One of our partner organisations has highlighted the obvious and significant impact upon health – physical and mental health – which planning and other aspects of local policy can have on individuals and groups. This has become more obvious to all of us over the last two years, with exceptional restrictions and guidance being put in place for everyone.
The government guidance on the need to undertake HIA as a key element in public policy is clear. It is good practice.
The guidance can be found by clicking here.
In our local context, the absence of good communication between the local authorities and local residents is a potential contributory factor to stress, ill-health and a sense of powerlessness. For those with existing conditions or those who are more vulnerable due to poverty or disabilities, the impact is all the greater.
We invite comment – particularly in the context which has raised the profile of this issue – which relates to the significant amount of major new developments supported by Folkestone and Hythe District Council. The extent to which planning policy and major decisions are underpinned by HIA is of particular public interest.
Update: a series of well-reasoned and well-informed comments have been added on this topic – see below.
A summary document containing some of the key arguments in favour of a Health Impact Assessment has been compiled by a member of the Leas Residents Action Group – which has been pressing for better communication. The document can be downloaded by clicking here
3 thoughts on “Health Impact Assessments (HIA)”
There was already a problem with parking provision on The Leas before there was even a mention of the Leas Pavilion proposals. I wrote to the council (parking department) in January 2019 about how difficult it was becoming to park on The Leas, even with a permit or a blue badge. There are many disabled people living within the local community with blue badges, who need to park close to their homes. I pointed out to the council that sometimes disabled people had to park way away from their homes, often on dark winter nights in adverse weather conditions. This is a significant health issue. My original email was never replied to. Indeed, I was asked to send it in again, but was still ignored. Now I understand the possible reason why this was the case; namely that there were intentions to take away even more car parking facilities to service local development.
After the planning proposals were published, people were warning on the portal about parking chaos and lack of provision in the area; especially with the loss of the car parks. In the summer of 2021, I sent a photo in of the busy car parks one week before they were closed, and enquired as to where local residents were going to park and what the council intended to do to mitigate for the potential chaos?
Eventually, after writing in several times and complaining to the Ombudsman, we received a most indifferent response from the planning officer, showing a complete lack of understanding of the problem: –
The loss of the car parks was dealt with in the Committee repost. They were private car parks, not Council owned. As they were private car parks, the Council had no control over their long-term use, and could not therefore object to their loss as a parking resource. They could have been closed at any time by the owner of the site.
So whilst the FHDC couldn’t object, how does this mitigate for all the additional cars who would have used the car parks, now parking on The Leas instead – especially on busy summer days? The council did not say they would be providing extra provision. And what about the visitors to residents in the Leas Pavilion? 91 flats will mean a lot of visitors, many of whom will also be parking on The Leas.
This situation meant that the existing parking bays on The Leas would be even more important. The residents can ill afford to lose any more spaces. After the pavements were taken an officer from the Streetworks team came to the site and we were categorically assured that the parking bay in front of the Pavilion would not be taken by the development. This turns out to be untrue. Moreover, in our recent response from KCC Highways after photos were sent in of damage to vehicles, the response was: –
Thank you for the photos regarding the damage to parked vehicles. It is curious that one of these incidents occurred even after the pedestrian barriers were removed. It may be that suspension of the western bay where the van was parked in front of Prior’s Lees is the only way to prevent this damage in the short term. I will pass this on to the parking team at Folkestone and Hythe District Council for their consideration. Any suspension of parking bays will be handled by the parking team at Folkestone and Hythe District Council (FHDC). This is yet another parking bay, actually opposite No.1 The Leas, which is absolutely vital for the residents.
Both KCC Highways and FHDC seem to be prepared to close vital parking provision to service the development without any mitigation whatsoever for existing residents. Where are elderly, disabled and vulnerable residents supposed to park if there is not enough provision? People have started to not go out unless absolutely essential, for fear of losing their precious space. This is clearly not a healthy state of affairs. There are health repercussions in not providing enough provision for the vulnerable and disabled. This is why these issues are enshrined in law. And surely this demonstrates even more clearly the need for an HIA and an EIA?
