Representation by Public Health England (Public Health England)
- Date submitted
- 5 October 2018
- Submitted by
- Other statutory consultees
Thank you for consulting Public Health England (PHE) at the Acceptance of an Application for a Development Consent Order phase of this project. Our records show that we have previously responded to the following enquiries / consultations regarding this proposal:
- The request for scoping opinion consultation dated 1st July 2016, a copy of which can be found in the relevant Planning Inspectorate scoping opinion located on the National Infrastructure Planning Website (https://infrastructure.planninginspectorate.gov.uk/).
- Public Consultation 11th August 2018
- Additional Consultation 14th February 2018
We can confirm that we have registered an interest on the Planning Inspectorate Website and have commented on the following matters.
- General approach to the Environmental Impact Assessment (EIA)
The submitted EIA appears to use national and industry good practice. We note that in cases where there is no specific guidance, such as the assessment of air quality impacts from airports, a reasonable approach has been taken.
We note the omission of a Decommissioning Environmental Management Plan (DEMP) from the submission and understand the rationale. We note however that a DEMP can also feed into the planning and design process, ensuring that a site is constructed and managed in such a way as to simplify or expedite decommissioning when the time comes. We would recommend that decommissioning, demolition and contamination issues are fully considered in the design and construction stages of the project to minimise future risks to the environment and public health at such time as the site ceases to operate or faces further major development.
We have reviewed the Construction Environmental Management Plan (CEMP) submitted with the application and can confirm that we are satisfied with both the scope of the document and approach taken. We note that a significant number of supporting plans and documents remain to be finalised at the post development consent order stage. We understand that some matters cannot be finalised at this stage but would strongly recommend that, where possible, these documents are drafted and agreed prior to issuing of a development consent order.
We welcome the inclusion of the traffic assessment and reassessment of the potential air quality impacts associated with airport related vehicle movements.
- Chemical Pollutants and Land Quality
We note the land quality assessment and are satisfied with the approach taken in assessing the risks from historic land use.
We note that the contaminated land management submission requires further development and that additional intrusive investigation will be undertaken as necessary based on site conditions once development commences. We recognise that in order to finalise the contaminated land investigation and assessment, agreement will be needed with the Environment Agency, water company and Thanet District Council. We are satisfied that this approach should secure the protection of public health. With regard to unexploded ordnance and possible radiological waste we are aware that much of the management will be undertaken via the provisions of the CEMP.
We note the potential for accidental release of fuel or other chemicals during the construction and operational phases of the site. We are satisfied that the CEMP, major incident plan and other operational documents should provide adequate protection of public health.
- Emissions to Atmosphere
We agree with the rationale that the major pollutants of concern are nitrogen dioxide (NO2) and particulate matter of 10/2.5 µm diameter and smaller (PM10/PM2.5).
We note the inclusion of an odour assessment at the request of both Thanet District Council and the Planning Inspectorate. The current assessment appears to focus predominantly on odour from fuel and aircraft emissions. We request confirmation that potential odour from groundworks in /remediation of historically contaminated land will be addressed either via the CEMP or a similar mechanism.
We welcome the inclusion of an assessment of the impact of road transport on local air quality and are satisfied with the methodology employed to undertake the assessment and the conclusions drawn.
Section 6.4.3 of the report discusses the cumulative effects and table 6.3 identifies that ‘…The greatest impact of NO2 is on individuals with asthma or other respiratory conditions, but consistent impacts on these individuals is at levels of greater than 564 µg m?3 , much higher than typical UK ambient concentrations….’
The discussion of effects only occurring at high concentrations of NO2 applies only to effects of short-term exposures. PHE recommends that the applicant should demonstrate that the EU limit value for short term average concentrations (200 µg m-3 as a 1-hour average) [Redacted] will not be exceeded. WHO (2006) noted a meta-analysis indicating effects at levels exceeding this concentration [Redacted]
Volume 13 – Appendix 14.1 – 17.3 (paragraph 6.35) includes the phrase …The NO2 mortality CRF is based on a meta-analysis by Hoek et al in 2013 [93], which recommends a -33% adjustment to account for potential double-counting with PM2.5 exposure mortality…’ COMEAP published guidance on quantifying mortality associated with long-term average concentrations of NO2 in August 2018 [Redacted]. The coefficient recommended by COMEAP is lower than that recommended by the Health Risks of Air Pollution in Europe project (HRAPIE). An assessment based on the HRAPIE approach would therefore be expected to over-estimate effects associated with NO2 emissions and thus it can be considered to be conservative and protective of health.
- Emissions to Water
We are satisfied that the approach being taken by the applicant, in agreement with the water company and Environment Agency, should ensure that contamination of controlled waters should be avoided.
