The neglected pollutants: the effects of artificial light and noise on human health Contents

Chapter 3: Public policy implications


National noise policy

55.The Noise Policy Statement for England (NPSE) published in March 2010 sets out the Government’s long-term vision for noise policy. The NPSE states that the Government wishes to “promote good health and a good quality of life through the effective management of noise within the context of Government policy on sustainable development.”87 This is supported by three aims: to avoid significant adverse impacts on health and quality of life; to mitigate and minimise adverse impacts on health and quality of life; and where possible, contribute to the improvement of health and quality of life.

56.The Institute of Acoustics said that the NPSE did not need replacing; the focus should rather be on implementing it on the basis of the latest evidence.88 Witnesses agreed that it provided a reasonable framework but there is a lack of implementation detail and the policy had not been emphasised enough. Paul McCullough, a member of the Chartered Institute of Environmental Health, said: “there could be a more strategic approach … that would help to direct resources and competence in the field, which is required, particularly from a local government perspective.”89 The Institute of Acoustics set out its vision for a more strategic approach. 90

57.Stephen Turner, who was involved in drafting the NPSE, told us: “there has been an inconsistency between local policy and national policy.” He added: “we need to re-emphasise to people that this is the policy and it should be used to direct our noise management.”91

58.Several witnesses noted that although noise pollution is mentioned in the 25 Year Environment Plan, the five-year update does not refer to noise pollution.92 Stephen Turner said: “It is not one of the key areas of activity for the Office for Environmental Protection. If you go to its website to see what you can complain about, noise is not listed; nor is it mentioned in this year’s environmental improvement plan.”93

59.It was suggested that if DEFRA wanted to reduce noise pollution effectively there should be a target or targets against which progress can be measured. Mr Turner gave an example: “reducing over a period of time the proportion of the population exposed to a certain level of noise … Or [reducing] the number of disability-adjusted life years that noise impact causes”.94 UKHSA’s Dr Luke Price emphasised the value of a target of the second kind: “it is about not just reducing the decibels—the noise exposure—but ultimately improving health outcomes”.95

60.The Noise Policy Statement for England sets a good overall framework for noise policy but should be re-emphasised. DEFRA does not collect the data that demonstrate national policy interfaces with local policy appropriately. The Government should collect data to determine whether planning authorities and other relevant parties are making use of the Noise Policy Statement for England.

61.There should be a specific noise reduction target for the regulation of noise pollution. Strict decibel exposure limits are impractical, but a target based on reducing the calculated exposure to, and hence disease burden from, noise pollution would allow cost-effective interventions to be pursued. This target should be in place for the next five-year Environmental Improvement Plan cycle.

Box 1: Mapping and burden-of-disease calculations for noise pollution

DEFRA’s noise model

DEFRA is investing in a new £6 million noise mapping system. It will model time-averaged metrics of noise.96 There are internationally agreed-on standards for modelling the contribution of different sources, including road, rail and aircraft, to these metrics. This new model goes beyond earlier models of large urban areas and major transport sources and will cover road and rail for the whole country.

Model components

The model consists of three components: input data, propagation model and receptor model.

Input data for roads and rail takes into account the topography of the road or railway, average vehicle speeds, their types, etc., to assign each section of road or rail a noise emission level.

The propagation model then accounts for the terrain and meteorology between source and receiver and calculates how the noise will be attenuated on its journey to the receiver.

The receiver model calculates the acoustic energy at the exterior of every residential dwelling, which in turn allows the population exposure to noise above a threshold and the burden of disease to be calculated for road and rail.

Use of the model

DEFRA says that its data will be made available to other public bodies by the end of 2023, and that local authorities will be able to view the output from the model and take it into account in planning decisions. For local authorities that have acoustic modelling resources, DEFRA says the model can be used for scenario evaluation. The model is also being shared with the devolved administrations.

The calculation methods used in the model have been developed by a process that involves verification of the model results against measurement campaigns, which increases confidence in the model results. DEFRA says that “there is no verification to date of the specific implementation of the model as developed by DEFRA … however, cost-effective options for this are currently being explored.”

