HomeMy WebLinkAboutCOM 0825.058 2010-2012 Page 1 of 6
Murashige, Laura
From: Suzanne Wakelin [malamatree @gmail.com]
Sent: Wednesday, October 31, 2012 9:42 PM 7- 1 9: .?3
To: counciltestimony @co.hawaii.hi.us
Subject: Public Testimony, Bill 292, November 2, 2012
Attachments: Geo Drilling Noise and PGV Permitting Issues Oct2012.pdf
Aloha Council Members,
I am writing to submit my testimony in support of Bill 292. It summarizes some of the health and
permit issues for drilling. It includes some of the testimony I have submitted previously as well
as some additional testimony. I live a mile from PGV. When they drill it is extremely disturbing.
As this Bill has been gaining publicity in recent weeks we have been hearing from the
commercial interests that have concerns about Bill 292 infringing on their rights to make money.
Thank you for making the health and welfare of Hawai'i County residents a priority by passing
this Bill to protect us from night-time drilling.
Mahalo,
Suzanne Wakelin
Please note that a formatted PDF containing the text below is included as an attachment to this
email
Geothermal Drilling Noise and PGV Permitting Issues
Suzanne Wakelin, PhD.
October 23rd, 2012
1. Hawai'i County Geothermal Noise Studies identified noise as an issue that needs
addressing: The County of Hawaii and UH published two in-depth studies specifically to
address noise from geothermal activities in Hawaii:
"Potential Noise Issues with Geothermal Development in Hawaii" John Burgess,
University of Hawai'i, 1980. This study examined expected noise levels for construction
and (normal and upset) operations at HGP-A, including climate, weather patterns &
topography and makes approximate predictions of sound propagation and attenuation
based on noise characteristics and environmental conditions. The report developed
expected response of community to noise and expectation of"annoyance levels" due to
noise levels based on local population density and location. It was identified that although
no current(1980) legal limits to noise emissions from operations of the HGP-A,Hawaii
County has the statutory authority to develop and enforce noise regulations
The subsequent study "Geothermal Noise Level Guidelines" carried out for the County of
Hawai'i Planning Department in 1981 refers to UH 1980 Burgess study. It was the Hawaii
County response to complaints received from residents of the Puna District concerning
geothermal drilling operations. Based on this, the Planning Department developed
guidelines to determine acceptable noise levels for both geothermal exploration and
production. The acceptable noise levels for geothermal development are as follows: That a
general noise level of 55 dBA during daytime and 45 dBA at night not be exceeded. For
Comm. No. 3C2-"
11/1/2012 Ref. To:
Ref. Dote
Page 2 of 6
the purposes of these guidelines, night is defined as the hours between 7:00 p.m. and 7:00 a.m.
Despite these recommendations, Hawai'i County has as far as we are aware, not implemented any
except for the condition for BACT in the GRP-2, which has considerable leeway in the permitted
"exceedances".
2. Hawai'i County Planning Commission Geothermal Resource Permit has much to say about
noise but does little to protect residents and is inconsistent with its own rule (Rule 11-8) to
protect the welfare of residents: Comments on the Geothermal Resource Permit (GRP-2) issued
by County of Hawaii Planning Commission to PGV on 2/6/2001
a. The introductory narrative to GRP-2 as amended February 6, 2001, says on page 2 that the
"primary reason for the amendments is to incorporate regulatory standards and permit
requirements that have been promulgated and issued since the permit was originally
approved in 1989. of the 21 amendments requested, the majority (12) are necessary to
incorporate current regulatory standards..." Several of the amended conditions pertain to
noise, and an extensive portion of the introductory narrative pertains to noise.
