Industrial Wind Energy Facilities Policy and Health Dec 1 2013 2

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A Commentary on Industrial Wind Energy Facilities, Policy and Risk to HealthCarmen Krogh, BScPharm, December 1, 2013

Any errors or omissions are unintended

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A Commentary on Industrial Wind Energy FacilitiesPolicy and Risk to Health

By

Carmen Krogh, BScPharm December 1, 2013

The Right Honourable Stephen HarperPrime Minister of Canada

[email protected]

The Honourable Rona AmbroseMinister of HealthHealth [email protected]

Dear Prime Minister and Minister of Health, Health Canada

Re: Open letter: Industrial wind energy facilities, policy and risk to health

I have provided a number of submissions to federal authorities on behalf of Canadianfamilies reporting adverse health effects associated with the start-up of industrial windenergy facilities. In addition, I have corresponded and met with senior officials at HealthCanada and Natural Resources Canada.

As additional background, during the last 5 years I have researched health and other effects

associated with industrial wind energy facilities. I am peer reviewed and a publishedauthor/co-author on this topic. I am guided by the numerous peer reviewed articles; judicial proceedings; acknowledgements by various experts; and by the reports of those experiencingnegative health and social-economic effects which is correlated with the start up of a windenergy facility.

Purpose: the purpose of this letter is to:

report some of the issues associated with the implementation of wind energyfacilities which are located in close proximity to homes;

respectfully urge that:o

resources be made available to achieve relief/remedy for those reportingharm;

o in the interests of rural Canadian residents, prevention and precaution beinvoked before supporting further implementation of wind energy facilities;

o based on the credible scientific support for an association between windturbine noise and community annoyance, 1 the government of Canada discloseto the public, its current policy on industrial wind energy development.


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Disclosure

I declare no potential conflicts of interest and have received no financial support with respectto the research and authorship of this commentary.

This commentary is public and may be distributed.

Executive summary

The World Health Organization (WHO) 2 and Health Canada 3 acknowledge thatgovernment policies can impact health equity.

Canadians have advised the Minister of Health that exposure to wind turbine noiseand other emissions has impaired their physical, mental and/or social well-being. 4

The health effects reported by Canadians exposed to wind energy facilities includeannoyance, sleep disturbance, physical, mental and stress, social-economic issues andreduction of living conditions and quality of life. Chronic noise annoyance, sleepdisturbance, and stress can lead to serious medical conditions.

Health Canada representatives have proposed a noise limit for Canadian windturbines which they predict will result in an increased percentage of individuals beinghighly annoyed. 5,6,7,8

An increase in the percentage of Canadians expected to suffer harm to human healthis inconsistent with Health Canadas stated responsibility to help Canadians maintain

and improve their health.9

The government of Canada has administered subsidies to over 100 wind projects.Based on the Wind Technology Road Map (TRM) document, an objective of anindustry-led, government-supported initiative is to achieve a major increase indeployment of wind energy in Canada.

The World Health Organization states with respect to noise in general that In allcases, noise should be reduced to the lowest level achievable in a particular situation.Where there is a reasonable possibility that public health will be damaged, actionshould be taken to protect public health without awaiting full scientific proof. 10

It is in the public interest of rural Canadians that Health Canadas mission of improving the lives of all Canadas people 11 and the prevention principle which is afundamental component of modern health promotion 12 be upheld.


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Wind power development in Canada

The federal government, including Health Canada, has policies to address climate change andair quality. 13

Michaud et al. (2012) states: [ Authors Note 1]

Wind turbines (WTs) are becoming an increasingly common power generationoption across North America and in many parts of the world. This source of energy isviewed as a viable and environmentally friendly alternative to fossil fuels. Since theannouncement of the Government of Canadas renewable energy initiatives, there has

been a steady rise in the number of WT installations across Canada. 14

During a February 2, 2012 presentation to the Science Advisory Board (SAB), HealthCanada representatives briefly outlined the federal involvement in wind energy. An

interdepartmental committee known as the Wind Technology Road Map (TRM) initiativenoted Health Canadas membership on the committee. 15

The Natural Resources Canada website comments on the Wind Technology Road Map andindicates a series of three industry-led, government-supported Canadian wind energystakeholder workshops were held. Indications are over 75 key players from industry,

1 Authors note: Dr. David Michaud is the Principal Investigator of the Health Canada Wind Turbine Noisestudy


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government and academia attended each workshop; however, it is unclear whether membersof the public attended. 16 (Cited 06/09/2013 )

A message from Co-Chair Geoff Munro, Assistant Deputy Minister, Natural ResourcesCanada noted the WindTRM is an industry-led, government-supported initiative toachieve a major increase in deployment of wind energy in Canada. [ pg 5 ] 17

