Detailed Responses to Each Question and Transport Scotland Comment
Question 1: Do you consider there has been anything left out of the Transport Noise Action Plan?
Question 1 - Key Themes
- Active travel and modal shift underplayed
- Biodiversity impacts under‑represented
- Cycling as a quiet mode
- Freight and logistics insufficiently acknowledged
- Health‑focused outcomes missing
- Intermittent / impulsive / antisocial noise under‑represented
- Land‑use planning and road‑maintenance considerations
- Location‑specific mitigation expectations
- Technical capability not fully reflected
- Worker experience (rail sector)
Question 1 - Response Summary
Respondents were broadly positive about the draft TNAP but highlighted a number of areas they felt could be strengthened. Many called for a clearer health‑based focus, including explicit reference to sleep quality, annoyance, and preventative public‑health outcomes. A strong theme across responses was the need to better recognise the impact of intermittent, impulsive, and antisocial vehicle noise, particularly at night, which respondents felt is not fully captured by current average‑based noise modelling.
Several contributors identified gaps affecting specific groups or modes. These included the noise exposure of rail workers, requests for localised mitigation in specific communities, and clearer recognition that motorised traffic is the main generator of environmental noise. Active‑travel organisations emphasised the need to frame walking, wheeling, and cycling as central interventions, noting the feedback loop in which quieter streets encourage modal shift. Related to this, respondents highlighted the noise effects of modern vehicle size and weight, and asked for TNAP to explicitly acknowledge cycling as one of the quietest modes.
Technical respondents pointed to advances in data analytics and computational methods, suggesting that TNAP should better reflect opportunities to capture short‑term noise patterns alongside long‑term averages. In addition, trade bodies emphasised the critical economic role of freight, the need to balance noise management with efficient network operation, and the relevance of land‑use planning and road‑surface quality to long‑term noise outcomes. Finally, several respondents asked for greater acknowledgment of the ecological impacts of noise, including effects on species behaviour and habitat quality.
Question 1 - Transport Scotland Comment
We welcome the constructive feedback and broad support for the draft Transport Noise Action Plan. We recognise the importance of ensuring the TNAP reflects lived experience, including the impacts of peak and night time noise, and we will take this into account when considering future mitigation design and prioritisation.
We also acknowledge the suggestion to explore additional noise indicators beyond those required under the Environmental Noise (Scotland) Regulations 2006. While strategic noise maps must follow the statutory methodology, we will work with the Steering Group to consider how supplementary data could support decision making.
The TNAP sets out a range of direct and indirect actions that Transport Scotland and partners may take to reduce noise exposure. Decisions on specific mitigation measures depend on local feasibility and must align with wider policy frameworks across health, planning, climate, and environment. We therefore continue to work closely with partners and other Scottish Government policy areas to ensure alignment and maximise co benefits.
We also note that TNAP covers transport noise from trunk roads, major roads, and rail corridors, and that other noise action plans apply to agglomerations and airports. Matters outside these remits — such as commercial premises or renewable energy noise — are governed by separate regulatory frameworks. We will share the consultation feedback with the owners of these documents and work together to determine any joint actions.
As we move into delivery, we will continue to strengthen linkages with other policy areas and ensure that prioritisation decisions reflect both strategic mapping outcomes and the practical management of Quiet Areas.
Question 2: Is there anything you consider should be discussed at the Transport Noise Action Plan Steering Group during the next 5-year cycle for Round 5?
Question 2 - Key Themes
- Freight‑corridor considerations
- Impulsive and night‑time noise as a priority
- Place‑based alignment
- Rail decarbonisation and workforce issues
- Reviewing past mitigation
- Strengthening the evidence base
- WHO 2018 guideline implications
Question 2 - Response Summary
Respondents identified several areas they felt should be prioritised by the TNAP Steering Group. A major theme was the need for more explicit consideration of intermittent, impulsive, and night‑time noise, particularly given its impacts on sleep and health and the unequal exposure of communities near major transport corridors.
Technical respondents encouraged the Steering Group to broaden the evidence base, exploring dynamic noise data, improved modelling approaches, and clearer communication of the limitations of average‑based metrics. Public bodies stressed the importance of place‑based approaches, aligned with National Planning Framework 4 (NPF4) and the People and Place Programme, and emphasised the value of involving Regional Transport Partnerships more systematically in the delivery and monitoring of noise actions.
