Review of the MOE Turbine Noise Compliance Test at the Libby Home
John Harrison, PhD.
May 2013

Errors in the MOE Analysis
Whoever provided the analysis of the MOE measurements at the Libby residence has no idea of what they were doing. This is serious because the analysis purports to show that the measured sound pressure levels are not so bad. What was done was to take the measured sound pressure level, subtract the regulation sound pressure level at the same wind speed and compare the difference with the regulation sound pressure level. This is nonsense.

The second column was labelled ambient but that is wrong. The sound pressure level limits have the reference ambient sound pressure level built in.

Conclusion
I conclude that the turbines close to the Libby home are non-compliant and need to be shut down. I also conclude that there needs to be more supervision of those making turbine noise compliance measurements. Finally, these measurements highlight the inadequacy of the present prediction protocol.
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This submission is being made regarding risk of harm to a child associated with exposure to a wind energy facility. This facility is not yet operational but approval for the facility is pending.

This submission is made on behalf of the Correia family from Ontario, Canada. The family raises concerns about their son who will be at risk from exposure to a wind energy facility. Included is a commentary by a specialist physician regarding risk factors associated with the Correia's son.

I have forwarded a number of submissions, both public and confidential, to the Minister, Health Canada on behalf of other families who had expressed concerns for their children and grand-children. In addition, I have provided several submissions, public and confidential, with examples of increased vulnerability associated with pre-existing medical conditions such as autism, respiratory conditions and other when industrial wind turbine facilities are sited in close proximity to family homes and schools. These have been copied to the Principle Investigator of the Wind Turbine Noise study as part of the peer review process.

The Policy Interpretation Network on Children’s Health and Environment comments on the use of the precautionary principle i.e. prevention:

Policies that may protect children’s health or may minimize irreversible health effects should be implemented, and policies or measures should be applied based on the precautionary principle, in accordance with the Declaration of the WHO Fourth Ministerial Conference on Environment and Health in Budapest in 2004. 

Regarding precaution, the World Health Organization states: 

“…where there is a reasonable possibility that public health will be damaged, action should be taken to protect public health without awaiting full scientific proof.” 

There is an opportunity for Health Canada to invoke the precautionary principle and assist with protecting the Correia's son. Until guidelines are established that protect human health and social-economic viability, no further development of wind energy facilities should occur and existing sites reporting health issues should be resolved to the satisfaction of the those reporting health impairment or risk factors. 

Respectfully submitted on behalf of the Correia family from Ontario, 
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Carmen Krogh, BScPharm
Ontario, Canada  

carmen.krogh@gmail.com
 
 
UN Convention on the Rights of the Child and Canada’s RolePart 6 of 6 The Right to Rest and LeisureCanada played an instrumental role in drafting and promoting the United Nations Convention on the Rights of the Child. The Convention outlines the responsibilities governments have to ensure a child’s right to survival, healthy development, protection and participation in all matters that affect them. The four general principles of the Convention are: non-discrimination, the best interests of the child, the right to life, survival and development, and respect for the views of the child. [1] Public Health Agency of Canada

Convention on the Rights of the Child [2]
Article 31

1. States Parties recognize the right of the child to rest and leisure,

The Right to Rest and Leisure 


-    For years people have been suffering the detrimental effects from wind turbines that are operating too close to homes and schools. “Living with turbines for almost 5 years, we have become used to the lack of sleep and all of the side affects that go along with it. We live within 700m of two turbines, there are 6-8 within 1 km, and at least 12 within 2 kim's. Yesterday was report card day and my eldest son's report card broke my heart. It started with a glowing report "...is a very responsible student in every area within the school. He walks in the hallways in the manner that is expected, demonstrating to others what aresponsible student looks like. He works hard to ensure..." but my heart broke when I read "...should continue to put his best effort forth in paying close attention to the teacher and his classmates when they speak, rather than resting his head on his desk surface." My son complains often that he has a hard time at school because he is so tired all the time, and when I asked him how he handled it he said he tried to close his eyes on his desk from time to time, but it really hit home when it was there in black and white on the report card.”[3]

-      6.3 Sleep disruption [excerpts are not intended to be exhaustive] Sleep deprivation associated with the operation of industrial wind facilities has been documented in peer reviewed and / or other sources. 34 , 35 , 36 , 37 , 38 , 39 Chronic sleep deprivation can lead to extreme fatigue, cognitive dysfunction and inability to concentrate and learn, depression, anxiety, increased risk of cardiovascular problems, and emotional responses such as fear, anguish and humiliation. 40 , 41 [4]

