I’m reliably informed that your advice to developers is that: "“For the pre-application consultation process, applicants are advised to include sufficient preliminary environmental information to enable consultees to develop an informed view of the project… The key issue is that the information presented must provide clarity to all consultees.”
Once again, I must complain that clarity is the very last thing that we, as residents, have been provided with.
My understanding is that RSP is obliged to produce a Health Impact Assessment (HIA) that sets out what effect their cargo airport is going to have on our health and our life expectancy. They have completely failed to do this. At 1.1.91 of the PEIR, RSP says: “The health-related effects are not (my emphasis) assessed here as the HIA analysis has not been finalised and its results are unavailable."
This means that we are being consulted but that RSP is not giving us the information to help us to assess whether or not we're happy with the health implications of the project. RSP is intending to submit its HIA with its DCO application. This means we won't be allowed to consult on it as we don't get to consult at that stage. This surely represents a failure to comply with the requirements of the consultation process. As residents, our health and wellbeing is vital to us, arguably the most important area on which we should be consulted and renders this latest consultation flawed in this most fundamental aspect.
I have written on other aspects of the flawed nature of RSP’s consultations. I, together with many similarly irate residents, feel that RSP is deliberately avoiding proper consultation, most particularly on those aspects of their plans that would have the most damaging impact on the health and wellbeing of residents.
Until an application has been received and accepted for examination, the Planning Inspectorate (the Inspectorate) has no views on the merits or acceptability of any Proposed Development.
Preliminary Environmental Information (PEI)
The Infrastructure Planning (Environmental Impact Assessment) Regulations 2017 (EIA Regulations 2017) refers to PEI as information that:
(a) Has been compiled by the applicant; and
(b) Is reasonably required for the consultation bodies to develop an informed view of the likely significant environmental effects of the development (and of any associated development).
If you are of the view that this information has not been provided, you should notify your local authority in relation to the adequacy of consultation. Relevant local authorities will be invited to make an Adequacy of Consultation Representation to the Inspectorate, as set out in our previous advice to you:
You may also wish to consider registering as an Interested Party should an application be made and accepted for examination. For information about how and when you can have your say, please read our Advice Note 8 series: attachment 3
Health impact assessment
We note your comments regarding health impact assessment (HIA). There is no requirement under the EIA Regulations 2017 to prepare a stand-alone HIA. Schedule 4 Section 4 of the Regulations requires “4. A description of the factors specified in regulation 5(2) likely to be significantly affected by the development: population, human health….”. It is for the Applicant to decide how to provide this information, which may be in the form of a separate HIA or integrated into the Applicant’s Environmental Statement (eg as part of noise and vibration and air quality assessments amongst other topics). This information would need to be provided with any application for development consent made to the Inspectorate.