Thurrock Flexible Generation Plant

The views expressed in this page do not represent those of the Planning Inspectorate. This page consists of content submitted to the Planning Inspectorate by the public and other interested parties, giving their views of this proposal.

Thurrock Flexible Generation Plant

Received 14 August 2020
From PUBLIC HEALTH ENGLAND

Representation

Thank you for your consultation regarding the above development. Public Health England (PHE) welcomes the opportunity to comment on your proposals at this stage of the project. PHE has considered the submitted documentation and at this point has a number of specific observations and comments. Environmental Public Health The potential for minor and moderate air quality impacts on a number of human receptors has been highlighted in the Environmental Statement (ES). This includes particulate matter emitted during construction and from nitrogen dioxide (NO2) during operation and in both cases, with consideration of other developments (and potentially new receptors) in the study area. The supplied ES methodology indicates that the final significance of an effect rests with the expert’s professional judgement and that an explanation of this judgment would be provided. However, where a potential moderate impact from air pollution has been assigned, the level of detail justifying why this impact is only of minor significance (i.e. not relevant to EIA or requiring further mitigation) is very limited. Further detail would be useful. As stated in our section 42 consultation response, reducing public exposures to non-threshold pollutants (such as particulate matter and NO2) below air quality standards has potential public health benefits. We support approaches which minimise or mitigate public exposure to non-threshold air pollutants, address inequalities (in exposure), and maximise co-benefits (such as physical exercise) and encourage their consideration during development design, environmental and health impact assessment, and development consent. Whilst Appendix 2.2: identifies potential accidents and emergencies, with the appropriate mitigation measures listed against each, there is no assessment of risk, only a statement that each event is of low likelihood or below with no justification. As noted in our scoping opinion, PHE would expect to see an assessment of all potential hazards in relation to construction, operation and decommissioning; including an assessment of the risks posed; and identification of risk management measures and contingency actions that would be employed in the event of an accident to mitigate off-site effects. Human Health and Wellbeing Further to PHE’s request for a specific human health chapter, we welcome Environmental Statement Vol 3 Chapter 13: Human Health, and Vol 6, Appendix 13.1 Human Health Baseline. We are also broadly supportive of the methodology provided by the Design Manual for Roads and Bridges (LA112). Reference to other chapters with details of open space, accessibility, transport and socioeconomics is also noted. We recognise the challenges of obtaining ward level health data. However, the difference in health outcomes within different wards as demonstrated by your health baseline data, illustrate the importance of such analysis. These inequalities are unjust and the reduction of health inequalities across populations is one of PHE’s key roles. Appendix 13.1 suggests there is a disparity in the number of years lived in poor health between the most and least deprived communities in the area of the proposed development. Furthermore, evidence suggests that people living in more deprived areas tend to have less access to greenspace. Therefore, PHE requests details of deprivation levels (IMD) for Walton Common, the area which will be lost to the proposed development, and Zone E, the agricultural field proposed as a replacement. We also note that the Transport Assessment (Appendix 10.1) suggests there is capacity for cyclists on the network near the proposed development. However, although there is proposed provision for vehicle parking, there is no provision for cycle parking. PHE therefore requests further information on cycle parking provision at the proposed development.