Wind SubmissionsPlanning SectionDepartment of the Environment, Community and Local GovernmentCustom HouseDublin 1Email: windsubmissions@environ.ie

Dear Sir/Madam, I wish to make the following submission to the Department of the Environment, Community and Local Government on the Wind Energy Development Guidelines 2006 Focused Review and the current Draft of the Statutory Wind Energy Development Guidelines (WEDG).

• Overview of the WEDG Focused Review

Due to the failure of the State to consult with the public, I was until a few months ago, unaware of both the Focused Review of the Wind Energy Guidelines 2006 and the National Policy and plans for wind farms nationally and in the Midlands Region. As a consequence, in February 2013 I was prejudiced from making an informed submission and was in effect excluded from phase 1 of this review.

In addition and without prejudice to the foregoing, I note that the timing of the original notification; the 30th January 2013 and the immediate and short period given for Phase 1 Submissions (to the 15 th

February 2013, or 10 working days) was wholly inadequate and further prejudiced the Public’s rights under the Public Consultation (Aarhus Convention) Directive.

It is apparent from the above that the intention by the Government was to keep the Public uninformed and excluded from the process, and the right to adequate time to make researched and evidenced based submissions was entirely suppressed.

With respect to the scope of the WEDG Review it too should have been subjected to public consultation. In this regard I note the position of the Irish Planning Institute which states; “these technical guidelines cannot take key strategic issues on the future location of renewable energy projects into account” and it called for “a national strategy for wind energy alongside a national landscape strategy”.

In addition to the process and scope, what is of equal concern is that those evidence based submissions which were made by the public, such as those made by CREWE and independent experts including the world leading Acoustician Dick Bowdler, and indeed by the State (the Deputy Chief Medical Officer) have been entirely ignored by the Government in the current draft.

It is of concern that these submissions were not published, particularly given the lack of public confidence in the SEAI’s oversight of the guideline review process. The lack of transparency in relation to the formulation of the draft WEDG is compounded by the failure to include the Best Practice Guidance to be contained in Appendix 1.

• I submit that the WEDG06 Review must be entirely compliant with the legally binding Consultation (Aarhus Convention) Directive and that at a minimum both a consultative and scoping phase be included to ensure all breaches as identified at paragraphs 2 to 7 above are thoroughly remedied.

2. Key Objective

The stated objective of the Draft WEDG is to achieve a balance between the protection of residential amenity and facilitating national renewable energy targets. This objective is readily achievable through the proper environmental assessment of all wind energy projects in compliance with the 1985 EIA Directive 85/337/EEC, as amended by Directive 97/11/EC, Directive 2003/35/EC, and Directive 2009/31/EC, now consolidated as Directive 2011/92/EU. The EIA Directive applies to all threshold wind farm projects in Ireland.

In terms of noise assessment, best practice on the assessment of noise requires consideration of the following issues:

• Sensitivity of location (e.g. existing land uses, Noise Management Areas, Quiet Areas); • Existing noise level and predicted change in noise level; • Character (tonal, impulsivity etc), duration, the number of occurrences and time of day of

the noise that is likely to be generated;

• Absolute level and possible dose-response relationships e.g. health effects.

The draft WEDG propose an absolute limit for wind turbine noise. While this approach does offer some clarity on the maximum acceptable level of wind turbine noise, the application of a ‘one size fits all’ limit to all environments, including Quiet Areas, without consideration of background noise levels, is in conflict with the objectives of the EIA Directive, which are to protect both the environment and the quality of life of individuals.

The proposed application of an absolute noise limit for wind turbine noise, irrespective of background noise levels, is also in conflict with the EPA Guidelines on the Information to be Contained in Environmental Impact Statements (2002). These statutory guidelines set:

“statutory criteria for the presentation of the characteristics of potential impacts”

These include an assessment of the magnitude and complexity of the impact of any development (p.23) including in the case of threshold wind farms, noise.

