1.3.6 This states that there is some flexibility to alter both the horizontal and vertical alignment of the route. While this may be acceptable generally this is not acceptable in an AONB. As an example, Grim’s Ditch, a scheduled ancient monument, is already impacted by the proposed scheme. Moving the line to the west could create a further loss. There is also flexibility to move the vertical alignment a maximum of three metres upwards. This is also unacceptable in an AONB, where raising the line could add considerably to the visual and noise impact. If these are not prohibited, at least they should be subject to agreement with the relevant local authority.
2 - Overview
2.1.3 purports to set out the villages in the area. However, both Little Kingshill (within 1km of the proposed route) and Prestwood have been omitted. Prestwood is the largest village in the area, being approximately three times larger than Great Missenden.
2.1.5 fails to recognise the A4128 as a major road. This runs from the A413 to High Wycombe.
2.1.6 is misleading as it omits Little Kingshill (approx 800 inhabitants) and Prestwood (approx 9,000 inhabitants). It is important to understand that these communities are integrated with the other communities listed. Including these two communities will at least treble the working population.
2.1.7 Little Missenden School caters for 4+ to 7+ not 3-9 as stated. There is an infant school and pre-school in Hyde Heath. In Little Kingshill there is a combined school. Prestwood has a post office and a number of shops. There are three schools, a primary and a junior, and Prestwood Lodge, a school for boys with behavioural and emotional issues, two doctors' surgeries, three dentist surgeries, a chiropractor and a chiropodist.
2.1.8 The list of centres for other services should include Wendover and Aylesbury.
2.1.9. Hyde Heath has a church, St Andrew’s, linked to Little Missenden Parish Church. Ballinger has a church, St Mary’s, linked to Gt Missenden Parish Church. (These have been recognised in 5.3.4 and 5.3.9) Little Kingshill has a Baptist Church. Prestwood has three churches, Holy Trinity C of E, a Methodist Church and a King’s Church.
2.1.10 fails to list the Weights and Measures Gym in South Heath, Great Missenden Cricket Club, Little Missenden and Hyde Heath Cricket Clubs. There are also Cricket Clubs in Little Kingshill and Prestwood which also has a leisure centre, and a range of clubs covering soccer, judo and gymnastics for both children and adults. In addition there are open spaces in both Little Kingshill and Prestwood with playgrounds. There are also allotments in both communities.
HS2 construction traffic to and from the construction compounds in this area will cause congestion and delays to many people using the main roads as well as the local roads in the area.
2.3.27 Little Missenden vent shaft satellite compound
Accessed via A413, A40, M40.
Traffic using this route would meet up with vehicles from CFA8 adding to the congestion along the A413 Amersham Bypass.
2.3.34 Chiltern tunnel north portal satellite compound
Accessed via an upgraded access track to Mantle's Wood via Hyde Heath
Road, B485 Chesham Road, Frith Hill, A413 and then A40 and M40 and/or
A355, A40 and M40.
Traffic using this route would meet up with vehicles from CFA8 adding to the congestion along the A413 Amersham Bypass as well as the A355 through Beaconsfield
2.3.46 South Heath green tunnel (south) satellite compound
Accessed via the B485 Chesham Road, A413, A40 and M40 from the east; and the A413,A355, A40 and/or B4009, A4010 and M40 and/or B4009, A4129, A418 and M40 from the West.
The route via the B4009, A4010 and M40 will have major impacts along roads not designed the high levels of HGV traffic. Princes Risborough town centre as well as congested roads through the outskirts of High Wycombe would be particularly badly affected. This is the main route for ambulances travelling from High Wycombe to Stoke Mandeville hospital. The B4009, A4129, A418 and M40 route would have serious implications for Thame.
2.3.59 South Heath green tunnel north satellite compound
Accessed via Frith Hill, B485 Chesham Road, A413, A40 and M40 from the
east; and the A413, A355, A40 and M40 and/or A413, B4009, A4010 and M40
and/or A413, B4009, A4010, A4129, A418 and M40 from the West.
See 2.3.46 above.
Below is a chart summarising the disruption to footpaths in CFA 9. This shows the extent of the disruption in a way that is not obvious in the ES. Please see also our comment in our response to Question 4 – Route Wide effects.
