[NPC Clearinghouse]

"Good Neighbors Keep Their Noise To Themselves"

The Standing Senate Committee On Energy,
the Environment and Natural Resources

Written Statement of Mr. Charles Komanoff regarding
Bill S-10, The Personal Watercraft Act, 6 May 2003

I first want to thank Senator Mira Spivak for her invitation to testify. The honor is all the greater because I am not a citizen of this country; I come from south of the border. Still, I am not a total stranger to Canada. I’ve visited several of your great cities and tramped with great pleasure through your verdant countryside.

For some years my family and I have been summertime residents at a lakeside cabin in New York State’s Adirondack Mountains, a region of forests and waters similar to much Ontario terrain. Our experiences there have enabled me to appreciate the importance of Bill S-10, The Personal Watercraft Act.

By training, I’m an economist. By temperament, I’m a lover of the outdoors who takes great pleasures in the sounds — and silences — of nature. Five years ago, after a series of lake and seashore outings that were ruined by the relentless din of so-called personal watercraft,(1) I undertook, in collaboration with a colleague, to quantify the social costs of jet ski noise, using analytical tools and research findings from acoustics, economics and mathematics.

Jet Ski Noise Costs: We compiled our research in a booklet, Drowning In NoiseDIN for short(2). Among other things, we estimated the noise costs due to jet skis in the United States, both daily per beach and annually for the entire country. I’ve translated these results into Canadian terms, adjusting for the exchange rate and the different number of jet skis in the two countries.

We found that a typical jet ski imposes $75 of noise costs on beachgoers over the course of a day’s use.(3) This figure is the sum total of the separate losses in amenity experienced by beachgoers who are exposed to the noise. Assuming that jet skis are used an average of 15 days each year, as Mr. Currie of the CMMA attested to last year,(4) the typical machine causes $1,125 (the product of $75 times 15) of noise costs per year. If there are 50,000 operable jet skis in Canada, their aggregate noise-annoyance costs to Canadian beachgoers is some $56 million per annum (the product of $1,125 times 50,000).

(1)The term "personal watercraft" is a construct of the jet ski industry. It is a misnomer, insofar as jet skis increasingly are designed to carry more than one person, and their impacts on other humans and the natural world belie the word "personal." If anything, the term applies far better to non-motorized craft usable by individuals, such as kayaks, canoes, small rowing shells and windsurfers.
(2)Drowning In Noise (80-page booklet) was published in 2000 by the Noise Pollution Clearinghouse, PO Box 1137, Montpelier, VT 05601 USA. A Web-based version is available at www.nonoise.org.
(3)Costs were estimated in Drowning In Noise to average $47 per day (based on 3 hours usage), in year-2000 US dollars. I converted these to year-2002 Canadian dollars by multiplying by 1.6, the rounded product of the US-Canada exchange rate on 15-August-2002 (1.5624) and the approximate US inflation rate from 2000 to 2002 (1.032).
(4)See p. 11 of the transcript of evidence for Bill S-26, dated June 11, 2002. Note that in a letter to me dated Oct. 29, 2001, Mr. Currie wrote:"...at the present time the number of PWC's in operation here in Canada is between 80,000 and 100,000 units." The mean of that range would imply an annual noise-annoyance cost of $100 million (the product of 90,000 jet skis and $1,125 in noise cost from each).

Jet Ski Noise Costs (C$)

$75/day per machine
(beachgoers would pay to be rid)

$1,125/year per machine
(based on 15 days use per year)

$56,000,000/yr for Canada
(based on 50,000 machines in use)
Viewgraph #1: Jet skis impose large noise costs on beachgoers. Costs shown are based on 3 hours usage over the course of a day. Costs to boaters, landowners, and hikers within earshot are an extra %40.

What do these dollars represent? They represent the aggregate amounts of money that beachgoers would pay if by doing so they could eliminate the jet ski noise. In other words, Canadian beachgoers - your constituents - would pay some $56 million a year to be rid of noise from jet skis. This $56 million figure is conservative - likely to err on the low side - because it includes only noise costs to beachgoers. The additional noise costs imposed on property owners as well as boaters brings the annual noise annoyance costs per jet ski in Canada to almost $1,600 and the national total close to $80 million.

Of course no "market" exists in which beachgoers can buy quiet. But then, as you legislators know, mediating such "market failures" is a key function of government and a major rationale for Bill S-10.

My colleague and I derived these dollar figures carefully and conservatively. We combed the literature for the best estimates of "parameters" such as the value people place on a day of beachgoing, and the effect of elevated noise levels on property values, to take two examples.(5)

(5)For the curious: the value of a beach day in our analysis ranges from $16 per person for a "popular," easily accessible beach, to $48 for a "secluded" beach that takes more effort to attain. Our estimate of the "noise depreciation index," the degree to which additional noise in an environment degrades its value, is 1%, so that raising the prevailing noise level by, say, 8 decibels reduces the beachgoer's enjoyment by 8%.

