Representation by UK Health Security Agency (UK Health Security Agency)
- Date submitted
- 31 August 2022
- 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 This section of the response outlines matters raised pertaining to environmental public health impacts that may arise from the scheme. We are satisfied that the promoter will discuss all requirements for air quality and dust monitoring with the local authority and that a dust management plan will be prepared in due course. We would be grateful for clarification on the following point: • We note that no justifications were offered as to why adjustment factors applied to the predicted road NOx concentrations were also applied to the predicted road PM10 concentrations. Human Health and Wellbeing This section of OHIDs response, identifies the wider determinants of health and wellbeing we expect the Environmental Statement (ES) to address, to demonstrate whether they are likely to give rise to significant effects. Public Health England (a predecessor agency of the UKHSA) 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, OHID wish to make the following specific comments and recommendations. Methodology - Determination of significant effects The structure of Chapter 13 Population and human Health prevents a clear understanding of the findings of the assessment. The Chapter follows the EIA assessment process, rather than considering each of the 8 duelling schemes in turn supported by a route wide assessment. This leads to excessive repetition and prevents the assessment methodology to be followed easily and clearly for each community. It is noted that Chapter 13 is drafted with reference to LA112 and as such no assessment of significance is provided for human health. This does not conform to the requirements of the EIA Regulations and as such an assessment of significance will be required to form part of the ES. This follows recent PINS consideration of this aspect within the Secretary of State’s (SoS) Scoping opinion for the National Highways M60/M62/M66 Simister Island scheme. Regulation 18 4(b) requires an ES to 'include the information reasonably required for reaching a reasoned conclusion on the significant effects of the development on the environment, taking into account current knowledge and methods of assessment’. In addition, Schedule 4 (5) requires a description of the likely significant effects of the development on the environment resulting from, inter alia: (d)the risks to human health, cultural heritage or the environment (for example due to accidents or disasters); The ES reports multiple conclusions of negative health effects, but no conclusion of their level of significance. This prevents an assessment of the adequacy of the proposed mitigation, particularly in relation to vulnerable populations, and does not aid decision making. Recommendation The ES must provide an assessment of significance for those health determinants scoped into the population and human health chapter. The population and human health assessment should draw upon the findings from other relevant chapters, including air quality and noise. As there is not a defined approach to the assessment of significance for population and human health, it is strongly advised that any proposed approach is agreed with OHID/UKHSA and the local Directors of Public Health. The guidance issued by the International Association of Impact Assessment (IAIA) could be used as a basis for the assessment of significance. Temple Sowerby to Appleby Paragraph 13.10.50 reports that Kirkby Thore Primary School sports pitch will be temporarily required to facilitate the diversion of a utility and will be returned to its existing use upon completion of the diversion works. The temporary land take equates to approximately 0.15ha which is approximately 35% of the outdoor space available to the School. This represents a major adverse temporary impact on the very high sensitivity receptor, which will be a very large adverse significant effect. The population and human health chapter does not report any proposed mitigation, however, the EqIA reports that: ‘No alternative provisions will be provided during construction of the utility diversion. Works will be planned to be outwith the school opening hours. The playing field will be reinstated to its existing condition upon completion of the works. The replacement lines will be higher than the current provision, thus increasing the vertical clearance above the school playing field.’ Recommendation The ES should assess the option to complete works outside of term time to minimise disruption to the school activities and use of the outdoor space. If this is not possible this should be justified and the ES should report on whether the outside space can be utilised during school opening times. 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.