A rather one-sided conversation

Anybody who has been reading my blogs for some time will not be surprised to learn that the major part of the response to the consultation on the document HS2 London to West Midlands EIA Scope and Methodology Report (EIA S&M report) that I authored on behalf of my local parish council was on issues of noise. In particular, I concentrated on issues relating to airborne noise – yes I know that the EIA S&M report prefers the more sanitised description “airborne sound”, only admitting to it being “noise” when an “impact” is identified, but I believe in calling a spade a spade and it’s all noise to me. In view of this specific interest of mine, my comments are concentrated on Section 13.3 of March 2012 version of the EIA S&M report; due to a reorganisation of chapters, this has become Section 14.3 in the March 2012 revision.

I made a number of specific points in the contribution to the consultation that I authored and so I thought that I would use this blog to check whether these had been reported in the document that summarises the consultation responses, HS2 London to West Midlands EIA Scope and Methodology Consultation Summary Report and whether any changes have been made to the EIA S&M report as a result.

One of the main observations that I made was that:

“… in support of the aims of Directive 2002/49/EC, the parameter Lden should be used in Chapter 13 wherever this is consistent with the noise nuisance level being assessed. This seems particularly apposite in view of the long lead time of the HS2 project and the expectation that EU requirements will have been strengthened by the time that noise from HS2 activities affects UK citizens.”

I have set out the reasons for making this suggestion in my blog How annoying is that? (posted 18 Oct 2012).

The document HS2 London to West Midlands EIA Scope and Methodology Consultation Summary Report makes no mention whatsoever of this matter. However, the following addition has been made to paragraph 14.3.10 on page 148 of the revised EIA S&M report:

“The LpAeq indicator is a proven and widely established indicator of community annoyance for railway sound and is therefore used in all relevant legislation, standards and guidelines. The EIA is also considering the maximum sound level for a train pass-by consistent with the assessment and design of HS1.”

But, this hardly qualifies as a response that addresses my point that it would be more appropriate to use the Lden version of the equivalent continuous sound level; so I think I am justified in regarding that my point has been ignored.

Another comment that I made was to welcome the introduction of the peak sound parameter LpAF,max as a new metric for the EIA S&M report, but qualified this welcome with the observation that “85 dB LpAF,max is much too high a level to be employed as an indicator of annoyance or health impacts. This point is covered in my blog A summit that is far too high (posted 26 Oct 2012).

Only a general response to this matter is given in HS2 London to West Midlands EIA Scope and Methodology Consultation Summary Report:

“Some comments suggested that the impact criteria for residential receptors for both ground-borne and airborne sound and vibration were not appropriate. The criteria proposed have been used successfully on other major rail infrastructure projects and are therefore considered appropriate to be adopted for the Proposed Scheme.”

No change was made to the EIA S&M report.

Other observations that I made in the response to the consultation by Cubbington Parish Council have been ignored, or treated in a perfunctory manner. These include:

  • The possible need to set a different peak noise threshold at night; a topic which I have mentioned in my blogs A rude awakening (posted 11 Dec 2011)  and I think that you may still be missing something (posted 15 May 2012).
  • The need for a review of the annoyance threshold specified for the day-time equivalent continuous sound level in the light of lower thresholds suggested by some authorities; something that I covered in my blog And, by the way, there’s also … (posted 30 Oct 2012).
  • The need to take account of train sound level increases due to the degradation of the track quality during normal use; a matter raised in my blog It could be a bumpy ride (posted 24 Oct 2011).
  • The lack of a strategy to take account of the increased impact that HS2 noise will have on previously tranquil locations; a topic which I have mentioned in my blogs It used to be really quiet ‘round here (posted 12 Oct 2011) and And, by the way, there’s also … (posted 30 Oct 2012).

I also stressed the need for a far more transparent approach to issues such as adapting the sound level calculation methodology for the higher operating speeds of HS2 and the design and evaluation of noise barrier designs. In my view, the amended EIA S&M report gives no assurance that this will be a feature of the Environmental Specification.

The problems that I have encountered in getting any responses out of HS2 Ltd to the comments that I submitted to the consultation on the EIA S&M report are just one aspect of “a rather one-sided conversation” that I am having with HS2 on noise. In my next blog, I will tell you about a similar refusal by HS2 Ltd to engage with me on noise issues within the community forum discussions.

PS: The response to the consultation submitted by Cubbington Parish Council to which I refer in this blog may be found here.

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