If PGV contends their permit is somehow etched in stone as to noise, that contention is
belied by the precedent of the 2001 amendment deemed "necessary to incorporate current
regulatory standards." The county noise ordinance would be such a new or current
regulatory noise standard, and according to precedent PGV's permit again could be amended
to incorporate its requirements.
b. The description provided by PGV to Con Planning in 1989 in application amendment to the
GRP addresses the requirement for description of impacts to public health and safety by
saying that drilling noise levels at residential receptors are predicted to range between 45-
51dBA from wellpads B, E & F and"All other well drilling noise levels were expected to be
less than 45 dBA at the nearest resident receptors. " During the recent drilling of KS-15, at
Well Pad B, PGV measurement data for both noise receptors shows that they have
significantly underestimated these noise levels.
c. DoH regulations adopted in 1996 apply to allow the permittee to emit up to 70dBA, 24 hours
per day because it is located in agriculturally zoned land. On issuing the GRP-2 permit,
Hawaii County Planning Commission wrote "This is unreasonably loud and the Planning
Commission believes that nearby residents are justified in seeking a stricter standard. It is
also understandable that they did not expect that noise standards would be so drastically
relaxed, after the permittee made representations that the noise levels would not exceed
55/45 dBA."
d. Condition 20 of the GRP-2 states that "Best Available Control Technology (BACT) must be
employed for noise emissions to all aspects of the project to minimize noise", which means
that noise reduction measures must be implemented unless the facility substantially complies
with residential noise standards. "The permittee substantially complies with the (BACT)
standards if
a. The average hourly noise levels do not exceed 55dBA during the day (7.00a.m. To
10.00p.m.) and 45dBA at night (10.00p.m. To 7.OOa.m.) more than 10%of the time with the
day and night hours separately considered, and
b. During hours when the noise levels are exceeded, the average exceedance is not more
than 5dBA, and the average hourly noise level never exceeds 60dBA days and 55dBA nights.
Periods of steam pipeline cleanout, construction, well drilling, and highly unusual events
shall be excluded and the standard adjustments referred to above shall apply."
With the additional average exceedances detailed in the permit, the night time violation of
the BACT condition for example for the month of April 2012 (during drilling) is 89% and
for April 2011 is 27% calculated from PGV measurement data.
11/1/2012
Page 3 of 6
e. Condition 22 of the GRP-2 states that"The permittee shall report average noise levels for
each hour, and shall report a daily average and a monthly average. Except as allowed
below:
a. The average for any month shall not exceed 54dBA
b. The average for any day shall not exceed 57dBA
c. The average for any hour shall not exceed 62dBA
d. The average for any 5 minute period shall not exceed 68dBA
The allowable noise levels may be exceeded, at each monitoring station, by no
more than 3dBA for the following periods:five months per year for the monthly
average;five days per month for the daily average; and five hours per month for
the hourly average.
During specified steam pipeline cleanout periods, construction and testing of wells.
BACT should be applied and the allowed noise levels may be exceeded by no more
than 5dBA. During specified periods of drilling, the permittee shall comply with the
Department of Health noise rules and permit requirements"
The rules outlined above are so complicated that there is no protection for the public and
neighboring residences provided by this permit and apparently during times of drilling, GRP-
2 does not provide any control either.
e. The Geothermal Resource Permit (GRP-2) issued by Hawaii County Planning Commission
on 2/6/2001 is granted such that"The proposed geothermal development activities would not
have unreasonable adverse health, environmental, or socio-economic effects on residents or
the surrounding property" (Rule 11-8) It is clear to anyone who is subjected to day and
night-time drilling for months at a time that residents are adversely affected in terms of their
environment and health. Detrimental socio-economic effects are also inflicted in that
residents cannot enjoy benefit of living at their property without the untenable noise of 24/7
drilling and would be unable to sell their property for its full value should they with to move.
3. Other PGV permits would require that a County Noise Ordinance to protect the welfare of
the public must be complied with:
a. The Plan of Operation Approval on 1/13/2006 from the Board of Land and Natural
Resources (BLNR) is subject to the condition: ..."That Puna Geothermal Venture comply
with all applicable statutes, ordinances, rules and regulations of the Federal, State, and
County governments"
b. The Department of Land and Natural Resources (DLNR) Rule 13-7 Chapter 183 Rules on
leasing and drilling of geothermal resources, §13-183-87 Drilling: "Protection of the
environment includes responsibility of the operator of any well to comply with all applicable
federal, state, and local standards with respect to air, land, water, and noise pollution, and
the disposal of liquid, solid, and gaseous effluent. "
c. Hawaii DoH Environmental Management Division,Non-covered Source Permit 0008-02-N
issued 12/15/2009 Attachment I, Standard Conditions: "...(6) This permit does not release
the permittee from compliance with other applicable statutes of the State of Hawaii, or with
applicable local laws, regulations, or ordinances"
11/1/2012
Page 4 of 6
d. Condition 15 of the Geothermal Resource Permit (GRP-2) issued by County of Hawai'i
Planning Commission to PGV on 2/6/2001 states that"..the permittee shall secure the
approval of the State Department of Health Clean Air Branch and shall comply with all NSP
requirements and standards."