It is internationally accepted that an increase of 5dB in background noise levels arising from any development is significant and may have the potential to have a substantial adverse impact. It is worth noting that in the case of Strategic Infrastructure, such as the proposed DART underground project, the following comment was made in relation to noise impact:

“The emphasis – at night – should be mainly on the pre-existing ambient levels outside people’s bedrooms. Internal noise ambient levels, at night, in many houses, both rural and suburban around Dublin are of the order of 18-25LA90, and even in daytime are not much higher. External levels of 32-35 LA90 are commonplace, in calm weather. Since the proposed fixed plant will operate for many years to come, it is very important that the noise due to the plant does not cause undue discomfort or any significant sleep disturbance. It is clear that due cognisance is to be taken of the existing ambient noise levels and that the increase in

this is to be minimised. Our recommendation is that a maximum increase of 3dBA, on the lowest reoccurring LA90 5mins, should be the objective.” [emphasis added]

The draft WEDG fail to take due account of existing ambient noise levels. This inconsistency in approach in relation to wind energy projects, by contrast with comparable projects such as the DART underground project, must be addressed if a balance is to be achieved between protection of residential amenity and facilitating national renewable energy targets.

• It is submitted that the WEDG Review must take account of existing background noise levels (to include character, magnitude and complexity) and sensitivity of locations (sensitive receptors and Quiet areas) and in accordance with comparable projects such as the DART underground, set “a maximum increase of 3dBA, on the lowest reoccurring LA90 5mins”. Under no circumstances should the “substantial adverse impact” threshold of a 5dB (or greater) increase in background noise be permitted.

3. Noise Sensitive Properties & “Quiet Areas”

The omission of commercial premises from the definition of noise sensitive properties in the draft WEDG needs to be addressed. In terms of areas of special amenity value, the 2002 END Directive 2002/49/EC requires measures to be put in place to protect the amenity value of Quiet Areas in Open Country. These areas, identified in the EPA and SWS Noise in Quiet Areas Report (2000), have not been considered in the draft WEDG.

This EPA report titled; “Environmental RTDI Programme 2000–2006 ENVIRONMENTAL QUALITY OBJECTIVES, Noise in Quiet Areas” was undertaken to comply with the Environmental Noise Directive. The Executive Summary identifies the status of this report:

“The European Commission has adopted a Directive relating to the Assessment and Management of Environmental Noise (EU, 2002). Member States, including Ireland, are required to implement the Directive and to adopt action plans to meet its objective. The purpose of the directive is to protect the quality of our acoustic environment, control and manage environmental noise in built-up areas, in public parks or other acoustically valued soundscapes (Quiet Areas) in an agglomeration and in Quiet Areas in open country. Establishing the location and determining the quality of Quiet Areas is the first step towards implementation of this directive.

The Environmental Protection Agency (EPA) in association with SWS Environmental Services developed this research project to meet the requirements of this directive … The information produced by the project will make a significant contribution to the implementation of the Environmental Noise Directive and will greatly assist Ireland and other Member States in introducing accountable noise abatement development programmes and related monitoring systems for reducing and managing noise pollution.” (pg. vii – Executive Summary) (emphasis added)

“This research provided comprehensive baseline data for Quiet Areas (as defined in the proposed EU Environmental Noise Directive) throughout Ireland.” (pg. 11)

The EPA Environmental RTDI Programme identifies the base line data and location of “Quiet Areas” throughout Ireland together with mapping of Quiet Areas which included “in excess of 170,000 environmental measurements.” (“RQA”):

The EPA Environmental RTDI Programme defines the Environmental Quality Objectives for how “Quiet Areas” are to be protected in Ireland to comply with the EU Noise Directive:

“The noise from anthropogenic sources should not be clearly audible at any point within Quiet Areas and the noise levels when measured in wind speeds of less than 2 m/s in the absence of significant environmental (geophonic or biophonic) sounds, should not exceed an LA90,1h of 30 dB by day or an LA90,1h of 27 dB by night. (The natural baseline sound level is regarded as the LA90,1h in the absence of anthropogenic noise.” (pg. 20) (emphasis added) “Considering that the Directive defines a Quiet Area in open country as an area that is undisturbed by noise from traffic, industry or recreational activities, it is proposed to define a Quiet Area as an area in open country, substantially unaffected by anthropogenic noise. The overall objective should, therefore, be set in such a way as to prevent the degradation of the acoustic quality by the sources of noise listed.” (pg. 17: Environmental Quality Objectives) (emphasis added)

For the avoidance of doubt, Wind Farm noise is one of the six anthropogenic noise types listed by the EPA. (pg 13, 6.1).

The Draft WEDG has entirely ignored the protection of Quiet Areas, and the overarching Environmental Noise Directive.

• It is imperative that the WEDG Review provides the protection specified by the EPA pursuant the Environmental Noise Directive for Quiet Areas, and that anthropogenic wind farm noise “should not exceed an LA90, 1h of 30 dB by day or an LA90, 1h of 27 dB by night” so as “ to prevent the degradation of the acoustic quality”.

