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30th May 2003

Cc: Herbert Smith & Co

Dear Mr Nixon:

SUPPLEMENT TO COMMENTS ON MR MANNING'S RESPONSES TO QUESTIONS (NOISE)

I am somewhat reluctantly responding to Mr Manning's dismissal of my "Comments on Mr Manning's Responses to Questions" which I received at the end of the Inquiry. Mr Manning responds with the words: "I have seen Mr Winch's further comments in relation to the responses set out above. These do not alter the views set out in this rebuttal or my principal proof of evidence, nor do they raise any new evidence or questions which require further comment".

We appreciate that this is very late to add material to the Inquiry, and the problem (and my reluctance to get further involved) has arisen from the fact that Mr Manning's analysis of events contradicts common sense and our experience that (a) traffic noise is damaging to our quality of life, (b) that increased traffic (as we submit is an inherent aspect of this proposal) must make the problem worse and that (c) this doesn't just have to be accepted by local people either at its present level or a higher level. This clash of prior assumptions and the technical nature of the subject makes Mr Manning's rebuttal very hard to counter in a constructive manner.

I have kept Mr Manning's own Appendices in mind in my responses but find that with the prior assumptions he makes the conclusions he comes to are inevitable. The problem lies with his prior assumptions and rationale, and to make these points clearer I have supplied alternative noise data and commentaries which to my mind make our conclusions clearer. These documents appear to be on average six years more recent than Mr Manning's extracts from the Manual for Roads and Bridges Volume 11 Part 7 Traffic Noise and Vibration ("The Manual"), but I am not suggesting that our data or critique of the subject are necessarily different. However we find that different interpretations and conclusions arise from the documents we enclose which helps us to make our points more clearly.

The distinction in The Manual between noise, as variously measured, and noise nuisance, is important but the subject is obviously highly technical. We seek to address these matters in a less technical, common sense manner, suggesting that whereas the analyses are technical the prior assumptions are thoroughly "political". They are issues that the generalist is in fact required to take rather than the specialist. To illustrate this point we would mention that the derivation of a concept of noise nuisance from noise levels in The Manual (Chapter 3 p A27 in Mr Manning's Appendices) raises all sorts of value judgements such as how many more people will be upset by this or that development. At least sometimes, the prior assumption should be: "Can we reduce the nuisance in absolute terms?". When, as we propose is the case with this tunnel proposal, the presumption is made that "x" people must suffer so that "y" people (probably different people and in fact not quantified) may benefit on the assumption of a questionable economic improvement, it is important to recognise that both the "do-something" and the "do-nothing (or a minimum)" options are in reality manifestations of a further inexorable deterioration of local people's quality of life. Members of the Alliance find this approach unacceptable, and indeed inappropriate in the case of the Tunnel Application. We seek the alternative of traffic reduction. My further comments to Question 13 below, concerning what is and isn't "realistic", also refer.

The documents I attach as Appendices have been supplied to me amongst others by various Alliance members, none of whom is an expert on noise matters but some of whom deal with experts from time to time (as do I): the documents are authoritative however (some come from the same (but later) source as Mr Manning's) and my colleagues and I feel that they confirm various aspects of the traffic noise problems that we argue would follow from the tunnel scheme. The documents which I enclose are as follows:

382/O/10 Appendix a ("Noise: More than an Irritant" UK Noise Association).

382/O/10 Appendix b ("3.3 Interference with Speech Communication", from "Guidelines for Community Noise" by Bergland et al WHO (2000)).

382/O/10 Appendix c ("Table 4.1:Guideline values for community noise in specific environments" Bergland et al).

382/O/10 Appendix d (WHO Guidelines 1999 extract regarding speech communication problems in noisy places)

382/O/10 Appendix e (Bergland et al 2.2: Transportation noise 2pp)

382/O/10 Appendix f (DETR "Proposed Environmental Noise Directive").

382/O/10 Appendix g ("Noise News", Newsletter of the UK Noise Association Issue 1 Autumn 2000).

I refer to these documents individually in my further comments on Mr Manning's response to my questions, as follows. My original comments are reproduced in plain text, followed by my new comments which are in italics:

Questions 1 and 2: I appreciate that noise is measured logarithmically but I find it hard to accept that a 25 percent increase in traffic gives rise to only 1 dB increase in sound level. Perhaps Mr Manning is referring to the maximum "swish" when vehicles pass. In practice however increased traffic means that one can converse with a companion (such as children accompanied to school on foot) (say) 25% less 25% = none of the time. That is in fact my experience and my particular sum assumes the road starts 75% full and increases in traffic level to 100% full (or a higher level of "stress") which is the apprehension we have.

