Proof of Evidence on Noise Helene C S Evans BSc(Hons) MIOA MASA

Transcription

1 Proof of Evidence on Noise Helene C S Evans BSc(Hons) MIOA MASA Appeal Ref No: APP/R0660/W/15/ Cheshire East Application No: 14/0114M Hybrid planning proposal by Argonaught Holdings Ltd c/o LPC Living Ltd for mixed-use redevelopment seeking: A. Full planning permission for alterations to existing employment buildings, construction of new employment buildings and installation of new ground services, piping and ducting. B. B Full planning permission for demolition of remaining redundant employment buildings and removal of redundant over ground services, piping and ducting C. Outline planning permission for construction of dwellings, associated infrastructure, landscaping and other associated works (means of access) at Harman Technology Site and adjacent land. Ilford Way, Town Lanes, Mobberley. Inquiry: May Helene Evans_ _Appeal PoE Page 1 of 24

2 1. Expert Experience 1.1. I am Helene Caroline Evans. I am a free-lance acoustic consultant and sole proprietor of Performance Acoustics, Mobberley I specialise in all aspects of building acoustics with particular interest in housing, education, hospitals and concert hall design I hold a Bachelor of Science in Electro-Acoustics Engineering awarded by the University of Salford in 1986 and have been an acoustic consultant since February I am a member of the UK Institute of Acoustics with 25 years of continuous membership. I also have 28 years continuous membership of the Acoustical Society of America I have lived in Mobberley for the last 8 years Recent dwelling projects include education projects include Hungate Development, York, Bishopstoke Care Village, Chamberlain Hall - University of Birmingham student accommodation and Lancaster & Morecambe College. In all instances, the acoustic and ventilation solution of the building facades was a fundamental design principle that needed to be resolved. Each project required a unique solution based on the basic acoustic design principles External noise control on existing buildings provide different challenges from new build projects. The following projects on existing buildings provided different and complex external noise environments that needed to be controlled: the refurbishment of Birmingham Town Hall, Leeds City Museum, Bluecoats Arts Centre - Liverpool, and the recently opened Birmingham New Street and Palasades Shopping Mall Birmingham. Helene Evans_ _Appeal PoE Page 2 of 24

3 2. Manchester Airport Operations 2.1. Manchester airport operates in an easterly direction only 20% of the time. During easterly operations, aircraft approach Manchester airport on landing over Mobberley and take-off over Heald Green % of the airport s operations are in the westerly direction. This means that aircraft take-off over Mobberley We understand that the noise contours used at Manchester Airport are prepared annually by Environmental Research and Consultancy Department of the Civil Aviation Authority using their ANCON (v2.3) noise model. The CAA uses the Airport s 2012 traffic data and applies the average runway operational splits for the summer period (e.g. the % of operations that were made in a westerly and in an easterly direction). The accuracy of aircraft following the departure tracks is taken from the actual data from Manchester Airport s Noise and track monitoring system (MANTIS). The assumptions on aircraft departure profiles (rate of climb, speed and thrust) are taken from the actual departure profiles for the predominant types of aircraft in use at the Airport (B , B , A319, A320 and B747). Date on time of operation, destination, departure route, aircraft type etc. is all actual data from the summer period of the specific year Note that the airport should also generate predicted contours for the following two years. We have not seen any predicted contours from the airport Also note that landing operations are quieter than take-off, and these noise levels are not included in the contour models The contours referred to in this report for the years 2012 and 2014 are those published by the Manchester Airport. We have not had sight of any other contours The site is only ~1500m from the end of Runway 2 which is principally used for take-off. 80% of the time take-off is over Mobberley Village. The Preferred Noise Route agreed Helene Evans_ _Appeal PoE Page 3 of 24

4 as part of Runway 2 s operations dictates that all aircraft have to depart directly over this area of the village following which they can only commence a right turn at ~2000ft (~600m) to avoid Knutsford, therefore they cannot avoid the site. This planning condition was specifically to reduce the number of people adversely affected by aircraft noise, i.e. taking off more often over the rural Mobberley end than the urban Heald Green end When landing from the east, over Mobberley, the aircraft are guided on final approach by the Instrument Landing system and the average height over the site is 350ft (~100m) Manchester Airport are currently operating at 50% of their current capacity. Planning permission has been granted for significant development at the airport which is likely to increase capacity by a further 33% on current capacity Published information from CAA give flight movements over the years from Manchester Airport and the number of movements in 2008 was 204,610 movements. In 2010 the number of movements dropped to 147,032 and have been growing steadily since then. In 2012 the number of movements was 160,473 and in 2014 it was 162,919 and grew to 173,124 in 2015 showing the continual growth anticipated. 3. Appellant s First Noise Report 3.1. The first acoustic report provided by the appellant was drafted by ACIA dated 01/11/2013 and submitted 31/10/ The ACIA report reviews noise from the existing industrial operations, on aircraft noise based on the 2012 noise contours as published by Manchester Airport ACIA measured aircraft noise measurements were undertaken in 2008 and these levels indicate a higher noise level on site than the 2012 contours. However, there is no explanation given for this difference and no comparison with the 2008 noise contours that the airport must have published. Helene Evans_ _Appeal PoE Page 4 of 24

