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Neglect of Wind Shear in Assessing Long Range Propagation of Wind Turbine Noise M WToft Select Committee on Wind TurbinesSubmission 193 - Attachment 1 About the author: • BSc in Physics (University of Bristol); PhD on turbulence and vorticity in superfluid flow (University of St Andrews) • Over 20 years’ experience with CEGB and successor companies in acoustics-related field of ultrasonic non-destructive testing (NDT), as applied to safety of UK nuclear reactors; in particular the validation of theoretical models of propagation of acoustic and elastic waves; programme manager for Generic NDT Development at BNFL-Magnox Generation; provision of expert advice and documentation to the Nuclear Installations Inspectorate, on capability of ultrasonic inspection to guarantee structural integrity of UK nuclear reactors • Former Member of the British Institute of Non-Destructive Testing (BINDT) - recipient in 2007 of the Institute's premier award, the Roy Sharpe Prize, for contributions to research and development over 20 years • Member of Peer Review College of the Engineering and Physical Sciences Research Council, 2000 - 2003 • On retiring from the nuclear industry in 2005, made Visiting Fellow at the Department of Physics, University of Bristol, although not active in the latter role • Expert Witness on noise to Save Berkeley Vale in Public Inquiry APP/C/1625/A/11/2155923/NWF, Jan-Sep 2012, opposing the proposed wind farm development at Standle Farm, Stinchcombe, Dursley Glos Select Committee on Wind TurbinesSubmission 193 - Attachment 1 Contents 1.
Wind Shear – Introduction 2.

Motorway Noise Example 3.

Application to Wind Turbine Noise 4.

Implications for Low Altitude Winds 5.

Wind Shear in Practice 6.

Implications of Wind Shear Variation (i) Overview; (ii) IoA proposed approach to implementation of ETSU-R-97 (iii) Analysis - A; (iv) Analysis - B (v) Analysis - conclusions 7.

Neglect of Wind Shear in Noise Impact Assessment 8.