DANGEROUS ROADS AND PAVEMENTS SURROUNDING THE LEAS PAVILION SITE
+ RESPONSE FROM SENIOR PLANNING AT KCC HIGHWAYS
• The situation regarding the roads and pavements surrounding the Pavilion has already caused chaos, damage and danger to life and the plan moving forward will only exacerbate the situation. The pavements were taken away from the local community in June last year. Confusing and inadequate signage was put up by the street team at Highways. There were many concerns and objections. We sent in photos and videos clearly showing the situation and warned of many impending problems, some of which have already indeed ensued.
• When we complained about the loss of the pavements and people forced in to the road, KCC responded: – “A walkway is being placed on Longford Terrace to accommodate for pedestrians. This will ensure pedestrians have access up Longford Terrace and do not have to walk in the road. This will be done by tomorrow morning at the latest. The traffic management company will be carrying out daily site checks to ensure the site safety. A pedestrian diversion with proper signs will be placed out, so pedestrians know to cross over to the path on The Leas and to ensure people do not walk in the road like you witnessed.”
• So after a couple of weeks, a hazardous and unworkable temporary walkway was installed on Longford Terrace, which could only be used by able bodied people (and then only in daylight hours). There was no provision for the elderly, the disabled (many with sticks, walkers, wheelchairs and buggies), or Mums with push chairs. Indeed, these vulnerable groups were still being forced to walk in the road. Moreover, the majority of people did not cross over to the path on The Leas, as this is effectively the long way round.
• Delivery lorries were constantly hitting the barriers or having to move them to turn in to the road. There was damage to vehicles. 3 residents lost driver’s side wing mirrors that were caught by turning lorries, including my own wife’s Motability car. This was a most costly and stressful experience.
• After many complaints that were largely ignored, it had to be explained to KCC Highways that this was an area with many disabled, sight-impaired and elderly people and that the walkway was both dangerous and actually illegal; as it broke both the Equality act (section 149), the council’s Public Sector Equality duty (PSED) – as the provision was not applied equally to all; and it was also a contradiction of KCC’s “Safety at Street Works and Road Works, A Code of Practice’ document.” There were no lights on the hoardings for 6 weeks, despite the KCC cabinet officer writing to us stating that this was a legal requirement.
• By the end of 2021 the walkway was removed by KCC Highways, but still left no provision for the elderly, disabled, sight-impaired (many with sticks and walkers, wheelchairs and buggies) and Mum’s with push chairs being forced to walk in the road. We were back to the same issues as when the pavements were taken 6 months before. So if there was a need for this provision (i.e., a ‘safe’ walkway) in the first place after the pavements were taken, why had no viable alternative been applied?
• And it made little difference to the problems, as during February a lorry smashed up a car during manoeuvres out of Longford Terrace. There is so little room on this turning and the hoardings have obscured the view as well. The idea that this little road will be used for construction traffic as well as Iceland lorries, next to a pedestrian entrance for predominantly elderly and disabled people is not only very badly thought out, but actually completely unworkable and just plain dangerous.
• We have recently received an answer from Senior Management at KCC Highways regarding the difficulties they are facing with trying to implement a plan that doesn’t actually work without creating complete chaos. We are grateful to this manager for at least being honest about the situation. So KCC Highways have now confirmed: – (Italics = KCC comments, Bold = Our response comments)
1) It is fair to say that access to and around this site is less than ideal. The historic road widths and rather random narrow and missing sections of footway are really not helpful to anyone, especially when part of this network is further restricted. So completely inadequate planning then? Surely, all the more need for an HIA?
2) Unfortunately the problems faced in the construction phase of a project are not considered a material objection to a planning proposal as it is only a temporary issue. Nevertheless, a temporary issue that will severely impact on our community for over 2 years! All the more need for an HIA.
3) No one is trying to pretend that this project will go ahead without having an impact, clearly there will be some degree of disruption, this is inevitable. So we are left with trying to make the best we can from a less than ideal situation. Surely a further admission that the planners have got it wrong? All the more need for an HIA.
4) Regarding the indicated closure of Cheriton Place and access issues for Pleydell gardens. The construction management plan as approved via FHDC planning being slightly inaccurate with reference to Cheriton Place/Pleydell Gardens does not affect or dictate which part of the road we as local highway authority will allow the contractor to close. Now an admission of inaccurate information with no understanding that “which part of the road” or indeed any part of the road, has a massive bearing on people’s lives. All the more need for an HIA.
