PROPOSED SKATEPARK: MEMORIAL PLAYING FIELD: STEYNING

Transcription

1 PROPOSED SKATEPARK: MEMORIAL PLAYING FIELD: STEYNING AS NIA An Assessment of the Impact of a Proposed New Skatepark on nearby Residential Premises Prepared: 18 th February 2013 Friends of Memorial Playing Field c/o 5 Charlton Street Steyning West Sussex BN44 3LE t[details for page numbers - DO NOT edit without guidance] [Total no. of pages] 22-3

2 [PAGES FOR FOOTER] 19 [Footer Text in row below - apply colour to show text. Edit if necessary BEFORE applying footers.] [Set colour white BEFORE printing]

3 CONTENTS!"#$ % &&'()#*&&(+, -#.!"!$/ /, -''0.! --'.!($/ -#.!!$/ 1 -''0.!2$/ 1 List of Attachments AS7313/SP1 AS7313/TH1 4 Site Plan showing noise survey location and the proposed skatepark location Time Histories showing the current typical noise levels at nearby residential properties Appendix A Appendix B Acoustical parameters Calculations AS7313/C1&C2 Base design

4 1. INTRODUCTION It is proposed to construct a new skatepark in the Memorial Playing Field, Steyning, West Sussex. The proposed location is on the site of the current basketball court on the western boundary of the playing field. The closest affected residential property is Byways in Mill Road to the north of the playing field. It is approximately 90 metres from the centre of the proposed skatepark location to the dwelling. The property Toad Lodge and others on Newham Lane to the south of the playing field are also some 110 metres from the centre of the proposed skatepark. Because of the landform of the playing field, these are also noise sensitive properties. The noise climate in the area has some road traffic noise from Charlton Street, Mill Road and Newham Lane, but is generally a quiet area. Alan Saunders Associates (ASA) have been commissioned by the Friends of the Memorial Playing Field to undertake a noise survey of the prevailing background noise climate and subsequently assess the suitability of the site for the skateboard park facility in relation to current standards and guidance documents and other appropriate assessment procedures. ASA have also been asked to review noise impact reports produced for Steyning Parish Council, originally by Atkins (September 2012) and subsequently by Acoustic Dimensions (November 2012). Both of these reports have been submitted to Horsham District Council (HDC) in support of a planning application for the skatepark. 2. SURVEY PROCEDURE An environmental noise survey was carried out over the extended weekend period from 14:30 hours on Thursday 31 st to 12:00 hours on Monday 4 th February Measurements of the L Amax,fast, L A10, L Aeq, and L A90 noise levels were made over consecutive 10 minute periods. The following equipment was used for the survey. Norsonic Data Logging Sound Level Meter Type 116 Gras Environmental Microphone Type 41AL Norsonic Sound Level Calibrator Type 1251 The measurement location in the garden of Toad Lodge in Newham Lane was considered to be representative of the typical noise levels existing at the closest residential AS7313 PROPOSED SKATEPARK, MEMORIAL PLAYING FIELD, STEYNING Page 1 of 19

5 properties to the proposed skatepark site. The microphone was set up in the rear garden at approximately 1.8 metres above ground level. This measurement location is shown in the site plan AS7313/SP1, where the location of the proposed skatepark is also indicated. The calibration of the equipment was verified before and after use. No calibration drift was observed. Measurements were made generally in accordance with ISO :2007 Acoustics - Description, measurement and assessment of environmental noise Part 2: Determination of environmental noise levels. Because of the time permitted by HDC the weather conditions were not ideal during the survey period with gusty winds. Since the survey was carried out, however, to determine predominantly the background L A90 noise levels, these levels would be less affected by the wind gusts. During the less windy periods of the day, the typical L Aeq,10m and L Amax values are representative of typical values. The validity of the ASA measurements is confirmed by the measured L A90 levels during the survey being about the same or lower than those levels measured by both Atkins and Acoustic Dimensions during their very short term surveys. An explanation of the acoustic terminology used in this report is in given in Appendix A. 3. RESULTS Figures AS7313/TH1-TH4 show the L Aeq, L Amax,fast, L A10 and L A90 as 10 minute environmental noise levels. The Steyning Parish Council (SPC) Operational Management Plan, published as part of the planning process indicates an operational period for the skatepark from 08:30 until dusk. The term dusk is non-specific but is qualified in the proposed notice at the rear of the Management Plan as not to be used when it is dark. During the summer evenings this could be as late as 22:30 hours but a closing time of 21:00 hours has been assumed as a reasonable end to the day based on previous experience of use at many other skateparks. Since there is no security fencing proposed, however, there is nothing to prevent use outside this period when any impact would be significantly greater than predicted in this assessment as the background noise level reduces. Typical noise levels measured on site are shown in Table 3.1. AS7313 PROPOSED SKATEPARK, MEMORIAL PLAYING FIELD, STEYNING Page 2 of 19

