Moving noise action planning towards more environmental health equity. Five propositions

ABSTRACT

European noise policy is originally committed to the precautionary principle of environmental planning, aiming at high environmental health standards. Recent assessments of the European Noise Directive report an increase of traffic and an under-estimation of health effects, however. In addition to traffic-related noise exposure, the European Union faces another serious public health problem: health inequity, with social epidemiological research providing tentative evidence on social and socio-spatial inequalities in noise exposures and health effects. In view of these two challenges, we set out to describe five propositions offering entry points to achieve more environmental health equity through noise action planning.

KEYWORDS:

• Environmental health equity
• environmental justice
• precautionary principle
• vulnerability of the population principle
• European Environmental Noise Directive
• noise action planning

Introduction

Traffic-related noise exposure has been recognised as a major environmental threat to health in the European Union more than 20 years ago (European Commission 1996). In compliance with the precautionary principle laid down for environmental policies in the European Union (Art. 174/191 Sect. 2 of the European Treaty 1997/2012 (European Parliament and Council of the European Union 2012)), the European Commission has been taking efforts to establish a sound grounding for its noise policy, responding to scientific evidence by guidelines of the World Health Organisation (WHO) in 1999, 2009, and 2018 (Berglund et al. 1999; WHO Regional Office for Europe 2009, 2018) and contributing to the quantification of healthy life years lost due to environmental noise in 2011 (WHO Regional Office for Europe/Joint Research Centre of the European Commission 2011).

At the heart of the European noise policy is the Environmental Noise Directive (END) enacted in 2002 (European Parliament and Council 2012). The Community commits itself ‘to achieve a high level of health and environmental protection’ (preamble) and ‘to avoid, prevent, or reduce on a prioritised basis the harmful effects, including noise annoyance, due to exposure to environmental noise’ (Art. 1, Sect. 1). In what follows, the END requires member states to quantify source-specific environmental noise exposure and to estimate their health effects separately every five years (noise mapping rounds 2007, 2012, 2017), to communicate the results to the public as well as to protect and improve environmental quality through noise action plans following the noise mapping. Despite its high objective, the END does not include binding environmental values. Furthermore, regulations on content and procedures are vague.

However, the assessment reports by the European Environment Agency (EEA 2014, 2020a) describe traffic-related noise exposure as rather persistent, with exposure to road and rail traffic noise being expected to increase from 2017 to 2020 inside and outside urban agglomerations. Given its prevalence, exposure to road traffic noise remains the most prominent source, though varying largely between urban agglomerations (‘urban areas’) within Europe. Limited data availability and spatial coverage of END exposure mapping¹ on the one hand and exposure-response-relations reaching below mapping thresholds² on the other hand imply an underestimation of true health effects. Due to implementation deficiencies, noise action planning could not avert failing to reach European goals according to the Seventh Environment Action Programme (EEA 2020a), i.e. ‘noise pollution in the Union has significantly decreased, moving closer to WHO recommended levels […]’ by ‘[…]implementing an updated Union noise policy aligned with the latest scientific knowledge, and measures to reduce noise at source, and including improvements in city design […]’ (European Parliament and Council of the European Union 2013, L 354/188).

Apart from traffic-related noise, there is another enduring public health problem that the European Union has declared to tackle: health inequities (European Union/European Commission 2013). Variations in exposures and health effects (modifications) are major components of social epidemiological models explaining the persistent link between social and health inequalities (e.g. CSDH (Commission on Social Determinants of Health 2008, Krieger 2011). The higher one’s social position, the more positive is the balance between harmful and beneficial exposures across contexts and the lower the responsiveness (vulnerability) to adversities. With respect to noise exposure, these two mechanisms of exposure variations and effect modifications are pivotal in models on environmental health equity (justice) (e.g. Bolte et al. 2011, 2018) and have been subject of qualitative and systematic reviews (scientific papers: Barnes et al. 2018, Dreger et al. 2019, reports: EEA 2018, Science for Environment Policy 2016). Apparently, there is no clear-cut social/socio-spatial gradient in noise exposure in Europe.³ Yet, there are indications of identifiable population groups being exposed to higher traffic noise levels and less environmental resources relevant for restoration and noise reduction (as measured by access to/availability of green and blue spaces, for example). These groups can be defined by indicators like deprivation (transfer income) or ethnic community and migration background. People with low educational attainment, low household income, low occupational status, or migration background can be more vulnerable to traffic noise exposure because of different access to resources as defined by institutions (e.g. public services and policies, including planning), (local) economies (e.g. labour, housing and grocery markets), and communities (e.g. social networks and support) (cf. ‘neighbourhood environments and rules of access’, Bernard et al. 2007, for example). Moreover, these population groups may have less capabilities to maintain resources relevant for both civic engagement (Köckler 2017) and health. Consequently, they experience reduced control (over one’s exposures and coping options), increased stress levels, and negative behavioural and health sequelae (Whitehead et al. 2016, Riedel et al. 2017a). In our view, noise action and local planning contributes to exposure distributions as well as to controllability perceptions through planning procedures. We therefore consider unequal exposures and vulnerabilities as inequities and planning policies as responsible for distributional and procedural environmental justice. Yet, the END neither obliges member states to assess socio-spatial inequalities in noise exposures and health effects nor to deal with them in noise action plans.

