Right to reply. PES: North America

Transcription

1 Right to reply The Canadian Wind Energy Association (CanWEA) recently filed comments with respect to a proposed Health Canada study, Health Impacts and Exposure to Wind Turbine Noise: Research Design and Noise Exposure Assessment, to be undertaken in collaboration with Statistics Canada. Here, PES looks in detail at the issues raised by the proposed study, and the association s response The Canadian Wind Energy Association (CanWEA) is the voice of Canada s wind energy industry, actively promoting the responsible and sustainable growth of wind energy on behalf of 400 members. CanWEA monitors and reviews all credible sources of information related to wind energy. CanWEA, in its thorough review of the materials posted by Health Canada for public comment, has significant concerns related to the proposed methodology and the scope of this study as it was presented. Many of these concerns, CanWEA believes, were fundamental. It is the opinion of CanWEA that substantial modifications to the proposed methodology and study design would be required to ensure the results of the study make a useful contribution to the significant volume of global scientific literature already in existence. CanWEA has submitted comments in the following areas: treatment of annoyance; participant and project selection; treatment of control groups; the lack of demonstrated ability to account for the prevalence of reported symptoms and bias; the proposed sound modeling and measurement procedures; the poor amount of research cited; and the lack of a commitment to compare results (e.g., executing a risk assessment) between wind energy and other sources of community concern or known health/environmental impacts. While it may be the case that the concerns of CanWEA are mainly attributable to the lack of detail provided by Health Canada (meaning, areas where concerns have already been accounted for, but not yet articulated by Health Canada), CanWEA has requested the study team provide a formal response to the concerns that have been raised and then re-issue a revised study design and methodology with much more detail (considering the comments received) for further review by stakeholders. CanWEA believes the proposed study has the potential to make a valuable contribution to our understanding of the issue of wind turbines and human health if it is executed with sufficient scientific rigor, absent of bias, and produces results that are reproducible by an independent research group. The Canada Wind Energy Association believed there was an insufficient level of detail provided in the documents posted by Health Canada regarding the Health Impacts and Exposure to Wind Turbine Noise: Research Design and Noise Exposure Assessment. CanWEA has submitted a number of comments many of which are outlined in this article with a goal to ensuring that the proposed study has an opportunity to meaningfully contribute to the existing significant global body of research in this area. CanWEA has stated that the level of detail provided by Health Canada on the proposed Health Canada study Health Impacts and Exposure to Wind Turbine Noise: Research Design and Noise Exposure Assessment (proposed study) is not sufficient to fully understand specific details or the full scope of this proposed undertaking. Therefore, furnishing constructive comments is challenging, given the lack of detail provided. This study proposal was also presented to the Health Canada Science Advisory Board3. While the Science Advisory Board (SAB), in its discussion of the proposed study, noted several important points for consideration, CanWEA noted specifically that the SAB provided the following comment: 38 PES: North America

2 Meaningful and effective community engagement is a fundamental and long term commitment for any wind energy project, and is the cornerstone of all successful projects 39

