Representation by Public Health England (Public Health England)
- Date submitted
- 19 March 2021
- Submitted by
- Other statutory consultees
Thank you for your consultation regarding the above development. Public Health England (PHE) has previously been consulted at the Scoping Stage of this development on the 16th July 2020. PHE was not consulted at the Section 42 stage of this application process. Therefore, we can confirm that we have registered an interest on the Planning Inspectorate Website. In addition, we have the following comments in light of not commenting at the Section 42 stage: Environmental and Public Health In the Main Statement Chapter 7 entitled Land use and socio-economic effects (Section 7.238), the Applicant has stated that a decommissioned cruise ship will be used to accommodate construction workers for 2 years located in Tilbury. The Environmental Statement (ES) does not state if the cruise ship will be powered by on shore connections or from its own engines. This is potentially a source of emissions to air and therefore we recommend clarification be sought on if and what impacts this cruise liner may have on local air quality. Human Health and Wellbeing This section of PHE’s response, identifies the wider determinants of health and wellbeing we expect the ES to address and to demonstrate whether they are likely to give rise to significant effects. PHE has focused its approach on scoping determinants of health and wellbeing under four themes, which have been derived from an analysis of the wider determinants of health mentioned in the National Policy Statements. The four themes are: • Access • Traffic and Transport • Socioeconomic • Land Use Having considered the submitted ES PHE wish to make the following specific comments and recommendations: Methodology Monitoring The ES states that monitoring measures may be required, for example the update of local accommodation by construction workers. It is acknowledged that the need for and type of monitoring will still evolve but a rational, robust and transparent monitoring strategy is required within the ES. The monitoring strategy will be a key asset to engagement with the local community and local stakeholders, and on which to base future decisions. The scale and nature of the scheme is such that local communities will be sensitive to construction and operational impacts, where the planned mitigation may not be successful or there may be unforeseen impacts that will need to be addressed. The World Health Organisation (WHO) recommend the final stage of a health impact assessment involves monitoring to see if the predictions made during the appraisal were accurate, and to see if the health, or health promoting behaviours, of the community have changed. Recommendations PHE expects an assessment to include consideration of the need for monitoring, particularly in relation to community impact. The ES should clearly state the principles on which the monitoring strategy has been established, including monitoring in response to unforeseen impacts or effects. It may be appropriate to undertake monitoring where: • Critical assumptions have been made in the absence of supporting evidence or data • There is uncertainty about whether significant negative effects are likely to occur, and it would be appropriate to include planned monitoring measures to track their presence, scale and nature. • There is uncertainty about the potential success of mitigation measures • It is necessary to track the nature of the impact or effect and provide useful and timely feedback that would allow action to be taken should negative effects occur The monitoring strategy could be published as a separate document to ensure a transparent, co-ordinated and consistent approach. The monitoring strategy to set out: • Monitoring methodologies • Data sources • Assessment methods • Publication methodology • Reporting frequency • Temporal and geographic scope The monitoring could include: • Noise complaints • Feedback / complaints from local residents / communities • Impact from demand on local services • Impact from demand on local housing provision The monitoring strategy should form part of the embedded mitigation measures within the Development Consent Order and form part of the reporting mechanisms to local communities and local agencies. The monitoring strategy should be agreed with the local authority Director of Public Health, Clinical Commissioning Group (CCG) and Integrated Care System (ICS). Safe, suitable and stable homes The report identifies the requirement for permanent land take in order to achieve the construction and operational phase. Loss of homes will attract compensation, with existing schemes directed to property occupiers, but the compensation code does not clearly identify the rights for tenants. The compensation code also identifies potential rights to compensation for noise and disturbance. Compensation code is not clear on the rights to compensation for tenants of domestic property, who can often be considered vulnerable and not have the capability or capacity to access the compensation procedure. The ES identifies that a proportion of the accommodation demand required by non-home-based workers will be met from the provision of a caravan site, cruise liner and an element of local accommodation. No details are provided for the caravan site facilities or the standards to which the liner will operate. The ES proposes to establish an accommodation hub to link workers to local housing provision. The safety and suitability of this accommodation may be unregulated creating risk to the safety and welfare of both the non-home-based workers and occupiers. Recommendation The ES identifies the potential for occupiers of housing to rent space within their accommodation outside of the formal private rented sector to non-home-based workers. The safety and suitability of this accommodation will largely be unregulated creating risk to the safety and welfare of both the non-home-based workers and occupiers. The ES should address how this may be mitigated and may form part of the Construction Workforce Accommodation Strategy. The ES does not provide any details regarding the standards of facilities, management systems or location for the caravan site, leading to the potential for poor sanitation and safety concerns such as fire. Information regarding the services, facilities, location and management of the caravan site should be established. Detailed plans can be established later. The ES does not address health risks associated with the operation of the cruise liner. The ES should confirm that it will comply with any requirements under ship sanitation regulations and have in place infection prevention and control measures for outbreaks of infectious diseases. Recreational land and open space The ES identifies the areas of recreational and open space required for the DCO and a commitment to improve the quality and accessibility of the remaining publicly accessible land. The impact of the DCO has implications for the changes to the perceptual qualities (including tranquillity) of a recreational resource as a direct result of the DCO Project (as a result of increased noise levels and the significant visual impacts). The likely impact of changes to noise levels on the recreational amenity of these individual resources as a result of the DCO Project cannot be fully understood until the impact on tranquillity has been assessed. The ES identifies the temporary and permanent closure of several Public Rights of Way (PRoW) as a result of the construction and operational phases. This will result in the loss of access to open space in addition to the impacts from loss of tranquillity and visual impacts during the course of the construction phase. Although mitigation is in place for the operation phase, the construction phase will have a significant impact on the local community. This will have a significant impact during the short term and the ES does not offer any alternative options or mitigation. Recommendations Additional details are required in relation to an assessment of noise impacts on tranquillity for users of the public open space. The ES should consider the phasing of mitigation measures to minimise the effects from visual impacts and impact on tranquillity. Effective phasing could create accessible better quality provision to green and blue space as set out in the landscape strategy. In addition, early planting of mature natural screening as proposed in the landscape strategy will assist in minimising visual impacts. Greater clarity on the early phasing of these mitigation measures is required and greater detail on the likely visual appearance of the scheme from the PRoW. Healthy food environment PHE welcomes the intention to provide healthy food options at catering outlets for visitors and staff. The staff accommodation strategy outlines the general provision for the flats, which will share living and kitchen facilities. The kitchen facilities should have adequate space and facilities to enable the production of fresh and healthy food options. Being able to store, prepare and cook a range of foods, including perishable food (such as fruit, vegetables and other staples including potatoes, tubers etc) enables people to have a healthy, balanced diet, which plays a significant role in avoiding a large number of preventable illnesses. Recommendation We recommend aligning the requirements relating to kitchen and dining facilities with those that enable people to meet their needs for a healthy, balanced and affordable diet. This might include storage space for food, including a fridge freezer, a cooker (or space for it), sockets for cooking appliances, and surfaces for food preparation. Please do not hesitate to contact us if you have any questions or concerns.