Against this background, we want to put forward five key propositions how to move noise action planning towards more environmental health equity.⁴ To confer an idea of different stakeholders’ responsibilities, we compiled potential entry points for authorities, local parliaments, researchers, nongovernmental and civil society organisations, citizens, and the European Union in Table 1. Though referring to the situation in Germany, we believe that our five propositions are of more general interest.

Table 1. Stakeholders for action on more equity in noise action planning.

Urban planning department	Environmental department	Health department	Local parliament with its committees	Researchers	Nongovernmental and civil society organizations	Citizens	EU
Proposition 1) Implementing noise action planning effectively requires noise and health in all (planning) policies. Binding standards for noise-related environmental quality and inter-sectoral collaboration across political and administrative levels help establish this requirement.
Local: Contribute to noise action planning	- Integrate views of other departments - Set own standards on noise - Negotiate agreements with other departments	Contribute to local (environmental) planning	-Commit itself to noise and health in all policies -Decide on local environmental standards -Call for and support agreements with higher levels.	Provide evidence for standards	Expert associations: Offer trainings for practitioners to understand other stakeholders and develop argumentation lines	––––	Set environmental standards
Proposition 2) Noise action planning should consider differences in health effects (different vulnerabilities).
Inform environmental department about sensitive infrastructures	Integrate multiple burdens and vulnerability in analysis	Support with data on vulnerability and knowledge in this field	Provide political mandate	Provide tools for integrated multiple burden assessment and evidence on vulnerability among population groups	Expert associations: Raise public awareness through different media and trainings	––––	Adapt END on integrating vulnerability
Proposition 3) Distributional effects of noise action plans have to be evaluated.
––––	Work together with neighbouring municipalities to follow ‘all affected’ principle Use results from vulnerability assessment (see proposition 2)	––––	Provide political mandate	Develop and help establish an indicator system for monitoring purposes	––––	––––	Adapt END on distributional effects
Proposition 4) The assessment of the total noise exposure is necessary to estimate the extent of inequalities in environmental exposures.
Develop linkages to integrate noise in land use plan or urban development concepts systematically with the focus on multiple burdens	Try innovative approaches from science	Support with data on vulnerability and knowledge in this field	Provide political mandate	Develop modelling techniques and communicate their results	Expert associations: (like VDI in Germany) develop guidelines on methods on multiple burdens and noise	––––	Adapt END on methods on multiple burdens
Proposition 5) Public information and consultation according to the END involves empowerment and innovative methods to enable effective and just civic engagement.
Provide experience in public participation to colleagues from environmental department	Run a participatory process taking vulnerability of people into account	Offer knowledge and methods on empowerment and setting related approaches	Provide political mandate	Develop innovative tools and methods for participation	- Make us of the participatory processes - Encourage citizens and provide instrumental support (e.g. overcome illiteracy, language barriers, etc.)	- Make use of the participatory processes - Give feedback on perceived effectiveness of measures	Develop Aarhus convention further

Notes. This table was inspired by the WHO environmental health inequalities resource package (Fairburn et al. 2019) that provides information on what experts and stakeholders can do. We selected the categories of the environment department that is responsible for noise action planning in Germany according to the END. We included the urban planning as well as the health department. Other departments might be relevant, too. As in Germany the local level is politically strong due to their right to self-government, we included the local parliaments with its committees, mainly the one on the environment. Furthermore, we added researchers, non-governmental organisations and civic organisations, citizens and the EU as responsible institution for the legal framework. This table is much more to show relevant stakeholders named in our five propositions than being comprehensive in the sense of a policy analysis.

