Consultation Responses

15 February 2013 – DCLG Consultation on the Review of Government Planning Practice Guidance

While the NAS believes that there is a need for up to date guidance on noise we also advise that such guidance includes provision for and/or takes into account the following recommendations:

A. The strengthening of building regulations relating to noise pollution to create a single, national standard for the design and construction of homes and to improve acoustic protection in buildings, following a review of standards in comparable northern European countries.

B. Allowance for local authorities to refuse planning permission where noise in the completed development would be deemed to be excessive and cannot be cost effectively reduced.  New noise sensitive developments should not be created in places where occupants would be likely to resort to legal action against established economic activities which are otherwise acceptable.

C. The Code for Sustainable Homes should be updated, with noise protection included as one of the measures for sustainable building design, reflecting the importance of quiet buildings to the health and wellbeing of the occupiers.

D. Planning Policy should enable and encourage local communities to create and protect tranquil spaces and green squares and empower planners to consider the availability of conveniently located tranquil spaces when granting planning permission for homes in noisy environments.

E. The establishment of development zones, as part of the Code for Sustainable Homes, that create and maintain sufficient acoustic separation between residential and other noise sensitive uses, and noise generators (such as commercial and enterprise zones). This zoning should guide planning application considerations and allow residential and commercial (and other noise generating areas) to function successfully and cost effectively. Local authorities should be empowered to ensure that the economic, social and cultural benefits of land use mixing are secured without creating noise disturbance.

F.Government policy should encourage local authorities and third sector partners to test innovative approaches to tackling intractable local noise and soundscape problems, such as in the White Night West Street Story project designed and run jointly by the Noise Abatement Society and Brighton & Hove City Council; including through targeted funding for pilot projects covering noise prevention and other beneficial outcomes such as crime prevention and enhancing the urban environment.

G. The Government should establish a cross-sector, inter-disciplinary acoustic, academic, NGO and property industry task force to provide greater assistance to minimise the health effects of Low Frequency Noise, establish the impact this has on people and create a maximum exposure limit for householders. The task-force should be mandated to recommend updates to building regulations to protect residents in their homes from unnecessary noise disturbance.

H. The Government should strengthen building standards for schools to better address the impact of poor acoustics on educational attainment, building on the extensive research that has been conducted into this problem. These guidelines should set stricter minimum acoustic protection levels and lower maximum allowable noise levels for class rooms that should be followed by developers and architects when designing new schools, universities and colleges (and extensions to existing facilities) to create better learning environments.

I. The Government should introduce a new funding programme, to tackle poor noise insulation, which creates acute distress leading to neighbour conflicts in parts of the UK’s existing housing stock, in partnership with private sector funding and within the auspices of the ECO home improvement programme and the Code for Sustainable Homes. This would be complementary to the aims of the Green Deal and could be achieved at no additional cost using insulation that provides both acoustic and thermal properties.

 

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11 January 2013 – Consultation response to the Health Protection Agency workplan on noise and health

NAS’ detailed comments focus on the individual objectives of section 7. Examining gaps and options for HPA work. The Noise Abatement Society welcomes the opportunity to comment on this consultation, and the commitment of the Health Protection Agency to stepping up to the responsibility for developing a programme of work to address the impact of neighbourhood and environmental noise on public health.

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7 January 2013- DCLG Consultation on Nationally Significant Infrastructure Planning: extending the regime to business and commercial projects

NAS do not believe the proposed accelerated process will deliver the commitment to “the principles of ‘sustainable development’” or deliver “environmental outcomes”. In particular, we believe the proposed process will seriously weaken protection for communities and countryside from local environmental impacts from noise – given the probability that increased traffic and other activities will result from development. Proposed extension of the regime gives us no confidence that noise will be adequately considered in assessment of these developments.  Clause 158 of the Planning Act 2008, confers statutory authority for nuisance action for developers of major infrastructure projects – therefore there is no intrinsic right for neighbours for protection from noise or other disturbance or unhealthy emissions from development covered by the nationally significant infrastructure regime.

We believe the proposed developments in manufacturing, warehousing, conference, leisure, sports stadia, office or leisure premises are very unlikely to comprise ‘nationally significant infrastructure’ – and there is no clarity as to what ‘national significance’ is. All of these have implications for and impacts on local communities. They are likely to have impacts on the amenity and quality of life in an area in terms of noise and other local impacts – from, for example, from air conditioning, heating, cooling plant and from increased traffic. We question whether it is in the national interest that noise, for example, from a leisure development, is more important than the amenity of neighbouring homes.