5 3.4. Note to obtain the published noise contours, the actual aircraft movements and weather conditions are inputted in a model and the contours calculated. The airport do have noise monitoring positions around the airport but we do not have access to this raw data only the published noise contours ACIA s should have compared their measured data with the relevant published contours to validate their data and the contours for this site Published information from CAA give flight movements over the years from Manchester Airport and the number of movements in 2008 was 204,610 movements. In 2010 the number of movements dropped to 147,032 and have been growing steadily since then. In 2012 the number of movements was 160,473 and in 2014 it was 162,919 and grew to 173,124 in This could explain the difference between the measured numbers in 2008 and the contours published in However, we also know that significant growth is planned for the airport and therefore the 2008 numbers are likely to be a good indicator of the near future levels on the site The results of the report recommends designing the houses as sealed boxes with upgraded acoustic glazing and fully mechanically ventilated so that suitable internal noise levels can be achieved. A discussion of these mitigation measures is given in Section 7 of this report This report also comments on the high levels of industrial noise on the site and proposes some outline mitigation measures to reduce this noise However, a noise contour of the industrial noise and the aircraft noise in combination has not been included Our full critique of this report is given in Appendix 1 of this report. Helene Evans_ _Appeal PoE Page 5 of 24

6 4. Appellant s Second Noise Report 4.1. The second acoustic report submitted by the Appellant was by Temple and dated 20 th August This report provides no new data and only deals with noise from aircraft. It provides a review of literature concerning aircraft noise and public health The report comments on the various public health studies but does not relate it to levels on this site No mitigation measures for internal or external noise are given as part of the report but they have been proposed later. The closed box solution is also proposed by Temple to achieve the recommended indoor noise levels. Again see section 7 and 8 of this report for our comments on this proposed solutions For external noise control, a car-port style canopy is proposed. The effectiveness of this proposal is discussed in Section 8 of this report Our full critique of this report is given in Appendix 2 of this report. 5. Daytime Aircraft Noise Levels on the Site 5.1. The ACIA report provides continuously measured noise levels for aircraft noise measured between 22 July 2008 and 29 July The full data are not provided in the report These noise levels have not been compared to the published noise contours for that year although the airport will have published this data The airport was operating in the easterly direction all day on 24 July 2008 and until 1200 on 25 July 2008 and again on Monday 28 July The noise levels on these three days are the lower daytime levels at 58dB L Aeq,16hr, 61dB L Aeq,16hr and 58dB L Aeq,16hr respectively. Helene Evans_ _Appeal PoE Page 6 of 24

7 5.4. The rest of the daytime measurements are 63dB LAeq,16hr on 22 July 2008 (a shortened measurement period) and 65 db LAeq,16hr Using only the noise levels for the days when the airport is operating in a westerly direction, the average daytime noise level is 64.6dB LAeq,16hr and 64.9dB LAeq,16hr if you consider only the days when the full 16 hours were measured This data implies that the 65dB LAeq,16hr contour runs across the middles of the site shown in the figure below: Helene Evans_ _Appeal PoE Page 7 of 24

8 5.7. These measured noise levels have not been compared with the Airport s published noise contours for that year and therefore it is difficult to assess the real measured noise values with the modelled values from the airport However, ACIA have used the contours for the year 2012 to assess aircraft noise on the site. These contours show significantly lower noise levels across the site with the highest contour clipping the top of the site being 63dB L Aeq,16hr as shown in the figure below: Helene Evans_ _Appeal PoE Page 8 of 24

