(APPENDIX TO KEY DECISION REPORT - ‘THE COUNCIL’S RESPONSE TO THE MAYOR OF LONDON’S DRAFT AMBIENT NOISE STRATEGY’) [Final text to be transferred onto Councillor Moylan’s letterhead] Ken Livingstone Esq Mayor of London (Ambient Noise Strategy Consultation) Greater London Authority FREEPOST 15799 LONDON SE1 2BR [First date after implementation period to be inserted] Dear Mr Livingstone The Royal Borough’s response to the draft London Ambient Noise Strategy Background noise caused by road traffic, trains, or low flying aircraft is part of daily life in central London, but in some parts of the Royal Borough, where noise levels are unduly high, it is a source of considerable annoyance to residents. In fact there are few parts of the Borough that do not suffer a certain amount of disturbance from busy roads, although in an overall sense this reflects vibrant activity, the ‘buzz’ that you yourself refer to. This Council welcomes a comprehensive approach to controlling background noise, whether from transport sources, or industrial and commercial operations. An action- orientated noise strategy for London, which prepares the way for the National Ambient Noise Strategy expected in 2007, should put London in a stronger position to influence the controls, such as noise limit values, eventually imposed by Government. We are very much in favour of proactive measures to reduce ambient noise levels that can be achieved without disproportionate costs, and that target the worst affected areas. The Royal Borough together with the London Boroughs of Hammersmith and Fulham and Wandsworth, successfully negotiated a substantial noise mitigation scheme to offset the railway noise impact on line-side residents of Channel Tunnel trains using the West London Line. With regard to traffic noise, and in particular to reducing road/wheel noise, we have already re-surfaced more than two miles (3 kilometres) of the Borough’s main roads with porous asphalt. Together with you and others, the Council has contributed financially to the Human Rights case about sleep disturbance caused by night flights. We will continue to voice our objections, which include concerns over increased noise disturbance, to the option to build a third runway at Heathrow Airport. To improve noise awareness, we are exploring different ways of introducing noise awareness to schoolchildren through initiatives like the successful junior citizens week held annually in the Borough. Your three key issues and initial priorities in the main coincide with the Council’s view of what needs to be tackled, although in the absence of a ruling from the European Court of Human Rights which may include a recommendation for a night- flight ban, which will then be in the hands of the Government, we would like to see 1 more focused restrictions rather than a total ban. We would also like to see railway noise and vibration featured more prominently by including them in the key issues section. We do not agree with the way you embrace neighbourhood noise and noise nuisance issues within your strategy, these are outside your remit and should be dealt with by the boroughs, and your most effective contribution should be in providing more police resources to support borough enforcement activity as reflected in policy 82. We have looked at the detail of the draft strategy in terms of its significance for the Borough’s noise policies and in relation to cross-borough initiatives, but we have not commented on every item. I set out below our responses to a number of your specific proposals collected together under noise source headings. Our comments are referenced to the numbered policies and proposals. Roads and road traffic noise (1) NIGHT TIME ROAD WORKS [paragraph 4A.21 and proposal 5] The Royal Borough supports stringent controls on the hours when road-works may be undertaken. A recent survey of Kensington and Chelsea’s residents shows that construction noise including road-works bothers 32% of the respondents, compared with only 2% of respondents to a national survey. We are very concerned about the possibility of more night-time working, and we are looking to you to resist the Government’s intention to increase night-time road-works with its associated disturbance. You have control over TfL’s work programme and therefore have a specific opportunity to prevent this in London. Evening and Saturday works would be preferable, to ensure that peak capacity on the affected roads is maintained. The Council would support proposals to increase the powers of highway authorities to control public utility works. (2) QUIET SURFACES [proposal 7] Your aim to replace noisy carriageway surfaces with quieter surfacing is welcomed. The Royal Borough already specifies ‘UL-M’ noise-reducing surfacing on our major/principal roads, and we have very high standards of maintenance and renewal, which minimises potholes and other imperfections that can create noise disturbance when cars pass over them. Locations where many buses