Further, given the continuing lack of clarity as to the guidance in place for assessing noise and associated wider local impacts of development, we believe more major change to the planning process is, at this stage, premature as it is not possible for consultees to consider the context and therefore full implications of these proposals as the findings of Lord Taylor’s review on planning guidance were only published in late December – and have not been implemented. To date the, admittedly out of date PPG24 has been used as a benchmark – there remains no up to date guidance on criteria for noise assessment in planning.

We therefore believe, for these types of development, that communities and local authorities should continue to be involved in a local decision making process that will shape the soundscape, landscape and economic operation of their neighbourhoods.

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Consultation on the Code of Practice on Noise from Ice-Cream Van Chimes, Etc., 1982

Today we have lodged our response to Defra to their Consultation on the Code of Practice on Noise from Ice-Cream Van Chimes, Etc., 1982.

While the Society welcomed the opportunity to respond to the consultation, we were extremely surprised and concerned not to have our views sought during the pre-consultation process described in section 2.13 of the Consultation Document. As the UK’s only registered Charity who’s sole remit is to find solutions to noise pollution problems, we were at a loss to understand how a reasonable review of “noise stakeholders” could not have included the NAS.

We also expressed our concern that Paragraph 2.13 of the Consultation Document is prejudicial, referring to “initial discussions with noise stakeholders that suggest that they are not overly concerned by a relaxation of the Code”. Government should not prejudge the positions of stakeholders on the basis of cursory discussions in which people may be reserving their positions in the context of Prime Ministerial comments which may themselves be considered prejudicial.

We fail to understand how a consultation on adding more noise into sensitive environments benefits anyone or is aligned with any of the principles, aims or objectives of the Government’s Noise Policy Statement for England.

NAS would like to go on record to clearly state that it does not support the view of other “noise stakeholders”, as stated in Section 2.13 of the Consultation Document, of being “not overly concerned by the relaxation of the Code”. The exact opposite is true.

The use of chimes in public streets is a form of aggressive selling and noise pollution that would not be countenanced for other industries. It abuses and seeks to bypass the relationship between children and their parents/guardians, exploiting the ‘pester power’ of children. 

It is especially irresponsible to encourage such selling practices of ‘fast food’ and sugary treats for children. Parents may be concerned at child obesity, encouraging healthy eating and may want to protect their children from aggressive selling and the attendant peer pressure from other children. People can usually get ice cream from plenty of other outlets, including convenience shops and supermarkets, which do not use inane noise pollution to force their attention on citizens who have a basic human right to peace and quiet in their own homes.

As has been well documented in numerous studies, noise can cause annoyance and fatigue, interfere with communication and sleep, reduce efficiency and damage hearing. Long undisputed by practitioners and underpinned by the World Health Organisation in its report Burden of disease from environmental noise, quantification of healthy life years lost in Europe (World Health Organization 2011, www.euro.who.int), “the health impacts of noise are a growing concern among both the general public and policy-makers in Europe”.

The WHO report presents a summary of “synthesized reviews of evidence on the relationship between environmental noise and specific health effects, including cardiovascular disease, cognitive impairment, sleep disturbance and tinnitus”.

It shows that “with conservative assumptions applied to the calculation methods, estimated DALYs lost from environmental noise were 61 000 years for ischaemic heart disease, 45 000 years for cognitive impairment of children, 903 000 years for sleep disturbance, 22 000 years for tinnitus and 587 000 years for annoyance in the European Union Member States and other western European countries”.

Callers to the NAS’ National Noise Helpline give a human voice to these findings with their appeals for help heard on a daily basis:

‘Ever since we moved in my life has been hell. I don’t want to go home sometimes but there’s nowhere else to go.’

‘I am a prisoner in my own home because of noise.’

‘I can no longer tolerate the noise. I have not slept properly in weeks.’

It is not unusual for highly distressed callers to the Helpline to cry on the phone.

It is against this backdrop of our own experience, those of the callers to our helpline and the considerable evidence as to the adverse health effects of noise pollution, that it is NAS’ strong view that given the many disturbances that residents are already required to put up with in the built environment, there is no justifiable reason to encourage unnecessary noise disturbance in order to encourage unhealthy eating practices amongst the young and the attendant health risks this will engender later in life.