- Noise
Public Stakeholder engagement It is not clear whether the proposed Noise Mitigation Plan was discussed and tentatively agreed by the Community Consultative Committee referenced in the same plan.
Significance of Impacts
It appears the applicant has determined significant and unacceptable adverse effect levels (Significant Observed Adverse Effect Level (SOAELs) and Unacceptable Adverse Effect Level(UAELs)) for daytime noise exposure based on recommendations for airport actions in the Aviation Policy Framework (APF) (2013) (cf. Environmental Statement paragraphs 12.6.64 and 12.6.65). The night time SOAEL appears to be chosen as the level where adverse health effects occur frequently, a sizeable proportion of the population is highly annoyed and sleep-disturbed and there is evidence that the risk of cardiovascular disease increases, according to the WHO Night Noise Guidelines [1].
However paragraph 15.7.8 states that significance will be based upon: a. the magnitude of potential impacts b. the sensitivity of the communities affected c. identified local health needs and objectives.
We could not find reference as to how the 2nd and 3rd bullet points were considered in the judgement of significance of noise effects.
It is not clear how the applicant arrived at the conclusion that “Overall, the magnitude of impact on health and wellbeing due to noise is considered to result in a moderate adverse effect prior to mitigation” (cf. 4.1.73).
The applicant also appears to assume that sound insulation will address most of the adverse effects for those properties eligible for it. We recommend that this argument is backed up by evidence which demonstrates that noise insulation is effective at mitigating the adverse psychological and physiological health outcomes associated with aviation noise. See also Mitigation section below.
We also recommend that the applicant clarifies paragraph 15.8.8.
Health Outcomes It is not clear why annoyance was not included as a health outcome, as recommended by the WHO [2] and the Interdepartmental Group on Costs and Benefits Noise (IGCBN) [3]. Also it would have been helpful if the applicant expressed the noise impacts in terms of Disability Adjusted Life Years (DALYs) and in monetary terms using the methodologies in [2, 3].
Sleep disturbance
We welcome the applicant’s approach of quantifying both the number of noise induced awakenings and the number of people highly sleep disturbed. It is not clear how the applicant has reached the conclusion that “No significant impact on sleep disturbance is predicted due to the small number of night flights forecast” (cf. 4.1.72) in spite of the fact that there will be nearly 1,400 people highly sleep disturbed in Year 20 (cf. Appendix 15.1 Health Impact Assessment Table 6.3) and 225 properties exposed to the levels above the SOAEL chosen by the applicant (55dB Lnight) (c.f. Environmental Statement 12.7.51).
The applicant should clarify that the WHO Night Noise Guidelines [1] do not specify a night-time SOAEL (c.f. 12.6.68). With regards to paragraph 12.6.72, it is not clear why the applicant has not used the more recent evidence, in particular Table 1 in the WHO Night Noise Guidelines [1].
Mitigation measures – in particular sound insulation
We expect decisions about all mitigation measures to be underpinned by good quality evidence, in particular whether mitigation measures are proven to reduce adverse impacts on health and quality of life. For interventions where evidence is weak or lacking, we expect a proposed strategy for monitoring and evaluating their effectiveness during construction and operation of the scheme.
With regards to the sound insulation of buildings, any proposed schemes should be based on a holistic approach which achieves a healthy indoor environment, taking into consideration noise, ventilation, overheating risk, indoor air quality and the need to open windows.
If the funds do not cover the full insulation of dwellings, it is likely that those on a low income will be most impacted, because they are unlikely to be able to afford the extra cost required for full insulation. Therefore it is important to ensure the full insulation criteria, inc. roof if necessary, and ventilation provisions to ensure good indoor air quality and safe indoor temperatures are considered.
We note that the assessment of night-time awakenings is based on an assumption of an outside to inside sound level difference of 21 dB (assumed to be A-weighted). PHE assumes that this is the yearly average referenced in the WHO Night Noise Guidelines. The figure of 21dB was derived specifically to be used with the annual averaged Lnight metric, and PHE questions whether it is appropriate to apply a yearly average to a noise event assessment. We recommend that separate assessments are carried out for windows open and windows closed scenarios.
It is not clear what a “reasonable” level of noise insulation and ventilation for schools and community buildings (cf. 2.4 Noise Mitigation Plan point 3) is – it would be helpful to have this expressed in terms of measurable outcomes.
Green spaces and private amenity spaces
We expect proposals to take into consideration the evidence which suggests that quiet urban areas can have both a direct beneficial health effect and can also help restore or compensate for the adverse health effects of noise in the residential environment [4-6]. Research from the Netherlands suggests that people living in noisy areas appear to have a greater need for areas offering quiet than people not exposed to noise at home [4].
