See the tube noise action group's response below:
The Tube Noise Action Group welcomes the opportunity to comment on the draft Mayor’s Transport Strategy for London. We welcome the Mayor’s emphasis on improving public transport and the benefits to residents’ health that this initiative promises.
The Tube Noise Action Group (see www.tubenoiseactiongroup.com ) is an informal mutually supporting group of Londoners who are adversely affected by the growing levels of noise and vibration pollution arising from London Underground’s (LUL) operations. Groups are located across London – in the central areas of the City, Westminster and Kensington/Chelsea but also in Camden, Haringey, Lambeth and Redbridge. We have no doubt that residents in other London Boroughs are similarly affected. We recognise and support the Mayor’s commitment to reducing air pollution and the need to reduce vehicle movements and increase the use of electric traction – including use of the underground.
However, the Tube Noise Action Group advocates raising the priority, in the Mayor’s Transport Strategy, of reducing another significant source of pollution and nuisance with proven adverse consequences on health and well-being: noise pollution. We, like other Londoners, have been increasingly concerned by the growing noise and vibration transmitted to homes by London Underground’s trains. These concerns are likely to grow as London Underground increases the frequency of its train running (eg through the upgrading of the sub-surface lines in its 4LM plan) and the duration of train operations (Night Tube).
Clearly, it’s in the interests of all Londoners that London Underground is able to extend the duration and increase the intensity of its train operations and this promises to make a significant contribution to reducing air pollution. However, this must not take place at the expense of residents who are already suffering significant noise and vibration pollution from the current tempo of operations which already exceed the World Health Organisation’s (WHO) norms. Our experience, based on what we suffer daily in our homes and have learned through numerous unproductive meetings with LUL, is that TfL has done too little to discharge its mandate to reduce noise pollution. Regrettably, we have formed the conclusion that it has no intention of implementing policies commensurate with the miserable experience it is daily, and nightly, inflicting on many London residents.
The Mayor’s established policy on noise remains that set out in the GLA’s 2004 “Sounder City. The Mayor’s Ambient Noise Strategy”. This states that: (policy 25 page 109) “The Mayor will expect Transport for London to develop cost-effective plans…. To minimise noise and vibration through improvements in the design, operation, monitoring and maintenance of transport infrastructure”; (policy 26 page 109); “taking account of resident and other complaints in assessing the need for remedial treatment”; (4B.23); “one of the legacies of historic under-resourcing is poor track quality in many parts of the Underground”; (4B.25); “infrastructure needs to be brought up to best modern practice” (4B.4)
Noise nuisance has increased significantly in many locations. In many cases it is not clear why this has taken place – and LUL has offered no explanation. On the sub-surface lines we believe that the new trains run faster and, as ridership increases, the trains are more heavily loaded thus increasing noise and vibration. But it is not clear why noise levels have risen on deep level lines. London Underground’s (LUL) own measurements in residents’ homes across London have shown noise levels of 50db+ inside homes. This level is for a single train and underestimates the noise pollution actually experienced inside homes since LUL (for good operational reasons since it seeks to identify particularly noisy individual trains) discounts measured levels generated when two trains pass simultaneously. Noise levels thus comfortably exceed 50db in some homes.
World Health Organisation (WHO) night noise guidelines state that “adverse health effects are observed at noise levels between 40 and 55db”. The WHO regards night as “the time most people are in bed” – clearly this includes the times – say later than 2300 and later than 0530 when normal LUL train operations are continuing on nights and lines when/where night tube services are not operating. The WHO Levels when two trains pass probably exceed 55db when the WHO states “Adverse health effects occur frequently. A sizeable proportion of the population is highly annoyed and sleep disturbed”. The relevant British Standard, BS ISO 14837-1:2005 notes (para 5.3. note 1) that “people lying on beds may also perceive ground-borne noise/vibration at much lower levels” and that (para 6.3 note 3) “Ground-borne noise levels predicted or measured near the walls of a room may be 2dB or 3dB greater than those near the centre”.
Accordingly, the Tube Noise Action Group whilst welcoming the emphasis in the draft transport strategy on increasing provision of public transport and increasing investment in public transport infrastructure and operations, asks that specific provisions are made in the strategy to require London Underground to adopt best modern practice in upgrading its tracks (eg continuously welded rail; resilient noise and vibration reducing fixings such as Pandrol Vanguard clips; sleeper pads etc) and to prioritise track upgrading in areas where there is a long standing history of nuisance caused by pollution from LUL’s operations. The London Assembly Environment Committee referred to an “epidemic” of noise pollution arising from LUL’s operations and Tube Noise Action Group believes that the Mayor’s Transport Strategy should prioritise reducing the “epidemic” of noise pollution and nuisance arising from LUL’s operations.
We are happy to provide any further information that may be of use to the Mayor on request.