3 The SAB questioned the presenters on aspects of study design with special attention to the questionnaire, control groups and data sources. They were satisfied that the team had covered many of the concerns associated with a study such as this. The use of many of the concerns suggests that Health Canada was not able to address all of the concerns/comments brought forward by the SAB. CanWEA are understandably keen to better understand all of the concerns raised by the SAB in this study; which ones have been addressed, and how; and which ones were not addressed, and for what reason. There are hundreds of thousands, if not millions of people in 89 countries around the world that enjoy productive lives in and amongst wind energy projects, and have been doing so for many decades. The response that some communities have to a project can vary based on many different factors, and these experiences, while predominantly positive, always have the potential to result in a negative community response. Meaningful and effective community engagement is a fundamental and long term commitment for any wind energy project, and is the cornerstone of all successful projects. CanWEA noted in its response to the proposed study, that the balance of credible, peer-reviewed research and key published literature reviews in the area of wind turbine sound and health clearly indicates that: Wind turbines do not have a negative impact on human health; Wind energy is one of the safest forms of electricity production, when compared against most traditional forms of electricity production; and the degree of community response to a wind energy development depends on many factors, which include, but are not limited to, sound, visual aspects, attitude and economic benefits. The wind industry of course acknowledges that wind energy developments, like any major development, may result in some community members experiencing annoyance to a varying degree, and that the overall response of a community towards a wind energy project is based on numerous variables, not solely attributable to the audible sound produced by a wind turbine. The Health Canada researchers themselves noted that the relationship is complicated and cannot be solely attributed to sound. Specifically, Section 1.1 of the proposed study stated: Indirectly, noise annoyance has been found to be positively correlated with [wind turbine noise], which is suggestive of a direct causal relationship. This relationship has intuitive appeal, but attribution of this correlation is complicated as it has been found to be moderated by economic and visual effects it is difficult to make causal statements about the relationship between exposure to [wind turbine noise] and community annoyance and, therefore, to set science-based sound level limits. This complication is inherent, due to the subjective and very personal nature of a response by an individual or community towards a wind project, or any other potential source of community annoyance (e.g., cell towers). It is this subjective nature that has historically made community response metrics difficult to establish (not just for wind energy). This does not justify dismissing the need for Health Canada to study this relationship, but it highlights the fact that such a study must consider the potential influence and impact of many variables not just one. Recently, the Chief Medical Officer for Ontario, Dr. Arlene King, re-affirmed her conclusions from her original report on wind turbines and sound (The Potential Health Impacts of Wind Turbines May 2010). Specifically, Dr. King stated in testimony provided July 23, 2012, before the Standing Committee on Estimates: Studies in Sweden and the Netherlands found that wind turbine sound is annoying to some people, particularly people with a negative attitude to the visual impact of wind turbines. Also, importantly and conversely, 40 PES: North America

4 the direct economic benefit from wind turbines was associated with decreased annoyance as well. So there are factors that influence whether or not people are annoyed by wind turbines. In addition to the work referenced by Dr. King, a recent sociological evaluation of rural wind farm development in Australia has also found that community response to wind facilities can vary for a variety of non-acoustical reasons. Specifically the researchers stated: Community members publicly opposing their local wind farm spoke as self-appointed representatives for others nursing grievances with wind farms. Most were hobby farmers with small acreages, former professionals and/ or members of Landscape Guardian groups [groups concerned with visual impacts] and, This opposition has several origins including a symbolic response of rural communities to political neglect from cities, an antidevelopment stance, and also opposition to a green or climate action political agenda. The SAB also raised concerns in this area, noting: The study needs to mediate confounding factors - how they are framed is vital - social influence and contagion, although difficult to factor in, e.g., real estate values, need to be taken into consideration. It is not clear from the documents posted by Health Canada, including the strong recommendation from Health Canada s SAB, how the research team plans to address the social influence and contagion factors (e.g. attitude, economic benefits, visual cues, etc.) in the proposed study. Based on the above recommendation from the SAB, acknowledgement by the researchers themselves, as well as the significant body of peer reviewed research that has demonstrated that factors such as attitude, sound, visual intrusion on line of sight and economic benefits all can contribute and influence community response to a wind energy development, it is unclear why Health Canada is proposing to study a dose-response relationship whose only variable being considered is sound. CanWEA believes that limiting the scope of work to focus entirely on sound will significantly restrict the effectiveness of the proposed study in understanding the variables associated with community response to wind energy projects. Such a narrow focus is therefore likely to produce an incomplete or incorrect understanding of the key factors that exist in understanding how a community responds to a wind energy project. There are many aspects of a wind energy project that must be considered when executing a study of this broad scope. Project operators should be engaged early in the study in order to ensure Health Canada can: Gain access to their site to conduct an appropriate sound measurement campaign (e.g., CSA or IEC compliant) Obtain available site-specific and real time meteorological data, including historical meteorological data Obtain unique/important operational control schemes that may affect the sound level of the wind energy project at different receptors (e.g., sector management programs, etc.) Understand any implications associated with unique project operating characteristics of the entire wind energy project, as well as that of individual wind turbines Obtain from the operators any logged complaints, and all of the associated details of those complaints (who, what, when, where, why, resolution?) Determine whether any of the projects being studied are subject, or pending subject, to litigation due to complaints from the community In addition to the above, CanWEA is concerned that Health Canada has defined the scope of participants in the study too narrowly to ensure that the study has an opportunity to produce meaningful and representative results. The association believes that a diverse and comprehensive list of potential participants in this study should include a wide variety of stakeholders. All study participants should be described based on the nature of the stakeholder group they represent (e.g., permanent vs. nonpermanent residence; participating vs. non-participating residence, etc.). It is recommended that Health Canada also consider the nature of each stakeholder in the study, and how varying perspectives, as well as social and environmental differences, may influence their attitude, and hence response, towards any particular wind project. Examples of potential participants are provided below: Landowners participating in the project, including those hosting wind turbines and other project components (e.g. access roads, meteorological towers, etc.) these individuals are often exposed to higher noise levels and increased maintenance vehicle traffic relative to non-participating landowners Community members not participating in the project, and who can see and hear wind turbines or other project components Community members not participating in the project, and who cannot see or hear wind turbines or other project components Permanent residences Non-permanent/temporary/secondary residences (e.g., vacation/cottage homes) Members of the public who do not have wind turbines in their community and who are unable to see or hear wind turbines Community members who are aware of a planned project, that has yet to be constructed Community members who have lived with a wind project for more than 5 years Community members who have lived with a wind project for a short period of time Individuals less than 18 years of age (e.g., a more diverse age group). However, it is important to develop a strong methodology that limits outside influence in reporting for minors if they are to be included. There may also be legal issues related to consent that must also be considered A demographically representative group reflective of modern Canadian society Health Canada should also consider the following in the proposed study, with respect to participants: 41