e. The NSP document to which the GRP-2 refers is the Hawai'i DoH Environmental
Management Division,Non-covered Source Permit 0008-02-N issued 12/15/2009
Attachment I, Standard Conditions"...(6) This permit does not release the permittee from
compliance with other applicable statutes of the State of Hawai'i, or with applicable local
laws, regulations, or ordinances"
4. PGV's extended period of KS-15 2012 drilling i may be out of complience with drilling
permits issued by DLNR: The DLNR issued PGVs geothermal well drilling permit for KS-15 on
May 31st,2011, valid for a period of 365 days. PGV continued to drill until early July 2012, over a
month later than that permit expired. We do not know whether they actually had a permit from
DLNR to cover the entire period in which their drilling was carried out.
In addition, in May 7th 2012, Hawai'i Department of Health granted a Variance to PGV which
permitted them to make "excessive noise"while conducting geothermal well drilling until June
30th 2012. We do not know whether they actually had a permit from DoH to cover the entire period
in which their drilling was carried out either.
5. Hawai'i State Noise Control rules provide for additional ordinances issued by the County for
the protection of the public: Hawai'i Department of Health Administrative Rules - Title 11,
Chapter 46 Community Noise Control provides the State noise level rules that the GRP-2 permit
refers to:
§11-46-4 Maximum permissible noise levels on C zoned areas is 70dBA, during both day or night.
However, it also states:
§11-46-13 Other ordinances and rules: The council of any county may adopt and provide for the
enforcement of ordinances regulating any matter relating to excessive noise. No ordinance shall be
held invalid on the ground that it covers any subject or rule of the State; provided that in any case
of conflict between the statute or rule and ordinance, the law which affords the most protection to
the public shall apply.
6. Noise zoning in Hawai'i is supposed to protect public health and welfare: The zoning of land
leased by PGV and the surrounding areas is Class C, which according to Hawai'i Administrative
Rules Chapter 46 "Community Noise Control" includes"all areas equivalent to lands zoned
agriculture, country, industrial, or similar type". That same document states as its purpose
(Paragraph 11-46-1) "It is the purpose of this chapter to define the maximum permissible sound
levels, and to provide for the prevention, control, and abatement of noise pollution in the State
from the following excessive noise sources: stationary noise sources; and equipment related to
agricultural, construction, and industrial activities. It is also the purpose of this chapter to
establish noise quality standards to protect public health and welfare, and to prevent the
significant degradation of the environment and quality of life"
and..."Maximum permissible noise levels on C zoned areas is 70dBA, during both day or night".
The rule for"A zoned"residential areas is 55dBA during day and 45dBA at night. The area where
PGV is located is largely residential and the industrial facility is not consistent with either
residential or agricultural use. Geothermal drilling noise significantly degrades the environment
and quality of life for the neighboring residents.
11/1/2012
Page 5 of 6
7. "A weighted" noise measurement does not address a significant component of the noise
emitted from geothermal power generation and does not protect the public: A large part of the
noise coming from the drilling activities and the cooling fans in normal operation is low frequency
noise, which propagates through the atmosphere with less attenuation than higher frequency noise.
Neighbors to the plant, both near and far are subjected to it and although auditory hearing is less
sensitive to those low frequencies, we still feel it in our bodies, it keeps us awake, raises stress
levels and is an ongoing nuisance. Another issue that can cause extreme discomfort for those
neighbors is the fact that the frequency range of low-frequency noise corresponds to wavelengths
that may match and resonate with building structures and even our physical body parts. These
resonances can be every disturbing, even though the sound waves are not within the audible
spectrum. Drilling in particular is a noise source that can cause considerable aggravation,
annoyance and disturbance in our local environment. "A weighting" or"dBA"reduces the low
frequency components of the measured spectrum by up to 70dB. "C weighting" (dBC)provides
spectrum measurement that includes both low frequency components as well as audible
components.