The Executive Summary of the report comments on the WindTRMs vision: [ pg 6 ]


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The WindTRM Vision and Path Forward notes a number of benefits: [ pg 8 ]

In order to inform and engage Canadians, WindTRM action items included: [ pg 16 & 18 ]

The WindTRM conclusion comments on the vision for Canadians and notes that more than

20% of its electricity needs are met by wind. [ pg 23 ]

An appendix from WindTRM provides further information. [ pg 22 ]


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On July 7, 2012, Health Canada announced the wind turbine noise and health study andindicated its approach and that the research will ultimately support decisions, advice and policies regarding wind power in Canada:

The Science Advisory Board, February 2, 2012 presentation indicates goals, and a policy andresearch work plan.


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A Health Canada May 19, 2010 presentation indicates federal targets of 20 % by 2025 forCanadas electricity generation. It is projected that by 2015, approximately 14,000 housesand buildings (about 28,000 individuals) would be within 1,000 meters of wind turbines. 18

The national targets for generating 20% of Canadas electricity by wind power by 2025 isassociated with the June 2011 Speech from the Throne . 19


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Conclusion

In a peer reviewed reference published in Canadian Family Medicine, the official journal ofthe College of Family Physicians of Canada, Jeffery, Krogh and Horner (2013) note:

We are guided by the references and the desire to safeguard the health and wellbeingof those living in the environs of IWTs. Harm can be avoided by placing IWTs at a

protective distance from residents. The acknowledgment that health effects occur insome is an important step toward achieving this goal. 20

Some of the nontrivial percentage of Canadians highly annoyed by the sound of windturbines can be expected to experience stress related health impacts. 21,22

Allowing an increase in the percentage of Canadians expected to suffer harm to human healthis inconsistent with:

Health Canadas stated responsibility to help Canadians maintain and improvetheir health, while respecting individual choices and circumstances. 23


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Health Canadas mission of improving the lives of all Canadas people . 24 The prevention principle which is a fundamental component of modern health

promotion. 25 The WHO constitution which endorses The enjoyment of the highest attainable

standard of health is one of the fundamental rights of every human being withoutdistinction of race, religion, political belief, economic or social condition. 26

The United Nations 2012 Political Declaration on the Prevention and Control of Non-communicable Diseases which Reaffirm the right of everyone to theenjoyment of the highest attainable standard of physical and mental health; 27

Health Canadas stated belief that prevention and health promotion can holdhealth care costs down and improve quality of life in the long term. 28

"Quality of life" implies the opportunity to make choices and to gain satisfactionfrom living. Health is thus envisaged as a resource which gives people the ability tomanage and even to change their surroundings. This view of health recognizesfreedom of choice and emphasizes the role of individuals and communities indefining what health means to them. 29

The World Health Organization states with respect to noise in general:

In all cases, noise should be reduced to the lowest level achievable in a particularsituation. Where there is a reasonable possibility that public health will be damaged,action should be taken to protect public health without awaiting full scientific proof.30

Based on the evidence available, there is an opportunity for Health Canada to reconsider andretool the federal government policy supporting wind energy facilities until the issuesregarding risks to health are resolved.

There is a further opportunity to advocate for the health and social well-being of Canadianfamilies already exposed to industrial wind energy facilities in quiet rural areas. Actionshould be taken to resolve the reported health, degraded living conditions and quality of life,and the social-economic issues to the satisfaction of those currently affected.

Communities should have freedom of choice in defining what health means to them and todetermine their living environments.

I respectfully urge that the health of Canadians be given a high priority with respect to thistopic and that the current policy on wind power development be publicly disclosed.

Respectfully submitted,

Carmen Krogh, BScPharmOntario [email protected]


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References

1 Dr. David Michaud, meeting with MP Poilieve June 2013 community newsletter2 World Health Organization. (2008). Closing the gap in a generation: Health equity through action on the socialdeterminants of health (Final report of the Commission on Social Determinants of Health).http://www.searo.who.int/LinkFiles/SDH_SDH_FinalReport.pdf 3 Health and Welfare Canada, Achieving Health for All: A Framework for Health Promotion, (1986)http://www.hc-sc.gc.ca/hcs-sss/pubs/system-regime/1986-frame-plan-promotion/index-eng.php 4 Correspondence obtained from a federal Access to Information and Privacy (ATIP) request (2012)5 Keith SE, Michaud DS, Bly SHP: A justification for using a 45 dBA sound Level Criterion For Wind TurbineProjects6 Keith SE, Michaud DS, Bly SHP: A proposal for evaluating the potential health effects of wind turbine noisefor projects under the Canadian Environmental Assessment Act. Second International Meeting on Wind Turbine

