Friday, 29 June 2018
Thursday, 28 June 2018
Grenfell Tower Questions???
How did the fire start? Who made the first 999 call?
"The fire is thought to have been caused by Mr Kebede's fridge." (Image PA)
"After calling 999 and alerting neighbours Mr Kebede fled the tower." (Image PA) The Times states this was logged at 12.58 am. This was four minutes after the first recorded call to the Fire Brigade at 12.54.
The two images above are taken from a (Daily) Mirror newspaper article on the 21st June, 2018 here: https://www.mirror.co.uk/news/uk-news/grenfell-tower-dad-two-who-12759921
They both claim to show Mr Behailu Kebede leaving the Grenfell Tower building, the inference being that this was after fire had broken out in his flat (Number 16) on the fourth floor of the block.
In both images he appears to be making his way to the entrance/exit as shown by the floor grating holding a mobile phone. However there is clearly a problem and it is a BIG one!
The two locations appear to be different and Mr Kebede is clearly wearing different clothes. So these images must have been taken at different times and they cannot both be of the moment he left the building, post fire.
The question therefore arises, given the sensitive nature of the images, how were they allowed into the public domain and for what purpose; and why given the different times to which they relate, was this and its implications not made clear? If one of the images does not relate to the fire, how can we be sure the other portrays what it purports?
But that is not the only issue thrown up by these images.
In the Times of the 22nd June, 2018, Mr Kebede is quoted as saying, "I banged on the bedroom doors at about the same time as I was calling 999. I then ran out of my flat barefoot, wearing only my boxer shorts and T-shirt. I banged on the front doors of all the five other flats on the fourth floor ... Most understood the urgency and some began screaming."
He continued, "I ended up leaving my flat without any personal possessions. All I had on me were the clothes I was wearing and my mobile phone with which I was calling 999. I left without my shoes, my wallet, my second mobile phone, my flat keys or my car keys."
So what is the problem with this account? In fact there are several serious ones as far as I can tell!
First note the rather strange behaviour and account of what happened. He banged on the bedroom doors in his flat, yet he appears to make no attempt to open the doors to ensure whoever is inside the rooms is made aware of the danger and is physically removed. Who would leave such a thing to chance?
There is no mention of whether the occupants got out safely with him, although separately reported it subsequently transpired he had two female lodgers - Elsa Afeworki and Almaz Kinfu - one of whom had a large silver suitcase that earlier had been assumed to be his. He also claims to have raised the alarm on the landing whilst dialling 999.
Indeed the first 999 call is timed four (4) minutes prior to the second photo above of him leaving barefoot without shoes which might fit, but there is another big problem with this account.
First there is absolutely no collaborative background noise to support the description of what he was doing at the time - i.e. banging doors and shouting warnings, but much more importantly the recorded 12.54 am first 999 call, identifying the room 16 and a problem with the refrigerator is made outside the building! The emergency operator asks the question several times, "Are you outside and safe?" and the caller states clearly and repeats, he is.
Listen to the first 999 call timed at 12.54 am here: https://www.youtube.com/watch?v=IIMMxLK7SMY
The conclusion to be drawn from this is extraordinary and crucial and can only be one of the following:
Of course it raises secondary questions as to the reliability of Mr Kebede's account and even if the man who made the first call was actually him or someone else entirely!
After all if Kebede was filmed coming down the stairs at 12.58 am, he physically could not have been the person who made the 999 call four minutes prior to that at 12.54 am.
The second photo image of Kebede, if genuine must have been taken four minutes after someone else had phoned from outside!
Did Kebede phone the emergency services at all and if not why was he checking his phone as he came down the steps?
Is it not very strange that no one in police, press or inquiry have noticed this startling fact or sought an explanation for it?
But that is not the only problem highlighted by the two pictures at top of page showing Kebede leaving the building.
Note he said he was wearing only boxer shorts and T-shirt when he abandoned his flat 16 and the fourth floor. However although the second image does show him bare foot he most definitely is not only wearing boxer shorts. He appears to be wearing casual slacks - in fact the same as the ones he is wearing in the first photograph, though with a different top.
Also very strange, neither of these photographs display any sign of panic or even anxiety. There is no suggestion of rush or even the signs of smoke contamination on his clothes. His hands and arms as well as feet show no sign of soot or smoke contamination.
Further in both photographs he is clearly leaving alone. If as he reported he had raised all the other occupants on the floor, surely some would have been leaving with him? And not even his two lodgers with him?
Room photographs show red plastic covering the electric point behind the refrigerator, presumably placed there by the Fire Brigade as it shows no sign of melting with the heat. The sink unit is rather strangely bent upward and is charred under. Was wrenched up by a strong fireman or forced up by some explosive force?
https://www.google.co.uk/search?q=grenfell+tower+images+inside&rlz=1C1ARAB_enGB463GB464&tbm=isch&tbo=u&source=univ&sa=X&ved=0ahUKEwjqooX4yvfbAhXLTMAKHZGmCGsQ7AkINA&biw=1280&bih=891#imgrc=19SIYXRTi3ahkM:
In any event if Mr Kibede was in the flat as described when "white smoke started billowing from behind the fridge/freezer" there is no suggestion he made any attempt to turn off the electrical supply of fight the fire in any way before abandoning the flat and its occupants. Nor do the above photographs support the description below that he was "rushing outside". The photograph rather suggests a certain nonchalance about the whole thing, that is if it can be relied upon.
Flat 16 Interior.
https://www.google.co.uk/search?q=grenfell+tower+images+inside&rlz=1C1ARAB_enGB463GB464&tbm=isch&tbo=u&source=univ&sa=X&ved=0ahUKEwjqooX4yvfbAhXLTMAKHZGmCGsQ7AkINA&biw=1280&bih=891#imgrc=1cahJh316OWA8M:
The fact that the police offered 'witness protection' at an 'unknown address' appears unusual for the victim of a fire or crime and is much more common when regarded as police agent or asset, although I am not suggesting this was the case here.
From the Mirror here: https://www.mirror.co.uk/news/uk-news/grenfell-tower-dad-two-who-12759921
"Mr Kebede was woken by the sound of his smoke alarm shortly before 1am on June 14, and found white smoke billowing from behind his fridge-freezer.
So to summarise, for obvious reasons Mr Kebede and Flat 16 on the fourth floor of Grenfell Tower have become, to a certain extent, the centre of attention.
How did the fire start? Who made the first 999 call?
"The fire is thought to have been caused by Mr Kebede's fridge." (Image PA)
"After calling 999 and alerting neighbours Mr Kebede fled the tower." (Image PA) The Times states this was logged at 12.58 am. This was four minutes after the first recorded call to the Fire Brigade at 12.54.
The two images above are taken from a (Daily) Mirror newspaper article on the 21st June, 2018 here: https://www.mirror.co.uk/news/uk-news/grenfell-tower-dad-two-who-12759921
They both claim to show Mr Behailu Kebede leaving the Grenfell Tower building, the inference being that this was after fire had broken out in his flat (Number 16) on the fourth floor of the block.
In both images he appears to be making his way to the entrance/exit as shown by the floor grating holding a mobile phone. However there is clearly a problem and it is a BIG one!
The two locations appear to be different and Mr Kebede is clearly wearing different clothes. So these images must have been taken at different times and they cannot both be of the moment he left the building, post fire.
The question therefore arises, given the sensitive nature of the images, how were they allowed into the public domain and for what purpose; and why given the different times to which they relate, was this and its implications not made clear? If one of the images does not relate to the fire, how can we be sure the other portrays what it purports?
But that is not the only issue thrown up by these images.
In the Times of the 22nd June, 2018, Mr Kebede is quoted as saying, "I banged on the bedroom doors at about the same time as I was calling 999. I then ran out of my flat barefoot, wearing only my boxer shorts and T-shirt. I banged on the front doors of all the five other flats on the fourth floor ... Most understood the urgency and some began screaming."
He continued, "I ended up leaving my flat without any personal possessions. All I had on me were the clothes I was wearing and my mobile phone with which I was calling 999. I left without my shoes, my wallet, my second mobile phone, my flat keys or my car keys."
So what is the problem with this account? In fact there are several serious ones as far as I can tell!
First note the rather strange behaviour and account of what happened. He banged on the bedroom doors in his flat, yet he appears to make no attempt to open the doors to ensure whoever is inside the rooms is made aware of the danger and is physically removed. Who would leave such a thing to chance?
There is no mention of whether the occupants got out safely with him, although separately reported it subsequently transpired he had two female lodgers - Elsa Afeworki and Almaz Kinfu - one of whom had a large silver suitcase that earlier had been assumed to be his. He also claims to have raised the alarm on the landing whilst dialling 999.
Indeed the first 999 call is timed four (4) minutes prior to the second photo above of him leaving barefoot without shoes which might fit, but there is another big problem with this account.
First there is absolutely no collaborative background noise to support the description of what he was doing at the time - i.e. banging doors and shouting warnings, but much more importantly the recorded 12.54 am first 999 call, identifying the room 16 and a problem with the refrigerator is made outside the building! The emergency operator asks the question several times, "Are you outside and safe?" and the caller states clearly and repeats, he is.
Listen to the first 999 call timed at 12.54 am here: https://www.youtube.com/watch?v=IIMMxLK7SMY
The conclusion to be drawn from this is extraordinary and crucial and can only be one of the following:
- the recorded caller misrepresented he was outside the building when he made the call
- Kebede did not call 999 whilst still on the fourth floor but did so when he got outside. The problem with this is that he is videoed still in the building four minutes after the first call is made
Of course it raises secondary questions as to the reliability of Mr Kebede's account and even if the man who made the first call was actually him or someone else entirely!
After all if Kebede was filmed coming down the stairs at 12.58 am, he physically could not have been the person who made the 999 call four minutes prior to that at 12.54 am.
The second photo image of Kebede, if genuine must have been taken four minutes after someone else had phoned from outside!
Did Kebede phone the emergency services at all and if not why was he checking his phone as he came down the steps?
Is it not very strange that no one in police, press or inquiry have noticed this startling fact or sought an explanation for it?
But that is not the only problem highlighted by the two pictures at top of page showing Kebede leaving the building.
Note he said he was wearing only boxer shorts and T-shirt when he abandoned his flat 16 and the fourth floor. However although the second image does show him bare foot he most definitely is not only wearing boxer shorts. He appears to be wearing casual slacks - in fact the same as the ones he is wearing in the first photograph, though with a different top.
Also very strange, neither of these photographs display any sign of panic or even anxiety. There is no suggestion of rush or even the signs of smoke contamination on his clothes. His hands and arms as well as feet show no sign of soot or smoke contamination.
Further in both photographs he is clearly leaving alone. If as he reported he had raised all the other occupants on the floor, surely some would have been leaving with him? And not even his two lodgers with him?
Room photographs show red plastic covering the electric point behind the refrigerator, presumably placed there by the Fire Brigade as it shows no sign of melting with the heat. The sink unit is rather strangely bent upward and is charred under. Was wrenched up by a strong fireman or forced up by some explosive force?
https://www.google.co.uk/search?q=grenfell+tower+images+inside&rlz=1C1ARAB_enGB463GB464&tbm=isch&tbo=u&source=univ&sa=X&ved=0ahUKEwjqooX4yvfbAhXLTMAKHZGmCGsQ7AkINA&biw=1280&bih=891#imgrc=19SIYXRTi3ahkM:
In any event if Mr Kibede was in the flat as described when "white smoke started billowing from behind the fridge/freezer" there is no suggestion he made any attempt to turn off the electrical supply of fight the fire in any way before abandoning the flat and its occupants. Nor do the above photographs support the description below that he was "rushing outside". The photograph rather suggests a certain nonchalance about the whole thing, that is if it can be relied upon.
Flat 16 Interior.
https://www.google.co.uk/search?q=grenfell+tower+images+inside&rlz=1C1ARAB_enGB463GB464&tbm=isch&tbo=u&source=univ&sa=X&ved=0ahUKEwjqooX4yvfbAhXLTMAKHZGmCGsQ7AkINA&biw=1280&bih=891#imgrc=1cahJh316OWA8M:
The fact that the police offered 'witness protection' at an 'unknown address' appears unusual for the victim of a fire or crime and is much more common when regarded as police agent or asset, although I am not suggesting this was the case here.
Grenfell Tower Fire Inquiry: Flat 16 - In pictures
From the Mirror here: https://www.mirror.co.uk/news/uk-news/grenfell-tower-dad-two-who-12759921
"Mr Kebede was woken by the sound of his smoke alarm shortly before 1am on June 14, and found white smoke billowing from behind his fridge-freezer.
He alerted his two female housemates, Elsa Afeworki and Almaz Kinfu, before knocking on every door of the neighbouring flats on the block's fourth floor and then rushing outside.
Suggestions that he caused the fire by tampering with his fridge-freezer or that he had packed a bag before escaping led to safety concerns from the police.