Implementation of the Environmental Noise Directive in Germany

According to German legislation, ambient noise mapping and action planning is part of local environmental planning – except for federal railways managed by the Federal Railways Agency. Germany conforms to noise mapping requirements, but still lags behind in regard to noise action planning in urban areas and major traffic infrastructures (European Commission 2019). Though caution is warranted when comparing exposure data between years, the number of people exposed to road traffic noise levels above the mapping threshold seems to have stabilised at least or even decreased. More than 20% of the population in urban areas are exposed to adverse noise levels during the day-evening-night period (up to 66% in the most affected city, followed by 46% in the second worst-off) (EEA European Environment Agency 2020a, 2020b). In spite of the precautionary principle, current practice is rather focused on managing high noise levels than on protecting quiet areas and developing long-term strategies. However, higher environmental standards for noise action planning are increasingly called for (cf. memorandum of understanding by noise experts (Brink et al. 2019), graduated target values by the Federal Environment Agency (Federal Environmental Agency (Umweltbundesamt) 2019, Köckler 2017). At the same time, quiet areas – as one element of noise action planning that has been applied in Germany only very rarely until now – are beginning to gain attention (cf. recent guide promoted by the German Federal Environment Agency (Heinrichs et al. 2018)).

Tendencies for socially unfavourable distributions of environmental noise, air pollution and public green areas have been found in selected German cities (e.g. in the Ruhr Area and in the city states Berlin and Hamburg (BfS Federal Office for Radiation Protection (Bundesamt für Strahlenschutz 2011, Köckler et al. 2018).

Environmental health equity through noise action planning? Five propositions

1. Implementing noise action planning effectively requires noise and health in all (planning) policies. Binding standards for noise-related environmental quality and inter-sectoral collaboration across political and administrative levels help establish this requirement.

Certainly, achieving a high level of environmental health equity calls the local environmental departments to account for environmental adversities accumulating locally (‘multiple burden’), e.g. traffic-related noise and air pollution, as suggested by the European Environment Agency (EEA 2018, 2020a). In view of the noise objective of the END, we focus on noise-related environmental quality for healthy living conditions.

In Germany, local environmental and urban planning departments and committees are required to address noise-related healthy living conditions: The environmental departments are responsible for the implementation of the END. They therefore deal with ambient noise in the whole city. The END sets no binding standards on noise levels to be reached, however. The planning departments deal with urban land use planning in general and act on the overall commitment to a sustainable and just development, as laid down in the German Federal Building Code (BauGB Baugesetzbuch 2017) and specified in the Federal Land Utilisation Ordinance (BauNVO Baunutzungsverordnung 2017). The latter includes regulations in relation to different land uses including binding standards on noise. These standards have to be applied in case of land-use planning procedures for new developments, only.

What is more, noise-related quality standards do not improve environmental health if they are unambitiously low, as if ignoring scientific evidence of exposure-response-relations. Comparably high decibel levels for new plans have been introduced for inner city areas only recently in the Federal Land Utilisation Ordinance (BauNVO Baunutzungsverordnung). Regarding END, such overall standards are missing. Some state authorities (Environment Ministries of the Federal States) recommend their own standard values for noise action planning. In the densely populated state of North Rhine Westphalia (NRW), the Environment Ministry decreed very weak environmental standard as a level of orientation of 70 dBA L_den values in the vicinity of residential land uses and vulnerable infrastructures in 2008 (Ministerium für Umwelt und Naturschutz NRW 2008). As these standards are recommendary to the local level and not binding like those set by the EU for air quality, the responsibility for setting standards is passed on to the local level.

In contrast, the new WHO Guidelines on Environmental Noise define a need for action even below the current mapping thresholds. In addition, the revised Annex III of the END requests to assess health impacts based on exposure-response-relations and formulas derived from the discourse with the WHO guideline development (European Commission Directive (EU) 2020/367 of 4 March 2020). In consequence, environmental planning practice should not need to justify lower noise levels. Instead, justification should become compulsory wherever not exhausting possibilities for noise reduction and improvement of environmental qualities even if acting in highly contested and conflictual are(n)as. This calls for action on the EU level. In this vein, quiet areas need further qualifying, e.g. from access to quiet sides and courtyards, inner-city parks to protected landscapes, thereby promoting social, psychological and physical aspects of health and well-being beyond mere disease prevention. Different uses and restoration needs may allow specifying differentials in noise-related quality standards (Heinrichs et al. 2018, SRU Sachverständigenrat für Umweltfragen 2020).

