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reasonable protection from any health effects, including health effects from noise and shadow flicker, associated with wind energy systems." Id. Dr. Jevon McFadden, your colleague at DPH, was appointed to the seat on the Wind Siting Council reserved for a "University of Wisconsin System faculty member with expertise regarding the health impacts of wind energy systems." Wis. Stat. §15.797(1)(b) 8. In that capacity, he is scheduled to make a presentation to the Council on May 17, 2010. Presumably, Dr. McFadden's presentation will include the views of DPH. Therefore, it is essential that the Wind Siting Council and the PSC understand clearly the division's position with respect to the evidence that wind turbine noise is a threat to human health. The Position of DPH With Regard to the Health Impacts of Wind Turbine Noise My knowledge of the position of DPH regarding the health impacts of wind turbine noise is based on your May 6, 2010 letter to Ms. Liv L. Moyer, a resident of Eden, Wisconsin. Your letter stated: We have reviewed the available scientific literature on wind energy projects and public health, as well as reports issued by the National Academy of Sciences and other state health departments. Based on this review, the Division of Public Health finds no clear scientific evidence to support the conclusion that wind turbine development using existing setback criteria would result in specific adverse health impacts to the public. DPH believes that wind turbine noise may be a cause of sleep disruption. DPH believes that there are "gaps" in its knowledge of how wind energy systems may impact human health. DPH believes that people affected by wind turbine noise should see their doctors. DPH believes that further evaluations by medical providers will allow DPH to determine possible links between wind turbine noise and health complaints and will help improve DPH's understanding of that relationship. DPH believes that it is important to look for ways to "minimize potential impacts" of wind energy systems. DPH will "continue to seek data and information to guide public policy on the matter" of the impacts of wind energy systems on public health. DPH has not studied the health effects of wind energy systems in Wisconsin. DPH does not contend that wind energy systems may not result in adverse health impacts generally. DPH has not concluded that adverse health impacts are not positively correlated to noise. You reviewed only "scientific" literature, not medical reports nor resident complaints. You reviewed only what was "available" to you. You reviewed only unnamed reports. You found no "clear" scientific evidence to support the conclusion that wind energy systems "would" result in "specific" adverse health impacts. Your opinion assumes the use of unspecified "existing setback criteria." If I have misunderstood DPH's position in any way, please contact me as soon as possible.

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There is Substantial, Credible, and Scientifically Valid Evidence That Wind Turbine Noise is a Threat to Human Health Included in this letter are links to five reports --one of which is the wind industry's own report-- supporting the conclusion that wind turbine noise can cause adverse health effects. The following are summaries and excerpts from each report. I encourage you to read each report in its entirety. 1. Colby, W. David, MD (2009). Wind Turbine Sound and Health Effects: An Expert Panel Review. Prepared for the American Wind Energy Association and the Canadian Wind Energy Association. Available at http://awea.org/newsroom/releases/12-15-09-sound_panel_release.html There have been no epidemiological studies of the health effects of wind turbine noise. Wind turbine noise is "not unique." It consists of low-frequency noise and infrasound. Low frequencies are more difficult to detect than higher frequencies. The A weighting decibel scale does not work well with low frequency sound.2 Higher frequencies are "controlled more readily" than low frequency sounds. "[M]ost external sound when heard indoors is biased towards low frequencies." According to Alves-Pereira and Branco (2007), low frequency noise can adversely affect health even when the levels are below the average person's ability to detect or hear them. Low frequency sounds may be "irritating" and "stressful" and some complaints are "impossible" to resolve. Infrasound and low frequency sound may cause indirect physiological effects, similar to the effects from other sounds. Some studies report vibro-accoustic disease (thickening of cardiovascular structures, such as blood vessels) from inaudible wind turbine sound levels of 40 to 50 dBA. A higher proportion of people are annoyed by wind turbines than by other sources of environmental noise at the same decibel level. Any sound that is chronically annoying may create "chronic stress, which can lead to other health problems." Chronic noise exposure can lead to chronic health problems, such as hypertension and heart disease. Noise induced hearing loss may cause hypertension. Noise can "create conditions of psychological stress . . . which can, in turn, cause physiological stress reactions." Protracted annoyance may undermine coping and progress to stress related effects. Research by Pedersen and Persson Waye found that wind turbine noise was more annoying than several other environmental sources at comparable levels. The "swishing"