The EPA identifies the appropriate noise measurement indicator for both environmental background noise and anthropogenic wind farm noise and specify assessment is required:

“Where natural environmental sounds dominate, the LA90 is a very good indicator, while the LAeq is a good indicator when quantifying anthropogenic noise.” (pg. 19). (emphasis added)

“Approval for any proposed development related to commercial or industrial activity or transportation, within or within such distance of a Quiet Area(s) as would be likely to be audible should be subject to the production of an impact statement of noise within the Quiet Area(s) from the development.” (pg. 19)

“Where an impact statement of noise is to be produced, noise modelling and prediction of noise levels should be undertaken to illustrate the impact of noise levels within the Quiet Area(s) using appropriate GIS/noise-modelling methodologies.”

• It is imperative that the WEDG Review uses the appropriate LAeq Noise measurement for anthropogenic Wind Farm noise as specified by the EPA Environmental RTDI Programme pursuant to the Environmental Noise Directive. It is submitted that evidence based assessment (Noise Impact Statement) together with noise modelling must be undertaken as part of an application which illustrates in accordance with the Directive that Quiet Areas will not degraded.

The EPA Environmental RTDI Programme identifies that protection of Quiet Areas under the Environmental Noise Directive should be integrated with other EU Directives and that Quiet Areas should also be protected in conjunction with sites of inter alia, national, regional, local, heritage and cultural importance and environmentally sensitive areas:

“Implementation of the Environmental Noise Directive and the identification and management of Quiet Areas should be integrated with other relevant EU Directives such as the Habitats and Birds Directives.” (pg. 17)

“Criteria for selection and identification of Quiet Areas should be linked with sites of national, regional or local importance with regard to landscape, cultural or historical sites, amenity areas or environmentally sensitive areas such as RAMSAR or SPA.” (pg. 17)

There is a non-coincidental, direct correlation between the EPA Quiet Areas and those areas which are rich in Biodiversity and recorded EU protected species.

Ireland has significant sites of National, Regional, and Local importance. For example, the monastic site of Clonmacnoise and it’s integral surrounding landscape has been submitted by the State in 2010 for Unesco World Heritage Site Status: Clonamcnoise is described on the UNESCO website as an “unparalleled and outstanding example of a relict early medieval Insular monastic city unobscured by modern building development. It is set within a superlative semi-natural landscape that deepens it’s spiritual qualities, adding greatly to its authenticity and integrity. The interaction between man and the natural environment at Clonmacnoise is of unique universal value. The architectural enssemble at Clonmacnoise represents a significant stage in the development of early Medieval Christianity in the North Atlantic. It is highly significant to our understanding of the development of urbanism generally in Atlantic Europe, as well as clarifying non-Viking urbanisation in an Irish context”. Furthermore, Clonmacnoise developed in the midst of extensive peatlands at the point where the Sli Mhór Esker crosses the River Shannon. The documentation submitted by the Irish Government to the OECD and UNESCO in 2010 notes that “these two great route ways facilitated trade, commerce and pilgrimage in Medieval Ireland. The remains of the monastic city display an outstanding response to the constraints and opportunities provided by an environment shaped by glacial, fluvial and climatic actions. This extremely diverse semi-natural and sacred landscape is the product of human creativity and interaction over many centuries. Sustainable land use has helped to maintain this diversity of habitats considered to be some of the most endangered worldwide”. The integrity of the natural heritage of Clonmacnoise is protected by the highest national and international nature conservation designations. The Esker system at Clonmacnoise has rare plants and habitats protected under the EU Habitats Directive. Should wind farm development (which includes wind turbines and overground pylons and cabling and related infrastructure) be built within a 25km radius of Clonmacnoise, it will visually dominate and impressively impose on this sensitive landscape.

UNESCO is responsible for the designation of World Heritage Sites and individual States are accountable to it for the subsequent management of all Sites. The deserved designation of Clonmacnoise as a World Heritage Site would be of significant importance for Ireland and particularly Offaly, given the competition globally for such designation. It would bring with it considerable tourism interest and the associated economic spin-offs to the area. For instance, the Giant's Causeway is a must see for international tourists visiting Northern Ireland, as is the Great Wall of China when visiting China. That is the potential of these ancient Monastic Sites should they attain Unesco World Heritage Status.

• It is submitted that in addition to Noise Assessment, that Visibility Modelling be carried out to ensure development is not visible from Quiet Areas and sensitive sites of national, regional and local importance.