6 Assessment period 08:30 21:00 hrs Typical L Aeq,10m (db) Typical L A90,10m (db) Typical L Amax,fast (db) Byways & Toad Lodge Table 3.1 Current measured noise levels [db ref 20µPa] Reviewing historical hourly weather data for Steyning and the Time History plots, the afternoons of Thursday 31 st January; Saturday 2 nd February; and Sunday 3 rd February gave acceptable wind speeds, for which the above measured L A90 levels of 30-38dB are representative of levels over the proposed operational periods. A typical level of 35dB: L A90 has, therefore, been used in the subsequent noise impact assessment for the proposed skatepark. It should be noted that, whilst Atkins undertook manual background measurements until 19:3 0 hours and show similar levels to those measured by ASA, the Acoustic Dimensions report contains no measurements beyond 15:00 hours and does not, therefore, represent the actual ambient (L Aeq ) and background (L A90 ) noise levels during the late afternoon and early evening when the impact of the skatepark is likely to be at its maximum. 4. METHODS OF ASSESSMENT In relation to the noise produced by leisure activities, such as skateboarding, there are no specific assessment methods or criteria in relation to noise impact. There are, however, a number of assessment methods which are related to activities where sudden loud noises occur during skateboarding (L max ) heard against a generally quiet underlying background (L 90 ). A comparison of the L Aeq,T (the average energy during the time T) with the underlying background L 90 is also relevant to the impact on nearby residential properties and other tranquil uses. These methods have been used extensively by Alan Saunders Associates in relation to skateboard noise for both assessment and the design of actual skateparks. These methods were accepted by the court in the landmark case in relation to skateboard noise, Richardson v Devizes Town Council, where the judgement forced the Local Authority to remove the skatepark equipment and awarded substantial damages and costs to Mr Richardson. These assessment methods have been adopted by a number of local authorities and other acoustic consultants. In order to assess the impact of noise from the skatepark, reference should be made to published guidelines which reflect current scientific thinking and Government advice. This AS7313 PROPOSED SKATEPARK, MEMORIAL PLAYING FIELD, STEYNING Page 3 of 19

7 good practice of using assessment methods which are relevant and helpful, is endorsed by the procedures set out in the draft document BS9142: Guidelines for Environmental Noise Management. Measurements of skateboard/skatepark use noise have previously been undertaken at numerous other sites by Alan Saunders Associates as part of design and research projects for bowl and street scene skateparks. The data that will be used for this assessment were measured at a concrete skatepark, which is the same as the likely proposed construction material and semi bowl type for this site. The data for this assessment uses the average noise level (L Aeq,1h : 54.5dB) generated by approximately 20 skaters with typically 5 using the skatepark bowls and ramps measured at a distance of 40m from the centre of the skatepark. To ensure a robust assessment, this level has been used throughout. Even with fewer overall numbers of skaters, its use by 5 skaters during much of the opening hours is probable during the school holidays and at weekends. Maximum noise levels of skateboarding events (L Amax :71.0dB) have also been measured at a distance of 45m which relate to use of the street scene parts of the skatepark, which will be used to assess event noise. The noise levels will be calculated to approximately 3.5m outside the rear facades of the nearest residential receivers in Mill Road and Newham Lane, using standard sound propagation theory. From experience, all of the following three methods of assessment need to show acceptable noise levels for a new skatepark to ensure that complaints in relation to activity noise are unlikely to occur. In practice, the third method of assessment based on the CIEH document Clay Target Shooting, Guidance on the Control of Noise is the most sensitive as it relates specifically to the maximum noise levels, which are the most common cause of complaints in relation to skateboard noise. 4.1 British Standard BS4142: 1997 British Standard BS4142:1997 Method for rating industrial noise affecting mixed residential and industrial areas is designed explicitly to assess the noise impact from industrial noise on residential properties, and does not refer to any recreational areas. However, due to the lack of guidance when assessing skatepark noise and the quantification of tonal, impulsive or intermittent noise upon residential receivers, BS4142 can at least provide some guidance as to the likelihood of complaints, even though it may not be specifically designed for this purpose. As stated earlier, this assessment AS7313 PROPOSED SKATEPARK, MEMORIAL PLAYING FIELD, STEYNING Page 4 of 19

