments.
An analogy used is the boxer in the boxing ring. Under infrasound contamination, it is as if you were continuously in a boxing ring. In order to provide some respite to the body, it is necessary that the boxer leave the boxing ring and recuperate. Then, he or she can go back into the ring, but not without some respite, some recovery or recuperation.
The World Health Organisation states in its 2018 Environmental Noise Guidelines:
“Further research into the health impacts from wind turbine noise is needed so that better-quality evidence can inform any future public health recommendations properly.”
“Wind turbines can generate infrasound or lower frequencies of sound than traffic sources. However, few studies relating exposure to such noise from wind turbines to health effects are available.”
“The noise emitted from wind turbines has other characteristics, including the repetitive nature of the sound of the rotating blades and atmospheric influence leading to a variability of amplitude modulation, which can be a source of above average annoyance (Schäffer et al., 2016). This differentiates it from noise from other sources and has not always been properly Characterized.”
“Assessment of population exposure to noise from a particular source is essential for setting of health based guideline values. Wind turbine noise is characterized by a variety of potential moderators, which can be challenging to assess and have not necessarily been addressed in detail in health studies. As a result, there are serious issues with noise exposure assessment related to wind turbines.”
The attached decision letter for Arecleoch Extension demonstrates just how the reporters and Scottish Ministers are able to minimise and dismiss real concerns by councillors, expert witnesses and third-party objectors:
“5.107 We keep in mind Ms Spence’s own experience of noise at her property from the existing wind farms, and the association she makes between that and her ill-health. We also acknowledge Dr Armstrong’s views on that subject. However, whether that association is correct (and, if so, whether or not it is a function of audible sound or infrasound, or both combined), we must return to an assessment based on ETSU-R-97. Noting what it says about offering “a reasonable degree of protection to wind farm neighbours, without placing unreasonable burdens on wind farm developers”, and noting the Scottish Government’s endorsement of that approach, Ms Spence’s experiences do not lead us to recommend that the application be refused on the basis of the predicted noise emissions at Dochroyle Farm.
This approach leaves underfunded and inexperienced councils with ultimate responsibility for the health and wellbeing of people impacted by noise from wind turbines and therefore NPF4 does not perform its required outcome. The windfarms under current guidance can therefore appear to be compliant but there is still a case to answer when windfarm neighbours are suffering therefore ETSU -R-97 does not protect neighbours from noise nuisance.
The Scottish Government (Assembly) solely relies on the ETSU-R -97 wind turbine noise guidance The emails to the Scottish Government and the affected victim’s complaint statements, Wind Turbine Noise Complaints Affected receptors 25- 27 February 2022[vii] , form crucial evidence of the, often repeated outcomes when large scale Wind Power Stations are recommended for consent and subsequently consented, far too close to homes: The Email exchanges between Wind turbine noise victim and Scottish Government. Jan – Feb 2022__[viii] clearly demonstrates how the victim’s impacts are effectively side-lined and it becomes increasingly difficult for windfarm neighbours to gain effective and timely resolution to their justified complaints. This ongoing unacceptable situation is being exacerbated by the ever- increasing size and power of the current turbines proposed and consented.
Justice Richards reaffirms within the Bald Hills judgement: 20220325 Uren v Bald Hills WF 2021 VSC 145[ix] , the significance of the planning balance between the protection of affected residents residential amenity and the deployment of wind turbines by commenting:
“(6) What is the social and public interest value in operating the turbines to generate renewable energy?
The generation of renewable energy by the wind farm is a socially valuable activity, and it is in the public interest for it to continue. However, there is not a binary choice to be made between the generation of clean energy by the wind farm, and a good night’s sleep for its neighbours. It should be possible to achieve both.”