ISO 9613-2 – Disparities of Wind Turbine Applications with Original Design Constraints 9.
ISO 9613-2 – Validation Studies on Extended Application to Wind Turbine Noise Prediction (i) Study 1; (ii) Study 2; (iii) Study 3; (iv) Conclusions Select Committee on Wind TurbinesSubmission 193 - Attachment 1 Section 1 Wind Shear - Introduction Select Committee on Wind TurbinesSubmission 193 - Attachment 1 Wind shear effects on noise propagation Wind shear is change in wind speed with height above ground level 120rm Wind speed usually increases with height- but not always: positive wind shear is the normal condition lOOr- Refraction by w ind shear is of paramount importance in determining propagation paths of outdoor noise 80 r- Wind shear refraction shapes propagation paths in all directions, strongly affecting intensity of sound at receiving locations 40 Wind shear is a principal cause of noise levels being often unexpectedly enhanced at locations a long way downwind of a noise source Understanding of effects of wind shear was established _ by Stokes, Reynolds and Rayleigh in the mid to late 19th Century Select Committee on Wind TurbinesSubmission 193 - Attachment 1 Section 2 Motorway Noise Example Select Committee on Wind TurbinesSubmission 193 - Attachment 1 Wind shea r effects on noise propagation Motorway noise provides an everyday example: If you stand immediately next to a motorway when the wind is blowing across it, it doesn't matter which side you stand on, upwind or downwind, noise levels will be essentially the same If you wa lk away from the motorway on the upwind side, ie walking into the wind, noise levels will drop off quite rapidly This is not true of walking away on the downwind side: noise will persist at significant levels for many hundreds of meters Select Committee on Wind TurbinesSubmission 193 - Attachment 1 Wind shear effects on noise propagation Were there to be a 25 mph gale blowing across the motorway, with the same wind speed at all heights, the motorway would be equally noisy at long distances upwind as downwind This effect is not within our normal experience but would occur in
 such a situation of zero wind shear It would happen because the speed of sound in air is around 768 mph, so movement of all the air at 25 mph one way or the other will have very little effect Select Committee on Wind TurbinesSubmission 193 - Attachment 1 Wind shear effects on noise propagation But in practice the wind is generally stronger at greater heights, which progressively changes the speed of sound with height This in turn changes the curvature of the wavefronts and hence the direction of their propagation The opposite happens on the upwind side Soundwaves consequently bend back down to earth on the downwind side at longer distances from the source Sc~ematlc of ray propagatlon developed us1ng Johns Hopkrns Umvers1ty On-line Virtual laboratory Select Committee on Wind TurbinesSubmission 193 - Attachment 1 Section 3 Application to Wind Turbine Noise Select Committee on Wind TurbinesSubmission 193 - Attachment 1 Wind shear effects on noise propagation Wind turbines will also operate under generally positive wind shear conditions Turbine noise propagating upwind is refracted upwards into the sky, reducing long range impact at ground level The wind speed gradient will have a similar effect on long range propagation of turbine noise Turbine noise propagating downwind is refracted downwards towards the ground, enhancing long range impact at ground level Schematic of ray propagation developed using Johns Hopkins University On-line Virtual Laboratory Select Committee on Wind TurbinesSubmission 193 - Attachment 1 Wind shear effects on noise propagation It is noteworthy th at under the less common condition of negative wind shear, noise propagation would be entirely counter-intuitive Long range noise impact at ground level is now enhanced in the up-wind, rather than the down-wind direction Noise propagation at longer range downwind is refracted upwards into the sky, reducing impact at ground level This emphasises that sound is not simply 'blown along by the wind'
 Schematic of ray propagation developed using Johns Hopkins University On-line Virtual Laboratory Select Committee on Wind TurbinesSubmission 193 - Attachment 1 Section 4 Implications for Low Altitude Winds Select Committee on Wind TurbinesSubmission 193 - Attachment 1 Wind shear effects on noise propagation 250 m One recognised meteorological condition involving a region of negative wind shear is that of a low altitude wind, or 'low-level jet' A plausible wind speed profil e is shown here in relation to the height of a modern wind turbine, illustrating a low level j et with negative wind shear above a height of 50 m This profile is consistent with measurements presented in a study of road traffic noise propagation in the USA See Ovenden, Shaffer and Fernando: 'Impact of meteorological conditions on noise propagation from freeway corridors' Journal of the Acoustical Society of America, 126 (1), July 2009 ~-~ ~ • • • 200 • • • • ~ • • • • • • • • • » • • • • • • • •• • • • 0 • • 2 4 • • 6 L- Wind speed m/s 150 100 so -2 Select Committee on Wind TurbinesSubmission 193 - Attachment 1 Wind shear effects on noise propagation 120 m A low-level jet in fact consists of regions of both positive and negative wind shear For the illustrated case of a parabolic jet below hub height, this could lead to localised upwind regions of high turbine noise impact ~...;........;....;..___'.?
!.~~~~· Wind shear can thus produce seemingly anomalous behaviour under certain well-recognised meteorological conditions near ground level l :±:!.!::!
:________;_, ~ ~ \ \ \ \\\ :; ~ \\\\ \\\~ - ~~-=----- Schematic of ray propagation developed using Johns Hopkins University On-line Virtual Laboratory Select Committee on Wind TurbinesSubmission 193 - Attachment 1 Wind shear effects on noise propagation 120 m 100 Downwind propagation under a low-level jet In the downwind direction, such a low-level jet will cause propagation to be highly divergent, such that noise impact falls off rapidly at longer range A low-level wind thus has an effect opposite to that of 'blowing sound along' 111/ff/~.--~ Schematic of ray propagation developed using Johns Hopkins University On-line Virtual Laboratory Select Committee on Wind TurbinesSubmission 193 - Attachment 1 Section 5 Wind Shear in Practice Select Committee on Wind TurbinesSubmission 193 - Attachment 1 Wind shear in practice Wind shear varies significantly and systematically over the course of 24 hours, according to the meteorological condition of the atmosphere Whilst positive wind shear is the normal condition, zero or negative wind shear can occur in practice, as made clear in the 'Acoustic Bulletin Agreement' of April 2009: .... "On some sites and in some wind conditions the situation may arise that the wind speed U1 (at the greater height H1) is equal to or lower than the wind speed U2 at the lower height H2."
The following illustrations pertain to a proposed wind farm site in Gloucestershire, and show measured diurnal variation in positive wind shear at 60 to 70 m height, spanning 3 seasons of the year -each figure represents the average for a different season, taken over a period of at least 6 weeks The figures are based on developer's tall mast measurements of wind speeds, recorded every 10 minutes at heights of 60 and 71 m, and were accepted as evidence at Public Inquiry l I Select Committee on Wind TurbinesSubmission 193 - Attachment 1 Wind shear in practice Daily variation in wind shear averaged over 7 weeks in spring - Berkeley Vale 2010 0.6 0.5 -+--- - - - - - - - - - - - - - - - - - - - - - - - ---f\-------1 +J c Q) c 0 a. X Q) L. ro Q) 0.4 -t------:-ifr-+..Jf-H--------..-r---++---------------+--:-------l~+-----\ ~ V') 0+-~~~~-~~~~~-~~~~~-~~~~~~~~~~~ 0 Time of day- hrs Select Committee on Wind TurbinesSubmission 193 - Attachment 1 Wind shear in practice Daily variation in wind shear averaged over 6 weeks in early summer - Berkeley Vale 2010 +J c Q) c 0 a. X Q) 0.5 + - - - ----- - - - - - - - - - - - - - - - - - - - - - - - -1 L. ro Q) OA+#~~~+-~~-----------------~-~-_, ~ V') 0+-~~~~-~~~~~-~~~~~-~~~~~~~~~~~ 0 Time of day- hrs Select Committee on Wind TurbinesSubmission 193 - Attachment 1 Wind shear in practice Daily variation in wind shear averaged over 7 weeks in early autumn - Berkeley Vale 2010 +J c Q) c 0 a. X Q) 0.5 4 - - - - - - - - - - --Pr---- - - - - - - - - - - - - - - - - - - - - - - ; L. ro Q) OA+--+--+~~~~-~+------------~~-4-~-~ ~ V') 0+-~~~~-~~~~~-~~~~~-~~~~~~~~~~----; 0 Time of day- hrs Select Committee on Wind TurbinesSubmission 193 - Attachment 1 Wind shear in practice The above analysis shows systematic daily patterns of very significant wind shear variation at this proposed UK wind farm site Diurnal
 variation in wind shear exponent a is strikingly similar across the seasons - strongest variation is observed in early summer These results are more extreme than similar observations in a wide-ranging US Department of Energy study, of wind shear in the US Central Plains at heights relevant to modern turbines See: Wind shear characteristics at Central Plains tall towers M. Schwartz and D. Elliott American Wind Energy Association Wind Power 2006 Conference Pittsburgh, Pennsylvania, June 4-7, 2006 The UK observations of consistently high night-time shears, a = 0.4 to 0.5, recorded over 3 different seasons at a single location, were not encountered in the US study covering the entire length of America Select Committee on Wind TurbinesSubmission 193 - Attachment 1 Section 6 Implications of Wind Shear Variation (i)Overview Select Committee on Wind TurbinesSubmission 193 - Attachment 1 Implications of wind shear variation Owing to the effects of refraction, this significant pattern of daily wind shear variation will cause large variations in turbine noise propagation and subsequent impact at receptors Crucially, excursions in received turbine noise levels under varying wind shear conditions will particularly predispose to complaints This is shown by following analysis of loA proposed implementation of ETSU-R-97 approach to noise impact assessment: Receptor X !
- t .. • I Select Committee on Wind TurbinesSubmission 193 - Attachment 1 Section 6 Implications of Wind Shear Variation (ii) IoA proposed approach to implementation of ETSU-R-97 Select Committee on Wind TurbinesSubmission 193 - Attachment 1 Implications of wind shear variation Wind speed at hub height relates directly to turbine noise emission level Basis of loA proposed approach to implementation of ETSU-R-97 - - - - - - Vhub !
- t .. • I These emission levels yield 10 minute average predictions of turbine noise at each receptor These received noise levels are then correlated with local background levels measured over the same 10 minute periods at each receptor Average predictions of turbine noise are compared with representative levels of background noise Receptor X Select Committee on Wind TurbinesSubmission 193 - Attachment 1 Section 6 Implications of Wind Shear Variation (iii) Analysis - A Select Committee on Wind TurbinesSubmission 193 - Attachment 1 Implications of wind shear variation for noise impact assessment A background noise survey could record many repeated instances of a particular hub-height wind speed and its associated turbine noise prediction at the receptor - - - - - - Vhub many separate instances of, say, Vhub = 8.4 m/s many repeated predictions of L turbine = 37 dB Receptor !
Select Committee on Wind TurbinesSubmission 193 - Attachment 1 Implications of wind shear variation for noise impact assessment These multiple instances of the ~ same turbine noise prediction will then always be plotted at the same standardised 10 m wind speed in the ETSU noise assessment plot 120 m 100 Hub height= 80m - - --- - Vhub - ae many separate instances of, say, Vhub = 8.4 m/s 60 40 20 many repeated predictions of l turbine = 37 dB V1o ref = 6.0 m/s { !

