Your Chance to Comment on the Quarry Applicant’s Health Impact Assessment.
The quarry applicant decided to appeal against the Herts County Council’s decision to reject two applications for permission to extract gravel from Bengeo Field. The appeal to the Planning Inspectorate led to a Public Inquiry which took place in May. During the inquiry the Stop Bengeo Quarry campaign requested that the residents of Hertford should be given an opportunity to comment on the Health Impact Assessment (HIA) which was submitted by the quarry applicant on the 25 April 2018 – just a few days before the public inquiry started.
The Planning Inspector considered the request and decided to adjourn the inquiry until October, allowing the community of Hertford to have an opportunity to comment on the Health Impact Assessment (HIA). Of course, the quarry applicant claims in the Assessment that there will be no adverse effect on the health of local residents or the children at Bengeo Primary School.
The latest version of the HIA can be viewed here
The HIA states that there is no significant risk to health, but does not back up this claim with reliable evidence on crucial issues. For example, how much dangerous fine-grained silica dust will pollute the air around the proposed quarry? How can the applicant claim no harm without providing observations made locally? As a first step, the applicants should provide an analysis of the fine-grained material that would be disturbed by quarrying.
The HIA fails to convince that there is no significant risk to health. We summarise here our comments on the shortcomings of the HIA.
Stop Bengeo Quarry Comments On The Health Impact Assessment
Weaknesses In The Applicant’s Environmental Statement and Other Documents
The HIA is based on uncritical acceptance of the data and conclusions provided by the applicant’s ES, together with various reports commissioned by the applicant. This raises questions as to the impartiality and objectivity of the document.
Although the HIA reviews the responses from various consultees, it does not reference the Acoustic Associates Noise Assessment commissioned by HCC, which reaches significantly different conclusions to those in the applicant’s Noise Assessment.
The HIA fails to take any note of the groundwater concerns raised by SBQ, including the authoritative November 2017 hydrogeological report by Professor Frederick Brassington. The HIA fails to take an appropriately long-term view of the consequences for health of loss of supply of water from pollution of the chalk aquifer during or following the proposed quarrying operations.
Confusion Resulting From The Two Applications
There is an unnecessary layer of complexity introduced by interchanged reference to either the “1.75m tonne application” and the current “1.25m tonne application”. This is potentially confusing and therefore discourages the general public from scrutinising the information presented. For example, there are 47 references to “the Environmental Statement” in the HIA, but rarely (if at all) any indication of which ES is being referenced. It is unsatisfactory that it is left to the reader to decide which ES is being referenced and to resolve any potential ambiguity.
Arguments Based On Assumption Not Data
The majority of section 9 of the HIA (Potential Effects) consists of the author making reasoned assessments on the basis of expected outcomes given a particular set of input data. There is obviously scope for unconscious bias to creep into such assessments and anyone preparing such a document should be extremely careful to ensure that they are “data-driven” rather than “expectation-driven”. Section 9.2.3 appears to be an example of an assumption being used to justify a conclusion. To paraphrase, the section states that the higher potential for dust in dry conditions is balanced by the fact that winds are lower in the warmer months. In Hertford the average wind speed in January 2017 was 12.5mph while in June 2017 it was 10mph. Without clear references to research that justifies this assertion, there is no way to tell that this difference is large enough to totally offset the drying effects of warmer weather.
The Air Quality section (9.2.5) reports that the World Health Organisation (WHO) guidelines for PM2.5 dust (10 micrograms per cubic meter) are already exceeded by the dust baseline at all modelled locations. Section 9.2.10 appears to say that the dust generated by the quarry can therefore be ignored. However, we would expect that any additional dust that the quarry would generate may exacerbate existing respiratory conditions. At the very least there should be a reference to the research that underpins the author’s conclusion.
Section 9.2.18 states “Given the semi-rural context (where baseline air quality is generally good)…” We are puzzled that the air quality in Bengeo is described as “generally good” when section 9.2.5 reports the level of one type of particulate as being above WHO guidelines.
Department for Environment, Food & Rural Affairs (DEFRA) stated in the recent draft Clean Air Strategy 2018 consultation: “We will progressively cut public exposure to particulate matter pollution as suggested by the World Health Organisation. We will halve the population living in areas with concentrations of fine particulate matter above WHO guideline levels (10 µg/m3) by 2025.” Further decreasing of the air quality in a community where levels already exceed these WHO thresholds is inconsistent with this commitment. https://consult.defra.gov.uk/environmental-quality/clean-air-strategy-consultation/
Community Liaison & Building Community Trust
Several HIA sections (e.g. 9.5.15, 9.5.16 9.5.17) stress the importance of community liaison and building the trust of the community. The document also concludes that without this the general health and well-being of the community would be affected. We note that, apart from a poorly advertised public exhibition in late 2015, the applicant has made no attempt to research the importance of Bengeo Field to the local community or to engage with the residents about their other concerns. Instead the applicant made repeated efforts to impose the quarry project against very strong community resistance. We contend it is unlikely the applicant will be able to build any sort of trust at this point and that if permission for the quarry is granted, there will be a significant negative effect on local health and well-being.
Recommended Minimum Distances
In section 11.2.3 HIA recommends a 100 yard[NG1] stand-off for The Orchard. We are puzzled that there is no equivalent stand-off recommended for the properties at Sacombe Road, especially since they are closer to Phase 2 than The Orchard is to Phase 1.
The distances from the application boundary to the nearest properties are as follows: Houses to the West (160 Sacombe Road) – 2.5m, houses to the East (Waterworks Cottage) – 53m, houses to the South (The Orchard) – 27m, and Bengeo Primary School – 340m.
Public Rights Of Way (PRoW)
Section 11.2.10 identifies the creation of two new looped rights of way around the western and eastern sides of Bengeo Field as being a potential health benefit that could come from the project. It seems likely that quarrying would in fact reduce the health benefit that the field provides, even with the proposed new Rights of Way. Bengeo Field is already very well-used and two good circular routes exist: A) via Byway 1 Footpaths 1, 3 and 4 and paths in Waterford Heath; B) a long-used unofficial path around the western side of the field linking Byway 1 and Footpath 1 (a very pleasant walk with excellent views) – it seems that route B is effectively the route proposed for the new western loop. Should the quarry go ahead, however, the value of path B (and therefore the western loop) would be compromised, initially by the presence of the quarry itself and subsequently by tree planting and landform changes which would destroy all the open views. We believe that quarrying would lead to less health and recreational use of the field rather than more.
A loop on the eastern side would run a few metres from the B158. In view of the tranquillity available on the western side of the field we again speculate that an eastern loop would not be well-used and is unlikely to be a significant health benefit.
We contend that the public health and well-being of the local community are much better served by leaving Bengeo Field as it is, and that the best positive health outcome would be for the landowners to remove uncertainty about route B by working with HCC to make it an official PRoW.
There is no recognition or analysis of the interaction of lorries queueing to enter the site and morning rush hour traffic.
There is no analysis of the collision data associated with gravel lorries
We welcome the recommendation in paragraph 11.2.16 that no traffic would enter or leave the site during school opening and closing times. We look forward to seeing this formally incorporated into the proposal.