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High Speed Rail Consultation – Chiltern Society response
The Chiltern Society is a registered charity and company limited by guarantee. Its objectives, as approved by the Charity Commission, include requiring it to encourage conservation, development and improvement of the amenities, areas of tranquillity and features of historic interest in the Chilterns, and to encourage high standards of planning and design in the Chilterns.
The Society, formed in 1965, now has over 6,700 members and about 450 volunteers who 'care for the Chilterns' in a wide variety of ways. Its area covers 650 square miles of the Chilterns across parts of four counties: Bucks, Beds, Herts and South Oxfordshire. The Society maintains a significant role in planning matters, at all levels of the planning system. It participates in national and regional consultation processes when the issues and outcomes are likely to have implications for the Chilterns.
The Society's formal position on High Speed Rail
The Society is not against the concept of high speed rail in principle. However, it is opposed to the construction of a high speed rail route across the Chilterns. It believes that it is not in the national interest for a high speed rail route to cross the Chilterns Area of Outstanding Natural Beauty.
Summary of the Society's position on the Government's HS2 consultation
The Society believes that:
Construction and operation of the proposed HS2 route would cause serious, irreversible harm to the special ancient countryside and landscapes of the Chilterns.
The current HS2 proposals are premature and unsound.
Fundamental weaknesses of the case for HS2 are that the HS2 proposals have been made in the absence of an appropriate national strategic policy framework and a failure thoroughly to evaluate alternative routes or scenarios that would avoid crossing the nationally protected Chilterns Area of Outstanding Natural Beauty.
A decision on the HS2 preferred route from London to the West Midlands should not be made before a comprehensive national policy framework is in place and a rigorous evaluation of alternatives has been conducted.
Q.1
This question is about the strategy and wider context:
Do you agree that there is a strong case for enhancing the capacity and performance of Britain's inter-city rail network to support economic growth over the coming decades?
This question is misleading due to its generality.
At the specific level, the Society believes that the current HS2 proposals are unsound and a strong case for them has not been made.
At the general level, the Society accepts that there appears to be a prima facie case for enhancing the capacity and performance of Britain's inter-city rail network, but that there remains huge uncertainty as to the best way of achieving that goal.
Absence of a national strategic context
1.1
The Society, as a founder member of the Right Lines Charter Group, believes that an efficient sustainable transport system is vital to Britain's prosperity and well-being. Reducing the damaging impact of travel on the environment and local communities by shifting journeys from road and air to rail needs to be a key priority. High speed rail (HSR) is only one option for increasing rail capacity, connectivity and the performance of the national rail network as a whole.
1.2
The Society believes that a 'strong case' for any particular HSR proposal will not be acceptable and demonstrable unless:
a) It has been set in the context of a long term national rail network development strategy and a wider national transportation strategic policy framework; both of which have been subjected to rigorous appraisal and testing through effective professional evaluation and fully open public participation.
No such context currently exists, nor is likely to for at least a year of two. Neither has there yet, therefore, been any opportunity for a comprehensive public debate on the wider national strategic context. The current HS2 proposals are therefore premature and consequently unsound.
b) A range of alternative scenarios has been studied in sufficient depth such that a short-list of alternative strategies and network development options has been rigorously examined and exposed to effective public consultation.
It is evident that the alternative route comparisons conducted by HS2 Ltd fall well short of this normal expectation for major projects.
c) It has been proven that the proposal has a high certainty of viability, manageable risks and will create significant net benefits for the national rail network as a whole.
Methodology and Approach
1.3
The Secretary of State has accepted that there is a once in a century opportunity to make fundamental structural improvements to the inter-city rail network and that it is important to get it right. He has recently made similar statements with respect to his current consultative proposals to develop a sustainable framework for UK aviation, but with the added proviso that it is important to take "the time necessary" to "ensure the outcome is a positive and enduring policy framework that will deliver the benefits of a flourishing … transport sector" .
1.4
That prudent approach contrasts starkly with the highly polarised approach that the previous government (Lord Adonis) adopted in commissioning the current HS2 project proposal, which the Coalition Government subsequently maintained.
1.5
The HS2 project has been described as a high level strategic assessment. However, the political drive behind it has distorted the nature of the work conducted and the proposal has taken on the air of a project that is far more mature and sound than is actually the case.
1.6
The genesis of the HS2 project stems from the very narrowly drawn remit agreed between Lord Adonis and the then Chairman of HS2 Ltd (HS2L). That remit was drawn up in the absence of a national strategic framework for rail network and transportation system development. It was also highly constrained by a number of "absolute requirements". Some of those have subsequently proved impossible to deliver or unviable. These factors alone render the current proposals unsound.
1.7
The clear consensus emerging from informed commentators is that the single option, 'predict and provide' approach, as initiated by Lord Adonis and continued as a matter of expedience by the present government, is inappropriate for such a major investment of public money. Moreover, for economic evaluation purposes, the project has been assumed to have a fiscal life-cycle of 60 years – an extremely bold assumption for a project with such a wide range of inherent uncertainties and risks.
1.8
There is inevitably a very wide profile of potentially high risks for any such single solution approach. The scale and depth of that risk profile are significantly greater if, as with the current HS2 proposals, the basic proposition is to aim for (and become dependent upon) the highest degrees of technological advancement and operational improvement. Furthermore, to focus on a dedicated high speed rail network, with very limited interconnectivity with the rest of the national rail network, immediately reduces the options for a fundamental change of network strategy should the chosen strategy fail or significantly underachieve.
