Written evidence from the Chiltern Countryside
Group (HSR 178)|
The Chiltern Countryside Group (CCG) was established
at the time of the National Air Traffic Service's Terminal Control
North Public Consultation 2008 as a natural evolution of local
groups with the same aim of preserving the character and peace
of the Chilterns and its Area of Outstanding Natural Beauty (AONB).
Following this consultation, the whole SE airspace area is now
Our submission is not confined to the locality of
the Chilterns. The CCG and its supporters are not against the
principle of high speed rail. Whilst the Chilterns and its AONB
would be heavily impacted by the current HS2 proposals, we recognise
that the concept of a HSR provision for the UK is of great national
importance, therefore our evidence is focused on the question:
"Are the present proposals truly in the nation's best interests?"
Our considered view is that the current proposals
from the Department of Transport (DfT) are not in the nation's
We give below our supporting evidence which we hope
the Transport Select Committee will accept and fully consider
when reaching their decisions.
1. The Chiltern Countryside Group is not against
the concept of High Speed Rail but is not persuaded that the HS2
proposals currently out for Public Consultation are in the nation's
2. The principal arguments for HSR of improved
capacity and connectivity, reduction in journey time and reliability
are not unique to HSR and can also be true for improvements to
existing rail routes and development of local infrastructures.
3. There is scant evidence to prove a causal
link between HS2 HSR and regeneration to those areas most in need,
evidence is inconclusive.
4. Principal arguments against HS2 HSR are economicshould
the UK taxpayer fund a project of uncertain benefits when essential
services are being cut? Such a long-term commitment is extremely
high risk; the passenger demand forecasts are highly questionable.
Costs do not take rising inflation into account.
5. In the present and foreseeable future, the
world and domestic situation is politically and economically unstable.
Committing the vast sums of taxpayers' money required to finance
HS2 HSR will inevitably take away from investment in the "classic"
6. HS2 HSR will not reduce carbon emissions.
At best it will be carbon neutral but even this depends on a high
7. If HS2 HSR went ahead, the preferred route
would set a precedent since 2000 (CROW Act) for the approval of
infrastructure of this scale through an Area of Outstanding Natural
8. Those areas which HS2 HSR passes through without
any stations will suffer degeneration environmentally and thus,
9. Investment in transport will not achieve optimal
benefits without simultaneous investment in business opportunities.
Moving people from place to place does not itself generate economic
expansion or regeneration. It may well simply transfer money.
10. Modal shift, upon which the environmental
and financial success of HS2 HSR depends, is not reliable and
can be easily transformed by other factors eg improved technology,
unanticipated national or world issue, unexpected competition.
People will still use domestic and Continental aviation where
flights are cheaper and offer a total journey time of less than
three to four hours. Cost is a key motivator. Where groups of
people travel together by car, the cost per head and convenience
is unlikely to produce a modal shift to air or train.
11. The Government is investing £530 million
in the UK's broadband networkmore people will need to travel
12. Omissions have been found in relevant legislation,
policy and objectives in HS2 Ltd's Appraisal of Sustainability
(AoS). This has led to concerns that the DfT, HS2 Ltd and its
consultants have failed to give sufficient weight to conserving
designated land in route design. This may give rise to unplanned
cost implications which impact on the business case.
13. When designing a route, it is important to
avoid, or minimise the length of route, in AONBs and National
Parks. When such a route is demonstrated to be in the national
interest, a tunnelled option throughout the length of the designated
land should be included for public consultation. Tunnelling produces
much less spoil than deep cutting per km, as well as producing
a far superior environmental landscape solution. HS2 Ltd's severe
underestimation of spoil generated in the Chilterns will add to
14. Without full and exhaustive information on
noise and its effects no sensible analysis of the environmental
costs and benefits can take place. A full Environmental Impact
Analysis can be the only basis for such a decision and this is
not available. This is a grave error.