The EPA Environmental RTDI Programme pursuant to Environmental Noise Directive, identifies the importance of Quiet Areas to human wellbeing:

“Ireland has a considerable number of large, open places of astonishing beauty and relative wildness. Each area can have a distinct and powerful aura, fully dependent upon the landscape, natural sounds

and natural quiet. As such, these areas afford unique opportunities for undisrupted respite, solitude, contemplative recreation, inspiration, and education. Further, these areas also provide scarce refuges and undisturbed natural habitats for animals. This project has identified a significant number of Quiet Areas in rural Ireland, still largely unaffected by anthropogenic noise. In these areas, tranquillity can be achieved to the fullest extent in relation to not only sound but also the other senses of the body. The results of this research demonstrate that the quality of the natural soundscape in many areas is excellent; however, monitoring also identified how societal changes and human activity are impacting on Quiet Areas and the extent to which natural tranquillity or quietness can be disturbed by the introduction of man-made noise from transportation, industry and other activities. (pg. 22)

Noise should be included in environmental quality criteria and quality of life indices. A subsidiary EQO (Environmental Quality Objective) will be to protect selected Quiet Areas from the adverse effects of anthropogenic noise.” (pg. 17)

There are many vulnerable sectors to noise within our community such as the elderly, children, persons suffering from vertigo and those within the autism spectrum. These sectors cannot tolerate increased noise levels. Quiet Areas are chosen for respite, and for instance the “Learning Difficulty Analyst Centre” which is a center for inter alia, screening for Dyslexia, Visual Perception difficulties and Neuro Development Therapy” is located in EPA Quiet Area.

• It is imperative that Quiet Areas and areas with sensitive receptors are fully protected from the introduction of anthropogenic wind farm noise pollution in the WEDG Focused Review so as to “ to prevent the degradation of the acoustic quality.”

4. Sound and NoiseNoise is not simply an “unwanted sound”. As the UK Health Protection Agency has highlighted:

“noise is sound that is perceived as unwanted, annoying or disturbing.”

Contrary to the assertion in the draft WEDG “that given the ‘unwanted’ component it can have a strong subjective aspect” there is a wealth of evidence outlining the noise characteristics, social and environmental factors that contribute to the perception of sound as noise, with obvious implications for human health.This issue was addressed by the Department of Health’s Deputy Chief Medical Officer in her response to the Department’s request for feedback on the targeted review of WEDG06, with specific reference to the risk that industrial wind turbines pose for certain people. The Draft WEDG must take account of the Deputy Chief Medical Officer’s advice given by the Department of Health in relation to the:

“consistent cluster of symptoms related to wind turbine syndrome which occurs in a number of people in the vicinity of industrial wind turbines. There are specific risk factors for this syndrome and people with these risk factors experience symptoms.”

• It is submitted that given this assessment by one of the State’s chief public health experts, it is critical that the Draft WEDG take seriously the objective health effects of wind turbines rather than treating people’s response to wind turbine noise as a subjective reaction to unwanted noise.

5. Wind Turbine NoiseThe Marshall Day Report highlighted the need to deal with the following special audible characteristics of wind turbine noise, including:

• Amplitude modulation

• Impulsiveness

• Infrasound

• Low frequency noise

• Tonality

It is of significant concern that though the Minister purports to take an evidence approach to the WEDG Review, they have ignored an evidenced approach where their experts have suggested same.

• It is imperative that the WEDG Review includes an evidenced based approach to dealing with Amplitude modulation, Impulsiveness, Infrasound, Low frequency noise and Tonality as recommended by Marchall Day.

Furthermore, the failure to include the Best Practice Guidance to be contained in Appendix 1 reflects the inadequacy of the Draft WEDG and prompts the need for a further round of public consultation to determine the public response to the environmental protection measures proposed in this guidance.

6. Setback We concur with the finding of the Marshall Day report that setback distance is not an appropriate approach to take solely as a means of noise control. As noted in the Draft WEDG setback distance is also required:

“in order to provide for other amenity considerations e.g. visual obtrusion.”

Recent independent studies on the impact of wind turbines on property values confirm the on-the-ground experience of property auctioneers and valuers that wind turbines adversely impact property values.

The most recent independent study undertaken over a 12 year period by the London School of Economics (which is due to be published in March 2014) looked at over one million sales of properties within close proximity of 150 wind farm sites in England and Wales. The results of this survey confirm that homes within 2km of wind turbines will experience the greatest devaluation, on average 11%, but the study also finds that homes 4km from a wind farm site also experience a diminution in property value of 3%.