5) With reference to the weight limit on Longford Way, I queried this myself with our Highway Structures Team in the early days of the planning application being live. I found that the weight limit has no traffic regulation order attached to it (i.e. is not legal) and it is thought that the signing was originally put in place many years ago as a quick fix temporary deterrent to protect a weak cellar under the road. This cellar/road was subsequently strengthened and the signing is now not required, just a left over from a historic issue. I had asked for it to be removed so as not to confuse issues locally, but this clearly hasn’t happened yet. So why were we told by a member of the Streetworks team when the pavements were first taken, that “the hoarding bollards were put on the pavement outside the car park rather than inside, because they are worried about a huge hole beneath the car park and they’re worried about it collapsing and taking the road with it”? We have sent in photos of the ground sinking within both car parks. And where is the evidence that the cellar was strengthened?
6) Obviously there is always the risk of conflicting vehicle movements. But as the Iceland deliveries will not be high in numbers every day and the contractor will have trained banksman on site to help vehicles manoeuvre, I would hope any problems can be minimised. Surely ‘hoping’ is a euphemism for just guessing? The correspondent clearly has no understanding of what goes on in Longford Terrace nor that actually there are deliveries taking place at all times of day. The idea that there will be a trained banksman on site surely only alludes to the expected chaos?
7) The construction management plan is not so detailed that it has to explain every last detail of operation. We cannot move forward assuming that site delivery drivers and site contractors have no common sense. Surely more guessing? Who is to say that delivery drivers will have common sense or not? And even if they do, there is little room for manoeuvre. After all, there have been 4 vehicles damaged already. Did these drivers lack common sense? Three of them just drove off! And this is without added construction traffic – where there will be many different sized vehicles.
8) There will be many different sized vehicles serving the site and early conversation between contractor and supplier/driver is key to ensuring they arrive at the most suitable part of the site; larger vehicles are likely to use the Cheriton Place side of site and Leas frontage. So will there also be ‘early conversation’ between contractor and supplier/drivers AND Iceland, McDonalds and independent delivery drivers not associated with the development? How could this possibly work?
9) The supervising contractor liaising with supplier to make sure they arrive when the site frontage and access to site gates is clear is a key element of smooth operation and they will want to do this, it is in their own best interest. Likewise the issue regarding the height restriction on Longford Way. That’s not to say that they won’t ever get a rogue delivery driver just randomly turning up unannounced, but nothing that relies on people with free will is completely fool proof. So there is also the problem of height restriction in Longford Way and the issue of ‘rogue’ delivery drivers? There are all kinds of delivery drivers turning up unannounced throughout the day!
10) Regarding the temporary footway problem, we are aware that the temporary pedestrian guard railing was not working as well as we would like considering the limited space. With the construction project building right up to the back of the footway, as is their right, we have no choice but to close the footway completely. It is simply not possible to construct the building of this size and have the footway adjacent to the site open. So they have admitted that the temporary walkway didn’t work, that there is not enough space and that they had no choice but to close the footpath. “Not working as well as we would like” is a serious understatement, given that many disadvantaged people couldn’t use it at all and it was constructed on 2 levels – half on the pavement and half on the road. It was self-evident that it was an untenable idea. So who made the final decision to install a completely useless walkway?
11) One of the problems we face (not just in this location) is that pedestrians on the whole are straight line creatures. They often ignore signing or diversions if it means they have to take a longer route. So maybe this accounts for why the majority of people are walking in the road along the Leas in front of the Pavilion rather than crossing the road to walk on the sea side of The Leas. It’s clearly just not what people would do, as it is the long way round and means crossing a road which can be busy and where traffic often speeds along (despite the 20mph limit). But it seems in this case it is the fault of the pedestrians being ‘straight line creatures’ and not the ill-thought out scheme accompanied by untenable diversions and inadequate signage?
