Noise occupies a paradoxical position in terms of UK environment policy. By contrast with other pollutants, it is almost universal in our urban areas, is increasingly encroaching on rural, "tranquil" areas, and is progressively eroding the period of night-time quiet. Despite this, the control of noise has never been subject to an overarching policy or legislative framework, in the same way as, for example, air quality or waste disposal. This neglect may be partially explained by the fact that the effects of noise on the general population have been historically easy to overlook. In addition, the nature of noise, and the reaction of people to it, does not lend it easily to the sort of mechanistic approach available to other pollutants.

However, there is evidence, from various sources, that the general public is unwilling to accept excessive levels of ambient noise in their living environment, as quality of life becomes increasingly valuable. While noise is transitory in nature, the effects it has on human health, and the quality of life and urban environments, are cumulative and so it comes under the umbrella of sustainable development. Therefore, if full integration with other social, environmental and economic issues is to be achieved, there must be a more strategic approach to the measurement, understanding and control of environmental and domestic noise.

The relative absence of data means that scope for the rapid development of such a strategy, with clear targets and measures, may be limited. Nevertheless it is important to develop a more coherent and integrated policy framework and get into place specific timetables and targets for priority issues. It is also important that this framework is set within the context of the UK strategy for sustainable development and that it encompasses the social and economic aspects of noise, as well as the environmental. The emphasis of the strategy must be ambient noise, the main source of which is road transport, although industrial, domestic and leisure noise must also form an integral part. These arguments are based on the paper submitted to the Environment Minister, Michael Meacher, as part of the NSCA's continuing campaign for a UK noise strategy.

Any strategy needs to have an overall and clearly stated objective towards which it, and the actions it contains, must be directed. While there is no wish to pre-empt the necessary discussion on the form of this objective, the following may offer a working objective for the time being:
To minimise environmental noise, where it is cost effective and practicable to do so, within an economically, socially and environmentally sustainable transportation, commercial and industrial infrastructure.

The development of more detailed objectives and targets should then be addressed in a way which reflects the special characteristics of noise as a pollutant. There is a crucial divergence here from other strategies, in particular that for air quality. A noise strategy cannot be built on the development of absolute standards or objectives as this would ignore some of the quintessential aspects of noise as a pollutant. The variation in the subjective reactions to noise, the difficulty in quantifying quality of life and the valuing of amenity and its loss, all act against the setting of blanket standards. Simple application everywhere of health-based thresholds, as has been done for air quality, will not suffice, because of the need to include annoyance and quality of life considerations.

The provision of adequate access to tranquillity, both spatially and temporally, is a key issue and one which the strategy must address. Given the current limitations in knowledge concerning both the noise climate and the effect of that climate on the population, any targets should be incremental and progressive rather than absolute. Nevertheless there should be an overall goal which might best be expressed in terms of securing a universal access to certain "rights" in respect of noise annoyance.

As part of this process, there should be a review both of current legislation and of the standards, formal and informal, currently in use by enforcing authorities, house builders, designers, etc. There are many instances where numerical targets, proposed in the 1960s and 1970s to suit conditions and technology then in play, are still in regular use by authorities and others. These are occasionally reviewed or amended on an ad hoc basis resulting in a disjointed and inconsistent noise control regime. An assessment of these quasi-official standards is required, and they need to be either updated or replaced with a more relevant and strategic enforcement and assessment system.

In parallel with the establishment of an overall objective for the strategy, an up-to-date assessment of the key sources of environmental noise and noise annoyance should be assembled. This will need to consider the trends in the principal sources, their impacts - both in terms of the severity of effects and the numbers affected - and the metric by which sources are measured. The principal source categories included in this assessment are likely to be:

• neighbour noise
• leisure noise
• industrial noise
• transport/general environmental noise.

The assessment should not, at this stage, attempt to prioritise sources; this is a task which should be open and informed and should come during later stages of the strategy's development. It should also be borne in mind that while transport is the principal source of environmental noise, it is by no means the principal source of complaint. The strategic priorities, when they are set, should reflect the public's concerns and should engage the general public by addressing their main preoccupations in the noise field. Care must be exercised when considering the methodology for assessing these concerns - it is insufficient to use complaint data alone and more reliable and sophisticated methods should be developed. Furthermore, the source analysis recommended above should inform the development of a clearly defined noise research strategy. It should also assist in clarifying Government's stance on noise mapping and the role it sees for this in an overall process of noise assessment and management.

