When you hear that helicopter noise is not different from any other city noise, think of the two people who were killed when Senator Robert Kennedy's funeral train was passing through Elizabeth, New Jersey—killed because the noise from the low-flying Secret Service and news media helicopters masked out the warning horn blasts of the approaching train that hit them.
Someday, highway noise will be discovered to be a significant cause of traffic accidents.
Churches are no more a sanctuary from noise assault than the secular environment. Noise intrusion has no respect even for death. Mourners find that the sanctity of the graveside funeral service is violated by construction noise and lawn mowers.
The minister of one local church near a USAF base in England arranged for a "hot line" between the base and his church: a phonecall silences the jets for weddings, funerals, and other special services. Churches near commercial airports are not as fortunate. They must either build soundproofed structures or endure interrupted services. In ruling against the Town of Hempstead's attempt to control jet noise over its land area, the courts acknowledged that church services were interrupted, but accepted this as the price of progress.