Comment to Falmouth Board of Health regarding state Wind Science Panel Report

January 30, 2012

Board of Health

Falmouth Town Hall

59 Town Hall Square

Falmouth, MA 02540

 

Re: Comment to Falmouth Board of Health regarding state Wind Science Panel Report

 

Dear Chairperson Harkness and Board Members,

The board made the invitation welcoming public comment while the board reviews the Wind Science Panel’s Report.  I continue to review the report myself.  However, I wanted to share with you my initial impression of what effect this report may have on Falmouth, as well as all Commonwealth munici- palities.

I cite the letter received by the board from Ms. Weinstein, Deputy Asst. Commissioner, Bureau of Waste Prevention, “Based on the report findings and public comments received, MassDEP may choose to review it’s current noise policy and propose changes if warranted.”

The language causing most concern is the address of current noise DEP guidelines that may be modified and become less protective.  Here’s how.

Couple the intent of Ms. Weinstein’s letter; “MassDEP may choose to review it’s current noise policy and propose changes if warranted,” with the recommendation made by the Panel.  This is the excerpt from the Panel’s report.  “The Panel recommends that noise limits such as those presented in the table above be included as part of a statewide policy regarding new wind turbine installations.”

The alarming issue raised for Falmouth, if the recommendation is adopted, is that the current 40bB limit would raise to 45dB (Villages, mixed usage 45dB(A) per the Promising Practices for Nighttime Sound Pressure Levels by Land Use Type, Pg. ES-10).  I use the “ Villages, mixed usage” criteria for sake of argument, though it’s contended our neighborhood correlates more appropriately with “Land Use, Residential.”

I believe if 45dB(A) were adopted as policy, community’s would be worse for the wear.  Falmouth’s  21 month long problem would remain unresolved, and a perplexing dilemma would be-fall the Planning Board’s new wind turbine bylaw drafting efforts.

Reflect closely on the following language directly from the report.

-“Wind turbines can produce unwanted sound (referred to as noise) during#operation (p. ES-4)”

- “In other words, it is possible that noise from some wind turbines can cause sleep disruption (p. ES-6)

-“Since the most commonly reported complaint by people living near turbines is sleep disruption…” (p. 14)

- “It is acknowledged that noise from wind turbines can be annoying to some and associated with some reported health effects (e.g., sleep disturbance) (p.29)

-“The epidemiological studies indicate that noise and/or vibration from wind turbines has been noted as causing sleep disruption (p. 30)

-“Given the effects of sleep deprivation on health and well-being, including problems with mood and cognition, it is possible that cognitive and mood complaints and other medical or psychological issues associated with sleep loss can stem from living in immediate proximity to wind turbines, if the turbines disrupt sleep (p.32-33)

These represent one important fact.  The Report’s evidence demonstrate that industrial wind turbines cause annoyance and disrupt sleep.

No matter the Panel’s cited evidence, no matter the guidance offered by DEP or DPH, the board knows the complaints, the documented illnesses, and the dimension to our community’s problem.

Presenting the board’s feed-back to the state, intensely watched statewide, makes it all the more valued since the  board’s response will hold great sway in validating the Panel recommendations.  The recommendation I encourage the board to embrace is “In general, more comprehensive assessment of wind turbine noise in populated areas is recommended (p. ES-11).

I urge the board to take great care in it’s response.  And I strongly urge the board not to weigh your responsibility to the community’s wellness lightly.

The general fallout from new noise scaling could allow local health, planning and selectmen boards an inflated metric to deploy against suffering neighbors and neighborhoods.  Such actions would certainly reduce the response need of the MassDEP and MassDPH to municipal requests for turbine health-related intervention (i.e. Falmouth Board of Health request to MassDPH, March 2011).  And may contribute to even more development of IWT’s too close to neighborhoods.

Bottom-line, the Panel’s suggested revision of governing criteria will give municipal decision makers a few more decibels of reason to put new turbines too close to residents.  Revising an existing noise criteria that has been demonstrated not to be effective in Falmouth, to a degree that further reduces the public’s protection, couldn’t conceivably be considered a “best practice.”

The MassDEP and MassDPH must be made aware of the dilemma the Panel’s recommendation presses upon our community.  I urge the board to relay to the state that such action, if adopted, would be in conflict with, as well as be diametrically opposite to the Falmouth Board of Health’s mission.

Respectfully,

Mark J. Cool

Fire Tower Rd.

Falmouth, MA

Copy:

Jeffrey M. Ellenbogen, MD; MMSc#

Assistant Professor of Neurology, Harvard Medical School#

Division Chief, Sleep Medicine, Massachusetts General

Hospital#

jeffrey_ellenbogen@hms.harvard.edu#

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Sheryl Grace, PhD; MS Aerospace & Mechanical Engineering#

Associate Professor of Mechanical Engineering, Boston

University#

sgrace@bu.edu #

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Wendy J Heiger-Bernays, PhD#

Associate Professor of Environmental Health, Department of

Environmental Health,#

Boston University School of Public Health#

FROM THE DESK OF

!

MARK COOL!

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Chair, Lexington Board of Health#

Email unavailable#

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James F. Manwell, PhD Mechanical Engineering;#

MS Electrical & Computer Engineering; BA Biophysics#

Professor and Director of the Wind Energy Center, Department

of Mechanical & Industrial#

Engineering University of Massachusetts, Amherst#

manwell@ecs.umass.edu#

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Dora Anne Mills, MD, MPH, FAAP#

State Health Officer, Maine 1996–2011#

Vice President for Clinical Affairs, University of New England#

Email unavailable#

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Kimberly A. Sullivan, PhD#

Research Assistant Professor of Environmental Health, De-

partment of Environmental Health,#

Boston University School of Public Health#

Email unavailable#

#

Marc G. Weisskopf, ScD Epidemiology; PhD Neuroscience#

Associate Professor of Environmental Health and Epidemiology#

Department of Environmental Health & Epidemiology, Har-

vard School of Public Health#

mweissko@hsph.harvard.edu#

FROM THE DESK OF

!

MARK COOL!

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