Comments on sections of the Scoping Report and documents and  Site Layout of an Extension to Arecleoch Windfarm

Arecleoch Extension

Review of the Scoping Report and associated documents and points and advise I would like the Scottish Ministers to consider:

1. Landscape
2. Hydrology and Geohydrology
3. Noise
4. Other Matters 

1.Landscape:

This site is far too close to the village of Barrhill and a number of individual rural properties. The general thrust of the guidance is an important material consideration. The area to the north east of the application site boundaries are less than 2 km from the boundary of the village of Barrhill. Although the site itself is on the plateau moorland, the proposed turbines would be experienced as a part of the marginal area, unlike the sense of containment and confinement of the existing Arecleoch wind farm on the plateau. The extension would appear to encroach upon the more settled valley to the north east and be an intrusion. Just as the reporters found in Case Reference WIN-190-1; South Ayrshire Council Development plan landscape guidance does not support the use of the application site as a wind farm.

Residential receptors, those living nearby, would see the turbines as spilling over from the plateau towards them. A number of properties would be affected, but the significant change in the experience of the wind farm would be for those at Knockshin, Dochroyl, Laggish, Mullwhilley, Chimorrie, Farden , Kilrenzie and Weeb. The amenity of those places would be further damaged. Many of these properties have a relatively open outlook in most directions and views of the turbines would not be partially screened by forestry. The proposed turbines would add to the busy clutter of the existing turbines and bring them closer to the house. In cumulative terms, many of these houses, and others further afield have turbines visible in almost every direction. That sense of being surrounded would be made worse by the proposed extension.

Further afield, for those travelling or touring on the A714 would share the experience of local residents. The turbines would loom large and this adds to the unacceptable impacts of the proposed turbines.

2. Hydrology and Geohydrology:

The consent and building of Arecleoch (and Markhill and Kilgallioch) went ahead before the real impact on the Geohydrology from wind turbine construction was known. Scottish Power Renewables were never required to do full base line water quality monitoring for Arecleoch and there have been incidents of pollution of the Stinchar and tributaries that have gone unchallenged, Living in the area on Crailoch Burn, close to the River Stinchar and Water of Tigg, I can testify to pollution incidents – sadly I was unaware of their cause at the time.

Dr Rachel Connor found out that construction activity for the phases of Whitelee 1 and 2 wind developments had caused problems. Each phase of construction was accompanied by an ES, but each of these repeated the flawed assessments which led to contamination issues and resulted in similar inadequate conditions. The ES for Arecleoch, Markhill and Kilgallioch were not materially different in this regard.

In the decision notice for the Whitelee WF 3 Extension, issued only in October 2016, 20 months after the Inquiry, Dr. Rachel Connor was criticised by Scottish Power and the Reporters as being unqualified to draw any conclusions as to how so many water supplies during that windfarm construction were either lost completely (four in total) or suffered serious contamination with sediment and bacteria. The Whitelee Extension 3 Public Inquiry in June 2015 lasted almost a week and dealt largely with the alleged impact, caused by constructing Whitelee WF original and its two Extensions (2006 -2013) on public and private water supplies as well as on surface and groundwater. Permission was ultimately refused for “landscape” reasons. Case Reference WIN-190-1

In the Sneddon’s Law Inquiry case No PPA-190-2058 (another windfarm application affecting the private water supplies around Whitelee), a professional water risk assessment, commissioned by the developer  used the same background geohydrological risks to draw many of the same conclusions as were drawn by Dr. Rachel Connor and her team, at the Whitelee 3 Inquiry. Therefore, doubt cannot be cast on the evidence, the conclusions and the credibility of their experts.

Rural dwellers rely on their private water supplies and usually have no alternative supplies. They are more vulnerable to contamination and pollution than public water supplies. It should not be the case in 21st Century Scotland that our citizens have to fight for the right to protect and maintain their water supplies in a clean and wholesome condition. SEPA has been presented many issues of water contamination from windfarm development including Kilgallioch and Blackcraig windfarm in Dumfries and Galloway. Unless a full independent Geohydrology report is made standard practice with all the correct monitoring, then citizens will continue to become ill as the water environment continues to become contaminated.
Water is a basic human right and a requirement for life. There have been several successful human rights cases based on pollution of PWS in Europe, not just because of pollution by commercial developers but also by local authorities. This is a live issue wherever industrialisation takes place.

 

Sneddon Law WF Private Water Supply Risk Assessment (PWS RA): https://app.box.com/s/61683trl1bryoq9sjlyp1wvffufpk945 Chapter 3.2.5 identifies the same potential effects which actually occurred during the construction of Whitelee windfarms: the contamination of surface and ground water caused by leakage and spills of chemical from vehicle use and groundwater contamination from concrete pouring for turbine foundations within excavated areas, in close proximity to groundwater linked to potential pathways linking the source of the pollution with the receptor.

Again the potential for erosion and sedimentation pollution into surrounding watercourses, during construction, occurs during rainfall events from exposed ground or borrow pit excavation and ground disturbance in the proximity of emergent springs can also cause a deterioration of sub surface water quality.

