Response by AEF on EU Environmental Noise Directive – needs strengthening to preserve health
The European Commission held a consultation on the “relevance, effectiveness, efficiency and EU added value of the Environmental Noise Directive (END).” The AEF has responded to this, commenting that while the END had improved noise monitoring, it should be strengthened to achieve its aim of reducing the health burden of noise from transport sources including aviation. The END requires member states to produce action plans to reduce ‘excessive’ noise levels. The END helped establish noise as a major public health issue, with the mapping requirement helping to improve awareness of the noise problem around the UK’s airports. However, AEF believes the END “should explicitly outline noise levels (limit values) that should be met in order to reduce the health burden from noise. These noise levels should be in line with WHO recommendations (1999) and set out in the END.” AEF believes “noise action plans should be assessed in terms of how effectively they contribute to reducing noise towards health-based levels” … Also “the END’s objective ‘to preserve environmental noise quality where it is good’ is not currently being effectively delivered and the protection of rural quiet areas should become a stronger priority for noise action plans.” Full response by AEF.
AEF comments: evaluation of the Environmental Noise Directive
March 29th 2016 (AEF – Aviation Environment Federation)
AEF responded to a European Commission consultation on the Environmental Noise Directive (END), highlighting that the European legislation had improved noise monitoring but that the Directive should be strengthened to enable it to achieve its aim to reduce the health burden of noise.
The END came into force in 2002 with the aim of protecting EU citizens from the harmful effects of noise. The legislation followed the WHO’s 1999 community noise guidelines which highlighted the health effects of environmental noise (noise from industry and from transport sources, such as road, rail and aviation). The END requires member states of the EU to identify and map noise sources, including airports which are large or close to built up areas. It also requires member states to produce action plans to reduce ‘excessive’ noise levels.
The consultation was part of the European Commission’s evaluation of the END which considered its effectiveness and whether EU noise policy should be adapted.
AEF believes that the END has helped to establish noise as a major public health issue that needs to be tackled, with the mapping requirement helping to improve awareness of the noise problem around the UK’s airports.
However, we believe the Directive should explicitly outline noise levels (limit values) that should be met in order to reduce the health burden from noise. These noise levels should be in line with WHO recommendations and set out in the END. We believe that noise action plans should be assessed in terms of how effectively they contribute to reducing noise towards health-based levels.
Finally, we believe that the END’s objective “to preserve environmental noise quality where it is good” is not currently being effectively delivered and the protection of rural quiet areas should become a stronger priority for noise action plans.
Further details of our comments are provided in the link below.
European Commission Evaluation of the Environmental Noise Directive (the consultation started on 21.12.2015 and closed on the 28th March 2016).
The objective of the consultation was:
“The Commission has decided – in the context of “Better Regulation” – to evaluate the Environmental Noise Directive with a view to regulatory fitness. The Commission already collected – via an external evaluation – the views of enterprises and public bodies by means of dedicated interviews. This was followed up by an expert workshop (comments on the documents discussed at that workshop can still be submitted). With this questionnaire, the Commission is now collecting the views of citizens and associations of citizens, but also of all other interested stakeholders, addressing specifically the relevance, effectiveness, efficiency and EU added value of the Environmental Noise Directive.”
The WHO guidelines (1999) Executive Summary states:
[Some extracts …]
“The effects of noise in dwellings, typically, are sleep disturbance, annoyance and speech interference. For bedrooms the critical effect is sleep disturbance. Indoor guideline values for bedrooms are 30 dB LAeq for continuous noise and 45 dB LAmax for single sound events. Lower noise levels may be disturbing depending on the nature of the noise source. At night-time, outside sound levels about 1 metre from facades of living spaces should not exceed 45 dB LAeq, so that people may sleep with bedroom windows open. This value was obtained by assuming that the noise reduction from outside to inside with the window open is 15 dB. To enable casual conversation indoors during daytime, the sound level of interfering noise should not exceed 35 dB LAeq. The maximum sound pressure level should be measured with the sound pressure meter set at “Fast”.
“To protect the majority of people from being seriously annoyed during the daytime, the outdoor sound level from steady, continuous noise should not exceed 55 dB LAeq on balconies, terraces and in outdoor living areas. To protect the majority of people from being moderately annoyed during the daytime, the outdoor sound level should not exceed 50 dB LAeq. Where it is practical and feasible, the lower outdoor sound level should be considered the maximum desirable sound level for new development.”
For Schools and Preschools:
“For outdoor playgrounds the sound level of the noise from external sources should not exceed 55 dB LAeq, the same value given for outdoor residential areas in daytime.”