The logistics sector pressed for early and ongoing engagement to ensure noise interventions do not inadvertently constrain freight capacity or conflict with decarbonisation requirements. Rail stakeholders highlighted opportunities linked to electrification and modern rolling stock, while the Institute of Acoustics encouraged a review of the effectiveness of barriers and other mitigations installed to date.
A small number of respondents raised the role of WHO 2028 Noise Guidelines in major projects. These comments relate more to scheme‑specific expectations than to the Steering Group’s strategic remit, but they underline the need for clarity on how TNAP interfaces with project‑level assessment.
Question 2 - Transport Scotland Comment
We welcome the range of suggestions for future Steering Group discussions and the strong support expressed for its role. All proposed topics will be captured and incorporated into the Steering Group’s forward work plan. This includes considerations of peak noise, modelling improvements, alignment with place‑based policy, and opportunities linked to rail decarbonisation and freight.
Question 3: Do you have any views on the long-term opportunities to better address Scotland's needs for managing transport noise?
Question 3 - Key Themes
- Biodiversity and ecology
- Fiscal and regulatory mechanisms
- Planning principles
- Prevention‑first, health‑focused approach
- Reducing noise at source
- Road‑surface quality
Question 3 - Response Summary
Respondents outlined a wide range of long‑term opportunities for strengthening Scotland’s approach to transport noise. Many emphasised a shift towards a prevention‑first, health‑centred strategy, addressing noise as an environmental pollutant and prioritising reduction at source. This included calls for greater emphasis on sleep, annoyance, and the disproportionate impacts faced by vulnerable groups.
Active travel, cleaner vehicles, and freight mode shift were seen as key opportunities. Respondents highlighted the significant share of short trips in Scotland and the noise‑reduction potential of increasing cycling, walking, and wheeling. Electrification of HGVs and rail was also viewed as important, alongside ensuring safety and visibility standards for new vehicle types.
Participants also raised the potential of fiscal and regulatory measures, including noise cameras and strengthened regulation of modified exhausts, along with more local monitoring to capture lived experience. Land‑use planning — particularly the application of the Agent of Change principle — was highlighted as essential for avoiding long‑term conflict between sensitive uses and noisy activities.
Public bodies and logistics organisations also drew attention to road‑surface quality, noting that quiet surfacing can provide effective noise reduction over the long term. Environmental respondents stressed the need to integrate biodiversity considerations, aligning noise policy with wider environmental frameworks.
Question 3 - Transport Scotland Comment
We welcome these suggestions and will share relevant points with other noise‑action‑plan leads. Through the Steering Group, we will continue to bring together specialists from across transport, planning, and environment to strengthen knowledge exchange and support a more integrated approach.
We recognise the value of a health‑centred approach and will explore opportunities to develop this further, including consideration of emerging “soundscape” approaches. We will continue to update technical guidance at appropriate intervals and ensure alignment with evolving evidence.
Where Transport Scotland identifies specific opportunities for noise reduction, we will seek the most effective funding route and consider noise mitigation.
Question 4: Are there any other comments you wish to provide in relation to transport noise or the Transport Noise Action Plan?
Question 4 - Key Themes
- Accountable, joined‑up governance
- Built‑in mitigation on future projects
- Integration with wider policy
- Lived‑experience evidence
- Transparent monitoring and evaluation
Question 4 - Response Summary
Respondents used this question to reflect on broader issues relating to governance, delivery, and the wider policy environment for noise management. Several highlighted inconsistent responses across agencies, which contributes to uncertainty around responsibility and accountability for noise issues. Others emphasised the need for clearer monitoring and reporting, including greater transparency around prioritisation and more opportunities for regional partners to contribute to evaluation.
A strong message from individuals was the importance of capturing lived experience, particularly in relation to unpredictable, high‑impact noise events that are not well represented in modelled averages. Respondents suggested expanding opportunities for residents to report issues and contribute local data.
Active‑travel organisations reiterated the importance of aligning TNAP with wider behaviour‑change and transport decarbonisation agendas, noting the reciprocal relationship between quieter streets and increased uptake of walking, wheeling, and cycling. Community groups also highlighted opportunities to embed noise mitigation into major projects from the outset, although some of the comments related to scheme‑specific matters that fall outwith TNAP’s remit.
Question 4 - Transport Scotland Comment
We welcome these wider reflections and will continue to review our overall policy approach to transport noise, ensuring alignment with technical guidance and related policy frameworks. We recognise the importance of clarity, transparency, and consistency across agencies and will work with partners to support improvements in these areas.