The last paragraph of 3.2.5 states:

The introduction of impermeable infrastructure and any associated drainage during the construction phase of the Development, may lead to the diversion of flow from upper catchment areas. Whilst turbine foundations will be impermeable, access tracks and material used for the temporary and permanent substation will be of crushed stone and will maintain a level of permeability. Diversion of flow could lead to deterioration in the quantity of water along its original pathway, causing a potential reduction in yield at any abstraction point; and could remain for the life of the impermeable barrier. In addition, excavation from borrow pit construction or dewatering can result in the lowering of the water table. The assessment of ‘drainage’ in this WRA refers to the potential for the Development to alter the direction of natural drainage paths to the source. This could result in a reduced volume of water along the natural drainage path. The potential for an activity to cause a reduction in flow is again based on a combination of the type of flow path, the nature, direction and extent of the activity and local topography. The assessment of this potential risk is based on implementation of good practice throughout all phases of the Development, professional judgement and experience from other relevant projects.

PWSRA Chapter 4.3 Geology and Hydrology again confirms Dr. Rachel Connor’s findings of complicated aquifer flows which are unknown without detailed studies and even then, due to the complex nature of the groundwater, studies should not be taken as a complete reference point as some groundwater pathways will still Not be known.

‘Good practice’, ‘professional judgement, desk studies and experience from other relevant projects’ is jargon used by developers and does NOT provide factual information. How can the developer be allowed to submit an Environmental Statement (ES) which is so deficient that it fails to list almost all the PWS that are deemed to be at major risk of either pollution (loss of quality) or loss of quantity, or loss altogether?  If developers submit Environmental Statements which do not identify ALL PWS at risk, and do not identify ALL watercourses at risk, then how can they be protected?

In Sneddon Law WF Private Water Supply Risk Assessment (PWS RA) many of the PWS at risk were outside SEPA’s designated (LUPG 31) 250m ‘one size fits all’ buffer zone. This is SEPA’s guidance for the minimum distance for a water source to lie from a windfarm related excavation of more than 1 metre in depth (ie borrow pits or turbine foundations.) This rule of thumb is “designed” to provide absolute protection for private water supplies. But it does not do that.

The PWSRA in paragraph 3.2.3 suggests that because searches are based on property location, rather than source location, that the search area is based on a 500m radius from the boundary as it provides ‘a more conservative and precautionary assessment and aims to capture any source locations that are at a distance from the registered property’. It also highlighted the need to consider the fractured nature of the bedrock as potential hydrological pathways and that each PWS needed to be individually assessed and highlighted that assessment should be driven by localised hydrological and hydrological conditions and not restricted to the LUPS-GU31 SEPA guidance of 100m and 250m.

The stated major risks of affecting water quality not only risks public health by virtue of contaminating water, but it risks the welfare and business of farm animals and wildlife, which is dependent on clean water.

If Water supplies are affected, it will be because groundwater is either contaminated or groundwater flows have been altered by quarrying or construction. These effects are likely to last months and may be permanent. Such changes are contrary to the Water Framework Directive and transposed Scots Law.

Sneddon Law Wind Farm Decision PPA-190-2054

The Inquiry statement from the recent Sneddon Law windfarm PWS Enforcement appeal Inquiry from the consultants (Natural Power) employed by Community Power Ltd. (All documents related to this enforcement appeal can be found on ENA-190-2009.
The Reporter has not yet issued her decision)
Natural Power Ltd needed to drill 8 replacement boreholes for PWS badly affected by building the SW Scotland Interconnector (similar construction to windfarms by their own admission). These new boreholes were all unplanned and reactive, as far as was ascertained from evidence given under oath at the inquiry, ie. no risk assessment had been done beforehand which predicted trouble and PWS spring water was affected well outside SEPA guidelines for at least one property affected by road construction (buffer zone recommended 100m) – their spring was more than 500m from a new access road.

 

I would therefore conclude that a fully Independent Geohydrology report is essential for Arecleoch Extension should the application be allowed to proceed. The site is totally within the River Stinchar Protected Water catchment Area (attachment 1) and the Water of Tigg, a very important tributary rises and runs through the centre of this proposed site.  

 

All the following which should NOT be scoped out:

Matters Scoped Out

At this stage, it is proposed that the following can be scoped out of detailed assessment:

 Detailed Flood Risk Assessment. Published mapping confirms that most of the Site is not located in an area identified as being at flood risk. It is proposed, therefore, that a simple screening of potential flooding sources (fluvial, coastal, groundwater, infrastructure etc.) is presented in the EIA Report and measures that would be used to control the rate and quality of runoff will be specified in the CEMP.

During the construction and early operation of Arecleoch original there were many incidences of spate flooding of the tributaries including the Tigg and Crailoch causing the Stinchar to flood. Ancient woodland and especially Craig wood an SSSI line the valleys of these tributaries and will be particularly susceptible to damage from  flooding incidents. Pollution from this development will be unavoidable as the site lies totally within the River Stinchar Catchment and as such should be protected from developments causing pollution.

The Southern Upland Fault lies North West of this development and has been completely ignored by SPR in all Arecleoch scoping reports: Attachment 2: Extract from sheet 7BGS Girvan.

Fault lines (cracks caused by fracturing such as earth quakes) and dykes (caused by an igneous intrusion from the centre of the earth) are dominant in much of Scotland but are very much ignored by the competent authorities and wind developers. They can have an important impact on the aquifer allowing water to flow in a different direction to the topography. This means that without extensive borehole testing there is no way of knowing the relationship between dykes/fault lines and aquifers. The FOI below clearly illustrates that this essential information is not monitored, therefore there is NO way of identifying the integrity of water networks let alone how they influence rivers and burns and PWS.

FOI Ref: FOI85279 Q. 8. Is SEPA monitoring the relationship between dykes/fault lines and aquifers?

