High Speed Rail - Transport Committee Contents

Written evidence from Friends of the Earth (HSR 177)

Friends of the Earth (FOE) is pleased to respond to this inquiry. We are a supporter of the environmental NGOs' "Right Lines Charter",[398] with its four identified principles. In this submission—because the Transport Committee is reviewing the strategic case for HSR—we are placing particular emphasis on its first principle: "High Speed Rail proposals need to be set in the context of a long-term transport strategy stating clear objectives". In FOE's case the fundamental purpose of that strategy must be to ensure that transport policy and investment makes its necessary contribution to the overall national challenge of Greenhouse Gas emissions reduction.

FOE has a strong network of autonomous local groups - some of whom will have made their own submissions to this inquiry.

TC1: What are the main arguments either for or against HSR

FOE believes there is a clear need for an agreed strategic assessment framework which identifies the primary issues against which the HS2 proposal should be evaluated. We believe that the proposal must be tested against the following questions, and that it is the responsibility of government to provide clear answers before a decision in support (or not) of HS2 is made.

FOE Q1: What is the contribution of HS2 to long-run UK transport policy?

Set against the DfT policy backdrop of the last 30 years— with its pattern of repeated failures: abandonment of the Advanced Passenger Train; bus deregulation; "Roads to Prosperity"; rail privatisation; aviation expansion; and finally the "lost decade" of the 2000s—the proposed commitment to expansion of the rail network represents a refreshing change of strategic direction. If this represents a fundamental shift in favour of "strategic Rail" as against "strategic Road" (and also "strategic aviation") then FOE strongly supports this, but it must be embedded within both a long-term national transport policy which gives certainty to this new direction, and a comprehensive expenditure programmes through to 2030, organised around carbon reduction and also contributing to overall sustainability.

FOE Q2: What priority should be accorded to high-speed rail compared to other potentially competing priorities within a national transport policy and associated investment programmes over the next two decades; and then within overall UK expenditure, in the context of the need to fund the hugely challenging task of carbon reduction in a cost benefit sequence?

HS2 will cost around £17 billion (£32 billion for Y-network), it is understood that funding will commence at £2 billion per year after Crossrail is completed in 2015. It is vital that expenditure on HS2 does not compromise spending on other important transport priorities—particularly those which will deliver the urgent carbon reductions needed from transport well before HS2 opens. In Western Europe/OECD economies, capital investment in inland transport averages around 0.8% GDP per annum,[399] for the UK this would imply a figure of around £11.5 billion,[400] in fact the current, actual UK figure is around £7.7 billion[401]—the UK does not invest as much in transport as other countries. A (non exhaustive) list of urgent transport policy and investment priorities will include, in our view, investment like:

—  Rapid transit networks in our major cities (ultra light trams in 12 cities—£2 billion).[402]

—  National Programme of Smarter Travel Choices (£200 million per year over 10 years).

—  Electrification and capacity upgrades on existing rail network.

—  Cycling England plan to triple cycle use in five years (£0.5 billion).

—  Charging infrastructure for electric vehicles.

If HS2 goes ahead the Government must show how it will continue to fund these (and other) urgent transport priorities which will contribute significantly to carbon reduction in the short term.

It should be noted that 57% of car journeys are less than five miles and 64% of carbon emissions from cars comes from journeys of under 25miles (90% from under 100miles).[403] Funding for policies and infrastructure investment that reduces carbon from these shorter journeys which are responsible for the bulk of transport emissions must not be sacrificed in order to fund HS2.

So, the relative priority of HS2 must be considered within the wider context of a national transport policy through to 2030, with its associated expenditure programmes, which is what the Government must provide. It is not possible to assess the priority of HS2 expenditure in isolation.

FOE Q3: Is there a demonstrated need for HS2?

The government case is that HS2 is the best response to a "long term capacity challenge" p 34. It predicts that there will be a progressively increasing shortfall in both WCML and ECML capacity in the 2020s and then beyond (1.46-52). However other commentators have pointed to evidence that travel demand may have peaked and that it is not linked to any growth in GDP.[404] In this uncertain context, FOE believes any new rail line should primarily be designed to achieve modal shift from less sustainable modes and set within a policy context designed to achieve this. Public policy should also seek to reduce the need to travel—for example, in the context of long distance travel this implies support for technology to replace business travel like video conferencing. There is also the question of whether any new capacity be provided via a new high-speed network or alternatively by upgrading the existing infrastructure?—see also our response to question TC3/2.

FOE Q4: Since FOE is an organisation whose aim is to promote sustainable development, what is HS2's contribution to overall sustainability (all three pillars: economic, social and environmental)?

