Representation by UK Health Security Agency (UK Health Security Agency)
- Date submitted
- 12 July 2024
- Submitted by
- Members of the public/businesses
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 details UKHSA’s comments in relation to the environmental public health aspects of the proposed scheme. We make the following observations: • The Promoter’s assertion that the scheme would not cause significant air quality (AQ) impacts is mainly premised that there will be no predicted exceedances of nitrogen dioxide (NO2) at human health receptors in the Opening Year. The Promoter’s assessment predicts improvements in local air quality from preferential use of the bypass, however, there is also predicted a deterioration of local air quality at selected human health receptors in the Do Something (DS) scenario (Opening Year of 2028). • With regards to particulate matter, PM2.5, the Promoter effectively scopes PM2.5 out for detailed assessment concluding that with reference to their PM10 modelling that PM2.5 concentrations will not cause an exceedance of the annual mean National Air Quality Objective (of 20 µg/m3). • Furthermore, the Promoter predicts that the Scheme will not impact the achievement of the PM2.5 annual average target concentration of 10 µg/m3 by 2040, based on the premise that PM2.5 concentrations from changes in road traffic are very small and are mainly influenced by existing background concentrations which are currently below this future target. This conclusion is drawn without a full quantitative assessment and discounts the interim annual mean target of 12 µg/m3 by 2028 (with reference to the Environmental Targets (Fine Particulate Matter) (England) Regulations 2023). • We maintain the position stated in our Scoping and Public Consultation responses with regards to supporting approaches which minimise and mitigate exposures to non-threshold airborne pollutants (such as particulate matter and nitrogen dioxide) and encourage their consideration during development design, environmental and health impact assessments, and development consent. Human Health and Wellbeing - OHID 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. 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 consultation documents, OHID wish to make the following comments and recommendations. Vulnerable populations Chapter 12 Population and Human Health utilises both DMRB LA112 and IEMA guidance for Determining Significance for Human Health in Environmental Impact Assessment. The Chapter does not adequately identify local vulnerable populations and report on potential effects on these groups in addition to the general population. Some groups of individuals may be particularly vulnerable to changes in biophysical and socio-economic factors (adversely or beneficially) whereby they could experience differential or disproportionate effects when compared to the general population. While the average local health circumstance across a defined population may be considered good, there may be groups of individuals within that defined population who are particularly sensitive and could experience disproportionate or differential effects. On this basis the IEMA guidance for Determining Significance for Human Health in Environmental Impact Assessment identifies it may be appropriate to consider relevant sub-populations, i.e., groups of more sensitive individuals. The equalities impact assessment identifies two local gypsy, Roma and traveller communities (Tolney Lane and Bridge House Farm), which are to be considered vulnerable populations, but have not been included within the population and human health chapter. The population and human health chapter should be revised and report any differential or disproportionate effects on vulnerable populations, when compared to the general population. Suicide Prevention There is a privately run mental health facility at the western end of the scheme (Farndon Unit), specialising with women with mental health or learning difficulties. The report does not address potential suicide risk, despite the local concerns over suicide rates in Newark and Sherwood - Committee report template (with guidance) (nottinghamshire.gov.uk) and Suicide prevention (2023) - Nottinghamshire Insight The environmental statement does not consider the potential for increased risk of suicide or attempted suicide posed by the new highway design, including temporary or permanent bridge structures. Suicide risks should be addressed in accordance with CD 353, Design criteria for footbridges (Note to Para 2.4) and National Highways Suicide prevention strategy (2022) Further assessment is required in relation to risks from suicide and the existing or additional mitigation to be delivered by the scheme. National Highways have previously created Suicide Prevent Strategy Reports, which should also be generated and included within the ES for this scheme. The suicide prevention strategy report and supporting assessments, alongside any proposed additional mitigation measures should be agreed with OHID, the local Director of Public Health and the local Real Time Surveillance Working Group. 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.