  Q8. SEPA is not monitoring the relationship between dykes/fault lines and aquifers therefore we do not hold any monitoring data.

The fault acts as a pathway across the North West of the site of this extension and Arecleoch original development enabling possible pollution events into the Water of Tigg, Burns- Mid, Seurran, Dunnack, Crailoch Leana, Alligbert and Water of App. This has huge consequences for the aquatic environment.

An independent Geohydrological review from Dr. Steve Carroll (S.Carroll, Whitelee windfarm hydrogeology summary, 2015) comments on the presence of faults and Dykes:

Lavas of the CPV formation elsewhere in central Scotland often show zonesporous and permeable sedimentary rocks or broken up lava at the junction offlows of different age. These zones could form very localised aquifers and allow more rapid groundwater flows than would occur in fractured basalt that form most of the lava flows. These narrow aquifers and potential water channels through fractures are also more difficult to predict from an overall geological map. It is understood that with this this type of geology, where the structure of layers and fractures is unknown in detail, it can be practically impossible to predict the path, depth and quantity of groundwater with any confidence (Groundwater and its susceptibility to degradation.2003). Furthermore, the confined and limited aquifers, high water table and narrow unsaturated zone of soil or peat means this type of geology and ground structure is particularly susceptible to pollution.

 Water Quality Monitoring. Classification data is available from SEPA for the watercourses at Site and, other than forestry, there are no known sources of potential water pollution at Site that might give rise for the need for water quality monitoring as part of the EIA Report. Water quality monitoring may be required and undertaken prior to, during and post construction if the project were to be granted planning permission.

Diagram 1. below illustrates the potential for pollution:

 

Jacobs was commissioned by SPR to undertake a programme of groundwater monitoring and sampling, laboratory testing and subsequent assessment and reporting at the original Whitelee Windfarm site during its construction. The aim of the work was to provide data to assist in the assessment of whether the windfarm development was having any impact on local groundwater quality.

The windfarm was officially opened and became operational in May 2009. Following the completion of the construction works, Scottish Power commissioned Jacobs to undertake a further round of groundwater sampling and laboratory testing for comparison with the previously collected data.

It was recommended that during any such Phase 2 groundwater monitoring, bi-annual monitoring of the boreholes within the Phase 1 area is also undertaken and the data reassessed on a yearly basis. During this monitoring it is recommended that phenols at WP01 are specifically targeted and subjected to further assessment and review.

This was conveniently hidden and no such subsequent monitoring occurred.

Groundwater pollution prevention measures cost 10–20 times less than groundwater clean-up and aquifer remediation programmes.  The importance of water quality monitoring cannot be stressed. If no boreholes are drilled or groundwater testing requested from the developer by planning or regulatory authorities, even in relation to assessing impacts to groundwater from potentially polluting activities such as quarrying, the importance of potential pollution pathway into shallow groundwater through superficial deposits or to deep groundwater through rock fractures is not adequately assessed.

CIRIA 352 is regarded as a key reference in guiding construction methodology and SPR makes reference to complying with CIRIA recommendations in its construction mitigation methods.(Planning condition 6.4 WL Extensions) CIRIA 352 states with regard to avoiding pollution 2.5.3 : Piling, in particular vibro-replacement piles forms a direct flow pathway down columns of granular material for contaminated water and leachates to potentially move into an underlying aquifer both during and after construction.

Blasting for quarries, turbine bases and access roads can further fracture the bedrock and form pathways direct to the aquifers (see diagram 1).  Quarry sites are selected for their easy access to the bedrock and are often at the top of a water catchment area. They are continuously used by heavy contract vehicles such as bulldozers and excavators etc. (which require fuel and oil etc.). Any spillage could find its way directly to the aquifer through a fracture with no potential to mitigate.

‘Repowering onshore wind farms: a technical and environmental exploration of foundation reuse.’ ‘A Carbon Landscape and Drainage’ has relevance.

Knowledge Exchange Network-led report, project managed by ‘Construction Scotland Innovation Centre’ – Section 7 on The Environment Considerations should be taken into account by the ministers.

 Detailed Groundwater Dependent Terrestrial Ecosystems (GWDTE) Assessment. As the Site is currently used for commercial forestry it is not expected that a standalone or detailed GWDTE assessment will be required or warranted. National Vegetation Classification (NVC) data will be used to assess for potential areas of GWDTE, but at this stage no detailed assessment is expected.

Forestry Commission Scotland

Nisbet (2001) stated that the major water quality concerns associated with commercial forestry are increased turbidity and sedimentation due to the soil disturbance accompanying cultivation, drainage, road construction and harvesting operations; and the enhanced capture of acid deposition by forest canopies resulting in further acidification of surface waters.

The deforestation in preparation for windfarms is clearly linked with increased C and P concentrations and export in stream water.

Aquatic Carbon Loss

Accelerated forest clearance in preparation for windfarms cannot be separated from windfarm development as it would simply NOT be felled in this way other than to facilitate clearance for the industrial windfarm. Therefore the water contamination associated with forestry clearance has to be considered as part of the windfarm development.

The following research which I would like to submit as further evidence (it supports evidence from Murray 2012; Waldron et al. 2009 ): “Understanding aquatic carbon loss from upland catchments in south west Scotland during land use change from commercial forest to wind farm” by Melanie van Niekerk 2012 Submitted to the School of Natural Sciences Biological and Environmental Science University of Stirling Scotland.

https://www.windsofjustice.org.uk/wp-content/uploads/2016/12/MA-van-Niekerk-PhD-Thesis-2012.pdf

This research provides one of only three studies to investigate concentrations and fluxes of dissolved organic carbon DOC in water courses draining land subject to disturbance relating to wind farm construction. It is the only study that incorporates a period of time prior to work beginning and takes in the whole of the development phase. In this respect it provides a valuable addition to our understanding of the way in which peatlands respond to land use change and may provide useful tools to assist developers in minimising the impact of their activities on these valuable carbon stores.