From the World Health Organization Guidelines for Community Noise (p68)
"The evidence on low frequency noise is sufficiently strong to warrant immediate concern"
"Health effects due to low frequency components in noise are estimated to be more severe than for
community noises in general"
"A"weighting underestimates the sound pressure level of low frequency components"
Noise weighting filters are used to emphasise or suppress some aspects of a phenomenon
compared to others, for measurement or other purposes. Noise regulations must be defined in such
a way that they actually serve to protect the public and quality of the environment. The
appropriate noise weighting filter for industrial noise measurement is C-weighting so as not to
suppress the contribution made from low-frequency noise.
+20
+10
(C)
-10 (8. )
alt(. -20 (I))
-30 (A) (not donned)
(8)
-40
-50
10 100 1000 10k 100k
A-watgtating(tale),B(yellow),C 0a4 and D w fighting(elk)
11/1/2012
Page 6 of 6
Noise weighting curves show that A-weighing attenuation of frequencies less than 1000Hz
References
Geothermal Resource Permit(GRP-2) issued by Hawaii Couny Planning Commission, 2001
Application Amendment for the Puna Geothermal Project, 1989
http://scholarspace.manoa.hawaii.edu/handle/10524/23421
Hawai'i Administrative Rules, Chapter 46, Community Noise Control
http://gen.doh.hawaii.gov/sites/har/AdmRules1/11-46.pdf
"Potential Noise Issues with Geothermal Development in Hawaii" John Burgess, University of Hawai'i,
1980 http://scholarspace.manoa.hawaii.edu/bitstream/handle/10125/21521/6246293.pdf?sequence=1
"Geothermal Noise Level Guidelines" County of Hawai'i Planning Department, 1981
http://www.gpo.gov/fdsys/pkg/CZIC-gb 1199-7-h3-g46-1981/html/CZIC-gb 1199-7-h3-g46-1981.htm
PGV Plan Operation Approval issued by BLNR/DLNR, 2006
Department of Land and Natural Resources Rule 13-7 Chapter 183 Rules on leasing and drilling of
geothermal resources http://hawaii.gov/dIneland/administrative-rules/CHAP183.pdf
Hawai'i DoH PGV Noncovered Source Permit, 2009, Attachment 1, Standard Conditions
World Health Organization"Fundamentals of Acoustics"
http://www.who.int/occupational health/publications/noisel.pdf
World Health Organization"Guidelines for community noise"
http://www.who.int/docstore/peh/noise/guidelines2.html
11/1/2012
Geothermal Drilling Noise and PGV Permitting Issues
Suzanne Wakelin, PhD.
October 23`d, 2012
1. Hawai'i County Geothermal Noise Studies identified noise as an issue that needs
addressing: The County of Hawai'i and UH published two in-depth studies specifically to
address noise from geothermal activities in Hawai'i:
"Potential Noise Issues with Geothermal Development in Hawaii" John Burgess, University of
Hawai'i, 1980. This study examined expected noise levels for construction and (normal and
upset) operations at HGP-A, including climate, weather patterns & topography and makes
approximate predictions of sound propagation and attenuation based on noise characteristics
and environmental conditions. The report developed expected response of community to noise
and expectation of"annoyance levels" due to noise levels based on local population density and
location. It was identified that although no current(1980) legal limits to noise emissions from
operations of the HGP-A,Ha wai'i County has the statutory authority to develop and enforce_
noise regulations
The subsequent study "Geothermal Noise Level Guidelines" carried out for the County of
Hawai'i Planning Department in 1981 refers to UH 1980 Burgess study. It was the Hawaii
County response to complaints received from residents of the Puna District concerning
geothermal drilling operations. Based on this,the Planning Department developed guidelines to
determine acceptable noise levels for both geothermal exploration and production. The
acceptable noise levels for geothermal development are as follows: That a general noise level of
55 dBA during daytime and 45 dBA at night not be exceeded. For the purposes of these
guidelines, night is defined as the hours between 7:00 p.m. and 7:00 a.m. Despite these
recommendations, Hawai'i County has as far as we are aware, not implemented any except for
the condition for BACT in the GRP-2, which has considerable leeway in the permitted
"exceedances".