|Ref||Footpath||Temporary diversion||Permanent diversion||Comments|
|2.2.30||LMi/||No diversion needed, but there will be landscaping|
|2.3.39||LMi/17||1,500m||South of Portal||Via Bullbaiter’s Lane|
|2.3.39||LMi/21||Open||450m||Realigned to LMi/17|
|2.3.39||GMi/23/6||100m||Permanent existing route|
|2.3.39||GMi/23||50m||700m||Realigned via LMi/17|
|2.3.39||GMi/27||400m||150m||Via Hyde Lane bridge|
|Via Chesham Rd and Hyde Lane Via Hyde Lane bridge|
|2.3.39||GMi/33/3||Open||50m||Via Hyde Lane bridge|
|2.3.51||GMi/28||400m||Reinstated||Kings Lane, Chesham Rd|
|2.3.51||GMi/79||400m||Reinstated||Kings Lane, Chesham Rd|
|2.3.51||GMi/80||400m||Reinstated||Kings Lane. Chesham Rd|
|2.3.64||GMi/13||Open||750m||Via GM/12 overbridge|
|2.3.64||GMi/12||100m||Reinstated||Via GM/12 overbridge|
|2.3.64||GMi/2||Open||550m||Via GMi/2 overbridge|
Below is a tabulation of the work camps proposed for CFA 9, again shown in a form which highlights the enormity of the disruption to the area, which isn't immediately apparent in the presentation of the ES.
|Ref||Name||Time open||No. of workers||Comments|
|2.3.27||Little Missenden Vent||6¼ years||30-65||Managed Chiltern Main Compound|
|2.3.34||Chiltern Tunnel north portal – civils||4¼ years||25-55||Managed Chiltern Main Compound|
|2.3.43||Chiltern Tunnel north portal – rail||2 years||20-25||Managed Chiltern Main Compound – rail|
|2.3.46||South Heath Tunnel south||7¾ years||110-135||Managed Small Dean Viaduct Compound|
|2.3.56||South Heath Tunnel north – rail||1¾ years||25-45||Managed Chiltern Main Compound – rail|
|2.3.59||South Heath Tunnel north – civils||3¾ years||25-40||Managed Small Dean Viaduct Compound|
|Total Workers – civils||190-285|
|Total Workers – rail||45-70|
Below is a tabulation of the properties to be demolished in CFA 9, which demonstrates – in a way the ES fails to do – the significance of demolition in a close-knit rural community.
|Ref||Road / Area||No. of residential properties||No. of outbuildings||No. of commercial properties|
|2.3.39||94 King’s Lane||1||5|
|2.3.39||90 King’s Lane||1|
|2.3.39||86 King’s Lane||2|
|2.3.39||Weights & Measures Gym||1|
|2.3.39||National Grid Pylons||2|
|2.3.62||National Grid Pylons||1|
|2.3.62||Mulberry Park Hill||1||4|
2.3.82 states that inert excavated material (spoil) will be placed on land at Hunt’s Green Farm in CFA 10. This is unacceptable in an AONB. The landscape should not be reshaped to accommodate excess spoil it should be removed from the AONB.
A better alternative would be to avoid the AONB altogether or at least to tunnel underneath to avoid changing this designated landscape.
2.3.85 Table 3 states that 6,976,960 tonnes of material will be excavated in CFA 9. As solid material this will be approx 2,800,000 m3 with bulking up this will be close to 4,000,000 M3. This is a huge amount of spoil to dispose without creating a completely different land contour.
2.4.2. The first services will leave Euston at 05.00, thus passing through the Chilterns at 05.20. The last train into Euston will arrive at midnight, thus passing through the Chilterns at 23.40. With up to 18 trains per hour, this will substantially reduce the peace and tranquillity of the AONB. The trains will also introduce light pollution at night from both the carriages but also from the pantograph.
2.4.7 sets out that the maintenance regime will be at night starting at midnight and finishing at 05.00. This will involve noise e.g. from grinding rails, diesel engine movements etc and lighting.
Community Forum Engagement
The Society has had representatives at the Community Forum meetings for CFA 9. These have been an almost complete waste of time. HS2 refused to appoint an independent minute taker which meant that there was always disagreement over exactly what had taken place at the meetings. Minutes taken by both parties always differed leading to much wasted time at subsequent meetings. They also failed to respond to a number of requests.
2.5.4 contains the main concerns of the forums, and are still valid as there has been very little change in the proposed scheme.
2.5.5 talks about the consultation on the Draft Environmental Statement. This was full of errors, inconsistencies and ‘this will be dealt with in the Final ES’. It is apparent that no notice has been taken of the responses to that consultation.
2.5.6. The HS2 staff who attended the forums were either supercilious or were not allowed to engage in a serious debate about anything. The Area Manager's main concern was to avoid agreeing to anything.
Extended Chiltern Tunnel
The various alternatives looked at have all been rejected on cost grounds although:
2.6.11 recognises the environmental, cultural and heritage benefits that would derived from a fully bored tunnel to the northwest of Wendover.
What has not been recognised is that the essential nature of the AONB would be preserved. The social and economic damage through the disruption of up to seven years with construction and loss of visitors has also been ignored.
Raising the alignment by five metres reduces the cost of construction as stated in 2.6.32 and 2.6.34, but increases the environmental impact of visual, noise and light pollution.