Noise Cost Parameters

Jet ski distance -- Loudness in the water -- Loudness out of water -- % time out of water -- Duty Cycle -- "Clustering" -- Noise dissipation rate -- Value of beach day -- Noise Depreciation Index -- Beach length and depth -- Beachgoer population density -- Background noise level -- Number in use -- Days/year -- Secluded vs. popular beaches -- Lake vs. ocean beaches
Viewgraph #2: Over a dozen "parameters" had to be specified in Drowning in Noise to estimate jet ski noise costs. Each was derived rigorously, and a computer model was used to simulate a wide range of variations.

We then constructed a computer model to calculate the noise that jet skis add to a beach; this turns out to be a function of numerous factors such as each jet ski's noise output when it is in the water, the percent of time it jumps waves (which amplifies the noise), the jet ski's distance from people on the beach, and the background noise level (without the jet ski).

Mitigation Strategies: So much for the "absolute" level of jet ski noise costs. More important, perhaps, is whether, and by how much, the distress of beachgoers and cottagers could be mitigated if operators stayed further offshore, for example, or if each machine's noise output could be reduced in the first place. We researched these measures thoroughly and were disappointed by the meager returns.

Mitigation Strategy #1: Increase jet ski distance from shore - A growing number of US jurisdictions prohibit jet skis from operating closer to any shoreline than 500 feet. But such ordinances only slightly reduce the noise burden on beachgoers. As you can see from this graph from Drowning In Noise, even with perfect compliance - which is by no means assured - a 500-foot rule reduces the noise costs to US beachgoers from jet skis by only about a quarter, from around $900 million a year (US dollars, year-2000 prices) to $660 million.

Viewgraph #3: Because sound carries well across water, regulations to require jet skis to maintain a minimum distance from shore are ineffectual. Jet ski noise costs shown here and in next chart are aggregate for the U.S.

The reason is simple: sound carries very well across water. To halve the perceived loudness of a noise source on the water, it must be moved four times further away. As a result, even a quarter-mile distance rule dispels only about half of the noise impacts.

Mitigation Strategy #2: Reduce engine noise - Like any pollutant, noise is best abated at the source. Making jet skis quieter would please all parties. That is why the jet ski manufacturers associations here and in the US repeatedly hype purported reductions in noise from newer models. For example, a 1997 press release from Bombardier Corp. heralded a "D-Sea-Bel Noise Reduction System" that would reduce sound pressure levels by half on all new SEA-DOO watercraft and jet boats beginning in model-year 1999.(6)

(6)"Today, Bombardier Marine Products Division set the course for the future of the personal watercraft industry by announcing the installation of the D-Sea-Bel Noise Reduction System in all models of SEA-DOO watercraft and jet boats by model-year 1999… With the D-Sea-Bel sound reduction system, the GTX-RF1 has a full 50 percent lower Sound Pressure Level than the 1997 GTX model with the 800 Series Rotax marine engine…" Press release, "Bombardier Announces Quieter Watercraft for 1999," Sept. 16, 1997, Bombardier Motor Corporation of America, Melbourne, FL.

Viewgraph #4: The impressive-sounding 50% reduction in "sound pressure levels" for Bombardier's SEA-DOO machines amounts to just a 3-dBA reduction in noise, which in turn reduces aggregate noise costs only 22%.

Sadly, this claim and others like it are mostly hollow. Neither Bombardier nor other manufacturers making similar claims have presented one iota of hard evidence to support them. I've written to the manufacturers and trade associations many times seeking technical data or other solid evidence. All I've ever received, when I've heard back at all, is glossy brochures.(7) So while the jet ski industry boasts that "independent, scientifically conducted testing" shows jet skis "to be among the quietest motorized vessels in operation,"(8) they require that these assertions be taken on faith.

But the real problem lies deeper: the reductions in noise emissions are meager, by the industry's own claims. The impressive-sounding 50% reduction in "sound pressure levels" for Bombardier's SEA-DOO machines amounts to just a 3 decibel reduction in noise. As the chart on p. 5 shows, making jet skis 3 decibels quieter reduces their aggregate noise costs by just 22%. This barely dents the jet ski noise problem, especially with bigger, higher-horsepower machines designed to carry several people offsetting any technical refinements that reduce noise per unit of engine power.

Bans - Which leaves bans. Of course, any talk of banning jet skis is invariably equated with "locking out" large numbers of people from using our waters. This seems excessive, since it's the jet skis that would be locked out, not the people. Or we're told that discriminating against one form of recreation will open the door to banning other boating activities; yet making meaningful distinctions is an essential activity of human society, and regulation of conduct impacting others is central to effective government.

