Select Committee Evidence
Below, we reproduce the Chiltern Society's evidence to the Transport Select Committee, which is meeting to consider the future of high speed rail services in the UK.
See the Transport Select Committee reported (Nov 2011) here.
Q1 – What are the main arguments for or against HSR?
To answer this question meaningfully it is essential to distinguish between the concept of High Speed Rail (HSR), the proposed HS2 project and the issue of whether the latter is an effective response to the Government's case for the former.
1.2 HSR covers a wide spectrum of different rail track and train design speeds 1. If there is a demonstrable case for HSR, one key question is 'what design speed concept(s) will provide the best strategic fit and value for money for England, Wales and Scotland?'
1.3 The Chiltern Society is not opposed to the concept of HSR. It is though strongly opposed to the currently proposed HS2 project, which has been evolved through a highly flawed, and arguably unlawful, process. Moreover, the HS2 project has been proposed in the absence of a soundly developed national strategic context against which to test its soundness in terms of fitness for purpose. The Society is drawn into this debate because, as a direct result of these process failures, an HSR route through the Chilterns Area of Outstanding Natural Beauty (AONB) is proposed. This has been done without conclusive demonstration, as required by planning guidance 2 and best practice, that no alternative that avoids the AONB is possible to meet the (currently undefined) 'national interest' need for an HSR network.
1.4 The Society is prepared to accept that there are prima facie arguments for reducing rail travel times between major cities and, importantly, improving connectivity to and between major centres in the English Midlands and the North. Achieving these objectives is likely to require the use of one or more forms of HSR. By definition, the overlaying of a separate network of new 'dedicated' Very High Speed Rail (VHSR) track proposed by HS2 Ltd (HS2L) and DfT severely limits the number of major centres that can access and benefit most from HSR. In contrast, an 'integrated' approach to accommodate slower speed HSR trains as part of the development of the existing national strategic rail network would eventually enable many more communities to benefit from HSR. This could still require sections of new HSR track, such as a strategic 'spine' route integral with the existing network.
1.5 The HS2L/DfT HS2 proposals were founded on the presumption of future capacity restrictions on the West Coast Main Line tracks. Value of time and 'wider economic impact' (WEI) assumptions have been used to justify these proposals. The value of time assumptions used have been discredited 3 and there is no apparent robust evidence base to justify the WEI claims. At best, the HS2 economic case remains unproven.
1.6 Interestingly, the HS2 proposals are based on the 'dedicated' VHSR network concepts mainly used in non-European countries such as China where the populations served are separated by very long distances. In European countries where the major centres are not as closely located as they are in Britain, the preference has been for the 'integrated' network approach, with a consequent wider spread of benefits. By this comparison, the HS2L/DfT proposals do not seem fit for purpose.
1.7 It also seems perverse that the principal cause of the future capacity problems perceived for WCML arises mainly, not from the growth of long distance inter-city travel, but from rail industry responses to an increasing and extending demand for peak hour commuter services that are currently very heavily subsidised. This in turn distorts the sound economic provision of rolling stock assets and acts against the 'work-closer-to-home' trends, central to regional planning over recent years, of encouraging a reduction in commuting distances on sustainable development grounds 4. Government policy on the sustainability of commuting and subsidised pricing of commuter train services should be part of the strategic context against which major rail development options are tested.
1.8 It is self evident that the ultra high investment required for a 'dedicated' VHSR network will be far more sensitive and vulnerable to 'predict and provide' traffic forecasts (as underpin the HS2 proposals) than applying the same risk factors to an 'integrated' model for strategic development of the national rail network. The latter would have far more scope and flexibility to adjust to failure to achieve estimated traffic levels and operating costs.
Q2 – How does HSR fit with the government's transport policy objectives?
2.1 The short answer is that the Government has yet to produce a coherent set of transport policy objectives that would provide the comprehensive strategic context against which HSR proposals (such as HS2) can be tested and judged.
2.2 The Government recently launched a scoping consultation on its future sustainable aviation strategy 5. Its draft proposals for a National Policy Statement on National Networks are still awaited. Other initiatives, including work on delivering a sustainable railway, are understood to be in the pipeline. These will eventually help create the framework of a (currently non-existent) sustainable National Integrated Transportation Strategy. It is foolhardy prematurely to propose what would in effect become the spine of a national VHSR network for the next century (i.e. Phase 1 of HS2 between London and Birmingham) and take a decision on it prior to taking account of the outcomes of this programmed range of new transport policies and consultations.
2.3 Unlike the HS1 route, the 'dedicated' southern spine route of HS2 will not be available to slower speed HSR trains. With an 'integrated' approach based on slower speeds, there would be far more flexibility to use HSR trains to connect to intermediate stations and to cities linked to the HSR spine via the classic railway network.