1.9
Whilst the private sector might be prepared to undertake a high risk investment with these characteristics (although probably not in this case), it is highly questionable whether the public sector should entertain such an approach on the basis of a single scenario strategic level evaluation.
1.10
How does one avoid or minimise the impact of such potential pitfalls? The simple answer is by adopting a comprehensive scenario planning approach to evaluating different high-level strategic options (see responses to Q2 and Q3). This has the significant advantage of being able to test the relative robustness of alternative strategies against a comprehensive range of risks. In this manner, the sensitivity of shortlisted strategic options to potentially high risk key assumptions (e.g. the impact of value of time on forecast demand) provides greater clarity for decision making.
1.11
Studies by rail industry based HSR proponents and others in response to the HS2L proposals have highlighted the fundamental shortcomings of the very narrowly focussed approach to which HS2L was committed by the previous Government's Secretary of State for Transport. HS2L management has admitted that the narrow scope of the company's remit precluded consideration of a wider range of alternative strategic scenarios, as might normally have been expected for such a high level strategic review intended to explore such fundamental long term issues.
1.12
Several other key factors need to be borne in mind. First, HS2L was required to complete its work within the extremely unrealistic timescale of one year. This appears to have severely limited the depth and robustness of analysis. Secondly, serious consideration of key planning guidance/law seems to have been ignored, if it was considered at all (see response to Q.4). Thirdly, ministerial decision required HS2L to develop the concept of an Exceptional Hardship Scheme (EHS) to compensate people directly affected by publication of the single preferred route that was the outcome of the chosen approach. This emphasised the strong degree of political determination of the then government not to consider other strategic scenarios, seemingly on the grounds of expediency. Had a broader range of strategic scenarios and a fuller consultation process been considered, it is arguable that there would have been no need for the early introduction of an EHS scheme, which seems to have become a key reason why the present government appears opposed to any consideration of alternative approaches to meeting the country's future strategic rail network needs. This is despite pre-election statements that "all options would be considered".
Implications for Economic Growth
1.13
It is widely acknowledged that the assessment of the wider economic impacts of major transportation schemes is difficult to conduct with any significant level of confidence. A wide variety of complementary factors (such as the concentration and/or wider spatial dispersal of economic and housing developments) can have a crucial influence. Equally importantly, especially within this context, is the level and ease of connectivity between inter-city rail termini and the wider sub-regional hinterlands of those termini. Such factors raise deeper political and funding considerations than investment in an inter-city network alone.
1.14
One of the advantages of a comprehensive scenario planning approach is that the assessed benefits and disbenefits of different rail network and technology strategy options bring much greater visibility of the different advantages and risk profiles of different options. In such processes, the impact of a combination of uncertainty and potentially high risk assumptions on complex computer models can be exposed to more rigorous sensitivity testing than when used in a single option, predict and provide approach.
1.15
In summary –
The Chiltern Society believes that the whole approach adopted by the previous government to assessing the future need for high speed rail was fundamentally flawed. The adoption by the Coalition Government of the previous government's conceptual approach, on an expedited timeframe, has severely compounded the shortsightedness of the original terms of reference for HS2L. The net result is that a strong case for identifying the best manner by which the capacity and performance of the rail network as a whole should be enhanced has yet to be demonstrated and proven.
Q.2
This question is about the case for high speed rail:
Do you agree that a national high speed rail network from London to Birmingham, Leeds and Manchester (the Y network) would provide the best value for money solution (best balance of costs and benefits) for enhancing rail capacity and performance?
NO – In our response to Q1, we highlighted the need for two vital pre-requisites for determining the best manner in which the capacity and performance of the rail network could be enhanced:
a) The development first of a comprehensive national policy and strategy context against which to assess any specific high speed rail network proposal.
b) The need to adopt a strategic appraisal approach that comprehensively examined alternative approaches, preferably utilising broad ranging scenario planning techniques.
Since neither of these essential pre-requisites were met by the processes that led to the current HS2 proposals, it is impossible to judge whether the HS2 Y network option offers best value for money.
For additional reasons set out below, we believe that there are some strong grounds for asserting that the Y network proposal does not provide best value for money.
Y Network concept
2.1
In considering this question it is helpful to analyse the origins of the Y network concept.
2.2
The principal driver for HS2 was originally stated as being the need for additional passenger capacity between London and the West Midlands, due to perceived future capacity limitations between these two regions. The Memorandum of Association for HS2L states that the company's objects are the 'development of proposals for a new railway line from London to the West Midlands and potentially beyond'.
2.3
HS2L executives have made it clear that a stand-alone HSR line from London to Birmingham would not make economic sense. Indeed, HS2L's first report to Government (December 2009) stated that trains running off the high speed line onto the existing classic network was 'crucial to the business case'.
2.4
Following the Coalition Government's adoption of their predecessor's HS2 initiative, the vision and perceived benefits for the proposed HS2 network broadened. New emphasis was given to the wider transformational benefits that HSR could bring to the Midlands and Northern regions, particularly by improving interconnectivity within and between those regions and addressing inequalities of the North-South divide.
2.5
A key point arising from this is that, despite the original focus on a new London to West Midlands line, the case for a HSR network is not essentially about a route between London and Birmingham and the quickest way to get there, which is the main focus of much of the publicity surrounding this consultation. The underlying priority is to establish the most effective means of serving the English regions and major cities north of London, with the potential of extension to Scotland. Resolving the future capacity of rail routes between London and the West Midlands, in this context, is a subordinate, but nonetheless real, matter.