8 methodology has been accepted by the court in the case of Richardson v. Devizes Town Council with regard to skatepark noise impact. In order to quantify the impact of the skateboard activities, the British Standard BS 4142 is useful since it considers the character of the noise. This standard compares the noise levels in terms of an L Aeq for a one hour period during the daytime (07:00 23:00 hours) and a five minute period during the night-time (23:00 07:00 hours) for the noise source in operation, the Specific Noise Level, with the existing background noise level in terms of an L A90 when the noise source is not operating. As part of the assessment, consideration is given to the character of the noise. The standard states: If the noise contains a distinguishable, discrete, continuous note (whine, hiss, screech, hum, etc.), or if there are distinct impulses in the noise (bangs, clicks, clatters, or thumps), or if the noise is irregular enough to attract attention, add 5dB to the Specific Noise Level to obtain the Rating Level. From observations, skateboarding noise is transient with many bangs as the skaters hit the top of the ramps or jump on and off the equipment. This + 5dB character correction has, therefore, been applied in subsequent calculations. This standard then compares the noise level corrected for any character correction as an L Aeq 1 hour (for daytime) for the noise source in operation, called the rating level with the existing underlying background noise level in terms of an L A90 when the noise source is not operating. The arithmetical difference between the rating level and the background is called the assessment level. BS4142 indicates for the assessment level, in relation to noise sources of an industrial nature: A difference of around +10 db or higher indicates that complaints are likely. A difference of around +5 db is of marginal significance. AS7313 PROPOSED SKATEPARK, MEMORIAL PLAYING FIELD, STEYNING Page 5 of 19

9 If the rating level is more than 10 db below [i.e. -10dB(A)] the measured background noise level then this is a positive indication that complaints are unlikely. For new skateparks, however, an assessment level of 0dB has been used as a criterion of acceptability to ensure a robust assessment of the noise impact of skateboarding noise. The measured noise levels for skateboarding activities at another concrete bowl skatepark being used simultaneously by about 5 skaters have been used historically as the basis for this assessment. These measured levels have been corrected for distance so as to give the levels outside the closest properties. The closest residences, which would be most affected by noise from the skate park, would be the rear elevations of Byways in Mill Road and Toad Lodge in Newham Lane. These predicted noise levels are shown in Table 4.1 based on the calculations AS7313/C1&C2 shown in Appendix B to this report for the base design. These indicate the Specific Noise Level: L Aeq,1hr values for skateboarding which have been used for the BS4142 assessments. Condition Location Specific Noise Level L Aeq,1h (db) Rating Level L Aeq,1h (db) Typical Background L A90,10 m (db) Skateboarding noise to Byways, Mill Road Position Skateboarding noise to Toad Lodge, Newham Lane Table 4.1 Measured skateboarding noise levels Position db ref 20µPa Summarising the differences between the rating level, and the current background L A90 level over the proposed opening hours of 08:30 21:00 hours, the following assessment level has been predicted. Location Assessment Level (db) BS4142:1997 Assessment Skateboarding noise to Byways, Mill Road Skateboarding noise to Toad Lodge, Newham Lane Table 4.2 Predicted assessment level +17dB +16dB Complaints are very likely for skateboarding noise Complaints are very likely for skateboarding noise db ref 20µPa AS7313 PROPOSED SKATEPARK, MEMORIAL PLAYING FIELD, STEYNING Page 6 of 19

10 The above indicates that the predicted rating noise level at both receptors from the new skatepark would be significantly above the current typical background noise level and would not achieve the rating level criterion for skateboard noise of 0dB. The indicated levels would certainly result in complaints from residents. 4.2 World Health Organisation: Guidelines on Community Noise: 1999 The WHO document Guidelines for Community Noise sets out guidance on external noise levels at which there will be an unacceptable impact on communities. This guidance considers many different types of noise sources. In paragraph the impact of noise on dwellings is considered. The document states: During the daytime, few people are seriously annoyed by activities with [steady] L Aeq levels below 55dB; or moderately annoyed with L Aeq levels below 50dB. Sound pressure levels during the evening and night should be 5-10dB lower than during the day [i.e dB serious annoyance; 40 45dB moderate annoyance]. It is emphasised that for intermittent noise [such as the skateboarding activities] it is necessary to take into account the maximum [i.e. the L Amax ] sound pressure level as well as the number of events. The levels referred to above are L Aeq,16h values. As a worst case, assuming pessimistically that skateboarding on the new park is continuous for 9 of the 16 daytime hours, the L Aeq,16h close to the rear facades of the two receptor properties would be approximately 42-43dB(A). These values are within the limits indicated above for day or evening and indicate that the WHO Guidelines would consider these levels to be within acceptable levels in the nearby gardens. This level is about the same as the current evening L Aeq noise levels at the receptors measured during the Atkins survey. 4.3 Comparison of Skateboard Noise to Gunshot Noise The sudden nature, duration and the character of the skateboard impact noise during jumps and turns, etc., by skateboarders bears a close aural similarity with the noise from gunshots at a distance. There have been a number of research investigations into what levels of gunshot noise cause annoyance to residential occupants, notably by Sörensen S & Magnusson J, G F Smoorenburg and Hoffman. The current thinking on their impact which generally agrees with the previous research, has been published as Clay Target Shooting, Guidance on the AS7313 PROPOSED SKATEPARK, MEMORIAL PLAYING FIELD, STEYNING Page 7 of 19