- t .. • I - - Vlo ref = 6.0 m/s Receptor !
Select Committee on Wind TurbinesSubmission 193 - Attachment 1 Implications of wind shear variation for noise impact assessment For any of these instances, the corresponding wind speed nearer to ground level will be dependent on the actual wind shear pertaining at the time, and will vary significantly from instance to instance wind speed many separate instances of, say, Vhub = 8.4 m/s 40 many repeated predictions of l turbine = 37 dB V1o ref = 6.0 m/s { low shear - - Vlo ref= 6.0 m/s Receptor !
Select Committee on Wind TurbinesSubmission 193 - Attachment 1 Implications of wind shear variation for noise impact assessment It is this near-ground wind speed that determines the level of locally generated background noise experienced at a property from wind-dependent sources many separate instances of, say, Vhub = 8.4 m/s low shear - - VlO ref = 6.0 m/s many repeated predictions of l turbine = 37 dB V1o ref = 6.0 m/s { Receptor ~ Select Committee on Wind TurbinesSubmission 193 - Attachment 1 Implications of wind shear variation for noise impact assessment many separate instances of, say, V hub = 8.4 m/s many repeated predictions of { l turbine= 37 dB V10 ref = 6.0 m/s + Receptor X V10 ref = 6.0 m/s 50 ETSU noise assessment plot 40 c ·e 0 ... !
co "0 30 0 0 0 0 20 c u 2 4 0 0 0 "'O ,.,'80 Varying background gives large vertical scatter at any standardised 10 m wind speed in noise assessment plot, according to wind shear 8 10 shear 6 Standardised wind speed at 10 m height V10 ref m/s Select Committee on Wind TurbinesSubmission 193 - Attachment 1 Implications of wind shear variation for noise impact assessment At given hub-height wind speed, ground level wind speeds at their lowest under conditions of highest wind shear - ee many separate instances of, say, V hub = 8 .4 m/s many repeated predictions of l turbine= 37 dB V 10 ref = 6.0 m/s { V10 ref= 6.0 m/s Receptor !
50 ETSU noise assessment plot 40 c ·e 0 ... !

