The problem is, however, that local variations in noise policy do not necessarily relate to how quiet or noisy the area is, but are attempts by some local authorities to rewrite government guidance on a whim, without any basis for such changes in research. For example, PPG24 divides the 24-hour day into two parts: Daytime (07:00-23:00 hrs) and Night-time (23:00-07:00hrs).
Some local authorities have adopted an ‘Evening-time’ period (19:00-23:00hrs) into their PPG24 assessment criteria, with lower noise levels than for Daytime. That introduction is not supported by research and is even more nonsensical when it is adopted by local authorities in rural Kent, for example, where ‘Evening’ noise levels may well be lower, and metropolitan London, where ‘Evening’ noise levels are likely to be broadly similar or possibly noisier than the rest of Daytime.
It is with such conditions and the non-scientific rigour of their drafting that the noise consultant must deal. He must be able to provide a balanced view of the real noise impact of any scheme and give clear explanations in environmental statements or as evidence to an inquiry. Such a view should consider not only the actual published government guidance, but how the local environment will be affected if the new or revised development is permitted, based on the surrounding environmental conditions. One London local authority requires by condition that the Daytime noise levels in gardens should not exceed a level recommended by the World Health Organisation, when reference to the London Noise Map shows that there are almost no areas of the borough where such conditions currently exist!
Clearly these dichotomies require interpretation by an experienced professional and it is to be hoped that better government guidance as to national noise policy will be forthcoming in the future. On 15 March Hilary Ben simultaneously announced the formal adoption of 25 Noise Action Plans and a new Noise Policy Statement for England, the implications of which in terms of central government policy and local planning issues are yet to be understood. Watch this space!
Alan Saunders