11 Control of Noise published by the Chartered Institute of Environmental Health Engineers in January Measurement and social survey work carried out by the Building Research Establishment during 1996/1997 provides the basis for applying limits at noise sensitive premises, which range between the mid fifties to the mid sixties SNL 25 Shots:30minutes. The above research suggests that there is no fixed level for annoyance to occur. Annoyance is, however, unlikely below a level in the mid fifties : SNL 25 Shots:30minutes and highly likely above a level in the mid sixties SNL 25 Shots:30minutes as measured at the noise sensitive premises. The SNL 25 Shots:30minutes is the logarithmic average of the loudest 25 shots measured as a maximum (L Amax ) in a 30 minute period. From the predicted levels of noise for skateboarding activity taking place, the levels at Byways on Mill Road and Toad Lodge on Newham Lane would be 65dB and 63dB L Amax(fast), respectively equivalent to an SNL of 65 and 63dB. For the purposes of calculation, these maximum source noise levels are assumed to be at a nominal height of 0.5 metres above the base of the skatepark to represent the use of street scene parts of the skatepark. Using the above assessment method, this level represents one at which annoyance by the skateboard noise levels at both the Mill Road and Newham Lane receptors would be at or tending towards a level at which complaints would be highly likely. On the basis of this assessment it is very likely that these maximum skateboard noise levels would cause complaints from the residents living in Mill Road and Newham Lane. 5. DISCUSSION The above methods of assessment have demonstrated that the BS4142 and Clay Target Shooting impact predictions do not provide acceptable levels. As indicated previously, all the three methods of assessment need be positive for the skatepark to be viable in terms of noise impact. Because of the low levels of background noise in the MPF, the BS4142 assessment indicates assessment levels of +17dB for the closest Mill Road properties and + 16dB for those closest in Newham Lane. With these substantial excesses mitigation in the form of earth bunding or fencing is not a viable option. The currently indicated bunding at AS7313 PROPOSED SKATEPARK, MEMORIAL PLAYING FIELD, STEYNING Page 8 of 19

12 approximately 1.5 metres provides no more than 5dB attenuation. To achieve the 16-17dB attenuation required, would require bunds of a height which are unsustainable both structurally and in terms of visual amenity. Mitigation is not an option for the skatepark and these assessments are the strongest indication that planning permission should not be granted for the skatepark. The impact on the users of the Bowls Club and those in their allotments adjacent to the skatepark will also be significant. The skatepark will give impulsive noise levels which are different in character than current noises and significantly above the typical quiet background within the MPF. This is likely to result in significant annoyance to these users. 5.1 National Planning Policy Framework [NPPF] The NPPF was adopted on Tuesday 27th March 2012 and provides the following guidance with regard to noise Planning policies and decisions should aim to: avoid noise from giving rise to significant adverse impacts on health and quality of life as a result of new development; mitigate and reduce to a minimum other adverse impacts on health and quality of life arising from noise from new development, including through the use of conditions; recognise that development will often create some noise and existing businesses wanting to develop in continuance of their business should not have unreasonable restrictions put on them because of changes in nearby land uses since they were established; and identify and protect areas of tranquillity which have remained relatively undisturbed by noise and are prized for their recreational and amenity value for this reason. The NPPF in turn refers to the Noise Policy Statement for England [NPSE]. The NPSE was issued in March 2010 by Defra with the following aims: avoid significant adverse impacts from noise; AS7313 PROPOSED SKATEPARK, MEMORIAL PLAYING FIELD, STEYNING Page 9 of 19

13 mitigate and minimise its lesser but still adverse impacts; contribute to the improvement of health and quality of life through the effective management of noise, for example through the promotion of quiet areas. The NPSE utilises three concepts from toxicology to be applied to noise impacts. They are: NOEL No Observed Effect Level. Below this level, there is no detectable effect on health and quality of life due to the noise. LOAEL Lowest Observed Adverse Effect Level. This is the level above which adverse effects on health and quality of life can be detected. SOAEL Significant Observed Adverse Effect Level. This is the level above which significant adverse effects on health and quality of life occur. In a case such as the proposed skatepark, the scheme would not result in lower noise levels in the area. Neither of these documents, however, provide any guidance as to assessment methodology or levels at which the effects discussed can be noted. The skatepark would, however, have a substantial impact on the environmental noise levels in the surrounding area. 6. THE ATKINS AND ACOUSTIC DIMENSIONS REPORTS 6.1 Atkins Report of September 2012 Methodology The methodology used by Atkins is similar to that used by ASA, that is reviewing both the predicted L Aeq levels of skateboarding with the L A90 background using BS4142 and considering the impact of the maximum (L Amax ) noise levels using the CIEH guidance in relation to clay target shooting which has a similar character to skateboard noise at distance. Distance to Receptors The Atkins report quotes distances from the skatepark (Para 2.3) as 62 metres for Mill Road properties and 80m for those on Newham Lane. These are thought to be the distances from the closest edge of the skatepark to the property boundaries rather than AS7313 PROPOSED SKATEPARK, MEMORIAL PLAYING FIELD, STEYNING Page 10 of 19

