January 13, 2010 Re: Wind Turbines and Road Safety

Numerous industrial wind turbine developments are being installed in southern Ontario. I would like to ask for your attention to the road safety risks that are now at stake. There are 2 wind proposals within 15 km of where I live: the Adelaide Wind Project (40 wind turbines), and the Bornish Wind Project (50 wind turbines). Both projects are in their final steps of approval with the Green Energy Act, and both have serious issues attached to them, including the road safety issues: shadow flicker and wind turbine road setbacks. Shadow Flicker The Adelaide wind installation’s main safety issue is Shadow Flicker on the highway 402 and its County Road 6 interchange (Exit 56). The ramp has the potential to have the shadow flicker from 6 different wind turbines, with many more strung along the side of the road where the merging lanes are. This particular stretch of the highway is very treacherous in the winter time. When regularly traveling from London to Sarnia, it is noticed that the roads are generally fine until you reach Exit 56. Shadow Flicker poses a several serious problems: 1. Unsuspecting travelers will be plunged into a shadow flicker zone for 9 kilometers (9 minutes) with no alternative to turn around and reroute. 2. Those susceptible to flickering light (e.g. motion sickness, migraine, nausea and vertigo) could become ill instantly and this is dangerous not only for the driver, but for the other drivers on the 402. The Adelaide project will have overlapping shadow flicker from several different wind turbines across the 402, which creates a faster flicker rate that may cause seizures in epileptic travelers. 3. Exits will be treacherous with flashing lights strobing across and confusing the eye and its judgment. This could be a very serious issue, especially when ramping on and off of the 402 and turning onto the overpass. 4. Distraction with the movement of the blades and the series of flashing red lights at night.(large moving signs would not be allowed near roads in the number proposed here). Below is a short description of shadow flicker and how it affects the human body, according to Dr. Pierpont: “When turning with the sun behind them, turbine blades cast moving shadows across the landscape and houses, creating as a strobe effect within houses which can be difficult to block out. Some people get dizzy, lose their balance, or become nauseated when they see the movement of shadows or the movement of the huge blades themselves. As with car or sea sickness, such symptoms occur when the three organs of position and movement perception (the inner ear, eyes, and stretch receptors in muscles and joints) do not agree with each other: the eyes perceive movement while the ears and stretch receptors do not. People with a personal or family history of migraine, or migraine-associated phenomena such as

car sickness or vertigo, are more susceptible to these effects. The strobe effect also has the potential, like other flashing lights, to trigger seizures in people with epilepsy” Review of the Noble Environmental DEIS for Ellenburg, NY, Nina Pierpont,
MD, PhD http://www.windturbinesyndrome.com/wp-content/uploads/2008/07/noble_ellenburg_deis_critique_rev_7-5-061.pdf

The wind industry will say that wind turbines cannot trigger seizures in epileptics because the flashing is to slow. What they do not take into account is the overlapping shadow flicker that comes with many turbines closely spaced together, as in the situation with the Adelaide Wind Project, that will increase the frequency of flickering. A study was prepared in the UK to assess the risk of shadow flicker on epileptic people. “Since risk does not diminish with viewing distance, flash frequency is therefore the critical factor and should be kept to a maximum of three per second, i.e., sixty revolutions per minute for a three-bladed turbine. On wind farms the shadows cast by one turbine on another should not be viewable by the public if the cumulative flash rate exceeds three per second.” Wind turbines, flicker, and photosensitive epilepsy: Characterizing the flashing that may precipitate seizures and optimizing guidelines to prevent them http://www.mfe.govt.nz/rma/call-inturitea/submissions/186changeappendix3.pdf

