Barbara Carby|No to proposed increase in allowable noise levels

The National Environment and Planning Agency (NEPA) has in limited circulation a presentation titled ‘Review of the Draft Noise Planning Policy Guidelines (NPPG)’. The presentation contains suggestions for consideration and decision by the Town and Country Planning Authority/National Resources Conservation Authority (NRCA) boards.

Citizens’ Rights to the City, a network of citizen associations and individuals of 29 communities, primarily in Kingston and St Andrew, had sight of the presentation and strongly objects to an increase to 90 decibels (dB) as a new limit for construction sites. The proposed 90dB would be a level that is well above the 70-75dB recommended by the World Health Organization (WHO) in its 1999 publication, Guidelines for Community Noise.

The potential effects of noise on human health that are outlined in the WHO guidelines include hearing impairment from prolonged exposure and sleep disturbance, resulting in fatigue, depressed mood and decreased performance. For a good night’s sleep, the WHO guidelines recommend background noise below 30dB and individual noises below 45 decibels.

Noise can negatively affect performance of more complex cognitive tasks, particularly in children.

There is also concern that levels above 80dB may lead to a decrease in people’s helping behaviour and an increase in aggressive behaviour, a possibility we do not need in Jamaica.

Long-term exposure to noise may lead to permanent physiological damage. The WHO recommends that for noise guidelines, special consideration should be given to vulnerable groups, such as people with diseases or medical problems, in hospitals or rehabilitating at home, people dealing with complex cognitive tasks, the blind, foetuses, babies, young children and the elderly.

The recommendation for residential areas heavily polluted with noise is that the total adverse health impact of noise over a 24-hour period be considered and the precautionary principle be applied.

In considering the proposed 90dB noise allowance for construction sites, the following should also be taken into account:

Negative impacts on hearing start in the 85-90dB range, especially with continuous exposure. This has implications for the health of construction workers. In the draft NPPG, the Bureau of Standards recommends that mitigation measures be put in place for noise at 90dB over one or two hours. This would apply to construction workers, who should be given hearing protection. However, occupants of nearby residences would be exposed without any protection.

The trend of replacing single-family dwellings with large, multi-storey buildings means that many residences are in close proximity to construction sites, with little attenuation of noise. People at home during the day will likely be among the vulnerable - the elderly, children, babies, the ill and those recovering from illness. They will be exposed to construction noise continuously throughout the day.

Many construction sites are going beyond the currently allowable time limits, with noise, including heavy equipment noise, from early morning until well into the night on weekends, including Sundays and on public holidays. It is therefore alarming that in NEPA’s review of the draft NPPG, there is a proposal to extend allowable hours of work on construction sites to 10 p.m., and on Sundays and public holidays. Given that in some residential areas work on construction sites now continues until midnight without any intervention from the authorities, there is no confidence in the willingness or ability of the State to enforce the “indoor, quiet work “ stipulation made in the recommendation for extension of working hours.

The proposed change would likely only codify into policy what are now egregious breaches of relevant laws, and a source of distress for residents of communities. The proposed change could have the effect of diminishing the rights of citizens living in close proximity to construction sites to the peaceful enjoyment of their homes. The recommendation also seems to conflict with citizens’ right to a healthy environment, which is guaranteed in Article 13(3) of the Charter of Fundamental Rights and Freedoms in Jamaica’s Constitution. This constitutional provision guarantees to all persons in Jamaica the right to “enjoy a healthy and productive environment free from the threat of injury or damage from environmental abuse…”.

Construction sites are but one of many sources of environmental threat from noise pollution in communities. Depending on the location, community members may also be exposed to loud noise from entertainment, traffic and other sources. The potential cumulative effect is a highly adverse health load.

The matter of acceptable noise levels for national policy and legislation should be the subject of broad public discussion and agreement. It is crucial that NEPA facilitates such broad consultation as part of the decision-making process on the matters outlined in the draft NPPG. The agency must take steps to engage communities; representative groups, including vulnerable populations such as seniors; relevant professionals, including the medical fraternity; and allied professionals such as audiologists.

RECOMMENDATIONS

Some of the recommendations in the review document are noteworthy for support, including the conservative limits proposed by the UWI et al, which are in line with WHO guidelines, as well as recommendations for:

• The incorporation of more stringent conditions related to noise in the permit and licences conditions and planning permissions issued by NEPA.

• More rigid monitoring and enforcement of standards and conditions related to

noise.

• Establishment of noise class zones and greater engagement of citizens in the

policy guideline/plan-making process.

• The use of citizens and technological means to monitor noise levels, such as citizen noise groups, drones, and a noise quality network.

We also propose that the Government fund research by academic institutions on noise pollution and its impact on mental and physical health and the general well-being of citizens. Such research would provide the evidence to guide future policy and legislation.

Barbara Carby is a member of Citizens Rights to the City. Send feedback to columns @gleanerjm.com and citizensrights.tothecity@gmail.com.