2. Hawai'i County Planning Commission Geothermal Resource Permit has much to say
about noise but does little to protect residents and is inconsistent with its own rule (Rule
11-8) to protect the welfare of residents: Comments on the Geothermal Resource Permit
(GRP-2) issued by County of Hawaii Planning Commission to PGV on 2/6/2001
a) The introductory narrative to GRP-2 as amended February 6, 2001, says on page 2 that
the "primary reason.*the amendments is to incorporate regulatory standards and
permit requirements that have been promulgated and issued since the permit was
originally approved in 1989. Of the 21 amendments requested, the majority (12) are
necessary to incorporate current regulatory standards..." Several of the amended
conditions pertain to noise, and an extensive portion of the introductory narrative
pertains to noise.
If PGV contends their permit is somehow etched in stone as to noise, that contention is
belied by the precedent of the 2001 amendment deemed "necessary to incorporate
current regulatory standards." The county noise ordinance would be such a new or
current regulatory noise standard, and according to precedent PGV's permit again could
be amended to incorporate its requirements.
b) The description provided by PGV to CoH Planning in 1989 in application amendment to
the GRP addresses the requirement for description of impacts to public health and safety
by saying that drilling noise levels at residential receptors are predicted to range between
45-51 dBA from wellpads B, E& F and "All other well drilling noise levels were
expected to be less than 45 dBA at the nearest resident receptors. " During the recent
1 of 5
drilling of KS-15, at Well Pad B, PGV measurement data for both noise receptors
shows that they have significantly underestimated these noise levels.
c) DoH regulations adopted in 1996 apply to allow the permittee to emit up to 70dBA, 24
hours per day because it is located in agriculturally zoned land. On issuing the GRP-2
permit, Hawaii County Planning Commission wrote "This is unreasonably loud and
the Planning Commission believes that nearby residents are justified in seeking a
stricter standard. It is also understandable that they did not expect that noise
standards would be so drastically relaxed, after the permittee made representations
that the noise levels would not exceed 55/45 dBA."
d) Condition 20 of the GRP-2 states that"Best Available Control Technology (BACT) must
be employed for noise emissions to all aspects of the project to minimize noise", which
means that noise reduction measures must be implemented unless the facility
substantially complies with residential noise standards. "The permittee substantially
complies with the (BACT) standards if:
a. The average hourly noise levels do not exceed 55dBA during the day
(7.00a.m. To 10.00p.m.) and 45dBA at night (10.00p.m. To 7.00a.m.) more than
10%of the time with the day and night hours separately considered, and
b. During hours when the noise levels are exceeded, the average
exceedance is not more than 5dBA, and the average hourly noise level never
exceeds 60dBA days and 55dBA nights. Periods of steam pipeline cleanout,
construction, well drilling, and highly unusual events shall be excluded and the
standard adjustments referred to above shall apply."
With the additional average exceedances detailed in the permit, the night time violation
of the BACT condition for example for the month of April 2012 (during drilling) is 89%
and for April 2011 is 27% calculated from PGV measurement data.
e) Condition 22 of the GRP-2 states that"The permittee shall report average noise levels
for each hour, and shall report a daily average and a monthly average. Except as
allowed below:
a. The average for any month shall not exceed 54dBA
b. The average for any day shall not exceed 57dBA
c. The average for any hour shall not exceed 62dBA
d. The average for any 5 minute period shall not exceed 68dBA
The allowable noise levels may be exceeded, at each monitoring station, by no more
than 3dBA for the following periods:five months per year for the monthly
average;five days per month for the daily average; and five hours per month for
the hourly average.
During specified steam pipeline cleanout periods, construction and testing of wells.
BACT should be applied and the allowed noise levels may be exceeded by no
more than 5dBA. During specified periods of drilling, the permittee shall comply
with the Department of Health noise rules and permit requirements"
The rules outlined above are so complicated that there is no protection for the public
and neighboring residences provided by this permit and apparently during times of
drilling, GRP-2 does not provide any control either.