Source: adapted from DEFRA’s supplementary written evidence (ALN0094).

62.One of the main policy responses to noise pollution has been to map and quantify the problem. Dr Benjamin Fenech from UKHSA explained that the number of people exposed to transport noise is known “thanks to the mapping commissioned by DEFRA and by airports”. There was also “evidence of the exposure-response relationships—which link the exposure to the health outcomes”,97 allowing the burden of disease to be calculated. Dr Fenech noted that “the WHO guidelines were informed by more recent evidence” and the DEFRA-led Interdepartmental Group on Cost and Benefits (noise subgroup) had “commissioned a number of reviews” to assess this new evidence.98

63.Dr Fenech noted that the Environmental Noise Directive (2006) resulted in “strategic noise mapping across entire countries”, providing the data “which allow these epidemiological studies to take place.”99 DEFRA’s Dr Bill Parish described its new mapping effort as “a game-changer” which goes “much further than the requirements of the current directive”100 and which will guide “our policy interventions—where we should be targeting them and how.”101 Ms Pow described it as “the first of its kind in the world.”102 However, it currently maps only average metrics for noise exposure (see Box 1).

64.As noted in Chapter 2, the WHO concluded in its 2018 Guidelines on environmental noise that the health effects of noise are likely to be greater than previously thought. Professor Anna Hansell noted that as the UK’s mapping takes account of noise on minor as well as major roads, “if you take full account of all the traffic exposures, … that gives you higher estimates of burden of disease.”103 However, the Government can be slow to update policy on the basis of new evidence for burden of disease calculations, with Professor Charlotte Clark describing it as “really out-of-date”.104

65.The Committee welcomes DEFRA’s noise pollution mapping and modelling exercise, which provides an opportunity for a renewed focus on noise pollution. However, mapping is only the first step: interventions to reduce the noise burden must follow. The Government should use its mapping to identify key cost-effective interventions. The noise mapping and modelling should be made public. The Government should use this to update the burden of disease calculations used for noise pollution, including any new scientific evidence. Policy on noise pollution should be updated accordingly. This should include funding to carry out public health interventions that reduce noise burden in line with its noise reduction target.

66.It is essential that the Government commit to extending the mapping beyond 24-hour averaged noise exposure to include metrics of pitch, peak volume and intermittency of exposure.

Interventions to reduce noise pollution

67.Stephen Turner noted that “understanding of how to mitigate noise is quite mature”.105 Richard Greer, Fellow and Director at Arup, distinguished between addressing sound at source, intervening between source and receiver, and noise insulation at the receiver. The first includes changing tyres and road surfaces, the second sound barriers. “Noise barriers are very effective for railways, because we can put them very close to the trains. A noise barrier can straightforwardly halve the wayside noise level, a 10-decibel or greater reduction. That is a better reduction that can usually be achieved by measures at source.”106

68.However, this is not the case for roads: “Because the noise source is so wide, with six lanes of highway, noise barriers might make a noticeable reduction at 3 decibels or more, but scarcely ever would we get to a halving. For highways, it is control at source, particularly through very low noise surfacing”.107 (The Department for Transport’s Phil Earl noted that “there are trade-offs here between the noise emitted by a tyre and the safety of the tyre in keeping your vehicle gripping the road.”108) In contrast:

“insulation … should always be the last place we go. We should only protect people in the home if we have exhausted everything that we can do at source and between source and receiver. None the less, noise is an unavoidable consequence of a growing, thriving and vibrant economy, so there will necessarily be times when we need to resort to noise insulation in homes to protect people.”109

69.This was supported by DEFRA, which explained: “to obtain a reduction in sound … of only 3 dB requires half of the energy in the source to be removed … This contextualises how difficult it can be to engineer sound reduction solutions and therefore early consideration in the design phase of a project is generally more cost-effective than seeking solutions once operational.”110

70.John Stewart, Chair of the UK Noise Association, told us that “the two areas that most affect people are traffic noise and neighbour and neighbourhood noise.” He highlighted lower speed limits and low noise road surfaces as interventions that could be deployed “starting where the roads are noisiest.” For neighbour noise, enforcement is the key: “the laws tend to be there … but they are not being enforced properly, partly because of a lack of resources among local authorities.”111

