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A Commentary on Industrial Wind Energy Facilities Policy and Risk to Health By Carmen Krogh, BScPharm December 1, 2013 The

Right Honourable Stephen Harper Prime Minister of Canada pm@pm.gc.ca The Honourable Rona Ambrose Minister of Health Health Canada minister_ministre@hc-sc.gc.ca Dear Prime Minister and Minister of Health, Health Canada Re: Open letter: Industrial wind energy facilities, policy and risk to health I have provided a number of submissions to federal authorities on behalf of Canadian families reporting adverse health effects associated with the start-up of industrial wind energy facilities. In addition, I have corresponded and met with senior officials at Health Canada and Natural Resources Canada. As additional background, during the last 5 years I have researched health and other effects associated with industrial wind energy facilities. I am peer reviewed and a published author/co-author on this topic. I am guided by the numerous peer reviewed articles; judicial proceedings; acknowledgements by various experts; and by the reports of those experiencing negative health and social-economic effects which is correlated with the start up of a wind energy facility. Purpose: the purpose of this letter is to: report some of the issues associated with the implementation of wind energy facilities which are located in close proximity to homes; respectfully urge that: o resources be made available to achieve relief/remedy for those reporting harm; o in the interests of rural Canadian residents, prevention and precaution be invoked before supporting further implementation of wind energy facilities; o based on the credible scientific support for an association between wind turbine noise and community annoyance,1 the government of Canada disclose to the public, its current policy on industrial wind energy development.

A Commentary on Industrial Wind Energy Facilities, Policy and Risk to Health Carmen Krogh, BScPharm, December 1, 2013 Any errors or omissions are unintended

Disclosure I declare no potential conflicts of interest and have received no financial support with respect to the research and authorship of this commentary. This commentary is public and may be distributed. Executive summary The World Health Organization (WHO) 2 and Health Canada 3 acknowledge that government policies can impact health equity. Canadians have advised the Minister of Health that exposure to wind turbine noise and other emissions has impaired their physical, mental and/or social well-being. 4 The health effects reported by Canadians exposed to wind energy facilities include annoyance, sleep disturbance, physical, mental and stress, social-economic issues and reduction of living conditions and quality of life. Chronic noise annoyance, sleep disturbance, and stress can lead to serious medical conditions. Health Canada representatives have proposed a noise limit for Canadian wind turbines which they predict will result in an increased percentage of individuals being highly annoyed. 5,6,7,8 An increase in the percentage of Canadians expected to suffer harm to human health is inconsistent with Health Canadas stated responsibility to help Canadians maintain and improve their health. 9 The government of Canada has administered subsidies to over 100 wind projects. Based on the Wind Technology Road Map (TRM) document, an objective of an industry-led, government-supported initiative is to achieve a major increase in deployment of wind energy in Canada. The World Health Organization states with respect to noise in general that In all cases, noise should be reduced to the lowest level achievable in a particular situation. 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. 10 It is in the public interest of rural Canadians that Health Canadas mission of improving the lives of all Canadas people 11 and the prevention principle which is a fundamental component of modern health promotion 12 be upheld.

A Commentary on Industrial Wind Energy Facilities, Policy and Risk to Health Carmen Krogh, BScPharm, December 1, 2013 Any errors or omissions are unintended

Wind power development in Canada The federal government, including Health Canada, has policies to address climate change and air quality. 13 Michaud et al. (2012) states: [Authors Note 1] Wind turbines (WTs) are becoming an increasingly common power generation option across North America and in many parts of the world. This source of energy is viewed as a viable and environmentally friendly alternative to fossil fuels. Since the announcement of the Government of Canadas renewable energy initiatives, there has been a steady rise in the number of WT installations across Canada. 14 During a February 2, 2012 presentation to the Science Advisory Board (SAB), Health Canada representatives briefly outlined the federal involvement in wind energy. An interdepartmental committee known as the Wind Technology Road Map (TRM) initiative noted Health Canadas membership on the committee.15

The Natural Resources Canada website comments on the Wind Technology Road Map and indicates a series of three industry-led, government-supported Canadian wind energy stakeholder workshops were held. Indications are over 75 key players from industry,
1

Authors note: Dr. David Michaud is the Principal Investigator of the Health Canada Wind Turbine Noise study

A Commentary on Industrial Wind Energy Facilities, Policy and Risk to Health Carmen Krogh, BScPharm, December 1, 2013 Any errors or omissions are unintended

government and academia attended each workshop; however, it is unclear whether members of the public attended. 16 (Cited 06/09/2013)

A message from Co-Chair Geoff Munro, Assistant Deputy Minister, Natural Resources Canada noted the WindTRM is an industry-led, government-supported initiative to achieve a major increase in deployment of wind energy in Canada. [pg 5] 17

The Executive Summary of the report comments on the WindTRMs vision: [pg 6]

A Commentary on Industrial Wind Energy Facilities, Policy and Risk to Health Carmen Krogh, BScPharm, December 1, 2013 Any errors or omissions are unintended

The WindTRM Vision and Path Forward notes a number of benefits: [pg 8]

In order to inform and engage Canadians, WindTRM action items included: [pg 16 & 18]

The WindTRM conclusion comments on the vision for Canadians and notes that more than 20% of its electricity needs are met by wind. [pg 23]

An appendix from WindTRM provides further information. [pg 22]

A Commentary on Industrial Wind Energy Facilities, Policy and Risk to Health Carmen Krogh, BScPharm, December 1, 2013 Any errors or omissions are unintended

On July 7, 2012, Health Canada announced the wind turbine noise and health study and indicated its approach and that the research will ultimately support decisions, advice and policies regarding wind power in Canada:

The Science Advisory Board, February 2, 2012 presentation indicates goals, and a policy and research work plan.