Reducing noise levels while protecting and improving environmental qualities lays the strategic ground for identifying synergies and conflicts as well as solving the latter with other planning concerns in urban planning procedures and design. Inter-sectoral collaboration across political and administrative levels including mainly urban planning, environment and health department is indispensable to acquire political power and commitment to environmental health (equity). Engaging in inter-sectoral collaborations can provide access to financial means, e.g. from urban regeneration funds, which facilitates actions against noise exposure and for quiet areas. Agreements at both state and municipal levels can be conducive to such collaborations⁵ – in particular when it comes to noise action planning alongside federal or regional railways inevitably touching upon plans and programmes of various planning authorities on different levels (local, regional, state and national). Ideally, collaborations across and between levels ensure the inclusion of those ‘beyond conventional political boundaries’ according to the ‘all-affected principle’ of procedural environmental justice (Bell and Carrick 2018, p. 104).

• (2) Noise action planning should consider differences in health effects (different vulnerabilities)

Available exposure-response-relations are not calculated according to the heterogeneity of population groups (as characterised by indicators like income, e.g. separately for people living below and above poverty threshold). As pointed out in the introduction, differences in vulnerabilities to noise are plausible to assume. Internal (biological), psychosocial and social-structural as well as external (environmental) exposures join to shape vulnerabilities across the life course. While probing into the complexities of exposure variation and effect modification is an ongoing challenge, as demonstrated by new EU research initiatives centred around the ‘human exposome’ in living environments (Website of the European Human Exposome Network 2020), the precautionary principle prompts environmental planning to take provisions even if scientific evidence, data availability and quality are limited. In case noise maps showed comparable noise levels in socially disparate neighbourhoods and lower exposure levels prevailed in areas otherwise disadvantaged: Differences in personal exposures across settings, perceived constraints and coping options might still lead to different health effects. However, even if environmental planning had profound information on exposure variation and effect modification, there was still a risk of missing vulnerable groups ensuing from the spatial-temporal selectivity of mitigation measures. In this line, the previous WHO Night Noise Guidelines sought to deliver threshold values explicitly to protect certain ‘vulnerable groups’ (including shift workers, children, pregnant women, for example) (WHO Regional Office for Europe 2009).

To capture vulnerability, a ‘population- and setting-based analysis of risks and potentials’ (Riedel et al. 2017b) could serve as first step towards precaution related to environmental health equity. In a joint endeavour, health, environmental and planning departments could use indicators like migration background, educational attainments, places of work and residence, and combinations thereof in order to identify population groups who face disproportionate exposure distributions and/or have an increased vulnerability to health effects of traffic noise exposure. Environmental departments could approach local parliaments and committees and present reasons for differentiating noise levels and for allocating resources accordingly (as described under the first proposition). Moreover, such sets of indicators could be aligned with attempts to operationalise health- and engagement-related capabilities as a concept sensitive to group differences and applicable to different accountability levels (incl. residents, planning authorities, communities, and the state) (cf. Day 2018). Recurring to the capability approach in environmental justice involves an understanding of equity as justification for environmental and planning departments as well as political committees to apportion resources in relation to what is needed, thereby narrowing gaps along social gradients of health. This applies to exposure distributions, procedures and recognition in correspondence with the principles of proportionality (Bell and Carrick 2018) and vulnerability of the population principle (Köckler 2017, SRU Sachverständigenrat für Umweltfragen 2020, p. 307). Highlighting differences in affectedness, in individual and in communal mastery in face of environmental exposures in settings and places, these principles complement the precautionary principle of environmental planning.

• (3) Distributional effects of noise action plans have to be evaluated.

Inherent to the second proposition is the availability and generation of small-scale data on potentially vulnerable groups and exposures in settings. Such data is needed to anticipate and quantify distributional effects of planning interventions (Bolte et al. 2018), given that the application of different noise priority indices could yield different socio-spatial results (D’Alessandro and Schiavoni 2015). Thus, noise priority indices or other tools used for decision-making could be modified so that accumulations of adverse exposures are rather attenuated than aggravated. At the same time, population dynamics within and between spatial units have to be traced to recognise changes in population compositions at an early stage, i.e. at the onset of polarisation. A practice-based project has rated the integration of population-based (social and health-related indicators) and environmental exposure data as feasible in German agglomerations (Preuß et al. 2015) if small-scale data are available. In view of the European scope of the END, research on measuring environmental health inequalities (and capabilities as elements of agency and accountability) in Europe is needed to install a monitoring basis in order to assess the impact of noise action planning on environmental health equity (cf. WHO Collaborating Centre on environmental health inequalities (University of Bremen 2020)).