co "0 30 0 0 0 0 20 2 u shear 4 Standardised wind speed at 10 m height V10 ref m/s 8 6 10 Select Committee on Wind TurbinesSubmission 193 - Attachment 1 Implications of wind shear variation for noise impact assessment Focusing attention on the ETSU noise assessment plot below: 50 ETSU noise assessment plot 40 c ·e 0 ... !
co "0 30 0 0 0 0 20 u 2 4 shear 6 8 10 Standardised wind speed at 10 m height V10 ref m/s Select Committee on Wind TurbinesSubmission 193 - Attachment 1 Section 6 Implications of Wind Shear Variation (iv) Analysis - B Select Committee on Wind TurbinesSubmission 193 - Attachment 1 Implications of wind shear variation for noise impact assessment ETSU noise assessment plot 37 - - - - - - - - 0 so .5 E c ~ 0 0\ .
:3 co ""0 40 30 0 0 0 0 0 many repeated predictions of L turbine= 37 dB { VlO ref= 6.0 m/s low 00 0 range of background levels for multiple instances of Vhub = 8.4 m/s .... ~ ..... - - - VlO ref= 6.0 m/s { 20~----------~~--~~~----- high ------------~------------~ 2 4 shear 6 8 10 Standardised wind speed at 10 m height V10 ref m/s Select Committee on Wind TurbinesSubmission 193 - Attachment 1 Implications of wind shear variation for noise impact assessment many repeated predictions of L turbine= 37 dB { VlO ref= 6.0 m/s ETSU noise assessment plot 37 - - - - - - - - 0 so 40 .5 E c ~ 0 0\ .
:3 co ""0 30 0 0 0 0 2 4 0 00 0 0 (' :) ~---~------------------~~ Background levels at their lowest under conditions - - ---1 of highest shear shear 6 8 10 Standardised wind speed at 10 m height V10 ref m/s Select Committee on Wind TurbinesSubmission 193 - Attachment 1 Implications of wind shear variation for noise impact assessment But received turbine noise will rise above the predicted average as so - .

- - - - - - - - - - , - - - - - - - - r - - ----.


: propagation is enhanced with ETSU noise assessment plot 37 - - - - - - - - 0 40 .5 E c ~ 0 0\ .
:3 co ""0 30 0 0 0 0 2 4 increasing wind shear 0 00 0 0 (' :) ~-~------~~ Background levels at their lowest under conditions - - ---1 of highest shear shear 6 8 10 Standardised wind speed at 10 m height V10 ref m/s Select Committee on Wind TurbinesSubmission 193 - Attachment 1 Implications of wind shear variation for noise impact assessment ETSU noise assessment plot 37 - - - - - - - - Received turbine noise at its highest under conditions of highest shear 0 .5 E c ~ 0 0 0\ .
:3 co ~ 30~--~~~~~~~~~~~~~~~~--~--~------------~ 00 0 0 0 0 0 2 4 0 (' :) ~--~------------~ Background levels at their lowest under conditions - - ---1 of highest shear shear 6 8 10 Standardised wind speed at 10 m height V10 ref m/s Select Committee on Wind TurbinesSubmission 193 - Attachment 1 .5 E c ~ Implications of wind shear variation for noise impact assessment ETSU noise assessment plot Received turbine noise at its highest under conditions of highest shear 37 --- ------~--~--~~~~~~~~~--~------0~ 0 0\ .
:3 co "C 30 --+--"' ___ _,............,..
Whenever turbine noise impact is higher than average owing to the effects of wind shear, background noise levels will be lower than average ,~~~~~~~~~--~~~~--------~~r--- 0 0 0 0 2 4 0 (' :) ~---~------------------~ Background levels at their lowest under conditions - - ---1 of highest shear shear 6 8 10 Standardised wind speed at 10 m height V10 ref m/s Select Committee on Wind TurbinesSubmission 193 - Attachment 1 Implications of wind shear variation for noise impact assessment 50~------------~------------~------------~------------~ ETSU noise assessment plot .5 E c ~ 0 0\ .
:3 co "C 30 --+--"' ___ _,............,..