He said in a statement to the inquiry, published on Thursday: "I met a number of officers there. They offered to take me to an unknown address outside London for my own protection.
"They wanted to put me into witness protection because they were concerned about reports in the press that showed me in a negative light, reports suggesting that I was to blame for the fire.""
All recent newspaper reports have repeated the same line that he was not to blame and "did everything he could" to prevent the disaster. Apparently it is unlikely he will be called in person or cross examined by the inquiry currently sitting.
However this should not interfere with sensible consideration of his account to ensure it is in all respects accurate and truthful.
One thing is clear as I have demonstrated above, if the first caller rang the Emergency Services at 12.54 am from outside the building, it could not have been been Mr Kibede as claimed, if the image of him still in the building on the way out at 12.58 is reliable!
Saturday, 23 June 2018
Friday, 22 June 2018
22.6.18 Somerstown Coffee House Fire
Fresh from Canada look who just happens to be in the pub and reports it to the BBC...
And the date is quite interesting too.
"Are you a coincidence theorist?"
A large fire has broken out at a pub near three major railway stations in central London. The London Fire Brigade said it was called to a blaze in Chalton Street, a few hundred metres from Euston, King's Cross and St Pancras, at 20:06 BST.
A spokeswomen for the London Fire Brigade said: “Half of the roof and part of the first floor are alight ... The cause of the fire is not known at this stage.”
Station Manager Steve Chesson, who was at the scene, said: “The pub was open and in use at the time of the fire and a number of people left the building before the brigade arrived.”
The brigade was called at just after 8pm. Fire crews from Soho, Islington, Kentish Town, Shoreditch, Paddington and surrounding fire stations are at the scene.
Corin Faife was in the pub watching a World Cup game when he noticed smoke.
He told BBC News: “Suddenly the fire alarm went off and a staff member told us to get out. The bar staff were running around making sure everybody got out.
“It was a pretty scary situation. We grabbed all of our things and ran out.”
Corin Faife
@corintxt
Freelance journalist working between Canada + UK | co-organizer @HacksHackersMTL | interested in all things tech + accountability | open DM's for tips etc.
Joined November 2011
Talked to two firemen on my way back past the pub, who told me no one was hurt. "But did you manage to get your drinks out with you?", one asked as I walked away. Guess a sense of humour helps in that job...
Street is full of completely shocked drinkers and local kids who don't know what's going on
Jesus christ, was just in the Somerstown Coffee House pub in King's Cross and it caught fire
I'm reluctant to use the term, but being back in London has reminded me that British people really do have more bants.
https://www.youtube.com/channel/UCn8zNIfYAQNdrFRrr8oibKw
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Corin Faife
Corin Faife is a freelancer covering transport, infrastructure, cryptocurrency, and internet freedom for Motherboard. Find him on Twitter @corintxt.
Tuesday, 19 June 2018
Second detailed submission on proposed Penzance Heliport by Tim Veater.
Monday 18th June, 2018.
EXECUTIVE SUMMARY
1. Introduction
This submission should be read in conjunction to my earlier report and the response of 'WYG' to it.
First let me state clearly I have no general objection (subject to the following reservations) to the recorded short-term (ST 1-9) and long-term (LT 1-6) noise measurements that are tabulated in some detail in both 'WYG' reports.
As long as the noise measuring equipment was calibrated and operated properly and the results transferred to paper accurately, they cannot be challenged and should be taken as valid.
This however is not to say they are either accurately reflective of the true background noise level experienced in residential or other sensitive locations or reliable for predicting the actual nuisance value of the proposed helicopter operation for the reasons subsequently detailed below.
Any new survey of ambient noise levels should be located at residential and rural locations at set distances from the proposed site on the same day and at the same times for comparative purposes. It should also include noise sensitive locations such as hospitals/Nursing Homes (e.g. St Teresa's, Tolverth, Ponsandane, W.Cornwall Hospital) and schools (e.g. Ludgvan, Gulval, Newlyn)
In addition these sites should be used to monitor the actual noise of a helicopter operational cycle at the Jelbert Way location, rather than what appears to have been the case, measurements taken elsewhere in dissimilar topographical location and transposed to a theoretical model.
2. Long-term (LT) measuring sites.
It is not clear what the thinking was behind the choice of these six locations. Nor are we aware of the precise location of the measuring equipment. This rather obviously can have a huge impact on the recorded values obtained. The six LT sites are:
LT1 Adj. to Gulval Nursery (Adjoining Long Lane)
LT2 Adj. to Poniou Farm (Adjoining very noisy by-pass)
LT3 Adj. to 59 Godolphin Road (150 yds S. of by-pass)
LT4 Rear Sainsbury's Supermarket (between 2 arterial routes)
LT5 East of Marazion Marsh (Adj. railway line)
LT6 Newtown Lane, Marazion. (Adj. busy feeder road)
Each of the LT sites follow a similar pattern of monitoring between the 14th and 24th July, 2016.
Please note this correlates with the peak season both for background and projected helicopter noise. Again the effect of this is to provide worst case scenario background noise mitigating the added noise from the helicopter.
Sampling periods follow a similar pattern for each of the six sites, namely a short (4 x 1 hr) between 06:30 and 07:30 and 19:30 and 20:30 weekday; about 50 hrs between 07:30 - 19:30 over four days. In addition one sampling day to cover these same time periods (1hr; 12hrs; 1hr) for Saturday and Sunday.
It is difficult work out why it was thought necessary to have two sampling points (LT1 and ST4) only yards apart in Gulval unless to achieve higher sound levels by locating on a steep incline?
Why locate LT6 next the busy road when St Teresa's Nursing Home, set back from the road cried out to be monitored. Both LT2 and LT3 appear to have been positioned as close the noisy Long Rock by-pass as possible. Why place LT5 so close to the HST railway?
It should be noted that ALL these monitoring locations - the exception of LT5 which is positioned close to the HST railway line - are either adjacent or very close to busy roads although LT1 is less so. The consequence of this is to reflect the noise thus produced which is generally much higher than that experienced in most outdoor house garden space, particularly in quiet locations.
The only conclusion that can be drawn from this is that the LT results are skewed and do NOT represent typical domestic property background noise levels. From an expert acoustical point of view, it is hard to see this as other than intentional.
3. Short-term (ST) measuring sites.
In large part these nine (9) locations are subject to the same criticism. Sometimes they duplicate a LT site or may not. As the name suggests they are consistently of shorter duration - usually 15 mins. with variations as in 10/15/20/30/35/40 even one of 120 mins.
The reasons for these variations is not explained but can lead to discrepancies and/or bias.
The locations are as follows:
ST1 Junc. Quay Street and Quay (Adj. main town traffic route)
ST2 Junc. Penare Rd. and Castle Road (Adj. busy HILL junct)
ST3 Junc. Posses Lane and Jelbert Way (Adj. busy road junct)
ST4/LT1 Gulval to east of church (Adj. busy HILL junct)
ST5 Field N. Tolver (Should be quietest of the ST locations)
ST6/LT2 Poniou Farm (Adj. Long Rock by-pass)
ST7 Entrance Chy an Mor (Adj. busy by-pass round-a-bout)
ST8/LT3 48 Darlington Rd (100 yrds S. of by-pass)
ST9/LT5 Marazion Marsh (Aprox. 150 yds SE from rail line)
It should be noted that all these sites with the exception of ST5 are disproportionally influenced by road and/or rail noise. This has the effect of raising the L90 (background) and Leq (average) noise levels against which all future additional helicopter noise is compared and judged.
Note also that none of these monitoring sites attempts to represent domestic gardens, quiet residential areas unaffected by extraneous traffic noise or sensitive locations such as schools or medical establishments.
The importance of this omission cannot be over-stated. It renders all the results and conclusions unreliable.
4. Computer-generated predictions
In the 'WYG' response to the criticisms contained in the independent 'AAD' report and my own, additional comparative information is provided in tabulated form. Two tables relate to weekday and Sunday 12 hr periods on the fifteen sites where noise measurements were taken.
These assumptions may be reliable, but bearing in mind the aphorism "rubbish in, rubbish out", it should be remembered that if the entered parameters are deficient in some way, the predictions will be equally so.
5. Environmental (computer-generated) predictions
In the 'WYG' document a fourth set of figures are introduced labelled "E 2-11" for "Environmental" (I cannot see an 'E 1'!) that are concentrated around ecologically sensitive Marazion Marshes, of which only two appear to be actually measured, namely 'LT6' and 'ST9/LT5'. Again I presume these are predicted based upon the tainted recorded figures and other computer generated parameters that may or may not be valid.
6. Units of measurement
For each of the locations where LT and ST readings were taken five sets of dBA values are recorded and reproduced. At first sight these can be very confusing especially to persons new to the subject. The danger of course is that they are given superficial attention and that conclusions based upon them are adopted without critical examination. Some basic knowledge of their implications is therefore beneficial.
Because the ambient noise environment is continually fluctuating, different units of measurement provide insight into different aspects of sound characteristics. Noise is essentially unwanted, annoying, physically or psychologically harmful sound. Three characteristics are important: the intensity or loudness; frequency characteristics or pitch; and periodicity or how frequently the noise occurs.
Intensity is commonly measured in decibels on a logarithmic scale to make it manageable. This means that pressure doubles with every 3 dB. But loudness is only one aspect and so in interpreting any noise, account must be taken of these additional factors that loudness alone cannot provide. This is particularly important when considering aircraft with their high-pitched or impulsive elements.
The columns 1 - 5 in the 'WYG' Report are therefore as follows:
Column 1 Leq This effectively is the arithmetic average sound level over a sampling period that varies but is defined.
Column 2 Lmax or peak value which is the highest noise level record
Column 3 Lmin or lowest sound level recorded
Column 4 L10 or the level exceeded for 10% of the time
Column 5 L90 or the level exceeded for 90% of the time, which when averaged out provides a figure regarded to approximate to the 'background' noise level
The significance of this is that throughout, 'WYG' has used Leq which is consistently lower than the L90, sometimes by as much as >10 dB (see figures for LT1) This is repeated throughout the six LT sites and the nine ST sites. The long established BS 4142 Method for rating and assessing industrial and commercial sound, recommends using the L90 level but Leq has become the unit of choice.
However if in fact the L90 portrays 'background' noise level better, it might be expected these would have been factored in for comparative purposes. If they turn out to be lower than the Leq throughout this obviously makes a bigger dB gap between the two, indicating greater intrusion and nuisance likelihood.
This consideration is avoided by the "WYG" report.
We would have to conclude that even for the noisiest locations, true background noise levels have really been overestimated by a considerable degree. The helicopter noise will therefore be more intrusive than suggested.
Here are a few examples from the 'WYG' report.
LT1Gulval 07:30-19:30 Week Leq 54.3 L90 43 Lower by 11.3 dB
" " " " Sat " 50.5 " 40 Lower by 10.5 dB
" " " " Sun " 47.7 " 40 Lower by 7.7 dB
Not once in no less than 129 results, is this trend reversed. In other words to varying degrees the L90 background noise is ALWAYS less than the Leq. This is strongly indicative that the background noise is actually much lower than the Leq figure used to support the general argument.
7. Measurement criteria as applied to helicopters.
Helicopters have essentially three sources of noise. The first two are the engine and mechanical gearing or transmission. These tend to be fairly constant but are proportional to engine size and power output/revs. The other is the noise generated by the revolving rotor blades cutting through the air. This element is determined by speed and angle of attack. The latter is both directional and impulsive, which adds to its distinctive and intrusive quality.
In its response, 'WYG' assures us that the noise profile of the AgustaWestland - AW139 (now Leonardo) helicopter was obtained under full load conditions. However the hilltop aerodrome chosen does not replicate the distinctive amphitheatre-like Penzance and Mounts Bay location. The topography may be expected to amplify the sound directed to the south until it has gained altitude. It is not clear whether this has been taken in account in the predictions.
Making direct comparisons between traffic noise and aircraft noise is simply not valid. They are different sorts of noise with a different wave band frequency and characteristics. It is for this very reason that the 2008 Salford University study (1) recommends that "helicopter noise because of its distinctive characteristics should for nuisance calculation purposes, be given a loading of 15 dB over any measured level".
Even the existing optimistic predictions, make the proposal quite impossible to conform to planning (PPG) guidelines that impose restrictions on the approval of noise creating applications. We must ask why the Planning Authority appears to be prepared to ignore these statutory guidelines?
8. Leq as applied to helicopters
Throughout the 'WYG' report, "Leq" has been adopted to represent the noise generated by the helicopter. "Leq - equivalent continuous sound level - is the preferred method to describe sound levels that vary over time, resulting in a single decibel value which takes into account the total sound energy over the period of time of interest."
In other words the noise level when averaged over the measurement time period, whether that be an hour or twelve. It takes little imagination to realise the practical consequence of this. It reduces the absolute dB level to a time-averaged figure, which thereby appears far less intrusive, as compared to the background level already discussed.