14 the distances from the centre of the skatepark to a position approximately 3.5 metres from the residential facades used by ASA. Since the current skatepark drawing STMF- PSP01-rev C (16/11/2012) post-dates the Atkins report it is also not clear on what base information they carried out their distance measurements. Skateboard Source Measurements The Atkins report, however, uses as its source data individual measurements of specific activities normalised (corrected) to 1 metre (Table 6.2) and then calculates the level at the receiver treating the skatepark as a point source (i.e. a small point) rather than the large area source that it is. This significantly overestimates the reduction to the receptors from the skatepark and hence predicts levels at the receptors in Mill Road and Newham Lane which are too low. Based on research carried out into skateboard noise propagation at active skateparks, ASA measurements have been made at sufficient distance to allow normal correction procedures (6dB per doubling of distance) to be applied since they already contain the required source corrections. Taking into account the overall effects of the different distances used and the source corrections, the predicted impact and levels in the Atkins report are about 5dB(A) lower than those of ASA for the L Aeq and L Amax values. Environmental Noise Measurements Atkins carried out a manned environmental noise survey using 15 minute measurement periods. No measurements were made at the beginning of the operational day or in the morning, but were made into the evening when background noise levels would be reducing. The measured background noise levels show a similar range to that discussed in Table 3.1 of the ASA report and use correctly an arithmetic average level of 35/36dB: L A90 for their assessment. This is consistent with the L A90 : 35dB used in the ASA assessment as a typical background noise. Assessment of the Noise Impact For the reasons indicated above, the Atkins skateboarding noise levels at the receptors in Mill Road and Newham Lane are too low. The Atkins BS4142 assessment still, however, AS7313 PROPOSED SKATEPARK, MEMORIAL PLAYING FIELD, STEYNING Page 11 of 19

15 concludes that without mitigation Complaints are likely at both the closest residential locations. With regard to the assessment of the SNL, however, Atkins incorrectly quote the CIEH Clay Target document in their Para 7.4..the SNL predicted at Newham Lane is just within the recommended limit of 55-60dB.. The document actually states in Section 6.1 that At a shooting noise level below the mid 50 s db(a) (i.e. 55dB) there is little evidence of significant levels of annoyance at any site, whereas for levels in the mid to high 60 s (i.e. greater than 65dB(A)) significant annoyance is engendered at the majority of sites. This is qualified in Note 1 to of Appendix A.5.11 Planning permission should not normally be granted for a major (i.e. commercial) shoot if the mean shooting noise level exceeds 55dB where the background noise (i.e. L A90 ) is less than 45dB. The background L A90 noise level is usually significantly less than 45dB in the Memorial Park and the SNL limit should, therefore, be around 55dB, i.e. not 55-60dB as quoted by Atkins. Mitigation On the basis of their assessments Atkins conclude in para the development of the skatepark has the potential to impact on the amenity nearby noise sensitive receivers. And in 8.2 It is possible to reduce, but not necessarily eliminate, these impacts by employing a combination of a number of mitigation measures, including control of hours of operation, and appropriate earth bunding around the development. The bunding is in 8.3 likely to be at least 1.5m in height (above the highest surface within the park) and surrounding the extent of the skatepark, would offer some attenuation. The level of attenuation to be provided by the bunds is not specified in the report. The bunds that Atkins had in mind at 1.5m above the highest point of the skatepark have not been included in the drawings submitted with the planning application. The level in the SW corner of the park at is only 500mm below the top of the bund (at 13.81) on the north side of the skatepark. Calculations carried out by ASA indicate that the attenuation of the bund shown in the planning drawings is likely to be 5dB at best. The current skatepark design is, therefore, likely to cause significant annoyance to the closest residential areas. AS7313 PROPOSED SKATEPARK, MEMORIAL PLAYING FIELD, STEYNING Page 12 of 19

16 6.2 Acoustic Dimensions Report Methodology In their executive summary Acoustic Dimensions (AD) indicate they have assessed the noise from the proposed skatepark in relation to the current ambient (L Aeq,T ) noise and the noise from football. This is a flawed comparison for the following reasons:- i) For environmental noise, even that with a relatively broad frequency character such as an extract fan, the L Aeq needs to be assessed against the underlying background L A90 (the level exceeded for 90% of the time), not the ambient L Aeq. It is the noise impact during the 10% of each hour when the background noise is at or below the L A90 that relates to its annoyance. This is standard procedure for all local authorities. Comparison with the ambient L Aeq would substantially underestimate the true impact or likely annoyance. For noise with more a more complicated character such as skateboarding noise, comparison with the background noise is significantly more important. ii) iii) Comparing the noise from skateboarding with that from a football match assumes they have the same character when clearly they do not. They are completely different as anyone could identify. The annoyance from noise is not only related to its level, but also to its character. So a noise source which contains random harsh sounding bangs and crashes from skateboard impact with ramps and grind rails, etc., will be much more annoying than distant football noise which is mainly vocal with relatively subdued noises during kicking of the ball. The shouting human voice features significantly in football but not in skateboarding. Para of the WHO Guidelines recognises this as It is emphasised that for intermittent noise [such as the skateboarding activities] it is necessary to take into account the maximum [i.e. the L Amax ] sound pressure level as well as the number of events.. The AD report contains no mention of the maximum noise levels during skateboarding or their impact, which are the major sources of annoyance to residential occupants. Another factor that is directly related to the annoyance from a noise source is its duration and how often it occurs. To compare a football match which AS7313 PROPOSED SKATEPARK, MEMORIAL PLAYING FIELD, STEYNING Page 13 of 19

