Updated, 22.09.26

In September 2026, The Soundproof Windows submitted a technical response to the London Borough of Richmond upon Thames consultation on its revised Statement of Licensing Policy.

Under the Licensing Act 2003, the policy helps guide the Council when considering premises licences for activities including the sale of alcohol, regulated entertainment and late-night refreshment. One of the four statutory licensing objectives is the prevention of public nuisance.

The draft policy already gives detailed consideration to noise, vibration, entertainment, plant, deliveries and other activities capable of affecting neighbouring residents. Our response therefore did not simply ask the Council to “consider noise”. Instead, it focused on practical acoustic issues that can become important when licensed premises operate close to residential buildings.

View Richmond Council’s Statement of Licensing Policy Consultation

Entertainment noise is not always adequately described by a single overall sound level.

Music containing strong bass can include substantial low-frequency energy. Low-frequency sound can behave differently from higher-frequency sound, particularly where it passes through lightweight construction, openings or structural elements. In some buildings, residents may experience a combination of airborne music noise and structure-borne vibration.

Our consultation response suggested that, where relevant and proportionate, acoustic assessment should consider:

• the character of the sound
• frequency content
• low-frequency music or bass
• structure-borne vibration
• sensitive evening and night-time periods

rather than relying only on an overall A-weighted noise level.

Noise does not necessarily reach neighbouring homes through one building element. Depending on the premises, transmission may involve:

• loudspeaker location and isolation
• building structure
• floors and party walls
• doors and windows
• ventilation openings
• acoustic lobbies
• plant
• junctions between building elements

For this reason, acoustic mitigation should consider the complete transmission path rather than assuming that one component alone is responsible for the problem.

This principle is particularly important in older and mixed-use buildings, where construction may have changed over time and several transmission routes can operate simultaneously.

A central point in our submission was that noise should normally be addressed at its source before reliance is placed on modifications to neighbouring homes.

For entertainment premises this may include measures such as controlling source level, loudspeaker positioning and isolation, acoustic lobbies, management of doors and windows, plant control and operational management.

Receiver-side façade improvements can sometimes form part of a wider solution, but they should not automatically become the primary method of controlling noise generated elsewhere.

For background on residential protection from neighbourhood and entertainment noise, see our anti-social noise resource.

Richmond’s draft policy includes provisions relating to Noise Management Policies.

Our response suggested that these could usefully identify not only the potential noise source, but also:

• the nearest or most exposed noise-sensitive premises
• sensitive periods of operation
• the likely transmission mechanism
• the control measures relied upon
• how those measures will be checked in practice

This is particularly relevant where a strategy depends upon measures such as noise limiters, closed doors, acoustic lobbies, restricted use of outdoor areas or plant controls.

A mitigation strategy is more useful when it explains not only what should happen, but also how it will be verified.

The draft policy introduces provisions concerning the environmental impact of generators.

Generators can produce both airborne mechanical noise and vibration, including low-frequency components that may become particularly noticeable during quieter evening and night-time periods.

Where generators are necessary, our response suggested that acoustic considerations may include:

• location relative to residential properties
• operating hours
• acoustic screening or enclosure
• vibration isolation
• avoiding unnecessary night-time operation

The appropriate approach will depend on the individual site and circumstances.

Delivery-related noise is not limited to vehicle engines. In practice, neighbouring residents may also experience noise from:

• loading and unloading
• vehicle doors
• shutters
• handling of containers
• reversing alarms
• staff activity
• vehicles waiting outside premises

These sources can become particularly noticeable during early-morning, evening and night-time periods when background noise levels may be lower.

Our response therefore encouraged delivery arrangements to be considered as part of the wider noise-management strategy for premises located near homes.

One of the broader principles raised in our response was the need to consider how neighbouring homes are actually occupied.

Noise mitigation at a licensed premises should not automatically assume that nearby residents will keep their own windows permanently closed to avoid disturbance. This becomes particularly relevant during warmer periods, when occupants may depend on open windows for ventilation or cooling.

Older residential properties can also vary considerably in façade construction, window condition, ventilation, airtightness and acoustic weak points. The practical residential impact of a noise source therefore depends on more than the nominal specification of a window or glazing unit.

Where closed-window acoustic performance forms part of a wider strategy, ventilation should also be considered. See our acoustic ventilation resource.

During the Richmond consultation, the Home Office published revised Section 182 Guidance under the Licensing Act 2003 on 15 September 2026.

The guidance takes effect from publication and licensing authorities must have regard to it when carrying out their licensing functions. Our response therefore suggested that Richmond review the final policy against the September 2026 version before adoption.

View the September 2026 Section 182 Guidance

Our submission focused on several relatively narrow technical points:

• explicit recognition of low-frequency music, bass and structure-borne vibration where relevant
• assessment of the complete noise transmission path rather than isolated components
• source control before reliance on modifications to neighbouring homes
• clearer identification of sensitive receptors and transmission routes within Noise Management Policies
• practical verification of noise-control measures
• acoustic consideration of generators and servicing activity
• realistic assumptions about neighbouring residents opening windows
• review of the final policy against the latest Section 182 statutory guidance

These observations were intended to strengthen the practical application of the existing public-nuisance provisions rather than prescribe one technical solution for every licensed premises.

For transparency, the full technical response submitted by The Soundproof Windows is reproduced below.