APPEAL BY ISLAND GAS LTD, PORTSIDE, ELLESMERE PORT
APPEAL REFERENCE APP/A0665/W/18/3207952
PROOF OF EVIDENCE
ENVIRONMENTAL SUSTAINABILITY – PUBLIC HEALTH IMPACTS OF THE PROPOSED DEVELOPMENT
Dr PATRICK SAUNDERS FRCP FFPH
Table of Contents
- Evidence of Unequal Environmental Impact on Public Health
- Evidence of Climate Change Impacts on Public Health
- Appendix – House of Commons: Written Statement (HCWS42)
1.1 My name is Dr Patrick Saunders. I am a Consultant in Public Health and Visiting Professor in Public Health at the University of Staffordshire. A registered Public Health Specialist, Faculty of Public Health (FPH) Board member, I was awarded Fellowship of the FPH in 2011.
1.2 I have held service, research, teaching and management roles with the WHO, European Union, Health Protection Agency, local government, the NHS and a number of Universities. I retired from the NHS in 2013 as Associate Director of Public Health and maintain active research, teaching and consultancy commitments to a range of bodies including the Royal College of Physicians, Public Health England, the National Institute for Health and Clinical Excellence and the EU Horizon 2020 programme.
1.3 My research interest is in the public health impact, especially on reproductive health, of exposure to low levels of chemicals and was awarded a PhD at the University of Birmingham in 2004. I have published papers including a systematic style literature review on the public health impact of Unconventional Oil and Gas Developments in the peer reviewed literature.
1.4 The evidence which I have prepared and provide for appeal reference APP/A0665/W/18/3207952 in this proof of evidence is true and has been prepared and is given in accordance with the guidance of my professional institution and I confirm that the opinions expressed are my true and professional opinions.
2.1 The Indices of Deprivation 2015 – Hotspots of Deprivation in Cheshire West and Chestershow that two of the wards closest to this proposal, Rossmore and Ellesmere Port Town, include populations that are ranked amongst the 10% most deprived nationally. There is evidence that deprived communities are disproportionately exposed and vulnerable to the effects of exposure to environmental pollution including traffic related impacts on air quality.
2.2 The proposed development is to: ‘Mobilise well test equipment, including a workover rig and associated equipment, to the existing wellsite to perform a workover, drill stem test and extended well test of the hydrocarbons encountered during the drilling of the EP-1 well, followed by well suspension’ [CD 2.3].It is important to acknowledge that this application relates to the test- phase of the process which will inevitably be less intensive and of shorter duration than a fully operational site. However, that does not mean that the public health impacts of the proposed development are necessarily minimal or of short duration, as I set out below.
2.3 The seriously deprived populations closest to the proposal will gain nothing from this development but run the risk of adverse health consequences, as set out below. This would conflict with Council Policy SOC5, which promotes development that improves the health and wellbeing needs of local residents and does not support development that gives rise to significant adverse impacts on health and quality of life. As stated in paragraph 7.27 of the text explaining this policy: ‘The promotion of health and well-being is a key thread running through this Plan and is influenced by many of the policies and objectives within it, and within the Sustainable Community Strategy including promoting diversity, feeling safe, addressing community safety, health inequalities and reducing deprivation’.
2.4 Despite arguably being the most significant change in energy extraction since the advent of the fossil fuel economy, the published literature on the direct impact of unconventional oil and gas development on the health of local communities is very modest in a scientific context. However there are concerning signals in the literatureand a legitimacy to the anxieties of the community which require a precautionary approach. It is also clear that shale gas exploitation will exacerbate climate change with potentially catastrophic public health consequences. On these grounds alone, the risks already outweigh any possible benefits.