This research has:

1. Added three new catchments to the detailed knowledge base of DOC concentrations and fluxes from UK peatlands. It has also presented some of the highest known values for such areas. It also provides one of only four studies to investigate concentrations and fluxes of DOC in water courses draining land subject to disturbance relating to wind farm construction (Grieve & Gilvear 2008; Murray 2012; Waldron et al. 2009);
2. Confirmed the persistence and dominance of the seasonal pattern of DOC through a period of land use change and shown how the pattern was modified by two harsh winters;
3. Highlighted at the catchment scale an impact from wind farm development on DOC concentrations and fluxes;
4. Elucidated some activities that led to elevated DOC concentrations and fluxes, for example turbine base installation and forest harvesting;
5. Introduced activity scores as a novel means of attributing changes in DOC to the type and intensity of development activity; and
6. Used E4/E6 ratios as a way of detecting changes to DOC composition resulting from land use change.

This piece of research is highly relevant both by providing valuable information on the construction effects on the area of Arecleoch and confirming the impacts of forestry and windfarm construction on its water environment.

 Priority 1 Peat Habitat. The extent of the priority Peatland habitat identified on Site is located in the north eastern corner of the Site and as a consequence of its sensitivity and in conjunction with a number of other constraints will not be considered as part of the developable area.

 

This site is an area of peatland and historically, drainage ditches were used to lower the water table in an attempt to make peatland more suitable for farming or forestry (Armstrong et al., 2009). The water table is naturally high on peatland and lowering it, in the first instance, changes the ecology of a peatland by simplifying the micro-topography and species composition of the bog (Lindsay, 2010). A very small change in water table can result in substantial alterations to the bog moss communities (Lindsay, 2010). Reducing the water table also exposes peat to more aerobic conditions (altering the microbial community) which increases decomposition and mineralisation rates (Holden et al., 2007; Anderson et al., 2013). Increased mineralisation from the underlying mineral material (not the peat itself) would result in the leaching of nutrients (calcium, magnesium, manganese, aluminium and potassium) and increases in suspended sediment (from erosion), ammonium and Dissolved Organic Carbon (DOC) in water ways (Leeks & Roberts, 1987; Duxbery & Peverly, 1978; Holden et al., 2007; Worral et al., 2007). The hydrological response of peatland also changes with the lowering of the water table as water pathways change. In undisturbed peatland, most water movement occurs in the upper acrotelm layer (the living plant layer) and is controlled by the amount of water held there (NE, 2010). However, lowering the water table can result in the settlement of peat (drying) and a reduction in its porosity (Holden et al., 2007). This leads to a reduction in the storage capacity of the peat and faster discharge of water as it and the acrotelm layers ability to store water will be reduced. Ditches create more sub-surface storage but they also provide a rapid conduit for run-off (Holden et al., 2006; Ballard et al., 2012) which results in changes in the volume of runoff (Leeks & Roberts, 1987) and the frequency of flooding peaks (Holden et al., 2004; Ballard et al., 2012). However, the magnitude of change is variable and is linked to factors that include; density of ditches, the soil properties of the specific peat and the slope of the site (Holden et al., 2004; Lane & Milledge, 2013). In addition, drainage can increase the occurrence and or efficiency of naturally occurring soil pipes (tubes within the peat that can transport water) which can further increase sedimentation and runoff (Holden et al., 2007).

Another potential consequence of drainage ditches at wind energy facilities on blanket bogs is the risk of peat slides. These have been recorded at a number of wind energy facilities in Ireland and Britain (e.g. Derrybrien, Co. Galway and Garvagh Glebe, Co. Leitrim) and the construction of drainage ditches associated with roads have been linked as a secondary causal factor (Lindsay & Bragg, 2005 ; Long et al., 2011b). In their paper classifying peat movements, Dykes & Warburton (2007) define a peat slide as “failure of blanket bog involving sliding of intact peat on a shearing surface at the interface between the peat and the mineral substrate material or immediately adjacent to the underlying substrate” (Tosh, D.G., Montgomery, W.I. & Reid, N. (2014). ‘A review of the impacts of wind energy developments on biodiversity’. Report prepared by the Natural Heritage Research Partnership (NHRP) between Quercus, Queen’s University Belfast and the Northern Ireland Environment Agency (NIEA) for the Research and Development Series No. 14/02).

Forestry and peat are the two main sources of carbon capture and much of our forestry and peat lands are integrated needing real protection. The Scottish Government’s energy policy of industrialising our forests and peatlands is releasing vast quantities of CO2 into the atmosphere See Ramsar protection

https://www.youtube.com/watch?feature=player_embedded&v=ZcxZ9gvNfSU

Draining peat is the equivalent of burning fossil fuels. Draining an area of peat the size of a football field (the base for each individual windturbine) releases the same amount of CO2 as driving a family car 3x round the world.

The deforestation and loss of peat that has already occurred in Scotland to facilitate wind energy production, is a vast loss of a natural, irreplaceable, major carbon store; a complete contradiction, when reducing CO2 emissions is apparently the goal of installing windfarms.