There is thus a systematic anti-correlation between wind shear-induced variations in both received turbine noise and background noise ,~~~~~~~~~--~~~~--------~~r--- 0 0 0 0 0 0 2 4 shear 6 8 10 Standardised wind speed at 10 m height V10 ref m/s Select Committee on Wind TurbinesSubmission 193 - Attachment 1 Implications of wind shear variation for noise impact assessment ETSU noise assessment plot 37 - - - - - - - - 0 so .5 E c ~ 0 0\ .
:3 co ""0 40 30 0 0 0 0 20 'average' ..,.......-~;,__,:;;:....__....:..:...... __ _ background level 2 4 shear 6 best-fit line to scattered background noise data ( 0 00 0 A certain degree of variable noise impact is in fact allowed within the provisions of ETSU-R-97, via noise limits based only on 'average' background noise levels 8 10 Standardised wind speed at 10 m height V10 ref m/s Select Committee on Wind TurbinesSubmission 193 - Attachment 1 Implications of wind shear variation for noise impact assessment so~------------~--------------~------------~------------~ ETSU noise assessment plot predicted average 40~------ turbine noise 37 - - - - - - - - 0 0 0 0 0 20 'average' ..,......-~r::......._=------:..::----- background level shear best-fit line to scattered background noise data 0 00 But: It is statistically unsound to compare predicted average turbine noise with average background level, when fluctuations in underlying quantities are not statistically independent of each other under conditions of varying wind shear 2 4 6 8 10 Standardised wind speed at 10 m height V10 ref m/s Select Committee on Wind TurbinesSubmission 193 - Attachment 1 Section 6 Implications of Wind Shear Variation (v) Analysis - conclusions Select Committee on Wind TurbinesSubmission 193 - Attachment 1 Implications of wind shear variation for noise impact assessment 50 ~------------~------------~~------------~----------~ ETSU noise assessment plot predicted average 40 ~------------ turbine noise 37 - - - - - - - - 0 0 0 0 0 20 'average' ..,.......-~;,__,_:;;:....__....:..:...... __ _ background level 2 4 shear 6 best-fit line to scattered background noise data 0 00 Simply comparing ISO 9613-2 predictions of average received turbine noise with ETSU noise limits will not address the potential for complaints under worst-case wind shear conditions 8 10 Standardised wind speed at 10 m height V10 ref m/s Select Committee on Wind TurbinesSubmission 193 - Attachment 1 Implications of wind shear variation for noise impact assessment
 so~------------~--------------~------------~------------~ ETSU noise assessment plot predicted average 40~------ turbine noise 37 - - - - - - - - 0 0 0 0 0 20 'average' ..,......-~r::......._=------:..::----- background level shear best-fit line to scattered background noise data 0 00 This approach cannot provide the necessary confidence to Local Planning Authorities that complaints will not arise ~ 2 4 6 8 10 Standardised wind speed at 10 m height V10 ref m/s Select Committee on Wind TurbinesSubmission 193 - Attachment 1 Section 7 Neglect of Wind Shear in Noise Impact Assessment Select Committee on Wind TurbinesSubmission 193 - Attachment 1 Neglect of wind shear in noise impact assessment The major role of wind shear in outdoor noise propagation is not given explicit consideration in wind farm noise assessments Discussion is usually confined to quite separate implications of wind shear for generation of turbine noise at hub height and background noise at ground level Attention is restricted to differences between wind speed at different heights I Developers assume all propagation effects are covered implicitly by their use of International Standard ISO 9613-2 noise prediction methodology I This assumption is unjustified: ISO 9613-2 takes only limited account of wind shear effects on propagation, and only from low height, non-wind-dependent, stationary noise sources the degree of wind shear represented within the standard is not specified I Wider concerns regarding developers' choice and validation of ISO 9613-2, for application to modern, tall wind turbines are detailed below Select Committee on Wind TurbinesSubmission 193 - Attachment 1 Section 8 ISO 9613-2 – Disparities of Wind Turbine Applications with Original Design Constraints Select Committee on Wind TurbinesSubmission 193 - Attachment 1 Present applications of ISO 9613-2 show startling disparities with original design constraints 120 -m 100- 80 60- 40 - 20- --0- modern wind turbines have hub heights of 80
 m or more and blade tip heights are around 120 m when IS09613-2 was first applied to wind turbine noise prediction, hub heights were typically around 30 m Select Committee on Wind TurbinesSubmission 193 - Attachment 1 Present applications of ISO 9613-2 show startling disparities with original design constraints 120 m ISO 9613-2 is a 15 year-old empirical scheme 100 based on : average noise measurements from static, near-ground industrial plant 'moderate' downwind conditions - 10m height wind speeds up to 5 m/s - unspecified wind shear validated on: - a feedstuff plant - an asphalt plant - an oil refinery 80 60 40 20 Select Committee on Wind TurbinesSubmission 193 - Attachment 1 Present applications of ISO 9613-2 show startling disparities with original design constraints 120 m ISO 9613-2 is a 15 year-old empirical scheme 100 80 60 40 based on : average noise measurements from static, near-ground industrial plant 'moderate' downwind conditions - 10m height wind speeds up to 5 m/s - unspecified wind shear - a feedstuff plant - an asphalt plant - an oil refinery Food processing plant -height around 25 m {84ft) Select Committee on Wind TurbinesSubmission 193 - Attachment 1 Present applications of ISO 9613-2 show startling disparities with original design constraints 120 m ISO 9613-2 is a 15 year-old empirical scheme based on : average noise measurements from static, near-ground industrial plant 'moderate' downwind conditions - 10m height wind speeds up to 5 m/s - unspecified wind shear - low turbulence conditions - noise generation not wind-related 100 80 60 40 L Select Committee on Wind TurbinesSubmission 193 - Attachment 1 Present applications of ISO 9613-2 show startling disparities with original design constraints 120 m ISO 9613-2 is a 15 year-old empirical scheme based on : average noise measurements from static, near-ground industrial plant 'moderate' downwind conditions - 10m height wind speeds up to 5 m/s - unspecified wind shear An empirical model is not
 valid outside its (parameter space' - low turbulence cond itions - noise generation not wind-relat ed 100 80 60 40 L Select Committee on Wind TurbinesSubmission 193 - Attachment 1 Present applications of ISO 9613-2 show startling disparities with original design constraints 120 m 'Application creep' over 15 years: 100 80 60 40 10 m height wind speeds up to 10 m/s daily variation of wind shear exponent through large range (0.1- 0.5) extended periods of very high shear in evenings and night time 10m height wind speeds up to 5 m/s 'moderate' downwind conditions unspecified wind shear Select Committee on Wind TurbinesSubmission 193 - Attachment 1 Present applications of ISO 9613-2 show startling disparities with original design constraints 120 m 'Application creep' over 15 years: 100 80 60 40 wind-induced noise generation blade tip noise sources moving at up to 170 mph this is almost 1/4 speed of sound modern turbine will always have blade tip noise source above height of 100 m noise generation not w ind-related noise sources static and near-ground Select Committee on Wind TurbinesSubmission 193 - Attachment 1 Present applications of ISO 9613-2 show startling disparities with original design constraints turbulent incident airstream noise propagation through turbulent air of wake propagation will be affected by highly localised wind shear caused by motion of blades Select Committee on Wind TurbinesSubmission 193 - Attachment 1 Present applications of ISO 9613-2 show startling disparities with original design constraints m 60 40 turbulent wake extending a considerable distance downwind turbulence enhances long range noise propagation Select Committee on Wind TurbinesSubmission 193 - Attachment 1 Photograph from Ris0, Danish National Laboratory for Sustainable Energy, showing turbine wakes in the Horns Rev off-shore wind farm Image presumably obtained under atmospheric conditions rendering turbine wakes visible via formation of water droplets in response to pressure
