Massachusetts environmental protection department flunks wind farm compliance test

Acoustics firm hired by power giant Con Edison fails to show compliance with noise regulations, and uses some pretty dodgy methodology, too

Missing data, fudged presentations and contempt for reporting protocol–how the wind industry shows compliance with protective regulations [Shutterstock photo]
August 22, 2018

With thanks to Wind Wise Maine

The Department of Environmental Protection (DEP) for the Commonwealth of Massachusetts has rejected a technical report provided to the Town of Plymouth by Con Edison Inc., on wind turbines and compliance with noise regulations.

The technical report was prepared by Tech Environmental Inc., an environmental consulting firm based in Waltham, Mass.

In a politely written but nonetheless excoriating review letter, the DEP noted several critical points in the consultants’ report:

  • There were no compliance audit data available at the time of commissioning as is required
  • Two of the five turbines were turned off completely during monitoring
  • Noise assessment was to be done during the quietest hours of the night so as to indicate a worst-case scenario, specifically 12 -4 a.m.; the assessment was done for two hours only, from 11 p.m. to 1 a.m.
  • The consultant did not follow the government-required protocol for the presentation of data
  • Several data points were missing entirely

As a result, the Massachsuetts DEP said, it was “unable to concur with Tech Environmental Inc.’s conclusion” that the noise assessment demonstrated compliance with the noise limits.

Read the relevant correspondence here:

https://windwisema.files.wordpress.com/2018/08/dep-response-letter-tech-env-plymouthsound-stdy.pdf

This wholesale manipulation of data and flagrant contempt for regulations designed to protect health of the residents forced to live nearby industrial-scale wind turbines seems endemic to the wind power development industry.

In Ontario, many wind power projects are without completed acoustic Immission Audits post-operation as they are required and, when called on to perform assessments in the recent example of two homes in the Underwood project, seem free to manipulate the data at will. We regret too the news that the Ministry of the Environment Conservation and Parks has now accepted a noise abatement plan for the problematic single turbine operated by union Unifor, despite hundreds of complaints filed over five years, and the fact that noise complaints began on day one of the pilot noise abatement plan.

More government departments need to perform actual technical review of the material presented by power developers, and call them to account. If in violation, curtailment and shutdown need to be enforced, immediately.

contact@windconcernsontario.ca

Wind power project with 100s of complaints deemed ‘compliant’ says Environment ministry

Residents near the Underwood turbines have been waiting for a long time to get help for disturbing noise … they’re not getting it.

Ontario environment ministry has more than 500 reports of excessive noise — but nothing is being done. Why?  Computers say everything is OK.

August 13, 2018

Residents forced to live inside the 110-turbine Underwood wind power project operated by Enbridge have been waiting patiently to find out what the results were of a long-awaited post-operational acoustics audit.

Their wait is now over, but they’re not happy.

Residents received telephone calls recently from the Owen Sound Office of the (now) Ministry of the Environment, Conservation and Parks to the effect that the Underwood project audit report concludes it complies with Ontario wind turbine noise regulations.

In a letter dated July 27th, Owen Sound District Manager Rick Chappell wrote:

“The report states that based on the results of the assessment, the Underwood Wind Project is in compliance with applicable sound level limits at your location.”

Chappell then apologizes for the “stress” caused by the assessment process, but makes no mention of the many reports filed with the ministry by the family, or of the adverse health effects possibly experienced.

The acoustics audit was prepared by Aercoustics Engineering, a firm that does acoustics assessments for many wind power developers, and also helps them prepare noise assessments for their applications for approval.

The assessment was first done in 2015, under the government’s previous noise protocol, but was not accepted. Aercoustics explains how the data was prepared (recycled) for the new report.

As an alternative, Aercoustics proposed that the turbine electrical power threshold be
replaced by a threshold based on rotational speed. These findings and recommendations
were presented to the MOECC in a memo dated November 15, 2017. This memo, along
with the correspondence with the MOECC, is attached to this report in Appendix F.
With the alternative assessment methodology, based on turbine rotational speed rather
than power output, a full dataset was possible using Aercoustics’ measurement data at
R144 from July 8 to September 7, 2015. Valcoustics’ measurement data was used for
receptor R145 spanning May 1 to September 30, 2015; the added data was required due
to the wind direction during the summer months invalidating most of the measurement
data at R145. (Source: Aercoustics Assessment Report Project 15143.01, January 30, 2018, page 5)

The audit was done on two of the project’s 110 wind turbines, in response to noise complaints from the residents. The revised report was produced three years after the original.