A Commentary on Industrial Wind Energy Facilities, Policy and Risk to Health Carmen Krogh, BScPharm, December 1, 2013 Any errors or omissions are unintended

A Health Canada May 19, 2010 presentation indicates federal targets of 20 % by 2025 for Canadas electricity generation. It is projected that by 2015, approximately 14,000 houses and buildings (about 28,000 individuals) would be within 1,000 meters of wind turbines. 18

The national targets for generating 20% of Canadas electricity by wind power by 2025 is associated with the June 2011 Speech from the Throne. 19

A Commentary on Industrial Wind Energy Facilities, Policy and Risk to Health Carmen Krogh, BScPharm, December 1, 2013 Any errors or omissions are unintended

Conclusion In a peer reviewed reference published in Canadian Family Medicine, the official journal of the College of Family Physicians of Canada, Jeffery, Krogh and Horner (2013) note: We are guided by the references and the desire to safeguard the health and wellbeing of those living in the environs of IWTs. Harm can be avoided by placing IWTs at a protective distance from residents. The acknowledgment that health effects occur in some is an important step toward achieving this goal. 20 Some of the nontrivial percentage of Canadians highly annoyed by the sound of wind turbines can be expected to experience stress related health impacts. 21,22 Allowing an increase in the percentage of Canadians expected to suffer harm to human health is inconsistent with: Health Canadas stated responsibility to help Canadians maintain and improve their health, while respecting individual choices and circumstances. 23
A Commentary on Industrial Wind Energy Facilities, Policy and Risk to Health Carmen Krogh, BScPharm, December 1, 2013 Any errors or omissions are unintended

Health Canadas mission of improving the lives of all Canadas people . 24 The prevention principle which is a fundamental component of modern health promotion. 25 The WHO constitution which endorses The enjoyment of the highest attainable standard of health is one of the fundamental rights of every human being without distinction of race, religion, political belief, economic or social condition. 26 The United Nations 2012 Political Declaration on the Prevention and Control of Non-communicable Diseases which Reaffirm the right of everyone to the enjoyment of the highest attainable standard of physical and mental health; 27 Health Canadas stated belief that prevention and health promotion can hold health care costs down and improve quality of life in the long term. 28 "Quality of life" implies the opportunity to make choices and to gain satisfaction from living. Health is thus envisaged as a resource which gives people the ability to manage and even to change their surroundings. This view of health recognizes freedom of choice and emphasizes the role of individuals and communities in defining what health means to them. 29

The World Health Organization states with respect to noise in general: In all cases, noise should be reduced to the lowest level achievable in a particular situation. 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.
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Based on the evidence available, there is an opportunity for Health Canada to reconsider and retool the federal government policy supporting wind energy facilities until the issues regarding risks to health are resolved. There is a further opportunity to advocate for the health and social well-being of Canadian families already exposed to industrial wind energy facilities in quiet rural areas. Action should be taken to resolve the reported health, degraded living conditions and quality of life, and the social-economic issues to the satisfaction of those currently affected. Communities should have freedom of choice in defining what health means to them and to determine their living environments. I respectfully urge that the health of Canadians be given a high priority with respect to this topic and that the current policy on wind power development be publicly disclosed. Respectfully submitted, Carmen Krogh, BScPharm Ontario Canada Carmen.krogh@gmail.com
A Commentary on Industrial Wind Energy Facilities, Policy and Risk to Health Carmen Krogh, BScPharm, December 1, 2013 Any errors or omissions are unintended

