An excerpt of Carmen Krogh's preliminary submission is provided below. A Draft Proposal Dose Response study design (see link) was submitted to Health Canada by Krogh in May 2012 on invitation but was ignored. The key messages of this submission are:
- Reconstitute the Study Team, address the issues raised in this submission and ensure independent subject expertise participation.
- Discontinue the placement of wind energy facilities in proximity to humans until definitive research confirms human health protection for all exposed individuals.
The purpose of this submission is to provide my initial comments on the Health Canada Wind Turbine Noise and Health Study [the Study].
Members of the international public and scientific communities have requested my initial comments about the Study.
I have provided a copy of my comments to The Right Honourable Stephen Harper, Prime Minister of Canada, The Honourable Leona Aglukkaq, Minister of Health and the public.
The comments provided in this preliminary submission are intended to contribute my knowledge and expertise on the health effects of industrial wind turbines.
Basis for comment
On July 10, 2012 Health Canada announced the Study.
Study design peer review comments have been given a submission deadline of September 7, 2012. Attendees at conferences have the additional opportunity to participate in the peer review process.
Study design information provided by Health Canada appears to be limited 2 primarily to a few web pages and a paper authored by David S. Michaud, Stephen E. Keith, Katya Feder, Tara Bower and entitled "Health Impacts and Exposure to Wind Turbine Noise: Research Design and Noise Exposure Assessment " [Michaud et al (2012)]which is to be presented at InterNoise 2012.
As of the date of this submission some requests for clarification from Health Canada regarding the Study remain outstanding. Health Canada has suggested requests for information and/or clarifications should be referred to the Access to Information and Privacy (ATIP) request process. ATIP requests have been initiated and can be expected to take some time to obtain.
Therefore, the preliminary comments expressed in this document are based on the limited information currently publicly available.
I have offered to share my expertise and participate on the Study Team. For information, attached is the CONFIDENTIAL Draft Proposal Researching Human Health and Industrial Wind Turbines: A Dose Response Relationship, Prepared by Carmen Krogh, May 4, 2012.
- Based on existing evidence a 2011 Ontario Environmental Review Tribunal found that wind turbines can harm to humans if facilities are placed too close to residents. The debate has now evolved to one of degree.
- At least two published case studies have documented reports of adverse effects from individuals exposed to Canadian industrial wind turbine facilities;
- In some cases affected Canadians have effectively abandoned their homes and/or negotiated financial agreements with the wind energy developer.
- In 2009, The American Wind Energy Association and The Canadian Wind Energy Association "...established a scientific advisory panel ..."10 and funded a literature review, Colby et al. (2009). Colby et al acknowledges the symptoms documented in Dr. Pierpont's case study (which includes Canadian subjects) and states the symptoms "... are not new and have been published previously in the context of "annoyance"..." and are the "... well-known stress effects of exposure to noise ..."
- References produced by12 or for13 the Ontario Ministry of Environment report adverse effects or health impacts can be expected at typical Ontario wind turbine setback and noise levels;
- It is reasonable to assume that reported health effects from wind farms are going to proliferate in the future;
- Health Canada's apparent acknowledgement of the need for research is a positive development;
- The Study is not expected to be completed until 2014;
- The Study will not provide a definitive answer its own;
- Health Canada has not provided sufficient Study detail to the public and scientific communities on which to base comprehensive and meaningful peer review comments;
- There remain Study uncertainties that require clarification.
Wind turbines can harm humans if placed too close to residents.
Adverse health effects have been reported by individuals, including Canadian residents, exposed to wind turbine facilities.
Plausible mechanisms of causation have been identified.
Adverse effects are expected to occur at typical setback distances and sound pressure levels experienced in Ontario.
There are Study issues that must to be resolved before as a peer reviewer I can support the Study.
There is sufficient evidence to warrant that precautionary and preventative steps be taken to avoid harm to human health.
Based on the information currently available I recommend that Health Canada:
Reconstitute the Study Team, address the issues raised in this submission and ensure independent subject expertise participation;
Conduct in-person interviews with the Canadian residents reporting adverse health effects before finalizing the Study design;
Draft a detailed meaningful Study design and proposal and provide an appropriate comment period;
Focus on prevention and invoke the precautionary principle;
Discontinue the placement of wind energy facilities in proximity to humans until definitive research confirms human health protection for all exposed individuals;
Investigate and resolve wind energy facilities where adverse effects are reported.