16 December, 2010
Dr Arlene King, MD, MHSc, FRCPC
Chief Medical Officer of Health for the Province of Ontario
Toronto, Ontario
Dear Dr. King;
RE: YOUR REPORT "THE POTENTIAL HEALTH IMPACT OF WIND TURBINES"
We are concerned about the process by which you reached the conclusion of your report on wind turbines. We also note that the conclusion is not consistent with parts of the body of the report.
Since the report is being widely used by the wind industry to justify its claim that there are no adverse health effects from wind turbines on Ontario residents living near these installations we fear that your report is misleading the public and we believe that the misinformation contained in it should be corrected publicly at once. The basis for our concerns is set out below. We would appreciate written answers to all our questions.
There is a huge problem with the process by which this report was produced. In fact, the irregularities were grave enough to remove all medical credibility from the report itself. We would like to know why you, in your role as Chief Medical Officer of Health, did not conduct your investigation with medical and academic professionalism:
(i) Failure to investigate complaints of Ontario victims
First, your report appears to have been based almost exclusively on information supplied by the wind turbine industry. It made no attempt to investigate independently the complaints of patients actually suffering from the adverse effects of wind turbines in Ontario. The King report incorporates an oversight of required professional process of the most serious consequence in medicine. What physician would presume to overlook the complaints of over 100 patients and not even take the trouble to interview them and investigate their pathologies? Is that not medical incompetence? Will you explain this failure of process of universally accepted medical protocol?
(ii) Adoption of the position of the CanWEA/AmWEA Expert Panel Report
Your report regurgitated most of the information already published in the "CanWEA/AmWEA Expert Panel Report", an industry commissioned and funded literature search which denied even the scientific possibility of there ever being adverse health effects from wind turbines. Such an absurd position is entirely inconsistent with the scientific method or modern medical research. A failure of the proper process of independent investigation expected of a medical professional, especially one holding an office commanding credibility in the province, occurred when the report adopted what could be construed as the industry spin. A comparison of the parallel phraseology of both reports is self evident. We are asking you, as Chief Medical Officer of Health to explain this failure of process which undermined the credibility of the office of the Chief Medical Officer of Health in Ontario and internationally.
(iii) Loss of credibility because of selection of industry report principal author
Another failure of the universally accepted process for professional scientific investigation appears to have been your failure to consider the possibility of bias on the part of your appointees to the panel or to take into account their qualification for making judgements on the adverse effect of wind turbines on human health.
For example, Dr. David Colby had already been the major author of the contentious CanWEA/AmWEA Expert Panel Report. That report had attracted scorn from the international medical community because of its incompetence. It was criticized in the United Kingdom by the National Health Service for its incomplete and biased selection of research information and because it had failed even to employ the opinion of an epidemiologist, a standard in such reports.
Moreover, Dr. Colby had also already been advised by the Ontario College of Physicians and Surgeons not to make public statements or allow anyone to believe that he had expertise on the subject of wind turbine related health problems, since his expertise lies not in this area but in the field of microbiology and infectious diseases. A report in the Chatham Daily News had pointed out that Dr. Colby had previously appeared at an open house on behalf of a wind turbine developer reassuring the public that there were no harmful health effects from wind turbines.
The newspaper indicated that Dr. Colby had received an honorarium for his services on that occasion. And no doubt, Dr. Colby had been compensated for taking part in the industry sponsored panel report.
What is the definition of a conflict of interest? In terms of process, do we now accept that our Medical Officers of Health should be using the credibility of their title to promote the interests of a private corporation whose products have been widely alleged internationally to be detrimental to the health of some members of the rural community? (Remember, these allegations have occurred worldwide).
We need clarification as to what private activities (of such a controversial nature) the public can expect our Medical Officers of Health to engage in and whether those activities serve our interest in the protection of public health for which we employ them.
Was the process you followed not remiss in failing to investigate the actual qualifications and private interests of your star panellist, Dr. Colby? Would it not have been in the interest of unbiased scientific investigation to choose someone who had not already served as the principal author of an industry commissioned report? This is another issue for which we require an explanation.
(iv) Lack of scholarly rigour in researching available information
The King report has been criticized for its lack of academic rigour. A significant number of important, recent, authoritative studies were ignored. For example, "Health Canada advises…that there are peer-reviewed scientific articles indicating that wind turbines may have an adverse impact on human health".
In terms of process, it must be asked why, as Chief Medical Officer of Health, you failed to make certain that the literature search claimed as the authoritative basis for the report was, indeed, complete, peer reviewed and authoritative and represented a balanced consideration of the issue and was not slanted in the interests of the industry? It should be recalled that industry sponsored studies claiming the safety of their own product are seldom credible. This was learned over many years from the tobacco industry.
