Representation by UK Health Security Agency (UK Health Security Agency)
- Date submitted
- 22 February 2023
- Submitted by
- Other statutory consultees
Thank you for your consultation regarding the above development. The UK Health Security Agency (UKHSA) welcomes the opportunity to comment on your proposals at this stage of the project. Please note that we request views from the Office for Health Improvement and Disparities (OHID) and the response provided is sent on behalf of both UKHSA and OHID. We can confirm that: Environmental Public Health – Air Quality Reducing public exposures to non-threshold pollutants (such as particulate matter and nitrogen dioxide) 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. The applicant has included a methodology to determine significance of effects, noting that all human health receptors are assessed to be high sensitivity. When assessing the magnitude of change, the applicant has only considered receptors where the Air Quality Standard (AQS) has been exceeded and not where there is a deterioration or betterment in air quality, but the AQS has not been exceeded. Noting that the pollutants assessed by the applicant (particulate matter and nitrogen dioxide) are non-threshold, UKHSA would welcome further assessment and clear presentation on the summary of impacts on human receptors where there is a change in air quality, where the AQS is not exceeded. To assess the health impacts from exposure to PM2.5, the applicant has applied the UK AQS of 25µg/m3 as an annual mean to their assessment. UKHSA note that the World Health Organization (WHO) have developed short- and long-term air quality guidelines, including interim targets for PM2.5, considering new evidence of effects on mortality occurring at concentrations below 10µg/m3, which are lower than UK AQS. Within the UK’s Environmental Improvement Plan , there is a legal target to require a maximum annual mean concentration of 10µg/m3 by 2040, with a new interim target of 12µg/m3 by the end of 2028. UKHSA note that this interim target is within the construction period of the proposed development and recommend that further assessment is undertaken to demonstrate impact on identified receptors against these targets, as well as considering short-term air quality guidelines presented by the WHO. Within the air quality assessment, the applicant has applied a magnitude of change to NO2 and PM10 of 10% for large, 5% for medium and 1% for small. However, when considering PM2.5 the applicant has not provided an assessment (or justification for not including) for the magnitude of change for PM2.5 and UKHSA recommends that this is considered and included within the air quality assessment. With regards to particulate monitoring during the construction phase, the applicant notes that the appointed on-site contractors shall determine dust and particulate monitoring on a risk-based approach. No further information or commitment is provided on a detailed monitoring strategy including when monitoring will be undertaken, how the results will be interpreted or what this will mean in relation to mitigation measures for activity when results exceed UK AQS. UKHSA recommends that further clarity is provided on this, including rationale for when monitoring will be deployed, what monitoring will entail, what will be classified as a significant impact during monitoring and what actions will be taken (including complaint monitoring and response). Furthermore, no detail is identified on any proposed NO2 monitoring and UKHSA recommends further justification is provided on this, noting that exceedances of the AQS are presented for this pollutant. The applicant reports that impacts from Non-Road Mobile Machinery (NRMM) will be acceptable, given that these will be operating for short periods, where air quality concentrations are already low. UKHSA recommends that further clarification is provided on this point, including the number and operation of machinery, noting that the construction works are to occur for a 5-year period and considering potential health implications on non-threshold pollutants. The impacts of NRMM should be better assessed by the applicant and any construction monitoring requirements appropriately detailed. Electromagnetic Fields The applicant should assess the potential public health impact of EMFs arising from any electrical equipment associated with the development. Alternatively, a statement should be provide explaining why EMFs can be scoped out. For more information on how to carry out the assessment, please see the UKHSA scoping response reference for further information. We can confirm that we have registered an interest on the Planning Inspectorate Website. Please do not hesitate to contact us if you have any questions or concerns.