2.6
Whilst Birmingham should no doubt be integrated into any new HSR network, a proper strategic HSR network evaluation should comprehensively consider a wider range of options, than permitted by HS2L's remit, to achieve the Coalition Government's re-focussed wider transformational objectives. A Y network configuration may prove to be the best value option. However, there is growing evidence that alternative alignments of the leg of the Y (what might be regarded as the spine or trunk route of a future HSR network connecting London to the North) can offer significantly greater connectivity benefits and transformational opportunities than those achievable via HS2L's specific proposals.
HS2L's Terms of Reference
2.7
Study of HS2L's original remit reveals many of the constraints that led to their particular Y network proposal.
2.8
Among the 'Absolute requirements' specified were:
A 'Heathrow International Station'.
'No intermediate stations between Heathrow International and West Midlands'.
Demonstration that a 'Connection to HS1' was 'feasible'.
Requirements a) and b) predetermined that any spine route connecting the West Midlands to London must approach London from the West. They also effectively predetermined that the southern leg of any consequential HSR network would have to cross the Chilterns AONB and also large tracts of open countryside between the Chilterns and Birmingham. These requirements also compromised requirement c) and the prospect of an unconstrained connection between HS2 and HS1, which approaches London from the East. This in turn compromised the potential efficiency and future capacity for through service connections between points to the north of London and continental Europe.
2.9
Although not a 'fixed requirement', HS2L's remit included an aim to 'provide a costed option for passive provision for 4 tracks', because the 12 paths then envisaged as capacity for 2 tracks 'could quickly be filled' and it would be 'a great deal cheaper and quicker to lay 2 additional tracks on a safeguarded swathe alongside HS2 than to start from scratch on a second north-south alignment'.
2.10
This sensible future proofing aim had to be abandoned because it was not 'viable' to provide safeguards for 4-tracking on a route through the Chilterns AONB. Similarly, absolute requirement a) was also abandoned by HS2 in their initial report to the previous government, because 'the case looks weak'.
2.11
Despite HS2L's failure to meet these original key requirements and aims, and serious questions about the viability of a direct connection to Heathrow, HS2L and the Coalition Government have persevered with a Y network model based on a southern trunk route leg that approaches London from the West and crosses one of England's designated areas of the highest landscape value.
2.12
Evidence presented to the Transport Select Committee and to this consultation by other parties has cast doubt on whether HS2L's 2 track proposals are capable of satisfying the 36 train paths per hour capacity that the company has now assumed (which does not take account of future additional services to Heathrow). HS2L themselves have indicated that there might be a longer term need for a second HSR route from the North to London.
2.13
Given also the lack of a national strategic network context for HS2L's proposals and the absence of any comprehensive analysis of alternative scenarios, the combination of these factors must bring seriously into question the appropriateness of HS2L's approach to its Y network proposals. It can not therefore be assumed that HS2L's Y network proposals represent the best value for money solution.
Q.3
This question is about how to deliver the Government's proposed network:
Do you agree with the Government's proposals for the phased roll-out of a national high speed rail network, and for links to Heathrow Airport and to the High Speed 1 line to the Channel Tunnel?
NO – Whilst the principle of phased roll-out of major infrastructure projects is sensible, that presupposes:
a) That there is a well defined plan approved for the whole project programme: in this case, also in accordance with a clear national strategic policy context.
b) That all principal alternative scenarios, including design specifications, have been comprehensively examined.
c) That the risk profiles for the project programme have been thoroughly researched and fall-back strategies identified for all major areas of high uncertainty.
d) That there is a firm commitment to complete all interdependent phases of the programme or, at least, a high level of assurance that if the programme is not fully completed each completed phase of the project results in a viable and sustainable long-term beneficial outcome.
None of these criteria have yet been met by the current HS2 proposals.
A National High Speed Rail Network
3.1
The Right Lines Charter group has set out four key principles for doing High Speed Rail well. There has been wide endorsement of those principles.
3.2
The first principle says that HSR proposals need to be set in the context of a long-term transport strategy stating clear objectives. It is pointed out that the Government's proposals are not at present part of any long-term transport strategy or nationally agreed priorities. The Government has however announced a series of policy and strategy initiatives that, over the next two years or so, will contribute to formulating such a coordinated strategic framework. Until that framework is in place, it would be premature to confirm any decision on the form of a national HSR network. The current HS2 proposals would then need to be reviewed against the objectives of that framework.
3.3
There is emerging evidence that fundamentally challenges the philosophy and approach that underpins the current HS2 network proposals. Central to this is the debate about whether the 'dedicated' Very High Speed Rail (VHSR) network proposed by HS2L is the best way to proceed or whether the HSR network development should be more 'integrated' with the development of the existing national strategic rail network, possibly utilising slower speed HSR trains. The latter approach might still require sections of new HSR track, but would eventually enable many more city sub-regions to benefit from HSR network connections.
3.4
A number of alternative approaches submitted as evidence to the Transport Select Committee and to this consultation focus on alternative scenarios largely or in part based on an M1 motorway corridor alignment for the southern trunk section of a new HSR network. Those scenarios have network and potential wider impact advantages that should be tested (see also response to Q.4).
Link to Heathrow Airport
3.5
HS2L's work, the Mawhinney Report and various independent analyses have cast considerable doubt upon the viability of a direct link from the proposed HS2 southern spine route into the Heathrow airport complex. The results of the further work commissioned by the present government is not available within the timescale for this consultation. Evidence submitted to the Transport Select Committee challenges the HS2L capacity assumptions for the proposed HS2 southern trunk leg of the Y network. This raises further questions about the potential to mount additional services to Heathrow without compromising their HS2 inter-city service level and capacity assumptions.
