10 June 2014
Dovenby Hall, Dovenby, Cockermouth, Cumbria, CA13 0PN
Full planning application for M-Sport Evaluation Centre (MEC) incorporating test area, agricultural building and demolition of derelict School House, Hodgson House and Howard House. Outline planning application for four further land uses consisting of: future expansion space, offices, 60 bed hotel and 25 dwelling housing estate.
Planning Application Reference: 2/2014/0350
We refer to the recent consultation for the above application and have split it into relevant areas. These being Noise from the Development, Contaminated Land, Construction and Lighting.
1. Noise from the Development
Before sending formal comments and correspondence to the Planning Application on Noise from the Development, Environmental Health would like the applicant to address the following comments. Once all comments have been addressed, clarified and submitted, we will then send a full detailed response. At present however we feel the information submitted is not complete to enable us to provide our final comments at this stage.
However. at this stage we would wish to raise some issues , we have split each noise report and have comments listed under each heading. We have also concluded with a number of points.
Assessment of Community Noise Levels
1. This document is four pages of information and the rest of the document looks at results, formulas and tables. There is no definitions of terminology anywhere in the document and doesn't follow a standard noise report making it very hard to understand.
2. The majority of the document is looking at barriers, however it doesn't specify or have any conclusions as to which barrier will be used and what the LAeq/Lmax will be as a result at the 10m from trackside and the seven properties.
OVERALL - Difficult to understand and doesn’t follow an adequate Noise Impact Assessment based on the principles of BS4142.
1. Even though noise has been documented in the Environmental Statement (ES) it needs to make more reference to relevant British Standards (i.e BS4142) and World Health Organisation Guidelines for Community Noise (WHO).
2. There is no mention of Lmax and in 8.2.3 it states LAeq (1 Hour) has been agreed with ABC. The consultant is also aware we agreed Lmax and these need to be provided.
3. The diagram of measurement locations in Figure 8.1 is incorrect as it only refers to four locations and not the seven listed in other documents.
4. The ES is mainly talking about Construction Noise as opposed to noise from the Evaluation Centre and Test Track. This needs to be included as part of the ES as Construction Noise is temporary and can be dealt with by way of Planning Condition (please see below).
5. The Figure 8.2 is incomplete and therefore needs to reflect other documents submitted as part of the application.
7. Paragraph 8.5.2 makes reference to the vehicle attenuation and reduction in noise by its use. No details of this attenuator have been provided with this application to date.
OVERALL - a number of issues need to be rectified and explained. The whole focus is largely on Construction as opposed to the actual use of the track. This needs to include much more details on test track design, bunding, silencers along with LAeq and Lmax. Certain diagrams are also incomplete or incorrect and need to be changed. In order to gain an understanding of impact a final design of the track needs to be submitted which will form part of the assessment when designing the mitigation measures.
Draft Acoustic Strategy
1. We are unclear why a Draft Acoustic Strategy has been included as part of a Formal Planning Application. This document needs to be revised and re-submitted.
OVERALL - this document is what is says “Draft” and should not have been submitted in its current form. This document should adopt the principles of BS4142.
Noise Management Plan Strategy
1.This is one of the most important documents and as result this document needs to be more detailed and lengthy and also include Lmax as previously discussed with the applicant and noise consultant. These Lmax figures will run alongside the LAeq figures already presented at 10m from source as a control.
2. This document also needs to include days per week/per month as previously discussed with the applicant and noise consultant. It was also agreed that after any “Noisy Day” there would be one day of rest. For example:
No Limit Day/12 Days per Year/Maximum 3 Hour Day/No more than 1 No Limit Day per Month Monday to Friday
60dB/45 Days per Year/Maximum 5 Hour Day/No more than 1 60dB Day per Week Monday to Friday
50dB/75 Days per Year/Maximum 7 Hour Day/No more than 2 50dB Days per Week Monday to Saturday
3. Confidence needs to be provided in the plan as to how complaints would be dealt with if necessary and a more detailed method of communicating with the public needs to be established. A website needs to be created with a diary detailing when Category 1, 2 or 3 days will be taking place. On a weekly basis results also need to be sent to ABC to show compliance,
5. Additional information needs to be provided in relation to the Corporate Days within the Noise Management Plan and such an event will be controlled as there will be other noise sources that need to be considered.
OVERALL - This document lacks detail and need to be developed further. It needs to explain how the noise equipment will work and be located, how information will be provided to the public and the EHO/LPA. It is our view the system needs to be live and can be accessed by the EHO in the event of complaint, additionally results need to be sent weekly and a noise diary needs to be on a website for the public. It needs to include Lmax and more detail on Category of Use days. As the consultant is aware in any one hour period the car may be on the track for 5-10 minutes only so it essential to control maximum noise levels. Additionally tyre squeal needs to be mentioned and how it will be controlled. This noise management plan is the most important document for Environmental Health and in its current form is insufficient.
1. All documents listed need amendments and changes and it is the view of Environmental Health that these numerous documents become one document. This will make it easier to read and understand without conflicting information in numerous documents. These documents also need to be made easier for the General Public to understand and need a list of abbreviations as set out throughout the document.
2. The documents also do not give any confidence regarding noise management on the site and how this will be dealt with effectively. A noise diary needs to be established on a website detailing wind speed, direction and category of day. The whole operation needs to be open and transparent and establish a relationship with residents.
3. The noise documents fail to refer to the proposed Housing development or Hotel and this also needs to be included in the detail of the reports.
4. The initial Scoping Report stated that a Noise Impact Assessment (not included as part of the application) should follow the guidelines in BS4142. Can this be submitted as a matter of urgency with all other documents falling part of the same document.
5. There is no detail on the proposed Silencer. This needs to be submitted.
6. Lmax needs to be provided as part of the Pyramid at 10m from source and the seven receptor locations as well as the proposed housing and hotel.
8. We are sure the applicant is well aware most of the public objections now relate to noise from the test track. It is therefor essential that all points are considered, a new noise report is submitted detailing all necessary information in a clear, understandable way and a new Noise Management Plan is submitted in more depth and detail showing how noise will be controlled.