This in itself may be acceptable in scientific terms but it is not acceptable in human terms. The reason I say this is because humans will respond to the peak noise levels not the averaged ones.
Now it is true that people may put up with the occasional loud noise that they know will disappear such as a helicopter or jet passing overhead, but the Leq in no way represents the nuisance value of either the short-term peak values as the air craft lands, idles whilst off-loading and taking on passengers, followed by taxiing and take-off, nor the repetition of this occurring seventeen or thirty-four times during a twelve hour period.
So the 'WYG' report is seriously deficient in being wholly reliant on Leq values for the generated aircraft noise and basing all its assumptions as to nuisance on them. At the very least it should have supplemented them with L10 or linear peak figures for a much more rounded view of the likely impact.
9. Noise/movement time line
Nowhere in the 'WYG' is there a graphical representation of the practical impact of flights on the twelve hour period or segments of it. This is a serious oversight. It is one thing to speak in general terms about average noise levels as we have said, quite another to represent graphically the noise/time profile to illustrate how twelve hours a day, seven days a week this distinctive noise profile will be repeated.
The Salford document, contains an example on page eight (Figure 1: Simulated time history (SPL) of sporadic helicopter flyovers compared with 16hr Leq. See below) Although it is not an accurate representation of the prospective Penzance operation it is indicative of what should have been provided.
The following graphs are given for illustrative purposes only.
https://www.google.co.uk/search?q=helicopter+noise+graph&rlz=1C1ARAB_enGB463GB464&tbm=isch&tbo=u&source=univ&sa=X&ved=0ahUKEwiVofT1mN3bAhVlIsAKHW-vBzkQ7AkIRg&biw=1280&bih=891#imgrc=SMDyNMEyjDP29M:
For the following graph note: "If the aircraft noise spectrum has pronounced tonal content, then an additional correction of up to 6.7 dB is added to the perceived noise level (LpN)) to give a tone-corrected perceived noise level LTPN. The total subjective effect of an aircraft’s flyover must take into account the time history of the flight. This is accounted for by integrating the tone-corrected, perceived noise level to produce the effective perceived noise level, LEPN. Full details can be found in the ISO 3891 standard."
https://www.google.co.uk/search?q=helicopter+noise+graph&tbm=isch&tbs=rimg:CSGxc9_1gdV65Ijg-dtObkWedMiQ90ZAgJ1yIiPKfBlxrjVEqZgY8vrwwn997oo-n8jatPDN4Cn0PsqAj-IUo8b-hRCoSCT5205uRZ50yEZ6cme2y9nZJKhIJJD3RkCAnXIgRWmdmUbsuh2oqEgmI8p8GXGuNUREL2cAPX5cmGyoSCSpmBjy-vDCfEVB4eh3LPnpSKhIJ33uij6fyNq0RQxEcjU9xmqEqEgk8M3gKfQ-yoBEZJ6MpmiDjKioSCSP4hSjxv6FEEVDDB2Z8OduN&tbo=u&sa=X&ved=2ahUKEwi48sLwnN3bAhWD0xQKHT6RA3AQ9C96BAgBEBs&biw=1280&bih=891&dpr=1#imgrc=1iYrBNvj7dvKGM:
We have not been informed of the time cycle when the noise first appears, through the landing/unloading/loading process before it taxis and takes off again. At peak times averaged calculations are unlikely to apply. No planning conditions are envisaged to limit the number of flights in any segment of the day as far as I am aware. Noise output at certain times could therefore well exceed the predicted Leqs. The maps indicative of noise impact using contours and other devices are similarly highly suspect and disingenuous.
10. Flightpath noise over peninsula virtually ignored
The 'WYG' report gives virtually no attention to the noise footprint or periodicity of up to 34 flights over the Penwith Peninsula and its settlements, principally St Buryan and Sennen. Very little attention is given to Newlyn either, directly under the flight path. As far as I see the maps do not cover these areas and no recorded background levels were taken in these areas. The two figures given for Newlyn appear to be theoretical predicted and are not compared to the passing peak noise level created.
11. Other pollution and financial aspects
No irrevocable planning decision should be entertained until ALL the ecological, pollution and financial implications have been fully explored. To date this appears not to have been the case. The implications for a greenfield site outside the existing built up area, bird and animal life and the effects on property values affected, are all either not considered or dismissed. This does not do these issues justice.
12. Human heath implications of environmental noise
This critical topic to which local GP Mark Russell has drawn particular attention, has been given scant if any regard. He has pointed out that 15,000 people are potentially affected by the proposed noise and that any noise over 55dBA has recognised well-being and health consequences that are not lightly dismissed.
In 2011 the World Health Organization (WHO) released a report titled ‘Burden of disease from environmental noise’. This study collated data from various large-scale epidemiological studies of environmental noise in Western Europe, collected over a 10-year period.
The authors concluded that ‘there is overwhelming evidence that exposure to environmental noise has adverse effects on the health of the population’ and ranked traffic noise second among environmental threats to public health (the first being air pollution). The authors also noted that while other forms of pollution are decreasing, noise pollution is increasing. (5)(6)(7)
13. Conclusions
REFERENCES
1. https://vtol.org/files/dmfile/ResearchintotheImprovementoftheManagementofHelicopterNoise2.pdf
2. https://nparc.nrc-cnrc.gc.ca/eng/view/fulltext/?id=5b4e1fb6-bf62-4d92-b70c-6e6be4d2f2fe
3. Typical sound of helicopter here: https://www.youtube.com/watch?v=2TMTWAwktbc
4. file:///C:/Users/User/Downloads/TCDS_EASA_R006_LH_AW139_Issue20.pdf
5. https://www.science.org.au/curious/earth-environment/health-effects-environmental-noise-pollution
6. https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/372165/11-Quality_of_life--quality-of-life-assessment.pdf
7. https://www.researchgate.net/publication/286412976_Living_with_aircraft_noise_Airport_proximity_aviation_noise_and_subjective_wellbeing_in_England "The negative association between aircraft noise and peoples’ sense of worthwhile (b = 0.126, p < 0.01) was around half that associated with being a smoker"
8. http://www.richardbuxton.co.uk/what-we-do/aircraft-noise "In relation to compensation under the Land Compensation Act 1973 for new development at Plymouth City Airport, we intervened in a case which was about to be conceded by the government in favour of the airport, enabling residents to obtain compensation for helicopter operations."
9. http://www.airportwatch.org.uk/2017/09/plane-justice-ltd-v-caa-gatwick-route-4-court-case-passes-its-first-big-test/
EARLIER SUBMISSION
Penzance Heliport Application, PA16/09346.
1.0 Introduction
This is a somewhat belated and 'rear-guard' submission, by a resident who has only recently
I would submit the application should be refused for a catalogue of cogent reasons but
3.0 Experience
Perhaps I may first be allowed to point out the not insubstantial grounds of experience and
I have owned and lived in my existing property, less than half a mile to the NE from the
From a professional point of view I speak from over forty years of local government service
3.0 Principal Grounds for Objection
3.2 An existing airport with approved fixed wing and helicopter at Lands End fatally undermines the commercial case for an additional facility at Penzance. If the former operation was un-viable without this competition, how can the proposed new one be with all its increased start-up costs? (6)
3.3 The proposed location is a green field site of high agricultural and archaeological value being the site of a recently discovered Bronze Age barrow which has been partially excavated. (7) Overriding need must be demonstrated if these two criteria are to be ignored;
3.4 The proposal is contrary to the Cornwall Local Plan and Draft Neighbourhood Development Plan and will permanently change the status of the site from agricultural to commercial with all that entails, extending the built up area to the east. Again an over-riding need must be established to over-ride this; (8)
3.5 The visual and amenity impact will be adverse and immense, particularly as regards building and hundreds of parked cars, besides obviously the nuisance value of noise and other pollution from continuously arriving and departing aircraft;
3.6 It will add to road traffic congestion and pollution at that location;
3.7 The helicopter itself will create noise and pollution, seriously affecting the health and well being of a substantial number of properties within a mile radius and under the flight path. The adverse consequences on well-being, health and property valuation in these affected areas has not been addressed but is likely to be not insignificant. (A comprehensive academic review of the issues can be found here. (9))
3.8 The legal obligation for an Environmental Impact Assessment (EIA) has not been adequately fulfilled and the Noise Assessment submitted by the applicant is inherently biased and unreliable. (10)
In both instances it would be in the interests of the applicant to play down this figure and whether by default or intentionality, I believe that is what the Tresco commissioned "WYG" "Noise and Vibration Assessment" dated January, 2018, has achieved. Because of fundamental faults in measurement methodology their conclusions are unreliable and misleading.
The source noise may have been underestimated and by choosing sampling locations by sources of traffic noise, ensuring they are much higher than quiet residential or rural positions. By this sleight of hand they predict an increase in noise of 8.4 dBA, which although significant (perceived as a subjective doubling of noise) they not unsurprising conclude "is not considered to be significant during daytime hours".
My opinion is thoroughly and professionally backed by a separately commissioned "Review of WYG Noise & Vibration Assessment? by acoustic expert John Sim of AAD (Applied Acoustic Design). (10) This states, "There have been a limited number of measurement locations used to set baseline noise levels most of which are around Gulval, Longrock and Marazion. There are two in the main Penzance area, Lecudjack Hill (ST2) and Penzance Quay (ST1)" and that these are not representative of quieter residential and rural locations.
This is clearly designed to suggest background noise levels are higher and thereby reduce any apparent increase created by helicopter operations.
Further it would appear that "WYG" have used a noisy location at The Quay in Penzance, extrapolated without measurement, to the much quieter location at Trewarveneth Street in Newlyn. Not only is this bad science, you may well conclude this is unethical and deceptive, rendering the whole report unreliable!
This is not an isolated case as the AAD reveals but typical of the whole approach by the WYG report. To quote Mr Sim's assessment:
"Baseline ambient noise levels at R1 are likely to be significantly lower than the 64 dB LAeq, T values assumed, the only receiver locations with similar high levels of noise are at R5 and R6. These are receiver locations between about 80m and 50m of the A30. This cannot be correct. Drawings SK03 and SK04 show that the area around R1 and around R2 are the most affected in terms of noise from the over-flight of helicopters outside of the area around the proposed heliport location. It is therefore further not understood why no baseline noise measurements were made in Bowjey or other residential areas in southern half of Newlyn."
He adds regarding other measurements: "Again assuming the A30 road traffic to be the primary noise source in this area one would expect at location R25, at 340m from the A30, that the weekday baseline noise level would be around 45 dB LAeq, T but the weekday baseline is give as 55.5 dB LAeq, T, the same as at R23 and R25."
The result is that, "weekday contribution at location R25 could be 10 dB rather than the reported 0.3 dB" - a huge difference. For the 700 people living within 1km the report predicts a doubling of intensity of noise pollution.
6.0 Specific examples of unreliable or manipulated results
Located close to my address there were apparently two noise sampling points that specifically demonstrate the unreliability of the results on which the conclusion that the new helicopter service will not cause noise nuisance are based. The first is at Poniou Farm (LT2) which is immediately adjacent to the A30 Long Rock bypass, which by virtue of the frequency (some 65,000 traffic movements per 18hr day!) the speed and characteristics of traffic, and the concrete not tarmac road surface, is very noisy.
6.1 Results at LT2/R17 Poniou Farm
LAeq,T (dB) LAmax,T (dB) LAmin,T (dB) LA10,T (dB) LA90,T (dB)
Weekday Early Morning 06:30 - 07:30 4 hours 14/07/2016 - 20/07/2016
Results at LT2 Poniou Farm interpreted.
Close to a road, noises are heard as individual sources in contrast from a distance away, when they become more merged as a point source with less variation. The first column represents Leq, which is sound pressure averaged over the sampling period. As might be expected this is highest during a working week day and the figure of 55.3 dB is used as the background figure for this location for comparative purposes.
It should be noted that the average figure for a Sunday is 5.4 dB less, but no account of this is made in respect of the nuisance value of proposed Sunday flights. As can be seen from the second column that records peak values of passing vehicles (eg speeding motor bikes) these can be exceedingly noisy - well over 80dB, well past that which can cause occupational deafness in the longer term.
To summarise, this is a noisy location that is not representative of much quieter locations which has the effect of appearing to make the additional noise of a helicopter less intrusive, which seems to be the reason it was chosen rather than (or in addition to) another set back further such as at 'Pleming'. Nor is any account taken of the lower recorded values on a Saturday or Sunday or for 90% of the time (last column).
6.2 Results at ST5/R13 Tolver Farm
This also applies to locomotive movements on the railway in the vicinity of the Long Rock level crossing roughly half a mile to the south. Other sources of noise are passing aeroplanes and helicopters, periodic heavy duty agricultural activity in the fields, lane traffic recently significantly increased by commercial development locally and on occasions the noise of bird scarers.
However all of these are very temporary in nature and not to be compared with the almost continuous (about every 25 mins) noise of helicopters landing, idling whilst passengers disembark and load, then taking off again.