71.Interventions at source are not always possible. Mr Stewart highlighted freight trains, where the problem includes vibration as well as noise. But for passenger trains “there are technical ways of improving the rails and the trains’ wheels, which can reduce the noise quite considerably.”112

72.In assessing different interventions to reduce noise pollution, cost-effectiveness and practicability are two considerations. Richard Greer made the case that “there is an important distinction to be made between new projects … and our existing network. For new projects … the UK is on a par and in many respects leads the way.” However, retrofitting the existing network is less common. As Mr Greer told us: “building a noise barrier next to a new road or railway is one thing, but retrofitting it can be much more expensive and there can be engineering practicability issues.”113

73.The hierarchy of interventions for noise pollution should be: reduce, restrict, remodel. It is generally more effective to reduce noise at source, through planning and engineering, than it is to restrict transmission using sound barriers or to remodel the receiver’s environment with sound insulation. Mapping and modelling tools should be used to identify the most cost-effective interventions to reduce the disease burden of noise pollution, including determining where retrofits make sense. Information on how to reduce noise pollution must be made available at the planning stage for infrastructure projects, as intervention at source is generally more effective.


A national statement of light pollution policy

74.In contrast to noise pollution, there is no national Government strategy for tackling light pollution. Witnesses said little attention was paid to the topic. Stuart Morton, Professional Head of Highways and Aviation Electrical Design at Jacobs, told us “it would absolutely be beneficial to have a national strategy.”114

75.In 2009 the Royal Commission on Environmental Pollution published Artificial Light in the Environment.115 This considered the loss of viewing of the stars, the effects of poorly designed lighting and the effects of artificial light on nature. The All-Party Parliamentary Group for Dark Skies in 2021 set out ten policies for the Government to reduce light pollution.116

76.DEFRA responded to the royal commission in 2010,117 and again in 2014 with a Policy Update.118 This set out the steps that DEFRA had taken to address light pollution since the report, including a consultation on statutory nuisance exemptions, providing information—drawn up in collaboration with CPRE, the Campaign for Dark Skies and the Institute of Lighting Professionals (ILP)—on minimising light pollution and research projects on a range of light-related topics. However, Ruskin Hartley, CEO of the International Dark-Sky Association, said that “almost every recommendation … is still valid and should still be done but has not been”.119

77.WSP, an international consulting firm, said that “there have not been any definitive updates to Government policy in the intervening years [since the RCEP report] other than tweaks to relevant paragraphs of the [National Planning Policy Framework (NPPF)], of which there are few in relation to light pollution.”120 The relevant section of the NPPF says that “Planning policies and decisions should [take] into account the likely effects … of pollution on health.” It explicitly refers to both noise and light pollution, saying that policies and decisions “[should] limit the impact of light pollution from artificial light on local amenity, intrinsically dark landscapes and nature conservation.”121

78.The ILP noted that the NPPF replaced Planning Policy Statement 23: Planning and Pollution Control (PPS 23) and removed lighting requirements. Allan Howard, past-President of the ILP, told us that “it was agreed that PPS 23 would be expanded specifically to include a detailed lighting section, … but then the Government changed the planning rules and wanted to reduce a lot of red tape.”122

79.Emma Marrington noted the absence of light pollution in the Environmental Improvement Plan 2023, in contrast to its mention in the 25 Year Environment Plan, alongside noise pollution. She acknowledged the existence of a national planning policy on light pollution as set out in the NPPF, but then added “there is a variable approach to it in local authorities.”123

80.The Minister acknowledged that although DEFRA’s response to the 2009 royal commission report “concluded that there was not enough evidence to do anything to change the way we regulate”, this “was quite some time ago now and evidence is building and changing all the time.”124 Rebecca Pow accepted that a national policy statement on light “is certainly something that could potentially be considered.”125

81.The Government should issue a Light Policy Statement for England which details the Government’s policy on minimising light pollution and the roles it expects different departments to play.