2.5 The proposed development uses, loses and produces toxic chemicals at every stage of its development, operation, decommissioning and abandonment. The question is not whether toxic chemicals will be released; it is rather whether this is a hazard (the inherent danger) or a risk (the likelihood of that danger being realised) to local communities and beyond. In addition, the potential for serious interference with individual and community health and wellbeing through public health impacts (odours, noise, lighting, dust, traffic etc) is real. Determining the level of that risk not only requires an assessment of the level of exposure, it also requires an assessment of the susceptibility of the exposed population. This is where the evidence is stronger. Poorer people are not only more exposed to environmental pollution, they are more susceptible to the consequences of that exposure. As the Chief Medical Officer for England reminded us in her 2017 annual report:
“disadvantaged groups face: first, increased risks from social and behavioural determinants of health; second, higher risks from high ambient pollution exposure; and, third, an effect modification that makes exposure to ambient pollutants exert disproportionately large health effects on them compared with advantaged groups” [EP39, Chapter 6]
3. Evidence of Unequal Environmental Impact on Public Health
3.1 There is clear evidence that deprived communities in the UK live in more polluted environments, are exposed to multiple environmental and social stressors and have less access to health improving assets such as a healthy diet and good quality green spaces. The decline of local manufacturing in Ellesmere Port for example has left a legacy of derelict sites and contaminated land. The proportion of Rossmore, Ellesmere Port and Netherpool wards populations in the most deprived quintile of deprivation nationally are 100%, c. 85% and c. 55% respectively. Standardised mortality ratios in these wards are 53%, 42% and 24% higher than England respectively. Unemployment in Rossmore and Ellesmere Port Town is 88% and 65% higher than the average for England respectively. Rates of adult obesity are higher in Rossmore and Ellesmere Port Town than the England average and, in the case of childhood overweight and obesity, significantly so [Documents EP 04, 21, 22].
3.2 The most researched area in terms of exposure is air pollution. There is a strong social gradient in concentrations of two of the most important contemporary air pollutants, oxides of nitrogen (NOx) and fine particulate matter (PM), for example. There is a very clear relationship between deprivation and living in wards exceeding the national air quality standard annual average limit values for NO2(Figure 1 below).
Figure 1Population resident in areas exceeding the annual average legal limit value for NO2by deprivation decile, England 2001
Source: Walker G et al. Environmental Quality and Social Deprivation. Phase II: National Analysis of Flood Hazard, IPC Industries and Air Quality. The Environment Agency (2003)
Consequences – Air Quality
3.3 There is evidence that stress, at both the individual and the community levels, can weaken the body’s defences against external insult and influence the internal dose of toxicants . While the health experience of the relatively affluent is effectively independent of geographical region of residence, the Chief Medical Officer’s 2001 report clearly shows that geography has a major impact on the health effects of deprivation in England . Figure 2 shows that affluent men had similar and statistically significantly lower mortality rates than their poorer contemporaries irrespective of where they lived whereas the mortality rates of poor men showed a highly significant regional trend from the North East to the South West.
Figure 2Male age standardised mortality rates by English region and social class 1991-1993
(Source http://webarchive.nationalarchives.gov.uk/20121031020951/http://www.dh.gov.uk/en/ Publicationsandstatistics/Publications/AnnualReports/DH_4005607)
3.4 This difference has persisted and Sir Michael Marmot’s 2010 review found similar regional differences (see Figure 3 below). These differences cannot be explained by age, gender, deprivation or genetics. It is entirely plausible that environmental stressors such as air quality contribute to this inequity. There is a similar pattern in Cheshire. There is a clear relationship between higher Standardised Mortality Ratios (SMR) and lower life expectancy with increasing levels of deprivation in the wards that make up Ellesmere Port (see figures 4, 5 and 6). Given that the more affluent wards are also more rural their populations will be exposed to lower levels of air pollution.
Figure 3Male age Standardised Mortality Rates (25-64) by socioeconomic classification and English Region 2001-2003 (Source: Fair society, healthy lives: the Marmot Review: strategic review of health inequalities in England post-2010)
Figure 4 Life expectancy Cheshire West and Chester wards 2011-2015
(Source: Chester West and Chester Joint Strategic Needs Assessment Life Expectancy and Mortality Rates October 2018)
Figure 5 Ellesmere Port Wards male life expectancy by decreasing proportion of population in the most deprived quintile of deprivation nationally 2011-2015 (Source: Cheshire West and Chester Joint Strategic Needs Assessment)
Figure 6Ellesmere Port Wards all cause SMR by decreasing proportion of population in the most deprived quintile of deprivation nationally 2011-2015 (Source: Ward Snapshots 2017)
3.5 The evidence of health effects of air pollution across the life course from prenatal to old age is overwhelming and well documented in the Royal College of Physicians 2016 report. By definition, deprived populations will be more at risk given their higher exposures. However, their deprivation exacerbates the effects of that exposure. There is evidence from a number of studies that deprivation increases susceptibility to PM and cardiorespiratory effects, although the precise mechanisms remain unclear (ibid). A European review reported that poorer communities were more vulnerable to the effects of PM10 exposure, including morbidity and mortality.This is especially important as there is no safe levelof exposure to fine PM meaning that any exposure will have an impact at a population level. Deprivation modifies the impacts of both PM on preterm birth and black smoke exposure on respiratory mortality. Effects on cardiorespiratory disease and gestational hypertension continue to be reported. Other factors closely associated with deprivation, such as obesity and pre-existing cardiovascular and respiratory diseases, also increase vulnerability.