LAeq,T (dB) LAmax,T (dB) LAmin,T (dB) LA10,T (dB) LA90,T (dB)
Evening 35 Mins 14/07/2016 19:53
Unlike the results for LT2 above, the methodology at this site was quite different. The eight
As can be seen despite some anomalous peaks, the noise level for 90% of the sampling
All the sampling periods were taken over a four day period in July 2016. Living next door
Of course without these anomalous peaks the Leq (average) and L90 would have been
What is absolutely clear is that in this location, where background noise averages out at
7.0 Noise at source
A map of the route and 'noise sensitive sites' is provided in the WYG report but what is
Needless to say fuel burn and pollution is greater as the aircraft takes off or is hovering and
10.0 CONCLUSIONS
"Local planning authorities’ plan-making and decision taking should take account of the acoustic environment and in doing so consider:
2. "Environment Secretary, Michael Gove said: “Air pollution remains a significant threat to public health and we are committed to tackling its causes and improving air quality. This is why we are signing up to the amended Gothenburg Protocol and will shortly build on our £3.5bn plan to tackle roadside emissions by publishing a comprehensive Clean Air Strategy.” https://www.gov.uk/government/news/uk-to-ratify-international-protocol-to-reduce-air-pollution
Monday 18th June, 2018.
EXECUTIVE SUMMARY
- A well known aphorism states, "There are lies, damn lies and statistics." The same could be said of the treatment and interpretation of physical data and its measurement.
- Great reliance has been placed upon a report by acoustic experts 'WYG' employed by the applicant for the proposed Penzance Heliport, Tresco Estate, but despite its factual content being accurate, its overall assessment that the increase in noise "is not considered to be significant" is unreliable and misleading.
- This is achieved in essentially two ways: by the playing up of background noise and the playing down of helicopter source noise.
- The choice of monitoring points is critical. The fifteen chosen for long (LT) and short (ST) term measurement appear to have been chosen to unduly reflect road noise and are therefore not truly representative of the much quieter residential or rural acoustic environment. All other predictions are based on theoretical modelling that depend for their accuracy on the reliability of the input data.
- The chosen criteria of measurement (Leq) used throughout, although scientifically acceptable, is an arithmetical average over a given period. This has the effect of giving the appearance of higher background noise and lower source noise. As the projections of nuisance and health impacts are based upon the difference between the two, the adoption of this measurement unit is critical.
- The 'WYG' report chooses to ignore completely the expert opinion that any assessment of helicopter noise should include a loading of up to 15 dB to take account of its unique and impulsive characteristics. (1) For this reason it is inappropriate to make direct comparisons between traffic and helicopter noise without qualification.
- A more accurate picture of nuisance and health consequences would be given if in addition to Leq units, peak noise levels are compared with L90 background levels. The difference between the two is immense.
- Although the application is for 17 flights a day, the fact that this actually involves 34 passing trips over the Penwith Peninsula, landings and take-offs is virtually ignored. Nor is irregular frequency of flights within the 12 hour window discussed.
- Proposed conditions are significantly relaxed in comparison to the previous operation. In particular the inclusion of Sunday flying cannot be justified in any way.
- The report gives absolutely no consideration to the proven psychological and physical adverse effects of environmental noise or the depressing effect of noise on the quality and value of property adversely affected estimated to be in the region of 2% per decibel.
- Little attention is given to other environmental impacts such as the smell and pollution from turbine engine exhaust or the use of hydrocarbons and their by-products contrary to Government objectives.
1. Introduction
This submission should be read in conjunction to my earlier report and the response of 'WYG' to it.
First let me state clearly I have no general objection (subject to the following reservations) to the recorded short-term (ST 1-9) and long-term (LT 1-6) noise measurements that are tabulated in some detail in both 'WYG' reports.
As long as the noise measuring equipment was calibrated and operated properly and the results transferred to paper accurately, they cannot be challenged and should be taken as valid.
This however is not to say they are either accurately reflective of the true background noise level experienced in residential or other sensitive locations or reliable for predicting the actual nuisance value of the proposed helicopter operation for the reasons subsequently detailed below.
Any new survey of ambient noise levels should be located at residential and rural locations at set distances from the proposed site on the same day and at the same times for comparative purposes. It should also include noise sensitive locations such as hospitals/Nursing Homes (e.g. St Teresa's, Tolverth, Ponsandane, W.Cornwall Hospital) and schools (e.g. Ludgvan, Gulval, Newlyn)
In addition these sites should be used to monitor the actual noise of a helicopter operational cycle at the Jelbert Way location, rather than what appears to have been the case, measurements taken elsewhere in dissimilar topographical location and transposed to a theoretical model.
2. Long-term (LT) measuring sites.
It is not clear what the thinking was behind the choice of these six locations. Nor are we aware of the precise location of the measuring equipment. This rather obviously can have a huge impact on the recorded values obtained. The six LT sites are:
LT1 Adj. to Gulval Nursery (Adjoining Long Lane)
LT2 Adj. to Poniou Farm (Adjoining very noisy by-pass)
LT3 Adj. to 59 Godolphin Road (150 yds S. of by-pass)
LT4 Rear Sainsbury's Supermarket (between 2 arterial routes)
LT5 East of Marazion Marsh (Adj. railway line)
LT6 Newtown Lane, Marazion. (Adj. busy feeder road)
Each of the LT sites follow a similar pattern of monitoring between the 14th and 24th July, 2016.
Please note this correlates with the peak season both for background and projected helicopter noise. Again the effect of this is to provide worst case scenario background noise mitigating the added noise from the helicopter.
Sampling periods follow a similar pattern for each of the six sites, namely a short (4 x 1 hr) between 06:30 and 07:30 and 19:30 and 20:30 weekday; about 50 hrs between 07:30 - 19:30 over four days. In addition one sampling day to cover these same time periods (1hr; 12hrs; 1hr) for Saturday and Sunday.
It is difficult work out why it was thought necessary to have two sampling points (LT1 and ST4) only yards apart in Gulval unless to achieve higher sound levels by locating on a steep incline?
Why locate LT6 next the busy road when St Teresa's Nursing Home, set back from the road cried out to be monitored. Both LT2 and LT3 appear to have been positioned as close the noisy Long Rock by-pass as possible. Why place LT5 so close to the HST railway?
It should be noted that ALL these monitoring locations - the exception of LT5 which is positioned close to the HST railway line - are either adjacent or very close to busy roads although LT1 is less so. The consequence of this is to reflect the noise thus produced which is generally much higher than that experienced in most outdoor house garden space, particularly in quiet locations.
The only conclusion that can be drawn from this is that the LT results are skewed and do NOT represent typical domestic property background noise levels. From an expert acoustical point of view, it is hard to see this as other than intentional.
3. Short-term (ST) measuring sites.
In large part these nine (9) locations are subject to the same criticism. Sometimes they duplicate a LT site or may not. As the name suggests they are consistently of shorter duration - usually 15 mins. with variations as in 10/15/20/30/35/40 even one of 120 mins.
The reasons for these variations is not explained but can lead to discrepancies and/or bias.
The locations are as follows:
ST1 Junc. Quay Street and Quay (Adj. main town traffic route)
ST2 Junc. Penare Rd. and Castle Road (Adj. busy HILL junct)
ST3 Junc. Posses Lane and Jelbert Way (Adj. busy road junct)
ST4/LT1 Gulval to east of church (Adj. busy HILL junct)
ST5 Field N. Tolver (Should be quietest of the ST locations)
ST6/LT2 Poniou Farm (Adj. Long Rock by-pass)
ST7 Entrance Chy an Mor (Adj. busy by-pass round-a-bout)
ST8/LT3 48 Darlington Rd (100 yrds S. of by-pass)
ST9/LT5 Marazion Marsh (Aprox. 150 yds SE from rail line)
It should be noted that all these sites with the exception of ST5 are disproportionally influenced by road and/or rail noise. This has the effect of raising the L90 (background) and Leq (average) noise levels against which all future additional helicopter noise is compared and judged.
Note also that none of these monitoring sites attempts to represent domestic gardens, quiet residential areas unaffected by extraneous traffic noise or sensitive locations such as schools or medical establishments.
The importance of this omission cannot be over-stated. It renders all the results and conclusions unreliable.
4. Computer-generated predictions
The 'WYG' report uses a third category of noise measurements that are not measured but predicted on the basis of computer programmes and algorithms. These are listed (R 1 - 25) and are clearly dependent on the multiple variables on which they are based.
In the 'WYG' response to the criticisms contained in the independent 'AAD' report and my own, additional comparative information is provided in tabulated form. Two tables relate to weekday and Sunday 12 hr periods on the fifteen sites where noise measurements were taken.
In a majority of these cases the sensitivity model produces results which are slightly lower than the recorded ones, which apart from two, vary by no more than +/- 2.1 which it is claimed "verifies the method". Whether this is statistically significant is not determined.
These assumptions may be reliable, but bearing in mind the aphorism "rubbish in, rubbish out", it should be remembered that if the entered parameters are deficient in some way, the predictions will be equally so.
I am not clear what the methodology was for choosing these sites or predicting the noise levels at them, nor is it anywhere explained as far as I can see. However the majority appear to replicate locations where traffic noise can be expected to have a large contribution, making any notional additional input from the helicopter less pronounced.
5. Environmental (computer-generated) predictions
In the 'WYG' document a fourth set of figures are introduced labelled "E 2-11" for "Environmental" (I cannot see an 'E 1'!) that are concentrated around ecologically sensitive Marazion Marshes, of which only two appear to be actually measured, namely 'LT6' and 'ST9/LT5'. Again I presume these are predicted based upon the tainted recorded figures and other computer generated parameters that may or may not be valid.
6. Units of measurement
For each of the locations where LT and ST readings were taken five sets of dBA values are recorded and reproduced. At first sight these can be very confusing especially to persons new to the subject. The danger of course is that they are given superficial attention and that conclusions based upon them are adopted without critical examination. Some basic knowledge of their implications is therefore beneficial.
Because the ambient noise environment is continually fluctuating, different units of measurement provide insight into different aspects of sound characteristics. Noise is essentially unwanted, annoying, physically or psychologically harmful sound. Three characteristics are important: the intensity or loudness; frequency characteristics or pitch; and periodicity or how frequently the noise occurs.
Intensity is commonly measured in decibels on a logarithmic scale to make it manageable. This means that pressure doubles with every 3 dB. But loudness is only one aspect and so in interpreting any noise, account must be taken of these additional factors that loudness alone cannot provide. This is particularly important when considering aircraft with their high-pitched or impulsive elements.
Column 1 Leq This effectively is the arithmetic average sound level over a sampling period that varies but is defined.
Column 2 Lmax or peak value which is the highest noise level record
Column 3 Lmin or lowest sound level recorded
Column 4 L10 or the level exceeded for 10% of the time
Column 5 L90 or the level exceeded for 90% of the time, which when averaged out provides a figure regarded to approximate to the 'background' noise level
The significance of this is that throughout, 'WYG' has used Leq which is consistently lower than the L90, sometimes by as much as >10 dB (see figures for LT1) This is repeated throughout the six LT sites and the nine ST sites. The long established BS 4142 Method for rating and assessing industrial and commercial sound, recommends using the L90 level but Leq has become the unit of choice.
However if in fact the L90 portrays 'background' noise level better, it might be expected these would have been factored in for comparative purposes. If they turn out to be lower than the Leq throughout this obviously makes a bigger dB gap between the two, indicating greater intrusion and nuisance likelihood.
This consideration is avoided by the "WYG" report.
We would have to conclude that even for the noisiest locations, true background noise levels have really been overestimated by a considerable degree. The helicopter noise will therefore be more intrusive than suggested.
Here are a few examples from the 'WYG' report.
LT1Gulval 07:30-19:30 Week Leq 54.3 L90 43 Lower by 11.3 dB
" " " " Sat " 50.5 " 40 Lower by 10.5 dB
" " " " Sun " 47.7 " 40 Lower by 7.7 dB
Not once in no less than 129 results, is this trend reversed. In other words to varying degrees the L90 background noise is ALWAYS less than the Leq. This is strongly indicative that the background noise is actually much lower than the Leq figure used to support the general argument.
7. Measurement criteria as applied to helicopters.
Helicopters have essentially three sources of noise. The first two are the engine and mechanical gearing or transmission. These tend to be fairly constant but are proportional to engine size and power output/revs. The other is the noise generated by the revolving rotor blades cutting through the air. This element is determined by speed and angle of attack. The latter is both directional and impulsive, which adds to its distinctive and intrusive quality.
In its response, 'WYG' assures us that the noise profile of the AgustaWestland - AW139 (now Leonardo) helicopter was obtained under full load conditions. However the hilltop aerodrome chosen does not replicate the distinctive amphitheatre-like Penzance and Mounts Bay location. The topography may be expected to amplify the sound directed to the south until it has gained altitude. It is not clear whether this has been taken in account in the predictions.