-     Sleep Disturbance and Wind Turbines “Sleep is an essential part of healthy life and is recognized as a fundamental right under the European Convention on Human Rights (European Court of Human Rights, 2003).”[1] “Some people with wind turbines located close to their homes have reported a variety of clinical symptoms that in rare cases are severe enough to force them to move away. These symptoms include sleep disturbance…” [2]

The American Wind Energy Association and Canadian Wind Energy Association sponsored literature review entitled “Wind Turbine Sound and Health Effects” acknowledges wind turbine noise, including low frequency noise, may cause annoyance, stress and sleep disturbance and as a result people may experience adverse physiological and psychological symptoms. [3]

Wind turbine induced sleep disturbance is consistently reported by those experiencing adverse health effects from exposure to wind turbines. [4][5][6][7]  

“The recent analyses of the WINDFARMPerception and earlier Swedish studies by Pedersen and her colleagues gives, for the first time, robust evidence that wind turbines cause sleep disturbance and impair health and that this occurs at set-back distances previously regarded as adequate…Unfortunately all government and industry sponsored research in this area has used reported awakenings from sleep as an index of the effects of turbine noise and dismisses the subjective symptoms. Because most of the sleep disturbance is not recalled, this approach seriously underestimates the effects of wind turbine noise on sleep.” [8] [5]

[1] Public health Agency of Canada http://www.phac-aspc.gc.ca/ncd-jne/bck-info-un-eng.php
[2] Office of the High Commissioner for Human Rights http://www.ohchr.org/EN/ProfessionalInterest/Pages/CRC.aspx
[3] Ill Wind reporting website. https://www.illwind.org/reports/view/441
[4] Submission Health Canada Wind Turbine Noise and Health Studyhttp://windvictimsontario.com/preliminary-submission---health-canada-noise-and-health-study.html 
[5] The Society for Wind Vigilance http://www.windvigilance.com/about-adverse-health-effects/sleep-disturbance-and-wind-turbines
 
 
Weaver Family Submission

November 23, 2012
Dear Minister Aglukkaq,
Re: Health Canada Wind Turbine Noise and Health Study

Attached is a noise report relating to a family in close proximity to industrial wind turbines.   

The Weaver/Rooney family is one of those for which a pre- and post-turbine submission was forwarded to Health Canada "Health Canada submission_November 23 2012 FINAL" and "Pre_Post_Wind turbine submission_Updated February 4 2013" respectively.   

The family is reporting serious health effects that are associated with the start-up of the facility in December 2012.   

A noise study was conducted and the results indicate "that the IWT generated noise does not comply with the MOE noise guidelines ~50% of the time and that SPL’s are above the predicted “worst case” ~59% of the time."   

The family started journal December 26, 2012 and have maintained it to date. The attached contains extracts for the period of time that that the noise measuring equipment was set up at the family residence. The journal records the quality of life and health problems experienced by the family [see attached Appendix B of the report].   

The journal documents many negative sleep events where one or both members of the family could not sleep. In some cases, sleep medication was required or members had to sleep away from their home


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Part 5 of 6 UN Convention on the Rights of the Child and Canada’s Role

Canada played an instrumental role in drafting and promoting the United Nations Convention on the Rights of the Child. The Convention outlines the responsibilities governments have to ensure a child’s right to survival, healthy development, protection and participation in all matters that affect them. The four general principles of the Convention are: non-discrimination, the best interests of the child, the right to life, survival and development, and respect for the views of the child. [1] Public Health Agency of Canada

Convention on the Rights of the Child [2]

Article 29

1. States Parties agree that the education of the child shall be directed to:
(a) The development of the child's personality, talents and mental and physical abilities to their fullest potential;

Fullest potential

-          Research linking loud sounds to hearing loss in youngsters is now widespread, resulting in the issuance of warnings to protect children’s hearing. However, studies attesting to the adverse effects of intrusive sounds and noise on children’s overall mental and physical health and well-being have not received similar attention. This, despite the fact that many studies have demonstrated that intrusive noises such as those from passing road traffic, nearby rail systems, and overhead aircraft can adversely affect children’s cardiovascular system, memory, language development and learning acquisition.[3]

-          Furthermore, based on our knowledge of the harmful effects of noise on children’s health and the growing body of evidence to suggest the potential harmful effects of industrial wind turbine noise, it is strongly urged that further studies be conducted on the impacts of industrial wind turbines on their health, as well as the health of their parents, before forging ahead in sighting industrial wind turbines.[3]

-          The report concludes that exposure to ambient noise was found to be linked to small decrements in children’s mental health and poorer classroom behaviour. This link was stronger in children with early biological risk. [4]

-            “During exposure, young Justin, a healthy 2½-year-old, pulled on his ears and got cranky at the same times that adults in the family noticed more headache and tinnitus. His language development was good before, during, and after exposure, but his mother noticed during exposure that the child began to confuse T with K sounds and W with L sounds, which he had not done before. This sound confusion was ongoing six weeks after exposure ended, when I interviewed the parents.”