The Marshall Day report highlighted that a significant number of the 550 submissions received during public consultation on the Wind Energy Guidelines Focused Review supported mandatory setbacks that were:

“generally significantly higher than the 500 m separation referenced in WEDG06” (p.99).

Despite this, the draft WEDG have maintained a setback distance of 500m:

“because of the lack of correlation between separation distance and wind turbine sound levels.”

This approach is in conflict with the requirements of the EIA Directive, which as the EU Court of Justice confirmed in Case C-420/11, EU Jutta Leth v Republik Österreich

“the prevention of pecuniary damage, in so far as that damage is the direct economic consequence of the environmental effects of a public or private project, is covered by the objective of protection pursued by Directive 85/337”.

When considering setback, the Draft WEDG have failed to consider or assess the relationship between proximity to wind energy developments and diminution of residential amenity and property values.

The draft WEDG also ignore the findings of the Marshall Day Report that setbacks:

“may be required for other reasons, such as occupational health and safety buffer zones ” (p.61).

Separation distances are not only required to avoid adverse noise and shadow flicker impacts, but because of the enhanced safety risk arising from blade failure or turbine collapse. The throw distances of debris from a falling turbine can be confirmed by calculation, but debris is documented as travelling distances of over 1km. Evidence of the throw distance from the turbine collapse in Donegal in March 2013 should be considered in the context of appropriate setback distances, to ensure the public safety of those living in close proximity to wind energy developments. I also note the Irish Thoroughbred Breeders Association (and Thoroughbred Trainers & Jockeys Associations) position on a mandatory setback from registered Stud Farms and Equine centres to fully protect the health and safety of their industry (staff and horses).

• It is imperative that the WEDG Review, in accordance with the EIA Directive, and the EU Court of Justice ruling Case C-420/11, consider and assess the relationship between proximity to wind energy developments and diminution of residential amenity and property values and that occupational health and safety buffer zones be incorporated.

7. Absolute noise limitWe acknowledge that an absolute noise limit is easier to understand and apply, but there is no evidence for the assertion in the draft WEDG that “it is the most appropriate method to control noise impacts from wind energy developments in proximity to noise sensitive properties”.

• It is imperative that in the determination of the impact of any development, including a wind farm, noise must be assessed with reference to pre-existing background noise levels, to determine the magnitude of impact that it will have. While I support the adoption of an upper noise limit, this must be relevant to the existing noise environment.

8. Absolute noise limit chosenThe adoption of an upper limit for wind turbine noise is appropriate and consistent with the approach adopted internationally for wind energy developments. I also support the application of a single appropriate upper limit for both day and night time noise, to protect residential amenity.

However, the choice of a noise limit of 40dB LA90 10 min is not acceptable. As Dick Bowdler notes in his submission to the current WEDG submission phase, this proposed limit is actually significantly higher than most other jurisdictions, contrary to the statement in the draft WEDG (p.7) that this proposed limit is “in the lower end of the range of limits applied internationally”.

Furthermore, there is no basis for the assertion that the draft WEDG limit of 40dBA LA90 10 min :

“takes into account World Health Organisation findings in relation to night time noise.”

In fact, the use of the LA90 10 min indicator, which is adopted primarily in Commonwealth countries to measure wind turbine noise, cannot be compared to the LAeq based indicator used by the World Health Organization and most other EU member States (and recommended by the EPA) for wind turbine noise unless the correct minus 2dB correction is made. To achieve an LA90 night noise level equivalent to the WHO night noise limit of 40dB would require a 38dB LA90 10 min limit.

There is no evidence suggested or provided in either the Marshall Day report or the Draft WEDG to support the use of the LA90 indicator for the measurement of wind turbine noise. LA90 is essentially a determinate of the minimum noise level in the receiving environment and is commonly used to measure background noise or minimum environmental noise levels. As Marshall Day highlight in their report, the measured LA90 noise level reflects the noise level that is exceeded for 90% of the measurement survey period.

Neither is there any evidence that the 40dB LA90 10min limit meets WHO standards or provides reasonable protection for residential amenity. On the contrary, there is mounting evidence that the use of the LA90 10 min indicator may not be appropriate for the measurement wind turbine noise. The AECOM Report for Defra on Wind Farm Noise (2011) confirms that

“there are few if any standards that set noise limits using this index. Additionally it is argued that because the LA90 10 min index focuses on the quietest periods in the measurement period it is relatively insensitive to rapid fluctuations in noise level where the noise varies rapidly over a short periods e.g. as with aerodynamic/amplitude modulation, and the impact of such characteristics can be underestimated using the LA90,t noise index” [emphasis added].