“For most spaces in hospitals, the critical effects are sleep disturbance, annoyance, and communication interference, including warning signals. The LAmax of sound events during the night should not exceed 40 dB(A) indoors. For ward rooms in hospitals, the guideline values indoors are 30dB LAeq, together with 40 dB LAmax during night.”
“For a good night’s sleep, the equivalent sound level should not exceed 30 dB(A) for continuous background noise, and individual noise events exceeding 45 dB(A) should be avoided. In setting limits for single night-time noise exposures, the intermittent character of the noise has to be taken into account. This can be achieved, for example, by measuring the number of noise events, as well as the difference between the maximum sound level and the background sound level. Special attention should also be given to: noise sources in an environment with low background sound levels; combinations of noise and vibrations; and to noise sources with low-frequency components.”
………….. and there is a great deal more detail at http://www.who.int/docstore/peh/noise/ComnoiseExec.htm
AEF says, in its response:
Has the END been effective?
AEF believes that the END has helped to establish environmental noise in Member States as
a major public health issue that needs to be tackled. The communities and local authorities
that we represent regard aircraft noise as a critical issue that needs effective policy action,
especially given the Commission’s own analysis that the population exposed to aircraft noise
levels above 55 dBA Lden is forecast to increase 15% by 2035 compared to 2012 levels when the number already stood at around 5 million EU citizens. (Link)
The EU has taken a leading role in calling for action on environmental noise. As the EU’s flagship policy to tackle the noiseproblem, however, we consider the END in its current form to have significant limitations.
The mapping requirement in the END originally, we believe, played a useful role in improving
the data availability in relation to noise exposure around the UK’s airports. The UK
Government’s Department for Environment, Food and Rural Affairs (Defra) published online
noise maps from 2006 for all airports covered by the Directive (including large airports and
those close to conurbations). These maps used noise metrics that communities perceived as providing a better representation of the noise problem than the UK’s official daytime noise metric, 57 dBA Leq. For some of these airports, noise contours were made publicly available for the first time.
However, the 2011 data was by contrast not presented in a central publicly available location, with Defra instead providing links to the airports’ NAPs in a document published in 2015, titled ‘Strategic noise mapping: Explaining which noise sources were included in 2012 noise maps’ (Link). It was then up to the airport how it presented the information required under the END. The lack of consistency and central location to view data has made it challenging to look at trends at airports across the UK.
Being able to assess trends in the noise environment is a useful tool for examining the
effectiveness of NAPs. In the UK, the airports are the competent authority for producing NAPs to tackle any noise they themselves deem to be excessive. NAPs require some level of consultation and Defra has responsibility for assessing them but it is currently unclear how the judgement is made of what constitutes excessive noise levels and how appropriate action is judged.
It is AEF’s view that this lack of clarity is the central challenge to the effectiveness of the END and the reason why AEF believes the END is failing in its overarching aim to protect EU citizens from the harmful effects of noise.
Without meaningful targets or limits to reduce the health impacts of noise the Directive succeeds only in harmonising a process without requiring common and equivalent action for all airports. Since the END came into force, the AEF has argued consistently that few airports in competitive situations would, voluntarily, impose effective measures that could limit capacity. We believe that NAPs could be better assessed if they delivered improvements towards a clearer definition of acceptable noise levels, as highlighted below.
Are any changes needed to the END?
AEF strongly believes that the Directive should explicitly outline noise levels to be attained in order to reduce the health burden from environmental noise.
We note that different noise sources have different dose-response relationships in terms of contributing to sleep disturbance, annoyance, and cardiovascular illnesses and understand that further information on these relationships will be available as an Annex to the END following the WHO’s updated Community Noise Guidance this year.
Limit values should, we believe, be in line with WHO recommendations and set out in the END. NAPs should then be assessed in terms of how effectively they contribute to reducing noise towards health-based levels. The mapping requirement of END should, we argue, extend to assessing the burden of disease in conurbations and around airports in the UK from environmental noise. A monetised estimate of the burden of disease could then be produced based on the methodology developed by WHO Europe and outlined by Defra IGCB(N) (Link)
We believe the END should be revised to stipulate that the competent authority should be independent of the airport operator.
Finally, we believe that the END’s objective “to preserve environmental noise quality where it
is good” is not currently being effectively delivered. The protection of quiet areas in rural
and urban locations is an important, health beneficial, component of the END. At the
moment, the requirement for NAPs to identify quiet areas only extends to urban locations.
The Commission was mandated to submit a report to the Parliament by 2009 about
implementation of the Directive including proposing strategies for the protection of quiet
areas in open country but no comment was provided in the 2009 report. The protection of
rural quiet areas should become a stronger priority in the END and in NAPs.