Representation by UK Health Security Agency (UK Health Security Agency)
- Date submitted
- 23 June 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. This response should be read in conjunction with our responses to previous consultation stages: Non-Statutory Pre-Consultation: 31 August 2018 Request for Scoping Opinion: 29 April 2019 First Section 42 Stage: 16 December 2019 Additional Section 42 Stage: 01 April 2022 Environmental Hazards We have assessed the submitted documentation and wish to make the following comments. Our response focuses on the key areas of omissions from the information provided in the consultation material. Air Quality & Population Impacts The applicant has undertaken a quantitative assessment of the effects of population health outcomes associated with changes in air pollution concentrations resulting from operational traffic, both on-airport and aircraft emissions. While the methodology used to assess long-term impacts is clearly set out, we recommend the applicant justifies the data and methodology used in prediction of the short-term impacts, including selection of short-term or long-term coefficients, for example, 1.008 used for PM10 attributable respiratory and cardiovascular hospital admissions is the correct short-term value. We expect use of the most up to date coefficient, for example a coefficient of 1.06 for PM2.5 attributable mortality has since been updated to 1.08 (95% Cl: 1.06, 1.09) per 10 µg/m3 annual average PM2.5. The applicant should also set out how they have converted the percentage variation (as set out by COMEAP here) to a correlation coefficient. The applicant has determined the significance of potential air quality impacts through comparison with the current Air Quality Standards. The air quality assessment has predicted slight adverse impacts at two receptor locations for annual mean NO2 concentrations (Phase 2a and Phase 2b), and the applicant has concluded that this impact is not significant, as there is predicted to be sufficient headroom below the AQS. Evidence suggests that health effects can still occur below limit values for air pollutants under regulation. Our position is that pollutants associated with road traffic or combustion, particularly particulate matter and oxides of nitrogen are non-threshold; i.e., an exposed population is likely to be subject to potential harm at any level and that reducing public exposures of non-threshold pollutants (such as particulate matter and nitrogen dioxide) below air quality standards will have potential public health benefits. We support approaches which minimise or mitigate public exposure to non-threshold air pollutants, address inequalities (in exposure), maximise co-benefits (such as physical exercise). We encourage their consideration during development design, environmental and health impact assessment, and development consent. Recommendation The applicant should review their assessment of the population health impacts using the appropriate coefficients for both short-term and long-term quantitative assessments of health outcomes, making clear the assumptions and methodology used. 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. OHID has focused its approach on the 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: Noise Compensation Scheme and Support The Report identifies the requirement for compensation or noise insulation grants, with existing schemes directed to property owners. Tenants of the private rented sector require landlord approval for noise insulation works. The preliminary environmental information report identified the presence of private rented sector housing in the local community, which varies from ward to ward. The tenants of these properties may have poor health or be considered vulnerable. The ES identifies the role for community engagement but makes no mention of the potential for supporting tenants in understanding and utilising uptake for compensation and noise insulation. Recommendation The compensation and noise insulation scheme literature should confirm the eligibility, approach and support to tenanted property occupants. Impact on Health Care Local health care services are likely to experience additional demand from the influx of non home-based workers, increased airport employment and in particular the increase in passenger numbers. The ES does not consider the impact on local primary health care, acute services and emergency responders from the significant increase in passenger numbers. The current demands are not quantified to establish a baseline and future demand is also not quantified. Whilst at the wider study area effects may be diluted, the ES must address any localised effects. The ES does not identify specific issues related to unaccompanied children arriving at Luton. The Local Authority will have the statutory responsibility where they first present on entry to the UK. When unaccompanied children arrive on inbound flights the Local Authority has a duty to assess such children and provide support. The increase in passenger movements, from 18 MPPA to 32 MPPA, will have a proportionate increase in service demand subject to changes in the proportion of international flights and border control procedures. Recommendation The ES should assess the current and future demand on health and social care services and the subsequent assessment of significance as a result of the DCO. The ES should report on the results of engagement with the local healthcare system and any proposed embedded or additional mitigation. Health Impacts of Noise from the Development Scope of this response This response looks specifically at whether the information provided is suitable to inform decision should be read in conjunction with previous comments provided by UKHSA at Scoping and PEIR stages. General Comments Specifically in relation to the human health impacts associated with noise, UKHSA welcomes: • The Applicant’s engagement