2.4 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. 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 that, for example, the case for a HSR link to a twin-runway Stansted post 2030 would be less than that perceived for Heathrow in 2011. If the country needs a new HSR spine track south of the Midlands, would it not be prudent to locate its southern approach to London where it could facilitate easier access from the North to a range of major transport nodes in Southern England, including a London station on the HS1 route? Such long term strategic scenarios should be an integral part of the nation's HSR network strategy considerations. There was no such consideration in the conception of the HS2 proposals, because HS2L's remit was so heavily constrained by current thinking influenced by the traditional dominance of a Heathrow hub airport. This repeated a fundamental mistake made in the 2003 Aviation White Paper. 6
3 – Business Case
3.1 There remains considerable doubt as to whether the highly constrained 'dedicated' VHSR approach (e.g. current HS2 proposal) with its very high risk profile, is an affordable or safe strategy. Challenges to the HS2 business case by other parties seem to confirm that.
3.2 By any standards, the HS2 passenger forecasts are very bold, particularly the assumptions about new traffic generation and transfer from air. Given the huge timescales involved, over a period of inevitably uncertain change, traffic forecasting is more an act of faith than a science 7. Over a 30 to 50 year period we can expect to see further life-changing communications developments that will reduce the need to travel for business purposes; and also cultural changes, such as more working from home as an alternative to 5-day commuting. This emphasises the need to adopt infrastructure strategies that maximise the flexibility to respond to change, rather than those which have built-in inflexibility such as the current HS2 proposals.
3.3 There appears to be no clear Government policy on the regulatory rail pricing regime that will apply once HS2 commences service. Statements by ministers seem to imply that competitive pricing will be permitted between HS2 and operators on the classic network. That seems both sensible and essential for the late 2020s and beyond. The rail industry should by then be using the more advanced inventory control pricing systems that are now commonplace in the airline industry. However, given the wide difference in the load factors between HS2 and WCML quoted for 2043 8, this highlights an important weakness in HS2 passenger forecasting. Learning from airline competition experience, a 58% HS2 load factor would not be sustainable against promotional pricing by slower competing WCML services, with 69% spare capacity over the same sector. The same would apply with respect to pricing competition on an improved Birmingham-London Chiltern Line.
3.4 Work by other parties on the possibility of upgrading scenarios for the West Coast Main Line (WCML) draws out several points. First, there is more optimism than assumed by HS2L that capacity improvements on WCML and development of the Chiltern Line could postpone any critical capacity point well beyond that assumed by HS2L and DfT. Second, government institutional thinking is heavily biased by the history of poor performance and high cost of previous WCML upgrades and the additional risks to sustaining service standards during construction.
3.5 Management of the Olympic and other recent major projects suggests that the second point reflects undue caution. Certainly the Government is dedicated to improving risk management in major projects. 9 Arising from the first point, one must seriously question whether it is essential, as the Government implies, for a decision on the proposed HS2 southern spine to be taken before the end of 2011 and before the Government has considered the outcomes of its major national transportation investigations referred to above. The Government should resist pressure from the rail industry lobby for such an early decision, when there is so much uncertainty on critical strategic issues and the potential environmental harm to special protected areas, such as the Chilterns AONB, would be devastating, as the previous government's transport minister admitted in Parliament 10.
Q4 – The strategic route
4.1 The proposed HS2 southern spine route alignment stems from the very narrowly drawn and highly constrained remit given to HS2L. Hence, this, and the Coalition Government's political commitment to an early decision, has meant that a proper comprehensive strategic review of feasible scenarios and options has not been conducted.
4.2 The original 'Adonis' remit for HS2L, which the present Government essentially adopted, was focussed on a London to West Midlands route 11. Among the 'Absolute requirements' of that remit were: a 'Heathrow International station'; a 'Connection to HS1'; 'no intermediate stations between Heathrow International and West Midlands'. Those requirements determined that any southern HSR spine route must approach London from the West. With those constraints, alternative scenarios that might have approached a London terminal from the north were effectively outside HS2L's remit. That remit also denied HS2L the opportunity to investigate fundamental changes to the distribution of rail services into London that might have facilitated better passenger service in the post-Crossrail era and achieve a far more direct and speedier HS2 connection to HS1. It also effectively ruled out in-depth consideration of an 'integrated' model of HSR network provision that could, in future, have provided for slower HSR services to intermediate stations in the South Midlands Sub-Regional Growth Area (and beyond) and, for example, HSR services between that area and the London Gateway Growth Area in Kent.
4.3 HS2L's first report made it clear that HSR services between London and Birmingham alone would not be economically viable. That has been stated subsequently on several occasions by HS2L's former Chairman and its Chief Engineer. Yet HS2L places great weight on achieving a straight line connection between London and the West Midlands (Birmingham). The real benefit of HSR is over greater distances, e.g London to Manchester and Leeds/Sheffield. Had the original remit been prioritised to link those cities to HS1 and London, the 'straight line' philosophy would have suggested a more easterly alignment for the southern HSR spine that would have passed through the South/East Midlands.