It takes thousands of years to create the depth of peat that will be been excavated. It is naïve to believe that the damage caused will be mitigated in just a few years. It is ironic that in trying to encourage renewable energy generation, developers are succeeding in tearing up areas of natural carbon regulation unsurpassed by anything in human technology. Forests and the sphagnum moss, which drives peat formation, holds significant amounts of water and releases it only slowly. This means it is held for long periods in the uplands before it finally filters towards the lowlands, so providing a degree of natural regulation which helps prevents downstream flooding also purifying the water before it enters the reservoirs and the rivers. Industrialisation, on this massive scale, of these pristine protected water catchment zones has led to deteriorating water quality for many people in Scotland. This is industrial scale exploitation of designated water catchment areas.

 

3. Noise:

South Ayrshire Council and Dumfries and Galloway Council have received many Noise complaints from residents living in close proximity to wind developments including Arecleoch. These have risen substantially since the operation of Kilgallioch began. This extension will just add to the cumulative effect.

Loss of amenity through noise pollution suffered by people living in close proximity to industrial wind turbines is a cause of misery and deteriorating health.

A large number of rural properties and the community of Barrhill have the potential to be severely affected by the Arecleoch Extension industrial development. Legal regulations only cover ETZU 97 -volume of sound emitted and not the character, the frequency, and the impulsive, cyclical nature of the acoustic emissions. The regulations are inadequate as the new WHO Noise Guide line illustrate and they fail to include infrasound, low frequencies and high frequencies. The Scottish Government should now insist that a full range of noise monitoring be included in the Environmental Statement as described below:

 

ETZU 97 only measures audible noise – above 40 dBA – the black line in the graph above. The actual noise pollution which the body is exposed to is shown all the other colours in the graph above.

 

Professor Mariana Alves-Pereria of the Lusofona University in Portugal has degrees in physics and biomedical engineering, and a PhD in environmental science. Her team has been researching vibroacoustic disease since 1980, initially focused on the low frequency noise that adversely affected the health of aeronautical technicians. Professor Mariana’s presentation in Slovenia explains these diagrams, the science and the physiological effects, and why this is so very important to human and animal health

https://www.youtube.com/watch?v=ZXCZ3OyklrE

 

This peer reviewed paper by Mariana Alves-Pereira concluded that noise regulations need updating to reflect noise levels that endanger human health.

http://www.engineersjournal.ie/2018/01/23/ilfn-infrasound-low-frequency-noise-turbine-health/

 

The conclusions:

Accredited acousticians cannot ascertain compliance levels for ILFN because there are none – the vast majority of regulations worldwide do not cover this part of the acoustic spectrum. Nevertheless, public health officials and agencies should fulfil their job descriptions by becoming aware of the limitations of current noise guidelines and regulations.

Alternatives exist to gather the acoustic information relevant to the protection of human populations, in both occupational and residential settings. Noise regulations and guidelines need urgent updating in order to appropriately reflect ILFN levels that are dangerous to human health.

Home 1: A-weighting, 1/3 octave bands (0.5-4000 Hz), 10-minute average – Red Channel

Fig 4: Data covers a 10-minute interval analysed between 0.5-4000 Hz, in 1/3-octave bands, as recorded in Home 1, on 10 October 2017, at 18:30 (red microphone, i.e. inside child’s bedroom-2).

The red bars are A-weighted values, while the gray bars indicate the acoustic energy that is, de facto present, in dBLin. In this environment, the human being would perceive through the ear an overall A-weighted pressure-level of approximately 34 dBA (Tot – red bar), while being concomitantly exposed to an overall acoustic pressure-level of approximately 74 dBLin (Tot – grey bar).

 

 

 

Home 1: A-weighting, 1/3 octave bands (0.5-1000 Hz), 10-minute average – Red Channel

Fig 5: Data covers a 10-minute interval analysed between 0.5-1000 Hz, in 1/3-octave bands, as recorded in Home 1, on 10 October 2017, at 18:30 (red microphone, i.e. inside child’s bedroom-2). The red bars are A-weighted values, while the gray bars indicate the acoustic energy that is, de facto present, in dBLin. In this environment, the human being would perceive through the ear an overall A-weighted pressure-level of approximately 26 dBA (Tot – red bar), while being simultaneously exposed to an overall acoustic pressure-level of approximately 74 dBLin (Tot – grey bar).

Home 1: No weighting, 1/36 octave bands (0.5-1000 Hz), 0.2 s average – Red Channel

Fig 6: Sonogram that covers the same 10-minute interval (600 s) as in Figs 4 and 5 showing time-varying features. The colour-coded bar on the right indicates sound pressure level values in dB Linear (no weighting). The horizontal line seen at 20 Hz is not a continuous tone because over the 600 s, its pressure level (colour-coded data) varies. A strong (yellow) acoustic phenomenon can be seen to exist at 1.6 Hz and also at 0.8 Hz.

Fig 7: Periodogram covering the same 10-minute interval (600 s) as in Figs 4-6, and analyzed between 0.5-1250 Hz. The blade pass frequency of the IWT is 0.8 Hz. Harmonics of this fundamental frequency are shown in the figure. Each frequency band composing the harmonic series has a well-defined peak, e.g., the horizontal line seen in Fig 7 at 20 Hz is represented here as a peak at 20 Hz.