As an organisation campaigning for sustainable development (SD), our preferred approach is to identify both benefits and disbenefits in relation to all three "pillars" (economic, social and environmental) and then integrate them to an optimum outcome. In the specific case of HS2 this will involve a complex assessment of, for example, a (re)distribution of economic benefits along the length of the route and spreading outwards from it, and the balancing of different kinds of impact (eg negative environmental impact in the Chilterns versus possible positive economic impact in more northern regions). We urge the Committee to test whether all three component parts of SD have been adequately modelled and accessed.

FOE Q5: What will be HS2's contribution to climate change emissions reduction, firstly in the priority decade to 2020, then in the period to 2030, and finally through to a 2050 end date?

See our responses to Committee question TC2 and TC6/1 on this critical issue.

FOE Q6: Are there particular arguments for or against the current specific proposal and route?

In our view a decision to proceed with HS2 must be contingent on the Government providing the correct policy context and overall funding strategy for transport. With these two conditions met, HS2 is one option for providing additional rail capacity. However, we have serious concerns about the development and transport integration implications of the current proposal for a Birmingham interchange station—see TC4.


FOE recognises that the HS2 proposal is a hugely important decision point in long-run UK transport policy. We welcome the national debate—but we believe it is now for the Government to answer the questions we have identified.

—  If the Government is able to demonstrate that HS2 can be a positive component within a wider national transport strategy, focused around carbon reduction, contributing to overall sustainability, and affordable alongside other more urgent investments in necessary national infrastructure, then FOE would be able to support its continuation into more detailed development, including addressing environmental impacts along the route.

—  But if the government is not able to answer these questions, or if its assessment throws up fundamental incompatibilities, then FOE will continue to question the proposal.

The Transport Committee report itself will in due course be an important contribution to that national debate and strategic assessment, and we will await its findings.

TC2: How does HSR fit with the Government's transport policy objectives

One of the Secretary of State's two stated priorities on accepting his appointment in May 2010 was to cut carbon emissions from transport. It is critical that HS2 is set within an overall transport carbon reduction strategy that will deliver the GHG savings to enable our carbon budgets to be met. In the long term this means HS2 needs to be an agent of modal shift from more carbon intensive modes—air and road. To achieve this, the right companion policies must be in place so that rail is price competitive and is well integrated with other public transport. The grid must be de-carbonised by 2030 and there must be a strategy to make released "classic network" rail capacity achieve further modal shift for freight and passengers.

Before opening in 2026 at least HS2 it cannot play a part in carbon reduction for the first three carbon budgets, and only a minor role if any in the 4th (2023-27). For the next 15 years or more, carbon reduction from transport will need to come entirely from other policies. It is also likely that emissions reduction ambition will have to be increased for two reasons: (1) the Committee on Climate Change has recommended tightening the first three carbon budgets—increasing the 2020 target from 34% cut (from 1990 levels) to 42%[405] and (2) bio-fuels emissions reductions assumptions are unsound—the TSC will be familiar with recent evidence[406] on indirect land-use change which undermines the carbon reductions assumed for bio-fuels.

So, the Government needs to urgently revise its transport carbon reduction strategy and expenditure prioritisation framework to ensure any commitment to fund HS2 does not mean a reduction in funding for more urgent carbon reduction initiatives. In the short term these will need to focus on travel behaviour change.

1.  HSR is designed to improve inter-urban connectivity. How does that objective compare in importance to other transport policy objectives and spending programmes, including those for the strategic road network?

As we noted under FOE Q2 above there are other transport investment priorities to be reviewed alongside HS2, and which must not be jeopardised by its development. However because HS2 expenditure will be undertaken over decades it may be possible to accommodate all these priorities and spending programmes if the government is able to demonstrate how and that they intend to do so; so far they have not done this. Expenditure on new rail capacity should be accorded a much higher priority than that on the strategic road network; a decision to investment in the former offers the opportunity to signal a decisive positive shift in national transport policy.

2.  Focusing on rail, what would be the implications of expenditure on HSR on funding for the "classic" network, for example in relation to investment to increase track and rolling stock capacity in and around major cities?

The identifiable problems are that the consultation document identifies that the WCML will be "full up" (in 2024) some EIGHT years before the second stage extension to Manchester is opened in 2032. No equivalent assessment is provided for the ECML, which has not had a recent comprehensive refurbishment. In addition there are major issues on the "classic" network requiring attention—electrification and "pinch points". Therefore the government has to identify, alongside the specific HS2 proposals, how it also intends to dovetail these with continuing classic network expenditure where this is necessary.

