REDACTED VERSION

Marie-Eve HEROUX
Technical Officer, Noise
Environmental Exposures and Risks (EER)
WHO European Centre for Environment and Health
WHO Regional Office for Europe
Platz der Vereinten Nationen 1
D-53113 Bonn, Germany
info@ecehbonn.euro.who.int
contact@euro.who.int
Wolfgang Babisch
Federal Environment Agency, Department of Environmental Hygiene, Berlin, Germany
Goran Belojevic
Institute of Hygiene and Medical Ecology, Faculty of Medicine, University of Belgrade,
Belgrade, Serbia
Mark Brink
Federal Office for the Environment, Bern, Switzerland
Sabine Janssen
Netherlands Organization for Applied Scientific Research, Delft, The Netherlands
Peter Lercher
Division of Social Medicine, Medizinische Universitt Innsbruck, Innsbruck, Austria
Marco Paviotti
European Commission, Directorate-General for Environment, Brussels, Belgium,
Gran Pershagen
Institute of Environmental Medicine, Karolinska Institute, Stockholm, Sweden
Kerstin Persson Waye
Occupational and Environmental Medicine, The Sahlgrenska Academy at the
University of Gothenburg, Gothenburg, Sweden
Anna Preis
Institute of Acoustics, Adam Mickiewicz University, Poznan, Poland
Stephen Stansfeld
Barts & the London School of Medicine & Dentistry, Queen Mary University of London,
London, United Kingdom

Martin van den Berg

Ministry of Infrastructure and the Environment, Den Haag, The Netherlands
Jos Verbeek
Finnish Institute of Occupational Health, Helsinki, Finland
August 5, 2016
Dear Dr. Heroux and members of the WHO Panel,
REDACT Open Letter: Review of the WHO Environmental Noise Pollution Guidelines
for Europe [WHO Panel]
The purpose of this letter is to share information with the WHO Panel regarding the World
Health Organization (WHO) initiative to update its noise pollution guidelines for Europe. It
is my understanding this update includes noise guidelines for industrial wind turbines (IWT).
Please share this message with the members of the WHO Panel for their consideration.
Note this is a redacted version and I ask it replace the August 4 version.
As background, I am a retired pharmacist and have been researching adverse health effects
associated with industrial wind energy since October, 2008. I am an independent, full time
volunteer and published researcher regarding adverse health effects and industrial wind
energy facilities and share information with: communities; individuals; researchers; federal,
provincial and public health authorities, wind energy developers; the industry; and others. I
am an author / co-author of peer reviewed articles and of conference papers presented at wind
turbine noise scientific conferences and of other references relating to this complex topic. See
attached a summary of these references.
During my career, I have held senior executive positions at a teaching hospital, as a drug
information researcher, a professional organization, and Health Canada (PMRA). I am a
former Director of Publications and Editor in Chief of the Compendium of Pharmaceuticals
and Specialties (CPS), the book used by physicians, nurses, and health professionals for
prescribing information in Canada.
This letter is public and can be shared.
A recent media release indicates the WHO Panel is investigating adverse health issues in
local residents following the construction of wind turbines, the health benefits of noise
mitigation and possible government intervention to decrease noise levels.1
If the WHO Panel is planning to investigate those reporting adverse health effects, it may be
helpful to be aware of the legislative authority available in Canada and an investigative
approach taken by a USA Board of Health. Comments on conducting an investigation are
provided below.

The World Health Organization (WHO) defines noise as unwanted sound. 2 Sound,
regardless of its source, becomes a risk to human health if it is perceived as noise.
IWTs tend to be sited in quiet rural communities which typically have low ambient noise
levels. As a result, their installation has resulted in a significant change in the living
environment of residents who live in proximity to these facilities.
WHO (1999) reports that regarding the rural sector: As the name suggests, people in this
sector live in rural surroundings and for the most part are not subjected to noise levels that
could be detrimental to their health.3
Based on international research, some rural family members living in proximity to wind
facilities are reporting adverse health effects such as sleep disturbance, effects on quality of
life, annoyance and other.4,5,6,7,8,9,10,11,12,13,14 Research indicates workers associated with
industrial wind energy can also be negatively affected.15,16,17,18,19,20,21 In some cases,
families residing in proximity to IWTs have effectively abandoned their homes, been billeted
by wind project developers or successfully negotiated financial agreements with
developers.22 Audible and inaudible noise, visual impacts, stray voltage and socio-economic
impacts are identified as plausible causes of adverse effects.23
Research specific to IWT is challenged by numerous variables such as individual responses
and noise sensitivity, pre-existing medical conditions, siting array, density of IWT and
distances from homes, wind direction and speed, MWatt output, sound emissions (Aweighed, low frequency/infrasound), electromagnetic and radio frequency, and other. In
addition, there are a number of knowledge gaps such as lack of research relating to
vulnerable population groups, prevalence of abandoned homes, vigilance monitoring and
long term surveillance, and socio-economic impacts on communities and residents.
Despite the IWT-specific research variables and knowledge gaps, it has been determined that
noise in general can lead to short- and long-term health problems. For example, WHO
reports:
Noise is an underestimated threat that can cause a number of short- and long-term
health problems, such as for example sleep disturbance, cardiovascular effects, poorer
work and school performance, hearing impairment, etc and that nuisance at night
can lead to an increase in medical visits and spending on sleeping pills, which
affects families budgets and countries health expenditure.24
WHO also concludes that chronic disturbed sleep (either from internal or external factors)
leads to, or at least is associated with, fatigue, lower cognitive performance, depression,
accidents, diabetes, obesity and cardiovascular diseases and that animal experiments show
that sleep deprivation shortens lifespan.25