3.6 The proposed development will increase traffic and associated emissions including NO2and PM.Over all phases of the application this amounts to 2316 movements over 104 working days. 392 of these will be Heavy Goods Vehicles (HGV). The flaring of ‘waste’ gas as proposed is also a potential source of air pollutants including NO2, H2S, SO2, PM, Benzene Toluene Ethylbenzene Xylene (BTEX) and Polyaromatic Hydrocarbons (PAH). Given that some of these pollutants, for example Benzene and PM, are non-threshold, i.e. there is no safe level of exposure, any increase in levels of damaging pollutants to this community, no matter how small, should be avoided as the evidence shows this is a community that is highly susceptible to the adverse impacts.
Consequences Other Stressors
3.7 In addition to poor air quality, deprived communities such as those in Rossmore and Ellesmere Port wards are also simultaneously exposed to other environmental and social stressors including unemployment, poorer quality housing and restricted access to environmental assets and a healthy diet. These factors not only impact health and wellbeing directly but, in some cases, magnify the harmful effects of air quality impacts. One of the main mechanisms through which air quality impacts affect lung and heart health is by the activation of ‘oxidative stress’ in the airways and circulation. Diets that are rich in antioxidant nutrients or which include micronutrient supplements may help to protect against the harmful effects of air pollution. However, the availability of such foods tends to be more restricted in poor communities while cheap calorie dense fast foods are readily available. These unhealthy products are inevitably attractive to deprived communities, given that food prices increased 12% in real terms between 2008 and 2012, while median incomes in the most deprived decile fell 12% between 2002 and 2011. Analysis of the cost of ‘more healthy’ and ‘less healthy’ foods over a very similar period (2002–12) found that the former were consistently more expensive, and that this gap had widened with healthier foods being almost three times more expensive by 2012. For poorer social groups avoiding the expense of cooking entirely is a cost effective way of sourcing energy. It is hardly surprising then that obesity levels in such communities are much higher than in more affluent areas as is the cases in Rossmore and Ellesmere Port wards.
3.8 There is evidence that individuals and communities experience adverse psychosocial effects during the planning stage of shale gas extraction in the face of local opposition as Dr Anna Szolucha has described in her evidence. Her research of the experiences of communities living in close proximity to actual and potential drilling sites in Lancashire during 2015 and 2016 involved participant observation and expert witness testimony at the two planning application hearings, and follow up semi-structured interviews with citizens involved in the local opposition campaign. This research found communities experienced a form of ‘collective trauma’ including an increased sense of powerlessness, fear, betrayal, guilt, anger, stress, and anxiety, as well as sleep disturbances [EP07],experiences she has also found in communities proximal to this application. Psychosocial stresses such as these can have serious adverse health impacts including cardiovascular health and longevityand there is active research in the area of stress-related hormones and heart disease as well as susceptibility to chemical exposures. These stresses may also be exacerbated by concerns about the impact on property values. As I have stated in 3.3 there is evidence that individual and community stress can weaken the body’s defences against external challenges and the physical and mental health impacts reported in Dr Szolucha’s evidence are entirely plausible.
3.9 As set out in the evidence of Dr Szolucha, the local community has genuine concerns about the proposed development and is already suffering stress and fatigue as a result. Part of this comes from a feeling of powerlessness within the process and that their democratic will, as voiced by the Council’s planning committee – locally accountable democratically elected representatives – will be overturned. This contrasts markedly with the approach on wind farm applications, which is to give local people the final say on such applications and requires local planning authorities to grant permission only ‘following consultation”, so it can be demonstrated that the planning impacts identified by affected local communities have been fully addressed and therefore the proposal has their backing’ [Appendix]. While I accept that approach is not directly applicable to the proposed development, it is instructive that, were it applicable, it would weigh strongly against the grant of planning permission.