The audit also assumed that a single turbine was worthy of assessment and shut the other turbines down, in the fallacious/convenient belief that multiple turbines do not have an accumulated effect.

Complaints lodged, no action taken

Wind Concerns Ontario has copies of Incident Reports and Master Incident files provided under a Freedom of Information request from the then Ministry of the Environment and Climate Change. The collection of documents from 2006 to 2016 show that there are 515 reports of excessive noise related to the Underwood wind project.

In one report dated April 2011, ministry staff notes say that the caller was told there would be an audit by Valcoustics and a report provided, equipment was installed from November 2009 to April 2010 , but no results were ever provided to the caller. Staff note a report (number 66) was made to a Bob Simpson of Enbridge; the closing note says “noise modeling indicates no exceedances.”

In another report, also dated 2011, the caller to the ministry Spills Action Line reports “loss of sleep due to wind turbine noise” –this adverse effect is recorded again through several more calls. The ministry staff person notes “advised the caller that he should contact the Grey Bruce Health Unit… regarding health concerns.”

Aercoustics actually states in the 2018 report that because the monitoring towers were placed closer to the turbines than the residents’ homes, there was “a measure of conservatism … actual turbine-only sound at the receptors is expected to be lower than those measured at monitoring locations.”

In the case of one turbine assessed, that distance was only 38 metres.

Table 2: Receptor Measurement Locations

Receptor Location UTM Coordinates Distance to
Turbine [m]
Predicted Sound Level*
R144 Receptor 17T 458093mE
4907987mN
537 39
Monitor 17T 458092mE
4908028mN
  499
R145 Receptor 17T 459854mE
4907073mN
453 39.8
Monitor** 17T 459931mE
4907082mN
  375

Predicted level taken from Table 4 of the Revised Environmental Noise Assessment [1], sound
level at 6 m/s.
Predicted level taken from Table 3 of the Revised Environmental Noise Assessment [1], sound
level after
wind direction adjustment. * UTM coordinates for R145 monitor taken from Aercousticsmonitoring equipment, which was
erected less than 10 meters from Valcoustics monitoring equipment

 

“This determination of compliance in the face of hundreds of complaints about this project, which has been operating since 2008, is nothing short of outrageous,” says Wind Concerns Ontario president Jane Wilson.

“It is a violation of the government’s own Environmental Protection Act to have allowed this many noise complaints to go on for so long, especially with the staff notations of adverse health effects. All the ministry does is talk about testing and compliance—they are not responding to the real problems that people are reporting to them. Acceptance of this whitewash report is a complete failure of their mandate to protect.”

To read the Aercoustics report, click here: http://www.enbridge.com/~/media/EF4720063692403B82FD1AA859689E0F.ashx

If the link does not work for you, follow these directions from Enbridge:  www.enbridge.com, and then go to ‘An interactive experience:  Our North American assets map’ on the home page.  Click on see the map, and zoom in to find the Underwood Wind Farm (aka Ontario Wind Power Project).  Click on the wind symbol and you will see a link that says ‘Click here to read Aercoustics Engineering’s acoustic immission audit on the Underwood wind farm’. 

contact@windconcernsontario.ca

 

 

Algoma community group calls attention to wind power negative impacts

A turbine in the Algoma Highlands. Photo: Gord Benner

August 5, 2018

Save Ontario’s Algoma Region or SOAR, has written to MPPs and ministers in the new Ontario government to call attention to the potential for negative environmental and economic impacts from recently constructed wind power projects.

In the letter, SOAR says that the wind power projects will have a negative effect on eco-tourism in the Algoma Region, where tourists come from around the world to visit the formerly pristine environment. The result could be job loss, SOAR says.

“Poverty impacts human health. The energy rates in Ontario which have skyrocketed due to the
policies of “green” energy have impacted all Ontarians—especially those in lower income
brackets and those who live in areas where a sustainable year-round economy is largely
dependent upon eco-tourism in a natural environment untouched by the presence of industrial
wind turbines.”