Promoting good lighting practice

82.A significant proportion of light pollution is unnecessary and caused by bad design or poor use of LEDs.126 The ILP told us that options existed that could help address this. For example, Andrew Bissell highlighted the adaptive tunability of LEDs: one example he discussed “has a whiter colour temperature early on in the evening but … shifts towards a much warmer, calmer colour temperature and decreases in intensity as the evening passes, so you have a lower level of light.”127 Ruskin Hartley described

“simple things [that] can be done to tackle light pollution … ensuring that all new [outdoor] lights are fully shielded and point down at the ground where they are needed, and ensuring that all new lights are put on control systems so that they can be dimmed down when there are fewer people and turned off when people are no longer around.”128

83.Organisations such as the Institution of Lighting Professionals have developed guidance on lighting installations that can minimise unwanted light pollution. Mr Howard had “developed a guidance document for the ILP, Domestic Exterior Lighting: Getting it Right”. However, this guidance has not always been followed by industry. Mr Howard said: “you cannot go to any of the major retail outlets and buy a luminaire, a security light with a sensor, that would do what we want it to do.”129

84.Good practice guidance for lighting already exists. The Light Policy Statement and planning guidance should incorporate up-to-date guidance from the Society of Light and Lighting, the Institution of Lighting Professionals and the Chartered Institute of Building Services Engineers, on best practice for lighting.

Light pollution as a statutory nuisance

85.Artificial light can be classed as a statutory nuisance under the Environmental Protection Act 1990 if it “substantially interferes” with the use of a home or other premises or could injure health. Councils must look into complaints of this kind and can then serve an abatement notice if they agree that a statutory nuisance is occurring.130 A number of witnesses expressed dissatisfaction with the statutory nuisance regime, which allows for certain exemptions, including “railways and airports and transport infrastructure”.131 Allan Howard said: “We want those exclusions removed, and we would like it to cover any artificial light, not just from one premise affecting another premise.”132

86.Asked about the nuisance regime, Ms Pow told us: “While DEFRA owns the policy on statutory nuisance legislation, it is still for the local authority to operate it”. In contrast to noise as a nuisance, “we do not have 150 years of case law on light because we brought light into consideration only in 2005.”133 It is not clear whether Government tracks complaints under this regime: we were told that the analysis of complaints is “taking place at a local level.”134

87.The Government should make clear that exempt facilities are still expected to conform to best-practice lighting guidelines.

88.Local authorities should report on complaints about light pollution to Department for Levelling Up, Housing and Communities so that central government can compare local authorities and highlight any issues.

Issues affecting noise and light

Implications of net-zero policy

89.The move to net zero requires widespread infrastructure changes, for example the possible widespread use of heat pumps and electric cars, which may have implications for light and noise pollution. For example, Ms Pow acknowledged that for “heat pumps, noise is now one of the issues that [we have] to deal with.”135 Dr Antonio Torija Martínez described the “transition towards electric mobility” as “the most radical change in the soundscape we have experienced”, due to the lack of engine noise from electric cars.136

90.Dr Edward Wynne-Evans pointed out that adapting to climate change can entail trade-offs between different risks: “if you open a window to improve your ventilation, for example, you potentially make your risk of noise exposure greater.”137 Dr Torija Martínez highlighted the importance of researching the noise impacts of the net-zero transition, so that noise does not become a “showstopper … a barrier to the wider adoption of air source heat pumps, electric mobility, drones etc.”138

91.The Government should take steps to ensure that the implications of the technological shifts required for net zero and adapting to climate change for noise and light pollution are understood and addressed early on.