3.6
A core political argument of Government for HS2 (in response to its policy decision not to build a third runway at Heathrow) is that it will facilitate the transfer of passengers to HS2 from domestic air services to Heathrow from the North of England and Scotland. HS2L suggests that their HS2 proposals will only be broadly carbon neutral, but even that depends on the assumption that vacated domestic air service slots at Heathrow will remain unfilled. Both these assumptions are fundamentally flawed.
3.7
Domestic flights into Heathrow are becoming less economic. When bmi recently pulled out of its Heathrow-Glasgow services, British Airways responded by increasing its services from London City Airport to Glasgow and easyjet increased its Glasgow-Gatwick services. International transfer passengers to/from Manchester and Scottish airports are far more likely to transfer to connecting flights to/from Continental hubs, enabling them still to check in their baggage at their originating airport, rather than carrying it onto an HSR train and then via additional modal interchanges to reach their departure terminal at Heathrow. Such practices are entirely consistent with Government statements about providing choice and putting passenger interests first.
3.8
An HS2 connection to Heathrow is unlikely to have significant impact on reducing carbon emissions from aviation. Any runway slots released would be reutilised by larger long-haul aircraft, unless prohibited by regulation – an unrealistic prospect, given current pressures and policies.
3.9
Whether the Government currently believes it or not, its recently launched consultation on a sustainable framework for UK aviation will inevitably lead to a review of its decision to oppose additional runways at Stansted and Gatwick airports. In which case, given the many challenges and likely fundamental changes facing the global airline and airport industries, it would be highly unwise to assume, for example, that the case for a HSR link to a twin-runway Stansted airport post 2030 would be less than that perceived for Heathrow in 2011. Current thinking reflected in HS2L's reports is unduly influenced by the traditional dominance of a Heathrow hub airport. Whether or not there are any new runways approved in future within the South-East, it is inevitable that there will be a major redistribution of air services between the major London airports over the next decade. Recent decisions by the Competition Commission will encourage that process.
3.10
This is another aspect of national transportation strategy that should be taken into account before deciding on the most appropriate strategy for a national HSR network.
Connections to High Speed 1
3.11
HS2L has proposed only a very restricted solution for connecting their West London orientated HS2 trunk route to HS1. This depends on utilising the heavily trafficked North London Line and accessing HS1 via a single track tunnel with a capacity limit of 3 trains per hour. This highly compromised and expensive fix stems directly from the 'absolute requirement' for HS2 to be routed to provide connection to Heathrow.
3.12
It raises a fundamental question about whether the UK's second HSR line should be optimised to serve Heathrow at the expense of an ability to provide a two track connection, with relatively unconstrained capacity potential, to HS1 and the Channel Tunnel. HS2L predicts only a low level of traffic demand for HSR through services from north of London through to HS1 and Europe. However, this raises an important issue of Government policy: should long term provision for a much higher level of through service capacity to HS1 and Europe from cities to the north of London be made? One would have thought that, despite HS2L's low demand forecasts, such provision should be made as a matter of public policy. Sub-regional and city authorities to the north of London will have views on these issues.
3.13
If the Government were to decide that greater priority should be given to a less capacity constrained and more direct HS2–HS1 through service link, it should commission a thorough examination of the options for developing or safeguarding a more effective provision for HS2-HS1 through services for the longer term. An obvious option would be to explore in greater depth the various proposals currently emerging for an HS2 southern trunk route alignment that approaches London via a more easterly alignment than the current proposal. An alternative, as hinted at by HS2L and others, would be to develop a second HSR route from the North into London. Either way, this issue and that of a Heathrow link are greater than just a question of project phasing and warrant a more fundamental re-examination of the alignment of any future HSR southern trunk route between London and the Midlands/North.
Q.4
This question is about the specification for the line between London and the West Midlands
Do you agree with the principles and specification used by HS2 Ltd to underpin its proposals for new high speed rail lines and the route selection process HS2 Ltd undertook?
NO – There are three major areas of fundamental concern:
a) The very high speed specifications for HS2 track and trains.
b) The conceptual approach of a segregated HSR network with minimal interfaces with the classic rail network system.
c) A failure to conduct comprehensive analysis of alternative network scenarios and route alignment options.
Very High Speed Specification
4.1
HSR covers a wide spectrum of different rail track and train design speeds.
4.2
The agreed speed objective for the new line in HS2L's remit was stated as 'likely to be designed to at least the maximum speed of HS1' (186 mph/300 kph). Emphasis was placed on the need to 'optimise journey time benefits balanced with operational energy costs and achievement of maximum capacity'.
4.3
Although the perceived need for additional capacity was the original driving force for the HS2 project, the strategic appraisal seems to have focussed in on a very high track speed specification (400kph), 'in line with designs for future routes in Europe', at a very early stage of the initial HS2L strategic appraisal. It is not clear to what extent, and to what depth of detailed evaluation, different maximum track and train speeds scenarios were tested. It is clear that this very high speed specification subsequently became a critical factor in the HS2 business case evaluation, because of the impact of time savings achieved for passengers on HS2L's rather bold assumptions about the valuation of time saved.
4.4
This apparent change of key driver, from capacity enhancement to very high speed, has had a profound impact. Most importantly, the achievement of very high speed and passenger time saving clearly became key determinants in the criteria for the initial comparison of route options from West London (Old Oak Common) to the outskirts of Birmingham.
4.5
The political requirement for a link to Heathrow already dictated that the new route would almost certainly have to cross the Chilterns AONB. The choice of a 400kph VHSR specification, with all its more demanding technical specifications and associated very high costs made it inevitable.