12) However, taking account of the additional problems caused by the temporary footway barrier, our Streetworks Team have agreed an alternative which is to ban pedestrians from Longford Terrace all together and re-route them along Longford Way, returning to The Leas on the western side of Cheriton Place. Even this route is far from ideal, but on balance better than what we started with. It is not only far from ideal, but very much
the long way to send people along Longford Way and not a safe route either. It is a totally unfeasible plan. And what does the terminology of ‘ban’ demonstrate regarding the prevailing attitudes of the decision makers? Longford terrace is used by a large number of pedestrians. The only access for the residents of Prior Lees. Rear entrance for No.1 the Leas. And main access for all those who live in the houses on the west side of the terrace. It is access to Sandgate Road and nearby shops, access to the rear entrance of Iceland and access to the Leas. It is a right of way on the land registry and simply cannot be closed to pedestrians, as they are actually residents of Longford terrace and there are many disabled, elderly, partially-sighted and vulnerable people whose main access this is. We now understand that pedestrians will be ‘banned’ from only the West side of Longford Terrace, so the residents of Priors Lees and No.1 The Leas will still have access to their gates and their entrances. But does this mean everyone will be forced down Longford Way upon exiting? This would be extremely challenging for the elderly and disabled.
And this is also the only entrance for drivers from both buildings, home deliveries, postal services and emergency vehicles. Moreover, many residents use disabled buggies, wheelchairs and walkers, and need space in Longford Terrace. The road is used all the time by pedestrians and if people are returning home from Sandgate road they enter Longford Terrace to reach the entrances to Priors Lees (their only entrance) and the back entrance to No.1 The Leas (used all the time by many residents).
Given all the information above, does it not seem clear that Longford Terrace could never be used as a safe and workable construction site entrance, nor closed to pedestrians; and is therefore part of an inadequate and dangerous plan? There simply isn’t enough room.
Moreover, why has the fact that disabled people actually need pavements and walkways been an afterthought of the planning process? Why has there been no provision built in to the plan? Is this because the health and well-being of the local community have been largely ignored? Hence the necessity (even at this late stage), for a proper independent health impact assessment.
Finally, as provision also seems to be applied by FHDC and KCC Highways in a most unequal way (such as the totally ineffective and inadequate pedestrian walkways and ‘far from ideal’ solutions to roads and pavements), causing danger to vulnerable people; is there not also the need for an Equality Impact Assessment (EIA), so that provision connected with this development is applied equally, without prejudicing disadvantaged groups and subjecting them to additional dangers and anxieties?
To FHDC, KCC Highways, Gustavia, FLC, and everyone else involved directly or indirectly with the Leas Pavilion development: –
On behalf of the residents surrounding the Leas Pavilion; given the reality of the problems and anxieties that have already been experienced and the potentially massive difficulties to come, we call again for a Health Impact Assessment (HIA) to determine the short and long term effects of this major development upon the existing local community.
Before construction has even begun, there have already been significant detriments to the community; causing inconvenience, distress and dangers to life and property.
There have also been a series of arbitrary and contradictory decisions by planning and highways officers; often without proper expert knowledge or effective consultation.
The situation is both chaotic and confused. We have many elderly, disabled and partially sighted people in this community, who are living in constant uncertainty and fear and many are struggling to cope with the situation. Some people are actually having to consider moving. They feel that their concerns have been largely ignored. There is dismay and resentment within the existing community, with genuine fears about the chaos it will cause, and is already causing. There is an overwhelming feeling of uncertainty. Moreover, the construction plan just exacerbates the situation, as it completely unworkable without severely disrupting the local area and seriously blighting the lives of the existing residents.
AVOIDING A HEALTH IMPACT ASSESSMENT
The policy HW2 criteria for “improving the Health and Wellbeing of the Local Population and Reducing Health Inequalities” (so greatly needed on this particular project), has been avoided on a technicality of being 9 units under the required threshold. The HIA was bypassed with the contention that 100 units is required for an assessment whereas this construction only has a proposed 91 units. So how does one ascertain the definition of a unit? Is this measured by dimensions or just flat numbers? If this is the case, then when the flats are huge, this could potentially be the equivalent of say 150 units where the flats were smaller. This development is a huge construction of 91 large flats (aka units). Thus it appears to the residents that it’s been set up like this to deliberately avoid the need for an HIA. And despite the health impacts being pointed out on the portal at planning stage, being sent to the local government ombudsman, being sent on a number of occasions to FHDC planning and parking, KCC Highways and the developer; they have been brushed aside as simply material considerations with indifference and a glaring lack of duty of care.
THE NEED FOR A HEALTH IMPACT ASSESSMENT
With the instigation of such a massive and forced change to people’s lives, and the issues surrounding it; surely it’s essential to hold a proper and effective HIA to mitigate for these changes, and address the health and well-being of the existing community before embarking on such a huge construction project? For many in the community, their physical and mental health are already being compromised. Even if not ‘technically’ required, surely an HIA is the sensible, responsible and moral thing to do?