As stated, pressure waves are not constant, they vary in time and frequency. The WHO calls noise “inanimate mechanical forces” which you may or may not hear. What is the difference between the low frequency noise which we cannot hear and the audible noise that we can hear? It is the difference between the sound waves, the peaks. Low frequency noise has a very large distance between the peaks and audible noise has a very short distance between the peaks. Low Frequency noise can travel further and can penetrate the ground and buildings.

 

SPR are well aware that noise pollution is already a problem for many homes and some residents are already complaining of health issues in the area. This extension will put them under further constant bombardment from this mechanical acoustical pollution. The LFN waves can penetrate and resonate in homes in the same way as sound resonates from a loud speaker.

Many of the properties are down-wind of the turbines under prevailing wind conditions and audible noise and amplitude modulation will be a problem too.

The topography also dictates the intensity of the noise pollution and many of the homes are in the valley/basin where the LFN from the cumulative surrounding wind turbines will resonate off each other and magnify these inanimate mechanical forces in the homes.

http://publicaccess.south-ayrshire.gov.uk/online-applications/files/391473C6297E5D1855926AF0FE980B4D/pdf/14_00764_APPM-ES_Addendum_-_Vol_4_-_Appx_4a_-_LVIA_Figures__Fig_13_-507952.pdf

illustrates just how many industrial wind turbines are within the whole area, especially within 10km. It is a serious problem for the health of our environment, not just for people, but for animals, birds, and bats and the whole ecology of the Biosphere.

Quote from:

 

Castelo Branco NAA, Alves-Pereira M, Martinho Pimenta A, Reis Ferreira J.

Clinical protocol for evaluating pathology induced by low frequency noise exposure. EuroNoise 2015, Maastricht, The Netherlands, 31 May-3 Jun, 6 pages.

[considered a non-peer-reviewed paper as it was presented at a conference called Euronoise (in 2015]

“4. Health Impact of ILFN Exposure

Over the past decade, the health impact of ILFN exposure has taken on a new life due to the worldwide energy crisis and the urgent implementation of numerous industrial wind turbines (IWT), as decreed by many governments.

 

Since little regard was initially given to the ILFN generated by these devices, it was not long after their installation that families living in their vicinity began having complaints. Recognizing the problematic situation, several agencies and institutions worldwide began conducting studies and publishing papers with titles suggesting that health impacts were being evaluated among these residential populations.

 

However, upon a closer examination, significant design flaws rendered most of these studies useless [31, for example]. While this may not have been a concerted effort, it is however a consequence of the perpetuation of an historical fact: acousticians, usually with no medical background, are generally greatly involved in noise-impact study designs.

 

Therefore, information on the “health impacts,” as rudimentarily obtained through questionnaires or interviews, is often deemed sufficient in order to establish whether or not ILFN is, de facto, having an impact on the health of human populations. Objective clinical evaluations of families and animals living in the vicinity of IWT are not commonly performed.

 

ILFN is a physical agent of disease, and infrasound (<20 Hz) is internationally classified as non-ionizing radiation. The type of toxicological effect and the evolution and onset of disease caused by ILFN exposure is partially analogous to that caused by radiation.

 

As with radiation exposure,

1. a) the onset of ILFN-induced disease greatly depends on time-exposure patterns; b) different wavelengths of the physical agent affect different organs and tissues; c) the individual need not perceive the agent of disease for a pathological effect to occur within the body; and
2. d) prior exposure histories are a determining factor of key importance.

These facts must condition the design of studies purporting to evaluate the health impacts of residential ILFN exposure; but currently, they do not.

 

It is recognized that there is an added cost to conducting real clinical studies among ILFN-exposed populations. The next obvious question, though, is: what is the added cost associated with continuing with the status quo. While this issue is way beyond the scope of this paper, it is nevertheless pertinent to recall episodes in humanity’s recent history, having to do with asbestos, smoking and pesticides.

 

5. Looking Forward

In the interest of becoming a responsible and mature human society, activities that are deleterious to human health and wellbeing should not be hidden, obfuscated, or otherwise camouflaged. History unequivocally demonstrates the benefits of dealing outright with any potential human-health issue.

 

It is recognized that the production of electrical energy has become the warp and woof of modern societies, and hence the urgency to procure new ways of harvesting energy that can be rapidly (and inexpensively) transformed into electrical energy.

There need not be, however, such antagonistic, acrimonious and spiteful endeavors between ILFN disturbed families and industry, be it in of the energy, transportation, military, entertainment or manufacturing sectors of society.

 

Having contextualized the issue, it is therefore of paramount importance that the clinical parameters used to evaluate the specific type of pathology caused by excessive ILFN exposure be the most appropriate for the job.

Audiometry, electrocardiography, cortisol levels, and number of nighttime arousals are remarkably imprecise measures to clinically evaluate the adverse health impacts of noise exposure.

Whether transverse or longitudinal epidemiological studies are planned, the clinical parameters required to ascertain the extent of ILFN-induced pathology have herein been outlined. It is hoped that this report will contribute to a symbiotic relationship between the ILFN-generating industries and world citizens.”

[31] Executive Office of Energy and Environmental Affairs of the State of Massachusetts, USA: Wind turbine health impact study: Report of an independent expert panel. January 2012.

www.mass.gov/eea/docs/dep/energy/wind/turbine- impact-study.pdf

 

Also, evidence given by Dr. John Yelland and Melvin Grosvenor in support of those suffering from ILFN in the Fairlie Community of North Ayrshire was latterly supported by NAC councillors; it looks like the Hunterston turbines will now decommissioned: http://www.largsandmillportnews.com/news/16239757.Hunterston_test_turbine_site_hits_trouble_just_months_after_receiving_permission_for_a_two_year_extension_/ SSE are well aware that there is a problem from the turbines and that the Fairlie community will continue to fight it. This way they do not have to admit to a problem and no president is set.