Why Jet Ski Noise Is Unlike That From Conventional Motorboats: Industry lobbyists like Mr Currie insist that jet skis are no more noisome than other motorized watercraft.(9) A visit to any lake or bay where jet skis are being used will instantly dispel this notion. There are three reasons why.

(7)My letter to the Manager for Communications and Public Relations of Bombardier Recreational Products, dated Oct. 1, 2002, seeking technical data on Sea-Doo noise emissions, has gone unanswered.
(8)Monita Fontaine, executive director of the Personal Watercraft Industry Association, wrote in response to my May 28, 2002 inquiry only that "[jet skis are] among the quietest motorized vessels in operation."
(9)From p. 4 of the transcript of Mr Currie's appearance on June 11, 2002: "[Personal watercraft] are not inherently noisy. Personal watercraft are demonstrably among the quietest powerboats in the water …" From a letter dated Sept. 20, 2001from Marc R. Lacroix, Manager, Communications and Public Relations, Bombardier Recreational Products, to Mr C. Desjardins of Saint-Adolphe d'Howard, "A number of recent studies have proven that our personal watercraft emit far less noise and are much quieter than many other motorized recreational watercraft…" See also the May 28, 2002 letter from PWIA executive director Monita Fontaine quoted in an earlier footnote.

1. Jet skis are designed and used differently from motorboats, in ways that make them likely to be more annoying to more people. Jet skis are marketed and used for one purpose only - the thrill of speed. They are seldom driven at less than full throttle. Motorboaters as often as not head for a fishing or picnicking spot, then douse the engine and drop anchor. But jet skiers seldom have a destination in mind. Rather, they use their vehicles continuously as a recreational end in themselves. Moreover, with their small size and shallow draft, jet skis can and do venture closer to shore than motorboats operated at similar speeds.

Mitigation? Good Luck!

1 Distance Limits?
Sound carries; and not all comply.

2 Quieter New Models?
Higher hp cancels tech fixes.

3 Ban
Only sure-fire solution.
Viewgraph #5: The only assured way to protect cottagers and other lake users from jet ski noise is to allow them to ban the machines outright.

2. Unlike most motorboats, jet skis continually leave the water. This magnifies the noise in two ways. First, without the muffling effect of the water, the engine's exhaust is much louder. Second, each time the jet ski re-enters the water, it smacks the surface with an explosive "whomp" - sometimes with a series of them.

Leaving the water is central to the "fun" of jet skiing. The ultimate thrill seems to be to take to the air and bounce off the water repeatedly. This is easily accomplished - by jumping the wake from a passing motorboat or another jet ski (often in a duet of mutual wake creation and riding), or from one's own machine. But jet skis don't have to deliberately jump to leave the water. Because of the short hull, a jet ski ridden fast on even a slightly choppy surface will lift out of the water naturally, eliminating the water's sound-muffling action and creating the jarring whomp.

We can now see the answer to the question, Is it the craft or the operator? With jet skis, it's both: by the operator's intent and the vehicle's design, jet skis wind up "out of the water" a great deal of the time - enough, we estimated in DIN, to add 8 to 10 decibels to the average noise output of a hypothetical jet ski that never leaves the water.

3. The final characteristic that distinguishes jet skis from motorboats is their rapid maneuvering - "rad" moves - and frequent speed changes. In addition to jumping wakes, jet skis are designed and marketed for weaving, sharp turning, spinning doughnuts and generally erratic throttle use.

In all these maneuvers, the jet impeller has no consistent water "throughput," and, thus, no consistent load on the engine. Consequently, the engine's speed rises and falls through a wide range from moment to moment with each maneuver. The result is a penetrating whining sound, rising and falling rapidly in pitch like a dentist's drill and forcing the attention of anyone within earshot.

Jet Ski Noise Is Different

[Note: each +10 dB = 2x louder]

1 Full throttle / All the time

2 Leaving the water (adds 8-10 dB)

3 "Rad" moves (adds 12-15 dB)

2+3 -> An 80 dB jet ski feels 4-6x louder than an 80 dB outboard.
(The jet ski feels 15-30x closer.)
Viewgraph #6: The combination of constant wake-jumping and "radical maneuvers" makes jet skis sound 4 to 6 times as loud as other watercraft with the same in-water measured sound levels.

Indeed, the variable nature of the noise helps explain why jet skis are so bothersome. A tenet of psycho-acoustics is that varying noise is more disturbing than a steady noise. The reason is that varying noise demands the hearer's involuntary continuous attention. It can't be tuned out.

In Drowning In Noise we estimated this effect - the extra annoyance of jet skis' whirring and whomping noises, varying from moment to moment - as having the same annoyance effect as an additional 12 to 15 decibels in noise level. You won't see it on a noise-meter, but the impact on the human ear and brain is real just the same. Combining it with the measurable 8-10 dBA higher noise level from leaving the water, we see that a jet ski feels 20 to 25 decibels noisier than an outboard vessel with the same "in-water" noise level.