The Green Energy Act does not ask for any studies on shadow flicker on homes, roads or other environments- this is a change from what was required in the Renewable Energy Act that was previously in place. In fact the Adelaide Draft Addendum report by TCI Renewables states, “It should be noted that some effects assessments conducted for the Adelaide Wind Farm under O. Reg.116/01 are now no longer required for renewable energy projects, including wind farms. These include the following: geophysical environment, atmospheric environment, visual landscape, socio-economic resources, land use, traffic, electromagnetic interference (EMI), public health and safety, the effects of the environment on the project and cumulative effects. Although no longer required under O. Reg. 359/09, AET has voluntarily updated their shadow flicker analysis based on the revised turbine layout and new wind turbine model.” Adelaide Wind Facility- Application for Renewable Energy Approval- November 23rd, 2009 Pg. 14

William K.G. Palmer P. Eng., reviewed the submission of TCI’s first environmental screening report. He states his concern of the lack of scrutiny that the MOE and wind company displayed when reviewing the Adelaide Wind Project and its shadow flicker. “Review of Volume 7, Appendix G, “Shadow Flicker” shows that the review considered only homes, and not highways. This project is unique in that it sites 15 turbines on the southern side of Highway 402, at distances from 250 to 350 metres from the highway plus 3 more at about 800 metres. During both morning and evening hours, drivers traveling Highway 402, would pass through a zone of shadow flicker as they pass these 18 wind turbines over a 9 km pathway, meaning that at a velocity of 100 km/h, the exposure time would be about 5 minutes. The Danish Wind Industry provides a simple shadow calculator on it’s website at http://www.talentfactory.dk/en/tour/env/shadow/shadowc.htm The calculator shows that on today’s date, the shadow flicker on highway 402 would persist for 152 minutes. In June, the shadow flicker effect would persist for about 190 minutes. There is no assessment of the impact of this shadow flicker on drivers. We would assume that the “mitigating action” to close Highway 402 for some 3 hours a day would cause considerable impact, yet it is known that some drivers, who are severely impacted by flicker would arrive into this zone without warning. It is known that some persons are more sensitive to shadow flicker than others. Various proponents have suggested that the remedy for shadow flicker is simply to pull the blinds for the period of time that the flicker is intense. One can hardly

expect this to be an appropriate action to be taken while traveling at 100 km per hour. The fact that the MOE notes that AET has considered possible adverse impacts when the subject of flicker on impact on drivers is not even mentioned shows that the initial Screening Report and the Ministry review of it are flawed, and suggest this should be a subject for a proper Environmental Assessment in conjunction with the Ministry of Transport to consider the safety impact on Highway 402. Even the proximity of the turbines alongside the highway for such an extended distance is grounds for concern even when not producing shadow flicker, because of the distraction that the turbines pose. A moving turbine draws one’s eyes away from the roadway far more than a stationary sign, tree, or building.” Review of Environmental Screening Report Portions- Request for Elevation for Adelaide Wind Farm- Sept 29, 2009 Setbacks In both the Bornish and the Adelaide Wind projects, wind turbines are located closer to roads then what the manufacturer recommends. Topple Distance for a GE 1.5 xle turbine: 121m Manufacturer’s (GE) recommended setback: 243.75m • Adelaide: 1 turbine sits ~150m from Kerwood Rd. County Road #6- this is also directly beside the 402, Exit#56, ~180m from the exit lane. This distance does not protect from ice or blade throw. Bornish: 2 wind turbines are located 115m from a road (Kerwood Rd. County Road #6, and Bornish Dr.). This is not even topple distance from the road.

Mr. Palmer warned the MOE of the dangerous setbacks before the GEA was in place. “The setback of 250 metres to highway 402 is inadequate for ice throw protection, and for blade accidents. As a Professional Engineer with experience and education in risk assessment, I am obligated to formally bring this deficiency to your attention. Inadequate setbacks are unnecessarily putting the lives of citizens at risk.” Unfortunately the New GEA has made the setback distances to roadways even less then before, and as a result the wind companies have situated some of their wind turbines dangerously close to our roadways. Please take time to seriously review these issues, as they may result in many preventable casualties if ignored. Thank you for you attention to this important issue.

Yours sincerely,

Harvey Wrightman

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