 changes Select Committee on Wind TurbinesSubmission 193 - Attachment 1 Present applications of ISO 9613-2 show startling disparities with original design constraints 120 m 100 There appears no scientific foundation to this extended application of ISO 9613 Wind farms now cause noise problems in a not insignificant number of cases This highlights depth and rigour needed in validation studies claiming to support such extended application 80 60 40 Select Committee on Wind TurbinesSubmission 193 - Attachment 1 Section 9 ISO 9613-2 – Validation Studies on Extended Application to Wind Turbine Noise Prediction - Study 1 Select Committee on Wind TurbinesSubmission 193 - Attachment 1 Three validation studies on extended application of ISO 9613-2 to wind turbine noise prediction 1.
Bass J H, Bullmore A J, Sloth E, EU Joule Project Final Report (1998): 'Development of a Wind farm Noise Propagation Prediction Model' report fails to present any data whatsoever in graphical or tabular form Select Committee on Wind TurbinesSubmission 193 - Attachment 1 Three validation studies on extended application of ISO 9613-2 to wind turbine noise prediction 120 m 1.
Bass J H, Bullmore A J, Sloth E, EU Joule Project Final Report (1998): 'Development of a Wind farm Noise Propagation Prediction Model' 100 80 60 40 used loudspeaker source on a mast at heights between 15m and 30m 'to identify the influence of specific parameters on noise propagation' ~ ~ ~ 1ft ~ i;J)j ~ ~ ~ ~ ~ 1ft ~' ,;Jj ~ ~ Select Committee on Wind TurbinesSubmission 193 - Attachment 1 Three validation studies on extended application of ISO 9613-2 to wind turbine noise prediction 120 m 1.
Bass J H, Bullmore A J, Sloth E, EU Joule Project Final Report (1998): 'Development of a Wind farm Noise Propagation Prediction Model' 100 80 60 40 20 use of low height loudspeaker noise source completely eliminates effects of a turbine wake study fundamentally flawed for validating ISO 9613 application to wind turbines ~ "' ~ ,;J) ..; ~ Select Committee on Wind TurbinesSubmission 193 - Attachment 1 Three validation studies on extended application of ISO 9613-2 to wind turbine noise prediction 120 m 1.
Bass J H, Bullmore A J, Sloth E, EU Joule Project Final Report (1998): 'Development of a Wind farm Noise Propagation Prediction Model' 100 80 60 40 20 elimination of turbine wake effects effectively 'throws out the baby with the bath water' ~ ~ (f!IY '~ study fundamentally flawed for validating = ~ ISO 9613 application to wind turbines ,;J) = ~ ~ ~" IIJ)j - ~ ~ Select Committee on Wind TurbinesSubmission 193 - Attachment 1 Three validation studies on extended application of ISO 9613-2 to wind turbine noise prediction 120 m 1.
Bass J H, Bullmore A J, Sloth E, EU Joule Project Final Report (1998): 'Development of a Wind farm Noise Propagation Prediction Model' 100 80 60 40 20 ISO 9613 is an empirical model derived from noise sources that are: near-ground non-wind-related without a turbu lent wake ~ ~ (f!IY '~ study fundamentally flawed for validating = ~ ISO 9613 application to wind turbines ,;J) = ~ ~ ~" IIJ)j - ~ ~ Select Committee on Wind TurbinesSubmission 193 - Attachment 1 Three validation studies on extended application of ISO 9613-2 to wind turbine noise prediction 120 m 1.
Bass J H, Bullmore A J, Sloth E, EU Joule Project Final Report (1998): 'Development of a Wind farm Noise Propagation Prediction Model' 100 80 60 40 20 ISO 9613 should by definition perform well for such loudspeaker sources: the situation falls within the model's parameter space ~ ~ (f!IY '~ study fundamentally flawed for validating = ~ ISO 9613 application to wind turbines ,;J) = ~ ~ ~" IIJ)j - ~ ~ Select Committee on Wind TurbinesSubmission 193 - Attachment 1 Three validation studies on extended application of ISO 9613-2 to wind turbine noise prediction 1.
Bass J H, Bullmore A J, Sloth E, EU Joule Project Final Report (1998): 'Development of a Wind farm Noise Propagation Prediction Model' Further to ill-conceived scope, report appears inconsistent with established physics from pl.
.... 'The major objectives of this project are thus: -to establish by measurement the important parameters controlling the propagation of wind farm noise to the far field ..... ' However: the report appears to give no discussion whatsoever of the effects of wind shear neither does any wind shear data appear to have been measured or provided it would appear that wind shear was not considered as an important parameter influencing downwind noise propagation Select Committee on Wind TurbinesSubmission 193 - Attachment 1 Three validation studies on extended application of ISO 9613-2 to wind turbine noise prediction 1.
Bass J H, Bullmore A J, Sloth E, EU Joule Project Final Report (1998): 'Development of a Wind farm Noise Propagation Prediction Model' The report then appears totally mistaken in its conclusion that: {The primary cause for the observed variation in noise levels is the systematic dependence of the sound pressure level on the component of vector wind speed from the source to the receiver' (p9 - unscreened propagation over all terrain types) this assertion of a causal relationship between sound pressure level and wind speed is quite wrong - the two are essentially unrelated It appears not to have been realised that wind shear must have been simultaneously varying with wind speed, and was causing the observed effects Select Committee on Wind TurbinesSubmission 193 - Attachment 1 Three validation studies on extended application of ISO 9613-2 to wind turbine noise prediction 1.
Bass J H, Bullmore A J, Sloth E, EU Joule Project Final Report (1998): 'Development of a Wind farm Noise Propagation Prediction Model' See in contrast a recent authoritative publication on the problem of sound propagation in a wind: G. W. Gibbons & C. M .
Warnick "Traffic noise and the hyperbolic plane", Annals of Physics 325 (2010) One of the authors is Prof Gary W Gibbons FRS, Professor of Theoretical Physics at DAMTP, the Department of Applied Mathematics and Theoretical Physics, University of Cambridge Select Committee on Wind TurbinesSubmission 193 - Attachment 1 Three validation studies on extended application of ISO 9613-2 to wind turbine noise prediction 1.
Bass J H, Bullmore A J, Sloth E, EU Joule Project Final Report (1998): 'Development of a Wind farm Noise Propagation Prediction Model' See in contrast a recent authoritative publication on the problem of sound propagation in a wind: The paper includes a historical perspective on understanding of enhanced noise propagation at long distances downwind: 'This apparent paradox, and its resolution, have been known since at least the time of Stokes [1857].'
'The explanation given by Stokes is that this effect is produced by wind shear, the variability in the wind speed as a function of height.'