Abatement Measures
In the next stage, the strategy needs to pull together a coherent government assessment of what can be achieved in the main abatement options. In particular:

- A more coherent approach to the consideration of noise within the planning regime. There should be a government commitment to review and strengthen this, as well as a clear indication of its views as to the scope for progress.

- Given the social character of noise, education and incentives can play a critical role. The Government has largely left this to voluntary bodies and, given what are often very tight budgetary constraints, it has not received the profile it deserves. Government should give a clearer indication of where responsibilities in the educational field lie, and what the key focus should be.

- The Government must also set out, within the wider context, the role it sees for regulation in relation to noise, addressing the following issues:

a. the outcome of its review of domestic noise legislation, and the scope for regulation in this field
b. how it sees the treatment of industrial noise being carried forward, in the context of IPPC and, in particular, whether it proposes to maintain a role for nuisance legislation. The options considered should include the possibility either of moving progressively to a prior authorisation approach to industrial noise emissions, or of developing best practicable means as a general legal obligation, rather than simply as a defence to nuisance charges
c. the effectiveness of the current building regulations in ensuring that domestic sound insulation is of a sufficiently high standard, and the relationship of this to other environmental policies.

The combination of the analysis of the main sources and the effectiveness of the abatement options should then closely inform the process of setting the strategy's priorities. NSCA would strongly support the use of the methodology for the development of environmental standards set out in the 21st report of the Royal Commission on Environmental Pollution to develop the priorities. The full and early integration of public values and concerns into the strategy will greatly enhance the relevance and importance of the final document.

The Framework for a Strategy
Following the analyses detailed in the previous sections, the framework of a final strategy will have begun to emerge. The elements of this framework are the objectives for the strategy, the principal sources of noise, the abatement options and a preliminary set of priorities for action. However, in order to strengthen this framework and to enable key action areas to be identified, the strategy should also cover the following:

- How noise mapping might be used at local level as a data collation and presentation tool, and as a basis for testing local strategies and delivery options. This should be linked to national policies and priorities.

- A systematic approach to the assessment of costs and benefits, which should be built into the earliest stages of strategy development, rather than incorporated at a relatively late point as with the Air Quality Strategy.

- Notwithstanding a predominant focus on environment (and therefore largely transport) noise, an attempt to address separately three specific problem areas:
a. eliminating hearing damage or measurable health impacts from identifiable sources - notably leisure events
b. household noise - a long-term policy in the context of the Government's recent review and the possibilities for raising the standard in terms of domestic sound insulation, both in terms of new build and the existing housing stock
c. a policy framework for the treatment of industrial noise which can guide the way noise is addressed within IPPC, and clarify the relationship between statutory controls and nuisance, in the context of the role of best practical means.
While all the above issues have challenging features, it should be possible to develop a clear stance on each of them with relative simplicity. The central issues of environmental noise, and in particular transport sources, could then be addressed. The strategy should take the form of a phased programme with the following incremental objectives:

- Seeking to avoid deterioration in the noise climate and protection of tranquil areas (and times).

- Development of a wider programme of measures to ensure that the likely impact on noise levels of increased vehicle numbers and more intensive use over the next 20 years is offset.

- Identification of priority areas for supplementary local action and the implementation of measures to reduce noise levels in these areas, avoiding displacement to non-priority areas.

- A general framework for reducing overall noise levels by, amongst other things, planning measures, implemented through guidance to local authorities which allows them to assess local priority areas.

Assigning Responsibility
The final element of the strategy, once the framework is assembled and the priorities established, is to assign responsibility for action under these priorities. It is very important that action is taken at the appropriate scale and that there is a clear understanding by all involved as to what this is. Clearly some actions, for example the control of noise from vehicles through manufacturing standards, lie most appropriately at the European level. Other action is most appropriately vested in national Government and agencies, others for regional government, still others for local government etc. While this may appear obvious, other strategies and policy areas have failed where responsibility is not properly assigned, or where the actions do not fit with the scale of organisation in which they are vested.
The strategy must therefore clearly assign responsibility and tasks for:

• central Government
• national agencies
• regional bodies and devolved administrations
• local government
• business and industry
• voluntary organisations and NGOs
• individuals.

In setting these responsibilities, there must be a full and participative dialogue with all those involved and attempts must be made to engender a sense of ownership of the issues. In the process of developing the strategy, a full analysis of the resource implications should be undertaken. In identifying the necessary resources, the strategy should adopt an innovative approach, to include the hypothecation of fees and charges, incentives for industry and direct grant support for individuals involved in improving their noise environment.