The proposed sound insulation scheme will not protect amenity spaces (such as private gardens) from increased noise exposure. Furthermore, although public Quiet Areas were included in the assessment of noise sensitive receptors, none were identified within the study area. No health impacts were recorded due to increased noise exposure in public green spaces, since none were identified as receptors.
We note that, given the increased noise exposure in private amenity spaces, there is an opportunity to create new tranquil public spaces that are easily accessible to those communities exposed to increased noise from the scheme.
Construction noise
The ES states that “Construction noise would be temporary (with phased works) and subject to control by the CEMP. No significant adverse impacts on health due to any temporary noise disturbance during construction are predicted” (cf. 15.8.13). It would be helpful if the applicant has a definition of “temporary” within this context. The construction phases are predicted to extend from 2019 to 2036 inclusive. It is not clear to what extent noise sensitive receptors will be exposed to increased noise levels from construction during multiple phases. Therefore it is not possible to make an assessment whether construction noise can be classified as “temporary” for all sensitive receivers.
We acknowledge that there is a paucity of scientific evidence on the health effects attributable to construction noise for large infrastructure projects, where construction activities may take many years. We recommend that the applicant considers emerging evidence as it becomes available (e.g. HS2 [7]) and regularly reviews its assessment of impacts.
Interaction effects
We note that the HIA does not consider potential interaction effects between the wider determinants of health (e.g. noise, air quality, community cohesion), which could lead to cumulative effects not captured in the assessment.
Finalisation of flight paths
We acknowledge that for aviation noise, noise modelling was based on indicative, rather than finalised flightpaths. We expect the applicant to agree a strategy with relevant stakeholders to address this issue, and an additional HIA may be necessary during the finalisation of flightpaths if consent is granted, to assess the full scale and distribution of localised impacts.
Strategy to disseminate HIA
We expect the applicant to propose a suitable strategy to ensure the dissemination of the findings of the HIA to relevant stakeholders, including the noise sensitive receptors impacted by the scheme.
References: [1] WHO Night Noise Guidelines for Europe, 2009 [2] WHO Burden of Disease from Environmental Noise, 2012. [3] Defra/Interdepartmental Group on Costs and Benefits Noise Subject Group, 2014. [4] Health Council of the Netherlands Publication no. 2006/12, 2006 [5] LIFE09 ENV/NL/000423, QSIDE - The positive effects of quiet façades and quiet urban areas on traffic noise annoyance and sleep disturbance [6] COST TD0804, Soundscape of European Cities and Landscapes, 2013 [7] HS2 U&A ref 2109 in HS2 Phase One register of undertakings and assurances
- Waste
We note that the Waste Management Plan is still to be finalised and will be subject to agreement with the Environment Agency at a later time. In the absence of detailed information we cannot provide any additional comments on this matter.
- Electric and Magnetic Fields (EMF)
The submitted proposal does not include a specific section assessing risks associated with EMF but we note that document 6.1 contains the following comment against our earlier request for details on EMF. “Following the DECC Voluntary Code of Practice for assessing EMF from electricity distribution infrastructure, overhead power lines or underground cables operating at <132kV are compliant by design with guideline public exposure levels set to protect public health, as are substations at or beyond their publicly accessible perimeter” PHE can confirm that we accept this position and wish to make no further representation with regard to Electric and Magnetic Fields.
- Ionising Radiation
We note that a report from the Defence Evaluation and Research Agency (DERA) Radiation Protection Services suggested that, as with many RAF sites, radioactive materials, and particularly radium luminising material, may have been present in equipment buried at the site and may have been disposed of in waste pits or areas where ash was disposed of.
In the event that any radium luminising material or other radiological contamination is identified during the construction works it will be necessary to ensure that suitable steps are taken to mitigate the risk both during the works and for any future use of the site. We request that the CEMP be amended to include a requirement that the applicant document their proposed radiological screening process and obtain agreement with the proposed process from PHE and appropriate regulatory bodies prior to the commencement of works on site.
- Significant effects on population and human health
We welcome the inclusion of a Health Impact Assessment in the submitted documentation. We note the conclusions drawn and make the following comments: The HIA has undertaken limited community engagement and consultation with the local public health and health care system. It does identify a series of recommendations that should be agreed with the local Director of Public Health and incorporated into the development plans. There is a need for ongoing assessment in conjunction with input from the local DPH / CCG and through local community consultation.
We hope that our comments are useful but should you wish to discuss any issued raised in this letter or have any questions relating to our response please do not hesitate to contact us.