Segregated or Integrated HSR Network
4.6
HS2L was established to develop proposals for a new high speed railway line between London and the West Midlands. Its remit introduced a number of constraints that further limited the scope of its work, notably the requirement to provide a link to Heathrow. It is therefore understandable that the company did not spend much effort in addressing broader national rail network strategy issues and the potential role of different HSR scenarios within a network-wide context. Other studies on which the Government and HS2L have relied for assessment of alternatives were also limited in scope.
4.7
In essence, the HS2 concept has the nature of a discrete operational function in its own bubble isolated from the rest of the rail network, except for when its classic-compatible trains emerge from the bubble for onward journeys on the classic rail network. The fleet of trains that operate only within the bubble are even called the 'HS captive fleet'. The HS2 network concept, differs from the HS1 concept in that it is not proposed that slower HSR trains, such as the Javelin trains that switch between HS1 and the Kent classic rail network, be allowed onto the HS2 segregated network. Lack of this added functionality, which would have an impact on track capacity, effectively denies HSR service to many smaller cities and sub-regions in the Midlands and North.
4.8
The principle of a discrete HSR network concept that underpins HS2L's proposals is a valid approach to HSR operations, but it is only one approach. It has to be recognised that, from a national network strategy point of view, there are alternative concepts and underpinning principles that might equally exploit the benefits of HSR operations, but in a far more integrated manner with the rest of the rail network. Such alternatives could possibly yield much greater national benefit. This emphasises the major concern that, given the huge investment envisaged for the HS2 Y network, no comparative evaluation of such alternative scenarios has been conducted.
4.9
HS2L did not investigate more integrated approaches to using HSR to enhance capacity and performance of the inter-city rail network on a national scale. It was not remitted to do so. There has been no equivalent high level strategic appraisal to investigate whether an integrated approach, based on using slower speed HSR trains over a wider network, could produce greater and wider regenerative and transformational benefits than the isolated VHSR model which is the focus of this consultation. Any such model could still require sections of new HSR track, such as a strategic trunk route more closely integrated with the existing network. Other submissions to this consultation have explored such alternative approaches in some depth and warrant serious consideration.
Route Selection Process
4.10
The Society has already highlighted various aspects of the need for alternative scenarios and route options to the current HS2 proposals to be properly considered. It has stressed the absence of an appropriate national strategic context for decision making on such a huge generational investment. It has also described the heavy bias introduced into the methodological approach used by HS2L by the company's highly constrained terms of reference and the apparently obsessive focus on creating a very high speed HSR network segregated from the rest of the national network.
4.11
Two further aspects of the route selection process are also very worrying. First, is the extremely high level of the 'pairwise comparisons' approach used to shortlist potential routes from 'Old Oak Common to Birmingham'. This was conducted at an early stage of the 2009 study period against high level criteria that placed the greatest weight on engineering and construction feasibility and related costs. In contrast, despite strong representations during invited consultations with environmental bodies in 2009, environmental and spatial planning considerations were clearly only considered by HS2L at a very superficial level. This introduced further bias into the route selection process.
4.12
The recent submissions by other respondents demonstrate that there is also convincing evidence that the route selection process used by HS2L did not consider alternative route options closely aligned to the M1 corridor very seriously at all. This was surprising in view of the fact that the conventional wisdom in Europe is to give priority to locating new railway lines close to existing major motorway or rail corridors. However, no doubt this was mainly due to the fact that HS2L had already decided that the route should go via Old Oak Common, rather than directly to Euston or another London terminus. The 'M1 option' rejected at an early stage of the pairwise comparison process was not aligned to the M1, other than for a relatively short distance.
4.13
This failure to evaluate other route options is seriously compounded by the failure of HS2L, either at their own initiative or in response to the 2009 consultations referred to above, to produce a comparative evaluation of their preferred route option and an alternative that avoided crossing the Chilterns AONB. In failing to do this in a fully objective and rigorous manner HS2L, and subsequently the Government, have failed to demonstrate compliance with the provisions of Section 85 of the Countryside and Rights of Way Act 2000 and of Planning Policy Statement 7 (PPS7).
4.14
The former requires any public body to have regard to the special qualities of an AONB when undertaking its activities. The latter guidance sets out very high standards for ensuring that 'major developments', including those that 'raise issues of national significance', 'should not take place' in nationally designated areas such as AONBs unless they have been subjected 'to the most rigorous examination'. Such examination should include an assessment of 'the cost of, and the scope for, developing elsewhere outside the designated area, or meeting the need in some other way' as part of the need to demonstrate that the proposals are 'in the public interest'.
4.15
Neither HS2L nor the Coalition Government has produced evidence for public consultation that these important provisions of national interest have been met. Given the notice given to HS2L in 2009 that such evidence would be expected, it must be regarded as a blatant failure of public duty not to have done so. It is also counter to the Government's commitment to transparency.
4.16
It appears, from discussions with HS2L/DfT staff during the consultation process, that the defence for this fundamental omission is based either on the belief that these provisions do not apply to the circumstances of HS2L's work, and/or that they will be considered during the much later stages of the process. Neither of these arguments is acceptable on the grounds of public policy principles, or best practice, particularly as the Coalition Government has emphasised the importance of thorough public consultation in public statements and in the context of the Localism Bill.
Q.5
This question is about the route for the line between London and the West Midlands
Do you agree that the Government's proposed route, including the approach proposed for mitigating its impacts, is the best option for a new high speed rail line between London and the West Midlands?
