Noise limits in connection with the amendment to Czech Government Regulation No. 272/2011 Coll.

[Czech]

Executive Order 433/2022, adopted on December 7, 2022, allows for higher noise levels from infrastructure projects. These changes will come into effect on July 1, 2023. Whilst a glance at the sound level changes expressed in decibels or dB might appear trivial, it is essential to understand that dB is a logarithmic scale, not a linear one. 

So, while the initial perception may be that the increase in noise limits is relatively small, such as 5 dB, 8 dB, or a maximum of 13 dB, it is important to understand that the impact of this increase is not linear but exponential.

For instance, raising the noise limit by 5 dB from 55 dB to 60 dB does not correspond to a linear increase of approximately 10%. Instead, it results in a multiplication effect, approximately tripling the noise level.

Such a ploy ignores the resultant health and productivity costs to the economy; it defers them. It moves them off the balance sheet of the infrastructure project and into a later, but greater, socio-economic burden that is harder to assign or attribute.

In certain situations, this exponential increase can lead to an astonishing 20-fold expansion of the noise limits. It is difficult to comprehend that the politicians voting for this legislative change truly understood what they were voting for.

Now to the data. (You can convert dB to a linear x-fold scale simply as xLinear=10^(dB Δ/10). But it’s better to represent this linear scale in Pascals because they represent a measure of force per area on a person’s ear drum. We can convert dB to Pascals as xP = 10^(dB/20) * 0.00002)

Accordingly, we have taken the Government’s original dB levels, the new increased dB levels, and the World Health Organisation’s (WHO) recommended levels, converted them all to millipascals (mPa) and plotted the differences. The results are striking. It is a case of the devil really being hidden in the detail.

We used Koridor D8’s excellent infographic^[1]https://kd8.cz/nase-temata/hluk/ as our data source. They also explain the basic principles of sound very well. There is also a good analyis from the law firm CHS Legal^[2] … Continue reading.

In brief, the changes that will come into effect on 1/07/2023 are:

For transport infrastructure permitted until 31/12/2000:

• Tracks: The noise limit will increase from 60 dB/55 dB (outside the protection zone 55 dB/50 dB) until 30.6.2023 to 68 dB/63 dB from 1/7/2023 day/night.
• Highways, roads I. and II. classes, and local roads I. and II. classes: The noise limit will increase from 60 dB/50 dB until 30.6.2023 to 68 dB/58 dB from 1/7/2023 day/night.
• Road III. classes, local communication III. classes, and purposeful communication: The noise limit will increase from 55 dB/45 dB until 30.6.2023 to 68 dB/58 dB from 1/7/2023 day/night.

For transport infrastructure permitted after 1/1/2001:

• Tracks: The noise limit will change from 55 dB/50 dB outside the protection band to 60 dB/55 dB from 1/7/2023 day/night.
• Highways, roads I. and II. classes, and local roads I. and II. classes: The noise limit will remain the same at 60 dB/50 dB.
• Road III. classes, local communication III. classes, and purposeful communication: The noise limit will change from 55 dB/45 dB until 30.6.2023 to 60 dB/50 dB from 1/7/2023 day/night.

Here are the amendments graphed as sound pressure changes and percentages:

How much do the changes represent on a percentage basis?

Czech HSR.  (VRT)

How many people are affected? We can make a rough and simplistic estimate as follows.

As one moves further away from a road or rail track, the inverse square law causes a rapid decrease in sound intensity. This means that the swathe of people living next to the road or track will experience a  reduction in the acoustic energy reaching them. The sound waves spread out and become more diluted, resulting in a weaker perception of sound as distance increases.

If we know the distance at which sound is measured (often 25m), we can calculate the distance where a second, lower dB sound level will occur. This is useful to us in the current scenario because there are scientific measurements of noise for HSR pollution where both the level (dB) and the distance are given.

For example, the US Department of Transport’s ‘High Speed Rail: Cost of Compliance for Noise

Mitigation Procedures’ ^[3]https://railroads.dot.gov/sites/fra.dot.gov/files/2022-01/HSR%20Noise%20Mitigation%20Procedures.pdf Pg 29 & 30 give 85dB at 25m for HSR.

Now, if we use the following formula with this 85db at 25m source value: 

distanceLimit = measuredDistanceSrc *(10^( (measuredDBSrc – limitDB) / 20) ), we can see that the 55dB legal limit will be met 790m away from the measuring point, which is 25m from the source.

The Czech Republic has an average of 134 people/km^2^[4]https://worldpopulationreview.com/countries/czech-republic-population.

The VRT is 580km long. Therefore the ‘‘exclusion zone’ is 790m + 25m wide (x2) = 1.63km wide x track length = 945km2, so 126,684 people will be affected. 

