Representation by Public Health England (Public Health England)
- Date submitted
- 28 October 2020
- Submitted by
- Other statutory consultees
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 and makes the following comments relevant to the assessment process and development itself: 1. The proposed Construction Environmental Action Plan is important to minimise public health impacts from the development; PHE requests that the plan is enacted and reviewed throughout the build. 2. The ES reflects a narrow approach to human health and continues to focus primarily on health protection issues, eg, air quality, noise and vibration, and flood risk. As such the ES presents limited information on local health priorities and effect of the scheme on these priorities, including on mental health and health inequalities. 3. The application does not appear to contain an Equality Statement, or to provide a specific definition of vulnerable groups within the general population that were included in the assessment. There is limited understanding of the differential effects of the scheme on these groups. 4. The ongoing monitoring of population and human health relates exclusively to health protection factors, that is, air quality, noise and vibration and flood risk. Ideally some level of monitoring to understand the effect of the development on the wider determinants of health for the local population would be valuable for local stakeholders. 5. We would expect that the PRoW Management Plan would have been submitted with the DCO application, however it was not included and instead the ES states it will be produced by the main contractor after the DCO is granted. We question whether this is appropriate. 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.