As a planning condition, the Construction Management Plan (CMP) was imposed on the developer by FHDC to “ensure a suitable means of construction, ensure highway safety and to protect the amenity of neighbouring residents”. The community does not feel safe with the construction, nor with highway safety; and nor do we feel that our amenities are being protected.
1. Dangerous roads and pavements surrounding the site: –
The situation regarding the roads and pavements surrounding the Pavilion has already caused chaos, damage and danger to life and the plan moving forward will only exacerbate the situation. We have recently heard from a senior development planner at KCC, who has stated: – It is fair to say that access to and around this site is less than ideal. The historic road widths and rather random narrow and missing sections of footway are really not helpful to anyone, especially when part of this network is further restricted.
He acknowledged other problems we are facing; essentially demonstrating that the plan really isn’t fit for purpose. See Appendix 1: Roads and Pavements.
2. Lack of parking provision, especially for blue-badge holders: –
There was already a problem with parking provision on The Leas before there was even a mention of the Leas Pavilion proposals. I wrote to the council (parking department) in January 2019 about how difficult it was becoming to park on The Leas, even with a permit or a blue badge. This correspondence was ignored.
After the planning proposals were published, people were warning on the portal about parking chaos and lack of provision in the area; especially with the loss of the car parks. There are many disabled people living within the local community with blue badges, who need to park close to their homes. Now not only are the car parks gone and it’s becoming very difficult to ever find a space, the intention is now to remove more parking bays from The Leas and create a most difficult situation. People have started to not go out unless absolutely essential, for fear of losing their precious space. This is clearly not a healthy state of affairs. There are health repercussions in not providing enough provision for the vulnerable and disabled. This is why these issues are enshrined in law. And surely this demonstrates even more clearly the need for a HIA?
See Appendix 2: Parking Provision.
3. Loss of light and panorama for people with serious visual impairments: –
The planning case officer’s report analysed the potential impact on both No.1 The Leas and Priors Lees and concluded, “due to the location of this development, and its orientation it is not considered that there would be any mutual overlooking, any creation of a sense of enclosure or loss of sunlight/daylight… There would undoubtedly be a change in outlook, particularly for the residents of No.1 The Leas, but this in itself is not a ground to refuse”.
In this ‘consideration’ did the planning case officer seek proper expert opinion regarding sense of enclosure or loss of sunlight/daylight? Did she actually look in to problems surrounding sight-impairments and get medical advice before reaching her conclusion?
I have asked this question 4 times now and nobody has replied. There are many within this community with serious sight issues. We have people in our building with macular degeneration and my own wife has serious uveitic glaucoma. We personally came to live on the Leas 6 years ago, specifically for my wife’s eye health. The clarity of light and the large panorama + the fresh sea air were the main factors in regard to this.
The loss of light aspect and sunsets will have a major health impact upon my wife, as the panorama of light and view is vital for her particular visual impairment. The same would apply to those suffering from other visual impairments, thus many people’s health will be affected. Furthermore, why did the case officer say that there will be no mutual overlooking when the building will be 9 storeys? How can this possibly be true?
I have also pointed out that stress exacerbates glaucoma. This has been documented and put in writing by our Doctor’s and surgeons and sent to FHDC and the developer, only to be ignored. In view of the number of visually impaired people within this community, we call for an HIA to ascertain the problems and what can be done to mitigate or at least compensate.
Whilst we recognize that there is ‘no right to a view’ under current legislation, it has become obvious that planners and developers are using this ‘flaw in the law’ so to speak, to completely disregard the needs of people they are building adjacent to. The lack of consideration has become intolerable and this development is a prime example where the needs of the existing community have been completely ignored. Hence the need for an HIA.
My wife and I run an online charity resource called Glaucomarize.org, for people all around the world suffering from glaucoma and other sight impairments. We have compiled an article regarding visual panorama and light aspects for those with sight impairments.
See Appendix 3: The Big Sky
or online at https://glaucomarize.blogspot.com/2022/01/the-big-sky.html
4. Dangers of dust and overheating
To avoid all the dust (and the noise) from this construction, people in our building facing west will need to close their windows during the day. Especially as the prevailing wind is South-West. Therefore if the windows are open, the dust will blow straight in the windows, as our building overlooks the proposed development and is only a few yards away. Moreover, as the sun shines powerfully through the windows during the height of the day, this will be absolutely intolerable and could actually result in heat stroke. In the recent heatwave, it was very challenging – particularly for the elderly and disabled members of our community.