15. The HS2 HSR programme is seriously flawed
in its judgement of demand, its claim on the UK taxpayers' purse
during the present planning stage and years of construction and
in its environmental impact. This is a long-term project which
may never achieve the benefits it seeks to portray but will cost
each UK constituency c £51 million and every UK
taxpaying family c £1,200. During its first stage construction
of at least seven years, it will bring physical, economic, environmental
and social degeneration to those communities through which it
passes, from which they may never recover.
16. HS2 HSR should be withdrawn and more robust
planning using correct modelling undertaken including for those
alternatives which could offer greater benefit with more affordable
costs and the local connectivity sought by many areas. A regional
approach, which is not London centred, could offer better opportunity
for a truly national regeneration of greater fairness and access.
17. The CCG find that the DfT in its response
has not adequately addressed the recommendations made by the Transport
Select Committee following the 2010 Inquiry into Transport and
the Economy. (ref 1)
18. The CCG finds the Government and the Treasury
have still to establish an overall integrated & sustainable
transport policy which is affordable & makes best use of the
Q1: What are the main arguments for or against
The principal arguments to support High Speed Rail
in journey times.
However, these outcomes are not unique to the HSR
programme but are also true for improvements to existing rail
routes and development of local infrastructures.
These additional benefits are promoted by Government,
but it is highly questionable they will be achieved; Government
has given little concrete evidence to support their claims that
HS2 HSR will be "the engine for":
of deprived and impoverished areas.
the "North-South economic divide" in the UK.
In the 2010 report by Dr Terry Gourvish, commissioned
by HS2 Ltd to research the global experience of high speed railways,
Dr Gourvish states: "most studies indicate that it would
be unwise to pin much faith in new railways as engines of growth".
The EU Commission estimated that HS rail networks "would
only add 0.25% to EU GDP and 0.11% to employment over 25 years."
(ref 2) Other leading experts in economics have expressed
Some of the arguments against the current HSR programme
(i) Basic cost of planning and building HS2 HSRcommitment
to spending a minimum of £33 billion (2009 value) of
taxpayers' money over several decades is required to fulfil the
programme's stated objectives.
(ii) British construction costs are higher than
others in Europe. HS2 Ltd's commissioned study (ref 3)
shows "civil engineering costs in the UK are up to twice
what they are in other comparable European countries". This
not only increases the funding required but places greater risk
of non-profitability and bankruptcy.
(iii) Insufficient weight has been placed on
environmental cost regionally and nationally.
(iv) The UK does not need to "catch up"
with Europe, as it has had a high speed rail system for years,
with routes already capable of trains running at 125 mph
(official definition of high speed rail). Virgin Trains Euston-Birmingham
fastest train 1 hour 11 minutes. (ref 4)
(v) The UK does not have long distances between
major centres of population compared to other nations to justify
the cost and environmental impact of the ultimate speed of 250 mph
for the proposed HS2 route (64 mph faster than top speed
of HS1) with only 35 minutes time saving on phase 1.
(vi) Reliance on the high risk strategy of one
contentious and expensive project (HS2) to primarily resolve the
UK's economic future. Reduced ticket revenues might not even service
the debt from construction.
(vii) The DfT appear to have ignored the
economic lessons of HS1, the franchise of which was sold at a
loss in 2010. HS2 construction (2009 estimate) is £100 million
per km. (ref 5)
(viii) Environmentally, the programme is reliant
on modal shift and high load factor to break even. (ref 6
p 53) If this is not achieved, then neither is sustainability.
(ix) Modal shift is unlikely to be achieved domestically
as cost and convenience will dictate choice. Good local and cross-country
connections which do not drag the consumer to a large conurbation
he is only visiting as a transit point are more likely to be attractive
and lessen carbon footprint by reducing time and miles travelled.
(x) Increase in capacity is only necessary at
peak times, which may be for a few hours daily and in extremity,
weekly (eg Friday evenings). HS2 HSR is a very expensive and highly
disruptive solution to this.