Noise complaints from wind turbines are a problem which many Councils are failing to deal with for the reasons described above. The policy, of asking the perpetrator such as SPR, and SSE to produce results of noise pollution, is failing the victims who are subjected to noise abuse. Homes have been abandoned and bought out in Assel Valley (Kay Siddell and the Baldwins); since Kilgallioch became operational, Pat Spence, Andy and Lorraine Sinclair and Heather Bourne are all complaining about noise issues and have all had equipment installed for over twelve months without any worthwhile results. The equipment is deemed either faulty or there is some problem preventing correct results from being analysed. These people are living in torturous conditions from which they cannot escape, ruining their amenity and their health. The development of yet more turbines is just going to exacerbate the problem and subject even more people to noise pollution.

In October 2018 the World Health Organisation published its new Noise Guidelines.

Compared to previous WHO guidelines on noise, this version contains five significant developments:

• stronger evidence of the cardiovascular and metabolic effects of environmental noise;
• inclusion of new noise sources, namely wind turbine noise and leisure noise, in addition to noise from transportation (aircraft, rail and road traffic);
• use of a standardized approach to assess the evidence;
• a systematic review of evidence, defining the relationship between noise exposure and risk of adverse health outcomes;
• use of long-term average noise exposure indicators to better predict adverse health outcomes.”

“These guidelines have been developed based on the growing body of evidence in the field of environmental noise research,” concludes Professor Stephen Stansfeld, Chair of the Guidelines Development Group. “They aim to support public health policy that will protect communities from the adverse effects of noise, as well as stimulate further research into the health effects of different types of noise.”

 WHO European noise-guidelines-10-10-2018.pdf Important and related references to wind turbines

Very important references selected below. All extracts from WHO Environmental Noise Guidelines for the European Region 2018 in italics (Bold and underlined is my emphasis)

Synopsis of WHO Noise Guidelines with reference to wind turbines

Page 85:

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. It is also unknown whether lower frequencies of sound generated outdoors are audible indoors, particularly when windows are closed.

Standard methods of measuring sound, most commonly including A-weighting, may not capture the low-frequency sound and amplitude modulation characteristic of wind turbine noise (Council of Canadian Academies, 2015)

Page 86:

Based on all these factors, it may be concluded that the acoustical description of wind turbine noise by means of Lden or Lnight may be a poor characterization of wind turbine noise and may limit the ability to observe associations between wind turbine noise and health outcomes.

Balance of benefits versus harms and burdens

Further work is required to assess fully the benefits and harms of exposure to environmental noise from wind turbines and to clarify whether the potential benefits associated with reducing exposure to environmental noise for individuals living in the vicinity of wind turbines outweigh the impact on the development of renewable energy policies in the WHO European Region.

Additional considerations or uncertainties                                                                     

There are serious issues with noise exposure assessment related to wind turbines.

Page 100:

4.2 Implications for research on health impacts from wind turbine noise

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. For the assessment of health effects from wind turbines, the evidence was either unavailable or rated low/very low quality.

Exposure of interest: Exposure to noise at a wide range of levels and frequencies (including low-frequency noise), with information on noise levels measured outdoors and indoors (particularly relevant for effects on sleep) at the residence is needed. The noise exposure should be measured objectively and common protocols for exposure to wind turbine noise should be established, considering a variety of noise characteristics specific to wind turbine noise.

Page 103:

The studies should use measures of exposure including noise exposure at a wide range of levels and frequencies (including low-frequency noise), with information on noise levels outdoors and indoors (particularly relevant for effects on sleep).

 

Page 106:

The fourth principle is to inform and involve communities that may be affected by a change in noise exposure.

Page 110: 5.6 Route to implementation: policy, collaboration and the role of the health sector

promoting the guidelines to health practitioners and physicians, especially at the community level (through associations of physicians, cardiologists and so on as part of the stakeholder group);

 

Noise is an important public health issue. It has negative impacts on human health and well-being and is a growing concern. The WHO Regional Office for Europe has developed these guidelines, based on the growing understanding of these health impacts of exposure to environmental noise. The main purpose of these guidelines is to provide recommendations for protecting human health from exposure to environmental noise originating from various sources: transportation (road traffic, railway and aircraft) noise, wind turbine noise and leisure noise. They provide robust public health advice underpinned by evidence, which is essential to drive policy action that will protect communities from the adverse effects of noise. The guidelines are published by the WHO Regional Office for Europe. In terms of their health implications, the recommended exposure levels can be considered applicable in other regions and suitable for a global audience.

I and others in the community will be acting upon these recommendations and I hope that Scottish Ministers will do likewise.

 

4. Other Issues:

No wonder Scottish Power Renewables want to extend Arecleoch, and other wind development sites when they are being paid so much to switch off their turbines. Please see the attached payments to Arecleoch, Kilgallioch and Markhill. I would conclude that Arecleoch Extension is completly superfluous to requirement when so much of the time they are paid not to produce power. Please see details in the article below.

Scottish power’s £107m to switch off turbines- Daily Express 25^th November 2018

By Ben Borland

 

Scottish Power was paid £107million for switching off its wind turbines during a three-year delay in completing an undersea cable project which was supposed to solve that very problem. The £1billion Western Link from Ayrshire to North Wales was specifically designed to prevent so-called “constraint payments” by allowing more Scottish green electricity to reach consumers in England.