The human risk factors associated with IWT low frequency noise (LFN)/infrasound is
debated globally. However, early26,27 and subsequent28,29,30, 31,32,33,34,35,36 research indicates
some are adversely affected by these noise emissions.
The Ministry of the Environment of Ontario, Canada commissioned a low frequency noise
review which concluded the sound from wind turbines, at the levels experienced at typical
receptor distances in Ontario, Canada was expected to result in a non-trivial percentage of
persons being highly annoyed and that research had shown that annoyance associated with
sound from wind turbines can be expected to contribute to stress related health impacts in
some persons.37 During an Ontario Environmental Review Tribunal, the author of the low
frequency noise review was qualified as an expert and testified under oath. He stated: ...two
or three fairly comprehensive studies in Europe on annoyance versus sound levels, they have
found that in the range of about 35 to 40 dBA, you know, about six percent of people will be
annoyed or very annoyed, as the term is considered, and above 40 dBA, that number jumps
to about 20 percent. [p. 189] 38 The author also agreed during testimony that six percent is
not trivial. [p. 257]
Research indicates a variable that should be considered relates to low frequency noise in that
IWTs are becoming bigger, more powerful resulting in the relative amount of low frequency
noise being higher for the larger (2.33.6 MW) than the smaller turbines ( 2 MW and the
difference is statistically significant.39
It appears WHO is considering the conduct of an investigation. A randomized study is not
comparable to an investigation. By its nature, a randomized study will not necessarily select
affected individuals. However, investigations of affected individuals are frequently used to
advance the science and achieve breakthroughs.
For example, the Center for Disease Control (CDC) states:
Investigations of noninfectious disease clusters have also resulted in notable
examples of breakthroughs, such as angiosarcoma among vinyl chloride workers (4),
neurotoxicity and infertility in kepone workers (5), dermatitis and skin cancer in
persons wearing contaminated gold rings (6), adenocarcinoma of the vagina and
maternal consumption of diethylstilbesterol (7), and phocomelia and thalidomide
(8).40
Some European Union (EU) and other countries may have legislative authority to conduct a
complaints-based investigation.
In Canada, indications are the federal Radiation Emitting Devices Act (REDA)41 and the
Ontario, Canada Health Protection and Promotion Act (HPPA)42 may have provisions to
investigate complaints. However, I am not aware that an investigation of complaints has been
formally initiated under the legislative authority of the REDA or the HPPA.

An example of an investigative process of adverse health complaints is that of the Brown

County Board of Health, in Wisconsin, USA. The investigation considered presentations by
affected residents, sworn affidavits and written personal accounts regarding adverse health
effects. Some parents reported that children were experiencing adverse effects. By motion,
the Board formally requested temporary emergency financial relocation assistance from the
State of Wisconsin for those families suffering adverse health effects and undue hardships
caused by the irresponsible placement of industrial wind turbines around their homes and
property.43 Noise testing through a collaborative effort by four acoustical firms opined that
enough evidence and hypotheses were provided to classify LFN and infrasound as a serious
issue, possibly affecting the future of the industry and recommended additional study on an
urgent priority basis. 44 On October 14, 2014 the Board unanimously approved a motion
which declared the IWTs at Shirley Wind to be "a Human Health Hazard".45
Conclusion and suggestions for moving forward
1. WHO Panel participation
Regarding stakeholder representation, I propose that those affected by IWT be given the
opportunity to be represented on the WHO Panel. They should be viewed as IWT new
experts.46
In my research, those who indicate they are currently affected, or in the past have
experienced adverse health effects, have real life experience. These individuals are a valuable
resource. I have found they are prepared to share their experiences. However, there is rarely
an opportunity to share knowledge as formally recognized members of a research design
team or an initiative similar to that of the WHO Panel.
I suggest their contribution would be invaluable and could assist the Panel with its
deliberations.
2. Conducting an investigation
Literature reviews and randomized studies do not equate to a robust investigation of affected
individuals.
It appears there is an opportunity to conduct an investigation of those reporting adverse
health effects. To assist with appropriate diagnosis and investigation of reported symptoms,
medical studies should be included. Qualified physicians and other health professionals with
subject specific specialities such as sleep, audiology, and other should be available to support
the investigation. Actual noise measurements by qualified acousticians inside homes should
be conducted rather than use of predictive models. The full spectrum of noise emitted by
IWT such as dBA, low frequency/infrasound etc should be included. As well,
electromagnetic and radio frequency should be included in the investigation. Medical and
qualified experts in these fields should be engaged to support the subject specific
investigation.