(xi) Almost complete rebuilding of Euston, a
major main line and local station with its associated severe disruptions
to all users over a minimum of seven years.
(xii) To support running costs, ticket prices
are likely to attract the highest paid employed population sector,
unless tickets are subsidised, in which case, the travelling taxpayer
(xiii) Reliability may not be achieved as the
proposed HS2 HSR programme uses untested technology.
(xiv) Those areas and communities "by-passed"
by HS2 HSR are likely to see their wealth and potential transferred
to those places served by HSR. The UK may see a transfer of wealth
rather than an actual increase in wealth.
(xv) Employment may increase in those areas served
by HS2 HSR but this may well reduce the employment and skills
pool for those areas which are not. This would result in a location
transfer of skilled and professional workers rather than an actual
increase in numbers.
(xvi) No value cost has been placed upon the
impact of construction on those areas through which the currently
proposed HS2 HSR route passes, nor on the social/health cost to
(xvii) No environmental or health value or cost
has been placed on the increased aural and light pollution to
communities and the individual.
Q2: How does HSR fit in with the Government's
transport policy objectives?
Q2.1 The DfT sets out five goals for transport:
climate change; productivity and competitiveness; equality of
opportunity; health, safety and security; quality of life and
natural environment. HS2 HSR fails to satisfy any of these goals.
2.1.1 Inter-urban connectivity is important,
but London already has good high speed rail links to other major
UK cities. Moving away from a London-centred approach to give
better East-West & regional links would have many benefits
in removing pressure from the congested SE and London networks,
reducing travel time and cost for those who are only using London
as an interchange, not a final destination. For example, currently,
travellers by rail to the NE from the Northern Home Counties have
to go South into London & then out again or drive tens of
miles, clogging roads, to access the London-NE rail network.
2.1.2 Local and regional developments such as
the Northern Hub (ref 8) could generate prosperity
within those regions, improve wider social inclusion and opportunity
through an integrated transport connectivity which is accessible
and affordable (in capital and travel costs). Funding for this
is estimated at £530 million. Can the UK afford this
and the HS2 HSR programme? Which offers the best Cost Benefit
Ratio? will come on stream first? offers greater benefit to more
people where it's most needed? Regional developments may of course
impact on HS2 HSR passenger demand and thus profitability.
2.1.3 Secretary of State for Transport, Philip
Hammond speaks of the high cost of the UK railways: "Britain
has one of the most expensive railways in the developed world.
According to the independent regulator, up to 40% more expensive
than our main competitors...public subsidy running at £5.5 billion
a year..this has to change". (ref 9) Whilst this
is ambiguous, we presume the change sought by Mr. Hammond is cost
reduction. We are unclear how committing public funds of £33 billion
to HS2 HSR will enable such change, especially if further annual
public subsidy is necessary to keep its ticket costs at affordable
2.1.4 The Sustainability Commission in its outgoing
report finds the richest 10% of the population benefit from receiving
four times as much public spending on transport as the poorest
10%. Its recommendation to Government on transport is for "policy-makers
to prioritise reducing the demand for transport; encouraging more
sustainable modes of transport and improving the efficiency of
existing modes of transport over increasing the capacity of the
transport system". (ref 10) The CCG totally endorses
2.2.1 It is challenging to see how committing
£17 billion over the next 15 years and a similar further
amount to the HS2 HSR project will not reduce the amount of Treasury
money available for investment in the "classic" rail
structure. The CBI (20.9.10) recommends: existing transport
assets to be maintained; all public sector transport projects
to undergo more rigorous value for
The CBI warns (ref 11) of "squeezed
household budgets, weak wage growth, high wage inflation"
and "rising commodity prices putting more upward pressure
on inflation". Not only will this slow growth, challenge
demand for HS2 HSR, but also heavily impact on eventual capital
2.2.2 The experience of HS1 for Ashford commuters
is that "journey times are only a little, if at all, quicker
than..before. Many high-speed trains run almost empty. Conventional
services that people actually do want to use have significantly
deteriorated". (ref 12)
2.2.3 And for Southeastern commutersIn
2010 Southeastern reduced their new high speed Javelin London-Dover
service as demand fell away. Commuters said "passengers for
Victoria lost their peak period services" ... "an even
more expensive service ..which terminates in a place no one wants
to be". (ref 12a)
2.2.4 In France, one-third of existing high-speed
lines lose money and older, non-high speed and suburban lines
are poorly equipped and maintained as investment is put into TGVs.