4. Evidence of Climate Change Impacts on Public Health
4.1 The final product of the proposed development, methane, is a powerful greenhouse gas. As the climate change witness, Professor Kevin Anderson, demonstrates, there is considerable evidence that leakage rates from extraction and distribution are much higher than the industry or the regulator have estimated. A global rise in atmospheric methane concentrations since 2006 has caused alarm amongst climate scientists with evidence that the oil and gas industry is a major contributor
4.2 There is an overwhelming scientific consensus that we must slow the current increase in global temperature to avoid catastrophic climate change. The recent Intergovernmental Panel on Climate Change report has a stark conclusion: we must reduce CO2emissions by at least 45% in the next 12 years compared to 2010 levels; and achieve net zero CO2production by 2050 [EP10]. The consequences of failing to achieve the IPCC limit will be largely borne by poor communities which have contributed least to runaway climate change (in a UK context, this includes communities such as those in Ellesmere Port and Rossmore), and which have derived no benefit from shale exploration. Not only would this be iniquitous, it would mean the local community bears a disproportionate risk of harm.
4.3 The Intergovernmental Panel on Climate Change’s new synthesis of more than 6,000 recent scientific papers has highlighted the scale of the public health and environmental dangers posed by global warming including extreme weather events, rising sea levels, destruction of coral reefs, loss of biodiversity, ocean acidification and deoxygenation, and extreme heat. Crucially, climate change is a “threat multiplier” that exacerbates and intensifies poverty, food insecurity, water stress, forced migration, and conflict between states and communities. In addition there is the real threat of feedback resulting in unpreventable, runaway global warming.
5.1 There is good evidence that deprived communities are disproportionately vulnerable to the effects of exposure to environmental impacts of development. The evidence is currently insufficient to rule out direct local adverse health impacts associated with this proposed development. While this application relates to the test-phase of the process it is important to recognise that the uncertainties inherent in the air quality modelling together with the reality that some emissions will be non-threshold, and the plausibility of associated negative public health impacts it would be imprudent to assume no local health or well-being impact.
5.2 The Appellant seeks to rely on benefits associated with energy security and maintaining the supply of gas. These benefits do not arise from a short exploration project. They will only arguably arise if the project discovers an exploitable shale gas reserve and shale gas production occurs. I am aware that the planning process focuses on exploration by itself. But if the Appellant is permitted to rely on the benefits of exploiting a shale gas reserve for production, then the harmful impacts of production must also be taken into account. A UK unconventional oil and gas industry will undoubtedly contribute to global warming increasing the potential of harm to communities which will derive little, or no, benefit from that industry.
6. Appendix – House of Commons: Written Statement (HCWS42)
Department for Communities and Local Government
Written Statement made by: Secretary of State for Communities and Local Government (Greg Clark) on 18 Jun 2015.
I am today setting out new considerations to be applied to proposed wind energy development so that local people have the final say on wind farm applications, fulfilling the commitment made in the Conservative election manifesto.
Subject to the transitional provision set out below, these considerations will take effect from 18 June and should be taken into account in planning decisions. I am also making a limited number of consequential changes to planning guidance.
When determining planning applications for wind energy development involving one or more wind turbines, local planning authorities should only grant planning permission if:
- the development site is in an area identified as suitable for wind energy development in a Local or Neighbourhood Plan; and
- following consultation, it can be demonstrated that the planning impacts identified by affected local communities have been fully addressed and therefore the proposal has their backing.
In applying these new considerations, suitable areas for wind energy development will need to have been allocated clearly in a Local or Neighbourhood Plan. Maps showing the wind resource as favourable to wind turbines, or similar, will not be sufficient. Whether a proposal has the backing of the affected local community is a planning judgement for the local planning authority.
Where a valid planning application for a wind energy development has already been submitted to a local planning authority and the development plan does not identify suitable sites, the following transitional provision applies. In such instances, local planning authorities can find the proposal acceptable if, following consultation, they are satisfied it has addressed the planning impacts identified by affected local communities and therefore has their backing.
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