Making direct comparisons between traffic noise and aircraft noise is simply not valid. They are different sorts of noise with a different wave band frequency and characteristics. It is for this very reason that the 2008 Salford University study (1) recommends that "helicopter noise because of its distinctive characteristics should for nuisance calculation purposes, be given a loading of 15 dB over any measured level".
Even the existing optimistic predictions, make the proposal quite impossible to conform to planning (PPG) guidelines that impose restrictions on the approval of noise creating applications. We must ask why the Planning Authority appears to be prepared to ignore these statutory guidelines?
8. Leq as applied to helicopters
Throughout the 'WYG' report, "Leq" has been adopted to represent the noise generated by the helicopter. "Leq - equivalent continuous sound level - is the preferred method to describe sound levels that vary over time, resulting in a single decibel value which takes into account the total sound energy over the period of time of interest."
In other words the noise level when averaged over the measurement time period, whether that be an hour or twelve. It takes little imagination to realise the practical consequence of this. It reduces the absolute dB level to a time-averaged figure, which thereby appears far less intrusive, as compared to the background level already discussed.
This in itself may be acceptable in scientific terms but it is not acceptable in human terms. The reason I say this is because humans will respond to the peak noise levels not the averaged ones.
Now it is true that people may put up with the occasional loud noise that they know will disappear such as a helicopter or jet passing overhead, but the Leq in no way represents the nuisance value of either the short-term peak values as the air craft lands, idles whilst off-loading and taking on passengers, followed by taxiing and take-off, nor the repetition of this occurring seventeen or thirty-four times during a twelve hour period.
So the 'WYG' report is seriously deficient in being wholly reliant on Leq values for the generated aircraft noise and basing all its assumptions as to nuisance on them. At the very least it should have supplemented them with L10 or linear peak figures for a much more rounded view of the likely impact.
9. Noise/movement time line
Nowhere in the 'WYG' is there a graphical representation of the practical impact of flights on the twelve hour period or segments of it. This is a serious oversight. It is one thing to speak in general terms about average noise levels as we have said, quite another to represent graphically the noise/time profile to illustrate how twelve hours a day, seven days a week this distinctive noise profile will be repeated.
The Salford document, contains an example on page eight (Figure 1: Simulated time history (SPL) of sporadic helicopter flyovers compared with 16hr Leq. See below) Although it is not an accurate representation of the prospective Penzance operation it is indicative of what should have been provided.
The following graphs are given for illustrative purposes only.
https://www.google.co.uk/search?q=helicopter+noise+graph&rlz=1C1ARAB_enGB463GB464&tbm=isch&tbo=u&source=univ&sa=X&ved=0ahUKEwiVofT1mN3bAhVlIsAKHW-vBzkQ7AkIRg&biw=1280&bih=891#imgrc=SMDyNMEyjDP29M:
For the following graph note: "If the aircraft noise spectrum has pronounced tonal content, then an additional correction of up to 6.7 dB is added to the perceived noise level (LpN)) to give a tone-corrected perceived noise level LTPN. The total subjective effect of an aircraft’s flyover must take into account the time history of the flight. This is accounted for by integrating the tone-corrected, perceived noise level to produce the effective perceived noise level, LEPN. Full details can be found in the ISO 3891 standard."
https://www.google.co.uk/search?q=helicopter+noise+graph&tbm=isch&tbs=rimg:CSGxc9_1gdV65Ijg-dtObkWedMiQ90ZAgJ1yIiPKfBlxrjVEqZgY8vrwwn997oo-n8jatPDN4Cn0PsqAj-IUo8b-hRCoSCT5205uRZ50yEZ6cme2y9nZJKhIJJD3RkCAnXIgRWmdmUbsuh2oqEgmI8p8GXGuNUREL2cAPX5cmGyoSCSpmBjy-vDCfEVB4eh3LPnpSKhIJ33uij6fyNq0RQxEcjU9xmqEqEgk8M3gKfQ-yoBEZJ6MpmiDjKioSCSP4hSjxv6FEEVDDB2Z8OduN&tbo=u&sa=X&ved=2ahUKEwi48sLwnN3bAhWD0xQKHT6RA3AQ9C96BAgBEBs&biw=1280&bih=891&dpr=1#imgrc=1iYrBNvj7dvKGM:
We have not been informed of the time cycle when the noise first appears, through the landing/unloading/loading process before it taxis and takes off again. At peak times averaged calculations are unlikely to apply. No planning conditions are envisaged to limit the number of flights in any segment of the day as far as I am aware. Noise output at certain times could therefore well exceed the predicted Leqs. The maps indicative of noise impact using contours and other devices are similarly highly suspect and disingenuous.
10. Flightpath noise over peninsula virtually ignored
The 'WYG' report gives virtually no attention to the noise footprint or periodicity of up to 34 flights over the Penwith Peninsula and its settlements, principally St Buryan and Sennen. Very little attention is given to Newlyn either, directly under the flight path. As far as I see the maps do not cover these areas and no recorded background levels were taken in these areas. The two figures given for Newlyn appear to be theoretical predicted and are not compared to the passing peak noise level created.
11. Other pollution and financial aspects
No irrevocable planning decision should be entertained until ALL the ecological, pollution and financial implications have been fully explored. To date this appears not to have been the case. The implications for a greenfield site outside the existing built up area, bird and animal life and the effects on property values affected, are all either not considered or dismissed. This does not do these issues justice.
12. Human heath implications of environmental noise
This critical topic to which local GP Mark Russell has drawn particular attention, has been given scant if any regard. He has pointed out that 15,000 people are potentially affected by the proposed noise and that any noise over 55dBA has recognised well-being and health consequences that are not lightly dismissed.
In 2011 the World Health Organization (WHO) released a report titled ‘Burden of disease from environmental noise’. This study collated data from various large-scale epidemiological studies of environmental noise in Western Europe, collected over a 10-year period.
The authors concluded that ‘there is overwhelming evidence that exposure to environmental noise has adverse effects on the health of the population’ and ranked traffic noise second among environmental threats to public health (the first being air pollution). The authors also noted that while other forms of pollution are decreasing, noise pollution is increasing. (5)(6)(7)
13. Conclusions
- The choice of the 15 monitoring sites and the results from them though accurate, give a misleading impression of background noise levels because they are disproportionately influenced by their proximity to traffic routes.
- As a result the background noise levels against which the helicopter noise is judged is unrepresentative of the true rural and residential noise levels experienced. This completely undermines the whole rationale and conclusions of the report.
- The conclusion that there will be no significant impact by the imported helicopter noise is made using only the Leq unit of measurement, which being an arithmetic average, plays up background noise (as compared to L90) and plays down the helicopter noise because total energy is averaged over a 12 hour period. It in no way represents therefore the health and nuisance aspects of periodic (<34 times per day) peak noise input to a much quieter environment than predicted.
- Insufficient weight has been afforded to the extent of potential financial, nuisance, well-being, psychological and physical health impacts of the increase in noise and other pollution.
- A failure to properly consider these issues within the context of a fresh independent approach to obtaining and interpreting monitored results prior to making any irrevocable planning decision could render the Cornwall Council to a further Judicial Review. (8) (9)
14. Recommendations
- The planning application should be deferred until the issues in this document are addressed.
- A new noise monitoring exercise should be carried out at rural and residential sites that accurately reflect true ambient noise levels
- Any new assessment should provide accurate background and peak noise values to accurately predict the intrusiveness and annoyance of the proposed helicopter noise
- Proper weight should be given to other pollution, economic, ecological, psychological and physical health consequences prior to any planning decision on the matter.
REFERENCES
1. https://vtol.org/files/dmfile/ResearchintotheImprovementoftheManagementofHelicopterNoise2.pdf
2. https://nparc.nrc-cnrc.gc.ca/eng/view/fulltext/?id=5b4e1fb6-bf62-4d92-b70c-6e6be4d2f2fe
3. Typical sound of helicopter here: https://www.youtube.com/watch?v=2TMTWAwktbc
4. file:///C:/Users/User/Downloads/TCDS_EASA_R006_LH_AW139_Issue20.pdf
5. https://www.science.org.au/curious/earth-environment/health-effects-environmental-noise-pollution
6. https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/372165/11-Quality_of_life--quality-of-life-assessment.pdf
7. https://www.researchgate.net/publication/286412976_Living_with_aircraft_noise_Airport_proximity_aviation_noise_and_subjective_wellbeing_in_England "The negative association between aircraft noise and peoples’ sense of worthwhile (b = 0.126, p < 0.01) was around half that associated with being a smoker"
8. http://www.richardbuxton.co.uk/what-we-do/aircraft-noise "In relation to compensation under the Land Compensation Act 1973 for new development at Plymouth City Airport, we intervened in a case which was about to be conceded by the government in favour of the airport, enabling residents to obtain compensation for helicopter operations."
9. http://www.airportwatch.org.uk/2017/09/plane-justice-ltd-v-caa-gatwick-route-4-court-case-passes-its-first-big-test/
EARLIER SUBMISSION
Members
of the Strategic Planning Committee.
The
Chief Planning Officer.
The
Chief Environmental Health Officer.
Dear
Sir/Madam,
Penzance Heliport Application, PA16/09346.
Strategic
Planning Committee, 28th June, 2018.
1.0 Introduction
This is a somewhat belated and 'rear-guard' submission, by a resident who has only recently
become
alarmed at the likely devastating impact of the above application, on
the quiet
enjoyment
of his property and locality. If approved in accordance with the
current criteria, it
will have
a permanent and significant detrimental effect, made worse by the
fact that normal
legal
avenues for compensation and abatement of nuisance, are virtually all
blocked by
statute, if
and when planning permission is given.
I would submit the application should be refused for a catalogue of cogent reasons but
if despite
this, the Planning Authority chooses to approve it, only stringent
conditions
can
make it tolerable. In
no event should these be more lax than those applying to the
former
operation that ceased in 2012 because it was considered
commercially un-viable.
Specifically
but not exclusively, this should at least rule out flights on a
Sunday and operate
within
the same time framework.
- Noise and its Measurement
Rather
akin to the definition of “weeds” - “plants in the wrong place”
- “noise” is just “unwanted and/or harmful sound”. In this
sense it is always a subjective human response but of course even if
there were no humans in the world, there would still be 'sound',
created and heard by the natural world. Beethoven perhaps illustrates
both the value of created sound in the form of majestic music, whilst
demonstrating the implicit tragic results in the loss of the human
facility to hear.
Noise
is a form of physical energy that requires a source, a medium and a
receptor and will vary in intensity (loudness) and characteristics,
from which we determine from experience the likely cause. Just as
light is a spectrum, so any noise contains within it a range of
frequencies from low to high, analogous to the notes on a piano.
Humans with their usual ingenuity, have not only created the machines
that generate noise but also the machines to measure it, which has in
turn created the science of 'acoustics' by which standards and
judgements are made.
Noise
by definition is either annoying or harmful to humans. It has become
ever more a ubiquitous feature of modern life. Public bodies are
urged to be alert to the need to control unwanted sound but often in
their decision making, do the exact opposite, making the problem
worse. That will unavoidably be the case if the Penzance Heliport
application is approved. Its adverse consequences should not be
underestimated.
Everybody
knows sustained high levels of noise (roughly over 85dBA) can cause
occupational deafness, but what is less well known is that levels
well short of this can seriously impinge on psychological well-being
and actually reduce life expectancy from a range of other medical
conditions (See: Ref. 11 below) It is generally agreed that where a
noise is subjectively twice that of the background noise environment,
nuisance will be caused. This equates to 10dBA but other factors such
as the characteristics of the noise, its frequency, periodicity, the
susceptibility of the receptor and time of day can increase or reduce
the problem.
The
decibel (dB) scale is logarithmic. This means that sound pressure
doubles with every 3dB. The human ear accommodates this and explains
why it only appears to have doubled at 10dB despite actually
being nearly eight times the physical intensity. The significance
of this fact becomes clearer when the applicant claims the helicopter
will add only 8.4 dB to the acoustical environment. I believe this to
be false and a misrepresentation resulting from methodological errors
to down-play the impact. It should also be noted that the use of
certain recognised measurement indices, notably 'Leq', averages
out sound over a time period. It therefore inherently
underestimates the noise created during the actual activity of
landing, idling and taking off.
It
is in this general context that The Civil Aviation
Authority's observation should be understood:
“Helicopter
noise is far more complex to measure and assess than fixed-wing
aircraft noise. This is mainly because helicopters often don’t have
to follow predefined routes, like fixed wing aircraft, and because
helicopters may hover over a specific area for a while making the
impact of the noise last for longer. Also, variations in the speed of
the rotor blades means that the way noise travels also varies, and
results in an asymmetric noise distribution, i.e. different noise
levels from one side of a helicopter to the other.” (13)
3.0 Experience
Perhaps I may first be allowed to point out the not insubstantial grounds of experience and
technical
competence from which I speak.