9 5.9. Comparing the latest published contours from 2014, the noise levels on the site have increased from 2012 but are still below those measured in The 2014 contours are shown in the figure below: The government has marked 57dB L Aeq,16hr as the onset of significant community annoyance during the day ( ) No matter which data you look at, the entire site is above this noise contour and therefore significant community annoyance is anticipated Comparing the published noise contours from 2012 and 2014, it is clear that noise from aircraft has increased across the site. It is essential to note that the airport is currently Helene Evans_ _Appeal PoE Page 9 of 24

10 operating at 50% of its current capacity. So noise is likely to increase due to more flight capacity currently available However, Manchester Airport have been granted permission to expand the airport significantly with Airport City, World Trade Centre and development plans for terminals. This would allow for even greater growth of flight movements anticipated to add 33% and increased noise in the vicinity of the airport Due to previous planning agreements with the airport, the Preferred Noise Route takes all flights over Mobberley, both on take-off and landing The Manchester Airport Noise Action Plan estimated 1600 houses in the noise contours 63-65dB L Aeq,16hr and 5650 houses in the 60-62dB L Aeq,16hr. Importantly, the vast majority of these houses lie NE of the airport in Heald Green and Stockport, areas where they are only subjected to these levels 20% of the time. The houses in Mobberley are subjected to the noise levels 80% of the time. All the houses in this development fall within these contours and would therefore add to the number of houses to these contours One of the obligations on Manchester Airport as part of the S106 planning agreement for the 2nd Runway, was to provide a contribution towards insulation of any existing houses falling within the 62dB L Aeq,16hr contour. Nearly half the proposed houses would fall within the 62dB L Aeq,16hr contour as shown in the figure below. The red line is the 2014 Helene Evans_ _Appeal PoE Page 10 of 24

11 63dB LAeq,16hr contour and the yellow line is the estimated location of the 62dB LAeq,16hr contour based on the 2014 contours: As part of the second runway development the airport was obliged until 2011 at least, to not increase the population and area subjected to 60dB LAeq,16hr or greater levels. We have not been able to obtain the 1992 contours but we are sceptical that the area or population within the 60dB LAeq,16hr contour has remained the same as the levels in The increase in the areas within the 60dB LAeq,16hr contours from 2012 to 2014 support our view. It is unclear what the Airport s obligations are after 2011 but generally the government aims for a reduction not an increase. Helene Evans_ _Appeal PoE Page 11 of 24

12 6. Night-time Aircraft Noise Levels on the Site 6.1. The night-time noise levels measured on the site in 2008 and again the noise levels for the easterly and westerly operations of the airport were separated. The night-time noise levels for westerly operation was 52.4dB LAeq,8hr and 49.dB LAeq,8hr for easterly operations Therefore the 52dB LAeq,8hr night-time contour runs across the middle of the site as shown in orange in the figure below. The estimated 50 and 53dB LAeq,8hr contours are shown in yellow This indicates that all the proposed housing development area (approximately 365 houses) of the site is in a noise level above 50dB LAeq,8hr. Helene Evans_ _Appeal PoE Page 12 of 24

13 6.4. The measured noise in 2008 are higher than the 2012 noise contours as shown in the figure below. Helene Evans_ _Appeal PoE Page 13 of 24

14 6.5. However, if we use the most recent 2014 contours, the night-time noise levels are significantly higher as shown in the figure below: 6.6. The 2014 contour indicate that the entire site is subject to noise levels above 57dB L Aeq,8hr Similar to the Airport s obligation to not increase the area within the 60dB L Aeq,8hr as measured in 1992/3. This obligation was up to 2005 and to be reviewed with the intention of extending it to It is not clear what their obligation beyond 2011 is. From the difference between the 2012 and the 2014, we anticipate that the area of the 60dB L Aeq,8hr contour has increased significantly from the 1992/3 area. Note that virtually all of the proposed housing area is above the 60dB L Aeq,8hr contour as shown in the figure in para 6.5 above. Helene Evans_ _Appeal PoE Page 14 of 24

15 6.8. The World Health Organisation (WHO) Night Noise Guidelines indicates that noise levels between 40 and 55dB L Aeq,8hr cause adverse health effects in the population and the population has to develop coping strategies with vulnerable groups being severely affected. Above 55dB L Aeq,8hr situation is considered increasingly dangerous for public health According to the 2014 contours, all houses in the proposed development will be subject to noise levels greater than 57dB L Aeq,8hr. In fact virtually all the houses will be above the 60dB L Aeq,8hr contour, significantly above the upper limit for night-time noise level of 55dB L Aeq,8hr. In summary, the WHO would deem the entire housing development as a danger to public health Due to the location of the site directly in line with the runway 2, it is highly unlikely that the noise level at the site could be reduced by up to 15dB by altering aircraft noise emissions or flight take-off and landing patterns Using the 2014 contours ALL the houses are significantly above the 55dB L Aeq,8hr limit. And a noise reduction in the order of 20dB would be required on the site to meet the WHO guidance of 40dB L Aeq,8hr and 25dB Reduction to meet the BS8233 requirements of 35dB L Aeq,T. These levels of reduction are only possible with the closed box mitigation measures discussed in section 7 and would oblige residents to have windows closed at all times to maintain suitable internal noise levels. 7. Propose Mitigation Measures Internal Noise Levels 7.1. BS8233:2014 Guidance on sound insulation and noise reduction for buildings is the current British Standard providing guidance on the acoustic design of buildings. The Standard advises appropriate criteria and limits for different building types including dwellings BS8233 provides guidance regarding acceptable internal and external noise level criteria for dwellings but does not form any statutory requirement to achieve the guidance values Helene Evans_ _Appeal PoE Page 15 of 24

16 provided therein. The BS8233 internal design criteria for dwellings are given in the table below: Activity Location Time of day 07:00 to 23:00 23:00 to 07:00 Resting Living rooms 35dB L Aeq,16hour - Dining Dining Room / Area 40dB L Aeq,16hour - Sleeping (daytime resting) Bedroom 35dB L Aeq,16hour 30dB L Aeq,8hour 7.3. Section G1 of BS 8233 advises that, where windows are open for ventilation, then sound reduction is limited to 15dB. Therefore when external noise levels are 50dB L Aeq or below, open windows will provide a suitable internal environment in living Rooms and Bedrooms External levels above this will require some level of attenuated ventilation system to provide sufficient ventilation and a suitably quiet internal environment The proposal for noise mitigation is to provide acoustic glazing to all windows, enhanced roof construction and fully mechanically ventilate the house with air-conditioning. It is not clear to what extent these mitigation measures are proposed. However, we would assume that all the houses would need this treatment since they are all above the 60dB L Aeq,16hr contour Although this acoustic treatment is effective and would ensure that the internal noise levels meet the WHO recommendations, it relies on the windows being closed at all times, meaning no natural ventilation Mobberley village is a rural village surrounded by fields and farmland. Tractors and horses are not an unusual sight on our streets and the outside environment is an integral part of Mobberley life. The concept of living in an enclosed environment is not in keeping with the rural setting. Helene Evans_ _Appeal PoE Page 16 of 24

17 7.8. Note that these mitigation measures would be compatible for any buildings designed for employment use. 8. Propose Mitigation Measures External Noise Levels 8.1. For gardens and terraces, the Standard states that it is desirable that the steady noise level does not exceed 50dB L Aeq,T whilst a level of 55dB L Aeq,T would be acceptable in noisier environments. However, BS 8233 states that, 'it is also recognized that these guideline values are not achievable in all circumstances where development might be desirable In such a situation, development should be designed to achieve the lowest practicable levels in these external amenity spaces, but should not be prohibited' The WHO recommends that every dwelling has access to an outdoor living area that is subject to noise levels at or below 50dB L Aeq,16hr with 55dB L Aeq,16hr regarded as the upper limit for these spaces There is nowhere on this site that is below 55dB L Aeq,16hr and most of the gardens for the housing development area are subject to noise levels above 60dB L Aeq,16hr The appellant has proposed a Tranquillity area at the furthest south eastern corner of the site. Although this area is in fact the quietest area of the site it is far from tranquil and subject to noise levels above 57dB L Aeq,16hr, higher than the WHO s upper limit for open spaces Note that the tranquillity area proposed equates to approximately 1% of the area of housing. It is also adjacent to the playing fields and sports pitch. Again not tranquil activities The concept of such a small area in an unacceptably high noise environment and as far from the housing as possible being a tranquillity area is absurd In addition to the Tranquillity area, they have proposed a Noise Zone Canopy onto the garden to provide a noise shelter in the garden. Each canopy to be at least 12m2 and made from material with a minimum sound resistance of 15dB R w. Helene Evans_ _Appeal PoE Page 17 of 24

