Glyn Rhonwy Pumped Storage

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.

Glyn Rhonwy Pumped Storage

Received 13 January 2016
From Public Health Wales

Representation



Dear Sir / Madam

Re: NSIP Application by Snowdonia Pumped Hydro Ltd for an Order Granting Development Consent for the Glyn Rhonwy Pumped Storage Project

In Wales, the statutory function for public health is delivered through Health Boards with specialist support from Public Health Wales as necessary. We have consulted our technical advisors within Public Health Wales as well as Public Health England PHE CRCE – Wales. Our comments are based on the information contained within the application documentation to date. We have divided our comments to cover both the operational and construction phases.

Note: In this context we consider off-site sensitive human receptors may include people living in residential premises; people working in commercial, and industrial premises and people using transport infrastructure (such as roads and railways), recreational areas, and publicly-accessible land.
Consideration should also be given to environmental receptors such as the surrounding land, watercourses, surface and groundwater, and drinking water supplies such as wells, boreholes and water abstraction points.
Overall the submitted Environmental Impact Assessment (EIA) has acknowledged public health risks.

Operational Phase
It will be vital to mitigate from the outset, impacts from noise and vibration that may arise from surface, underground operations and nighttime water pumping. The final project designs and operational plans to protect sensitive human receptors from noise and vibration should be agreed in conjunction with the local authority.

Advice on mitigation of any possible health effects associated with the electric and magnetic fields around substations and the connecting cables or lines has been previously supplied by PHE – we have however supplied again for the attention of the developer in Appendix 1.

Subject to the above impacts from the operational phase as described, do not present a concern for public health.




Construction Phase
We understand that the construction phase may last circa 5 years. We appreciate this phase will comprise a number of individual elements ultimately linked by underground water pipelines / tunnels.

Potential impacts upon health are possible during this phase unless they are avoided or mitigated. Impacts from construction and material handling include dust and invisible particulates (point source, fugitive and traffic-related), noise and vibration (including from rock blasting).

We therefore recommend that the developer
1. Agrees to and operates a Construction Environmental Management Plan (CEMP) which outlines mechanisms to respond to any complaints during construction.

2. Liaises with
• the local authority for matters relating to noise, vibration, odour, and dust nuisance.
• the local authority regarding any impacts on existing or proposed activities on local air quality.
• the local authority to agree mechanisms to respond to any complaints from the community during construction, operational and any decommissioning phases.

3. Has regard to any cumulative impacts, including those arising from associated development, other existing and proposed development in the local area and new vehicle movements associated with the proposed development

We hope that the above is useful but should you have any questions or concerns please do not hesitate to contact us.