In a large number of sections the catenary towers have become visible. Where bridges could have followed the contours of the land these are now generally raised, adding a visual distraction to the landscape. The opportunity to create wide green bridges has been lost, which would not only accommodate PRoWs, but would also allow room for animal migration paths, which the proposed scheme ignores completely.
Leather Lane is a sunken lane, a very ancient form of byway and typical of the Chiltern landscape. It would be preferable for this type of landmark to be retained. A fully bored tunnel would achieve this.
3 - Agriculture, forestry and soils
3.2.3 sets out an assumption that agricultural land disturbed through construction of the route will return to pre-existing quality. This needs to be assessed on a field by field basis as disturbing the underlying soil can change drainage patterns and introduce a change in the chemical balance of the land, eg. when applying chalk to a previously acidic soil. Also this is subject to the Code of Construction Practice being observed properly, which was not the general experience with HS1 in Kent.
3.3.20 notes that prehistoric cross-ridge dykes suggest that a pattern of trackways had been established before Roman times. These ancient patterns are rare and need to be preserved for future generations.
3.3.23 notes that approximately 17% of the study area, i.e. within 2km (3.2.2) of the proposed route, is wooded and that as the national average is 10%, this makes woodland a resource of low sensitivity. This is a fatuous comment. The UK is under-forested compared with the rest of Europe. The country needs a greater density of forest to help with CO2 reduction. As such woodland is a receptor of high sensitivity. As most of the woodland is ancient woodland, this makes it even more sensitive as a receptor.
3.2.25 Table 9 sets out an assessment of the permanent impact. Again the assessment of the impact is called into question, by the moderate adverse effect on Hyde Farm. Not only is a large part of the holding taken but the farm will be on the side of a 25m deep cutting with up to 36 trains per hour passing. The same applies to 94 King’s Lane, Bury Farm and Mulberry Park Hill.
3.3.26 Table 5 shows the holdings within the 4km wide zone. This comprises 21 holdings totalling 1,509ha.of which 15 have not been approached by HS2 Ltd. This again shows how little effort has gone into establishing the baseline
3.4.6 The scheme design seeks to reduce structural disruption, as far a reasonably practicable. What does this mean?
3.4.7 says that restored land will be subject to five years of managed aftercare, meaning a further period of disruption, although necessary.
3.4.8 169.9ha of agricultural land will be needed during the construction period, of which 144.2ha will be BMV land. Only 65.8ha of this will be restored, leaving a permanent land take of BMV land of 78.4ha. This represents a substantial loss of precious land.
Table 7 sets out the impact on the 21 holdings. Of these the report in 3.4.16 considers that 15 holdings will suffer major/moderate or moderate effects during construction. However, the ratings are suspect as, for example, Elwis Field Farm, where 100% of the land is required, but this is only rated as a moderate adverse impact. This calls into account the whole of the assessment of impact.
3.4.17 states no farm enterprises are particularly sensitive to noise or vibration during the construction period. However only 8 owners have been interviewed and a number of the holdings have horses, which are sensitive to noise. There is also no mention of the impact on Chapel Farm, which lies immediately adjacent to the proposed route. Again the quality of analysis and opinion is called into doubt.
3.4.20 Table 8 shows the permanent land take which includes 98ha of farmland and 13.8ha of woodland. 3.4.21 states that BMV land is a receptor of moderate sensitivity in this study area. What this means is that because there is a comparatively large amount of BMV land in the study area, the impact of a loss is moderate. However, nationally BMV land is a receptor of high sensitivity. Using this interpretation the impact is a major adverse impact. This again demonstrates the unreasonable assumptions used in assessing the impact of the proposed scheme.
3.4.23 states that the report assumes that the land taken for the South Heath tunnel will be returned to agricultural use, however some of this may used for woodland, thus increasing the amount of BMV land lost.
3.4.24 sets out the loss if woodland as 13.8ha, which is assessed as insignificant, as there is a lot of forestry in the area. Refer to 3.3.23 above on the unrealistic assessment of the loss of woodland. In addition the woods being lost are ancient woodland, which even this ES agrees is irreplaceable.
3.4.25 shows that a residential property will be demolished at Middle Grove Farm, but this does not appear in the above list shown in: 2.3.49 Table 2: Demolition works at South Heath green tunnel satellite compound and Chilterns main compound.
This in another example of the inadequacy of the assessment.
4 - Air Quality
4.2.3 states that the degree of significance of air pollution is dependent on the number of receptors nearby. Thus less than 10 properties, within 20m of a site, heavily impacted by dust, is considered insignificant.
4.4.6 Although admitting there are a number of properties that will be directly impacted, the conclusion is there is no significant impact.