Noise, Lyon France September 20 -21 20077 Keith SE, Michaud DS, Bly SHP: A proposal for evaluating the potential health effects of wind turbine noisefor projects under the Canadian Environmental Assessment Act. J Low Freq Noise V A 2008, 27:253-265.8 Howe Gastmeier Chapnik Limited. (2010, December 10). Low frequency noise and infrasound associated withwind turbine generator systems: A literature review (Rfp No. Oss-078696). Mississauga, Ontario, Canada:Ministry of the Environment pg 49 About Health Canada, http://www.hc-sc.gc.ca/ahc-asc/index-eng.php (cited February 23. 2013)10 World Health Organization. (1999). Guidelines for community noise. Geneva; OMS, 1999, p 94. Ilus,Berglund, B., Lindvall, T., and Schwela, D. H.11 Health Canada, About Health Canada, About Mission, Values, Activities, Retrieved from http://www.hc-sc.gc.ca/ahc-asc/activit/about-apropos/index-eng.php , Cited August 24, 201212 Health and Welfare Canada, Achieving Health for All: A Framework for Health Promotion, retrieved fromhttp://www.hc-sc.gc.ca/hcs-sss/pubs/system-regime/1986-frame-plan-promotion/index-eng.php , Cited August24, 201213 Health Canada, Planning For A Sustainable Future: Health Canadas 20112014 Sustainable DevelopmentStrategy 20122013 Update, May 201214 Michaud, David S. PhD, Keith, Stephen E. PhD, Feder, Katya PhD, Bower, Tara, MSc, Health Impacts andExposure to Wind Turbine Noise: Research Design and Noise Exposure Assessment, Paper presented at Inter-

Noise New York, NY, August 19-22, 201215 Access to Information and Privacy (ATIP), Slide presentation to the Science Advisory Board, February 2,201216 17 Wind TRM website www.windtrm.gc.ca Accessed November 10, 201318 Access to Information and Privacy (ATIP), Slide presentation May 19, 2010, National Guidelines Workinggroup19 Access to Information and Privacy (ATIP), Slide presentation to the Science Advisory Board, February 2,201220 Canadian Family Physician Le Mdecin de famille canadien | Vol 59: september septembre 2013http://www.cfp.ca/content/current 21 Howe Gastmeier Chapnik Limited. (2010, December 10). Low frequency noise and infrasound associatedwith wind turbine generator systems: A literature review (Rfp No. Oss-078696). Mississauga, Ontario, Canada:

Ministry of the Environment.22 Correspondence, (March 6, 2013) Dr. P Bigelow, University of Waterloo, Research Chair, Renewable energy23 Health Canada, About Health Canada, Retrieved from http://www.hc-sc.gc.ca/ahc-asc/index-eng.php CitedAugust 24, 201224 Health Canada, About Health Canada, About Mission, Values, Activities, Retrieved from http://www.hc-sc.gc.ca/ahc-asc/activit/about-apropos/index-eng.php , Cited August 24, 201225 Health and Welfare Canada, Achieving Health for All: A Framework for Health Promotion, retrieved fromhttp://www.hc-sc.gc.ca/hcs-sss/pubs/system-regime/1986-frame-plan-promotion/index-eng.php , Cited August24, 2012


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26 The Constitution was adopted by the International Health Conference held in New York from 19 Juneto 22July 1946, signed on 22 July 1946 by the representatives of 61 States (Off. Rec. Wld Hlth Org., 2, 100), andentered into force on 7 April 1948. Amendments adopted by the Twenty-sixth, Twenty-ninth, Thirty-ninth andFifty-first World Health Assemblies (resolutions WHA26.37, WHA29.38, WHA39.6 and WHA51.23) cameinto force on 3 February 1977, 20 January 1984, 11 July 1994 and 15 September 2005 respectively and areincorporated in the present text. Accessed July 15, 201227 United Nations General Assembly, Political Declaration of the High-level Meeting of the General Assemblyon the Prevention and Control of Non-communicable Diseases, A/RES/66/2, Distr.: General 24 January 201228 Health Canada, About Health Canada, Retrieved from http://www.hc-sc.gc.ca/ahc-asc/index-eng.php CitedAugust 24, 201229 Health and Welfare Canada, Achieving Health for All: A Framework for Health Promotion, retrieved fromhttp://www.hc-sc.gc.ca/hcs-sss/pubs/system-regime/1986-frame-plan-promotion/index-eng.php , Cited August24, 201230 World Health Organization. (1999). Guidelines for community noise. Geneva; OMS, 1999, p 94. Ilus,Berglund, B., Lindvall, T., and Schwela, D. H.

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Industrial Wind Energy Facilities Policy and Health Dec 1 2013 2