Time exposed to a noise impulse DOES increase with traffic levels, and I suspect that at least in this sense the increase is disproportionate in the opposite sense to what Mr Manning claims. I.e., small increases produce disproportionally large amounts of distress. In the above example the situation changes from snatched conversation between passing vehicles, to no conversation. This is also my direct experience and seems to me to justify my remarks.

Further comment: Our Appendices a - d indicate that present sound levels as measured by Mr Manning on many residential and public access roads in the locality of the ends of the present tunnel are already excessive (TWPTA 6A Appendix B Table CM1). In our response to Question 9 we will argue that the sound levels experienced on pavements will be much higher than Mr Manning has measured. Our Appendix a for instance confirms that the sound levels measured, let alone higher figures as mentioned above can be anticipated to cause personal inconvenience and make conversation difficult. We claim that the construction of the tunnel would not only induce more new journeys than the proponents indicate, but also that the construction has to be viewed as part of a traffic-growth strategy. This has to be contrasted with the Alliance's (and, we understand, the Government's) preferred policy of traffic restraint (my comments on Question 13 below, as to what is "realistic" to expect, also refer). The level of noise nuisance which the Alliance seeks to reduce, and what the PTA proposes to impose on local people are clearly in conflict, and the outcome from the PTA's proposals would get worse still with time. This is contrary to Mr Manning's claim in his answer to Question 7 that noise on some roads would decrease. Even if Mr Manning's claim were true at the opening of the proposed new tunnel, the situation would deteriorate to a much worse state of affairs, subsequently.

Question 3 "It is not until one gets to much higher levels of noise than are being considered here that a threshold of tolerance might be considered.......". This tells us everything we need to know, namely that we are expected to put up with noise levels "such as 100dB" before we are considered to be "inconvenienced". What drivel! My comments about night workers apply, additionally. I take it that any concept of "tranquility" has gone not out of the window (more exactly, is expected to come in through the window by way of its denial, at up to 100dB).

Further comment: I acknowledge that my response above is intemperate, but in view of Mr Manning's seeming acceptance of noise nuisance in residential areas as a "fact of life" which can be increased 100% because this only causes 3Db(A) measured noise increase - which is considered to be marginally noticeable - I think the causes of my wrath, and that of Alliance members and local residents, will be understood by Mr Nixon. I appreciate that the "Tunnel proposal" does not anticipate a 100% traffic increase: however the logic of traffic increase I have set out in my comments above does clearly indicate that large traffic increases are inevitable in the course of time if this scheme is permitted. Indeed unless traffic reduction measures are taken, or gridlock has the same effect, 100% increases in traffic in some areas are inevitable, while lesser but still substantial increases would be the general experience.

Question 4 Mr Manning makes the point that those exposed to over 68dB road noise are not entitled to insulation unless this arises from a new or altered highway. I note that extra traffic from the proposed new tunnel would technically not qualify since the alterations to the highway occur mainly under the river, even though the extra traffic impacts directly on people's houses (and even worse, gardens, public places and pavements) all over the region. No joy here, then.

Further comment: We submit that noise outside houses is equally important to noise inside houses, and excessive noise is indeed a major feature of a poor quality of life in some urban environments as illustrated in Appendices a - d. The tunnel scheme would make the present situation worse (and increasingly bad), whereas in our view local residents are entitled to a better standard of living.

Question 5 I gather that we can expect maximum noise on pavements, public places and, in effect nearly all gardens, as I anticipated.

Further comment: Mr Manning acknowledges that roadside noise is not susceptible to reduction by mechanical barriers such as fences, insulation etc.

Question 6 I simply don't accept that no one would use a pavement or other public place where the noise is "unacceptable". People have no choice............... Oh yes they do! I'm wrong! They could avoid the problem (but add to the suffering of others) and go by car! Best of all, they could drive across the River in a new tunnel!

Mr Manning's answer, like my comment which is facetious, is cut off from reality. By "reality" I mean what myself and neighbours have to contend with every day of the week. Clearly there is a question over what we mean by "unacceptable". I mean "intrusive, making conversation difficult, and one's environment bloody awful".