2 The PSC uses the A weighting scale to measure turbine noise,

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from turbines was found to be the "most annoying type." Wind turbine sound is "easily perceived." Compared with sound from other sources, wind turbine noise as low as 35 to 40dBA was annoying to 5% of people. Wind turbine noise of 40 to 45 dBA was annoying to 18% of people. Another study found that approximately 10% of a sample of more than 1000 people reported being "very annoyed" at wind turbine levels of 40 dB and higher. Wind turbine noise can be more annoying at lower levels than traffic noise. The main adverse health effect of noise stress is sleep disturbance, which may lead to other adverse health consequences. The United States Environmental Protection Agency has concluded that sound levels as low as 35dBA indoors may disrupt sleep. 2. Minnesota Department of Health (2009). Public Health Impacts of Wind Turbines. Available at http://energyfacilities.puc.state.mn.us/resource.html?Id=24519 Case studies have suggested that health can be impacted by relatively low levels of low frequency noise," including "indisposition, decrease in performance, sleep disturbance, headache, ear pressure, crawl parasthsy [crawling, tingling or numbness sensation of the skin] or shortness of breath. Low frequency noise, unlike higher frequency noise, can also be accompanied by shaking, vibration and rattling. In addition, throbbing and rumbling may be apparent in some low frequency noise. While these noise features may not be easily characterized, numerous studies have shown that their presence dramatically lowers tolerance for low frequency noise (Bergland et al., 1996). Swedish studies have found that almost 25% of people surveyed reported annoyance from wind turbines at noise measurements as low as 35 dBA. Swedish studies have also found that noise annoyance from wind turbines was more likely in “areas rated as quiet and in areas where turbines were visible. In one of the studies, 64% of respondents who reported noise annoyance also reported sleep disturbance . . .." A number of un-reviewed reports have catalogued complaints of annoyance and some more severe health impacts associated with wind farms . . . The most common complaint is decreased quality of life, followed by sleep loss and headache.” A study in the United Kingdom reported complaints of “palpitations, migraines, tinnitus, anxiety and depression. [Nina Pierpont, MD, PhD] (2009) postulates wind turbine syndrome, consisting of a constellation of symptoms including headache, tinnitus, ear pressure, vertigo, nausea, visual blurring, tachycardia, irritability, cognitive problems and panic episodes associated with sensations of internal pulsation. She studied 38 people in 10 families living between 1000 feet and slightly under 1 mile from newer wind turbines. She proposes that the mechanism for these effects is disturbance of balance due to “discordant” stimulation of the vestibular system, along with visceral sensations, sensations of vibration in the

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chest and other locations in the body, and stimulation of the visual system by moving shadows. Pierpont does report that her study subjects maintain that their problems are caused by noise and vibration, and the most common symptoms reported are sleep disturbances and headache. However, 16 of the people she studied report symptoms consistent with (but not necessarily caused by) disturbance of equilibrium. . . .

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 is primarily a problem that may effect some people in their homes, especially at night problem for businesses, public buildings, or for people outdoors. The most common complaint in various studies of wind turbine effects on people is annoyance or an impact on quality of life. Sleeplessness and headache are the most common health complaints and are highly correlated (but not perfectly correlated) with annoyance complaints. Complaints are more likely when turbines are visible or when shadow flicker occurs. 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). It has been hypothesized that direct activation of the vestibular and autonomic nervous system may be responsible for less common complaints, but evidence is scant. The Minnesota nighttime standard of 50 dB (A) not to be exceeded more than 50% of the time in a given hour, appears to underweight penetration of low frequency noise into dwellings. Different schemes for evaluating low frequency noise, and/or lower noise standards, have been developed in a number of countries. For some projects, wind velocity for a wind turbine project is measured at 10 m and then modeled to the height of the rotor. These models may under-predict wind speed that will be encountered when the turbine is erected. Higher wind speed will result in noise exceeding model predictions. Low frequency noise from a wind turbine is generally not easily perceived beyond 1/2 mile. However, if a turbine is subject to aerodynamic modulation because of shear caused by terrain (mountains, trees, buildings) or different wind conditions through the rotor plane, turbine noise may be heard at greater distances. 3. Richard R. James (2009). Comments on WEPCO’s Glacier Hills Application and Supporting Documents Regarding Wind Turbine Noise and Its Impact on