Guillaume Pepy, president of the French state railways, SNCF,
says they are 'decaying..facing a financial impasse...and heading
for the wall'. (ref 13)
2.3.1 There will be no modal shift from air to
HSR in the first £17 billion London-Birmingham leg,
as there are no flights between the two cities. Sir David Rowlands
(former chairman of HS2 Ltd, now chairman of Gatwick Airport)
has rejected claims by the SofS that a HSR route from London-Scotland
will solve capacity at Britain's congested airports. (ref 14)
2.3.2 Transporting people around the UK to London
airports for them then to fly overseas increases their carbon
footprint, time and use of resources. This should be discouraged,
2.3.3 Research indicates that HSR is currently
not competitive with air for journeys longer than approximately
800 km. (ref 15)
2.3.4 BAA have indicated that should short-haul
slots at Heathrow become vacant through passenger fall-off, they
will fill these with long-haul flights, with consequent greater
air, noise pollution and carbon emissions. Therefore, HSR is unlikely
to reduce aviation, merely change flight destination. Expansion
at other airports will add to carbon impact.
Q3: Business case
Q3.1: Forecasting and modelling
3.1.1 The Public Accounts Committee describes
the DfT's knowledge of how many people use which parts of the
rail network and when as "inadequate, sketchy and so gives
a poor basis for decision-making". (ref 16)
3.1.2 The transport model used to design and
appraise the proposed route for HS2 was not able to realistically
model the balance of long distance travel between air, car and
HS2 and the effects of different HS2 designs on this. Thus it
cannot provide the scientific evidence base to support the business
case and in particular the benefit-to-cost ratio (BCR). The model
could not be used to assess the various options for serving Heathrow
(eg stopping at Heathrow, near Heathrow or ignoring Heathrow).
The transport model's origin-destination pattern was based on
rail ticketing data which would bias in favour of where people
currently buy tickets to. For eg people buy tickets to London,
even if they are travelling to rail destinations outside the city
on the other side. This model would not be capable for example,
of modelling the connection to HS1. The transport model does not
have a destination choice model to forecast the effect of changes
in the transport infrastructure on the origin-destination pattern
of travellers. Therefore it would not be capable of investigating
alternative HS2 routes properly and would give HS2 routing solutions
which copy the current set of rail routesas in this case
to parallel the West Coast Mainline. A properly specified destination
choice model would reflect the effect of changes in people's origin-destination
pattern on HS2. As HS2 offers a considerable change in transport
service provision, these effects are likely to be potentially
huge, so a properly specified transport model could find a completely
different HS2 solution to that proposed.
3.1.3 Even for a public transport scheme much
smaller than HS2 (eg £50 million), DfT modelling guidance
require the transport model to be composed of a full hierarchy
of choices: choice of trip frequency, mode choice, time period
choice, destination choice and route choice, interconnected in
such a way that one choice correctly influences the others by
connecting one choice model with the logsum from the model below
it. The model they used had route choice and some other ad-hoc
models which did not cover the same area and were totally disconnected
from each other. The model should have sufficient spatial detail
to be capable of modelling the infrastructure in question. This
model has about 250 zones (which could be suitable for a £50 million
scheme but would be too few zones for say a £200 million
scheme) whereas for infrastructure of the scale of HS2 the model
should have several thousand zones.