Cross-departmental co-ordination

92.Witnesses told us that responsibility for both noise and light pollution policy is spread across Government and the lines of accountability are not always clear. Professor Anna Hansell said: “There is no clear government department to involve, so DEFRA, DfT, BEIS and [DHSC] might be involved”.139 The Department for Levelling Up, Housing and Communities is also involved in enacting national policies at the local level. Emma Marrington said that this means light pollution can”[fall] through the cracks.”140

93.Aspects of existing DEFRA policy and existing legislation provide regulatory frameworks that can be applied across departments to regulate light and noise pollution. For example, the five environmental principles of integration, prevention, rectification at source, “polluter pays”, and the precautionary principle, set out in the Government’s Environmental Principles Policy Statement,141 are intended to apply to policymaking across government. These have already been legislated for in the Environment Act 2021.142

94.Rebecca Pow told us that “while DEFRA is responsible for protecting the environment and this area, an awful lot of the levers are in other departments. A lot of them are conducting their own research. We highlight the issues to them”.143 She added: “DEFRA works incredibly closely with at least 10 different departments and agencies … DEFRA could not possibly hold all the experts on all those areas just to do with light and noise, because we cover all pollutants.”144

95.Light and noise pollution cut across a number of departments. The levers for acting on problems identified by DEFRA often sit in other departments, such as the Department for Transport. This is unlike other pollutants, where DEFRA takes ownership of mapping and, through public bodies, regulation. There seemed to be little co-ordination between departmental policies in these areas. The status of light and noise pollution as policy areas under the aegis of DEFRA should be reviewed and interdepartmental co-ordination on these issues strengthened. The Government should make clear where in each affected department responsibility for noise and light pollution lies. Other departments should apply the environmental principles in the Environment Act 2021 to their approach to light and noise pollution.

Co-ordination with local authorities

96.Witnesses told us that there is a gap between policy as set by the Government and how that policy is applied by local authorities. Emma Marrington said that, even where guidance or advice exists, “it is about having awareness among our local authorities … [and] there are different approaches in councils.”145 Andrew Bissell said that every local authority “does the minimum of asking for a light pollution assessment or statement, but some take it far more seriously than others.”146

97.DEFRA’s Dr Parish accepted this:

“We do not audit what [local authorities] do … nor have we imposed a burden on them to provide reports on how they are managing nuisance. In all honesty, we do not have an accurate handle on what every single local authority is doing … if we were to … ask for something … we would inadvertently be providing them with an extra burden on top of the environmental health officer trying to sort out a nuisance problem.”147

98.These problems with inconsistent application are compounded by shortages in resources. Guy Harding, Technical Manager at the Institution of Lighting Professionals, said that “there is not always the expertise in the local authority … they do not necessarily have the funds to go to an external consultant.”148

99.Pressed on whether local authorities had the resources to tackle the problems of noise and light pollution and enforce the existing regulations, Ms Pow responded that “that does not fall under DEFRA, because local authority funding is ring-fenced and that is a matter for DLUHC and the Treasury. It is not for DEFRA to answer that question.”149

100.It is unclear how, and how consistently, national policies are implemented at local authority level. The Committee remains unconvinced that co-ordination on these issues is sufficiently effective. DEFRA does not appear to be receiving the information it needs to conclude whether its policies are being effectively implemented by local authorities and trends in that effectiveness over time. It is also unclear whether local government actions on noise and light pollution feed back data into DEFRA about whether the policies are successful. The Department for Levelling Up, Housing and Communities should set out what resources local authorities should have to respond adequately to light and noise pollution policies. Local authorities should be sufficiently resourced and incentivised, both in funding and access to information and expertise, to ensure they can properly regulate light and noise pollution.

87 Department for Environment, Food and Rural Affairs, Noise Policy Statement for England (NPSE) (March 2010) p 3: [accessed 23 June 2023]

88 Written evidence from the Institute of Acoustics (ALN0064)

89 Q 56 (Paul McCullough)

90 Written evidence from the Institute of Acoustics (ALN0064)

91 Q 58 (Stephen Turner)

92 The 25 Year Environment Plan says “We must ensure that noise and light pollution are managed effectively.” HM Government, A Green Future: Our 25 Year Plan to Improve the Environment (2018) p 83: There is no explicit target. Neither noise or light pollution are mentioned in the Environmental Improvement Plan, which is intended as the five-year update. HM Government, Environmental Improvement Plan 2023 (2023): [accessed 23 June 2023]

93 Q 66 (Stephen Turner)

94 Q 60 (Stephen Turner)

95 Q 127 (Dr Luke Price)

96 The main metric that it will use is LAeq. L denotes loudness, A denotes “A-weighting”, which in the acoustic field means that the sound has been weighted-averaged over the frequencies of human auditory response, and “eq” denotes a time average. It generates results to noise levels of LAden 40 dB (day-evening-night-time averaging) and 35 dB LAnight at the exterior of dwellings. The model output includes LA averages across 16-hour, 24-hour, day-, evening- and night-time periods, but does not include measures of intermittency or pitch.