Doing the same maths with the old 50dB night time limit gives us an affected population of 222,279

Therefore, increasing the VRT noise limit from 50 to 55db halves the liability.

Using the WHO’s 44dB night time limit gives us an affected population of 439,895!

Cost of noise pollution.

Increasing the permitted noise levels this much makes infrastructure projects much cheaper. But it adversely affects the health of the population, and, in economic terms, damages the economy in the longer term.

Whilst it’s challenging to obtain reliable econometric figures for this, the World Health Organisation, in their paper: “Environmental Noise Guidelines

for the European Region”^[5]https://www.who.int/europe/publications/i/item/9789289053563

strongly recommends reducing noise levels below

• Road: day 55 dB, night 45 dB (pg 30)
• Rail: day 54 dB, 44 dB (pg 49)

The Czech government’s new law means dramatically higher sound pressure levels than the WHO limits. 

The WHO reviewed scientific evidence from 2014-2018 on the health effects of noise. They found sufficient evidence to recommend reducing noise below specific levels for cardiovascular diseases, sleep disturbance, and annoyance. All recommendations in the table below, including to policymakers, were ‘strong’.

	Noise during day, evening and night (Lden)	Noise during the night (Lnight)
Road	53	45
Railway	54	44
Aircraft	45	40

The EU BCR noise abatement for railways is 7:1, see figure 5.28,  page 165 of the above document.

Furthermore, we would direct the reader to the 20/03/2023 ‘European Commission Report to the EU Parliament and Council on the Implementation of the Environmental Noise Directive in accordance with Article 11 of Directive 2002/49/EC’^[8]https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=COM:2023:139:FIN Section 4, Para 5, which says that their Directive aims to harmonize noise management in a cost-efficient manner, and it also states that implementing specific noise measures would yield a return of EUR 10 in societal benefits for every euro spent, thereby addressing health issues and providing long-term societal benefits caused by noise pollution.

The attitude of the Czech Ministry of Health demonstrates an apparent disregard for their citizen’s well-being. The Ministry’s arguments are clearly specious given that they are at odds with the WHO, the EU’s Phenomena report, above and the recent European Commission Report, also above.

A rebuttal of the Ministry’s position can be found here^[9] … Continue reading.

In so far as high-speed rail is concerned, noise is of particular concern because it is of a wide spectrum. It mainly comes from vortex shedding around the pantograph, ranging from 200Hz to 5kHz and increasing with the 4th power of train speed. For HSR, noise pollution countermeasures can add up to 30% of the track cost.

(For example, HS2 in the UK, which was about the same length, does have good noise pollution countermeasures. In 2010, the estimated cost was around £32 billion (963,65 miliardy Kč). By 2019 that figure had increased to £88 billion (2,654 bilionu Kč). The cost since then has stabilised because the eastern leg has been scrapped. We are awaiting the exact breakdown of these figures from HS2.)

We have a post about it here: https://vrt.wtf/en/2021/11/17/aerodynamic-noise-is-dominant-at-speeds-above-250-km-h/

Now this leads to an interesting conclusion about the real cost. If the current VRT feasibility studies^[10]https://vrt.wtf/en/2023/06/04/czech-hsr-feasibility-studies/ make little provision for noise barriers and noise suppression, can we not conclude that up to 30% of the track cost has been omitted? And if so, we can say with a degree of confidence that if the EU’s 7:1 BCR for noise mitigation is to be believed, then the VRT’s currently stated track cost should be divided by half, and that missing portion multiplied by 7 so see the true cost of the missing sound mitigation in socio-economic terms. So much for any ‘wider economic benefits’; they are, in fact, wider hidden costs.

By omitting adequate noise pollution measures, the real project cost becomes up to two times greater than that disclosed in the feasibility studies; ergo the outcome of manipulating a study is determined by whoever has control over the process. Hence the need for rigorous, independent, oversight.

Summary

The Czech Ministry of Health’s arguments contradict the WHO, the EU’s Phenomena report, and the recent European Commission Report.

When a government disregards the econometric costs to taxpayers and the wider economy of noise pollution, increasing the permissible dB levels can lead to cost savings in infrastructure development. 

This is because raising the dB levels allows for a broader area surrounding the infrastructure to be exempt from compensation for any resulting damage and there is less need to provide sound barriers for these people. 

By expanding the zone where compensation is not required or development allowed, the government can effectively reduce the visible financial burden associated with infrastructure projects.

Such a ploy ignores the resultant health and productivity costs to the economy; it defers them. It moves them off the balance sheet of the infrastructure project and into a later, but greater, socio-economic burden that is harder to assign or attribute.

Koridor D8 has started a petition. https://e-petice.cz/petitions/stop-navyseni-hlukovych-limitu-1.html

Please sign it.

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Press briefing at the Senate – Softening noise limits:

https://www.senat.cz/informace/galerie/videogalerie/video.php?id=1111