Further comment: My assertion that conditions on our pavements and elsewhere cause distress now, using Mr Manning's own measurements, are in our view validated by the criteria set out in my Appendices a - d. As indicated above, that Mr Manning should suggest that if this were not so, people wouldn't use these roads, is preposterous. If, conversely, Mr Manning is suggesting by implication that these noise levels must be acceptable because people do use these roads and pavements he should consider why they use them (because they live there), what factors constitute inappropriate stress (noise amongst other things), why health breakdowns occur (inappropriate stress), and what additional dependency on the health support services and loss of employment revenue through disability (let alone the discomfort and unhappiness of the people concerned) may arise from this cause.

Question 7 I think Mr Manning's point here is that we must all move into the country. But we must not all move to the same bit of country or we will simply transfer the problem we now have in towns, to the country. (This is exactly what will happen if traffic growth is not restrained). I don't accept Mr Manning's assertion that we have simply to put up with increasing noise as a consequence of living in an urban area and I regard this view as profoundly worrying, coming as it does from a noise specialist. Having lived in towns most of my life (although I was brought up in the country so I know what quiet is), and having lived in central London as well as in London's suburbs, Kent, various parts of Newcastle and now South Tyneside, I know that urban areas can be remarkably quiet. Unless you're near a busy road..............

Just to accept ever-increasing noise is indeed "unacceptable" in my book, and I expect it would be in Mr Manning's experience were he exposed to the problem. I take it that he isn't, since I can't believe he would respond to these questions, in this way, if he were.

Further comment: The criteria set out in Appendices a - d were met in all the urban locations in which I have lived as set out above. In South Tyneside these conditions are met where I live now since our house is separated from Victoria road by several other houses and gardens. (By a strange coincidence nearly every house I have occupied in urban areas has been near to a railway. A bed-sitter I occupied as a student backed onto the (then) Manors shunting yard which operated at night). The sound levels in all these residences were acceptable, and some were quieter than in the countryside where birds sing, sheep cough, foxes bark, trees rustle, and all in all there is frequently quite a racket going on at night. In contrast, and apart from the influence of roads, factories, and noisy neighbours, urban residential areas are mostly quiet. This means that there is no "urban licence" to create road noise or to exacerbate existing road noise as Mr Manning suggests. The implication of his remarks that towns are a free-for-all for noise generation is exceptionally worrying. One begins to wonder whether the tunnel project, which was described by one PTA witness as a bypass, has been routed through a densely populated area specifically because it is known that under present legislation (subject to a Public Inquiry when appropriate) noise can be imposed on town dwellers Willy nil. This is in our view insidious and false logic when the same development in a rural area would give rise to instant protest on the basis that it would damage the "tranquility" of the countryside. The denial of any possibility of "tranquility" to urban dwellers according to the argument that towns are sometimes noisy seems to me to constitute a false syllogism. As mentioned elsewhere, by way of comparison, one needs to recognise that the countryside can be noisy too. Concerning mitigation of noise in urban areas by way of physical barriers one has to accept that fences, and insulation of houses, don't meet the need.

Question 8 I take it we will happily be deafened on pavements, plus or minus 3 dB, and whether or not we can or cannot actually detect a 3 dB change. By "happily" I am not referring to the victim of this injustice, and I beg forgiveness for more irony.

Further comment: My point is that noise on pavements my be experienced less than one metre from the source, so applying the inverse square relationship which texts on acoustics state applies to the amelioration of noise with distance, the experience of noise at the kerbside is much greater than the figures Mr Manning gives us. Mr Manning's figures apply to the facades of adjacent houses or other buildings.

Question 9 I'm glad noise nuisance outside buildings gets some acknowledgment.

Further comment: Cannot spaces outside buildings also be required to provide "retreat and relaxation" (Mr Manning's words) from the inside world? Do we step inside our houses and other buildings to relax, or may we at least occasionally step outside into the open air for leisure purposes and relaxation especially, of course, in Summer? In the Alliance we don't accept that, outside buildings, urban GEORDIE can be exposed to any level of traffic noise that suits planners (and would-be tunnel-builders) just to "reduce congestion on A19 and A1". (In any case we argue that the tunnel wouldn't have the claimed effect in the long run and it would cause major additional problems elsewhere in the short run as well).

Questions 10 and 11 If Government guidelines are based on "normal" hearing then they do automatically discriminate against those with better hearing. In fact I suggest that the sort of standards we are talking about are unacceptable to people who are all but deaf. I define "unacceptable" as in my response to Question 6 (above).

