Public Service Commission of Wisconsin (PSC)
Submitted: 6/24/2010 11:08:34 PM
Wind Siting Rules 1-AC-231
Commentor Information:
Name: Glen R. Schwalbach, P.E. for towns of Morrison, Wrightstown, and Glenmore
Address: 1090 Moonriver Dr
City: De Pere   State:WI   Zip:54115
Phone: 920-680-2436
Submitted to: Public Service Commission of Wisconsin
Docket No. 1-AC-231 Draft Chapter 128--Wind Energy Systems

Request by the Towns of Morrison, Wrightstown and Glenmore
Brown County, Wisconsin
June 23, 2010

Issue: Request to delay issuing the PSCW wind siting standards until epidemiological studies of health complaints from Wisconsin`s current wind farms are thoroughly completed.

The towns of Morrison, Wrightstown, and Glenmore in Brown County are very concerned about the mounting evidence that there are serious negative impacts on human and animal health caused by wind turbines. It appears it is not only reasonable to delay the issuance of wind siting standards but it would be irresponsible to not do so in light of new studies and ongoing complaints of residents in and near Wisconsin`s existing wind farms.

In general, scientifically and statistically relevant studies have been limited. But, a very important report was published March 2010 by the World Health Organization (WHO) entitled "Night Noise Guidelines for Europe" (available at

The report is based on a six-year evaluation of scientific evidence by thirty-five scientists from medical and acoustical disciplines. WHO indicated that now governments have justifications to regulate noise exposure at night. WHO sets the limit for annual average exposure to not exceed 40 decibels (dB) outside of a residence.

WHO stated, "Recent research clearly links exposure to night noise with harm to health. Sleep disturbance and annoyance are the first effects of night noise and can lead to mental disorders. Just like air pollution and toxic chemicals, noise is an environmental hazard to health". WHO stated that they hope their new report will prompt governments to invest effort and money in protecting health from this growing hazard.

Our towns ask the PSCW to acquire the WHO report and evaluate its application to setting appropriate sound levels for wind turbines.

The PSCW`s draft rules do not address low frequency noise levels. It is not known whether the WHO report addresses this issue but other studies have described the likely effects. This is another area where epidemiological studies are needed before wind turbine setbacks can be reasonably proposed.

Besides sleep disturbance, there are complaints of other physiological problems. It is not acceptable to ignore or minimize the significance of these impacts as just quirks of human imagination.

Also, there is evidence that existing wind farms in Wisconsin are negatively affecting farm animals. Whether it is noise or some other physical phenomena, studies and testing should be done before setting siting standards.

At a public meeting of the Brown County Health Department and the Brown County Human Services Committee, reputable medical and health experts stressed the importance of epidemiological studies to determine the true nature of health impacts of wind turbines.

The State Board of Health pointed out that the lack of funding is a hurdle. But a conviction to do the right thing should prompt the PSCW to make a case to pursue the money issue with state legislators as well as our U.S. senators and representatives. Certainly, our towns would help in this endeavor. That said, it is even more appropriate for the wind developers and their associations to offer funding for independent studies since such studies should reduce future litigation. Electric utilities should have a stake in this effort as well. This is an opportunity to involve the University of Wisconsin research capabilities in both human health and animal health.

It appears that Act 40 does not set a deadline for completing the siting rules. This week a state senator who was one of the leaders in passing the wind siting law agreed that studies should be done to be sure the rules are adequate. If one or two years were used to study the existing wind farms while delaying any new installations, the developers would still have time to help utilities meet their 15% RPS by 2015. Again, if needed, our towns would help in getting the support of legislators.

Our towns implore the PSCW and the Wind Siting Council to not ignore the evidence of potentially serious health impacts and to not set standards until they have done the obvious and reasonable step of studying the health impacts of existing wind turbine installations in Wisconsin. Professional ethics demands no less. We believe our request aligns with the PSCW`s responsibility to protect the citizens of Wisconsin.

Submitted for the towns by Glen R. Schwalbach, P.E.

I affirm that these comments are true and correct to the best of my knowledge and belief.
Glen R. Schwalbach, P.E. for towns of Morrison, Wrightstown, and Glenmore