3.1.4 The HS2 model was based on simple elasticities
to determine the additional travel which could be generated by
HS2 providing a faster and better service. These elasticities
were calibrated on relatively small changes to the train speed
and service pattern and are designed to be applied on small rail
schemes, new stations etc. Simple elasticities are inapplicable
for something of the scale of HS2. The HS2 model is using these
elasticities well outside their calibrated range and it is no
wonder that the numbers they come up with are so out of kilter
with reality. Elasticity models say nothing about where this additional
HS2 travel is to come from. This additional HS2 travel is unlikely
to come from other modes of transport because travel (especially
car travel) is declining and has been for the past five or so
years (which pre-dates the recession so is real).
3.1.5 The model forecasting of future levels
of travel used very high growth assumptionsmuch higher
than would normally be used for rail schemeswhich are unlikely
to be achieved. Even the "normal" rail growth assumptions
are unlikely to be achieved. "Normal" rail growth forecasts
are based on the trend of rail growth since privatisationbefore
this, rail travel growth was much lower. Privatisation of the
rail system led to a better rail travel "product" and
better marketing so that rail travel grew at a higher growth rate
than before privatisation. This new rail travel has now been captured
plus travel in general is declining, so rail travel is unlikely
to grow at the rate assumed by HS2. The HS2 BCR is on the cusp
of acceptability so adopting more realistic growth assumptions
could well make it not worth building.
3.1.6 HS2 Ltd. should build a proper transport
model of the country with a full interconnected choice hierarchy
to sufficient spatial detail so as to do the job properly. They
would then have the right tool to be able to design the right
scheme on a sound scientific evidence base with a properly supported
BCR. Only then can they select a route and only then can they
be in a position to be able to persuade people that it is necessary
to build it (if indeed it is).
3.1.7 The assumptions for demand are not robustthese
are based upon economic growth not the precarious financial climate
of the foreseeable future.
3.1.8 Demand will be heavily dependent upon ticket
affordability. This affordability will be challenged by the change
of formula governing increases in regulated fares from RPI+1%
to RPI+3% from January 2012. (ref 17) A recent Passenger
Focus survey quotes fares in Britain already being 1.59% higher
than than any other European country (ref 18) with
some SE commutes costing over £5,000 per annum. The Campaign
for Better Transport comments "Politicians need to...understand
that people simply cannot afford to pay a fifth of their income
just to do a day's work". (ibid) "Government
has allowed Southeastern to increase fares by 7%, 3% above July
2010 RPI. But this masked higher increases approaching 13% on
some routes". (ref 19)
3.1.9 People facing these challenges will seek
alternatives to rail commutehome based work, more local
employment or road-based options such as coach or car, or simply
become unemployed. The 2010 Labour Force Survey1 (ref 20,
p 7) identified several benefits for home-based working,
including a better home-work life balance, reduction in business
costs and time and money spent travelling. Encouraging more home-based
or closer to home working will reduce peak commuter demand and
congestion and support local services. The 2010 Spending Review
(1.39) provides £530 million over the next five
years to develop the UK's broadband network. Current HS2 HSR proposals
fail to consider these changes and their potentially considerable
effect upon demand and viability.
3.1.10 Unless HSR is integrated into a complete
door-to-door service it will not attract passengers (ref 21)
DfT figures (2009) (ref: ibid 2.33) show 50% of all
trips are leisure, 18% business or commuting with 95% of all trips
less than 25 miles and 67% under five miles. This indicates the
narrow market share of all transport forms which a long distance
HSR rail service is seeking to capture.
3.1.11 The UK would be well advised to heed the
experiences of other European nations. In Holland, the Dutch high
speed operator could face bankruptcy; the service has not attracted
sufficient users with some trains having just 15% occupancy; fares
have been forced to drop by more than 50%. (ref 22)
3.2.1 The Sustainability Commission (ref 10)
states HS2 HSR will encourage long distance commuting which is
"inherently unsustainable ... [what is needed is] more distributed
development and local jobs rather than encouraging people to travel
longer and longer distances". Further, the Commission says
that a small proportion of the £17-33 billion HS2 budget
could transform local transport and offer more equal accessibility
& connectivity in towns and cities across Britain.