References
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Dr. David Michaud, meeting with MP Poilieve June 2013 community newsletter World Health Organization. (2008). Closing the gap in a generation: Health equity through action on the social determinants of health (Final report of the Commission on Social Determinants of Health). http://www.searo.who.int/LinkFiles/SDH_SDH_FinalReport.pdf 3 Health and Welfare Canada, Achieving Health for All: A Framework for Health Promotion, (1986) http://www.hc-sc.gc.ca/hcs-sss/pubs/system-regime/1986-frame-plan-promotion/index-eng.php 4 Correspondence obtained from a federal Access to Information and Privacy (ATIP) request (2012) 5 Keith SE, Michaud DS, Bly SHP: A justification for using a 45 dBA sound Level Criterion For Wind Turbine Projects 6 Keith SE, Michaud DS, Bly SHP: A proposal for evaluating the potential health effects of wind turbine noise for projects under the Canadian Environmental Assessment Act. Second International Meeting on Wind Turbine Noise, Lyon France September 20 -21 2007 7 Keith SE, Michaud DS, Bly SHP: A proposal for evaluating the potential health effects of wind turbine noise for projects under the Canadian Environmental Assessment Act. J Low Freq Noise V A 2008, 27:253-265. 8 Howe Gastmeier Chapnik Limited. (2010, December 10). Low frequency noise and infrasound associated with wind turbine generator systems: A literature review (Rfp No. Oss-078696). Mississauga, Ontario, Canada: Ministry of the Environment pg 4 9 About Health Canada, http://www.hc-sc.gc.ca/ahc-asc/index-eng.php (cited February 23. 2013) 10 World Health Organization. (1999). Guidelines for community noise. Geneva; OMS, 1999, p 94. Ilus, Berglund, B., Lindvall, T., and Schwela, D. H. 11 Health Canada, About Health Canada, About Mission, Values, Activities, Retrieved from http://www.hcsc.gc.ca/ahc-asc/activit/about-apropos/index-eng.php, Cited August 24, 2012 12 Health and Welfare Canada, Achieving Health for All: A Framework for Health Promotion, retrieved from http://www.hc-sc.gc.ca/hcs-sss/pubs/system-regime/1986-frame-plan-promotion/index-eng.php, Cited August 24, 2012 13 Health Canada, Planning For A Sustainable Future: Health Canadas 20112014 Sustainable Development Strategy 20122013 Update, May 2012 14 Michaud, David S. PhD, Keith, Stephen E. PhD, Feder, Katya PhD, Bower, Tara, MSc, Health Impacts and Exposure to Wind Turbine Noise: Research Design and Noise Exposure Assessment, Paper presented at InterNoise New York, NY, August 19-22, 2012 15 Access to Information and Privacy (ATIP), Slide presentation to the Science Advisory Board, February 2, 2012
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Wind TRM website www.windtrm.gc.ca Accessed November 10, 2013 Access to Information and Privacy (ATIP), Slide presentation May 19, 2010, National Guidelines Working group 19 Access to Information and Privacy (ATIP), Slide presentation to the Science Advisory Board, February 2, 2012 20 Canadian Family Physician Le Mdecin de famille canadien | Vol 59: september septembre 2013 http://www.cfp.ca/content/current 21 Howe Gastmeier Chapnik Limited. (2010, December 10). Low frequency noise and infrasound associated with wind turbine generator systems: A literature review (Rfp No. Oss-078696). Mississauga, Ontario, Canada: Ministry of the Environment. 22 Correspondence, (March 6, 2013) Dr. P Bigelow, University of Waterloo, Research Chair, Renewable energy 23 Health Canada, About Health Canada, Retrieved from http://www.hc-sc.gc.ca/ahc-asc/index-eng.php Cited August 24, 2012 24 Health Canada, About Health Canada, About Mission, Values, Activities, Retrieved from http://www.hcsc.gc.ca/ahc-asc/activit/about-apropos/index-eng.php, Cited August 24, 2012 25 Health and Welfare Canada, Achieving Health for All: A Framework for Health Promotion, retrieved from http://www.hc-sc.gc.ca/hcs-sss/pubs/system-regime/1986-frame-plan-promotion/index-eng.php, Cited August 24, 2012
A Commentary on Industrial Wind Energy Facilities, Policy and Risk to Health Carmen Krogh, BScPharm, December 1, 2013 Any errors or omissions are unintended

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The Constitution was adopted by the International Health Conference held in New York from 19 Juneto 22 July 1946, signed on 22 July 1946 by the representatives of 61 States (Off. Rec. Wld Hlth Org., 2, 100), and entered into force on 7 April 1948. Amendments adopted by the Twenty-sixth, Twenty-ninth, Thirty-ninth and Fifty-first World Health Assemblies (resolutions WHA26.37, WHA29.38, WHA39.6 and WHA51.23) came into force on 3 February 1977, 20 January 1984, 11 July 1994 and 15 September 2005 respectively and are incorporated in the present text. Accessed July 15, 2012 27 United Nations General Assembly, Political Declaration of the High-level Meeting of the General Assembly on the Prevention and Control of Non-communicable Diseases, A/RES/66/2, Distr.: General 24 January 2012 28 Health Canada, About Health Canada, Retrieved from http://www.hc-sc.gc.ca/ahc-asc/index-eng.php Cited August 24, 2012 29 Health and Welfare Canada, Achieving Health for All: A Framework for Health Promotion, retrieved from http://www.hc-sc.gc.ca/hcs-sss/pubs/system-regime/1986-frame-plan-promotion/index-eng.php, Cited August 24, 2012 30 World Health Organization. (1999). Guidelines for community noise. Geneva; OMS, 1999, p 94. Ilus, Berglund, B., Lindvall, T., and Schwela, D. H.

A Commentary on Industrial Wind Energy Facilities, Policy and Risk to Health Carmen Krogh, BScPharm, December 1, 2013 Any errors or omissions are unintended

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