Proposed amendment to the Environmental Noise (Scotland) Regulations 2006: consultation analysis

1. Summary of responses to the consultation

The consultation contained 12 questions that sought stakeholders views on extending to a ten yearly basis the production of noise maps and associated action plans, and to increase from one to two years the time between the publication of the maps and the action plans.

We received 16 consultation responses from the following groups:

The consultation and full responses are published on the Scottish Government website: Published responses for the Proposed amendment to the Environmental Noise (Scotland) Regulations 2006 - Citizen Space

Question 1 Do you agree with the proposal for the Scottish Government to produce maps identifying noise sources and quiet areas, on a ten-yearly basis?

We received 16 responses to this question. Looking at responses by sector, local authority and airport / airport groups responding supported the proposal, whilst all noise consultants responding did not agree with the proposal, and a mixed response from individuals to this question.

Question 2 Do you agree with the proposal for the Scottish Government to produce strategic noise maps and noise action plans (for noise sources other than airports) every ten years?

We received 15 responses to this question. Question 3 gave respondents an opportunity to provide reasons for their answer.

Question 3 What are your views on the proposal for the Scottish Government to produce maps identifying noise sources and quiet areas, strategic noise maps and noise action plans (for noise sources other than airports) every ten years?

We received 14 responses to this question.

The most common reason for not supporting the move to a ten-year cycle was changes due to new development and activities over this time period, and risks providing the public, local authorities and other stakeholders with obsolete datasets. In this group of respondents, it was suggested that the focus should be on improving the efficiency of the existing five-year process. Additionally, some respondents added that a ten-year cycle is too long a period for supporting strategic planning, land-use decisions, and the identification and management of noise impacts. It was highlighted by one respondent that moving to a ten-year cycle would break longstanding alignment with European best practice.

Respondents in support of the move to a ten-year cycle, recognised the current five-year cycle does not provide adequate time for the requisite information gathering and verification, review and development of action plans, and that the proposal provides a more realistic timescale. A respondent noted that whilst the ten-year cycle is reasonable, there must be a clear direction that planning decisions must primarily rely on measured on-site acoustic data, not decade old-modelled maps.

Wider comments identified specific activities that respondents felt should be considered as part of action planning, including areas where residents’ complaints about noise from motorways and industrial premises, addressing noise from light aircraft, and better capturing emerging public health risks related to noise.

Question 4 Do you agree with the proposal to remove regulation 7(3) that requires the Scottish Government every five years, and whenever a major development occurs affecting the existing noise situation, to review and if necessary, revise any strategic map showing agglomerations and major roads and railways?

We received 15 responses to this question, one respondent did not give a response. Question 5 gave respondents an opportunity to provide reasons for their answer.

Question 5 What are your views on the proposal to remove regulation 7(3) that requires the Scottish Government every five years, and whenever a major development occurs affecting the existing noise situation, to review and if necessary, revise any strategic map showing agglomerations and major roads and railways?

We received 12 responses to this question.

Respondents who emphasised the importance of retaining the current review and revision requirements noted that strategic noise maps play a vital role in identifying areas significantly affected by transport and other major noise sources. This, in turn, supports targeted mitigation and effective action planning. They also highlighted that reviewing and revising these maps following major developments is essential to ensure they remain accurate, up to date and relevant.

Respondents who supported removing the requirement to review noise maps whenever a major development occurs noted that the current approach can create unrealistic expectations that the maps should be updated after every infrastructure project. They also observed that undertaking a full review every five years, even when no substantial change has taken place, can be an inefficient use of time and public funds. Removing this requirement was considered more effective for long‑term planning, particularly in relation to noise management and public health.

A few respondents noted that the existing Regulations already provide flexibility within the five-year review cycle, as noise maps and action plans need only be revised when necessary. They noted that the Scottish Government can use its own judgement in determining whether revisions are required, based on changes in noise levels. From their perspective, a move to a ten-year cycle is not required, as the needed discretion already exists.

Question 6 Do you agree with the proposal for airport operators to be required to produce strategic noise maps and noise action plans (for airports) every ten years?