Assessing distributional effects of noise action planning requires from the local environmental departments of neighbouring municipalities noise mapping not to stop at the municipal borders of urban agglomerations in line with the ‘all-affected principle’ of procedural environmental justice (see proposition (1) above). To detect relocation effects of noise actions in adjacent areas outside the current spatial scope of the END, techniques allowing comprehensive modelling are needed, such as making use of remote sensing (2020). Comprehensive modelling would increase the comparability of state-wide indicators intended to monitor spatial trends indicative of sustainable development (e.g. the proportion of people exposed to adverse noise levels). If adopted by the END, such comprehensive modelling would facilitate to produce a more ‘complete health impact assessment’ (van Beek et al. 2015) across member states.

• (4) The assessment of the total noise exposure is necessary to estimate the extent of inequalities in environmental exposures.

Sources of traffic noise can coincide locally and/or temporarily, e.g. exposure to road plus rail traffic can affect residents simultaneously or subsequently, whereby time windows for restoration can be reduced significantly (SRU Sachverständigenrat für Umweltfragen 2020). This aspect of multiple burdens is critical for environmental health equity, demanding ‘noise action’. The END, however, requires health impact assessments to be source-specific. Acknowledging the concurrence of noise sources, the END advises to compare the ’relative importance of each noise source’ (Annex III). We call for promoting research-based and binding instructions on how to assess total noise exposure appropriately. In Germany, the expert association of German engineers (VDI) produces guidelines which are relevant for every day practice in planning and are applied to decide on legal actions. Such associations with expert knowledge and power to define best available methodologies could push endeavours to relate noise assessments to socio-spatial inequalities.

• (5) Public information and consultation according to the END involves empowerment and innovative methods to enable effective and just civic engagement.

The END puts much emphasis on transparent environmental health information and participation of the public.⁶ Participation is a key element of a sustainable and healthy development from a public health perspective (WHO Regional Office for Europe 2002) and linked to environmental health equity via the procedural aspect of noise action planning. Empowerment as a psychosocial concept of participation is related to overcoming perceived uncontrollability of traffic-related exposures (Lercher 2007) and attenuating vulnerability in terms of the principles of procedural environmental justice mentioned above – if structural conditions are balanced out. Moreover, conferring a sense of control in the process of noise action planning might prove as a strategy to alleviate negative controllability perceptions generalised to other life domains (e.g. help- and hopelessness) (Riedel et al. 2017a). To achieve such transformations in individuals and communities, consultations must go beyond single, occasion-related events (Bell and Carrick 2018) and establish community-engaged policy action cycles within environmental planning in general and noise action planning in particular. At this point, the environmental departments who are responsible for the participatory process are to use context-specific approaches of participation. Citizens have to witness meaningful involvement. This means participation results have to be taken into account in developing and enacting the noise-action plan in the environment department and in the environment committee. In accordance with the Aarhus convention (1998), this also implies communicating environmental health risks and planning constraints in order to develop trust in the institutional process among citizens. Furthermore, innovative, digital participation tools might be key to effective, inclusive and just civic engagement (Köckler and Simon 2019).

Conclusion

In light of recent assessments of increasing noise exposure, underestimated health effects, and persisting social and environmental inequalities in health, we outlined five propositions offering entry points to achieve more environmental health equity through noise action planning. The principles of proportionality and vulnerability of population as well as the precautionary principle in all (planning) policies may help realise a mitigation strategy in accordance with Marmot’s ‘proportionate universalism’ (European Union/European Commission 2013, p. 138): Considering the universal objective of the END, this strategy serves the population as a whole and is increasingly ‘effective’ with increasing exposure levels and/or vulnerability to road traffic noise (Riedel 2013, Dreger et al. 2019). Specifically, noise-related environmental equity could be generated from lower standard values for noise action for all as well as from setting- and population-based target values for restorative places. Noise action and local planning could build on different types of exposure data, from noise modelling to locals’ knowledge of settings, in order to allocate measures according to group-specific restoration needs. To explore these, civic engagement tools could be adjusted to different capabilities, thereby enhancing empowerment. Given the various social causes of vulnerability, these measures might even need go beyond the environment and planning sector, i.e. investments in the built environment, to make an actual difference to environmental health inequities. The opportunities are to be realised by different stakeholders as exemplified in Table 1. Each could act in his or her own arena, but in total the concerted impact will be even more relevant for health equity. The local parliament is able to submit a political mandate on quality standards for environmental planning and participation regardless of missing European standards, but the EU could ease the path to local standards by changing END regulations.

