Representation by Public Health England (Public Health England)
- Date submitted
- 30 September 2020
- Submitted by
- Members of the public/businesses
Thank you for your consultation regarding the above development. Public Health England (PHE) welcomes the opportunity to comment on your proposals at this stage of the project. Our records show that we have previously responded to the following enquiries / consultations regarding this proposal: PHE has considered the submitted documentation and we can confirm that we have registered an interest on the Planning Inspectorate Website and have commented on the following matters. Air Quality The potential for minor air quality impacts on a number of human receptors has been highlighted in the Environmental Statement (ES) of different components of the project, as well as during assessment of wider project elements. This includes particulate matter emitted during construction and nitrogen dioxide (NO2) associated with road traffic activities. The supplied methodology indicates that the final conclusion on significance rests with the expert’s professional judgement. However, where increases (albeit small) in concentrations of air pollutants have been identified at receptors locations, the level of detail justifying why no further mitigation is required is very limited. Further detail would be useful. The modelling method for traffic (roadside) also assumes that emissions will decrease in proportion to the legislated requirement. The applicant would benefit from undertaking appropriate sensitivity analysis to assess the effects of model assumptions, particularly at the discrete sensitive receptors where increases in air quality have been predicted. As stated in our section 42 consultation response, reducing public exposures to non-threshold pollutants (such as particulate matter and NO2) below air quality standards has potential public health benefits. We support approaches which minimise or mitigate public exposure to non-threshold air pollutants, address inequalities (in exposure), and maximise co-benefits (such as physical exercise) and encourage their consideration during development design, environmental and health impact assessment, and development consent It is also not always clear whether activities or processes which are subject to alternative regulatory assessments have been included within the cumulative assessments. Human Health and Wellbeing At Section 42/Scoping stage, PHE provided the following response: “[The ES] must ensure that the chapter relevant to human health is sufficiently comprehensive and not significantly reliant on cross referencing to multiple other chapters. “The ES should clearly identify the vulnerable populations that are being scoped into or out of any assessment and provide clear justification. The assessments and findings of the ES and any EqIA should be cross referenced between the two documents, particularly to ensure the comprehensive assessment of potential impacts for health and inequalities and where resulting mitigation measures are mutually supportive. “It is important that mental health and wellbeing is included within the HIA or population and human health assessment within the EIA. The previous third stage consultation of the draft PEIR included references to the assessment of effects on mental health of the local community and workforce. There should be parity between mental and physical health in the HIA, including suicide.” The applicant has not addressed PHE’s above recommendation as discussed in more detail below. The Volume 2 Chapter 28 Human Health and Wellbeing submitted as part of the DCO application heavily references and relies mainly on assessments of socioeconomic and environmental conditions (e.g., air quality, noise & vibration, traffic) found elsewhere within the ES. While these undoubtedly have an impact on health and wellbeing, the chapter only presents a cursory review of the proposal’s effects on wider health and wellbeing, which include stress, anxiety and quality of life, and did not address mental health or health inequalities as recommended by PHE at the Section 42 stage of this application. Based on lack of information presented, the assessment in this regard needs improvement. Furthermore, Chapter 28 Human Health and Wellbeing did not sufficiently cross-reference the Equality Statement also submitted as part of the DCO application. The Equality Statement presented differential effects for vulnerable populations for five broad categories, but this did not include wider health and wellbeing and health inequalities, while Chapter 28 Human Health and Wellbeing took a cursory view of wider health and health inequalities but did not define vulnerable populations as recommended. Additionally, by defining all groups within the population as high sensitivity, there is a risk of missing differential impacts and effects across groups. Therefore, the assessment of potential impacts of the proposed development on population health and inequalities across the life-course and within vulnerable groups, is unclear. Consequently, we are unable to evaluate whether the proposed mitigation measures are appropriate. The DMRB standards for highways (LA112) was updated in January 2020, and therefore supersedes the methodology used within this ES. The new DMRB contains a mitigation hierarchy for dealing with issues affecting walkers, cyclists and horse riders. Radiation Please see below some specific comments in relation to the radiation aspects of the Sizewell C Project Volume 2 Chapter 25 Radiological Considerations Para 25.3.40 Fetal doses related to the fishing family are also considered in the Human Radiological Impact Assessment but are not discussed here Para 25.6.21 It needs to be clear from which site and discharge route (aqueous, gaseous or both) the doses relate to. Para 25.6.47 states that “This is significantly below (0.4% of) the amount of radiation exposure from natural sources in the UK (2700 µSv yr-1).” The dose of 2700 µSv yr-1 includes medical radiation so this statement is not correct. Volume 2 Chapter 25 Radiological Considerations Appendices 25A-25C Appendix 25A: Construction Sediment Radiological Impact Assessment From Dredging Operations Para 1.1.12 states that “In context, the limit of the effective dose for any member of the public (10?Sv/y) is <0.4% the average annual background radiation of 2.7mSv/y (Public Health England, 2011).” This dose is not the background dose as it includes the contribution from medical exposures. This dose is the average United Kingdom (UK) radiation dose. The reference should be Public Health England, 2016. Para 1.1.13 states that “In England, RSR is delivered by the Environment Agency on behalf of the Department of Energy and Climate Change (DECC).” This needs to be updated. Appendix 25B: D1 Human Radiological Impact Assessment Para 30 states that “The different modules within PC-CREAM 08 model the contribution of radioactive decay chain products (‘progeny’) in slightly different ways. The DORIS, FARMLAND and RESUS modules do not explicitly model progeny that reach equilibrium with the parent radionuclides within one year; rather, such progeny are considered to be present at the same activities as the parent. This time is reduced to three minutes in PLUME, which allows important-short-lived radionuclides to be modelled explicitly. The first progeny not reaching secular equilibrium with the parent radionuclide is modelled explicitly in FARMLAND, RESUS and PLUME. DORIS considers all radionuclides in the decay chain and progeny that are not in equilibrium with the immediate parent are modelled explicitly [Ref 29].” It would be more accurate to state that “The different modules within PC-CREAM 08 model the contribution of radioactive decay chain products (‘progeny’) in slightly different ways. For the FARMLAND and RESUS modules only the first progeny that is not in secular equilibrium over a period of one year is modelled explicitly. In PLUME the first progeny, even if it is short-lived, is modelled explicitly so its contribution to dose at short distances downwind can be determined. DORIS considers all radionuclides in the decay chain and progeny that are not in equilibrium with the immediate parent are modelled explicitly [Ref 29].” Table 2-4 Footnote 7 – the link to ref 26 does not work and is this the correct reference? Para 124 – this paragraph discusses skyshine but does not reach a conclusion about whether the conclusions of the sensitivity analysis should be applied. Para 215 states “This is insignificant when compared to the annual skin dose limit of 50,000 ?Sv/y/cm2 under the IRR17.” Would it not be more appropriate to refer to the skin dose limit given in EPR 2016 Schedule 23 Part 4 (1) Para 2 (a)? Section 8 discusses sensitivity analyses. The three specific assumptions and parameters analysed are: • Discharges - expected best performance discharges against proposed limits. • Habits Data - generic food ingestion rates against site-specific food ingestion rates. • Food Source – 100% locally sourced seafood against 50% locally sourced seafood. Given the importance of the marine food pathway, it would be expected that the some of the important parameters related to marine dispersion such as volumetric exchange rates would also be considered. Has this been done by the applicant? Please do not hesitate to contact us if you have any questions or concerns.