3.2.2 The CCG outlined some alternative capacity
solutions in their Submission to the 2010 TSC Inquiry. (ref 23)
3.2.3 Sir Richard Branson, chairman of the Virgin
Group, claimed that "if the Government gave the private sector
more freedom to innovate, a further upgrade of the London-Glasgow
WCML could reduce journey times sharply (London to Birmingham
could be reduced by 22 minutes) and be self-funding". (ref 24,
20.9.09) Only one "relief" train to cope with the
Friday peak (18.43 Euston-Crewe) has been allowed to operatewhy
cannot these restrictions be addressed to give immediate relief?
Virgin lose the franchise in April 2012.
3.2.4 There are already five to six trains
per hour throughout the day between London Euston and Milton Keynes.
However in peak times Northampton has only a half hourly service.
It is these peak hour trains where capacity is a problem. These
could be doubled by a grade separated junction South of MK (estimated
cost £243 million) and new, higher performance rolling
stock. These could be delivered within five years at a cost slightly
less than one-third of the £17 billion HSR spend. (ref 25)
3.2.5 Long distance WCML Inter City trains have
only limited overcrowding presently and by increasing the number
of carriages, conversion of one first-class carriage per train
to standard, overall standard class capacity could be increased
by 112% without any significant infrastructure spend. (ref 25)
HS2 HSR is a sledgehammer to crack a nut.
3.2.6 The Spending Review October 2010 has provided
£14 billion for Network Rail for major work on the WCML
& ECML. (ref:Executive Summary p 7) We would expect
this considerable sum to bring some positive resolution to key
issues such as capacity.
3.3.1 Rail travel demand can be managed more
effectively by encouraging tele-commuting, smart ticketing, more
flexible working hours. Research shows that virtual meetings,
video chat and conferencing are overtaking traditional communication
methods as increasingly businesses use virtual ways for face-to-face
meetings. (ref 26)
3.3.2 The Government is calling for evidence
following the Local Transport White Paper 2011 Creating Growth,
Cutting Carbon on alternatives to travel for business and
commuting. Increasingly, people are seeking ways to reduce their
time and travel costs. With increasing uptake of electronic communication,
this is unlikely to fall.
3.2.3 The Public Accounts Committee (ref 27,
9.10.10) recommends the DfT conducts a fundamental review
of the railway industry structure as it "provides little
external challenge to its vested interest in its own growth"
and to "ensure..value for money..restraining the tendency
to seek solutions through growth". This is essential to the
prosperity and economic stability of the UK rail network.
3.4.1 Inflation is rising which will impact on
construction costs and CBR. How will this be accommodated?
Q4: The Strategic Route
4.1.1 "The really time-consuming part of
travelling from the West Midlands to London is getting to Birmingham
city centre. Live in the wrong suburb with no open railway station
and it can take nearly as long to get to New St as HS2 is proposing
to get to London": Telford commuter 5.5.11. This is true
for all HSR stations outside the main urban centre. Eurostar has
encouraged travellers from air as it delivers them straight to
central Paris, a smaller urban centre so shorter time to reach
4.1.2 A Leeds resident writing to the Leeds local
Guardian (21.3.11) calls not for future London-Leeds high speed
links but good links now between Leeds-Sheffield, Leeds-Manchester
and around all three with a fraction of HSR costs being invested
in electrification and more rolling stock.
4.2.1 It may well be worthwhile connecting Liverpool,
Manchester to Bradford, Leeds, York with a cross-Pennine higher
speed rail. These are close major cities which are currently poorly
connected by rail and have relatively few rail trips between themindicators
of high potential benefits. With a proper transport model, which
could model changes to people's origin-destination pattern, such
a scheme would offer a step-change in transport provision and
could provide considerable economic regeneration benefits. HSR
could connect-in to this at some point so that services can be
offered from these cities to places north, south, London and Europe.
