James review of noise studies for the proposed Ocotillo wind energy facility

Acoustics expert, Mr. Richard James, filed these comments on behalf of the Protect Our Communities Foundation and Backcountry against Dumps, Inc. as part of their public comments on the BLM EIS/EIR for the proposed Imperial County, Ocotillo Wind Energy Facility. Mr. James' testimony details the major problems with Cadna/SoundPlan and other commercial noise modeling software products based on the ISO 9613-2 noise modeling standard.

Conclusion of Mr. James testimony

It is the opinion of this reviewer, based on his personal experience and the review described in this document that a properly conducted study would identify higher sound levels and higher annoyance levels than presented in the EIS/EIR. More homes will have sound levels that exceed 40 dBA, some by as much as 8 dBA or more. When adjusted for known tolerances of algorithms and measurements used to construct the model, the increased sound power emitted by wind turbines at night under conditions of high wind shear, and normalized to account for the quiet rural community and impulsive character of the wind turbines both the BLM's Ldn and Imperial's CNEL criteria will be exceeded. The WHO nighttime limits of 40 dBA for safe sleep and avoidance of adverse health effects will also be exceeded.

The soundscape in non-residential areas used for campgrounds and outdoor recreation in the adjacent State Park will no longer be the natural sounds of nature but instead the industrial sounds of wind turbines. The belief that the noise from the highways will somehow 'mask' the wind turbine sounds is not supported by current research. Further, there is reason to be concerned that for a sub-set of the people in the community the infrasound and low frequency content of the wind turbine noise will pose additional health risks due to interactions with their organs of balance.

These concerns are not hypothetical. There are many similar large scale wind turbine projects operating in the U.S. and around the world. A fair number of these projects result in complaints from people living near or inside the project's footprint of night time sleep disturbance and symptoms that are part of wind turbine syndrome. These projects were granted permits based on the same process of assessing background sound levels and computer modeling that were used for the Project. Given the analysis above it is reasonable to conclude that this project will join the ranks of wind utilities that cause adverse health conditions and noise pollution if it is approved.

This project should be rejected based on the concerns raised in this report. None of the alternative scenarios are compatible with the community and current land use.

In the opinion of this reviewer the Project will result in the exposure of persons to or generation of noise levels in excess of BLM Guideline, standards established in the Imperial County noise ordinance, and also exceed the WHO 2009 nighttime guidelines setting of 40 dBA (Leq) at night as the threshold for adverse health effects. It will also result in a substantial permanent increase in ambient noise levels in the project vicinity above levels existing without the project.

The Project, as currently proposed should be rejected.

11 10 06 Final Ocotillo Wind Review Of Noise Studies And Related Material

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OCT 5 2011
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