NO – The Society has outlined above cogent argument why it can not be claimed that this is the best option for a new high speed rail line between London and the West Midlands. There may be a case for such a route, but that has yet to be proven.
In particular, the Society believes that:
a) No robust 'national interest' case for crossing the Chilterns AONB has been made.
b) The lack of rigorous evaluation of alternative scenarios/routes and the failure to evaluate, by a large margin, the full range of potential environmental impacts means that it is impossible to conclude that there is no better option.
c) The few general and specific measures so far floated for mitigating impacts across the AONB fall well short of what would be required, were the Government's current route proposals to proceed.
Proposed Route: the National Interest and the Environment
5.1
The proposed route across the heart of the Chilterns would have a devastating impact on the landscape and other widely treasured attributes Chilterns AONB.
5.2
AONB designation represents the highest national level of English landscape quality, equivalent to that for the National Parks. With that comes a 'national interest' obligation to provide the highest level of environmental protection (see response to Q.4). The landscape of the Chilterns AONB is also a unique part of the English heritage (see also response to Q.5). This uniqueness should be given special value in the weighing of the national interest benefits and disbenefits of such a major development right across the AONB.
5.3
HS2L's failure to address fully the national interest impact on the AONB is highlighted by their failure, before deciding on a 'preferred' route, to assess comprehensively the relative environmental harm caused by each of the three shortlisted 'feasible' routes that crossed the AONB.
Proposed Route: the National Interest and Wider Economic Factors
5.4
The remit for HS2L placed greater priority on linking to Heathrow than on achieving a link between HS2 and HS1. HS2L's work and report indicate that neither of these additions to their basic philosophy (of concentrating only on operating VHSR services exclusively between a few of the UK's largest cities) would be economic within their timeframe. The question of a future link to Heathrow remains wide open. HS2L was content to meet its remit on a HS2-HS1 link by providing for a highly capacity constrained, operationally compromised and relatively expensive proposal.
5.5
One is prompted to ask whether, if greater political weight were given to a HS2-HS1 link than to Heathrow, a more easterly route from a main London terminal to the Midlands would have resulted. We do not know. Such a scenario was not examined. Similarly, if HS2L had been asked to consider also a scenario that provided HSR services to a wider range of Midlands and Northern cities, than its Birmingham, Manchester and Leeds dominated scenario, how would the net Wider Economic Impact assessments have compared? Again, we do not know. However, various submissions to the consultation from pro-HSR respondents provide sufficient evidence to suggest that there are alternative scenarios that could widen the economic benefits and should be considered.
5.6
In these circumstances, and in the absence of a proper national strategic framework, it would be foolhardy to claim that the Government's proposed route is the best option.
Risk Profiling and Route Selection
5.7
Since the HS2L work was based on a single scenario approach, there has been no opportunity for rigorous comparative testing of a small range of different scenarios (which might include those mentioned above) to identify their different risk profiles. Neither has it been possible to judge how different scenarios might each impact, for example, on harm caused to the natural environment, on North-South divide issues and on the need for improved rail freight capacity and connectivity.
5.8
As mentioned earlier, the Government recently launched a two-year consultation programme on developing a sustainable framework for UK aviation. How can one judge at this stage whether compromising the country's new HSR network to serve Heathrow will be the best fit with a future South-East England airports policy strategy for the 2030s and beyond?
5.9
HS2L and the Government have been highly critical of alternative scenarios based on further upgrades of the WCML. Opponents of this scenario say it would only buy capacity into the mid-2020s. However, there appears to be a broad consensus that many of the infrastructure proposals identified for developing WCML capacity will be needed in any case well before HS2 could be operational. One risk reduction strategy therefore might be to delay a decision on the HS2 southern trunk route alignment until it has been possible to conduct more comprehensive evaluations of alternative scenarios, to ensure that the best risk profiled option for improving connectivity to the wider Midlands and North of England is selected.
5.10
An obvious vulnerability of the currently proposed Y network approach is the risk that, having built a VHSR link to Birmingham (which can not be justified on a stand-alone basis), national economic funding priorities are such that the remaining legs of the Y network are never completed. An HSR southern trunk route that was more directly integrated with the existing rail network would at least provide the prospect of continued rail service and wider economic development to intermediate cities and sub-regions.
Proposed Approach to Mitigating Impacts
5.11
It is not possible to mitigate satisfactorily the harm that will be caused to the ancient countryside of the Chilterns AONB by the proposed route. Even so, one consequence of the failure to investigate alternative approaches is that the normal evaluation convention of avoid, mitigate, compensate has not been followed.
5.12
The Government and HS2L have introduced a number of changes to the details of their preferred route published in March 2010. The most significant of these, in relation to mitigating impacts on the cross-Chilterns sections, were trailed at meetings with HS2L during 2009. These included more tunnelling, green bridges and deeper cuttings. However, the combination of all of the mitigation concepts floated to date, do not come near to compensating for the irreversible harm that construction and operation of the proposed cross-Chilterns HSR line will cause. Construction of the route itself would cause wide ranging environmental, economic and social harm to the basic fabric of the area. Hardly any detailed construction proposals or related information is publicly available. Neither is the proposed Constructors Code of Practice.
5.13
The Government's approach to mitigation is still very immature and lacking in detail.
Q.6
This question is about the Appraisal of Sustainability
Do you wish to comment on the Appraisal of Sustainability of the Government's proposed route between London and the West Midlands that has been published to inform this consultation?