with various stakeholders on the assessment methodology and noise envelope (Vol. 5 Table 16.8). • The Applicant’s presentation of population exposure to air noise broken down by absolute exposure (between LOAEL and SOAEL and above SOAEL) and also by predicted increase from Do-Minimum to Do-Something. • The presentation (Vol. 5 Table 13.14) of the population exposed to levels above 45 dB LAeq,16hr (day), which is more closely aligned to the threshold at which adverse effects of aviation noise are likely to start. • The Applicant’s acknowledgement of the strong link between transport noise and adverse health outcomes (Vol. 5 13.9.52). • The Applicant’s quantification of health effects due to aviation noise, quantified as DALYs, and its assessment of noise-induced awakenings. An equivalent assessment for surface noise was not carried out. In multiple locations the Applicant has chosen to make comparisons against the 2019 scenario. This can be misleading – the purpose of this Application is to present the implications of the Proposed Development. Reductions in noise that will occur due to fleet modernisation are very welcome, however they are not due to the Proposed Development and should therefore not have been presented with such prominence. The Applicant carried out the main health analyses for noise using published IGCB(N) guidance, which is based on evidence that is approximately 20 years old. UKHSA welcomes the sensitivity analyses and the awakenings assessment using more recent evidence (Vol.5 13.9.54 and 13.9.74 – 13.9.77). Decisions on SOAELs and UAELs are largely based on legal precedent, rather than informed by the latest evidence on the health effects of noise. As noted in previous UKHSA responses, the Applicant should explain what it’s choices for LOAELs, SOAELs and UAELs mean in health terms, especially to a non-technical audience. The ES noise aspects have several references to “precautionary” which UKHSA disagrees with. For example, “precautionary Unacceptable Adverse Effect” levels for air noise were defined at 69 dB LAeq,16h and 63 dB LAeq,8h (Table 16.13). From a health and quality of life perspective these choices are anything but precautionary. These levels are 20-25 dB higher than the likely threshold of adverse effects for aircraft noise, and approximately 15-20 dB higher than the levels where increased risks of cardiometabolic disease are believed to start. The PD briefly considers the potential implications of next generation aircraft (including electric or hydrogen powered) coming into service in the mid-2030s, and hence within the lifespan of the Proposed Development. The assessment of air noise effects for the Core Planning Case assumed that next generation aircraft would have a noise performance that is equivalent, and no better, than that of new generation aircraft. This was considered to be “a conservative approach” representing “a reasonable worst case”. The Applicant should clarify that this is not necessarily true – new propulsion methods could result in next generation aircraft having noise signatures that are significantly different, and potentially more annoying, for the same A-weighted decibel level. UKHSA encourages the Applicant to introduce safeguards in its Green Controlled Growth Framework to protect from such an eventuality. In parts of the assessment, significant adverse effects were predicted but their significance was somewhat watered down due to uncertainties in the prediction. For example 16.3.21 states “As these effects are far into the future and depend on forecast traffic data, the effects will be reassessed using more up to date traffic data nearer the time, and noise insulation will be provided to avoid the significant effects should the reassessment confirm that they are likely to occur.” The Applicant should clarify what legally binding mechanisms will be put in place to ensure such reassessments take place in the future. Summary of Population Exposure and Health Impacts from the Proposed Development PD = Proposed Development SOAEL – Significant Observed Adverse Effect Level According to the Applicant’s analysis , by 2043 (Phase 2b) there will be • 500 people exposed to daytime aviation noise levels at or exceeding 63dB LAeq,0700-2300 (Applicant’s choice of daytime SOAEL) – all of which are due to the PD • 3,250 people exposed to night-time aviation noise levels at or exceeding 55dB LAeq,2300-0700 (Applicant’s choice of night-time SOAEL) – ~60% of which are due to the PD • ~38,000 people exposed to daytime aviation noise levels above 51dB LAeq,0700-2300 (Applicant’s choice of daytime LOAEL); ~50% of which are due to the PD • ~63,000 people exposed to night-time aviation noise levels where adverse effects are known to occur; ~46% of which are due to the PD • ~118,000 people exposed to daytime aviation noise levels where adverse effects are known to occur. Of the people exposed to daytime aviation noise levels where adverse effects are known to occur, by 2043 (Phase 2b) • ~25,000 people will experience an increase of 2-3 dB in daytime noise due to the PD, • ~48,000 people will experience an increase of 2-3 dB in night-time noise; • 3,100 people exposed to the Applicant’s choice of night-time SOAEL (55dB LAeq,2300-0700) will experience an increase of 2-3 dB in night-time noise. Note: an increase of 2-3 dB is approximately equivalent to a 60-100% increase in the number of overflights (everything else remaining equal). An unspecified number of people will also experience at least one additional noise-induced awakening due to the PD (13.9.64 – 13.9.65). Between the years 2027 and 2043, approximately 1,500 (Vol. 5, 13.9.62) additional Disability Adjusted Life Years (DALYs) are predicted to be lost in total due to sleep disturbance from the Proposed Development when compared to without it. This number is likely to be a significant underestimate – sensitivity tests using more recent evidence suggest that the DALYs lost