Yours sincerely

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Appendix 1: Electromagnetic fields (EMF)
There is a potential health impact associated with the electric and magnetic fields around substations and the connecting cables or lines. The following information provides a framework for considering the potential health impact.
In March 2004, the National Radiological Protection Board, NRPB (now part of Public Health England), published advice on limiting public exposure to electromagnetic fields. The advice was based on an extensive review of the science and a public consultation on its website, and recommended the adoption in the UK of the EMF exposure guidelines published by the International Commission on Non-ionizing Radiation Protection (ICNIRP):-
http://www.hpa.org.uk/Publications/Radiation/NPRBArchive/DocumentsOfTheNRPB/Absd1502/
The ICNIRP guidelines are based on the avoidance of known adverse effects of exposure to electromagnetic fields (EMF) at frequencies up to 300 GHz (gigahertz), which includes static magnetic fields and 50 Hz electric and magnetic fields associated with electricity transmission.
PHW notes the current Government policy is that the ICNIRP guidelines are implemented in line with the terms of the EU Council Recommendation on limiting exposure of the general public (1999/519/EC):
http://www.dh.gov.uk/en/Publichealth/Healthprotection/DH_4089500
For static magnetic fields, the latest ICNIRP guidelines (2009) recommend that acute exposure of the general public should not exceed 400 mT (millitesla), for any part of the body, although the previously recommended value of 40 mT is the value used in the Council Recommendation. However, because of potential indirect adverse effects, ICNIRP recognises that practical policies need to be implemented to prevent inadvertent harmful exposure of people with implanted electronic medical devices and implants containing ferromagnetic materials, and injuries due to flying ferromagnetic objects, and these considerations can lead to much lower restrictions, such as 0.5 mT as advised by the International Electrotechnical Commission.
At 50 Hz, the known direct effects include those of induced currents in the body on the central nervous system (CNS) and indirect effects include the risk of painful spark discharge on contact with metal objects exposed to the field. The ICNIRP guidelines give reference levels for public exposure to 50 Hz electric and magnetic fields, and these are respectively 5 kV m?1 (kilovolts per metre) and 100 ?T (microtesla). If people are not exposed to field strengths above these levels, direct effects on the CNS should be avoided and indirect effects such as the risk of painful spark discharge will be small. The reference levels are not in themselves limits but provide guidance for assessing compliance with the basic restrictions and reducing the risk of indirect effects. Further clarification on advice on exposure guidelines for 50 Hz electric and magnetic fields is provided in the following note on PHW website:
http://www.hpa.org.uk/webw/HPAweb&HPAwebStandard/HPAweb_C/1195733805036
The Department of Energy and Climate Change has also published voluntary code of practices which set out key principles for complying with the ICNIRP guidelines for the industry.
http://www.decc.gov.uk/en/content/cms/what_we_do/uk_supply/consents_planning/codes/codes.aspx
There is concern about the possible effects of long-term exposure to electromagnetic fields, including possible carcinogenic effects at levels much lower than those given in the ICNIRP guidelines. In the NRPB advice issued in 2004, it was concluded that the studies that suggest health effects, including those concerning childhood leukaemia, could not be used to derive quantitative guidance on restricting exposure. However, the results of these studies represented uncertainty in the underlying evidence base, and taken together with people’s concerns, provided a basis for providing an additional recommendation for Government to consider the need for further precautionary measures, particularly with respect to the exposure of children to power frequency magnetic fields.
The Stakeholder Advisory Group on ELF EMFs (SAGE) was then set up to take this recommendation forward, explore the implications for a precautionary approach to extremely low frequency electric and magnetic fields (ELF EMFs), and to make practical recommendations to Government. In the First Interim Assessment of the Group, consideration was given to mitigation options such as the 'corridor option' near power lines, and optimal phasing to reduce electric and magnetic fields. A Second Interim Assessment addresses electricity distribution systems up to 66 kV. The SAGE reports can be found at the following link:
http://sagedialogue.org.uk/ (go to “Document Index” and Scroll to SAGE/Formal reports with recommendations)
Public Health England has given advice to Health Ministers on the First Interim Assessment of SAGE regarding precautionary approaches to ELF EMFs and specifically regarding power lines and property, wiring and electrical equipment in homes:
http://www.hpa.org.uk/webw/HPAweb&HPAwebStandard/HPAweb_C/1204276682532?p=1207897920036
The evidence to date suggests that in general there are no adverse effects on the health of the population of the UK caused by exposure to ELF EMFs below the guideline levels. The scientific evidence, as reviewed by HPA, supports the view that precautionary measures should address solely the possible association with childhood leukaemia and not other more speculative health effects. The measures should be proportionate in that overall benefits outweigh the fiscal and social costs, have a convincing evidence base to show that they will be successful in reducing exposure, and be effective in providing reassurance to the public.
The Government response to the SAGE report is given in the written Ministerial Statement by Gillian Merron, then Minister of State, Department of Health, published on 16th October 2009:
http://www.publications.parliament.uk/pa/cm200809/cmhansrd/cm091016/wmstext/91016m0001.htm
http://www.dh.gov.uk/en/Publicationsandstatistics/Publications/PublicationsPolicyAndGuidance/DH_107124
HPA and Government responses to the Second Interim Assessment of SAGE are available at the following links:
http://www.hpa.org.uk/Publications/Radiation/HPAResponseStatementsOnRadiationTopics/rpdadvice_sage2
http://www.dh.gov.uk/en/Publicationsandstatistics/Publications/PublicationsPolicyAndGuidance/DH_130703