Why Report Noise Pollution?
Noise pollution is any unwanted or disturbing noise, also known as environmental noise, which can have varying effects. Noise pollution often stems from workplace machinery, loud music, transportation, construction, and wind turbines, to name a few. These harms are also associated with several health conditions including hearing loss, cardiovascular problems, and faster cognitive decline.
To understand the proposed reporting guidance regarding noise pollution, a foundation in the law must first be introduced. The Clean Air Act is a federal law that grants the Environmental Protection Agency (EPA) authority to implement standards to protect public health. Title 42 Section 7641 of the United States Code authorized the establishment of an Office of Noise Abatement and Control to conduct investigations affecting public health to identify and classify sources of noise pollution. As of 2021, as stated in a recently proposed amendment to the bill, “approximately 28,000,000 individuals in the United States are afflicted with some hearing impairment, and it has been estimated that 10,000,000 of those impairments are at least partially attributable to damage from exposure to noise” (Bill Amendment). Noise reduction programs are at the forefront of some lawmakers' minds right now as noise pollution has become increasingly worse.
Given that noise pollution is an ongoing problem that society is trying to reduce, some companies’ stakeholders are asking companies to reduce their noise pollution. Towards this end, many companies are beginning to report and reduce noise outputs as part of their environmental, social, and governance (ESG) efforts.
Exploring the CDSB Framework
The Climate Disclosure Standards Board (CDSB) is an independent organization whose guidance has been consolidated into the International Financial Reporting Standards (IFRS), which allowed for the creation of the International Sustainability Standards Board (ISSB).
Before CDSB’s consolidation, it published a list of requirements to guide companies on ESG reporting. The CDSB’s framework was created to complement financial reporting and to encourage standardization of environmental and social reporting in companies’ mainstream financial reports. While the framework does not require any specific formats or styles to be used, the intention of the CDSB’s framework is to guide companies in creating streamlined and comparable financial reports that are easily digestible for stakeholders. This article will focus on the Reporting Requirement REQ-04 in the guide: Sources of environmental and social impact. The purpose of REQ-04 is to report material sources of environmental and social impact that have arisen over the reporting period using qualitative and quantitative data. The CDSB defines sources of environmental and social impact as activities of and outputs from the organization that have or may have caused or contributed to environmental and social impacts. Some of these activities relating to the environment include greenhouse gas (GHG) emissions, renewable and non-renewable energy consumptions, and non-GHG emissions, particularly noise.
The CDSB recommends that high-quality quantitative information should be supplied for these material sources of impact, and, at a minimum, companies should report where these issues arise from the operations or activities within its organization. An example of quantitative information could be reporting the average decibel output of a manufacturing plant or a plane landing zone relative to the distance of nearby listeners. The CDSB also recommends a narrative that aids the stakeholder in understanding the reported data. If reporting quantitative data is not possible, qualitative information should be given. Since many companies find it more difficult to publish quantitative data, many choose to publish qualitative narratives instead.
Qualitative information should be presented using normalized and accepted statistical methods and should avoid obscuring or misrepresenting the experience of the most at-risk groups.
The CDSB also recommends that sources of environmental and social impact that originate outside the organization’s reporting boundary still be reported when feasible. The CDSB also recognizes that because there is a lack of recognized methodologies for calculating these ESG impacts, things like dialogue, transparency, and information should be given to potentially-affected stakeholders when possible. Most importantly, the CDSB recognizes that most of this information is already collected by organizations because of regulatory agency requirements or other state law requirements.
While a full report of the CDSB framework is beyond the scope of this article, we can see how the framework recommends common sense and streamlined environmental and social reporting be included in financial reports. Many noise producing organizations are already measuring and reducing noise output so as to not harm workers or nearby civilians. The only leap the CDSB asks of these organizations is to make the data digestible and more readily available in financial reports. It is reasonable to believe that this framework will be a reference for the ISSB’s soon-to-be-announced guidelines.
Company Applications and Examples
For non-GHG emissions like noise pollution, it appears (based on the examples below) that stakeholders of noise impact organizations are typically more interested in the social and health consequences of these emissions on civilians and workers than the environmental effects.
While noise producing organizations may not explicitly use the CDSB framework, these companies do publish ESG reports that cover the topic of noise pollution and are in accordance with the CDSB framework. Below are two examples of ESG reports that discuss noise pollution and are in accordance with the CDSB framework.
The current lack of structured reporting on the topics of noise pollution and non-GHG emissions is apparent. While greenhouse gasses are a hot-button topic, and increasingly being reported, non-GHG emissions like that of noise are being left behind in terms of the amount of reporting and disclosure. The importance of reporting these emissions is increasing as non-GHG emissions are also health risks and societal problems. Companies compliant with the CDSB show strong transparency in noise pollution and other similar emissions. The published narratives like that of CNH Industrial and Stellantis show that there is headway being made in the non-GHG emissions field. ESG reports like these demonstrate how this valuable information can be included in the company reporting and increase the transparency of complex company responsibilities.