3.  What are the implications for domestic aviation?

Some modal shift away from domestic aviation has been demonstrated in Europe as a result of high-speed rail. However in the context of the UK's overall carbon emissions it is important that any surplus airport capacity which HS2 provides is not simply filled with more long haul flights with their attendant higher emissions. FOE suggests that a policy of "retiring" any freed up airport capacity should be deployed. This would have the additional benefit of making our busiest airports more resilient to major disruption, from (for example) bad weather.

TC3: Business case

1.  How robust are the assumptions and methodology - for example, on passenger forecasts, modal shifts, fare levels, scheme costs, economic assumptions (eg about the value of time) and the impact of lost revenue on the "classic" network?

The business case makes questionable assumptions that the cost of flying continues to fall, petrol prices remain broadly stable (£1.25 at 2009 prices in 2030)[407] and road user charging is not introduced. It is difficult to envisage that oil prices will not increase significantly in the next 20 years and that some sort of alternative Government income stream from electric cars to replace fuel duty will not have been introduced.

Using more realistic assumptions could significantly boost the business and environmental case for HS2, the Government must model a far wider range of sensitivity tests.

2.  What would be the pros and cons of resolving capacity issues in other ways, for example by upgrading the West Coast Main Line or building a new conventional line?

Since in our view the primary purpose of any new line should be to achieve modal shift, alternatives including, perhaps, a new dedicated freight line, should be examined through this policy "lens". Upgrades of existing lines have the disadvantage of the considerable disruption they would cause, however their local environmental impacts are likely to be significantly less.

3.  What would be the pros and cons of alternative means of managing demand for rail travel, for example by price?

We don't believe that managing demand for rail travel, whether generally or specifically on the HS2 corridors, should be achieved by pricing people off the railway, which is the likely impact of current fares policy.[408] UK rail fares are already amongst the most expensive in Europe.[409]

4.  What lessons should the Government learn from other major transport projects to ensure that any new high speed lines are built on time and to budget?

Friends of the Earth: There is evidence that rail projects in Europe are considerably less expensive than in the UK.[410] The completed McNulty review is likely to bear down on infrastructure costs. We hope the Government will act on its recommendations.

TC4: The strategic route

1.  The proposed route to the West Midlands has stations at Euston, Old Oak Common, Birmingham International and Birmingham Curzon Street. Are these the best possible locations? What criteria should be used to assess the case for more (or fewer) intermediate stations?

It is important that the line serves city centre stations rather than "parkway" style stations to minimise urban sprawl and maximise integration with other public transport. Birmingham Curzon Street must not be axed in any future cost cutting exercise. Through trains to destinations off the high speed line (ie Nottingham and Derby) should be favoured over creation of a "catch all" East Midlands parkway station. We also have serious concerns about the proposed "Birmingham Interchange" station, a separate station to the current "Birmingham International" on the West Coast main line. This will create urban sprawl and is a wasted opportunity to create a direct interchange with other public transport at Birmingham International.

2.  Which cities should be served by an eventual high speed network? Is the proposed Y configuration the right choice?

If HS2 goes ahead we believe the Y network represents the right choice.

3.  Is the Government correct to build the network in stages, moving from London northwards?

Yes, because this allows the expenditure to be spread over two decades, thereby making it more affordable in a context where a decision has to be taken in 2011-12 at a time of investment austerity. However it is equally essential that a legal commitment is made at the same time to the second stage extension of the Y network beyond Birmingham, in order to provide certainty for long-term planning purposes in the northern regions.

4.  The Government proposes a link to HS1 as part of Phase 1 but a direct link to Heathrow only as part of Phase2. Are those the right decisions?

We believe that there should be a link to HS1 in order to secure the integrated network benefits through to the European HS system. However we don't believe that a link to Heathrow should be a priority.

TC5: Economic rebalancing and equity

1.  What evidence is there that HSR will promote economic regeneration and help bridge the north-south economic divide?

The consultation document identifies a net positive BCR of 2.6 but also admits that HS2 "would deliver significant nonmonetised benefits, such as its contribution to job creation and regeneration and its potential to promote sustainable and balanced economic growth. It is these non-monetised benefits which underpin the strategic case for high speed rail"—however research for the DfT also highlights that agglomeration benefits will mainly come from making best use of freed up capacity to provide new regional services and dense mixed use development near stations.[411]

There are also other, as yet unresolved questions around regional benefit. Connecting important regional centres like Birmingham, Manchester and Leeds to London via HS2 could have a positive or negative effect on those economies; in other words in which direction will benefits travel along this "two-way road" (SACTRA)? Then will there be possible economic impacts on regional centres some distance from the HS2 route eg Bradford rather than Leeds, Liverpool rather than Manchester. Studies suggest these can be mitigated by introducing new local and regional services using freed up capacity.[412] It is therefore vital that this is factored into the Government's plans.