4.4 This fundamental failure initially to commission a much broader high level strategic rail network review has severely precluded a proper comprehensive evaluation of alternative HSR scenarios and spine route options. Since the current HS2 proposals also pre-empt the outcomes of other major strategic transportation studies and consultations, that project, including the proposed Y configuration, should at least be put on hold until a more comprehensive and coherent assessment is possible. The current HS2 proposals are widely perceived as unsound 12.
4.5 In terms of priorities for a HSR spine route over the last three-quarters of this century, there can be little doubt that effective HSR through-service capability to the Continent from the Midlands and beyond will be essential. It is far less certain over that timescale that an HSR connection to Heathrow will still be perceived as important as it is now. Indeed, with all of its inherited shortcomings and constraints, it is inconceivable that Heathrow will still retain such a dominant role over other UK and near European airports, making speedier HS2-HS1 connections far more important. Another priority is clearly the need for interconnectivity improvements between cities in the Midlands and the North of England. The phasing of the development of the national HSR network strategy should take these priorities into account.
Q5 – Economic rebalancing and equity
5.1 We have already referred to the lack of a substantive evidence base for WEI. However, it seems self-evident that the more flexibility there is eventually to deliver HSR connections to more cities in the Midlands and North, with their classic rail connections to their sub-regional hinterlands, the greater the prospects for regeneration and greater modal shift to rail. This points strongly towards an 'integrated' network strategic approach. In contrast, the 'dedicated' VHSR network approach of the current HS2 project is concentrated only on the country's major city conurbations, where arguably the need for regeneration support is much less. The wider rail network improvement is, the broader will be the benefit to a wider range of socio-economic groups. Concentration on the HS2L dedicated network could detract from sound investment in the development of sub-regional rail networks.
Q6 – Impact
6.1 Even HS2L seem to accept that its project proposals will be no more than carbon neutral. This is particularly because of its fixation on a business model based on an exclusive 400kph VHSR, dedicated track network. Slower HSR speeds would reduce carbon emissions substantially. They would also reduce energy consumption. Slower speeds permit greater track curvatures and reduced tunnelling and associated costs, as well as significantly reduced embedded carbon impacts. They also make it, in stark contrast to the HS2 proposals, far more feasible to align any new HSR track within the environmental envelope of existing major transport corridors. The latter seems to be accepted good practice in the most densely developed European countries.
6.2 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. 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 13.
International transfer traffic to/from Manchester and Scottish airports would be 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.
6.3 Note that the Government does not intend to publish its draft policy on a sustainable framework for aviation until March 2012. It will adopt the framework in March 2013 14.
6.4 The true environmental impact cost of HS2 has yet to be fully assessed. There are huge gaps in the environmental evidence base so far produced by HS2L 15, and therefore in the account taken of environmental costs in the HS2 business case.
6.5 The major concern for the Chiltern Society is the Government's proposal for a VHSR route right across the heart of the Chilterns AONB. The Chilterns is a unique example of ancient English countryside 16 and, as a result, one of only two AONBs to have a statutory conservation board. The Chilterns is the most easily accessible large area of designated special countryside close to London and the only AONB between London and Birmingham. AONBs share the distinction with the National Parks of representing the finest quality of English landscape. Driving a VHSR route through the Chiltern Hills is the equivalent for people in the many growth areas surrounding this tranquil ancient countryside to driving such a route through the fantastic National Parks that people in the cities of Yorkshire and the North of England rightly value, enjoy and protect. If there are alternatives to such devastating harmful abuse of these national assets, they must be used.
6.6 The highly restricted nature of HS2L's original and extended remit made it inevitable that the company would recommend a HSR route straight through the Chilterns. We are confident that a more well founded and comprehensive strategic assessment of the nation's future rail transportation needs, including HSR, would identify other feasible solutions with much wider benefits, without causing irreparable harm to the Chilterns.
Chiltern Society – May 2011
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2 See Planning Policy Statement PPS7 para. 22 and related legislation
3 Analyses by HS2 Action Alliance and others.
4 For example – see para. 23.7 of South East Plan
5 Developing a sustainable framework for UK aviation: Scoping document – DfT March 2011
6 Future of Air Transport White Paper 2003
7 The NAO report into Channel Tunnel 2005 – Found that passenger volumes and revenue forecasts were too optimistic. The Public Accounts Committee report on the Channel Tunnel Rail Link, 2005/06 – concluded that 'Where future income from passengers is expected to provide a major element of the revenue needed to repay the cost of constructing transport infrastructure, it is crucial that realistic forecasts are prepared from the start. Downside risks need to be given due weight, drawing on both UK and international experience, in considering future projects.'
8 Economic case for HS2 – Figure 4 p. 21
10 Mr. Sadiq Kahn – Hansard 11 March 2010 Column 458
11 HS2 Ltd remit. Sir David Rowlands letter to Lord Adonis 13 February 2009 and Lord Adonis' reply of 9 March 2009
13 ABERT Newsletter 25 April 2011
14 Developing a sustainable framework for UK aviation: Scoping document – DfT March 2011 – para.1.17
15 As admitted by HS2L staff/consultants at an HS2L Technical Seminar on 17 March 2011