ROB, it is the p’sak of the Biur Halachah (the one I and Avi quoted) to asser.
He even has a tzad that according to some rishonim it could be d’Oraisa.
He concludes: ??? ??? ?????? ?? ????? ??”? ??? ????”? ??? ??? ????? ?”? ???? ?????? ?? ???? ????? ?????? ??? ???? ??? ???”? ??”? ????? ???? ???? ??? ???
Avi, the point of ????? ????? is that it attracts attention, so whether that issue to the noise or a different factor (being outdoors in public view) shouldn’t make a difference.