 

Previously huge amounts of energy from Scotland’s wind farms became stuck in a bottleneck at the Border, resulting in operators being paid millions of pounds to shut down – and the cost being passed on to household bills.

The new high voltage link, a joint venture between SP Energy Networks and National Grid, was commissioned in 2012 and the project was supposed to be completed by December 2015. However, a series of major problems delayed the start for two years and it then operated at a reduced capacity until last May when it was shut down again before finally coming online on October 16.

 

According to figures compiled by the Renewable Energy Foundation (REF), Scottish wind farm operators received £267million in constraint payments during that period.

 

Remarkably, ScottishPower Renewables – another division of the company which was partly responsible for delivering the Western Link – received £107million for switching off turbines at 14 of its 24 wind farms.

 

REF director Dr John Constable said: “It is not possible to say how much of these consumer costs could have been avoided if the interconnector had been built on time. And it is still too soon to say how effective the Link will be in reducing constraints.

 

“After all, since it came online fully on October 16 there have been Scottish constraints to the tune of £8.8million, which is a large sum in absolute terms. That cost compares to £16million, £7million and £14million in the same period for 2017, 2016 and 2015, so it seems reasonable to say that while the interconnector is reducing constraint costs it has not fixed the problem.”

 

He added: “There are two big questions here. Firstly, will National Grid and Scottish Power be fined for late delivery and the constraints that were not prevented? Secondly, and this for me is the really important one, is the cost of the interconnector significantly less than the constraint payments it is preventing?”

 

Almost half of the constraint payments – around £49million – paid to Scottish Power during the three year delay in opening the Western Link were for shutting down production at Whitelee in Renfrewshire, one of the world’s largest onshore wind farms.

 

In addition, Black Law in Lanarkshire, Harestanes in Roxburghshire and Arecleoch in Ayrshire were paid around £14million, £11million and £10million respectively for switching off their turbines.

 

Ofgem, the UK electricity regulator, said in May 2016 it would “consider options to prevent ScottishPower Transmission and National Grid Electricity Transmission from benefitting financially from project delays with a view to protecting consumers’ interests”.

 

A spokesman added: “The Western High-Voltage Direct Current Link is now operational and we are in the process of assessing whether the relevant parties took reasonable and efficient steps to mitigate the risk and impact of any delays.

 

“If relevant licence conditions have not been complied with then we may consider taking enforcement action, this could include financial penalties, redress payments or a combination of both.”

 

Glasgow-based Scottish Power is a wholly owned subsidiary of Spanish firm Iberdrola. Its retail arm supplies gas and electricity to 5.2million consumers in the UK, its transmission arm owns the electricity network in southern Scotland, Merseyside and North Wales and its generation arm owns wind farms, coal power stations and hydro schemes.

 

A spokesman said: “The Western Link, developed by National Grid and SP Energy Networks, was switched-on in December 2017 and is currently in operation. SP Energy Networks is the regulated part of our business and a completely separate entity from ScottishPower Renewables. National Grid, as system operator, manages the flow of electricity across the UK and the constraints process.”

 

 

I would just like to clarify that there are two distinctly different forms of payment by the National Grid (NG) to generating companies – one is called by the NG “Payments to Rebalance System” (largely paid to gas and coal generation to counter intermittent and unpredictable, weather dependent, wind generation ) and the other “Payments to Manage Constraint” (mostly paid to wind generators). This is clearly clarified in the NG MBSS monthly reports – see http://www2.nationalgrid.com/UK/Industry-information/Electricity-transmission-operational-data/Report-explorer/Services-Reports/ Further, if she cares to look back over earlier NG MBSS reports she will see that constraint payments to wind generators have been increasing and not reducing as she claims.

 

Not only are constraint payments adding to the burden for households and businesses, but the cost of green subsidies continues to rise and will cost £66.1bn in the next five years, approximately £2500 for every household in the country, according to the latest figures from the OBR.

 

2.7 Environmental levies
	£ billion
	Outturn	Forecast
	2017-18	2018-19	2019-20	2020-21	2021-22	2022-23	2023-24
CRC Energy Efficiency scheme	0.5	0.5	0.5	0.0	0.0	0.0	0.0
Warm home discount1	0.0	0.3	0.3	0.4	0.4	0.4	0.4
Feed-in tariffs1	0.0	1.5	1.5	1.6	1.6	1.6	1.7
Renewables obligation	5.4	6.1	6.1	6.4	6.5	6.7	6.9
Contracts for difference	0.6	1.0	1.7	2.3	2.7	2.9	3.0
Capacity market1	0.0	0.7	1.0	1.3	1.0	0.9	1.2
Environmental levies	6.5	10.2	11.2	11.8	12.2	12.4	13.1
Memo: Expenditure on renewable heat incentive (RHI)	0.7	0.9	1.0	1.1	1.1	1.1	1.1
Note: The ‘Environmental levies’ line above is consistent with the ‘Environmental levies’ line in Table 4.6 of the October 2018 Economic and fiscal outlook.
1 The ONS have yet to include Warm Home Discount, Feed-in Tariffs and Capacity market auctions in their outturn numbers. If they were included, they would have been £0.3bn, £1.4bn and £0.2bn respectively.

https://obr.uk/efo/economic-fiscal-outlook-october-2018/

 

I do not think that this application should be allowed to go ahead. The damage it will cause to far out-weighs any benefits.

 

30^th November 2018