'This gives rise to refraction, causing sound rays to bend away from the ground in the upwind direction and towards the ground in the downwind direction.'

Select Committee on Wind TurbinesSubmission 193 - Attachment 1 Three validation studies on extended application of ISO 9613-2 to wind turbine noise prediction 1.
Bass J H, Bullmore A J, Sloth E, EU Joule Project Final Report (1998): 'Development of a Wind farm Noise Propagation Prediction Model' Gibbons & Warnick include the following historical references: [1] G. G. Stokes, "On the Effect of Wind on the Intensity of Sound," Report of the British Association, Dublin, 1857 [2] 0 .

Reynolds, "On the Refraction of Sound by the Atmosphere," Proc.

Roy.

Soc.

22 (1874) [3] J. W. S. Rayleigh, "The Theory of Sound", Macmillan (1986) §289, Vol 2.
Select Committee on Wind TurbinesSubmission 193 - Attachment 1 Three validation studies on extended application of ISO 9613-2 to wind turbine noise prediction 1.
Bass J H, Bullmore A J, Sloth E, EU Joule Project Final Report (1998): 'Development of a Wind farm Noise Propagation Prediction Model' The 3 authors cited by Gibbons and Warnick were leading 19th century scientists: Sir George Stokes was Professor of Mathematics at Cambridge and the future President of the Roya I Society Osborne Reynolds was another future member of the Royal Society Lord Rayleigh was another future President of the Royal Society and Nobel prize winner; he put the effect of wind shear on a more quantitative basis in 1894, in his founding work in the development of acoustics, 'The Theory of Sound'; this book was reprinted as recently as 1986 and is specifically recognised today as a 'landmark text' by the Institute of Acoustics, via the citation to their premier award for outstanding contributions to acoustics, the Rayleigh Medal Select Committee on Wind TurbinesSubmission 193 - Attachment 1 Section 9 ISO 9613-2 – Validation Studies on Extended Application to Wind Turbine Noise Prediction - Study 2 Select Committee on Wind TurbinesSubmission 193 - Attachment 1 Three validation studies on extended application of ISO 9613-2 to wind turbine noise prediction 2.
Bull more A J, Adcock J, Jiggins M, Cand M, Proc.

Wind Turbine Noise 2009 Conference, Aalborg Denmark, June 2009, 'Wind Farm Noise Predictions and Comparison with Measurements' This subsequent study was published 11 years after ref (viii) above.
It makes explicit reference to the earlier study and its conclusions, with no critical comment whatsoever This later study again: fails to specifically identify wind shear as a key variable in the mechanism of long range noise propagation contains no measurements of wind shear or discussion of its crucial role in this respect The study makes only one specific reference to wind shear, but only regarding differences in wind speed between hub height and standard reference height (p3, para3) Select Committee on Wind TurbinesSubmission 193 - Attachment 1 Three validation studies on extended application of ISO 9613-2 to wind turbine noise prediction 2.
Bull more A J, Adcock J, Jiggins M, Cand M, Proc.