We received 16 responses to this question. Question 7 gave respondents an opportunity to provide reasons for their answer.

Question 7 What are your views on the proposal for airport operators to be required to produce strategic noise maps and noise action plans (for airports) every ten years?

We received 16 responses to this question.

Respondents who considered the proposal for a ten-year cycle inadequate for effective airport noise management highlighted concerns about potential changes in modelling standards and methodologies, aircraft types, and flight frequencies. Population distribution and land-use patterns around airports can also shift over time. Together, these factors can materially alter both the scale and distribution of noise impacts. Some respondents also supported including all airports, and light aircraft, in the mapping and action planning process.

Respondents who agreed with a ten-year cycle noted that airports generally experience gradual, rather than rapid, change. One airport operator added “the Airport would however, where changes to our flight paths have been made under the airspace change process and implemented under CAP1616, voluntarily update our Strategic mapping and associated Noise Action Plan.”

Question 8 Do you agree with the proposal to remove regulations 10(3) and 11(4) that require airport operators every five years, and whenever a major development occurs affecting the existing noise situation, to review and if necessary, revise any strategic map showing the airport?

We received 15 responses to this question, and one respondent did not give a response. Question 9 gave respondents an opportunity to provide reasons for their answer.

Question 9 What are your views on the proposal to remove regulations 10(3) and 11(4) that require airport operators every five years, and whenever a major development occurs affecting the existing noise situation, to review and if necessary revise any strategic map showing the airport?

We received 16 responses to this question.

Most respondents disagreed with the proposal, noting that any major development with the potential to significantly affect the noise environment should trigger a review and, if necessary, a revision of the strategic noise maps. One respondent commented that there are “insufficient controls in place,” and that extending the review interval would reduce the amount of data collected, weakening the evidence base needed to require operators to reduce noise. They felt that removing this provision — especially when combined with extending the cycle to ten years — would further delay updates to mapping where major changes occur, such as alterations to airspace use or the opening of a new runway.

The small number of respondents who supported the proposal, suggested that operators could voluntarily provide other relevant data where needed, for example following changes to flight paths made through the airspace change process and implemented under CAP1616. Some respondents also highlighted that a ten-year cycle is a more realistic timescale given the resources required to undertake the work.

Question 10 Do you agree with the proposal requiring the time between the publication of the maps and action plans to be increased from one to two years?

We received 15 responses to this question and one respondent did not give a response. Question 11 gave respondents an opportunity to provide reasons for their answer.

Question 11 What are your views on the proposal requiring the time between the publication of the maps and action plans to be increased from one to two years?

We received 13 responses to this question.

Most respondents were in favour of this proposal, stating that this is a sensible adjustment and aligns with the requirements of the EU Environmental Noise Directive. A few respondents commented on the efficiency of the process, specifically that if the current time to produce the noise maps can be reduced then this would be a reasonable proposal

A small number of respondents felt that no change was needed, particularly if moving to a ten-year cycle.

Question 12 Do you have any other comments on the proposal not covered in response to previous questions?

We received 12 responses to this question, covering public health concerns, planning considerations, resourcing issues, international alignment, the noise impacts of future economic development, and the need for specialist acoustic expertise.

A few respondents emphasised that environmental noise is a major public health issue and raised concerns that extending the noise mapping cycle from five to ten years could have adverse implications for public health. On local delivery, some respondents called for additional funding and staffing for local authorities to support the noise mapping cycle; one suggested undertaking a cost-benefit analysis of noise mapping.

Some respondents raised wider issues – including the noise impacts of future developments (e.g. freeports), light aircraft and the impact on rural communities, as well as routes for escalating noise complaints, and the adequacy of planning guidance.

One respondent also suggested monitoring and reporting progress, including comparing measured noise monitoring data with modelled outputs.

A few respondents commented the proposal could create misalignment with international best practice and the European Noise Directive, potentially reducing comparability with European datasets and leaving Scotland behind peers on environmental standards. One respondent noted that the Round 5 noise maps are likely to be only a slight revision of the Round 4 noise maps.