Objections on grounds of noise |
This page is part of the campaign to
Save the Epping Forest Act.
It was hastily compiled from comments by
David Bowden (a Chartered Building Surveyor),
Tot Brill (whose house is immediately adjacent to the site),
Newham Council and a
local solicitor.
Noise is described as exceeding guidelines, yet no comparison is made with the existing level.
There will be generators on site which will start and stop automatically as electricity is needed. It is claimed that this will reduce noise emissions, yet it is the starting and stopping of any noise that is generally the most disturbing. It is claimed that they will only be used at peak times which it is claimed will likely to be during the day. The lighting will be needed more at night and electric lighting does not power itself no matter how ecologically efficient it might be.
The presence of horses does not appear to have been taken into account in preparing the noise data for this document. Paragraph 5.2 considers “movement of horses” as one of the main noise impacts from the operation of the site. But it is not clear how this has been factored into the estimates made of the noise output. Given that the perimeter fence is not going to reduce the noise from horses once they leave the MBDC and given that the horses are going to pass along residential roads, special consideration ought to have been given to this.
Further, it is not known whether the horses will leave and return to the MBDC at the same time. This is unlikely given that there are to be several places of deployment. Therefore residents could be faced with an almost continuous sound of horses throughout the day.
In addition to 24/7 generators, vehicle movements and a farrier workshop, the Metropolitan Police propose an aluminium trackway and wooden floors to the marquees. Hollow trackway and wooden floors are noisy. Frankly, the level of noise this intrusive and unwanted village will cause within a stone throw of bedrooms in Sidney Road is unsupportable. The residents ask, that, if Redbridge Council agree this application that sound deadening materials are used throughout the site and that movement and noise is restricted between 10.30pm and 7am.
Further, there is no mention of how the presence of horses on the site overnight may affect noise levels. It is not clear that this has been factored in to the assessment of data. Nor is there any mention of additional noise levels from dogs being kept on site during the day therefore it is to be presumed that this has also not been considered.
No thought seems to have been given to the fact that the area around the site where the MBDC is to be sited is reasonably quiet. The presence of an MBDC will completely change the character and temperament of the area.
No consideration has been given to the additional noise which would result if there was an emergency. An emergency could even occur during the middle of the night. The Applicant’s Planning Statement states at paragraph 7.69 that “the site will not be used for emergency ‘blue light’ response thus no sirens will emanate from vehicles using the site, except for an extreme emergency situation”.
To have prepared a noise assessment using data which would only be accurate if there was no emergency is a contradiction in terms. The purpose of the MBDC is to coordinate a response if there is an emergency. Therefore, it is not for the Applicant to make some kind of assessment of the likelihood or not of such an emergency occurring, but rather to assume that there will be an emergency and consider the impact that would have on the local neighbourhood.
It is worth bearing in mind that the data collected suggests that at night, the maximum noise level would marginally exceed World Health Organisation guidelines (although the argument put forward by the Applicant is that such a change would be imperceptible to local residents). Add to that any kind of emergency which, even if there were no sirens, would almost definitely result in an increase in traffic, and the Applicant will have far exceeded WHO guidelines.
The conclusions of the submitted noise report do not accord with the proposed operation of the site. Night time noise levels and impacts on Newham residents cannot therefore be predicted accurately. In the absence of accurate information noise attenuation measures at the site cannot be assessed.
The suggestion in the noise report that noise from the 24 hour generators should be within 5dB of the background does not meet with the Council’s standard requirement that plant operation and activity on site should not give rise to a BS4142 rating level greater than the background level at the nearest or worst affected property. Residents are entitled to be protected by reasonable standards. We acknowledge that this matter could be dealt with through a condition.
Newham Council propose the following conditions:
Prior to the commencement of works on the development hereby permitted, an acoustic report shall be submitted to and approved by the Local Planning Authority. Plant operation and activity on site shall not give rise to a BS4142 rating level greater than the background level at the nearest or worst affected property. Where it is considered impractical to meet this noise standard the report should detail mitigation measures taken to reduce noise to a minimum. .
The approved scheme shall be implemented prior to occupation of the development and shall be permanently maintained thereafter. The developer shall certify to the local planning authority that the noise mitigation measures agreed have been installed.
Reason: To protect the living conditions of nearby occupiers.
The hours where construction noise is audible at the nearest noise sensitive premises shall be limited to 08:00–18:00 Monday to Friday and 08:00–13:00 Saturday and at no time during Sundays and public holidays.
Reason: To protect the living conditions of nearby occupiers.
The number and time of vehicle movements shall not exceed those set out in the Transport Assessment. Vehicle movements shall be recorded and the data provided to the local planning on request.
Reason: To protect the living conditions of nearby occupiers.
National Planning Policy Guidance 24: Planning and Noise states at paragraph 5 that:
Plans should contain policies designed to ensure …that potentially noisy developments are located in areas where noise will not be such an important consideration or where its impact can be minimised. It may also be appropriate for local planning authorities to adopt policies to avoid potentially noisy developments in areas which have remained relatively undisturbed by noise nuisance and are prized for their recreational and amenity value for this reason.
It is contended that siting an MBDC on Wanstead Flats would breach PPG 24 on the basis that the area around the Fairground Site, despite having an“A” road running alongside, is actually quite quiet, given that it is in the middle of a vast open space. Further, the noise is not going to be self-contained within the site, but will spill over into the entrance and exit of vehicles and animals and along the route they take to their place of deployment.
The application also contravenes PPG 20 which states at paragraph 20 that
Special consideration is required where noisy development is proposed in or near Sites of Special Scientific Interest.
Insufficient regard has been paid to the fact that the MBDC will lie adjacent to a site of special scientific interest
This document was translated from LATEX by HEVEA.