Written evidence from Friends of the Earth
Friends of the Earth (FOE) is pleased to respond
to this inquiry. We are a supporter of the environmental NGOs'
"Right Lines Charter",
with its four identified principles. In this submissionbecause
the Transport Committee is reviewing the strategic case for HSRwe
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
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
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 2000sthe 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 prioritiesparticularly
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
for the UK this would imply a figure of around £11.5 billion,
in fact the current, actual UK figure is around £7.7 billionthe
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).
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).
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
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).
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
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. 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 travelfor
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
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
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
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
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 stationsee TC4.
FOE recognises that the HS2 proposal is a hugely
important decision point in long-run UK transport policy. We welcome
the national debatebut we believe it is now for the Government
to answer the questions we have identified.
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.
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
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 modesair 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 budgetsincreasing the 2020 target
from 34% cut (from 1990 levels) to 42%
and (2) bio-fuels emissions reductions assumptions are unsoundthe
TSC will be familiar with recent evidence
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 attentionelectrification 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
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)
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
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.
UK rail fares are already amongst the most expensive in Europe.
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. 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)
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
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
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
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.
It is therefore vital that this is factored into the Government's
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).
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.
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."
This position is then set in context: over 90% of
those total transport emissions are currently generated by road
transportwhich 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
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.
So significant carbon reductions ought to be possible through
modal shift to new rail freight services on the "classic
network" particularly intermodal services,
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?
398 http://www.cpre.org.uk/what-we-do/transport/rail/update/item/1683-a-charter-for-high-speed-rail Back
Transport investment and economic development-David Bannister
and Joseph Berechman 2000 page 4. Back
UK GDP 2010 $2.29trillion = £1.44trillion ($1.60 exchange
Page 11 HMT CSR document DfT Capital allocation.
All costed schemes from: "A Low carbon Transport Policy for
the UK, 2008"
DfT-Low Carbon Transport (2009)
Various studies including UCL reported in FT:
IEA reported in "Wired"
DECC announcement 17/5/11: "Government will continue to argue
that EU moves to a 30% 2020 target" this implies 42% reduction
"Driving to Destruction"
DECC Oil retail price assumptions, used by DfT:
McNulty interim findings: Network Rail renwal expenditure is 30-50%
less efficient than comparable European railways:
High Speed Rail-lessons for policy makers:
Page 185 CCC 4th Budget report:
Railfreight emissions per kg/km carried = 35% of road or 3% of
"Capturing the Benefits", Greengauge: