How to implement Noise Control BAT (Best Available Techniques) when obtaining an Environmental Permit

01 November 2015 by Andrew Corkill, Director

Within England and Wales, the Environment Agency (EA) and Natural Resources Wales (NRW) both adopt the same guidance on noise(1). Scotland’s SEPA has separate guidance. We will look at the situation within England and Wales.

The Horizontal Guidance requires installation to:

a) Avoid significant impact (effect) from the operation of plant, and
b) Utilise Best Available Techniques (BAT) for noise control to minimise any adverse noise effect.

There is a range of separate guidance on what constitutes a significant noise effect, however there is nothing from the Environment Agency currently what constitutes Best Available Techniques (BAT) for noise mitigation. There is however an EA Technical Report(2) which specifically deals with BAT for the control of noise and vibration. However it is written in 2005 which makes it a little old and in its introduction it states its purpose is to inform the preparation of guidance, and therefore it should not be used specifically as guidance in itself.

The 2005 EA Technical report covers the following areas:

- Principles of noise attenuation;
- Noise control equipment;
- Noise management practices;
- Planning noise control; and
- Costs, benefits and implications of noise control.

The first four aspects relevant to BAT are procedural matters, and any complex new project for which a professional and competent approach is being taken to its noise design, will adopt these types of procedures as a routine part of the design process. Sharing technical information with the EA to demonstrate that these procedures have been carried out should provide useful supporting evidence to show that Best Available Techniques are being used for noise mitigation.

The final aspect of Noise Best Available Techniques implementation is a cost-benefit analysis. The EA Technical Report advises that it would be normal for such an analysis to look at just one (the most likely or reasonable) mitigation treatment per noise source, and to potentially provide some costing information on these options. However, providing accurate costings on options can in itself be a costly exercise. Adequate information on costs can however often be implied in a qualitative rather than a quantitative cost analysis, and this is often more appropriate and easier to review.

EDF Energy’s West Burton 1350MW CCGT Power Station. Spectrum were EDF’s Energy’s Noise Consultant throughout the project and prepared a Noise Control Best Available Techniques report for submission to the EA

Finally, the example within Scotland is useful; there is more recent guidance on BAT justification. In their summary guidance(3) this states:

Noise Best Available Techniques (BAT) justification guidance in Scotland from SEPA

Place the noise impact into context and provide a demonstration that emissions have been prevented or reduced as far as reasonably practicable:

1. Concentrate on the dominant noise sources;
2. Detail all existing noise attenuation measures (enclosures, silencers, location of kit, operating time restrictions, maintenance regimes, etc.);
3. For dominant noise sources, consider all noise reduction techniques and come to a reasoned determination of what is achievable;
4. Where upgrades are identified – state the predicted impact of the works and commit to firm completion timescales; and
5. Develop a noise management plan.

The guidance within Scotland is helpful in understanding what information should be submitted to the EA in England or NRW in Wales. The key noise design strategy relating to the points listed, for new installations, is to try to avoid any single noise source from being dominant on the site, and where a dominant source is unavoidable then explain what noise mitigation measures were considered and why they cannot be adopted.

Further information on Best Available Techiques

References
(1) Horizontal Guidance for Noise Part 2 – Noise Assessment and Control, Environment Agency, 2004
(2) Best Available Techniques for Control of Noise and Vibration, EA, 23.6.2005
(3) Noise – Summary Guidance for PPC Applicants, SEPA, 2015