[1] Public health Agency of Canada http://www.phac-aspc.gc.ca/ncd-jne/bck-info-un-eng.php
[2] Office of the High Commissioner for Human Rights
http://www.ohchr.org/EN/ProfessionalInterest/Pages/CRC.aspx
[3]http://windvictimsontario.com/uploads/3/1/4/3/3143767/bronzaft_children_and_noise_wind_turbines.pdf
[4] http://www.documents.hps.scot.nhs.uk/ewr/pdf2002/0229.pdf
     http://oem.bmjjournals.com/cgi/content/abstract/59/6/380
[5] Wind Turbine Syndrome & the Brain Nina Pierpont, MD, PhD

 
 
May 6, 2013
Dear Minister Aglukkaq,

Re: Wind turbines can harm humans: health and social-economic impacts

This submission is being made on request and on behalf of the Yeats family from Wareham, Ontario. The project has been operational for over a year.

The attached submission references that 10 Billion dollars has been invested in a green concept by the Canadian government and more investment is pending.

Despite appeals from many rural families, some with babies and children, some elderly, some with pre-existing medical conditions, the Canadian government continues to ignore the people who have been harmed and will be harmed in the future.

There has been limited investment on the wind turbine health file with the exception of a $1.8 million dollar investment in a Wind Turbine noise study that will be completed in 2014 and will not be definitive.

The family's living environment has been altered by the imposition of an industrial wind energy facility in proximity to their home. This was done without their consent. Within a short period of time, family members are reporting serious health effects and there is no remedy except to remove the source by leaving their home. This would seem to violate ethical and human rights which are expected in our Canadian democratic society. Until guidelines are established that protect human health and social-economic viability, no further development of wind energy facilities should occur and existing sites reporting health issues should be resolved to the satisfaction of the New Experts.

In the meantime, on behalf of the Yeats family, I am requesting that emergency funding be considered to relocate the family to restore their physical, mental and social well-being until resolution has been achieved to their satisfaction.

Respectfully submitted on behalf of the Yeats family, from Wareham, Ontario,

Carmen Krogh, BScPharm

Ontario, Canada 

Cell 613 312 9663

carmen.krogh@gmail.com

 
 
Part 4 of 6 Environmental pollution, Parents and children, are informed

Canada played an instrumental role in drafting and promoting the United Nations Convention on the Rights of the Child. The Convention outlines the responsibilities governments have to ensure a child’s right to survival, healthy development, protection and participation in all matters that affect them. The four general principles of the Convention are: non-discrimination, the best interests of the child, the right to life, survival and development, and respect for the views of the child. [1] Public Health Agency of Canada

Convention on the Rights of the Child [2]

Article 24
1. States Parties recognize the right of the child to the enjoyment of the highest attainable standard of health
2. States Parties shall pursue full implementation of this right and, in particular, shall take appropriate measures:
(c) ... taking into consideration the dangers and risks of environmental pollution;
(e) To ensure that all segments of society, in particular parents and children, are informed, have access to education and are supported in the use of basic knowledge of child health (dangers from wind turbines near homes and schools)

Environmental pollution, Parents and children, are informed

-         The Ontario Provincial government and the Canadian Federal government do not inform those living, playing or working near industrial wind turbines of the possible dangers associated with operations of the turbines. The Ontario 400m to 550m setback is from residences. [3] There is no established setback from property lines, roads, or in the case of leased land, no setback for employees or children on that property.
-         The Ontario Ministry of Environment has repeatedly failed to adequately regulate, monitor and enforce emissions from industrial wind turbines. [4] [5] [6] [7] 
-         The Canadian Federal government regulates and defines "radiation" as either electromagnetic or acoustic. And governs this under the Radiation Emitting Devices Act [8]. The Canadian Federal government does not regulate of even inform Ontario citizens of the possible risks associated with industrial wind turbine operation.
-          H.A.R.M. 20 or more families suffering health effects. Christine and .....