REF has today written to the president of the Institute of Acoustics, Professor Bridget Shield, with the warning that the forthcoming IOA Good Practice Guide on Wind Turbine Noise will be valueless and lack credibility unless the underlying primary data providing the evidence base for the recommended methodology and conclusions underpinning the guidance is also published to enable independent validation.
This principle is enshrined in the IoA code of conduct for members; i.e.
"A1.4 Members shall show proper regard for the sanctity of data. In particular members will:
not knowingly alter, manipulate, fabricate or misrepresent data.
ensure that primary data used in any publication or report are available in a form that would allow for independent scrutiny and that sufficient details of any experiments, by which the data were derived, are available to allow others to replicate such experiments."
REF's letter has been sent to Michael Fallon MP, Minister of State for Energy at the Department of Energy and Climate Change (DECC), and to the Rt Hon Owen Paterson, Secretary of State for the Department of the Environment Food and Rural Affairs (DEFRA), the two departments responsible for the legislation protecting residents from unacceptable noise impacts arising from wind turbines.
The text of the letter is as follows:
Professor Bridget Shield
President
Institute of Acoustics
3rd Floor St Peter's House
45-49 Victoria Street
ST. ALBANS
AL1 3WZ
By email and post
19 April 2013
Dear Professor Shield,
Re IoA Consultation on ETSU-R-97
The Renewable Energy Foundation (REF) has been concerned for some years about the accuracy of
the wind farm noise guidance, ETSU-R-97, and the standard of wind farm noise assessments carried
out by members of the Institute of Acoustics. In an endeavour to increase the understanding of wind
farm noise impacts we have written several information notes on controversial noise issues and made
the raw data we used freely available.1
We have also contributed to the IoA Consultation on the ETSU-R-97 wind farm noise guidance.2
However, we have only uncertain confidence in the outcome of the IoA consultation, not least
because the draft consultation document itself contains a number of assertions that are not backed up
by data in the public domain, so cannot be independently tested. We note that the IoA has a specific
item in its Code of Conduct, which calls upon members to “ensure that primary data used in any
publication or report are available in a form that would allow for independent scrutiny”. However, we
are disappointed that acousticians working on wind industry noise issues routinely fail to comply with
this edict.
We have observed over the years that significant progress in the understanding of wind farm impacts
has been largely achieved by members of the public who have had to fight hard – often through the
courts – to obtain from acousticians and developers the primary data necessary to quantify noise
impacts. When such data is finally released, it has been routinely found that the claims made about
the data do not stand up. We strongly believe that the IoA should be pushing for full disclosure of
relevant data and not leaving this task to members of the public affected by wind farm developments.
We believe it is indispensable that you ensure that the final IoA report on the ETSU-R-97 guidance
contains no statements which cannot be independently verified by free access to raw data and that it is
made plain to readers where such data can be obtained.
Where such data is genuinely not available, we believe that conservative and reasoned assumptions
designed to ensure protection of neighbours’ amenity may be made, as distinct from those to date
where maximising wind farm output at the expense of neighbours’ amenity is the driving force.
Furthermore, we note that the consultation process has not addressed providing corroborative data
and we would suggest that another iteration of consultation is necessary to flesh out what data is
necessary. We hope that you can intercede in this matter to ensure that the IoA report can be seen to
be demonstrably fair and accurate.
I would be very grateful if you could let me know what if any steps you propose to take in relation to
the matters described in this letter.
Yours sincerely,
John Constable.
Director
CC:
Michael Fallon MP, Minister of State for Energy, DECC.
The Rt Hon Owen Paterson MP, Secretary of State for DEFRA.
1 http://www.ref.org.uk/publications/242-the-den-brook-amplitude-modulation-noise-condition;
http://www.ref.org.uk/publications/255-ioa-critique; http://www.ref.org.uk/publications/151-ref-publishes-data-on-wind-farm-noise-obtained-under-the-freedom-of-information-act
2 http://www.ref.org.uk/publications/274-ref-consultation-response-to-ioa-on-etsu-r-97