2.  To what extent should the shape of the network be influenced by the desirability of supporting local and regional regeneration?

The emphasis should be on larger scale regional regeneration and we believe this along with environmental safeguards should influence the shape of the network.

3.  Which locations and socio-economic groups will benefit from HSR?

An argument has been put forward that wealthier people will be the disproportionate beneficiaries of HS2: "Spending £16 billion to encourage rich people to travel a lot to London is not a priority" (John Whitelegg).[413] It is important that any High Speed line contributes to modal shift across socio economic groups. To achieve this the relative pricing of modes must favour rail, all policy levers including road fuel taxation, aviation taxation and Road User Charging will need to be considered.

4.  How should the Government ensure that all major beneficiaries of HSR (including local authorities and business interests) make an appropriate financial contribution and bear risks appropriately? Should the Government seek support from the EU's TEN-T programme?

We have no comment to make on this.

TC6: Impact

1.  What will be the overall impact of HSR on UK carbon emissions? How much modal shift from aviation and roads would be needed for HSR to reduce carbon?

The government's wider position on the contribution that rail (including HS2, and electrification) could make to the national Carbon Budget and emissions reduction trajectory is set out in paragraphs 5.11-17 of the DECC Carbon Plan (March 2011).

The CCC says that HS2 will be broadly carbon neutral: "We estimate that the effects of the high-speed rail proposals on surface transport emissions (ie the combined effect of the increase in emissions from electricity generation and any reduction in car emissions through modal shift) would be negligible."[414]

This position is then set in context: over 90% of those total transport emissions are currently generated by road transport—which is therefore where the main policy emphasis has to lie 1.67; and then in a wider sustainability context, folding in economic and social benefits as well: "HS2 could provide a relatively low carbon form of transport, offering the opportunity to deliver a major improvement in capacity and journey time between our major cities to support economic growth, without an increase in carbon emissions." 5.63

But the most important context of all is that which requires the almost complete decarbonising of UK electricity generation by around the same date that the extended HS2 network would come into operation (approx 2030). Consequently achieving this objective has to be a fundamental precondition for then proceeding with electrified high-speed rail, as well as for electric road vehicles.

2.  Are environmental costs and benefits (including in relation to noise) correctly accounted for in the business case?

No comment.

3.  What would be the impact on freight services on the "classic" network?

HS2 if built, should free up capacity on the congested West Coast Main Line, the primary North-South UK rail freight route. Rail freight is and is likely to remain a significantly lower carbon way of carrying goods compared to road or air.[415] So significant carbon reductions ought to be possible through modal shift to new rail freight services on the "classic network" particularly intermodal services,[416] providing the policy framework is in place. The Government must develop a strategy to achieve this which will need to include expansion of freight terminals.

4.  How much disruption will be there to services on the "classic" network during construction, particularly during the rebuilding of Euston?

No comment.

June 2011

398   http://www.cpre.org.uk/what-we-do/transport/rail/update/item/1683-a-charter-for-high-speed-rail Back

399   Transport investment and economic development-David Bannister and Joseph Berechman 2000 page 4. Back

400   UK GDP 2010 $2.29trillion = £1.44trillion ($1.60 exchange rate).

401   Page 11 HMT CSR document DfT Capital allocation.

402   All costed schemes from: "A Low carbon Transport Policy for the UK, 2008"

403   DfT-Low Carbon Transport (2009)

404   Various studies including UCL reported in FT:
http://www.ft.com/cms/s/0/de6c9b48-6ddc-11df-b5c9-00144feabdc0.html#axzz1MgyM3Mfl and
IEA reported in "Wired"

405   DECC announcement 17/5/11: "Government will continue to argue that EU moves to a 30% 2020 target" this implies 42% reduction from UK

406   "Driving to Destruction"

407   DECC Oil retail price assumptions, used by DfT:

408   Hansard Answer:

409   Passenger Focus:

410   McNulty interim findings: Network Rail renwal expenditure is 30-50% less efficient than comparable European railways:

411   http://webarchive.nationalarchives.gov.uk/+/http://www.dft.gov.uk/pgr/rail/pi/highspeedrail/hs2ltd/appraisalmaterial/pdf/widereconomicreport.pdf Back

412   High Speed Rail-lessons for policy makers:

413   http://virtual-lancaster.blogspot.com/2011/03/16-billion-should-not-be-spent-on-high.html Back

414   Page 185 CCC 4th Budget report:

415   Railfreight emissions per kg/km carried = 35% of road or 3% of air:

416   "Capturing the Benefits", Greengauge:

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