Investigating the validity of data is an essential and customary process fundamental to assure the integrity of research in every academic discipline. We require an explanation from you for the failure of this universally accepted process in your report.
Attached below is an outline of the First International Symposium on the Global Wind Industry and Adverse Health Effects held in October in Picton, Ontario. Numerous independent scientists from several countries presented information that was already available but never considered in your report. You and other government representatives were invited to this conference. You did not attend nor did you send a representative. Is this not a further failure of the investigative process the public would expect of a chief medical officer of health who should be attempting to keep informed on this important topic? Does it not undermine the credibility of your letter to the London Free Press dated 13 December 2010, which claims: "We will continue to monitor new scientific information on this subject". A web link to the actual reports from the conference is included below.
(v) Another accepted and customary process of academic research is the inclusion of dissenting opinions in the final report of an expert panel.
Why were the dissenting voices of two of your panel ignored when they requested that their minority opinion be included in the main report? Was this not a failure of process? Your office claimed that the report's conclusions were based on the majority opinion of the panel. But surely there is a breakdown in acceptable process to exclude the views of the one expert who had the greatest field experience with health complaints from wind turbines and possibly the only one who had already had considerable contact with actual victims? Or was it a government requirement that the report should be free from dissenting opinion in the hope that it would reassure the public that no problems existed?
We are asking if your report was predetermined by the government.
(vi) Dissenting opinion
(a) Grey-Bruce Medical Officer of Health Hazel Lynn was probably the only person on the panel who had as much actual first hand medical knowledge of the adverse health effects on those suffering from the wind turbines since she has come into contact with dozens of people in Grey and Bruce County who are currently suffering. (See
Grey Bruce Health Unit Board Report, September 17, 2010)
Here is her statement read recently at the Tara Town Hall Meeting:
"There is convincing evidence in the literature to conclude that, in some people, noise can induce annoyance and disrupted sleep including difficulty falling asleep and sleep interruption. (Public statement read at the Tara Town Hall Meeting, 30 September, 2010.)
Inadequate and disrupted sleep is associated with fatigue, cognitive impairment, increased risk of obesity, impaired glucose tolerance, high blood pressure, cancer, depression and impaired immunity. . . .This disruption from wind turbine noise is poorly predicted by simple measurements of the physical properties of the noise. As this disturbance can compromise health in susceptible individuals, care must be taken with respect to host communities in the siting of wind turbine installations". –Dr Hazel Lynn, (Medical Officer of Health for Grey Bruce)
Dr. Lynn has also publicly stated that the 550 metre setback is not enough and that 5-10% of those living even further from the wind turbines are being adversely affected.
She also told the Owen Sound Sun Times that "the final report glosses over the disruption that the introduction of wind turbines can cause in a community."
"The whole section that a couple of us really wanted in there on community health and community disruption went. It's not in there. I suspect politically she can't criticize another ministry, so I was a little disappointed," Lynn said.
Did the CMOH decide to compromise the integrity of her report for political considerations?
(b) Ray Copes, MD, Director, Environmental and Occupational Health, Ontario Agency for Health Protection and Promotion also requested that his dissenting voice be recorded in the report. According to the Owen Sound Sun Times, Dr. Copes said:
"I think it's a fair comment that there is other material that could have been in the report and wasn't,' said Dr. Ray Copes, the director of environmental and occupational health at the Ontario Agency for Health Protection and Promotion and another member of the committee that reviewed drafts of the report. Copes said there are 'really important and quite legitimate questions about wind farms that he and Lynn thought should be discussed, but I guess the CMOH's report wasn't the place for it."
As a matter of process, one has to ask then, where was the place for it if not an investigation into the alleged adverse health effects of wind turbines? Why did the process not allow "really important and quite legitimate" questions to be considered? The process of scientific enquiry does not include the arbitrary disallowing of evidence.
Moreover it is worrying also to hear a dissenting voice even among the CanWEA/AmWEA Expert Panel. In 2010 Geoff Leventhall, one of the panel members of the A/CanWEA Panel Review was quoted as stating that "
there was no doubt people living near the turbines suffered a range of symptoms, including abnormal heart beats, sleep disturbance, headaches, tinnitus, nausea, visual blurring, panic attacks and general irritability.…it's ruining their lives – and it's genuine…"– Countryside News, Wind turbines set to get bigger, January 28 2010
A more detailed analysis of the academic and scientific shortcomings of the King report can be found on the web site of the Society for Wind Vigilance entitled Delay Denial and Disappointment:
An Analysis of the Chief Medical Officer of Health (CMOH) of Ontario
We are also attaching our document, "Adverse Health Effects of Wind Turbines" to provide further information, much of which was overlooked in your report.