17 lasts, say, once each week 90 minutes with skateboarding noise which could potentially occur between 08:30 to 22:30hrs every day during the summer months (when there would be no football) is clearly a flawed hypothesis. A comparison would be if a helicopter flew over your house at low level once a week, you wouldn t be annoyed by it. If it happened five or six times in a day, you would probably begin to be annoyed. If this happened every day of the week, you would be highly annoyed. AD s assertion that The occurrence of maximum occupancy will be outside school hours. Usage of the skateboard facility will be very low during school hours, in the early morning and after dark. is clearly flawed as the schools have at least 20% of each year on holiday. Even during the Easter holidays when football is being played, it accounts for 1.7% of the likely period over which skateboarding could take place at that time of year and the football/skateboard noise comparison is less than dubious. In their Executive Summary AD confirm that when assessed under BS4142 complaints would be deemed likely. They then state that it is not applicable because the site has a very low background noise level. This is a misreading and misinterpretation of BS4142 which actually states in section 1 Scope, The method is not suitable..or when the background noise and rating levels are both very low. It defines very low as background levels below 30dB and rating levels below about 35dB. As previously discussed, background noise levels measured by Atkins, ASA and AD(Table in Para 2.3.1) vary between dB: L A90,15m. The rating level from Atkins and ASA is between dB. These are both significantly above the BS4142 threshold meaning it is applicable for this assessment. Whilst it is specifically used for industrial noise it does allow the assessment of impact and impulsive noises against the underlying background and, as the court ruled in Richardson v Devizes Town Council and accepted by Atkins in their report, is a reasonable and informative comparison in the absence of any specific guidance in relation to skateboard noise. In para 5.9 of the AD report they refer to further discussion in Appendix A in relation to BS4142 and the CIEH document. Unfortunately, Appendix A does not contain any further discussion. AS7313 PROPOSED SKATEPARK, MEMORIAL PLAYING FIELD, STEYNING Page 14 of 19

18 Distance to Receptors The AD report carries out calculations to thirty two residential receptors, although there is no details of their distances from the new skatepark save a mention in Para 5.5 of..receiver 32 80m. From the site plan in Para this location is at the rear boundaries of the closest properties in Mill Road. Skateboard Source Measurements In their Appendix C, AD report measurements made at distances of 2 metres from skateboarders in their table on Page 25. The table gives measurements in relation to the L Aeq over a variety of different time intervals and the SEL but no L Amax values. They then state (Para 3.1-Appendix C) We have used a point source propagation method to calculate noise from proposed skateboarding. They go on to say in Para Our calculations.based on guidance given in ISO : It is presumed they mean ISO as ISO 9623 relates to Metal pipe/adaptor fittings. In a similar way to the Atkins report, instead of just measuring noise from busy skateparks, at a distance, they construct a model using their measurements and an assumed activity pattern and assume that only 50% of the users are skateboarders whilst the other 50% are, the much quieter uses such as scooters and BMX bikes. There is no noise data provided for these uses. As the skatepark is a large area source, this overestimates the reduction to the receptors from the skatepark and hence predicts levels at the receptors in Mill Road and Newham Lane which are too low. Environmental Noise Measurements The current ambient noise that AD measured, as shown in their Para 3.1, indicate a Log average L Aeq,T based on only four 15 minute measurements between 09:00 and 15:00 hours of 53dB for Mill Road and 46dB for Newham Lane. This is an inadequate number of measurements over too short a period to make any informed judgement as the typical levels over the skateboarding day. It should also be noted that log averaging provides a level which is dominated by the highest value measured so, in their second graph on page 6, the three measurements they made at about 43dB: L Aeq,15m are skewed by the last measurement at 50dB: L Aeq,15m to give a value of 46dB, whereas 43dB is more the typical AS7313 PROPOSED SKATEPARK, MEMORIAL PLAYING FIELD, STEYNING Page 15 of 19