NAS Response to Consultation on Code of Practice for Noise from Ice-Cream Vans, Etc., 1982

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DCMS Deregulation of Schedule One of the Licensing Act 2003

It is absolutely essential that the Government makes a cast iron guarantee that the duties of local authorities to respond to the needs of citizens suffering distress from irresponsible noise, e.g. under the Environmental Protection Act 1990, the Anti-social Behaviour Act 2003 and the Noise Act 1995, are maintained. NAS has been extremely concerned at rumours that statutory nuisance itself may have been under threat. This was not ‘Red Tape’, but the expression of an age-old inalienable right of citizens, and a core component in the balancing of freedoms and responsibilities in a fair society.

DCMS_Consultation03Dec2011

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Draft National Planning Policy Framework Consultation response from the Noise Abatement Society

The Noise Abatement Society fully understands the aspiration to reduce the volume of national policy statements from over 1,000 pages. However, noise is a complex area where Planning Policy Guidance Note 24 ‘Planning and Noise’ has stood the test of time since 1994. PPG24 strikes a good balance, commanding a high degree of confidence and consensus, and its principles are widely understood. The costs of changing technical criteria should not be underestimated. Although predating the strongest push towards land use mixing and higher development densities, PPG24 has in practice allowed sufficient flexibility. Good acoustic environments support development, rather than blocking it.

Given current resource constraints, PPG24 should be kept operative until a broadly-based working party has fully considered the scope and content of new technical guidance on planning and noise, and produced something which is demonstrably better than PPG24. The work should include emerging understanding on soundscape quality. NAS would be keen to participate in this working party, which should include the key professional organization, the Institute of Acoustics, and key academics from universities such as Sheffield and Salford.

National Planning Policy Framework RESPONSE

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Developing a Sustainable Network for UK Aviation

Noise and local air quality are the most significant impacts for local communities. CO2 is alsovital for them, not only in terms of climate change risks, but also the higher costs of reducing CO2 in other sectors if aviation continues to take a larger share of total allowable emissions.

Aviation jobs for local communities should be treated with caution, since these are more subject to fuel price and climate change-related shocks than many other sectors where government policy could encourage employment. In accordance with the ‘polluter pays’ principle, noise and other environmental mitigation should be funded by levies on aviation users. As well as assisting in demand management, such levies should fund sound insulation of buildings, and other compensation, since, of course, constraints on the use of outdoor spaces remain, with implications for health.

AVIATION CONSULTATION

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Planning for New Energy Infrastructure Revised Draft National Policy Statements for Energy Infrastructure

The NAS welcomes this opportunity to respond to consultation on revised draft National Policy Statements for Energy Infrastructure. This response focuses on aspects of proposed policy that have changed, or particularly important issues which NAS believes should change. However, NAS would also draw the Department’s attention to the Society’s response dated 22 February 2010 to consultation on earlier drafts, and would request that points of principle made therein should be reconsidered alongside this submission.

DECC NPS Consultation 240111

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Noise Abatement Society’s Submission to the Police Reform and Social Responsibility Public Bill Committee

This submission enjoins the Police Reform and Social Responsibility Public Bill Committee to incorporate in the Bill a modest clause, supportive of its primary aim, namely to give the police access to a power already available to local authorities to take action on instances of excessive noise. The police would be able to use this power in response to the needs of local communities in circumstances such as where noise was indicative of situations likely to be symptomatic of wider unlawful activities.

POLICE REFORM and SOCIAL RESP REFORM_NAS Response

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Noise Abatement Society’s response to the Draft National Policy Statement for Energy Infrastructure

The NAS has called for urgent attention and respect of the Human Habitat in relation to the Government’s proposed process, via National Policy Statements, for approving large scale infrastructure projects of national significance. This process has rightly been called ‘undemocratic’ as it will, as currently proposed, be applied via the powers of an Independent Planning Commission (IPC). While the Conservatives have said that they will do away with the IPC, if elected, the National Policy Statements (NPSs) will be enacted into primary legislation by the current Government, as planned.

The NPSs in respect of Energy, and specifically Renewables, have been poorly drafted and are reliant upon outdated and ineffectual measurement criteria (ETSU-R-97) for on- shore wind turbines. The NPSs also put unfair burdens of proof on both developers and local government and communities to prove their assumptions. All in all a very poor job that will lead to poor choices by developers, enhanced suffering on the part of local communities and further lack of understanding leading to greater suspicion and mistrust about how to effectively deal with these issues. Given that on-shore wind farms, once erected, will be in place for a generation or more, then surely it’s worth the Government’s time to get the test and measurement criteria for them correct? And given the escalating concern about noise impacts and health effects: getting noise assessments correct for these large scale projects is imperative to avoid future disaster.

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