0 The Geothermal Resource Permit(GRP-2) issued by Hawaii County Planning
Commission on 2/6/2001 is granted such that"The proposed geothermal development
activities would not have unreasonable adverse health, environmental, or socio-
economic effects on residents or the surrounding property" (Rule 11-8)It is clear to
2 of 5
anyone who is subjected to day and night-time drilling for months at a time that
residents are adversely affected in terms of their environment and health. Detrimental
socio-economic effects are also inflicted in that residents cannot enjoy benefit of living
at their property without the untenable noise of 24/7 drilling and would be unable to sell
their property for its full value should they with to move.
3. Other PGV permits would require that a County Noise Ordinance to protect the welfare
of the public must be complied with:
a) The Plan of Operation Approval on 1/13/2006 from the Board of Land and Natural
Resources (BLNR) is subject to the condition: ..."That Puna Geothermal Venture
comply with all applicable statutes, ordinances, rules and regulations of the Federal,
State, and County governments"
b) The Department of Land and Natural Resources (DLNR) Rule 13-7 Chapter 183 Rules
on leasing and drilling of geothermal resources, §13-183-87 Drilling: "Protection of the
environment includes responsibility of the operator of any well to comply with all
applicable federal, state, and local standards with respect to air, land, water, and noise
pollution, and the disposal of liquid, solid, and gaseous effluent. "
c) Hawaii DoH Environmental Management Division,Non-covered Source Permit 0008-
02-N issued 12/15/2009 Attachment I, Standard Conditions: "...(6) This permit does not
release the permittee from compliance with other applicable statutes of the State of
Hawaii, or with applicable local laws, regulations, or ordinances"
d) Condition 15 of the Geothermal Resource Permit(GRP-2) issued by County of Hawaii
Planning Commission to PGV on 2/6/2001 states that"..the permittee shall secure the
approval of the State Department of Health Clean Air Branch and shall comply with all
NSP requirements and standards."
e) The NSP document to which the GRP-2 refers is the Hawai'i DoH Environmental
Management Division,Non-covered Source Permit 0008-02-N issued 12/15/2009
Attachment I, Standard Conditions"...(6) This permit does not release the permittee from
compliance with other applicable statutes of the State of Hawaii, or with applicable
local laws, regulations, or ordinances"
4. PGV's extended period of KS-15n 2012 drilling i may be out of complience with drilling
permits issued by DLNR: The DLNR issued PGVs geothermal well drilling permit for KS-15
on May 31",2011, valid for a period of 365 days. PGV continued to drill until early July 2012,
over a month later than that permit expired. We do not know whether they actually had a permit
from DLNR to cover the entire period in which their drilling was carried out.
In addition, in May 7th 2012, Hawai'i Department of Health granted a Variance to PGV which
permitted them to make "excessive noise"while conducting geothermal well drilling until June
30th 2012. We do not know whether they actually had a permit from DoH to cover the entire
period in which their drilling was carried out either.
5. Hawai'i State Noise Control rules provide for additional ordinances issued by the County
for the protection of the public: Hawaii Department of Health Administrative Rules -Title 11,
Chapter 46 Community Noise Control provides the State noise level rules that the GRP-2
permit refers to:
§11-46-4 Maximum permissible noise levels on C zoned areas is 70dBA, during both day or
night. However, it also states:
3 of 5
§11-46-13 Other ordinances and rules: The council of any county may adopt and provide for the
enforcement of ordinances regulating any matter relating to excessive noise. No ordinance shall
be held invalid on the ground that it covers any subject or rule of the State; provided that in any
case of conflict between the statute or rule and ordinance, the law which affords the most
protection to the public shall apply.
