Riga Township omits low frequency noise impacts from ordinance.

My name is Greg Horvath. I have been a Riga Township resident for 5 ½ years.  I am concerned that the redline Wind Ordinance submission posted on the township website does not go far enough to protect the health, safety, and welfare of Township constituents.  To my surprise, the ordinance does not contemplate either testing methodology or restrictions on low frequency noise.  This despite the fact that the topic has been previously discussed at both Township Board meetings and Planning Commission meetings.  Additionally, 6 hard copies of the proposed red-line draft were submitted to Paul Deusseau and the Planning Commission and emailed to Mike Homier in September 2010.  I had also spoken to Mike Homier in September regarding the proposed redline submission.

I have continued to communicate the fact that low frequency noise is significantly different from high frequency noise.  Further, there is a dramatic difference in testing methodology and community impact.  Current setbacks and 40 DbA sound threshold do nothing to address the well documented impact of low frequency noise to local residents.

For the record, I am submitting two documents for both Planning commission and township board review.  The first is a re-submission of the redline ordinance I submitted last fall which incorporates provisions for the testing and allowable thresholds for low frequency noise.  The second document dispels the myths and half-truths used by wind advocates to minimize the social impact of industrial scale turbine projects, particularly on the topic of noise.

There is a recently published study that discusses the deleterious impact of low frequency noise in fairly broad terms.  The report; “Wind Turbine Sound and Health Effects, An Expert Panel Review, December, 2009” was published by the American/Canadian Wind Energy Association.

This report clearly minimizes the impact on local communities.  Statements included in the report lack references and data to support their claims.  They are spun in a manner that misrepresents facts and contradicts well documented studies on the subject of low frequency noise.  This is the sort of propaganda we are currently influenced by through Juwi and Great Lakes.

Here is one of the “Myths” currently used by wind advocates to minimize noise impact:

What the advocates would say:

“The low frequency sound emitted by spinning wind turbines could possibly be annoying to some when winds are unusually turbulent, but there is no evidence that this level of sound could be harmful to health.”

AND:

“The infrasound emitted from wind turbines is at a level of 50 to 70 dB, sometimes higher, but well below the audible threshold. There is a consensus among acoustic experts that the infrasound from wind turbines is of no consequence to health.”

What the facts are:

Public Health Impacts of Wind Turbines Prepared by: Minnesota Department of Health Environmental Health Division states:

· “Wind turbines generate a broad spectrum of low-intensity noise. At typical setback distances higher frequencies are attenuated. In addition, walls and windows of homes attenuate high frequencies, but their effect on low frequencies is limited.” (low frequency noise travels right through the walls of our homes)

· “Most available evidence suggests that reported health effects are related to audible low frequency noise.  Complaints appear to rise with increasing outside noise levels above 35 dB(A).”  (This strongly implies that our ordinance threshold of 40dB(A) is insufficient and therefore set too high.)

· “For broadband noise, such as wind turbines produce, the low frequency components may travel further than the higher frequency components. Since low-frequency noise is particularly annoying to most people, it is important to specify limits for low frequency noise.”

· “Wind turbine noise, especially at lower wind and blade speeds, will contain more low frequency components than traffic noise. Light weight building home structures will not attenuate these frequency components as well as higher frequency components.”

Incorporating Low Frequency Noise Legislation for the Energy Industry in Alberta, Canada Authors: DeGagne, David C.; Lapka, Stephanie D states:

· “Unlike higher frequency noise issues, LOW FREQUENCY NOISE is very difficult to suppress. Closing doors and windows in an attempt to diminish the effects sometimes makes it worse because of the propagation characteristics and the low-pass filtering effect of structures.

World Health Organization, Guidelines for Community Noise, 1999 sums it up by stating:

· “Health effects due to low-frequency components in noise are estimated to be more severe than for community “high frequency” noises in general”

In conclusion, I would like to emphasize the importance of low frequency noise as probably the most important element of our Wind Ordinance.  It is incredible to me that wind advocates and our Township officials are ignoring well documented health, safety and welfare issues such as what was published in the excerpts I am submitting.

Juwi & Great Lakes spin the same false information, downplay relevant issues through failure to acknowledge problems with projects of this magnitude, and threaten legal remedy if we do not conform to their requirements.  This is equally incredible.

There is no doubt that audible noise such as emitted by modern upwind industrial wind turbines sited close to human residences cause significant adverse social impact. This is proven medical science. Turbine projects of this scale and magnitude require study on this complex topic.

There is too much data available to simply ignore because it is too ‘complex’ or because we do not understand it.  Ignorance in my opinion would be an egregious oversight by our Township and Planning Commission officials.

Please find for the record a re-submission of my re-line ordinance submission which has contemplated testing methodology and citing requirements for low frequency noise.

Thank you,

Respectfully Submitted,

Greg Horvath