5 Whether landowners were originally included in the project, only to later learn that due to the significant number of siting constraints associated with a wind project, they would no longer be a participant in the project (this speaks to individual experience with the project, and should be obtained from the project developer) Whether there are reports of other, unrelated concerns in the community, which may have been mistakenly attributed to a wind project? For example, have there been documented historical issues of stray voltage in the area, presently or in the past (an important consideration in projects located in agricultural areas)? Stray voltage is generally caused by either poor grounding practice by the local distribution company or inadequate on-site electrical grounding/ neutral conductor wiring. Negative and unrelated experiences such as this may result in local concerns related to all new electrical installations/modifications Geographic diversity is important. For example, Alberta has had slower evolution of regulations as they pertain to wind energy development, relative to Ontario. When compared with Ontario, Alberta does not appear to have experienced the same community concerns regarding health and several other non-related issues, as has been the case in Ontario. How will the study capture and reflect this difference? Participant pre-project health is an important consideration and needs to be well documented and understood when interpreting the results of this study. Will the medical history of participants be reviewed? How will this history be obtained and reviewed, and compared to self-reported symptoms in the survey? How will reports of stress be filtered to determine whether the source was from wind turbines and not from other sources of stress (or sound) prevalent in people s lives? Given the scale of technologies that are available to wind energy developers, and the evolution of wind turbine technology, it is important that the proposed study also consider a diverse range of technologies and the various regulations and codes that were in effect during project development. CanWEA has recommended in its response that a variety of technology, project and type of wind energy projects and locations be included in the proposed study, including at least one project per Province. The following examples have been provided for consideration in the proposed study, with a goal to obtain the necessary diversity of technologies and projects that presently exist in Canada: Project Ownership Structure: Individual Community Independent Power Producer Utility/Government Owned Other Equipment and Turbine Technology: Single turbine Multiple turbine Random turbine array Linear turbine array Old turbine technology (e.g., > 5 years old) New turbine technology (e.g., < 2 years old) Control scheme (e.g., unique operational controls) Utility scale wind turbine Residential/farm scale wind turbine Project Location: Ridge top Open field (agricultural & grasslands) Wooded Urban Rural Project Status: Old (e.g., > 5 years old) New (e.g., < 2 years old) Planned Projects (informing potential stigma effects) Furthermore, Health Canada has stated that: The sample will consist of dwellings at setback distances ranging from less than 500 meters to greater than 5 km. CanWEA has responded that it is important to define study locations where the setback distances apply, and that this should follow the standard of the province where that wind project is located, at the time the project was approved. Results of this study will need to be interpreted very carefully; they should account for the wide number of differences that currently exist in wind projects throughout Canada. Accounting for these variables can be complicated; for example, with respect to project age. Newer projects will have increased maintenance activities during the first year of operation, which could potentially lead to increased shortterm community annoyance. Older projects, however, may benefit from habituation (also raised by the SAB). In addition, older projects may also have been permitted under different regulations, which may influence how a community responds to a wind energy development. Permit requirements in Ontario have undergone 42 PES: North America