I have owned and lived in my existing property, less than half a mile to the NE from the
proposed
site, for over forty years. Although the noise
of trains and traffic intrudes to a
greater
or lesser extent depending on climatic conditions, it is a
relatively quiet and peaceful
rural
location. I therefore know what impact the previous helicopter
operation made. At times,
particularly
during extended idling or hovering, the noise was previously
intolerable. In
addition
the smell of burnt aviation fuel was also a nuisance. There
is no reason to suppose
these circumstances
will not be repeated, indeed to a greater extent because the proposed
site is
closer and the
proposed operation more intensive.
During
this time I have also witnessed a deterioration in the acoustic and
natural environment. With the exception of helicopter noise from
2012, when the last operation folded, noise from other sources has
increased with the introduction of the Long Rock by-pass, more
traffic, noisier trains and agricultural plant and local commercial
developments sometimes involving loud music. Meanwhile there has been
a marked change in agricultural practice with numerous old farms
being replaced by intensive farming which is probably responsible for
a marked decline in plant and animal diversity. Bees seem to have
disappeared. The number and variety of birds appears to have
declined, with some species that were formerly always in appearance
such as Curlews and Lapwings are no longer to be seen or heard.
Swallow numbers are only a fraction of what they were. The extent
to which human mechanical activity has contributed to this, is open
to debate, but one thing is clear, the reintroduction of constant
helicopter noise can only make matters worse.
From a professional point of view I speak from over forty years of local government service
that
centred on environmental, safety and health issues. I qualified as an
Environmental
Health Officer
(after four years of study) in 1972. I hold recognised Diploma
qualifications in
Environmental
Health, Health and Safety and Noise Control. I also hold the
degrees of BA
and MPhil
in related disciplines and a Post Graduate Diploma in the Philosophy
of Health
Care
from the University of Swansea. At various times I have held the
posts of Research
Fellow
in the the Leeds Polytechnic School of Law, Senior Lecturer in
Envir. Health at the
College
of NE London and Principal Environmental Health Officer at
N.Cornwall District
Council.
I have also been the Health and Safety Advisor to private
undertakings. In the
process
I have been responsible for investigating accidents and
incidents, including noise
and
other nuisance cases, up to and including fatalities.This
actually included at one time
in
the late seventies the monitoring of noise from the
previous helicopter operation! I mention
all
this merely to lend credence to my observations here.
3.0 Principal Grounds for Objection
3.1
This application is fundamentally at odds with the Government's
stated objectives of reducing noise, (1) atmospheric pollution
(2) and CO2, (3) whilst strengthening planning controls
(4) and enhancing the rural environment. (5) It runs
counter to all of them and subjects a large number of residential
properties to significantly increased noise levels.
3.2 An existing airport with approved fixed wing and helicopter at Lands End fatally undermines the commercial case for an additional facility at Penzance. If the former operation was un-viable without this competition, how can the proposed new one be with all its increased start-up costs? (6)
3.3 The proposed location is a green field site of high agricultural and archaeological value being the site of a recently discovered Bronze Age barrow which has been partially excavated. (7) Overriding need must be demonstrated if these two criteria are to be ignored;
3.4 The proposal is contrary to the Cornwall Local Plan and Draft Neighbourhood Development Plan and will permanently change the status of the site from agricultural to commercial with all that entails, extending the built up area to the east. Again an over-riding need must be established to over-ride this; (8)
3.5 The visual and amenity impact will be adverse and immense, particularly as regards building and hundreds of parked cars, besides obviously the nuisance value of noise and other pollution from continuously arriving and departing aircraft;
3.6 It will add to road traffic congestion and pollution at that location;
3.7 The helicopter itself will create noise and pollution, seriously affecting the health and well being of a substantial number of properties within a mile radius and under the flight path. The adverse consequences on well-being, health and property valuation in these affected areas has not been addressed but is likely to be not insignificant. (A comprehensive academic review of the issues can be found here. (9))
3.8 The legal obligation for an Environmental Impact Assessment (EIA) has not been adequately fulfilled and the Noise Assessment submitted by the applicant is inherently biased and unreliable. (10)
4.0 Nuisance
Value of Noise and Vibration
It
should be noted that noise has the capacity to cause not only
nuisance but also very real and adverse health effects.
Increased environmental noise is correlated with increased heart
attacks and premature death rates. Any activity or proposal that
increases it, is therefore to be taken very seriously indeed, if
heath and well being are valued at all. (11)
The
extent to which noise or vibration is a perceived nuisance to a
hearer depends on many factors which makes it an inexact and
subjective science. The following need to be taken into account:
- The level and characteristics of the noise at source;
- Times and duration of noise;
- The frequency spectrum;
- Reflective noise from structures and surfaces;
- Meteorological conditions;
- Height above ground of source;
- Distance between source and receptor;
- Characteristics of receptors location;
- Noise attenuation of receptor's building;
- Activity patterns inside or outside;
- Existing background noise levels at different times of day
- Personal characteristics - age, health, work/sleeping patterns, sensitivity, attitudes to non-disturbance etc.
What
is quite clear is that if the noise at source is underestimated
and/or the background noise level is overestimated, any calculation
on the estimated increase in noise
will be faulty and unreliable.
In both instances it would be in the interests of the applicant to play down this figure and whether by default or intentionality, I believe that is what the Tresco commissioned "WYG" "Noise and Vibration Assessment" dated January, 2018, has achieved. Because of fundamental faults in measurement methodology their conclusions are unreliable and misleading.
The source noise may have been underestimated and by choosing sampling locations by sources of traffic noise, ensuring they are much higher than quiet residential or rural positions. By this sleight of hand they predict an increase in noise of 8.4 dBA, which although significant (perceived as a subjective doubling of noise) they not unsurprising conclude "is not considered to be significant during daytime hours".
5.0 Flawed
Applicant's Noise Assessment Report
So
I would contend that the applicant's Noise Assessment Report by
"WYG", dated 31st January, 2018 (12) is
fundamentally technically flawed and no reliance can be
placed on it's conclusion that (and I quote) "noise
levels are not expected to exceed the relevant threshold value and
the impact is not considered to be significant during daytime hours
on Weekdays 07:00 – 19:00 and Saturdays 07:00 – 13:00 at all
receptors." Please note, no reference is made here to
the Sunday operation.
My opinion is thoroughly and professionally backed by a separately commissioned "Review of WYG Noise & Vibration Assessment? by acoustic expert John Sim of AAD (Applied Acoustic Design). (10) This states, "There have been a limited number of measurement locations used to set baseline noise levels most of which are around Gulval, Longrock and Marazion. There are two in the main Penzance area, Lecudjack Hill (ST2) and Penzance Quay (ST1)" and that these are not representative of quieter residential and rural locations.
This is clearly designed to suggest background noise levels are higher and thereby reduce any apparent increase created by helicopter operations.
Further it would appear that "WYG" have used a noisy location at The Quay in Penzance, extrapolated without measurement, to the much quieter location at Trewarveneth Street in Newlyn. Not only is this bad science, you may well conclude this is unethical and deceptive, rendering the whole report unreliable!
This is not an isolated case as the AAD reveals but typical of the whole approach by the WYG report. To quote Mr Sim's assessment:
"Baseline ambient noise levels at R1 are likely to be significantly lower than the 64 dB LAeq, T values assumed, the only receiver locations with similar high levels of noise are at R5 and R6. These are receiver locations between about 80m and 50m of the A30. This cannot be correct. Drawings SK03 and SK04 show that the area around R1 and around R2 are the most affected in terms of noise from the over-flight of helicopters outside of the area around the proposed heliport location. It is therefore further not understood why no baseline noise measurements were made in Bowjey or other residential areas in southern half of Newlyn."
He adds regarding other measurements: "Again assuming the A30 road traffic to be the primary noise source in this area one would expect at location R25, at 340m from the A30, that the weekday baseline noise level would be around 45 dB LAeq, T but the weekday baseline is give as 55.5 dB LAeq, T, the same as at R23 and R25."
The result is that, "weekday contribution at location R25 could be 10 dB rather than the reported 0.3 dB" - a huge difference. For the 700 people living within 1km the report predicts a doubling of intensity of noise pollution.
6.0 Specific examples of unreliable or manipulated results
Located close to my address there were apparently two noise sampling points that specifically demonstrate the unreliability of the results on which the conclusion that the new helicopter service will not cause noise nuisance are based. The first is at Poniou Farm (LT2) which is immediately adjacent to the A30 Long Rock bypass, which by virtue of the frequency (some 65,000 traffic movements per 18hr day!) the speed and characteristics of traffic, and the concrete not tarmac road surface, is very noisy.
6.1 Results at LT2/R17 Poniou Farm
LAeq,T (dB) LAmax,T (dB) LAmin,T (dB) LA10,T (dB) LA90,T (dB)
Weekday Early Morning 06:30 - 07:30 4 hours 14/07/2016 - 20/07/2016
54.9
75.1
38.6
56.3
49
Weekday
Day 07:30 - 19:30 51 hours 14/07/2016 - 20/07/2016
55.3
84.3
38.6
56.6
51
Weekday
Evening 19:30 – 20:30 4 hours 14/07/2016 - 20/07/2016
51.9
80.8
38.7
53.3
49
Saturday
Early Morning 06:30 – 07:30 1 hour 16/07/2016
48.2
68.8
37.1
50.2
45
Saturday
Day 07:30 – 19:30 12 hours 16/07/2016
52.7
75.7
40.3
54.3
48
Saturday
Evening 19:30 – 20:30 1 hour 16/07/2016
48.0
67.7
37.8
49.9
44
Sunday
Early Morning 06:30 – 07:30 1 hour 17/07/2016
45.5
69.9
33.9
47.8
41
Sunday
Day 07:30 – 19:30 12 hours 17/07/2016
49.9
78.9
34.6
51.2
47
Sunday
Evening 19:30 – 20:30 1 hour 17/07/2016
52.8
73.9
39.4
54.6
45
Results at LT2 Poniou Farm interpreted.
Close to a road, noises are heard as individual sources in contrast from a distance away, when they become more merged as a point source with less variation. The first column represents Leq, which is sound pressure averaged over the sampling period. As might be expected this is highest during a working week day and the figure of 55.3 dB is used as the background figure for this location for comparative purposes.
It should be noted that the average figure for a Sunday is 5.4 dB less, but no account of this is made in respect of the nuisance value of proposed Sunday flights. As can be seen from the second column that records peak values of passing vehicles (eg speeding motor bikes) these can be exceedingly noisy - well over 80dB, well past that which can cause occupational deafness in the longer term.
To summarise, this is a noisy location that is not representative of much quieter locations which has the effect of appearing to make the additional noise of a helicopter less intrusive, which seems to be the reason it was chosen rather than (or in addition to) another set back further such as at 'Pleming'. Nor is any account taken of the lower recorded values on a Saturday or Sunday or for 90% of the time (last column).
6.2 Results at ST5/R13 Tolver Farm
This
recording location is in an elevated position just under half a mile
NE from the proposed heliport. It is generally a very quiet spot but
background noise can vary subject to different atmospheric
conditions. The Long Rock bypass is the main source of noise but
strangely this can vary greatly from being quite inaudible to
intrusive, illustrating one of the problems with sound and its
measurement.
This also applies to locomotive movements on the railway in the vicinity of the Long Rock level crossing roughly half a mile to the south. Other sources of noise are passing aeroplanes and helicopters, periodic heavy duty agricultural activity in the fields, lane traffic recently significantly increased by commercial development locally and on occasions the noise of bird scarers.
However all of these are very temporary in nature and not to be compared with the almost continuous (about every 25 mins) noise of helicopters landing, idling whilst passengers disembark and load, then taking off again.
LAeq,T (dB) LAmax,T (dB) LAmin,T (dB) LA10,T (dB) LA90,T (dB)
Evening 35 Mins 14/07/2016 19:53
51.1
74.8
30.8
44.4
33.1
Daytime
30 Mins 15/07/2016 07:29
56.5
83.0
35.1
43.9
37.6
Daytime
30 Mins 15/07/2016 15:36
44.3
63.6
36.8
46.7
40.1
Daytime
30 Mins 15/07/2016 17:05
43.3
70.0
35.0
43.0
37.2
Evening
40 Mins 15/07/2016 19:14
39.7
71.6
30.3
38.3
33.0
Daytime
15 Mins 17/07/2016 07:33
35.2
50.9
28.2
37.5
31.0
Daytime
30 Mins 17/07/2016 16:30
34.4
62.2
28.3
36.0
30.8
Daytime
30 Mins 17/07/2016 18:15
34.1
55.4
29.4
35.7
31.8
Unlike the results for LT2 above, the methodology at this site was quite different. The eight
samples
over four days in July, 2016, averages out at a fraction over
thirty (30) minutes.
This
compares with average sampling times at Poniou /LT2 of
9.666 hrs. In other words
nineteen
times longer at Poniou than Tolver! It raises the question
as
to why so much more time was devoted to a very noisy sampling
site, than a very
quiet
one? Surely not to slant the results of background noise levels
pertaining?