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the Community. PSC REF# : 121105. Available at www.psc.state.wi.3 Those who assert that there is no research supporting a causal link between wind turbine sound emissions at receiving properties and homes and health effects do not reflect current understanding of thresholds of perception and mechanisms whereby such perception can occur. Wind turbine noise is experienced as more annoying than other sources of noise at the same or lower decibel level. Annoyance can start at sound levels of 10dBA or more below the level that would cause equivalent annoyance from other common noise sources. Whereas one would expect that people would be annoyed by 45dBA nighttime sound levels outside their homes in an urban area, rural residents are equally annoyed by wind turbines when the sound levels are 35dBA independent of the time of day. [T] he human body is more sensitive to infra and low-frequency noise (ILFN) and the organs of balance (vestibular) and cardio-vascular systems

respond at levels of sound significantly lower than the threshold of audibility. . . Wind turbine noise includes a significant low-frequency component, including inaudible infrasound….

Low frequency noise, the frequency range from about 10Hz to 200Hz, has

been recognized as a special environmental noise problem, particularly to sensitive people in their homes. Geoff Leventhall, Low Frequency Noise and Annoyance, 6 Noise & Health 23 (2004), ex. 809, p. 109. Leventhall bases his opinion on the findings of the World Health Organization. The World Health Organization recognizes the special place of low frequency noise as an environmental problem. Its publication on Community Noise (Berglund et al., 2000) makes a number of references to low frequency noise, some of which are as follows:

It should be noted that low frequency noise, for example, from ventilation systems can disturb rest and sleep even at low sound levels. For noise with a large proportion of low frequency sounds a still lower guideline (than 30dBA) is recommended. When prominent low frequency components are present, noise measures based on A-weighting are inappropriate Since A-weighting underestimates the sound pressure level of noise with low frequency components, a better assessment of health effects would be to use C weighting.

3 Go to "ERF," then "Search ERF," then enter PSC REF #.

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It should be noted that a large proportion of low frequency components in a noise may increase considerably the adverse effects on health. The evidence on low frequency noise is sufficiently strong to warrant immediate concern.4 4. Maynard, Robert and Morehouse, Andy (2009). Environmental Noise and Health in the UK. UK Health Protection Agency on behalf of an ad hoc Expert Group on the Effects of Environmental Noise on Health. Draft for Comment. http://www.hpa.org.uk/web/HPAwebFile/HPAweb_C/1246433634856 "Annoyance is probably the most widespread adverse effect of noise." "That sleep can be affected by noise is common knowledge." Exposure to noise has been shown to be associated with increased levels of

stress hormones in the blood. These include the adrenal cortico-steroids and also adrenaline and noradrenaline which reflect activity of the sympathetic system. Whether such increases in concentrations are harmful is uncertain but some authors have linked such changes with the possibility of long-term effects on blood pressure and on cardiovascular disease.

Long–term exposure to high levels of noise in the occupational setting has

been shown to be related to the likelihood of individuals developing cardiovascular disease. Recent research in community settings shows a similar relationship between transport noise and elevated blood pressure and medication for hypertension and a small increased risk of cardiovascular disease.

It has been suggested that exposure to environmental noise is associated with an increased likelihood of development of mental illness. This assertion has attracted some attention but the evidence is by no means clear cut. In our view it has not been established that exposure to environmental noise is linked to the likelihood of developing mental illness, although further research is recommended. Exposure to environmental noise has been shown to be linked with impairment of cognitive performance amongst children exposed to raised sound levels. A number of well conducted studies have confirmed this. Less clear are the long-term implications of this finding.

Complaints about low frequency noise come from a small number of people but the degree of distress can be quite high. There is no firm evidence that exposure to this type of sound causes damage to health, in the physical sense, but some

4 The WHO Guidelines for Community Noise are available at http://www ruidos.org/Noise/WHO Noise guidelines contents html

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people are certainly very sensitive to it. In some, but by no means all cases a source can be identified and controlled. For some who suffer from the effects of exposure to low frequency noise development of a coping strategy can be helpful.