6. Noise zoning in Hawai'i is supposed to protect public health and welfare: The zoning of
land leased by PGV and the surrounding areas is Class C, which according to Hawaii
Administrative Rules Chapter 46 "Community Noise Control" includes "all areas equivalent to
lands zoned agriculture, country, industrial, or similar type". That same document states as its
purpose (Paragraph 11-46-1) "It is the purpose of this chapter to define the maximum
permissible sound levels, and to provide for the prevention, control, and abatement of noise
pollution in the State from the following excessive noise sources: stationary noise sources; and
equipment related to agricultural, construction, and industrial activities. It is also the purpose
of this chapter to establish noise quality standards to protect public health and welfare, and to
prevent the significant degradation of the environment and quality of life"
and..."Maximum permissible noise levels on C zoned areas is 70dBA, during both day or
night". The rule for"A zoned" residential areas is 55dBA during day and 45dBA at night. The
area where PGV is located is largely residential and the industrial facility is not consistent with
either residential or agricultural use. Geothermal drilling noise significantly degrades the
environment and quality of life for the neighboring residents.
7. "A weighted" noise measurement does not address a significant component of the noise
emitted from geothermal power generation and does not protect the public: A large part of
the noise coming from the drilling activities and the cooling fans in normal operation is low
frequency noise, which propagates through the atmosphere with less attenuation than higher
frequency noise. Neighbors to the plant, both near and far are subjected to it and although
auditory hearing is less sensitive to those low frequencies, we still feel it in our bodies, it keeps
us awake, raises stress levels and is an ongoing nuisance. Another issue that can cause extreme
discomfort for those neighbors is the fact that the frequency range of low-frequency noise
corresponds to wavelengths that may match and resonate with building structures and even our
physical body parts. These resonances can be every disturbing, even though the sound waves
are not within the audible spectrum. Drilling in particular is a noise source that can cause
considerable aggravation, annoyance and disturbance in our local environment. "A weighting"
or"dBA" reduces the low frequency components of the measured spectrum by up to 70dB. "C
weighting" (dBC) provides spectrum measurement that includes both low frequency
components as well as audible components.
From the World Health Organization Guidelines for Community Noise (p68)
"The evidence on low frequency noise is sufficiently strong to warrant immediate concern"
"Health effects due to low frequency components in noise are estimated to be more severe than
for community noises in general"
"A"weighting underestimates the sound pressure level of low frequency components"
Noise weighting filters are used to emphasise or suppress some aspects of a phenomenon
compared to others, for measurement or other purposes. Noise regulations must be defined in
such a way that they actually serve to protect the public and quality of the environment. The
appropriate noise weighting filter for industrial noise measurement is C-weighting so as not to
suppress the contribution made from low-frequency noise.
4 of 5
+20
+10
(0)
(C)
-10 (B,C)
8 -20 (D) •
•
-30 (A) (not defined).;
(B)
-40 •
-50
10 100 1000 10k 100k
A-weighting (blue),B (yellow), C(red), and 0-weighting(bik)
Noise weighting curves show that A-weighing attenuation of frequencies less than 1000Hz
References
Geothermal Resource Permit(GRP-2) issued by Hawaii Couny Planning Commission,2001
Application Amendment for the Puna Geothermal Project, 1989
http://scholarspace.manoa.hawaii.edu/handle/10524/23421
Hawaii Administrative Rules,Chapter 46,Community Noise Control
http://gen.doh.hawaii.gov/sites/har/AdmRules1/11-46.pdf
"Potential Noise Issues with Geothermal Development in Hawai'i"John Burgess,University of Hawai'i, 1980
http://scholarspace.manoa.hawaii.edu/bitstream/handle/10 l 25/21521/6246293.pdf?sequence=1
"Geothermal Noise Level Guidelines"County of Hawaii Planning Department, 1981
http://www.gpo.gov/fdsys/pkg/CZIC-gb1199-7-h3-g46-1981/html/CZIC-gb1199-7-h3-g46-1981.htm
PGV Plan Operation Approval issued by BLNR/DLNR,2006
Department of Land and Natural Resources Rule 13-7 Chapter 183 Rules on leasing and drilling of geothermal
resources http://hawaii.gov/dlnr/land/administrative-rules/CHAP183.pdf
Hawaii DoH PGV Noncovered Source Permit,2009,Attachment 1, Standard Conditions
World Health Organization"Fundamentals ofAcoustics"
http://www.whoint/occupational_healthipublications/noisel.pdf
World Health Organization"Guidelines for community noise"
http://www.who.int/docstore/peh/noise/guidelines2.html
5 of 5