EBR Comment 20

Regarding the noise report

The noise report should be an important and significant part of the REA  It is full of errors and discrepancies and has serious omissions and should be considered as invalid and not meeting the requirements necessary
The REA must be denied based on the deficiencies in the Noise report and study

I have notified the proponent of deficiencies since 2009  and including the terrain, rock faces, siting errors, tower location discrepancies, tonality, receptors etc

They have ignored my comments, refused to speak to me and neglected to contact me to get further details.
Comments on the draft RA were ignored and errors persist.
Why accept something so obviously in error ?
After so many attempts, obviously there is no expectation this developer could ever produce a useful and correct study which can be used to evaluate the project

Issue 1. tower locations wrong
The tower locations in the report are not consistent. The UTM coordinates for towers 3 and 8 are not consistent form one table to the next  in various REA reports. Which location is the application for? How can the public know for certain that any of the locations are properly considered across the various reports? This is a fatal flaw in the reports

Issue 2 tower numbers wrong
Tower numbers in noise study do not correspond to the tower numbers in reports towers in noise study are 1 through 16 , and in REA they are 1 through 18. A small error but one that introduces confusion and inconsistency and potential for miscommunication with public

Issue 3 . Manufacturers report is fudged report is dated 2010 08 06, author Weinhammer. But the document as posted includes ‘Acrobat ‘ comments from ‘weinhammer dated 2011. This means the report was revised AFTER its supposed authorship date. If this is the case, what report are we really looking at? How can we rely on this report to be accurate and  to correspond to the issued 2010 report when revisions were made in 2011? What other things were changed?

Issue 4 Sound uncertainty

Noise report cover letter The modeling performed incorporated a 1.5 dB(A) safety factor applied on top of the maximum sound power level guaranteed by the wind turbine manufacturer. The manufacturer
recommends a 1 dB(A) safety factor to account for potential measurement error.

Manufacturer noise study:  the manufacturer report as part of the sound study indicates  The total measurement uncertainty is thus UC = +/- 2.2 dB.

So it seems someone is not telling the truth or there is some misunderstanding. What should the public believe? Is it that hard to properly present and interpret information?

Issue 5 – Impulsivity

Noise report Impulsivity refers to short bursts of noise, such as those created by hammering. Impulsive noise is generally not associated with modern wind turbines.  The Enercon sound power level guarantee included in Appendix C indicates that no impulsive noise is generated by the E82

Manufacturer noise study
5.3. Impulsive components  According to the subjective aural impression during the measurement period, there were no tonal components present within close range. An aural trial at more distant range did not yield any impulsive components either. The blade passage frequency was not noticeable. Table 3 displays the impulsive component results.

5.4. Directional characteristics
Via subjective aural impression, the sound emission of the WTG was investigated in various directions during an on-site visit in close range with the WTG in operation.  The throbbing of the rotor blades was more clearly audible against the wind and with crosswinds according to subjective aural impression – but not louder.

So there is no impulsivity (according to subjective IMPRESSION) but yet there was CLEAR THROBBING. This discrepancy is not addressed by the manufacturer, or the REA study This is a serious omission

Issue 6 – reflective surfaces
the proponent was told since 2009 that there are rock walls and noise reflective surfaces which will impact noise  from turbines The proponent has ignored or dismissed these issues Noise report p3 Exposed rock cliffs are located north of the wind park area, between turbines and noise receptors.   However, due to the relative orientation of wind turbines, cliffs and noise receptors, no amplification or echo effects are expected. For echoes to be produced, noise sources and receptors must be on the same side of a cliff to allow sound waves to bounce back from cliff faces. As the cliff faces are located between wind turbines and noise receptors, and are oriented to face noise receptors, these effects are not expected.
The reality is that the area is complex, with hills and slopes, and with the dispersal of towers in the project, there are most certainly steep slopes and rock faces that will reflect noise onto receptors.   The proponents statement that noise sources and receptors must be on the same side of a cliff to allow sound wave to bounce back is a simplistic and arguably insulting statement. Anyone who has played billiards knows that reflection or deflection is not simply a case of ‘bouncing back’.

This is a serious issue as I hear people on ski slopes 2 kilometres away talking- and the proponent was told this over 3 years ago – yet they continue to ignore the concern and dismiss it with absurd generalities.

Issue 7 minimum distance stated  incorrect
Rea noise report p1
The minimum distance between any wind turbine and any noise receptor as defined in O. Reg. 359/09 is 1171 m.  This is a not correct. I could not find evidence to confirm this statement.

Issue 8 Receptors not identified  correctly receptor AX should have been located in centre of lot as per sound study requirements

Issue 9  mitigation not discussed
The manufacturer and industry acknowledge that noise levels increase as blades and turbines wear. This increased noise over the lifetime of the project is not discussed, nor how to mitigate (and monitor). The mitigation discussed with the developer was not acknowledge- the night time reduced noise mode of operation which the manufacturer acknowledged.

Issue 10 – wind modeling doesn’t clearly identify when or how towers were moved

The modeling indicates for a number of receptors that they were moved , as per Google imagery
Also, the tower locations have been adjusted over the life of the project.
These movements (were tower numbers stayed the same) are not clearly identified or described anywhere in any of the reports.
How can the public know which tower location is being described, a 2009, 2010 ,2011 , or 2012 location (where tower moved but  tower number is same)
Also , why are receptors moved based on imagery from Google, when moved, and where were they before.
This give NO CONFIDENCE in the modeling, study or analysis.

Issue 11 receptors not based on ground truth
Noise modeling indicates receptors moved based on Google imagery
This is unacceptable because the proponent has been in location to attend parties and fundraisers and political meetings – yet cannot go to a few dozen homes to confirm what exactly the receptor location and specifics are.
This is totally unacceptable and shows how little regard the developer and the consultant have for the public and impacted people.

Issue 12  study indicates done by Wind Energy Engineer
The noise modeling indicates that MK Ince is Wind Energy Engineering
This cannot be confirmed – the principal is a geological engineer and the modeler is an electrical engineer
The statement that it is done by Wind Energy Engineering can mislead public to believe that there is some credibility where there may not be

Issue 13 – noise modeling mapping indicates tower layout form 2010
The final page of the noise modeling study indicates that the layout is 1.3.7 from 2010.
This is an old layout that was revised apparently. Does this mean that the noise modeling is based on old tower locations, inaccurate receptors?
Another error which means the public is left to try to confirm whether data has changed or is inaccurate.

Issue 14 – noise modeling not meant for complex terrain
This issue has been pointed out to proponent many times over last 4 years.
The modeling is appropriate for flat or gently sloping land. The project is located as close as possible to the cliffs and steep slopes. The modeling should have been developed specifically for this site or the existing modeling confirmed through on site testing. The proponent has not adequately addressed these concerns and has dismissed or ignored those concerns

Overall the problems with these reports are serious and this report should be thrown out as not worthy of review.
For the MOE to waste their time on a report with so many errors is a waste of public resources.
The public has commented on 2 draft versions already (and pointed out many of these errors and omissions) over the last 4 years. How can the MOE continue to accept mistakes ?
This report and study is flawed based on the inappropriate modeling,  and data inaccuracies. The public cannot rely on this study, and neither should the MOE

The MOE must reject the entire REA based on the errors, and omissions in the noise study. Enough is enough. Three strikes and you’re out bucko!

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