5 - Community
5.3.1 The baseline data only covers 1km from the proposed scheme. However this underestimates the impact on the surrounding communities as communities in the Misbourne Valley are closely inter-connected. (See comment on 2.1.3 above)
5.3.5 fails to mention, two pubs, village hall, school and church in Little Missenden.
5.3.7 fails to mention a large builders’ merchant and a turkey farm in Hyde Heath. In addition the annual craft fair will lose its site.
5.4.4 The conclusion of no temporary effects on Hyde Heath and Little Missenden is completely ridiculous. The pubs at Hyde Heath and Little Missenden derive a reasonable amount of business from walkers, who will be deterred from using the area, because of the construction. The construction traffic accessing the Chiltern Tunnel portal will use Hyde Heath Road. This will impact connectivity, access to the Misbourne School and Great Missenden station. Little Missenden will be impacted by the construction traffic using the A413.
5.4.11. The conclusion that there will be no temporary impacts on Hyde End is fatuous. The village will be heavily impacted by construction traffic accessing the Chiltern Tunnel north portal. The disruption in accessing the facilities in Great Missenden will have a severe impact. Travel to schools in Great Missenden and Aylesbury will be impacted, and possibly to Chesham with delays to school buses.
5.4.22. The opinion that the diversion of Frith Hill will be a minor adverse isolation effect is to ignore the reality, that an additional 400m will add 10 min each way to school children’s walk to school.
5.4.32. No temporary effects on Great Missenden. There will be a significant impact on traffic on the A413. This will cause traffic to back up in Great Missenden between 07.00 and 09.00 and in the late afternoon. Businesses in Great Missenden will be impacted by the loss of tourism based on walkers, who will be put off accessing the area because of construction. The construction has also blighted property in the area, impacting estate agents’ and solicitors’ business.
6 - Cultural Heritage
6.2.4 states that not all areas of the survey identified in the archaeological risk model were available for survey. Another example of incomplete survey work. We suggest that work should be completed before second reading.
6.3.4 demonstrates the poor quality of the survey work in that Great Hundridge Manor has been misspelt as Great Humbridge Manor.
6.3.5/6/7 list non designated archaeological remains which lie wholly or partly in the proposed scheme. This risks losing three assets of high value, five of moderate value, seven hedgerows that are historically important, and a further seven considered to be of low value.
6.3.8 lists 23 historic buildings whose settings are likely to be impacted.
6.4.27 assesses the impact on the setting of Grade II listed Hyde Farm and Sheepcotts Cottage as a moderate adverse effect, which has to be the understatement of the report. Both these properties will be on edge of a 25m cutting.
6.4.28/30 describe impacts on the settings of Grade II listed Cottage Farm and Woodlands Park, Grade II listed Bury Farm, Grade II listed Hammondshall Farm. All of these are ‘considered’ moderate adverse impacts. This is a complete under valuation of these buildings.
6.4.33/34 set out further work needed to assess the impact on heritage assets. This should be completed and consulted on before the second reading of the bill.
6.5.3 sets out the permanent impact from operation, which are considered moderate. Again a totally unrealistic assessment.
7 - Ecology
7.2.4 Significant areas not accessed for ES. As some of these are ancient woodland, and could contain protected species, survey should be completed before Second Reading
7.3.3 lists designated sites. These are summarised in the following table:
|Name||Area (ha)||Designation||Location||Type of Woodland|
|Weedon Hill Wood, High Springs, Ostlers Wood||49.9||LWS / BAP||Adjacent to Little Missenden Vent shaft||Ancient|
|Mop End Lane||2.5||LWS||Adjacent to land west of Shardeloes Lake||Hedgerow|
|Mantles Wood||20.5||LWS / BAP||Chiltern Tunnel site||Ancient|
|Hedgmoor / Farthings Wood||12.9||LWS||Chiltern Tunnel site||2.6ha ancient / Woodland|
|Sibley’s Coppice||7.5||Habitat of principal importance / BAP||South Heath Tunnel||Ancient|
|Rook Wood||30.9||LWS||Next to ecological compensation site||Ancient|
|Hyde Heath Common||5.2||BNS. Habitat of principal importance / BAP||Next to ecological compensation site||Woodland and grassland|
|Hyde House Wood||18.9||BNS. Habitat of principal importance / BAP||Next to ecological compensation site||Woodland|
|Hyde Lane Verge||0.4||BNS||Next to ecological compensation site||Hedgerow|
|Jenkin’s Wood||3.1||Habitat of principal importance / BAP||Adjacent to Proposed Route||Irreplaceable Ancient|
|Havenfield Wood||2.9||Habitat of principal importance / BAP||Adjacent to Proposed Route||Irreplaceable Ancient|
|Woodland on Route||44.4||Impacted|
|Woodland||105.3||Next to ecological compensation site|
||Adjacent to Proposed Route|
|Total at risk||155.7|