On the 12th December 2019 the Irish Department of Housing, Planning, Community and Local Government (DHPLG) released a proposed update to the Wind Energy Development Guidelines (WEDG). The draft update was produced with input from Department of Communications, Climate Action and Environment (DCCAE) and is subject to a 10-week consultation period.
The publication of the draft follows a review of the original WEDG which were published in 2006. Amazingly, the process of producing the update started all the way back in 2013. The fact that the review has taken so long is testament to the complex technical, political and environmental considerations which the Government departments have been seeking to consider and balance.
The guidelines cover a range of topics including
- Visual Amenity Setback;
- Shadow Flicker;
- Consultation Obligations;
- Community Dividends; and
- Grid Connections.
In relation to noise, the draft guidance makes some significant changes to the approach set out in 2006. The guidance provided in relation to noise in the original WEDG was lacking in detail and subject to a degree of interpretation. The draft update includes significantly more detail than the original 2006 version with a noise section that is now 60 pages long.
Since the first Irish windfarm began operating at Bellacorrick in 1992 there have been significant advances in the field of wind farm acoustics; it is a field which continues to develop today. The fact that the guidelines published in 2006 were subject to a review after just five years is a case in point.
When setting noise limits for any form of development there is a balance to be struck between the aim of reducing noise (and protecting those affected by the noise) and the desire for development. For certain types of development (e.g. motorways and airports) noise limits are set at relatively high levels in acknowledgement of the benefits to society. Striking the right balance is very difficult and the setting suitable limits is a matter for Government.
The DHPLG and DCCAE were clearly keen to ensure that the draft update considered the latest information available and reference has been made to the World Health Organisation (WHO) document ‘Environmental Noise Guidelines’ which were published in 2018. The WHO’s conclusions in that document relating to wind farm noise are however heavily caveated in its guidance, which notes that:
“Further work is required to assess fully the benefits and harms of exposure to environmental noise from wind turbines and to clarify whether the potential benefits associated with reducing exposure to environmental noise for individuals living in the vicinity of wind turbines outweigh the impact on the development of renewable energy policies in the WHO European Region”.
The WHO guidance also goes on to note, in relation to the ‘conditional’ recommendations made regarding wind turbine noise that:
“A conditional recommendation requires a policy-making process with substantial debate and involvement of various stakeholders. There is less certainty of its efficacy owing to lower quality of evidence of a net benefit, opposing values and preferences of individuals and populations affected or the high resource implications of the recommendation, meaning there may be circumstances or settings in which it will not apply.”
Whilst it is only right and proper that the guidance considers the latest information but care must be taken not to set guidance which will be in place for a number of years based on recommendations in documents like the WHO guideline which themselves suggest further work is required.
In the UK, the Government seemingly acknowledged the potential for further scientific developments by supplementing the guidance used to assess wind farms (ETSU-R-97 – which was produced in 1996) with a Good Practice Guide produced by the Institute of Acoustics (IOA GPG – which was produced in 2013). The IOA GPG notes in its preface that:
“The IOA will keep the document under review, and consider updating when significant changes to current good practice have occurred”.
Arguments will persist regarding whether the limits should be higher or lower but this is, in reality, a political decision which needs to balance up a number of factors including the need to protect residents, the climate emergency and Irelands ambitious renewable energy targets.
Putting the actual noise level limits to one side, there are a number of technical points in the draft update which TNEI believe require urgent consideration. Accordingly, in December 2019 James Mackay and Jim Singleton co-ordinated and submitted a holding response on behalf of a number of Acousticians who are either based in Ireland or have worked on wind farm projects in Ireland. The holding response, which you can read here, sets out a number of areas of concern and requests detailed, interactive consultation.
Unfortunately, at the time of writing Government have declined to meet with the group to discuss the points raised, they have however welcomed written submissions. James and Jim continue to work with the Group of Acousticians to provide further detail on the concerns raised and we will be looking to feed those back as part of the ongoing consultation process; we very much hope that Government will meet with the group to discuss the points raised.
TNEI strongly believe that it is necessary to consider the potential for further developments in the field of wind farm acoustics and to understand how the new guidelines would enable the industry to react to any such developments. Whilst the industry seems to be in broad agreement that more detail regarding noise is needed it is important to ensure that the any new guidelines include the potential to react to future research. It is not in anyone’s interests for us to be starting another review in five years time; the new guidance must be robust, proportionate and future proof and we will be doing what we can to feed into the consultation process to help achieve this aim.
Please note that the views expressed in this article of those of TNEI and do not necessarily reflect those of the other signatories of the holding response.