We now request that you appear before the media to acknowledge the deficiencies of your report in an attempt to re-establish public credibility in the office of Chief Medical Officer of Health and undo the harm that has been done to the cause of those suffering the adverse effects of industrial wind turbines.
Dr Robert Y. McMurtry, M. D., F.R.C.S.(C), F.A.C.S. has already been very specific in his criticism of the failure of process in putting together your report:
"Health concerns from wind technology in Ontario must be addressed. These concerns exist due to the inadequate implementation of Ontario's renewable energy policy. Front end health studies prior to establishing the renewable energy policy were not done. Vigilance monitoring and long term surveillance programs to ensure safe implementation were not established".
"Volunteers for WindVOiCe© continue to conduct a vigilance health survey for new victims. WindVOiCe© follows the principles of Health Canada's Canada Vigilance, a post-market surveillance program by which healthcare professionals and consumers report adverse health effects suspected to be related to a product. This is mandatory for Market Authorization Holders such as wind turbine manufacturers".
"To date, one hundred and two Ontarians have reported adverse health effects from industrial wind turbines and the number is climbing".
"The Society for Wind Vigilance calls upon the government to halt further development of industrial wind installations until a full independent, third-party study into the adverse health effects of industrial scale wind technology is complete".
"The recent RFP for noise specialists by Ontario's Ministry of Environment indicates that the technology and its affect on human health are not fully understood".
"Ontario families cannot rely on protection from their government when turbine related noise causes sleep disturbance leading to other adverse health effects. Clinicians and medical experts must be independently appointed from outside the government and its public health officers to protect Ontarians".
Your report also failed to take into account one of the most important principles in environmental legislation. The Bergen Declaration was signed by Canada in 1990. This principle has become part of customary international law over the past 20 years. It clearly states that "policies must be based on the precautionary principle. Environmental measures must anticipate, prevent and attack the causes of environmental degradation. Where there are threats of serious or irreversible damage, lack of full scientific certainty should not be used as a reason for postponing measures to prevent environmental degradation". Why was this principle which the 2008 Ontario Ministry of the Environment Statement of Environmental Values requires to be part in its decision making to protect human health and the environment, not given any consideration in your report? Surely this is an oversight of the gravest consequence to the health of Ontarians whom, as Chief Medical Officer of Health, you have an obligation to protect.
Your 13 December statement also notes that "the Ministry of Environment appointed a Research Chair in Renewable Energy Technologies and Health earlier this year. Dr. Siva Sivoththaman will advise Ontario on emerging technologies over the next five years including on the potential health effects related to energy from wind turbines". These are hardly words that will reassure the public.
Dr Robert Y. McMurtry, M. D., F.R.C.S.(C), F.A.C.S. has already been very specific in his criticism of the failure of process in this appointment. He has noted that "Dr Siva Sivoththaman is an electrical engineer. While we wish him well, in our view Dr. Sivoththaman's professional background lacks the clinical expertise to evaluate 'health impacts of renewable energy associated with industrial wind turbines.'"
Dr. McMurtry goes on to point out:
"Throughout the RFP, the required expertise, experience and qualifications continued to focus on renewable energy technologies. The health requirement appears to have been a secondary consideration if it was considered at all. These concerns have been communicated to the Ministry of Environment and the Chair of the Research Chair during the selection process".
Is Dr. Sivoththaman's appointment not a contradiction of credible process on the part of the government when such an investigation is totally beyond his area of professional competence?
Professor Sivoththaman is a recognized expert in semiconductor materials, electronic devices, and fabrication technologies with a major focus on photovoltaic (PV) energy conversion. His activities in PV include the development advanced PV materials and concepts for high performance, material-specific devices using thin-film and bulk semiconductor technologies. Are you suggesting that such qualifications make him an expert on epidemiology and the adverse health effects of wind turbines?
Since the report will take five years, by which time all the wind turbines will have been built, it is a total waste of taxpayers' money. Given the urgency of the suffering of those adversely affected in rural Ontario, is it not a further flaw in process to promise investigation but then delay the process seemingly indefinitely without explanation? (Bear in mind that real people are being forced out of their homes, are being deprived of sleep on a continuing basis and suffering serious physiological symptoms).
When can we finally expect to see results of the investigation by the Chair? What plan for the investigation has been determined? Are we going to see a proper, timely medical investigation of actual victims as is surely the appropriate process demanded by the principles of scientific investigation, not another literature review of cherry picked documents? Will you be recommending a moratorium on all further wind development approvals until the Chair's findings are available? When will we see a third party, independent health study using professionally qualified medical personnel and epidemiologists?