6 significant changes over the past several years, whereas in other jurisdictions regulations have been slower to evolve. It is noted that the study design posted by Health Canada references only a very small amount of the literature that has been published in the field of acoustics, annoyance and community response, occupational and environmental health, and wind energy. Health Canada has said that due to space limitations, an exhaustive list has not been included CanWEA has responded by stating that it looks forward to reviewing the complete list of references Health Canada has used in designing this proposed research study. The study team also cites grey literature that has not been peer reviewed or published. CanWEA has concerns over the use of non-peer reviewed research, and its validity towards informing public policy. The process for considering literature used in this work should be transparent, to ensure that peer reviewed literature informs, to a much more significant degree, findings, and ultimately public policy. It has been advised by CanWEA that the proposed study might benefit from ranking the study references based on The Cochrane Handbook for Systematic Reviews of Interventions. The GRADE approach can be used to assess the quality of the literature by ranking it high, moderate, low or very low. This approach to literature ranking is scientifically defensible because selection methodology and quality ranking parameters are all outlined and transparent, and has been employed by many researchers, including by the WHO. Despite the above, CanWEA has stated that it believes only credible and peer reviewed literature, should be used when informing this work. Given the clearly significant list of variables and differences in projects, it is hoped Health Canada will be able to better demonstrate how these will be incorporated into the final project design, how they will be accounted for, and ultimately aid in interpreting the results of the study. CanWEA would like to better understand the criteria that Health Canada aims to apply when selecting wind energy projects for their study. CanWEA has said that it appreciates that Health Canada has a mandate to fulfill, but does not feel that a study of this nature can be executed in isolation. Moreover, the association feels that Health Canada has failed to indicate how the results of this study will be compared to other sources of annoyance or, more importantly to other forms of electricity generation. The significant benefits associated with wind This opposition has several origins including a symbolic response of rural communities to political neglect from cities, an anti-development stance, and also opposition to a green or climate action political agenda energy development, from an environmental, health and economic perspective, and it is felt by CanWEA that they should also be included in this study. CanWEA has noted that all forms of energy production, as well as other land uses, result in varying degrees of response by a community, and that this is not unique to wind energy; proposed natural gas, solar and nuclear generating facilities, as well as agricultural, commercial and industrial facilities, have all demonstrated the ability to produce significant community reaction. Study results should therefore be placed into context by comparing them against studies that have examined community response to other potential sources. This was also recommended by the SAB: Also HC was encouraged to consider comparison groups felt essential to adequately assess annoyance. [It] was felt that the absence of community comparators exposed to sources generating similar complaints (e.g. cell towers) may render interpretation of the questionnaire more difficult. The comparator group doesn t need to have the exact same environmental conditions as the study group. HC agreed to raise this point with the study design peer committee. CanWEA would like to better understand how the study team plans to address the SAB comment noted above, as it is unclear based on the response provided by Health Canada. In addition, when interpreting results from this study, the research team must consider known risks associated with different forms of energy production. Furthermore, the study will also need to consider a comparison of the impacts of different types of noise sources. It is imperative to consider the alternatives when interpreting the results, since it is not simply a question of building wind projects or not building wind projects the wind energy developments being proposed both in Canada and abroad are proposed against a backdrop of other options for producing electricity, all of which have their advantages and disadvantages. Based on this, it is not possible to simply select the null approach, that being, no wind energy development we must select some form of energy production to meet our needs. It is within this framework that wind energy is often presented as the broadly preferred alternative, when compared against other forms such as nuclear or fossil fuel-sourced electricity. Given that one of Health Canada s stated goals is to aid policy makers in the decisions they must make in meeting rising energy demand, it is critical that the complete picture, including comparison of the alternatives, be furnished when presenting study results. This article has been extracted from the report: CanWEA Final Comments on Proposed Health Canada Study: Health Impacts and Exposure to Wind Turbine Noise: Research Design and Noise Exposure Assessment. With thanks to CanWEA For the full report, visit