To mitigate for this heat, blinds and curtains will need to be closed in the daytime. People will then be deprived of light and air during the day and will be way too hot. This is a potentially life threatening health impact. There are also people with lung conditions in this community who could be dangerously impacted by this dust and heat. Our Doctors have written expressing grave concerns regarding these health impacts – particularly breathing and respiratory. And despite being pointed out on a number of occasions, the council and developer have chosen to ignore these serious issues, brushing them off as being mitigated for in the construction plan. These are serious and neglectful oversights. Our concerns are NOT melodrama. They are an honest appraisal of the situation and for this alone there needs to be an HIA.
5. Loss of peace and quiet
This will obviously be a very noisy construction, going on all day and everyday (except Sundays) for over 2 years. See above regarding the closure of windows. As well as the sea air and clarity of light, many folks moved here to retire, (in many cases to convalesce) and for the wonderful peace and quiet. And like many folks here, my wife and I are no exception. We currently enjoy peace, tranquillity and the sound of the sea. In our case, we work from home and I personally run a small music studio. So in our case, I will no longer be able to work effectively in the day. There are others who work nights, so they will have trouble sleeping. Moreover, as they intend to build on Saturday mornings, we will lose the peace and quiet of the weekend. Even when the beach development below us has been rather loud, we were consoled by the fact that on a Friday at 5.30pm, all noise stops, peace is restored and the weekend begins. This is something else that is being taken from us. Something actually very important for folk’s well-being. Most of us came here for peace and quiet and peace of mind, many retired. What price peace of mind? Well at least if an HIA were held (even at this late stage), these issues could be addressed, even if they can’t be entirely solved. To ignore these problems without further examination and consultation, is to condemn the existing community to chaos and danger, coupled with anxiety and stress.
6. Mental and Physical Health and Well-Being
For my friends and neighbours representing our community, it has been most perplexing as to why our worries have been constantly disregarded and actually just brushed off as “material considerations”. There has been a constant and wearisome pattern of being ignored, misleading information and changes without consultation. It really upsets people and affects their minds and well-being. Especially as this is accompanied by a feeling of helplessness, with life-changing decisions being made without proper deliberation, nor indeed effective consultation. The fiasco over the tree that everyone was told by FHDC was saved, only to find out that it was to be destroyed after all and nobody actually in the end had a say. Does anyone making these decisions ever stop to think of the repercussions on people’s well-being? After all this is our little community and that tree meant a lot, as we are a conservation area. It was symbolic of at least something that would remain. The community have felt that they were misled. If local decisions being made by officers actually made sense, more people would be accepting and not constantly having to query the decisions.
Dealing with the councils and developers over these matters has taken up massive amounts of time, impacting heavily on people’s working and social lives. This in turn is already taking its toll on people’s mental and physical well-being. Folks are exhausted after such a long pandemic, but here we are doubly tired and weary; trying to get a workable plan put in place and accountability from the very people (i.e, our local councils) who we should be able to rely on and trust to look after our existing community, as well as looking after the developers’ interests.
I personally know many people in this community, and I can absolutely confirm that events are taking their toll on the mental and physical well-being of many. And there are many residents in this area in high-risk groups. It certainly feels like this also for my wife and I. And folks are tired, stressed out and scared that their way of life is about to be taken from them. Fear, stress and anxiety are now recognized as ‘killers’ and there have been many initiatives put forward regarding this in recent times. Protection of vulnerable groups is enshrined in law in the Equality Act, the Disability act and in the council’s own codes of practice. These are further reasons for an HIA.
We have contacted our local GP surgery, where our Doctors are concerned not only about our health and well-being, but also the whole community. We received a letter which ended:-
“I hope you can appreciate the impact on existing residents of areas where major building works are planned and will do your best to mitigate this.” This mitigation can only be properly planned and assessed by conducting an HIA.
Finally, we respect that there is development everywhere, and that people don’t always agree or accept the decisions of planning officers or developers. But the health and well-being of the existing community must be treated as a higher priority. So we call again for a proper HIA and a review of the CMP – especially the highways and pedestrian chaos.