Will you, as Chief Medical Officer of Health now please have the courage to face the public and explain the shortcomings of your report so that citizens of this province are no longer mislead?
Yours sincerely,
Keith Stelling.
CC:
The Honorable Deborah Matthews, Minister of Health and Long-Term Care
Christine Elliott, Critic, Health and Long-Term Care Deputy Leader
France Gélinas, Critic, Health and Long-Term Care
Adam Orfanakos, Office of the Ombudsman
Bill Murdoch, MPP, Grey Bruce Owen Sound
John Yakabuski, MPP
Tim Hudak, MPP, Leader, Official Opposition
Andrea Horwath, MPP
Attachments:
1.
Adverse Health Effects of Wind Turbines.pdf
2. Article by Joan Morris in Woodstock Beacon Herald
3. Summary of First International Symposium on the Global Wind Industry and Adverse Health Effects
Attachment 2: Recent article in Woodstock Beacon Herald:
Asked if wind farms are safe, Wilkinson said, "Yes, and I say that if a wind farm is built in the province of Ontario under the new, strict minimum distance setback and maximum noise allowance setback, then according to the chief medical officer of health for Ontario, Dr. Arlene King, they are indeed safe."
If Mr. Wilkinson and Dr. King feel Ontario's setbacks are strict, and standards are adequate to protect health, perhaps they should have attended the International Symposium on Wind Turbines and Adverse Health Effects October 29-31, where numerous independent scientists from several countries demonstrated just the opposite.
Is it a coincidence that Ontario government and health officials did not attend this symposium to expand their knowledge beyond the literature reviews they tout as 'proof' their policies could not be impacting health? Is it true they were told not to attend, as the topics would not be 'congruent with the government's policy'? Obviously it is politically expedient for the scientific evidence to be ignored by the current provincial government in their rush to fill rural Ontario with wind turbines. We should all ask why they are hiding from the truth – the effects being experienced in numerous communities already.
The evidence presented at the symposium by experts in ear physiology, sleep disorders, noise, infrasound, and epidemiology clearly demonstrated the mechanisms by which adverse health effects occur in proximity to wind turbines. Infrasound is a significant component in the etiology of health effects being experienced, yet is completely ignored in Ontario's regulations. Results from a case-control study in the U.S. will soon be published, showing a significant relationship between proximity to turbines and impacts on health, using standardized, validated health measurements.
According to Carl Phillips, PhD (public policy, Harvard; professor of public health): 'there is overwhelming evidence that there are health problems from turbines near residences'.
According to Alec Salt, PhD, Professor of Otolaryngology, allowing turbines to be located 550 metres from people's homes is 'insane'.
The symposium presenters, attending on their own dime, assembled to share their findings and scientific expertise in an effort to better understand the phenomena being observed in wind turbine developments worldwide. They all shared genuine concern and a desire to prevent harm. Dr. King, Mr. Wilkinson and our provincial government would do well to follow suit. Our rural families deserve nothing less.
J. Morris, MHSc (Community Health & Epidemiology)
Woodstock ON
Attachment 3: Summary of The First International Symposium on the Global Wind Industry and Adverse Health Effects.
The First International Symposium on the Global Wind Industry and Adverse Health Effects, held this past weekend in Picton, brought together American, British and Canadian acousticians, physicists, physicians, and medical researchers. The audience came from across Ontario and the United States and from as far as Australia.
Our understanding of how wind turbines can affect human health is steadily increasing. Since the facts often contradict the Ontario government's and wind industry's claims, it is imperative that the CMOH clarify the current state of knowledge. For complete transcripts please see
Symposium Proceedings
1. Claim: Ontario's regulations are the best in the world.
FACTS: Orville Walsh, CCSAGE chair and APPEC vice president, studied government regulations in every country hosting wind turbines. The standards differ widely and most are based on noise, not setback distances. Ontario's noise level is 40 dbA, measured outside a home. Countries, like Germany, with lower levels cite either 35 dbA or +3 dbA above ambient sound.
Night time ambient sound in a rural area is typically 30 dbA or less. (On the dbA scale, the ear can detect a difference of +/- 2-3 decibels and perceives 10 decibels as a doubling of sound.)