YES – However, the Society will defer to the professional advice of the Chilterns Conservation Board, The Wildlife Trusts, Bucks County Council and the Woodland Trust on wildlife, historic environment and other environmental parameters that fall within their specialised competencies. The Society's volunteers have assisted several of those bodies in compiling the data that underpins their specialist submissions.
The Society will limit its contribution to this question to topics in which it has particular expertise, provided by nationally recognised experts in their field.
Chilterns – a Cultural Landscape
6.1
Government is rightly tasked with protecting the Nation's most valuable landscapes through the designation of National Parks and Areas of Outstanding Natural Beauty. One of the Society's deep concerns about this very lightweight Appraisal of Sustainability (AoS) is that that the value of the Chilterns as a cultural landscape has been effectively ignored. To fully appreciate the long-term sustainability impacts of the current proposal, the AoS cannot be restricted to the confines of a route. It must address the wider damage in terms of regional integrity and to 'sense of place'. This includes the continuum of exceptional high quality traditional Chilterns' countryside views along and across its chalk stream valleys.
6.2
The Chilterns were first named by the Anglo Saxons in the 7th century and are a distinctive region of ancient countryside with a collection of characteristics that combine together in a way that is not found anywhere else. The enduring regional identity of the Chilterns has been recognised in numerous popular, academic and government studies, from Massingham's 1940 Chiltern Country to official studies by the Countryside Commission and English Nature who used it as a pilot study for their 'Natural Areas' programme.
6.3
The Chilterns Area of Outstanding Natural Beauty designation is restricted to two blocks of the highest quality English landscape. It does not include the major towns and villages or the smaller more fragmented areas of lower, but nonetheless still high, quality landscape.
6.4
The Misbourne Valley is the least spoilt of the five major troughs that cross the Chilterns. Despite claims from the DfT and HS2L otherwise, it is not a main transport corridor. The low trafficked A413 that runs along it mainly connects villages such as Wendover and Great Missenden to small towns such as Amersham and Aylesbury. Chiltern Railways also run a relatively unintrusive, low frequency, local branch line that terminates in Aylesbury. The most intrusive feature is a national grid power line, which ideally should be undergrounded. However, just because a non-strategic road, a local railway line and a string of pylons have already been built, does not mean that the landscape value of the rural valley is lowered to a point where anything goes.
6.5
HS2L's claims that the current route has been mitigated to avoid these small Chiltern settlements, rather than create more blight on alternative routes that may be more built up (such as the M1) is to entirely miss the point. In precious rural environments it is the countryside that has the greatest value, and that is not easily monetised.
6.6
In contrast, the type of urban fringe developments that are not far from the existing noise corridors of motorways and existing rail tracks tend to have less cultural heritage value and noisier environments. For that very reason, good compensation payments can more often satisfy landowners and householders who are forced to relocate.
6.7
The rural Chilterns sub-region has come under pressure from all sides as growth areas have been designated surrounding it. Profound changes have taken place in the rural landscape and the built environment on the fringes of the AONB, adding to the pressures within it. However, as these growth areas expand further their rapidly growing populations will need to find quiet open spaces where they can relax and engage in the types of peaceful countryside recreation that the Chilterns is renowned for. That is a key role foreseen for the Chilterns by local and regional planning authorities. The Chilterns has one of the densest footpath networks in the country. It is important to protect the integrity of this special place in a sustainable manner and to ensure that any reduction in landscape quality in the Chilterns heartland is not penalised further because of negative responses to damage already done.
Geology and Hydrology
6.8
Dr Haydon Bailey, the Chiltern Society's Geological Adviser, has undertaken studies for the Society of the Geology and Hydrology impacts of constructing a HSR rail route across the Chilterns. He has considered all of the originally proposed 'feasible' cross-Chilterns routes proposed by HS2L and also a nominal M1 alignment that might reflect some of the alternative proposals proposed by other consultation respondents.
6.9
For any of the cross-Chilterns routes considered, the underlying "chalk" geology is basically the same. In all cases the majority of the tunnelled sections will be through the Lewes Nodular Chalk and the underlying Newpit Marly Chalk formations. Both formations are relatively easy to tunnel through, being largely free of flint bands. Flints are not absent, particularly in the Lewes chalk, but they get progressively less common the deeper into the underlying geological section any tunnel is cut. The Newpit chalk is effectively flint free, making it a prime choice for tunnelling.
6.10
The proposed HS2 route has a 9km tunnel beneath the Misbourne valley which is also crossed by the line of the ice age proto-Thames. This will have disrupted a large lateral belt of the chalk surface between the Chalfonts, which means that tunnelling will suffer increased geotechnical problems along this part of the route due to groundwater loss and potential tunnel collapse. This is a feature not encountered on any other route as none of the other routes tunnel beneath the bed of the proto-Thames.
6.11
A basic rule is that the shorter the amount of tunnelled section cut, then the cheaper and easier to construct the railway will be. The preferred route was no doubt selected partly for that reason. It has 9km of tunnel from Denham to Old Amersham. Much of the rest of the Chilterns section is in deep cuttings. Construction would cause major impact on water resources and high costs due to tunnelling within the water table.
6.12
Any of the identified feasible routes would impact on the underlying hydrology and groundwater resources. These potential effects are outlined in Dr Bailey's geological studies and summarised for the proposed route as follows:
Probable major impact on water resources drawn from the Misbourne valley. There would probably be a loss of surface flow in the River Misbourne down the whole valley. Plus there would be the potential disruption to three or four public water sources in the valley with consequent financial implications of compensation to water suppliers.