As can be seen despite some anomalous peaks, the noise level for 90% of the sampling
time
(i.e. 27 mins of 30) ranged from 31 dB to 41.1 dB. Clearly this
is significantly lower
than
the 55.3 dB that was generally adopted as the background noise level,
yet this was
not
even referred to in the final result, as if it did not exist.
Presumably the scientific approach
adopted
was if the results did not support the foregone conclusion, they
would be
excised.
This is fraudulent science.
All the sampling periods were taken over a four day period in July 2016. Living next door
I
was not informed they were taking place - not that here was any
obligation on them to do
so
- although it may indicate a certain aversion to consultation,
particularly as no contact
has
been made on any other occasion, despite being identified as a
"Sensitive Receptor
Location"
in the WYG report.
The
timings appear random other than they concentrate on early
morning or late afternoon
but
all within the time frame of the application as it currently
stands. What I find rather
strange
is that all but two of the readings show very elevated peak
results (74.8; 83.0; 63.6;
70.0;
71.6; 50.9;; 62.2; 55.4) which are very difficult to explain in
such a quiet spot yet
none
is given.
Of course without these anomalous peaks the Leq (average) and L90 would have been
even
lower. Surely we cannot assume the sampling dates and times just
happened to be
when
heavy tractors were in operation in the vicinity? This is the
only explanation for the
huge
disparity between the L90 and Leq evidenced particularly in the first
two.
What is absolutely clear is that in this location, where background noise averages out at
under
40 dBA, the helicopter noise less than half a mile away, cannot avoid
being highly
intrusive
and a nuisance, both inside and outside the domestic premises.
7.0 Noise at source
A map of the route and 'noise sensitive sites' is provided in the WYG report but what is
lacking
from it is calculated noise
contours, showing
clearly the noise 'footprint' on the
surrounding
area, principally over land, as it arrives, hovers on landing,
idling whilst on the
ground,
taking off and flying out and over the peninsula.
Clearly
the noise output is subject to change at all these different phases,
subject to the
many
variables such as wind, climatic inversions, height, route,
topography, load etc. The
only
sure way of knowing what the actual impact will be is if a fully
loaded aircraft is recorded
in
situ from different monitoring positions as it goes through these
operational phases.
Why has
the applicant not suggested this or included even predicted noise
contours
to
inform the many residents who will be affected?
The
consultants, do not deny that it is a very noisy machine - they
report that at 10 mtrs it creates 104.1 dBA and
produce the following table:
Initial Startup &
Idle @ 10m Distance 98.4 dB LAeq,
5 Mins 104.1 dB LAmax
Aircraft
Idling @ 15m Distance 93.9 dB LAeq,
2 Mins 99.1 dB LAmax
Hover
Taxi to Take-off @ 25m Distance 92.3 dB LAeq,
30 Secs 98.6 dB LAmax
Departure @ 35m Distance 79.5 dB LAeq,
20 Secs 84.9 dB LAmax
Approach @ 25m Distance 83.8 dB LAeq,
30 Secs 92.1 dB LAmax
These
figures were apparently based upon measurements of an
existing Agusta Westland AW139 performing standard
ground running, take-off, departure, approach and landing manoeuvres
carried out at Cotswold Airfield in August 2016. However it does not
state whether this was an empty or fully loaded aircraft.
This
is an important omission as the baseline figures will be unreliable
if the aircraft was unloaded for obvious reasons. Can we assume
that the source figures were based upon an unloaded aircraft and
therefore not representative of one fully loaded with passengers and
luggage?
Sound
complies with the 'inverse square law' basically that energy in the
form of sound pressure, halves with every doubling of distance. Three
decibels represents a doubling of pressure. We may therefore,
using these best performance figures, calculate that at sampling
point ST5/Tolver, roughly 800 m distant, the machine is likely to
record a figure of between 77dBA (higher) and 62 dBA (lower)
both of which greatly exceed background at that point of under 40
dBA. Even on best estimates this is more than 20 dBA above
background.
(@
Source: 104dB (measured); @ 25m: 92.1dB (measured); @ 50m 89/86dB
(calculated); @ 100m 86/80dB; @ 200m 83/74dB; @ 400m 80/68dB; @ 800m
77/63dB)
This
is vastly different to and worse than the WYG projected Leq increases
which for this site (R13/ST5) at Table 6.2 and 6.3 as follows:
Table
6.2 Worst-case Aircraft Movement Noise Levels LAeq 1
hour (Westerly Departure, Easterly Approach)
4.2
weekday; 8.4 Saturday; and 8.4 on Sunday.
Table
6.3 Worst-case Aircraft Movement Noise Levels LAeq 1
hour (Easterly Departure, Western Approach)
Table
6.3 of the WYG report suggests an increase of only 3.7
weekday; 7.7 Saturday; and 7.7 on Sunday.
Note
departure noise is predicted to be significantly louder than arrival.
Even so it is hard to see how the WYG report came to such a
favourable assessment.
Rather
ironically, figures produced in the WYG report itself, affords
support for my contention that the noise levels under the flight path
and adjacent to it, will be much closer to my calculations than
theirs!
I
suggest above, that based on their figures, noise levels at ST5/R13
will fall between 63 and 77 dB in contrast to their suggestion of
43.4dB!
However
with regard to St Mary's Airport they state: "The
results presented in Table 7.4 above demonstrate that the highest
LAeq, 1hour noise levels from aircraft movements are predicted to be
up 70.1 dB at residential properties within 200 m of the existing St
Mary’s Airport runway."
That
you will notice makes my estimate far more credible than theirs and
should be explained by the applicant. If it is at least 70dB at St
Mary's there is no reason to suppose it will be any less 200m around
the Penzance Heliport is there?
National
Planning Policy Guidelines (PPG) in fact quoted by WYG state
categorically that increases of over 25 dB are: "Unacceptable
Impact at Receptor of High Sensitivity, as it is likely to alter the
character of the area despite short duration and infrequent events."
8.0 Evidence
of bias in WYG Report
The
noise assessment referred to by the acoustic specialists, "WYG",
was commissioned by the Tresco Estate in 2016 and published only in
January 2018. It can hardly be regarded as free of bias
whether it is or not. On the basis of "He that pays the
piper calls the tune" it is reasonable to assume the
outcome would be favourable to the proposal. Indeed the report itself
confirms as much for it states,
"This
report presents the findings of a noise assessment undertaken in
support of a full planning
application for the development of a proposed heliport on land to the
north of Jelbert Way, Penzance."
The
evidence of subtle manipulation of the noise readings and suggested
impact of the heliport and two helicopters gives credence to this
suggestion.
In
similar vein, the apparent public support for the scheme
(approximately 10:1 in favour) on closer examination is flawed.
Firstly those in favour are overwhelmingly passengers and
holiday-makers who were apparently e-mailed by the developer and
asked to support it. It is not clear whether in doing so they were
fully aware of an alternative fixed wing and helicopter service that
would in due course be available at Lands End.
In
stark contrast, as someone considered to be at a "Noise
Sensitive Site", I have never been contacted or
consulted. Nor I believe have many more house holders and land
owners who will be affected. The WYG Report is an example of
how the impact has been played down in what has been described as a
"very slick PR operation". We must all be aware of how
these work to degrade and despoil an environment already under great
pressure.
9.0 Other
environmental impacts
This
document has concentrated on NOISE, but decision-makers should be
cognisant of other equally important impacts of the development that
are hardly alluded to in the application.
Two
aircraft are proposed (beside others that may use the facility from
further afield) in thirty four arrivals and departures. That is up
to 238 journeys per week each one of which is ten
miles further than the route from Lands End or more than a third
further (28 miles from Lands End) This converts to
nearly 2400 additional miles every
week, or 876,000 additional miles in
a year.
Fuel
Burn. 150 gallons/hr. Flight time @ 160 kts approximately quarter
of an hour so approximately 60 hours flying time per week. So that's
9000 gals of aviation fuel a week and 32850000 gals a year. Now how
much carbon and other pollutants is that when the Government states
we should be emitting less?
Needless to say fuel burn and pollution is greater as the aircraft takes off or is hovering and
it
is proposed to impose this down wind on anyone in its path.
10.0 CONCLUSIONS
10.1
The proposed Heliport development in Penzance consciously and
wilfully breaches
many
important Planning Policy Guidelines (PPG) that thereby place a duty
on the Planning
Authority
to refuse the application, unless overwhelming public benefit can be
established.
10.2
These PPG's include the loss of a green field site and high quality
agricultural land;
contrary
to the Local District Plan; it destroys an important archaeological
(Bronze Age Barrow)
site;
proposed buildings and parked vehicles will have a detrimental effect
on
landscape
and visual amenity; the operation is intrinsically noisy and
polluting that will cause
significant
adverse consequences for those in the vicinity and under the flight
path - potentially
many
hundreds of properties and people.
10.3
Given that both fixed wing and helicopter services operate from Lands
End, it is now
impossible
to meet the PPG obligation to demonstrate an overwhelming public
benefit or need
for
this additional facility.
10.4
Given the fact that the Penzance location involves an additional
twenty miles per flight,
it
runs counter to all Government CO2 and pollution reduction policies.
10.5
Although the development will have many adverse consequences for
residents and
environment
one of the most severe and intrusive is noise. In this regard the
applicants place
great
reliance on a noise assessment by their agents 'WYG' that has been
shown to be
unreliable
and misleading.
10.6
This WYG report is biased and partial in its approach (being
commissioned by the
applicant)
and is defective in its methodology, results and conclusions.
No reliance can or
should
be placed on it by the Planning Authority in coming to an opinion on
the intrusive
nature
of the development.
Specifically
none of the following 'Conclusions' in the report are
credible:
a.
"At locations within one kilometre of the proposed
heliport, noise levels have been predicted to experience increases of
up to 8.4 dB during the weekend daytime period.
b.
"Despite a nominal increase in noise levels, it is considered
that the effect of maximum of 17 aircraft departures and approaches
during the daytime will not create a significant adverse impact.
c.
"An assessment of the change in noise level as a result of
helicopter movements has shown that sensitive receptors are predicted
to experience a small increase in noise levels within or below the
‘Lowest Observed Adverse Effect Level’.
d.
"An assessment of the change in noise level as a result of
additional helicopter movements on the Isles of Scilly has shown that
sensitive receptors are predicted to experience a small increase in
noise levels within or below the ‘Lowest Observed Adverse Effect
Level’.
e.
"Therefore, and in accordance with the requirements of the NPPF
and PPG: noise, the proposed development is not expected to have an
adverse impact on health or quality of life."
10.7
In particular as detailed here and in an independent assessment by
'AAD', the
choice
of monitoring sites close to traffic noise generation has the effect
of raising background
noise
baseline and does not accurately reflect much quieter rural and
residential areas.
The
comparative figures are thereby falsified to appear less intrusive
than they will be.
10.8
Further in this regard other defects in the measurement methodology
detailed here
and
in the AAD report make the conclusions quite untenable. No effort was
made to assess
the
true impact on sensitive locations such as schools and hospitals and
the increase in
noise
levels have been underestimated by as much as 20dB in places.
10.9
The WYG projections are largely theoretical. Only measurements of a
fully loaded
aircraft
landing, taking off and in flight in the designated area should be
used. Even so the
predicted
noise levels for quiet locations will be intrusive and annoying.
10.10
The scheduled times and days of flights (7.30 am - 7.30 pm,
seven days a week)
is
excessive and allows for no relief from constant disturbance, even on
Sundays. In the peak summer months there will be a take off and
landing every 25 minutes with each aircraft idling for up to 9
minutes creating engine noise for 37 out of every 60 minutes.
From 0730 to 1930, 7 days a week. This cannot be reasonable.
10.11
Were the application to be approved, reliant on misleading WYG noise
predictions,
it
would leave the Authority open to legal challenge with all that
entails.
10.12 Therefore
I conclude that none
of the following 'Conclusions' in the WYG report
are credible:
a.
"At locations within one kilometre of the proposed
heliport, noise levels have been predicted to experience increases of
up to 8.4 dB during the weekend daytime period.
b.
"Despite a nominal increase in noise levels, it is considered
that the effect of maximum of 17 aircraft departures and approaches
during the daytime will not create a significant adverse impact.
c.
"An assessment of the change in noise level as a result of
helicopter movements has shown that sensitive receptors are predicted
to experience a small increase in noise levels within or below the
‘Lowest Observed Adverse Effect Level’.
d.
"An assessment of the change in noise level as a result of
additional helicopter movements on the Isles of Scilly has shown that
sensitive receptors are predicted to experience a small increase in
noise levels within or below the ‘Lowest Observed Adverse Effect
Level’.
e.
"Therefore, and in accordance with the requirements of the NPPF
and PPG: noise, the proposed development is not expected to have an
adverse impact on health or quality of life."