19 value as can be seen in our Time History AS7317/TH1 measured at the Newham Lane properties. In the graph in Para 3.5, their ambient L Aeq is further skewed by using Site wide ambient and background noise levels. This further elevates their ambient and assessment levels by skewing them towards the louder measured levels on Mill Road so that when subsequently reviewed against football noise levels and skatepark noise levels in and they seem about the same as the current ambient levels. The graphs in AD s Para s and report Upper and Lower Log Ave (log average) L A90 noise levels. This is a fundamental technical error since L A90 values cannot be averaged logarithmically as they are statistical parameters, they can only be arithmetically averaged i.e. added up and divided by the number of values. It is also not clear, therefore, what the Upper and Lower.. values mean, as the values in their Appendix B in Para 2.3 have a much wider range than the values in the two graphs. Assessment of the noise Impact The AD Introduction states in Para 1.3 We have completed our assessment based on an appropriate methodology agreed with Horsham District Council. In Para 1.4 they state. We compare noise from the proposed skateboarding facility with ambient noise (i.e. L Aeq,T ) and with noise from football matches played at the Memorial Playing Fields. Any assessment method which does not consider the impact of maximum skateboard noise levels as well as the L Aeq against the underlying background L A90 noise level and the frequency of occurrence is flawed, since it is these characteristics which dictate the probable levels of annoyance to nearby residential. Mitigation In Para 6.1 and 6.2 AD note that the currently indicated bund does..not have a significant (effect?) on our calculations of noise at residential properties. This is because in their Para they state that Receiver locations were chosen 3 m off the ground corresponding to first floor (bedroom) windows. Our calculations assume a clear line of sight between source and receiver locations. At this receive height it is agreed the bunds would have no effect. At a normal daytime receive height, of say, 1.5 metres, AS7313 PROPOSED SKATEPARK, MEMORIAL PLAYING FIELD, STEYNING Page 16 of 19

20 however, the effects at the closest properties would be as detailed previously in this report, with the bunds giving about a 5dB reduction in propagated noise. To achieve the 16-17dB attenuation required, would require bunds of a height which are unsustainable both structurally and in terms of visual amenity. In their Para 6.4 AD state that In our opinion earth bunds are not required to provide additional reduction in noise from the proposed skateboarding facility. Noise levels will be suitably low that disturbance is unlikely.. This opinion is based on a novel but flawed assessment method. The current skatepark design is, in reality, likely to cause substantial annoyance to the closest residential areas. 7. SUMMARY AND CONCLUSIONS 7.1 Noise measurements of skateboarding on a concrete bowl skatepark have been used to predict the possible noise impact of the proposed new skatepark at the Memorial Playing Field at Steyning in West Sussex. There is no directly specific guidance as to the impact of skateboarding noise on the occupants of residential premises, but there is relevant guidance given by British Standard BS4142: 1997 Rating industrial noise affecting mixed residential and industrial areas the World Health Organisation document Guidelines on Community Noise: 1999 and the document Clay Target Shooting, Guidance on the Control of Noise published by the Chartered Institute of Environmental Health Engineers (CIEH) in January 2003 which has been accepted in landmark noise cases and is used by many acoustical consultants and local authorities for new skateparks. The most sensitive residential properties are some metres from the centre of the proposed skatepark location. From the predicted noise levels at these residences and long term measurements of the background and ambient noise levels, the likely impact of the skateboarding noise on the residential amenity has been considered using the three documents referred to above. This initial evaluation procedure has been used successfully at other currently operational skateparks. AS7313 PROPOSED SKATEPARK, MEMORIAL PLAYING FIELD, STEYNING Page 17 of 19

21 The conclusion of the analysis within the report is that the current skatepark design is likely to cause substantial annoyance to people living in the closest residential areas. 7.2 The methodology used by Atkins is similar to that used by ASA, that is reviewing both the predicted L Aeq levels of skateboarding with the L A90 background considering the impact on the underlying background noise and the impact of the maximum (L Amax ) noise levels using the CIEH guidance in relation to clay target shooting, although it misreads the guidance in relation to noise levels and likely annoyance. Their prediction of the source noise also underestimates the true noise impact at receptors. The Atkins report concludes that The skatepark has the potential to impact on the amenity of nearby noise sensitive receivers., and Any skatepark installed at this location should include the provision of mitigation measures in an effort to minimise these impacts. They then describe the mitigation measures as limiting the opening hours so as to close by 8:30pm and Carefully designed earth bunding required around the park at least 1.5m higher than the highest point within the park. Reviewing the SPC drawing the indicated bunding will not achieve the requirements set out by Atkins. 7.3 The Acoustic Dimensions Introduction states in Para 1.3 We have completed our assessment based on an appropriate methodology agreed with Horsham District Council. In Para 1.4 they state. We compare noise from the proposed skateboarding facility with ambient noise (i.e. L Aeq,T ) and with noise from football matches played at the Memorial Playing Fields. This is a flawed comparison because:- Even broadband noise sources such as an extract fan are required to be reviewed against the underlying background noise L A90 and typically to lower than this by 5-10dB. Comparison with the average ambient noise level (L Aeq ) on a Saturday and during a football march is neither logical nor representative of the likely impact on nearby residents. Comparing the noise from skateboarding with that from a football match assumes they have the same character when clearly they do not. Character is a significant indicator in human annoyance by noise. AS7313 PROPOSED SKATEPARK, MEMORIAL PLAYING FIELD, STEYNING Page 18 of 19