Further comment: Mr Manning says the noise levels concerned in the Application do not cause physical harm. I presume this means they don't burst ear drums. However Appendix c shows hearing impairment at 70 Db(A)LAeq and annoyance at 55 Db(A)LAeq, and these levels are experienced in the region now (TWPTA 6A Appendix B Table CM1 and much higher figures as I suggest will occur at the kerbside). Our common experience of noise levels routinely experienced on busy Tyneside roads, by those of us who live here, clearly indicates that noise is already unpleasant. I don't think local people elect councillors to make situations like this worse. Whatever one may consider the causes of general ill-health, and the cases of hearing impairment in the region, one cannot deny that loud road noise reduces the quality of urban life. Once again Appendices a - d refer. Appendix e (2.2.2 second paragraph) adds the point that noise increases when vehicles have to stop and start. This interference with smooth traffic flow must follow from a traffic increase on local roads and especially narrow residential roads.

Question 12 (Re: people on night duty) Mr Manning agrees this is a problem, but he writes that the small increase predicted to arise from the tunnel scheme will be marginally detectable. We contend that: a) the increase is underestimated (my response to Mr Emms and others refer), and b): the tunnel scheme is part of a traffic growth policy which does what it says and "grows" traffic. We seek a traffic reduction policy. So comparing our scheme with the NTC scheme, the difference in noise nuisance between the NTC proposal and our alternative would be large.

Further comment: I do not need to amplify this comment - the needs of people on night duty are illustrated by the table and quotations in our Appendix a.

Question 13 (Re: scheme comparisons with alternatives) My comments are the same as for (12) above.

Further comment: I have the further comment to make in response to Mr Manning's answer to the question of whether traffic reduction, which is the alternative to the tunnel proposal which we advocate, "is realistic". The word "realistic" came up at the Inquiry several times, and to repeat our argument on this point in this context, I suggest that the tunnel proposers' notion that traffic can be allowed to increase is most certainly unrealistic. The evidence for this may be found in all current planning guidance, by a short trip on the M25, and even a by look at the present congestion in parts of the region both on major and minor roads. The parking requirements for the present level or car ownership are also unrealistic, and indeed they are not met. People park their cars on the pavements, and the police do nothing about it. We feel it is not unrealistic to hope that Northumbria Police will follow their colleagues in other conurbations (eg London) and ban pavement parking other than in designated signed zones, and institute penalties for infringement of this ban. Then there would be even less space for vehicles on roads.

Question 14 (Re: House price reductions due to noise). My comments are as for (12) above.

Further comment: With the abandonment of the option of a new Riverside Route through the Hebburn to Pelaw Riverside Park (which is an outcome we celebrate) we note however that this means that, with the proposed tunnel in situ, traffic along Victoria Road Hebburn and the Felling Bypass would increase substantially with no alternative route available. This is due to extra traffic arising directly from the tunnel (which we suggest would be a net increase and not as the PTA argues) and indirectly through a permitted general increase in traffic. In our view this must affect house prices substantially. Many other roads such as Tynemouth Road and Wallsend Road on the north side are likely to suffer likewise.

It may be a philosophical or moral point, but with reference both to road noise and aircraft noise we question whether the fact that some people don't mind (even, notice) the problem means that the whole population should be subjected to the annoyance. This is a counsel for the adoption of the standards of the least aware and least critical in society, or in another sense "the lowest common denominator". This ties in with my suggestion in my original Question 10 that traffic noise is discriminatory (as is other noise) in that some people are far more susceptible to any given noise nuisance than others. I would add here that this can be for physical reasons (varying levels and types of hearing acuity) and aesthetic reasons (some of us can tolerate any given perceived level of racket more easily than others).

Question 15 (Re: Health impacts). Mr Manning claims that increases are so small they will have negligible effect. We disagree with this too, along the lines of (12) above.

I have no further comment on this item.

Related matter: Appendix f

We enclose Appendix f to indicate that the Government is likely to have to comply with more stringent noise legislation arising from the proposed European Noise Directive, so present levels of noise will come under increasing scrutiny, and measures such as the proposed tunnel which directly and indirectly make noise levels worse will be clearly non-compliant.

Related matter Appendix g

We enclose Appendix g as a good summary of the various noise issues confronting society of which road noise is just one. In noise terms as in others we see a clear need to improve the quality of life for all. Sometimes this aspiration is at variance with the perceived goal of increasing the quantity of goodies for some (uncritical "economic growth"). Against our more constructive aspiration, we in the Tyne Crossings Alliance see the tunnel proposal as an example of reactionary and short-term thinking which is against the public interest.

Appendices a to g are attached here. They are listed on page 1.

END