APPEAL FROM CLLR IAN CAREY
I’m looking for your help to push for a stronger insulation scheme to protect those who experience aircraft noise at night.
In the Fingal Development Plan all Swords Councillors, in fact all Councillors in Fingal, chose to put in place stronger measures to make the insulation scheme for those experiencing noise at night more effective.
Now, in the very last part of the process, the Minister of State Kieran O’Donnell, under the advice of the Office of the Planning Regulator, is trying to remove it.
There is no legal basis for this request.
The objective they are trying to remove is designed to protect people’s health and is in line with international best practice.
There is growing evidence that night noise has a bad impact on people’s health. It is linked to cardiovascular disease and mental health issues.
The World Health Organisation (WHO) in 2018 made a strong recommendation that we should try to limit the impact of night time noise to below 40db. This is what your Councillors have decided to include in the development plan.
It is to protect those impacted now and those who could be impacted in the future. It could be you or your family members in years to come.
The text that the council wants in the plan will mean that the insulation of homes needs to meet a specific standard. Right now there is not such commitment to meet ANY standard. The current insulation scheme does not guarantee that noise gets to a safe level in these homes.
Dublin Airport is currently on course to have possibly its best year on record. It is in line to make profits in excess of €100m. It is only fair that the DAA compensate the people who are suffering from the imact of the airport’s expansion.
Please make a submission RIGHT NOW to call on the Minister to drop this request. Submissions are open until May 2nd.
The proposed submission is in the highlighted text below. If you agree with it and you would like to add your voice to the call for better protection for people’s health follow these instructions:
Click this link to find the consultation page.
When there click the submission button.
If you don’t have an account you will need to create one.
If you do have one log in and then give your submission a Title.
Then you will be brought to a page where you can add an Observation. Under Theme put General and in the box below it put the following text (if you agree with it):
Observations in relation to proposed direction to delete an Objective (PH CH 8.1) about noise insulation from the Fingal Development Plan 2023-2029
The members of Fingal County Council unanimously decided to include the following Objective in the Fingal Development Plan:
“That the Development Plan recognises the inadequacy of the proposed noise insulation scheme to protect the health of those affected by aircraft noise and that in view of the increasing knowledge and scientific evidence of the serious health impact of aircraft noise on the physical health of Fingal residents that it is an objective to take measures including the expansion of noise insulation schemes operated by DAA to include all areas exposed to 40dB Lnight or higher as produced by aircraft during night time. The insulation schemes should be designed to ensure that internal noise levels are in keeping with BSI 25 | Page Standards Publication BS 8233:2014 Guidance on sound insulation and noise reduction for buildings, table 4: Indoor ambient noise levels for dwellings, as referenced in Chapter 14: Development
Management Standards of the Development Plan 2023-2029. This approach is in response to the knowledge that night-time aircraft noise above this level is associated with adverse effects including increased mortality, stress, high blood pressure and a deterioration in cardiovascular health.”
The Minister’s Draft Direction says:
IV. The Development Plan as made includes provisions that recognise the inadequacy of the proposed noise insulation scheme to protect the health of those affected by aircraft noise and that it is an objective to take measures including the expansion of noise insulation to ensure noise levels produced by aircraft during night time are reduced to below 40 dB Lnight, which matters are subject to a separate statutory code which includes the designation of a separate action planning authority, the Aircraft Noise Competent Authority, and the preparation of a Noise
Action Plan. The inclusion of matters which should be determined through the appropriate statutory process, including the Noise Action Plan, is therefore inconsistent with NPO 65.
We would like to make the following observations on the Draft Direction. The noise levels referred to in the Objective are in keeping with the Recommendations from the World Health Organisation in “Environmental noise guidelines for the European Region”
https://www.who.int/europe/publications/i/item/9789289053563 In relation to aircraft noise they state:
“For night noise exposure, the GDG strongly recommends reducing noise levels produced by aircraft during night time below 40dB Lnight as night-time aircraft noise above this level is associationed with adverse effects on sleep. To reduce health effects, the GDG strong recommends that policy-makers implement suitable measures to reduce noise exposure from aircraft in the population exposed to levels above the guidelines values for average and night noise exposure. For specific interventions the GDG recommends implementing suitable changes in infrastructure.”
NPO 65 of the National Planning Framework reads:
Promote the pro-active management of noise where it is likely to have significant adverse impacts on health and quality of life and support the aims of the Environmental Noise Regulations through national planning guidance and Noise Action Plans.
On the face of it, there’s nothing in the text on noise insulation which is inconsistent with NPO 65. In fact it seems to be entirely consistent with it, being the pro-active management of noise where it is likely to have significant adverse impacts on health and safety. The Draft Direction identifies the inconsistency as being due to “the inclusion of matters which should be determined through the appropriate statutory process.” There is no legal barrier preventing the Council from addressing noise through the County Development Plan. Indeed, the contrary is the case. It is clear that the impact of noise on human health, including that of airport noise, is a consideration that the Council must take account of in its planning decisions. Therefore, it is only logical that it be addressed in the Development Plan. The implication in the Draft Direction is that NPO65 requires that noise insulation not be dealt with in the Development Plan. This is not apparent from the face of NPO65. Indeed,
NPO65 explicitly recognises that the pro-active management of noise and the aims of the Environmental Noise Regulations can be achieved through national planning guidance, and therefore, implicitly, through the planning system. Furthermore, the Plan contains a series of other objectives aiming to protect public health from the impact of airport noise. If this Objective in the Draft Direction were contrary to NPO65, then surely the others would be too?
Not only are there many objectives about noise, including airport noise, there are many objectives specifically about noise insulation to protect against airport noise. Objective SPQHO82, Table 8.1 Objectives DAO11, DAO12, and DMSO45, Table 14.16, and Objective DMSO105 all explicitly cover noise insulation. It makes no sense to suggest that it is consistent with NPO65 to include provisions requiring noise insulation but inconsistent with NPO65 to specify the noise levels required to be reached by that insulation.
• The Objective has been formulated in accordance with the best scientific guidance to protect human health;
• Fingal County Council is acting within its powers in specifying the standard of noise insulation to be met;
• There is no basis for suggesting that this matter is not appropriate to the County Development Plan;
• There is no basis for suggesting that this Objective is contrary to NPO65 of the National Planning Framework;
• There is no legal basis or justification for the Draft Direction in relation to this Objective.
Please be sure to include your name and address to make the submission valid and click the Save and Review button.
Then on the following page click SUBMIT.
Thank you for taking the time to do this. Hopefully the more people who lend their voice to this it will help the Minister make the right decision and DROP this direction.