The age-old cliché that noise is the forgotten pollutant may no longer be valid. Noise initiatives are springing out of the woodwork which promise to quieten the UK noise climate and put a new emphasis on environmental regulation. How much this will affect business is a moot point. Within the last weeks, huge policy developments have taken place that will affect neighbourhood noise (loud stereos and yobs, for instance). Within the last few months, a £13m nationwide noise mapping exercise has been launched as a precursor to a national noise strategy. And London mayor Ken Livingstone has pre-empted the lot by launching his draft noise strategy, with national government pledging to do little more than think about it in 2008.
Industry could be forgiven for thinking these events are not of direct relevance. But noise is a funny thing – unlike other pollutants, noise pollution is not additive, and a loud noise can mask other noises. So a busy road or noisy school might well mask a slightly less noisy but more annoying industrial process. Solve the noise problem of the road or school – and it is possible industrial noise may attract new complaints.
Fixed penalty notices
The most recent anti noise initiative came in early March this year. The Home Office issued a White Paper that proposes new powers, and clarified powers, which will allow
environmental health officers to issue £100 fixed penalty notices to noisy people. And they will be able to close down “premises” that are noisy. This is aimed at pubs and clubs, but being a consultation, it is not clear whether this might also include industrial premises – or indeed whether fixed penalty notices could be extended to industrial sources.
Such powers will strengthen the hand of environmental health officers, who will no longer have to rely on cumbersome court process as fixed penalty notices do not need a court order.
That development is worth watching as things are moving quickly. Moving at a slightly slower pace is progress on tackling broader environmental noise.
Mapping UK noise
Completed last year, the Environmental Noise Directive, like many directives, has been watered down from its intention to oblige Member States to cut environmental noise.
Instead, it was agreed that member states must map noise to act as a benchmark for the future when there might be an obligation to cut noise. Mapping would require local authorities to model and monitor noise in their areas and produce contour maps of where there is excess noise.
Road traffic, air, rail and industrial noise will eventually be included on these maps, which would be used to allow planners to decide where noisy – or quiet – developments could take place, or where noise needs to be cut.
DEFRA launched a mapping process a year ago by appointing management consultant Schal to oversee the work. In December, Schal awarded a £600,000 contract to WS Atkins to map road noise in London, and there are numerous similar contracts to follow in the next few months, creating a bonanza for consultants (and a fear that many German firms with their long experience of noise mapping might scoop up the best contracts).
In terms of the London contract, Atkins will only be mapping road noise, which is dominant in most areas. Contracts are being let for air (CAA) and rail noise to produce contours to add to Atkins’ map.
These are strategic noise maps, and industrial noise is unlikely to have a huge impact. But local authorities will take the strategic map and add more detail – at this point industrial noise will be added to the map for planning purposes.
Local authorities will have some of this data for the medium-size processes they regulate (LA-IPPC part A2 processes) – where air, noise and other media are included in the permitting system. There is no statutory duty to include noise impacts for the 17,000 smaller processes regulated through LA-PPC part B processes, but where noise complaints have been made, there may be data available.
And of course the Environment Agency is gathering increasingly detailed data on noise impacts for the larger Agency-regulated IPPC (part A1 processes).
Late last year, the Agency released important guidance on noise assessment for the processes it regulates, and the larger part A2 processes regulated by councils. This ‘horizontal’ guidance is intended to cut across process-specific ‘vertical’ guidance as process noise control has common issues.
The horizontal guidance was put together by consultant Keith Horton amid fears that the new IPPC regime would reduce local regulation of many businesses. Local authorities feared that noise sources such as barking guard dogs and delivery lorries would be regulated by the Agency, and the authority would then be prevented from acting under nuisance legislation if there were local complaints.
Under the horizontal guidance, operators will be expected to stick to good practice in controlling noise by using plant maintenance techniques, especially on bearings, air handling plant and the building’s fabric as well as specific noise attenuation measures associated with plant and machinery.
The guidance will apply to both existing and new activities. For current operations where there are no existing limits, operators will need to demonstrate best practice (best available techniques or BAT) and ensure there is no cause for annoyance. These will need to be monitored for their impact and calculations made rather than relying on predictions.
The Environment Agency, which regulates PPC, is very keen to point out that lack of complaint should not in itself be an indicator that there is no noise problem. Instead the guidance recommends that there should not be any cause for annoyance to persons beyond the installation boundary.
The horizontal guidance has so far detailed local authorities’ new responsibilities. Guidance is shortly to be produced on the nitty gritty of how noise can be calculated and reduced.
While guidance is imminent, industry should keep an eye on the progress of the noise mapping exercise. For noise campaigners, progress is slow – mapping will take place to inform a decision in 2007 on whether the government will produce a strategy, as opposed to what it might say.
But for reasons discussed earlier, if the noise mapping does empower local authorities to take action on the loudest noise sources (essentially traffic, which does not attract public complaints), the focus may very quickly shift onto quieter, but more annoying industrial noise sources.
Such complaints will not be confined to noisy industrial processes. Cutting of traffic noise may prompt complaints from the public on ancillary sources such as air conditioning, reversing alarms, delivery truck rattles, roller doors, early morning gate clatter and other commercial activities.
It will be a great irony if the £13m national effort to quieten UK transport noise has the effect of increasing the number of complaints about industrial noise, leaving industry with a huge noise reduction task.