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We would ask about your response B2CT3032 of 4/04/2023, on what you covered in your review and what you mean by “the impact on public health should be minimal”. Your letter says you reviewed the documents submitted in support of the application". Did this review cover the plume modelling adopted and the results for the selected pollutants as enhanced at nearby hillside homes? Did you consider ultrafine particulates, in comparison with ordinary incinerators and best abatement technologies ? Seeing no reference to PHW's 2017 advice on the same incinerator that the pollutant levels should comply with the Minister's policy to be as low as reasonably achievable, was this accidentally overlooked? If it has not been dropped, would you review whether the unusually short stack near hillside hopes at higher elevation can meet the "reasonable" criterion? Secondly, what is meant by the word "minimal"? The planning requirement is no risk to human health; does "minimal" cover those most sensitive and vulnerable to air pollutants? Previous measures of harm from incinerator emissions have been "extremely small" and "not a significant risk to public health" (PHW 2019). Does your 'minimal' allow a slightly increased number of birth defects, which SAHSU's lead Paul Elliott accepted in 2019 ? |
If PHW has guidance on this rather technical area with definitions of significance etc, we should be pleased to receive a copy. In any case we'd ask for a fuller explanation of your 4 April letter.
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Thank you for your recent request dated 11th May 2023. As you are seeking clarification on some of the points that you raise from the report, much of what you are asking does not fall within the bounds of Freedom of Information because the information you request is not ‘recorded information’ and therefore your request is refused on the basis that Public Health Wales does not hold this information. Under our duty to advise and assist however, I can provide the following response that you may find of assistance. The report produced by Public Health Wales was provided to the planning authority. If you have any concerns about the information in the report and its impact upon any planning process, you should direct those concerns to planning authority. |
Public Health Wales published a position statement on incineration emissions and health effects and concluded that emissions from modern, well-managed and regulated incinerators are not a significant risk to health. This position statement is available here; https://phw.nhs.wales/services-and-teams/environmental-public-health/air-quality/incineration-and-health-view-january-2020/#:~:text=Emissions%20from%20modern%2C%20well%2Dmanaged,by%20are%20likely%20very%20small
If you are unhappy with the service you have received in relation to your request and wish to make a complaint or request a review of the decision, you should write to the Corporate Complaints Manager, Public Health Wales NHS Trust, 3, Number 2, Capital Quarter, Tyndall Street, Cardiff, CF10 4BZ.
If you are not content with the outcome of your complaint or review, you may apply directly to the Information Commissioner for a decision. Generally, the ICO cannot make a decision unless you have exhausted the complaints procedure provided by the Trust. The Information Commissioner can be contacted at:
Information Commissioner for Wales
2nd Floor
Churchill House
Churchill Way
Cardiff
CF10 2HH
Telephone: 029 2067 8400
Email: wales@ico.org.uk