This view is supported by the University of Salford Report on Health Impacts of Wind Turbines study which states (p.19) that:

“the LAeq, t index is more sensitive to the modulating (time varying) nature of WT noise”).

There is also sufficient evidence to show that wind turbine noise is more noticeable, annoying and disturbing than other industrial noise sources, such as rail, airway and road traffic noise due to its duration, modulation and low frequency noise content. As the most recent JRC and WHO report for European authorities notes (p.46) wind farms are among:

“a growing list of noise sources which fall into the scope of the END and may have a substantial health impact, but for which exposure reporting to the European Commission is not required.”

Health Impact studies in relation to the impact of wind turbine are currently being undertaken in Canada, Denmark, Germany, while a further study of low frequency noise from wind farms was recently announced in Australia. Research from the ongoing Japanese study into the health impact

of wind turbines undertaken by Seong et al (2013) suggests that the most appropriate indicator to measure wind turbine noise in the context of health impact is the LAmax noise parameter. This is consistent with the approach suggested by the WHO (1999) for modulating noise sources.

Specifically, as far back as 1999, the WHO Guidelines for Community Noise (1999) state (p.58) that:

“If the noise is not continuous, LAmax or SEL are used to indicate the probability of noise-induced awakenings. Effects have been observed at individual LAmax exposures of 45dB or less. Consequently, it is important to limit the number of noise events with a LA max exceeding 45dB. Therefore, the guidelines should be based on a combination of values of 30dB L Aeq, 8h and 45 dB LAmax. To protect sensitive persons, a still lower guideline value would be preferred when the background level is low. Sleep disturbance from intermittent noise events increases with the maximum noise level. Even if the total equivalent noise level is fairly low, a small number of noise events with a high maximum sound pressure level will affect sleep.”

Given the growing body of evidence in relation to the adverse impact of wind turbine noise the lack of any evidence-based approach in the draft WEDG to the setting or assessment of wind turbine noise limits is of concern.

• It is imperative that the LAeq noise indicator be used by WEDG as it is by Europe, WHO and as recommended by the EPA and AECOM Report for Defra in the UK. In accordance with the World Health Organisation, “the guidelines should be based on a combination of values of 30dB LAeq”. “To protect sensitive persons, a still lower guideline value would be preferred when the background level is low.” Furthermore and as submitted at section 2 above, the WEDG Review must take account of existing background noise levels (to include character, magnitude and complexity) and sensitivity of locations (sensitive receptors and Quiet areas) and in accordance with comparable projects such as the DART underground, set “a maximum increase of 3dBA, on the lowest reoccurring LA90 5mins”. Under no circumstances should the substantial adverse impact threshold of a 5dB (or greater) increase in background noise be permitted.

10. Shadow Flicker Control

We agree that no existing dwelling or other accepted property should have to endure shadow flicker. We accept that at distances greater than 10 rotor diameters, the potential for shadow flicker is extremely low in flat terrain, but this is not the case where wind turbines are sited on elevated hills and ridges. Incidences of shadow flicker are occurring at dwellings further than 10 rotor diameters from large turbines. This issue needs to be addressed in the draft WEDG.

While modern wind turbines have the facility to reduce or stop turbine rotation when shadow flicker is likely to occur, these mechanisms are currently not being employed at many locations. Unless there is a mandatory provision in the draft WEDG to prevent shadow flicker from occurring at nearby homes, we believe that wind turbines will continue to cause considerable distress to those in close proximity to these developments.

• It is imperative that a mandatory provision be provided in the draft WEDG to prevent shadow flicker from occurring at nearby homes.

Conclusion: Local communities will not accept a wind turbine noise limit that does not adequately measure the actual level of wind turbine noise experienced and which is wholly unrelated to their pre-existing noise environment. If the DOECLG is serious in its intent to strike a balance between protection of residential amenity and sustainable wind energy development, then it must address the shortcomings identified in the draft WEDG during the public consultation process and assure the public concerned that the setback distance applied to protect residential amenity is evidence based.

Yours Sincerely,

Caitriona Cullinane

(for and on behalf of Kilcormac/Kinnitty/Cadamstown Wind Energy Information Group)