Translated from decibels into the subjective realm of loudness, a jet ski feels and sounds 4 to 6 times louder than "equivalent" motorboats. Or, in more graphic terms, a jet ski operating at the same distance from shore as an equal-decibel motorboat (measured with both "in the water") feels and sounds 15 to 30 times closer.

So to those who object to "singling out" jet skis for regulatory treatment, I would say that it is the builders and purveyors of jet skis who have singled themselves out, by virtue of an inherently noisy mechanical design and a marketing strategy to match. With few exceptions, jet ski noise levels are higher than those of other boats, and the "quality" of the noise is far more grating and obtrusive.

This devastating combination of quantity and quality cries out for proactive governance. Vesting communities with "home rule" powers, as Bill S-10 would do, is an excellent place to start.

Appendix A: Conservatism of Jet Ski Noise Level Specified in Drowning In Noise

I freely acknowledge being an advocate of quiet waters. But first and foremost, my Drowning In Noise co-author, Dr Howard Shaw, and I are scientists. (Our qualifications are given on the final page of our monograph.) The ethos of science is to let the numbers speak for themselves. Dr Shaw and I have done just that throughout our professional careers.

So I was surprised that Mr Currie, whose scientific credentials are not stated, chose to characterize Drowning In Noise as "not scientifically rigorous" during the hearing on Bill S-26 last year.(10) The only particulars he offered were that "the data chosen are selective and was [sic] based on an out?of?date sound measurement using all types of personal watercraft, of which few are sold or in use."

(10) See transcript of evidence dated June 11, 2002, p. 5.

Viewgraph #7: "Normalizing" noise levels to a common distance (20 ft) shows that the noise level assumed in Drowning in Noise is less than those touted by both the jet ski lobby and Bombadier Corp. See footnote 12.

I gather Mr. Currie was taking issue with the value of 80 decibels at a distance of 20 feet that Dr Shaw and I chose for the mean (average) jet ski noise level. Presumably he believed it was too high. Yet not only is our 80-decibel figure fully supported by an exhaustive set of noise measurements made under carefully controlled field conditions by a respected limnologist;(11) but as well, our "reference" noise level for jet skis is less than the noise level reported to the Senate last year by Mr Currie, and less than what Bombardier claims for its vaunted Sea-Doo model with noise-abatement technology.(12)

If the jet ski lobbyists have objective noise-level data collected by qualified, neutral observers, they should present it. Let us be clear that based on the skeletal data they have offered so far, the noise levels presented in Drowning In Noise err on the side of conservatism, i.e., they understate the noise emissions of jet skis currently in use.

Appendix B: Charles Komanoff, Brief Professional Biography

Charles Komanoff is director of the consulting firm Komanoff Energy Associates, a founding trustee of the Tri-State Transportation Campaign, and leader of the New York City pedestrian rights organization Right Of Way.

His work combines expertise in policy analysis, a flair for expressing numerical and economic data in concrete terms, and a passion for progressive social change. Komanoff first gained renown for deconstructing the failed economics of nuclear power, as author-researcher (Power Plant Cost Escalation) and expert witness for state and local governments across the United States.

He is active in the pedestrian and cyclist movement in New York City as a founder of Right Of Way, as "re-founder" of Transportation Alternatives, and as editor and author of the Bicycle Blueprint and Killed By Automobile. His new web site, www.bridgetolls.org, is campaigning to toll car traffic on New York City's "free" East River bridges to raise revenue for public transit.

Komanoff graduated with honors from Harvard College with a B.A. in Applied Mathematics. He lives in New York City with his wife Judy Levine and their two sons.

Komanoff Energy Associates
636 Broadway / New York NY 10012 / USA
212 260-5237 / kea@igc.org

(11) See Drowning in Noise, sidebar, "Jet Ski Noise Levels," on p. 64.
(12) Each time the distance between source and hearer is doubled across open water, the loudness of the sound to that hearer declines by approximately 5 decibels. Accordingly, Mr. Currie's statement to the Committee on Transport and Communications, that at a distance of 75 feet jet skis produce "full-throttle sound levels...of less than 78 dBA" (transcript of evidence dated June 11, 2002, p. 4), is tantamount to saying that at a distance of 20 feet jet skis produce sound levels up to 87.5 dBA. Similarly, a page downloaded from the www.sea-doo.com Web site in October 2001 gave a decibel level of 71.37 for a Sea-Doo RX DI "tested on water at full throttle at a distance of 100 feet from a stationary landmark." This sound level equates to 83 dBA at the reference distance of 20 feet used inDrowning in Noise

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