6.13
Detailed assessment of any alternative M1 route that extended through the Chilterns would clearly depend on the actual alignment chosen and the location and extent of any tunnelling. However, Dr Bailey makes the following general comments based on his studies of the area:
An M1 alignment would likely cross the headwater catchment areas of the Ver, Lea and Flit rivers. Maximum impact would be in any tunnelled section where at least one, but most likely two, public water sources would be disrupted and potentially lost, with resulting financial implications of compensation to water companies involved. Both the Ver and Flit would likely be crossed with the track above surface. The impact should therefore be minimal, but there is the potential for pollution both during, and subsequent to, construction. The head waters of the Lea River are likely to be forced further downstream.
Other general issues:
6.14
Chalk Waste – increased tunnelling means the removal and disposal of chalk waste. It will be difficult to utilise chalk waste produced simply to backfill raised sections of the track. Consequently, there will be a large amount of white chalk spoil. When the Channel Tunnel was constructed a completely new area of dry land was created along the northern margin of the English Channel. This option is not available and the spoil will have to be disposed of with the associated costs of transport.
6.15
Environmental impact – sections where the route is kept at surface in order to minimise cost will have adverse environmental affects. River valleys over which a track is constructed will be damaged and water flow will be disrupted and potentially liable to pollution. In the case of the Misbourne Valley route, tunnelling could destroy the already vulnerable water course entirely, causing total loss of existing wildlife habitats.
6.16
Dr Bailey concludes that:
All the feasible routes identified by HS2L, including the preferred route, require extensive construction via tunnels and deep cuttings in order to cross the Chilterns and access the Vale of Aylesbury to the north. It will be impossible to do this without:
Potentially causing long term damage to the Chalk aquifer system (this applies to all routes).
Causing pollution of the main water supply system for the north western Home Counties area or to the northern Chiltern area – with the subsequent need to source water from other, much more distant parts of the country, at considerable additional cost.
Running the risk of serious ground collapse in areas with deep sections of weathered chalk.
The loss of surface flow in river systems and the destruction of the adjacent habitats.
The potential aesthetic loss of internationally scarce chalk stream rivers, such as the Misbourne or part of the Lea (alternative M1 alignment) and their replacement by dry valleys.
The loss of both biological and geological SSSI's and a Regionally Important Geological Site should the preferred route go ahead.
6.17
Finally, in the Hydrogeology chapter in the recently published Geology and Landscape of Hertfordshire (Catt et al., 2010) the authors note that "Chalk streams are part of a globally rare habitat, which is found only in some of the chalklands of northwest Europe..." and here we are discussing the wholesale destruction of one or more of these environmentally sensitive areas.
Q.7
This question is about blight and compensation
Do you agree with the options set out to assist those whose properties lose a significant amount of value as a result of any new high speed line?
NO – Whilst the Chiltern Society does not have a view on the personal Exceptional Hardship Scheme, it is very concerned about the blight and wider implications for the rural economy of the Chilterns.
7.1
This Chilterns area is first and foremost a farming and forestry region and the rural economy has suffered a series of significant declines over the last half century or so. Much of the region is a marginal farming area with its steep slopes and thin, stony chalk soils, which is very good for biodiversity but hard work for farmers. The few more financially successful farms are largely confined to agri-businesses on the better soils on the valley floors and the Chilterns' dip slope. The combined effects of global competition, along with EU policies such as set aside and diversification, has meant that farmers have been dividing up their land and selling it off as they struggle to make ends meet. Where economic difficulties persist, there is a trend to sell off significant proportions of land as "amenity land", rather than agricultural land. This particularly applies where small areas of land are adjacent to new development. Often this leads to the development of, for example, 'horsiculture' related land uses with a consequent degradation of the land and loss of chalkland biodiversity.
7.2
There is a strong association between profit and farm size: scale really does increase economic viability. The traditional small to medium sized farms (50 to 100 hectares) of the Chilterns struggle to survive and pasture is the least profitable endeavour. There has been a marked decline in the number of very dairy herds. In some areas, cows have given way to horses and fields have been fenced into paddocks.
7.3
Farmers are the major stewards of the countryside and the impact of HS2 through the region will exacerbate the problems that they are already experiencing. A long swathe of land will be fragmented, access will be more difficult and the noise and visual impact will reduce the attractiveness of the stewardship schemes and tourism opportunities that farmers currently use to top up their incomes. Severance of farm holdings adds disproportionately to operating costs. In addition the Secretary of State's plan to 'plant two millions of trees' will undoubtedly occur on farmland and valley sides adjacent to the line. Whilst this raises a host of other questions about type of trees, obscuring traditional long distance heritage views, impact on bodiversity etc., the potential cost and means of acquiring land for such purposes need to be defined.
7.4
It is extremely important that the compensation scheme takes into account not only the loss of the value of the land immediately affected, but all the wider damage not immediately adjacent to the route that will impact on rural businesses. The lack of transparency in the consultation and poor environmental assessment thus far gives the Society little faith and even less hope of an objective and fair outcome.
Note:
The Society's formal position, consistent with its obligations under its charitable objectives, is to oppose any new High Speed Rail (HSR) route across the Chilterns, not just across the Chilterns AONB. This would include opposing any routes across the South Chilterns, as proposed by some HSR proponents, or across the North Chilterns, whether or not they crossed the nationally protected AONB.
The Society's principal aim is to ensure that the least harm is caused to the Chilterns and to the Chilterns AONB in particular.
CHILTERN SOCIETY
July 2011
The Chiltern Society
White Hill Centre
White Hill
Chesham
Buckinghamshire
HP5 1AG
01494 771250