22 The comparisons made by Acoustic Dimensions do not consider for how long and how often the noise is produced. These again are major factors in human annoyance. If the football match occurred every day of the year over most of the daytime period, as the skatepark noise can potentially, then this would certainly be considered annoying by nearby residents. Once a week and only in the winter, when residents are not in their gardens, engenders a much higher level of tolerance to noise. The report like the Atkins report derives their source noise levels for skateboarding, using measurements made close to individual skaters (2 metres stated). For a moving source, however, any recorded distance can only be an estimate introducing the first potential for error. They then calculate the noise to distant receptors for a derived scenario of many skateboarders on a skatepark using.. a point source propagation method... This is incorrect, as the skatepark is a plane source whose area will mean that noise levels at distance are further underestimated. The noise impact is also underestimated as a result. In their Para 6.4 AD state that In our opinion earth bunds are not required to provide additional reduction in noise from the proposed skateboarding facility. Noise levels will be suitably low that disturbance is unlikely.. This opinion is based on a flawed assessment method. The current skatepark design is, in reality, likely to cause substantial annoyance to people living in the closest residential areas. Alan Saunders ALAN SAUNDERS ASSOCIATES AS7313 PROPOSED SKATEPARK, MEMORIAL PLAYING FIELD, STEYNING Page 19 of 19

23 Location 1: Byways, Mill Road 90 meters Proposed Skate Park Location Environmental Noise Monitoring Position 100 meters Location 2: Toad Lodge, Newham Lane Project: Steyning Skatepark, BN44 3LE Title: Indicative Site Plan Figure: AS7313 /SP1 Date: 18 th February 2013

24 100! Figure AS7313/TH1

25 100! Figure AS7313/TH2

26 100! Figure AS7313/TH3

27 100! Figure AS7313/TH4

28

29 ! " # "$% "" " " $% ""! " $% " # &$! # " ' ( ' )* )*( "+"%,' -* " #" ' )* """ #! ' " "" ' " " ".) " " #' " & ' " ' ' " '! " # " ",/""00 / & " 0 0 "" "12*34 ) / &9: )12 12* 2** )*** 1*** ;***.***

30 " & " &$:)**&$ 2* &$ "" " 7&$ " < " )*&$ """=" " " " $%&'%()% *+ ),-./'*0122'(% )%20(%2 *1 " >" 72? 6)* =""," )))2 >"", )61* ="", 1) >"" A, 3 ""! B " 0 "0:7" ""C " " 0 "0 "" " """ B "

31

32 Project: AS7313 Memorial Playing Field, Steyning Skatepark Newham Lane Impact as 'base' design BS4142 Assessment Receptor Toad Lodge,Newham Lane Distance 110 m L Aeq,1h for Skateboarding 55 40m Distance Loss to 110m -9 db Acoustic Screening 0 db L Aeq,1hr at Receiver(specific noise level) 46 db Character Correction 5 db Rating Level 51 db Background LA90 level 35 db Assessment Level 16 db * rounded to nearest db Conclusion Not OK Complaints very likely WHO Guidelines Assessment Skate Boarding 09:00-21:00hrs Worst case continuous 12 hours 7 hours out of 16hr Daytime 7 46 db(a) 9 0 db(a) Skating for 7 Correction -4 db out of 16 hours Acoustic Screening 0dB L Aeq,16hr = 42 db(a) * rounded to nearest db OK for day and evening (40-45dB) no moderate annoyance Clay Target Assessement L Amax for Bowlpark L Amax at Receptor Acoustic Screening L Amax at Receptor Comment L Amax (SNL)>55dB<65dB 45m 110m 0dB 63 db Tending towards 'Complaints being highly likely' Calculation AS7313/C1

33 Project: AS7313 Memorial Playing Field, Steyning Skatepark Mill Road Impact as 'base' design BS4142 Assessment Receptor 'Byways', Mill Road Distance 90 m L Aeq,1h for Skateboarding 55 40m Distance Loss to 90m -7 db Acoustic Screening 0 db L Aeq,1hr at Receiver(specific noise level) 47 db Character Correction 5 db Rating Level 52 db Background LA90 level 35 db Assessment Level 17 db * rounded to nearest db Conclusion Not OK Complaints very likely WHO Guidelines Assessment Skate Boarding 09:00-21:00hrs Worst case continuous 12 hours 7 hours out of 16hr Daytime 7 47 db(a) 9 0 db(a) Skating for 7 Correction -4 db out of 16 hours Acoustic Screening 0dB L Aeq,16hr = 44 db(a) * rounded to nearest db OK for day and evening (40-45dB) no moderate annoyance Clay Target Assessement L Amax for Bowlpark L Amax at Receptor Acoustic Screening L Amax at Receptor Comment L Amax (SNL)>55dB<65dB 45m 90m 0dB 65 db Tending towards 'Complaints being highly likely' Calculation AS7313/C2