Wind Turbine Noise 2009 Conference, Aalborg Denmark, June 2009, 'Wind Farm Noise Predictions and Comparison with Measurements' This subsequent study was published 11 years after ref (viii) above.
It is crucial to record vertical atmospheric wind shear conditions during noise measurements, in order to judge applicability to other situations - daily variation in wind shear might, or might not, have been substantial This information is not available - only horizontal variations in hub-height wind speed are stated between individual turbines withi n a wind farm Select Committee on Wind TurbinesSubmission 193 - Attachment 1 Three validation studies on extended application of ISO 9613-2 to wind turbine noise prediction 2.
Bull more A J, Adcock J, Jiggins M, Cand M, Proc.

Wind Turbine Noise 2009 Conference, Aalborg Denmark, June 2009, 'Wind Farm Noise Predictions and Comparison with Measurements' This subsequent study was published 11 years after ref (viii) above.
The study provides no specific validation evidence to support extended application of ISO 9613 to wind turbines with a turbulent incident airstream meteorological conditions, or wake effects from other turbines, could create such turbulent airstreams there is no reason why ISO 9613-2 predictions should be at all accurate in these cases Select Committee on Wind TurbinesSubmission 193 - Attachment 1 Section 9 ISO 9613-2 – Validation Studies on Extended Application to Wind Turbine Noise Prediction - Study 3 Select Committee on Wind TurbinesSubmission 193 - Attachment 1 Three validation studies on extended application of ISO 9613-2 to wind turbine noise prediction 3.
Evans T and Cooper J, Proc.

Acoustics 2011 Conference, Gold Coast Australia November 2011, /Comparison of predicted and measured wind farm noise levels and implications for assessments of new wind farms' This most recent study was published 13 years after ref (viii) above.
It identifies the studies of references (v) and (viii) above as 1key investigations', and gives a totally non-critical summary of their conclusions This most recent study again: fails to identify the crucial role of wind shear in determining the propagation path and intensity of outdoor sound fails to report any measurements of atmospheric wind shear pertaining at the time of the downwind noise measurements Select Committee on Wind TurbinesSubmission 193 - Attachment 1 Three validation studies on extended application of ISO 9613-2 to wind turbine noise prediction 3.
Evans T and Cooper J, Proc.

Acoustics 2011 Conference, Gold Coast Australia November 2011, /Comparison of predicted and measured wind farm noise levels and implications for assessments of new wind farms' This most recent study was published 13 years after ref (viii) above.
Again, the study provides no specific validation evidence to support extended application of ISO 9613 to wind turbines with a turbulent incident airstream meteorological conditions, or wake effects from other turbines, could create such turbulent airstreams there is no reason why ISO 9613-2 predictions should be at all accurate in these cases Select Committee on Wind TurbinesSubmission 193 - Attachment 1 Three validation studies on extended application of ISO 9613-2 to wind turbine noise prediction 3.
Evans T and Cooper J, Proc.
Acoustics 2011 Conference, Gold Coast Australia November 2011, /Comparison of predicted and measured wind farm noise levels and implications for assessments of new wind farms' The results of this study could mislead if simply taken at face value: ISO 9613-2 predictions employ the LAeq noise metric Measured noise levels employ the LA90, 10 min metric comparisons are presented between them, in which one appears to have been directly subtracted from the other In order to compare 11ike with like' a correction has to be applied to the data : ETSU-R-97 recommends subtraction of between 1.5 and 2.5 dB from LAeq values to yie ld a reasonable estimate of LA90,10 min levels for wind farm noise Select Committee on Wind TurbinesSubmission 193 - Attachment 1 Three validation studies on extended application of ISO 9613-2 to wind turbine noise prediction 3.
Evans T and Cooper J, Proc.
Acoustics 2011 Conference, Gold Coast Australia November 2011, /Comparison of predicted and measured wind farm noise levels and implications for assessments of new wind farms' The results of this study could mislead if simply taken at face value: Applying the ETSU-recommended correction: In 8 out of the 10 cases considered in this study/ ISO 9613-2 underpredicts wind turbine LA90 noise levels any concavity in the ground profile renders this underprediction significantly more severe (the above assumes the standard ISO input parameter of G = 0.5 for propagation over mixed ground) Select Committee on Wind TurbinesSubmission 193 - Attachment 1 Section 9 ISO 9613-2 – Validation Studies on Extended Application to Wind Turbine Noise Prediction - Conclusions Select Committee on Wind TurbinesSubmission 193 - Attachment 1 Three validation studies on extended application of ISO 9613-2 to wind turbine noise prediction 1.
Bass J H, Bull more A J, Sloth E, EU Joule Project Final Report (1998): 'Development of a Wind farm Noise Propagation Prediction Model' 2.

Bullmore A J, Adcock J, Jiggins M, Cand M, Proc.

Wind Turbine Noise 2009 Conference, Aalborg Denmark, June 2009, 'Wind Farm Noise Predictions and Comparison with Measurements' 3.

Evans T and Cooper J, Proc.
Acoustics 2011 Conference, Gold Coast Australia November 2011, 'Comparison of predicted and measured wind farm noise levels and implications for assessments of new wind farms' References (v), (vii) and (viii) of loA Draft Guidelines All 3 of these studies appear scientifically unsound and none of them have been published in a peer-reviewed journal They do not appear appropriate as fundamental references for DECC and loA-endorsed National UK Guidelines on the application of ETSU R 97 Select Committee on Wind TurbinesSubmission 193 - Attachment 1