and cyclists are turning are considered less suitable for quiet surfacing, for road safety reasons. TfL should improve maintenance and specify UL-M, or similar, for its roads as soon as possible. We are disappointed that you have been unable to attach a specific timescale to Proposal 7. (3) TRAFFIC CALMING MEASURES [proposal 9] The Royal Borough is in favour of a review of traffic calming measures to ensure that the most effective and appropriately designed measures are installed. This would need to include a review of road humps, speed tables and speed cushions and any unnecessary interventions removed, and of any alternative measures that might be 2 used to achieve noise, air quality and road safety aims, consistent with our streetscape policies. (4) REVIEW OF NOISE INSULATION REGULATIONS FOR ROADS [policy 11] The Council feels that changing the scope of the Noise Insulation Regulations for roads may result in a large number of applications for mitigation for relatively little gain; where there are numerous road improvements of a modest scale in a densely built-up urban area, this could simply result in an unwelcome increase in bureaucracy. (5) POWERED VEHICLE NOISE GENERALLY [proposal 12, policy 13, paragraph 4A.48] You have mentioned some practical measures (technological fixes) to reduce noise impacts of vehicles, for example ‘smart’ reversing alarms, quieter cross-over material, footways and other servicing surfaces (particularly in regard to “trolleying” noise). We consider it crucial that Boroughs are consulted on new materials and designs in order that a high quality and visually cohesive streetscape is maintained, or enhanced. It is equally important that your Strategy should be coupled with action, for example TfL could make significant strides in reducing noise problems through tougher controls/policing with regard to quieter vehicle technology, across the whole of the Greater London area. (6) PUBLIC SPACE - NOISE ENVIRONMENT IMPROVMENTS [proposal 27 and policy 12] We support the ‘100 Public Spaces’ initiative and the traffic noise-reduction benefits it could bring to residents through careful design, and look forward to seeing this concept being developed further, with full funding support, noting that Sloane Square and Exhibition Way feature in the list of the first of the spaces to be developed. (7) LORRY BAN [proposal 13] The London Lorry Ban is currently under review and it is our understanding that you are looking for greater flexibility. As you already know from our recent meeting, the Council strongly objects to the disturbance that would result from increased HGV traffic through densely built-up areas if the current Ban is relaxed in any way. In the Strategy you state that the review will take account of the noise implications, along with the wider strategic transport and environmental concerns. We note that you are putting considerable emphasis on ‘many heavy goods vehicles (having) become quieter’, this may be the case over the long term, but we do not believe the noise reduction has been so significant in recent years. In the current situation both average noise levels and the number of lorry movements are sensitive issues and an increase in movements would lead to more noise events. In addition, if road surfaces continue to be noisy owing to potholes or noisy surfacing, then these problems need to be remedied before contemplating relaxing aspects of the Lorry Ban. Residents’ amenity, i.e. protection from noise, should be safeguarded through a strategy that tackles issues in the right order. 3 (8) BUSES AND COACHES [proposal 14] The proposal to liaise with bus operators to secure practicable and cost-effective noise control, is welcome. We would suggest that the best way to ensure good practice at bus termini is to accommodate dedicated route controllers to supervise stand use and driver behaviour (including switching off engines) as this is often a problem in winter months. Driver training should then be backed up with regular monitoring. This should be specified in TfL’s tender documentation. (9) THE ROLE OF THE LONDON COACH FORUM [proposal 15] We feel that the London Coach Forum should play a key role in bringing together interested parties including TfL in improving coach parking, facilities and terminals with due regard to noise issues. This is a useful albeit limited body, but it is in danger of being a “talking shop”. The body requires dedicated funding and active support, particularly from TfL and the GLA, to achieve the aims outlined in the proposal. (10) MOTOR CYCLES AND SCOOTERS [proposal 17] We support your proposal to explore the ways that motor cycle and scooter users can be encouraged to maintain the noise specification of their machines, and to drive more slowly and carefully. In addition to liaising with the London Motorcycle Working Group, you should consider a public awareness-raising campaign for powered two- wheeled vehicles used by residents and commuters to/through London.