Representation by UK Health Security Agency (UK Health Security Agency)
- Date submitted
- 22 March 2024
- 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: Human Health and Wellbeing This section of the 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. OHID 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 ES OHID wish to make the following specific comments and recommendations. Demolition of Domestic Property It is noted that the ES utilises LA112 to consider the sensitivity of the community assets and private property. The approach within the ES considers the physical asset rather than the additional consideration of the vulnerability of the users or occupiers. The 32 residential properties subject to demolition are noted to be of medium sensitivity to change. This level of sensitivity is underestimated given the impact of forced relocation of the small community both in terms of land use and human health. The current ES assessment concludes a significant effect, so it is acknowledged that increasing sensitivity to high will not affect the final assessment conclusion. It does, however, assume that all residents are of equal vulnerability, where the only proposed mitigation is that of financial compensation. This approach does not consider the capability and capacity of the resident households to relocate and the potential loss of social networks and support mechanisms. The baseline data and equalities impact assessment establishes a higher level of resident population over 65 in the study area and as such the potential for vulnerable populations to be resident in the properties to be demolished. The ES identifies the sole mitigation to be compensation and comments this is outside of the impact assessment scope. DLUHC guidance (Guidance on Compulsory purchase process and The Crichel Down Rules) outlines other steps which should be considered to help those affected by a compulsory purchase order. Compulsory purchase proposals will inevitably lead to a period of uncertainty and anxiety for the owners and occupiers of the affected land. The guidance outlines additional support that should be offered to residents, but which are not identified within the assessment as potential mitigation measures. Recommendation Additional information is required to identify additional mitigation to be provided in support of households affected by compulsory purchase as outlined in Para 19 of DLUHC Guidance - Guidance on Compulsory purchase process and The Crichel Down Rules. Electromagnetic Fields It is noted that the current proposals do not appear to consider possible health impacts of Electric and Magnetic Fields (EMF). We request that the ES clarifies this and if necessary, the proposer should confirm either that the proposed development does not impact any receptors from potential sources of EMF; or ensure that an adequate assessment of the possible impacts is undertaken and included in the ES. 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.