Acknowledgement

We would like to thank all scientists and practitioners who contributed to the discussions during our workshop at the Institute of Public Health and Nursing Research, University of Bremen, in 2019.

Disclosure statement

No potential conflict of interest was reported by the authors.

Additional information

Funding

Natalie Riedel is currently funded for her research project ‘Exploring cognitive-motivational determinants of health (inequities) in the context of the European Environmental Noise Directive’ by the German Research Foundation [project number 387821120].

Notes on contributors

Natalie Riedel

Natalie Riedel is a post-doctoral scientist affiliated with the Department of Social Epidemiology, Institute of Public Health and Nursing Research, University of Bremen, Germany, due to her own project funding since 2015 (Excellence Initiative, German Research Foundation (DFG)). She graduated and received her doctoral degree at the Faculty of Spatial Planning, TU Dortmund University, Germany, in 2008 and 2014, respectively. She was granted a two-year fellowship for her dissertation at the Institute for Spatial Planning, TU Dortmund University. Her research is located at the interface of environmental health, urban and environmental planning, and environmental justice.

Heike Köckler

Heike Köckler is Professor on Place and Health at the Department of Community Health, Hochschule für Gesundheit in Bochum, Germany. She is a spatial planner by profession working on healthy urban development, environmental justice, and digital participatory methods of spatial analysis. One focus of her work is noise action planning and its potential for healthy, just and sustainable urban development. She completed her PhD at the Faculty of Spatial Planning, TU Dortmund University, and her habilitation at Kassel University.

Gabriele Bolte

Gabriele Bolte is an expert in epidemiology and public health. Since 2013 she is Professor of Social Epidemiology at the University of Bremen. She is managing director of the Institute of Public Health and Nursing Research (IPP) and head of the department of Social Epidemiology at the IPP. Since 2019 she is the director of the WHO Collaborating Centre for Environmental Health Inequalities. Main topics of her current research are environmental justice, urban health, and equity impacts of public health interventions. Besides her scientific career, she has profound experience in science transfer and to assess policy implications of scientific evidence by working in public health authorities at the national and at the federal state level.

Notes

1. restricted to urban agglomerations with > 100,000 inhabitants and major roads with > three million vehicles per year and railways with > 30,000 trains per year outside urban agglomerations since 2012. In the first round in 2007, noise mapping applied to agglomerations with > 250,000 inhabitants and traffic infrastructures with > six million vehicles and > 60,000 trains, respectively.

2. which are ≥ 55 dB A L_den (average A-weighted decibel levels during the day-evening-night period) and ≥ 50 dB A L_night(average A-weighted decibel levels during the night).

3. Inconsistencies in findings can stem from the indicators used to measure noise exposure (subjective response or objective modelling with different, more or less fine-grained techniques) and social positions (sociodemographic and -economic dimensions) on different levels (individual, household, residential blocks, or neighbourhoods) as well as study designs (using individual-level or aggregated ‘ecological’ data) (Riedel et al. 2014, Dreger et al. 2019).

4. These propositions result from a workshop with scientists and practitioners from different sectors and institutions held at the Institute of Public Health and Nursing Research, University of Bremen, 2019, complemented and updated by literature. The German documentation of the  workshop can be retrieved from: https://www.ipp.uni-bremen.de/uploads/IPPSchriften/IPP-Schriften_17.pdf 

5. as illustrated by the decree of Transport Ministry of Baden-Wuerttemberg (Ministerium für Verkehr Baden-Württemberg 2018) and administrative arrangement in the city state of Bremen (Gesundheitsamt Bremen 2018; cf. in addition: SRU Sachverständigenrat für Umweltfragen 2020).

6. Authorities responsible for noise action planning are required ‘to ensure that the public is consulted about proposals for action plans, given early and effective opportunities to participate in the preparation and review of the action plans, that the results of that participation are taken into account and that the public is informed on the decisions taken’ (END, Art. 8, no. 7).