Environmental noise is a problem in the UK today and many people are

concerned about its possible effects on health. In terms of wellbeing we have little doubt that a significant number of people are adversely affected by exposure to environmental noise. If it is accepted that health should be defined in such as way as to include wellbeing then these people can be said to suffer damage to their health as a result of exposure to environmental noise. There is increasing evidence that environmental noise, from both aircraft and road traffic noise is associated with raised blood pressure and with a small increase in the risk of coronary heart disease. Evidence that environmental noise damages mental health is, on the other hand, inconclusive.

We strongly urge that a programme of research into the effects of

environmental noise on health in the UK be established. A number of recommendations for further research have been made.

5. Stelling, Keith MA, MNIMH, Dip Phyt, MCPP (2009). Summary of Recent Research on Adverse Health Effects of Wind Turbines. Available at http://www.wind-watch.org/documents/summary-of-recent-research-on- adverse-health-effects-of-wind-turbines/

A generally acknowledged major concern about wind turbine disturbance centres around the low frequency noise projected from this heavy industrial machinery. Until recently measurements of this type of noise have seldom been carried out near wind turbines.

There is already ample scientific evidence that low frequency noise is a

cause of sleep disturbance in humans. The evidence also suggests that long term exposure normally leads to serious health problems.

Reinforcing this body of knowledge is the research that has been

conducted on animals. Long term studies by European biologists indicate that habitat disturbance and abandonment takes place around wind turbine developments. Further research on animals indicates that basic survival functions such as hunting, self protection and reproduction are interrupted by low frequency noise exposure.

The only effective mitigation is to adequately separate wind turbine

developments from sensitive wildlife habitats and human dwellings. It should be no great surprise to policy makers that failure to do so exposes the rural population to a serious health threat. The only mystery is why public health authorities, Members of Provincial Parliament and the wind industry have

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not yet accepted their responsibility to exercise due diligence in protecting human health and already done this. This report is intended to bring together the most recently published literature so that decision makers can now go forward and act preventatively before any further human suffering needlessly occurs.

DPH Should Conduct a Formal Investigation Into the Health Effects of Wind Energy Systems in Wisconsin DPH is "responsible for environmental and public health regulation" and for administering programs that "address environmental and occupational health, family and community health . . . injury prevention, chronic disease prevention and health promotion . . .. DPH [p]romotes public health through a statewide program to increase public awareness of environmental hazards . . . and prevent and control exposure to environmental hazards." DPH has reported on numerous subjects, from air and water quality to lead in venison. http://dhs.wisconsin.gov According to RENEW Wisconsin, 306 commercial wind turbines with the capacity to generate 449 MW of electricity were installed in Wisconsin between 1998 and 2009. http://www.renewwisconsin.org/windfarm/windwisconsin.htm. The PSC recently authorized the construction of up to 90 additional turbines with the capacity to generate 207 MW of electricity.5 An application to construct another 100 turbines with the capacity to generate up to 150 MW was filed with the PSC in October 2009.6 In your letter to Liv Moyer, you admit that DPH has knowledge "gaps;" you state the need to conduct further medical evaluations; you state the need to determine the links between wind turbine noise and health complaints; you state the need to improve DPH's understanding of those links; you state the need to "minimize potential impacts of wind energy systems; and you declare that it is DPH's intention to "continue to seek data and information," I can think of no reason why DPH would refuse to conduct a formal investigation of the health impacts of wind energy systems in Wisconsin, pursuant to the mission and activities of your office and the division's own admitted needs.

5 Application of Wisconsin Electric Power Company for a Certificate of Public Convenience and Necessity to Construct a Wind Electric Generation Facility and Associated Electric Facilities, to be Located in the Towns of Randolph and Scott, Columbia County, Wisconsin, Docket No. 6630-CE-302.6Application of Ledge Wind Energy, LLC for a Certificate of Public Convenience and Necessity to construct a 150 MW Wind Electric Generation Facility and Associated Transmission Facilities, to be Located in the Towns of Morrison, Holland, Wrightstown and Glenmore, Brown County, Wisconsin, Docket No. 9554-CE-100