11.0 Recommendations
11.1
The application for a Heliport at Penzance in its present form should
be refused.
11.2
If the Strategic Planning Committee is minded, despite all the cogent
reasons
against,
to approve the application, it cannot rely on the conclusions of
the WYG Noise
Report.
It is biased, defective and misleading. Only in the light of
an independent noise
investigation,
based on actual flight recordings of a fully loaded aircraft in situ,
should
be allowed for predictive purposes.
11.3
In no event should conditions be entertained less
strict than those pertaining to the
previous
BA helicopter operation from Penzance. In particular there should
be no flights
permitted
on Sunday to provide some respite to residents.
11.4
In the unfortunate event of approval, the Planning Authority by way
of Section 52
Agreement,
require the applicant to introduce a scheme of compensation for those
affected
to
an agreed standard for insulation works, as is common with airports
in the UK.
END
REFERENCES
1.
"The
first aim of the Noise Policy Statement for England: Avoid
significant adverse impacts on health and quality of life from
environmental, neighbour and neighbourhood noise within the context
of Government policy on sustainable
development." https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/69533/pb13750-noise-policy.pdf
"Local planning authorities’ plan-making and decision taking should take account of the acoustic environment and in doing so consider:
- whether or not a significant adverse effect is occurring or likely to occur;
- whether or not an adverse effect is occurring or likely to occur; and
- whether or not a good standard of amenity can be achieved.
In
line with the Explanatory
note of the noise policy statement for England,
this would include identifying whether the overall effect of the
noise exposure (including the impact during the construction phase
wherever applicable) is, or would be, above or below the significant
observed adverse effect level and
the lowest observed adverse effect level for the given situation. As
noise is a complex technical issue, it may be appropriate to seek
experienced specialist assistance when applying this
policy." https://www.gov.uk/guidance/noise--2
2. "Environment Secretary, Michael Gove said: “Air pollution remains a significant threat to public health and we are committed to tackling its causes and improving air quality. This is why we are signing up to the amended Gothenburg Protocol and will shortly build on our £3.5bn plan to tackle roadside emissions by publishing a comprehensive Clean Air Strategy.” https://www.gov.uk/government/news/uk-to-ratify-international-protocol-to-reduce-air-pollution
3.
"Amber
Rudd accepted the
advice of the government’s statutory climate advisers,
setting a target on Thursday of reducing carbon emissions 57% by 2030
on 1990 levels. The legally binding “fifth
carbon budget” laid
in parliament today is tougher than the carbon emissions target the
UK is signed up to as part of the European Union, which
requires a 40% cut by 2030 on 1990
levels.@ https://www.theguardian.com/environment/2016/jun/30/uk-sets-ambitious-new-2030s-carbon-target
4.
"Noise
needs to be considered when new developments may create additional
noise and when new developments would be sensitive to the prevailing
acoustic environment. When preparing local or neighbourhood plans, or
taking decisions about new development, there may also be
opportunities to consider improvements to the acoustic environment.At
the highest extreme, noise exposure would cause extensive and
sustained changes in behaviour without an ability to mitigate the
effect of noise. The impacts on health and quality of life are such
that regardless of the benefits of the activity causing the noise,
this situation should be prevented from
occurring." https://www.gov.uk/guidance/noise--2
5.
"Government policy for England is set out in
the National Planning Policy Framework (NPPF) published
in March 2012 (paragraph 112). Decisions rest with the relevant
planning authorities who should take into account the economic and
other benefits of the best and most versatile agricultural land.
Where significant development of agricultural land is demonstrated to
be necessary, local planning authorities should seek to use areas of
poorer quality land in preference to that of higher
quality." file:///C:/Users/User/Downloads/TIN049_edition_2.pdf
6. "On
Behalf Of Isles Of Scilly Steamship Group (Neutral)
Comment
submitted date: Thu 01 Mar 2018 (Edited to save space)
In
setting out our observations on the application proposals we have had
regard to applicable policies in the Local Plan, the successful 2017
judicial review of the application and more recent proposals by Lands
End Airport (LEA) to introduce a comparable helicopter service to the
Isles of Scilly.
Separate
representations are being made by LEA . Helicopter service that is
set to commence from Penzance Airport, operated by Specialist
Aviation Services (SAS) .
Heritage
(above and below ground)
The
Built Heritage Assessment is likely to affect a large number of
sites. The scope excludes a number of assets which may
experience effects on their aesthetic value (such as the listed
buildings to the north of Chyandour and those which fall outside of
Penzance Conservation Area). Further, at Gulval, in addition to a
Grade I listed church, there is a scheduled cross as well as Grade II
listed Lychgate and a K2 telephone box although the effect on the
significance of each is likely to be limited. However, in omitting
these, Paragraph 128 of the NPPF has not been comprehensively
applied.
The
proposed development is likely to have harmful effects on a
large number of assets including those listed at Grade I and
in particular on the setting of those assets. These impacts are not
likely to be considered 'significant' in EIA terms, but they do
comprise 'less than substantial harm' under paragraph 134 of the NPPF
and should be acknowledged by the Council and any harm weighed
against the public benefits of the proposal. In accordance with the
statutory requirements, where no substantive and deliverable public
benefits exist the presumption remains in favour of refusal. Historic
England as a statutory consultee has also raised concerns regarding
the impact of the proposed development on the setting of the heritage
assets.
An
incorrect definition of setting has been applied to the assessment
methodology which is not consistent with the NPPF (and as
confirmed by recent Court of Appeal decisions (Mordue Judgement)). As
a result, nil effect on significance is incorrectly ascribed in many
cases to the assets which have been scoped into the assessment. In
reality the proposals are likely to affect these assets, most notably
views from St Michael's Mount and to Gulval, in which the development
and the flight path would be most perceptible, and in close range
views of St Gulval Church and the surrounding conservation area,
where the proposals would erode its rural setting. These points were
raised previously by Historic England in their representations of
31st May 2017. They have once again raised serious
concerns about the impact of the proposals on the setting of
various heritage assets in their representations of 9th February
2018.
We
would expect a more robust assessment to acknowledge the potential
harm to these assets, and as required by the Planning (Listed
Buildings and Conservation Areas) Act 1990, the harm should be
recognised by the Local Planning Authority in their decision-making
and given considerable importance and weight. In the absence
of material public benefits the application should be refused in
accordance with the Council's duties under Section 66 (1).
In
considering harm to a heritage asset the Council need to consider any
alternative location as such a choice could avoid all of the
identified impacts, as confirmed in the case of R. On the application
of The Forge Field Society. An alternative location exists to
the currently proposed site which would avoid any harm to
setting which would arise as a result of the current application.
The
archaeological assessment appears to be sound assuming
that there are genuinely no practical alternatives to the site layout
as currently proposed. As with the above ground heritage assets, the
harm to the below-ground heritage assets may be avoidable if the same
public benefits could be delivered at a different location
altogether.
Environmental
Statement
The
Environmental Statement (ES)
The
principal weaknesses include:
-
The description of the site and surroundings is still limited and
doesn't include a plan or description of the scale of development;
-
There is no proper explanation as to why the scope of the ES has
changed to include three new topic chapters;
-
There appears to have been very little design development or
assessment of the environmental impacts of the different design
options;
-
The ES does not clearly indicate how consultee responses have
influenced the iterative design process. Details of consultation
responses are limited to three entries from members of the public
that were made in 2016 (Table 4.1). This has not been updated to
reflect the consultation that has occurred since then e.g. our
client's representations to their original application and ES or that
of other key statutory consultees;
-
Whilst technically an alternative site assessment has been undertaken
(and so meeting the standards required of the ES), the council must
be happy that the information and evidence provided as part of the
chapter 4 (and Appendix 4.1 and 4.2) are technically correct and
sufficiently robust to demonstrate that no real alternative exists.
In this regard the assessment fails to properly address the
suitability of LEA as an immediately available alternative with
a named helicopter operator which would avoid all of the identified
heritage and environmental impacts.; and
-
The NTS does not include a plan that shows the location of the key
environmental receptors.
We
would recommend that the council serve a Regulation 22 notice under
the EIA Regulations in order to secure the missing information from
the applicant and in doing so ensuring that the ES and the
assessments are complete and robust.
Socio
Economic Benefits
Although
not fully explained or justified in the socio-economic report, it is
evident that the key benefits arising from the proposed development
and resultant re-establishment of a scheduled helicopter service will
be an increase in visitor numbers to the Isles of Scilly.
This will generate additional spending in Penzance and on the
Islands, and will therefore support a level of indirect job creation
that is likely to exceed the direct job creation associated with the
construction and operational phases. However, the assessment
and these conclusions are now obsolete given the
recent announcement of a new helicopter service to the islands from
Lands End Airport, due to begin service 1 May 2018. The
council must request renewed and updated evidence from the applicant
to show the benefits proposed will still stand.
Putting
the LEA Helicopter service aside, the addendum socio-economic
assessment fails to accurately quantify the direct, indirect and
catalytic impacts of the proposed development, but has instead relied
upon a series of untested assumptions. The benefits are
overstated and no consideration has been given to the potential
negative impacts on LEA and the marine passenger service
which could cancel out a number of the claimed benefits. This is a
significant omission from the assessment.
Unfortunately
no evidence has been provided to show that an operator has been
formally engaged (or publicly notified), so we remain unsure as
to how the council can be certain that a service will
delivered and so in turn the promised benefits which are
being so heavily relied upon in drawing the overall planning balance
but more importantly, the public benefit tests required under
paragraph 134 of the NPPF. There does not seem to be a proper
understanding of the financial or operational viability of the
proposed service and so whether the perceived benefits are
capable of being delivered at all.
Planning
Policy
The
application is for development on unallocated land, currently
classified as open countryside and on grade 2 and 3b agricultural
land (highest value agricultural land). As such the
proposals conflict with policies 1 and, particularly Policy
21 of the Cornwall Local Plan. As such special
circumstances must be demonstrated to the local planning authority to
justify setting aside these policies. As such it is
difficult to see how a second operation could be viable and
hence whether any of the claimed benefits are deliverable.
Alternative
site assessment
It
is unclear how the assessment comes to the conclusion that the
proposed Penzance location has no issues with environmental
constraints given that part of the site
is in flood zone 3 at the highest risk of flooding. Whilst
the area is subject to Flood Risk Defence, residual risk of flooding
still remains and therefore sites such as LEA which fall entirely
within Flood Zone 1, and therefore at a low risk of flooding, should
be considered to be a sequentially preferable site.
The
dismissal of LEA as a sequentially preferable site over Penzance is
incorrect. We
trust the Environment Agency and Historic England are aware that a
viable alternative exists and so avoids any harm, heritage impact and
flood risk. As
such they may need to reconsider their submissions to the Council as
Statutory Consultees. Surely the proximity to Grade 1 listed
Church and impact on the views from St Michael's Mount should be
regarded as a sensitive receptor?
Overall
Conclusions on the application proposals
-
The sequential site assessment is currently flawed. It cannot
be relied upon, as it stands, to properly inform the EA or HE of
the alternatives that are available or to deal with the test in local
Policy 21 of the Cornwall Plan with regards to protecting the highest
value and most versatile agricultural land.
-
An updated alternative site assessment (as per the representations
made direct by LEA) would also impact the assumptions and assessments
made in the ES - this will need to be updated by the applicant to
properly reflect the current situation.
-
The applicant needs to update the socio-economic assessment in light
of this application proposing a 'second' helicopter service and so
demonstrate to the council the benefits which are so heavily relied
upon in the planning balance of this application still stand.
-
There are heritage impacts that are considered to lead to 'less than
substantial' harm, therefore triggering the test to demonstrate
public benefits under paragraph 134 of the NPPF. . As well as
the announcement of the new helicopter service from LEA which
inevitably changes the baseline and parameters assessed under this
planning application, there also remain to be flaws in some of the
information provided.
_ADDENDUM-3757136.pdf
https://www.cornwall.gov.uk/environment-and-planning/planning/neighbourhood-planning/
neighbourhood-planning-in-cornwall/tab-placeholder/n-r/penzance-neighbourhood-
development-plan/
9.1 "Living
within a daytime aircraft noise contour (at or above 55 dB) is
negatively associated with
all
SWB measures: lower life satisfaction, lower sense of worthwhile,
lower happiness, increased
anxiety
and lower positive affect balance. Revealed preference methods
generally find that house
prices
depreciate when affected by aircraft noise."
%20Aircraft%20noise%20and%20wellbeing_Transportation%20D%202016.pdf
9.2 Quality
of Life: Assessment Airports Commission
file:///C:/Users/User/Downloads/11-Quality_of_life--quality-of-life-assessment.pdf
10. file:///C:/Users/User/Downloads/18168%20001%20acoustic%20survey%20note%20DRAFT%20OUTLINE.pdf
12. file:///C:/Users/User/Downloads/PA16_09346-PART_1_NOISE_REPORT_-_TECHNICAL_APPENDIX_6.1-3631222%20(1).pdf
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