2. Claim: The sounds heard from wind turbines are no louder than whispers or a refrigerator.
FACTS: Dr. John Harrison, a physicist, explained that wind turbine sounds, especially the "swoosh," are different because of their amplitude and can exceed the 40 dbA regulatory limit because turbine sitings are based on computer models, not live measurements. Moreover, turbine noise is not masked by natural sounds and can sometimes be perceived over great distances. Depending on weather conditions and cloud cover, a large installation of wind turbines, such as those planned for Lake Ontario, could emit over 40 dbA of noise as far as 9-15 km away.
3. Claim: Wind Turbines do not produce low-frequency sound.
FACTS: Acoustician Rick James exhibited spectrograms of the sound coming from land-based wind turbines in which the low-frequency component was substantial and could be measured more than 5 km away. He also compared the symptoms of people suffering from "Wind Turbine Syndrome" to the identical symptoms reported in the 1970's and 80s by those working in so called "sick buildings." The latter problem was eventually identified as due to infra low frequency sound (ILFN) transmitted through ducting.
4. Claim: People cannot detect infrasound.
FACTS: Dr. Alex Salt, a physiologist, described his recent research findings in which parts of the inner ear reacted visibly to infrasound. His research shows that the ear does respond to low frequency sound even though we do not perceive it as sound. Further research will be required to understand how these impulses are transmitted to the brain, with possible disturbance and detrimental effects.
5. Claim: Complaints about wind turbine noise indicate annoyance, which is harmless.
FACTS: Dr. Arline Bronzaft, a noise researcher, explained how daytime transit noise near a New York City public school went well beyond annoyance and affected students' academic achievement. The effects of noise disturbance are not restricted to night time, and the effects of noise on children can be profound, impacting development.
6. Claim: Wind turbine noise is harmless.
FACTS: Dr. Christopher Hanning, a specialist in Sleep Medicine, explained how noise can disrupt the sleep patterns necessary for health and how loss of sleep affects memory and thinking, and can lead in the long term to risks of diabetes and heart disease.
Dr. Nina Pierpont, a physician and researcher and author of Wind Turbine Syndrome, explained how auditory systems react to sound and the negative effects of wind turbine sound on the patients she has studied.
7. Claim: Wind turbine noise affects few people seriously.
FACTS: Dr. Michael Nissenbaum reported on his studies of people living near wind projects in Mars Hill and Vinalhaven, Maine. Both studies indicate that residents within 2 km and beyond, compared to a control group outside the project areas, suffered serious sleep disturbance and stress.
8. Claim: Wind turbines are safe because no peer-reviewed studies prove otherwise.
FACTS: Dr. Carl Phillips, an epidemiologist, explained that clinical reports around the world are sufficient evidence of adverse health effects and that wind industry denials reflect misunderstanding of the stages of scientific inquiry and the value of peer review.
9. Claim: Wind development serves the public good.
FACTS: Carmen Krogh, board member of the Society for Wind Vigilance, applied the concept of social justice to public health and presented testimonies from Ontario, Germany, and Japan of people suffering from wind projects. Ontario rural residents are dismayed, to put it mildly, that every government agency has ignored their plight.
10. Claim: Ontario's Green Energy Act is unchallengeable.
FACTS: Lawyer Eric Gillespie outlined the legal actions Ontario residents can take against wind development, including the appeal process for the Ministry of Environment's Renewable Energy Approval of projects. Appeals, however, must meet a high standard by proving that harm to health is serious or harm to the environment is both serious and irreversible. By contrast, the Ian Hanna case has only to prove scientific uncertainty about the harm to human health.
11. Claim: Wind development saves lives by closing coal-burning electricity plants.
FACTS: Economist Dr. Ross McKitrick reported that Ontario's air pollution has declined steadily since the 1960s and that, according to data from government measuring stations, coal-related emissions are no more than one part per billion. Statistics of 250 to 9,000 Ontario deaths annually related to coal burning are based on dubious computer models from elsewhere; they are not founded on actual certificates of death. There is simply no problem arising from coal on which wind energy development could have a positive effect.
12. Claim: Wind Energy Development is a solution to the Need for Electricity.
FACTS: Journalist Robert Bryce, author of Power Hungry: The Myths of Green Energy and the Real Fuels of the Future, described society's need for reliable electric power, not intermittent, variable wind energy. Since there is no technology for mass storage of electricity, the power produced from wind cannot contribute substantially to electricity supply, let alone replace base load.
Considering the adverse health effects and practical limitations of wind energy, how is it that wind development remains so popular? The answer lies in twenty years of social marketing, environmental fears, and the false economic hope of green jobs. The Symposium should make everyone question what the Ontario government and wind industry would like us to believe.
Friends of Arran Lake
Wind Concerns Ontario
RR1 Southampton ON
Central Bruce Grey N0H 2L0
Scientists call it the Beepocalyspe. (OK, not scientists, but I 