97 Q 117 (Dr Benjamin Fenech)

98 Q 119 (Dr Benjamin Fenech)

99 Ibid.

100 QQ 140, 129 (Dr Bill Parish)

101 Q 140 (Dr Bill Parish)

102 Q 143 (Rebecca Pow MP)

103 Q 9 (Professor Anna Hansell)

104 Q 9 (Professor Charlotte Clark)

105 Q 63 (Stephen Turner)

106 Q 81 (Richard Greer)

107 Ibid.

108 Q 134 (Phil Earl)

109 Q 83 (Richard Greer)

110 Supplementary written evidence from Department for Environment, Food and Rural Affairs (ALN0094)

111 Q 109 (John Stewart)

112 Ibid.

113 Q 81 (Richard Greer)

114 Q 74 (Stuart Morton)

115 The Royal Commission on Environmental Pollution, Artificial Light in the Environment (27 November 2009): [accessed 23 June 2023] The report made a number of recommendations, including that: the highways authorities and local authorities reassess the lighting of roads against road safety and crime reduction benefits; the sale of all new external and floodlighting be accompanied by best practice guidance on avoiding light pollution and minimising nuisance; there should be explicit consideration of light in planning policy; and that DEFRA—and equivalent bodies elsewhere in the UK—take the lead in co-ordinating inter-departmental activity on artificial light.

116 All-Party Parliamentary Group for Dark Skies, Ten Dark Sky policies for the government (2021): [accessed 23 June 2023]

117 Department for Environment, Food and Rural Affairs, The Royal Commission on Environmental Pollution (RCEP) Report on Artificial Light in the Environment: Government response (18 March 2010): [accessed 23 June 2023]

118 Department for Environment, Food and Rural Affairs, Artificial Light in the Environment: Policy Update (December 2013): [accessed 23 June 2023]

119 Q 97 (Ruskin Hartley)

120 Written evidence from WSP (ALN0076)

121 Ministry of Housing, Communities and Local Government, National Planning Policy Framework (July 2021) paragraph 185: [accessed 23 June 2023]

122 70 (Allan Howard)

123 Q 97 (Emma Marrington)

124 145 (Rebecca Pow MP)

125 Q 148 (Rebecca Pow MP)

126 Q 68 (Allan Howard)

127 Q 73 (Andrew Bissell)

128 Q 96 (Ruskin Hartley)

129 Q 71 (Allan Howard)

130 Department for Environment, Food and Rural Affairs, ‘Artificial light nuisances: how councils deal with complaints’ (7 April 2015): [accessed 23 June 2023]

131 Q 89 (Arfon Davies) and Q 97 (Emma Marrington)

132 Q 74 (Allan Howard)

133 Q 149 (Rebecca Pow MP)

134 Q 145 (Rebecca Pow MP)

135 Q 151 (Rebecca Pow MP)

136 Q 6 (Dr Antonio Torija Martínez)

137 Q 120 (Dr Edward Wynne-Evans)

138 15 (Dr Antonio Torija Martínez)

139 Q 9 (Professor Anna Hansell)

140 Q 102 (Emma Marrington)

141 Department for Environment, Food and Rural Affairs, ‘Environmental principles policy statement’ (31 January 2023): [accessed 11 July 2023]

142 Environment Act 2021, section 17

143 Q 144 (Rebecca Pow MP)

144 Q 148 (Rebecca Pow MP)

145 Q 98 (Emma Marrington)

146 Q 68 (Andrew Bissell)

147 Q 149 (Dr Bill Parish)

148 Q 74 (Guy Harding)

149 Q 149 (Rebecca Pow MP)

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