could be in excess of twice that number (Vol. 5, 13.9.77). In the same period 500 (Vol. 5, 13.9.67) additional DALYs are predicted to be lost due to annoyance, although that number could be higher than 1,000 (Vol. 5, 13.9.76) due to uncertainties in the exposure response functions. Of the households exposed to daytime surface access noise levels where adverse effects are known to occur, by 2043 (Phase 2b) • 31,000 and 25,000 are predicted to experience increases of up to 1 dB in daytime and night-time noise, respectively due to the PD. • Approximately 6,000 are predicted to experience an increase of 1-3 dB in daytime and night-time noise due to the PD. • Approximately 150 and 90 are predicted to experience an increases of more than 3dB in daytime and night-time noise, respectively due to the PD For non-residential exposure, by 2043 (Phase 2b) 59 educational facilities and 28 healthcare settings will be exposed to aviation noise levels where adverse health effects (including cognitive impairment in children) are likely to occur (dependent on type of educational / healthcare setting). None of this information is mentioned in Vol.5 Non-technical summary. In UKHSA’s view, this limits the ability of a non-technical audience to fully appreciate the scale of the noise impacts from the PD. Mitigation and Noise Envelope The Proposed Development relies heavily on the air noise insulation scheme to mitigate significant impacts. UKHSA welcomes noise insulation as a last resort mitigation measure. However the Applicant should be transparent on the many limitations of such a mitigation measure, and on the significant uncertainties whether noise insulation will mitigate the adverse effects identified. For many decades large infrastructure projects in the UK have specified noise insulation measures as a mitigation measure, however none of them have evaluated their effectiveness to protect health. As a result, we still have very little good quality evidence to confirm whether sound insulations schemes are effective to protect health, and the extent of unintended consequences. For example, sound insulation may reduce indoor noise levels at the expense of poorer indoor air quality and increased risk of overheating. Partially funded schemes, such as the ones proposed by the Applicant (Vol. 5 16.10.5) may widen health inequalities (see also Human Health and Wellbeing section). Noise insulation will also do nothing to mitigate outdoor exposure, including at private and public amenity space and places of relative tranquillity. On the noise envelope (Vol. 7.08), UKHSA is of the view that the Green Controlled Growth Framework is best discussed and agreed amongst local stakeholders, including local communities currently affected, and those that may be affected in the future due to airspace changes. The Applicant is ultimately responsible for communicating the latest evidence on the health effects of noise in these discussions. UKHSA notes that the proposed Noise Envelope is defined in terms of the size of the 54 dB LAeq,day and 48 dB LAeq,night contours. The Applicant should communicate • that its choice of thresholds does not capture all adverse health effects attributable to noise; • who will be responsible for controlling population growth, and hence potential increases in population exposure within these areas. • how the distribution of the noise exposure within these areas, and the associated health effects, will be managed. Monitoring The Applicant states that 13.13.1 Monitoring of health outcomes is not proposed due to practical difficulties in obtaining accurate health data for the population in the study area and attributing any changes in observed health outcomes to the Proposed Development. Accurately identifying changes in the health status of a population resulting from a specific intervention requires a large-scale study that is not proportionate in the context of an EIA. However, precursors to health effects will be monitored, including air quality, noise, local employment and apprenticeships. These monitoring measures are described within the relevant aspect chapters in this ES. UKHSA does not agree with this statement. Given the scale of the adverse impacts attributable to noise, the uncertainties associated with the Applicant’s key mitigation strategy (noise insulation), and the ineffectiveness of this mitigation on noise exposure outdoors, UKHSA recommends that a commitment for monitoring the health and quality of life of local communities is made if the Application is granted. The scale of such monitoring, such as via social surveys, can be designed to be proportionate to the scale of negative environmental impacts and the predicted economic benefits. Conclusions The non-technical summary concludes that 13.3.5 During operation, prior to mitigation, likely significant adverse effects on health and wellbeing have been identified due to an increase in air noise. However, the provision of additional compensatory mitigation measures in the form of noise insulation to qualifying properties, where accepted, could help reduce the significant adverse health effect inside properties and would result in the adverse health outcomes reducing to minor adverse, resulting in an effect that would be not significant. UKHSA is of the view that this statement does not adequately reflect the scale of the noise exposure and attributable adverse health effects due to the Proposed Scheme, as outlined above. The wording chosen by the Applicant (“could help reduce … inside properties”) correctly recognises the uncertainties on whether the provision of noise insulation (which in many cases would not cover the full costs) will indeed mitigate adverse effects on health and quality of life. UKHSA believes that the scale of adverse noise impacts from the PD warrants a commitment to monitor the health and quality of life of affected communities. 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