18 8.8. This sounds plausible until you consider the physics of the canopy. The 15dB R w figure is misleading because the effectiveness of the canopy depends on its ability the SHIELD the receiver from aircraft noise. Otherwise the sound will miss the canopy and reach the receiver unattenuated. The canopy could be made out of solid 300mm concrete (~50dB R w ) and still not provide any protection from aircraft noise The canopy is supposed to act as a noise barrier similar to noise barriers along a motorway. The barrier works by hiding the noise source from the listener. If you have line of sight then there is no shielding provided from the barrier In the case of a motorway, the distance and height of the noise source and receivers are relatively fixed or do not vary significantly. However, with aircraft this is not the case. These canopies would only become effective when they block the view of the aircraft and it is likely that they would only achieve a 5-7dB reduction in that instance only. For the majority of a plane s flight path, the canopies will provide no protection whatsoever A rough calculation indicates that for someone sat under the very middle of the canopy, the planes would have to be above 300m (1000ft) above the houses. Data from the airport indicates that on landing, they are only 100m (300ft) above the houses. On takeoff the height and location of the planes will vary more significantly than on landing. Also, planes using runway 1 would have to be significantly higher for the canopies to be effective. Helene Evans_ _Appeal PoE Page 18 of 24

19 8.12. Also note that it would be more usual for people to sit in a circle under the canopy as shown in the appellant s submitted drawing, excerpt below, putting some of the receivers closer to the edge of the canopy and therefore making them even less effective Furthermore, since they are only a canopy, aircraft noise will bounce off adjacent houses and shortcut any shielding from the canopy. Of course, to enclose the sides of the canopy, making it essentially a conservatory would control the noise but then it would no longer be outdoor living space The appellant has provided no evidence to show that the proposed canopy solution would provide an acceptable area of outdoor living within appropriate noise levels. 9. Mitigation of Industrial Noise 9.1. The ACIA reports indicates that most of the noisy operations at the site will not exist once Harman Technologies have been relocated in their new and refurbished buildings. Helene Evans_ _Appeal PoE Page 19 of 24

20 9.2. However, the cooling towers will remain and they are the main noise source. The appellant proposes the reduction of fan speeds and addition of attenuators to the cooling towers would reduce the noise level by 7dB This would reduce most of the cooling tower noise to around 53dB L Aeq. However, the noisiest cooling tower would seemingly only be reduced to 60dB L Aeq. This level is likely to be incident on the nearest gardens and houses to the cooling tower The proposed mitigation to reduce the internal noise levels of aircraft would also be effective for the industrial noise but the garden areas would not meet the 50-55dB L Aeq,16hr recommended by WHO Also note that as is there is 60dB from airplane activity and 60dB from the industrial noise, the overall noise level will increase to 63dB L Aeq Also, the cooling towers will affect the external noise level on the community area further raising the noise level. 10. Traffic Noise None of the acoustic reports provided by the appellant mention the potential for increased noise levels due to traffic. This is likely to affect the houses on Ilford Way since all site traffic will use this for access This is a significant increase on the existing traffic on Ilford Way. The addition of 360 houses and the new office buildings, together with the existing Harman Technology employment and housing on Marion Drive, would create a significant number of extra traffic movements. The Applicant s traffic forecast for the design year (2018) predicts 410 two-way vehicle trips in the weekday morning peak period ( ) and 403 twoway vehicle trips in the weekday afternoon peak period ( ), and 259 two-way vehicle trips in the Saturday peak period ( ). Using the Appellants trip rate Helene Evans_ _Appeal PoE Page 20 of 24

21 factors (from the TRICS database) this equates to 2938 two-way trips using Ilford Way on the average weekday between the hours of 0700 and Aircraft Noise Effect on Health The Aviation Environment federation published a report on Aircraft Noise and Public Health The evidence is loud and clear in January This summarises studies undertaken to date looking at the correlation of aircraft noise and various health conditions The main conclusion from the report is that current aviation policy does not reflect the evidence on health and recommends that any new guidance considers the severe health burden associated with sleep disturbance A full review of this report is given in Appendix 3 of this report Exposure to aircraft noise can lead to short-term responses such as sleep disturbance, annoyance, and an impairment in learning in children and long term exposure is associated with increased risk of high blood pressure, heart disease, heart attack, stroke, and dementia. There is evidence to suggest that aircraft noise may also lead to longterm mental health issues With these known health problems, it is the local authority s duty of care to the inhabitants to protect them from unnecessary risk from aviation noise. This would include avoiding the construction of sensitive dwellings in high noise areas Noise from a particular event rather than average noise, is understood to be more relevant in terms of sleep disturbance We have not seen any information regarding noise from individual events in terms of L Amax or similar. However, the ACIA report did mention that they had measured 3 events in excess of 82dB L Amax during the week period measured. We do not know if this is typical and how many other events occurred even if at a slightly lower noise level. Helene Evans_ _Appeal PoE Page 21 of 24