Consideration could be given to include residents who may have relocated from a project.
This would be an opportunity to conduct long term surveillance which could assist with this
knowledge gap. (see below section 4. Research variables and knowledge gaps)
The following references may be helpful regarding diagnostic methodologies:
Robert Y McMurtry and Carmen ME Krogh, Diagnostic criteria for adverse health
effects in the environs of wind turbines. JRSM Open 2014 5:1-5 The online version
of this article can be found at: DOI: 10.1177/2054270414554048
http://shr.sagepub.com/ PMID: 25383200 [PubMed] PMCID: PMC4221978
http://www.ncbi.nlm.nih.gov/pubmed/?term=Diagnostic+criteria+for+adverse+health
+effects+in+the+environs+of+wind+turbines
Castelo Branco MAA, Alves-Pereira M, Pimenta, AM, Ferreira JR. Clinical Protocol
for Evaluating Pathology Induced by Low Frequency Noise Exposure. EuroNoise
2015, 31 May-3 June, Maastricht.
3. Disclosure of adverse health effects
Health professionals, authorities and the public would benefit from IWT disclosure regarding
risk factors associated with IWT development. There may be an opportunity for WHO to
provide IWT disclosure similar to that of other technologies such as cell phones.
4. Research variables and knowledge gaps
Research specific to IWT is challenged by numerous variables such as individual responses
and noise sensitivity, pre-existing medical conditions, siting array and distances from homes,
wind direction and speed, MWatt output, sound emissions (A-weighted, low
frequency/infrasound), and other. In addition, there are a number of knowledge gaps such as
lack of research relating to vulnerable population groups, prevalence of abandoned homes,
risk factors associated with chronic exposure, vigilance monitoring and long term
surveillance, and social-economic impacts on communities and residents and other.
Establishing IWT guidelines is challenging. For example, in 2011, Health Canada drafted
interim guidelines on IWT noise.47 However, the guidelines were not released due to lack of
agreement by all members of the working group regarding the overall content of the draft
voluntary guidelines.48 In 2012, during a presentation to its Science Advisory Board, Health
Canada stated to Place hold on Guideline finalization. HC will explore research options and
release guidelines only when knowledge gaps are filled.49
It is urged the research variables and knowledge gaps be resolved before exposing more
families to the risk of exposure and those residing in existing IWT projects and reporting
adverse health effects receive resolution to their satisfaction.

5. The precautionary principle

WHO states:
Health is a state of complete physical, mental and social well-being and not merely the
absence of disease or infirmity.50

WHO publications are frequently relied upon by the global community. Despite the research
challenges and variables associated with IWT, there is sufficient evidence that IWTs have
negatively affected the health of some members of the rural population globally. This merits
taking a precautionary approach until research has clarified the research challenges and
knowledge gaps which have yet to be resolved.
With respect to children, the Policy Interpretation Network on Childrens Health and
Environment comments on policy and precaution:
Policies that may protect childrens health or may minimise irreversible health
effects should be implemented, and policies or measures should be applied based on
the precautionary principle, in accordance with the Declaration of the WHO Fourth
Ministerial Conference on Environment and Health in Budapest in 2004.51
In addition, WHO states:
...where there is a reasonable possibility that public health will be damaged, action
should be taken to protect public health without awaiting full scientific proof. 52
Thank you for your consideration of this matter. I look forward to the Panels comments and
am available to assist if you wish to contact me. I may be reached at:
carmen.krogh@gmail.com

Respectfully submitted,

Carmen Krogh, BScPharm (retired)

Ontario, Canada
Attachments
REDACTED Open Letter: Review WHO Environmental Noise Pollution Guidelines for
Europe.pdf
Summary Krogh references April 2015.pdf
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