SOAR says further, the impact on the environment, wildlife and wildlife habitat is not truly known. “Despite the evidence of expert witnesses, to date the Ontario government has removed environmental protections, accepted flawed data from ‘researchers’ hired by wind companies and dismissed the concerns of objectors as self-seeking” SOAR stated in the letter.
As part of the Renewable Energy Approvals granted to the wind power developers, “the Ministry of the
Environment requires data of bird and bat mortality to be presented at post-operational community meetings for a 3-year period only. After that time, the public must request bird and bat mortality statistics directly from the wind companies,” SOAR says.

That is not enough oversight to ensure protection for the environment and wildlife.

SOAR is a community group member of the Wind Concerns Ontario coalition.

Read the entire letter here: Letter of Concern from SOAR re Industrial Wind in Algoma

contact@windconcernsontario.ca

 

 

 

 

Nation Rise project will create noise, health problems: WCO president to Tribunal

(C) ONTARIO FARMER

July 31, 2018

Report by Tom van Dusen

Finch, Ontario — Sitting demurely and speaking quietly, on July 24 the volunteer president of Wind Concerns Ontario blasted the provincial government approach to monitoring industrial wind turbines, accusing it of ignoring complaints about noise, health and other issues, or deferring them with no subsequent action.

Jane Wilson made  her comments while presenting as a witness during an Environmental Review Tribunal hearing into the Nation Rise wind power project planned for Stormont County. The hearing is scheduled to continue through August 2.

Currently engaged in the approval process, the project is sponsored by EDP Renewables Canada and calls for installation of some 33 turbines in North Stormont farm country delivering a total of 100 megawatts of power that, opponents observe, the province doesn’t need.

Headed by local resident Margaret Benke, opponents were hopeful the new Doug Ford government would cancel Nation Rise just as it did the White Pines wind project in Prince Edward County. But that didn’t happen and opponents’ legal fees and other expenses are up to $20,000. Benke noted that, with Ford in place, Nation Rise isn’t likely to proceed and yet opposing residents are still on the hook for costs.

Government not enforcing the law

A registered nurse, Wilson said Wind Concerns represents a coalition of more than 30 community groups across Ontario.

She emphasized that the Ministry of the Environment and Climate Change–renamed Environment, Conservation and Parks — has pledged to protect the environment and human health from any turbine side effects.

She cited former Environment Minister Glen Murray congratulating his officials for responding quickly to complaints and enforcing the law. However, Wilson’s review of incident reports obtained through Access to Information indicated the ministry doesn’t respond to all complaints and “does not, therefore, enforce the law.”

No answer to that

Total number of incident reports filed with the ministry between 2006 and 2016 was 4,574, Wilson told Maureen Cartier-Whitney, chair of the one-person panel. Records showed that in more than 50 per cent of formal complaints, there was no ministry response. Another 30 per cent were deferred. “In fact, only one percent received priority response.”

While he asked for some clarification, Paul McCulloch of the ministry’s Legal Services Branch, didn’t dispute Wilson’s basic facts. Representing EDP, lawyer . Grant Worden also offered no challenges to Wilson.

The repetitive nature of various complaints suggests, Wilson continue, that wind power developers are failing to live up to the terms of their approvals by allowing conditions triggering adverse effects including on health, to continue.

“Documented health effects include headache, sleep deprivation, annoyance, and ringing or pressure sensation in the head and ears. Most disturbing was the fact that these health effects were reported many times, and also among children.”

Wilson indicated that 39 per cent of 2006-2016 incident reports referred explicitly to sleep disturbance which is generally blamed for a myriad of diseases and disorders.

“Given the thousands of unresolved noise complaints in Ontario, and given Health Canada results of adverse health effects at distances of 550 metres to 1 km, it is reasonable to question whether the Nation Rise power project will not also engender community reports of excessive noise and adverse effects.”

contact@windconcernsontario.ca

To help support the appeal, which is bringing forward issues never presented to the ERT before, please send a cheque to Concerned Citizens of North Stormont, c/o Wind Concerns Ontario, PO Box 509, 250 Wellington main Street, Wellington ON  K0K 3L0

 

Nation Rise project: significant concerns over health, environmental damage