22 11.8. People are more annoyed by aircraft noise than by noise from other forms of transport and attitudes in the UK have identified that annoyance from aircraft noise is increasing despite individual aircraft becoming quieter Studies have shown that exposure to aircraft noise level above 63dB L Aeq,16hr has a 24% increase chance of stroke, 21% higher chance of heart disease and 14% higher chance of cardiovascular disease compared to people exposed to less than 51dB Using the 2014 contours, approximately 30% of the site is above 63dB L Aeq,16hr and therefore at this increased risk of cardiovascular diseases Note that the rest, a further 45% of the dwellings, would be in the dB L Aeq,16hr band and therefore still susceptible to the cardiovascular diseases, if with a slightly reduced risk It appears that night-time noise could be more important for cardiovascular health than day noise and this site is exposed to significantly higher noise levels than the government recommendations for night-time noise Aircraft noise has been found to be significantly associated with high levels of depression with the risk of depression increasing by 8.9% for every 10dB increase in noise level. This site is 17-23dB higher than the WHO recommended night-time noise level. This means that the inhabitants are at between 8.9 and 17.9% higher risk of depression The UK Government has retained the 57dB L Aeq noise contour as marking the onset of significant community annoyance despite evidence indicating it is out of date We understand that new policies are to be published later in Notwithstanding, the noise on the site is above this 57dB contour, the current guidance. It seems illogical to give permission for these house to be built in areas where noise exceeds the existing criteria knowing that we anticipate more stringent guidelines. The report concludes that Helene Evans_ _Appeal PoE Page 22 of 24

23 during the day, outdoor living areas should not exceed 55dB L Aeq,16hr and this is expected to be the new guidance in the near future and before the houses would be completed In 1999 WHO conclude that day time noise levels in outdoor living spaces should not exceed 55dB L Aeq,16hr to protect the majority of the population from being seriously annoyed and outdoor noise at night should not exceed 45 db L Aeq,8hr and 60dB L Amax for individual night-time events to offer protection from sleep disturbance The noise levels on the site (2014 contours) are in excess of 57dB L Aeq,16hr and approaching 65dB L Aeq,16hr in some places. Therefore even the quiet contemplative common areas are above the guidelines for outdoor areas The location of the dwellings are in noise environments above 60dB L Aeq,16hr which is a noticeable increase in level The night-time noise levels on the site are 20dB or more above the WHO recommendation Although it could be argued that the internal noise levels at night would be met with the proposed mitigation, it does rely on ALL windows being CLOSED. We would suggest that this is not commensurate with rural living and also not desirable no matter the location The report also monetises the health implications by noise level. With the limited data at our disposal, we can extrapolate that the cost to the NHS per person per annum associated with sleep disturbance ONLY will be between and Since we do not have any raw noise data and no L den data, we cannot review the associated costs of hypertension stroke, dementia, Heart attack or annoyance. However, the national cost of aircraft noise related annoyance is 198 million, for heart attack it 7.3 million, for hypertension stroke it s 23.9 million and for hypertension dementia it is 36 million. Helene Evans_ _Appeal PoE Page 23 of 24

24 All these numbers are very big and even a small proportion would be a significant cost impact on the local health budget. 12. Summary This site is wholly unsuitable for a housing development due to the high levels of aircraft noise incident on the site both during the day and at night-time Noise levels are significantly above the upper limit recommended by the World Health Organisation (WHO) and in government guidelines Although the appellant has put forward the concept of acoustic canopies to provide noise havens for outside living areas, these will not work. There are no mitigation measures available to provide suitable outdoor living areas anywhere on the site Heavy acoustic constructions are required to provide a quiet internal noise environment, it also requires that all windows remain closed at all times and the houses must be provided with full mechanical cooling and ventilation. This is not appropriate for the rural setting of Mobberley The noise levels on the site are expected to increase due to the latent operational capacity of 50% at the airport and further expansion plans which have been announced The cumulative health hazards identified by WHO associated with the noise levels on the site are compelling reasons to refuse development for housing in this location. The Council has a legal duty of care to all its residents as it is now wholly responsible for all aspects of public health in Cheshire East A full Environmental Impact Assessment on noise and a full public health assessment should have been undertaken before any development is given permission on this site. Noise mitigation measures would provide suitable working environments as already existing and therefore commercial uses would be appropriate for the site. Helene Evans_ _Appeal PoE Page 24 of 24