Download Quiet Area 5.6.7 WHAT LIMIT SHOULD APPLY A noise limit of

Quiet Area
5.6.7 WHAT LIMIT SHOULD APPLY
A noise limit of 40dbA attributable to one or more wind turbines, should be applied in order to
restrict noise from wind turbines at noise sensitive properties.
Applying a limit with no explanation on how this level is going to be measured is a nonsense. I do not
know what sounds will be included in this limit. Will AM, low frequency and infrasound be included.
Why is the A-weighed measuring scale used, when it is already acknowledged that using this
measuring technique, eliminates all the infrasound and some low frequency ranges.
“A cooperative study into infrasound and low frequency noise at a wind farm in Wisconsin USA by
four acoustic consulting firms considered that:
The four investigating firms are of the opinion that enough evidence and hypotheses have been
given herein to classify LFN and infrasound as a serious issue, possibly affecting the future of the
industry. It should be addressed beyond the present practice of showing that wind turbine levels
are magnitudes below the threshold of hearing at low frequencies
Infrasound remains a comparatively high profile issue in some jurisdictions and it is the subject of
ongoing research.” (pg 45)
“Even when A-weighted levels are considered, a substantial part of the noise is at low frequencies,
and for several of the investigated large turbines, the one-third-octave band with the highest level is
at or below 250 Hz. It is thus beyond any doubt that the low-frequency part of the spectrum
plays an important role in the noise at the neighbours” (Marshall Day, pg 47)
“For assessment of low frequency noise, the World Health Organization has stated that:
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. C-weighted
broadband noise levels are often cited in low frequency noise assessment guidance documents. “
The Government should adopt the World Health Organisation’s guidelines on Community Noise.
The noise from Wind turbines is continuous and should come under the same guidelines as all
continuous noises in the community and should not be measured differently. The WHO states that
30db should be the max level measured in a bedroom with open windows, if negative effects on
sleep and averse after effects are to be avoided. They WHO also advises that where the noise is
composed of a large portion of low frequency noise ( i.e the noise from wind-turbines), a lower value
again should be operational. Where back ground levels are low, a lower guideline again is strongly
recommended. (http://www.who.int/docstore/peh/noise/Comnoise-4.pdf). Based on the WHO
guidelines, the government should adopt a daytime and night-time maximum increase of no more
than5dB above ambient sound with the windows open.
The EPA’s publication: Environmental Quality Objectives- Noise In Quiet Areas, describes a “quiet
area” in open country according to satisfying the following criteria:
At least 3 km from urban areas with a population >1,000 people;
At least 10 km from any urban areas with a population >5,000 people;
At least 15 km from any urban areas with a population >10,000 people;
At least 3 km from any local industry
At least 10 km from any major industry centre;
At least 5 km from any National Primary Route, and;
At least 7.5 km from any Motorway or Dual Carriageway.
In the event that these criteria are satisfied then a very stringent noise criterion may be considered
appropriate. The Environmental Quality Objectives –Noise in Quiet Areas document proposes that
the following criterion be applied to anthropogenic noise sources in quiet areas: ‘The noise from
anthropogenic sources should not be clearly audible at any point within Quiet Areas’.
In order to comply with this criterion it is necessary to conduct an extensive background noise
survey, at a number of locations, over an extended period, under a range of weather conditions, in
order to establish existing noise levels. The results of the survey should be analysed to establish the
average background noise levels (in terms of LAF90) during daytime, evening and night-time periods.
The resultant noise criterion applicable to the licensed facility (in terms of either LAr,T or LAeq,T) is
then derived by subtracting 10dB from the average background noise level during each period. It
should be noted that, in a Quiet Area, it does not necessarily follow that levels of noise within
the area will be low. The noise levels in a quiet area will typically have little, if any, contribution from
manmade (i.e. anthropogenic) noise sources such as road or rail. However, the noise levels may be
elevated due to the natural noises that form the soundscape of the area in question.
Also, a quiet area should not be confused with an area of low background noise as these are two
distinct and different areas of concern in the context of this document.”
http://www.epa.ie/pubs/reports/research/land/EPA_noise_in_quiet_areas_ERTDI17_synthesis.pdf
“In the absence of formal standards, consideration could be given to the following proposed
standard:
• The noise from anthropogenic sources should not be clearly audible at any point within Quiet
Areas and the noise levels when measured in wind speeds of less than 2 m/s in the absence of
significant environmental (geophonic or biophonic) sounds should not exceed an LA90,1h of 30 dB
by day or an LA90,1h of 27 dB by night. (The natural baseline sound level is regarded as the LA90,1h
in the absence of anthropogenic noise when measured in wind speeds of 2 m/s or less.)
http://www.epa.ie/pubs/reports/research/land/EPA_noise_in_quiet_areas_ERTDI17_synthesis.pdf
These are the guidelines and recommendations from The EPA’s guidelines on noise in quiet areas.
Large proposed areas for wind turbines qualify as quiet areas, especially areas near boglands.
Under the European Directive 2002/49/EC of the European Parliament and of the Council of
25 June 2002 relating to the assessment and management of environmental noise Declaration by the Commission in the Conciliation Committee on the Directive relating to
the assessment and management of environmental noise which was adopted by Ireland in
2006.
The following numbered points are relevant to the noise limit:
(1) It is part of Community policy to achieve a high level of health and environmental
protection, and one of the objectives to be pursued is protection against noise. In the Green
Paper on Future Noise Policy, the Commission addressed noise in the environment as one of
the main environmental problems in Europe.
(2) In its Resolution of 10 June 1997(5) on the Commission Green Paper, the European
Parliament expressed its support for that Green Paper, urged that specific measures and
initiatives should be laid down in a Directive on the reduction of environmental noise, and
noted the lack of reliable, comparable data regarding the situation of the various noise
sources.
(7) In accordance with the principle of subsidiarity as set out in Article 5 of the Treaty, the
Treaty objectives of achieving a high level of protection of the environment and of health
will be better reached by complementing the action of the Member States by a Community
action achieving a common understanding of the noise problem. Data about environmental
noise levels should therefore be collected, collated or reported in accordance with
comparable criteria. This implies the use of harmonised indicators and evaluation methods,
as well as criteria for the alignment of noise-mapping. Such criteria and methods can best be
established by the Community.
(8) It is also necessary to establish common assessment methods for "environmental noise"
and a definition for "limit values", in terms of harmonised indicators for the determination
of noise levels. The concrete figures of any limit values are to be determined by the Member
States, taking into account, inter alia, the need to apply the principle of prevention in order
to preserve quiet areas in agglomerations.
(9) The selected common noise indicators are Lden, to assess annoyance, and Lnight, to
assess sleep disturbance. It is also useful to allow Member States to use supplementary
indicators in order to monitor or control special noise situations. http://eurlex.europa.eu/LexUriServ/LexUriServ.do?uri=CELEX:32002L0049:EN:HTML
Setting an absolute 40dBA noise limit for quiet areas is against this directive and the EPA
guidelines. Also suggesting a limit with no explanation of what is to be measured, how it is
going to be measured, and no regard for the existing ambient noise in an area is completely
against this European directive (which Ireland adopted in 2006).
Following the EPA recommendations, there must be a max 30dB day-time noise limit and a
27dB night-time limit set for quiet areas.