Alternatives like these need to be tested in a properly-specified
4.3.1 Appropriate modelling should be used to
inform choices, including a non-London centred approach. The biggest
potential financial benefits are likely to be for the phases from
Birmingham-North, where urban interconnectivity is poor and need
for regeneration is greatest.
4.3.2 Building in stages may spread cost over
time & gives some flexibility to accommodate eg demand changes.
However it runs the risk of phase 1 running over time and
budget, and thus impacting negatively on future phases, with the
possibility that should not be discounted, that they become unaffordable
or uneconomic. This is particularly true for the currently proposed
phase 1 (London-Birmingham) which ignores the present good intercity
rail services, offers the lowest CBR as the total journey is less
than 200km, yet has the highest environmental impact cost on an
AONB. The worst case, which is not unrealistic, is that the Chilterns
AONB will suffer severe degradation through phase 1 without any
benefit to the UK as later stages are never built.
4.4.1 Direct links between HS1 and HS2 are important
but need not necessarily be via London. A link with Heathrow assumes
that increasing the volume of travellers using Heathrow is desirable.
CCG questions this.
Q5: Economic rebalancing and equity
5.1.1 There is scant evidence to prove a causal
link between HS2 HSR and regeneration to those areas most in need,
evidence is inconclusive. The DfT's response to the TSC's recommendations
from their Inquiry into Transport & the Economy 2010/11 (ref 1,
Recommendation 9) sheds no further light.
5.1.2 Expecting one expensive project (HS2) to
resolve the complex and diverse problems of regional poverty,
decline and comparative regional discrepancies of wealth, opportunity
and resources is an extremely high risk strategy. Business leaders
hold disparate views. Government relies heavily on quoting large
sums of money/benefits which it predicts will be generated by
HS2 without substantial or adequately researched information to
support these claims.
5.1.3 Whilst "captains of industry"
speak in favour of HS2 HSR, it is notable that there is a lack
of private capitalists seeking to invest in the project.
5.1.4 HS1 has failed to generate employment in
Ashford. The town's "unemployment rate has fallen more slowly
than the Kent average, the SE average and the GB average".
Other towns off the line have done better. (ref 28)
5.1.5 The DfT predicts that HS2 construction
will generate 9,000 jobs, 1,500 operational on-the-line and 20,000
new jobs at Old Oak Common, 2,000 at Euston, 3,800 at the Birmingham
interchange and 4,500 at Birmingham New Street. Of the 30,000
"new" jobs, 73% will be in London. (ref 6 p 18,
5.1.6 We remain unconvinced that being able to
catch a fast train to the North will encourage people in the South
to travel there, particularly if jobs are harder to find, salaries
are lower and train fares higher. HS2 is more likely to attract
travellers from North to South, which is where they will spend
their disposable income.
5.2.1 Expectation would be that such a public
spend would support local and regional economies. Government predicts
that every working family in the West Midlands will benefit by
£2,600 (ref 29)but this excludes the costs,
resulting in net benefit of £1,400 per working family. However
benefits will not be equally distributed; spending on railways
benefits the better off much more than the lowest income families,
and will do little to help the 9.8% unemployed in that region.
So investment in the network, and changes to its shape, give a
poor rate of return to support local economies.
We suggest investing in directly supporting
business and enterprise now is more beneficial.
5.3.1 Limited and lack of integrated accessibility
and ticket costs will exclude lower income groups. Prime users
will be urban dwellers with high disposable incomes.
5.3.2 The £123 million Masterplan for
Birmingham's Eastside & City University regeneration will
be abandoned as HS2 needs the site, despite the £30 million
already investedand the University wants this back. Is
such a fundamental change wise in the current economy? Can Birmingham's
residents and taxpayers and the Government afford to waste such
amounts when all Councils are cutting services? (ref 30)
Q6.1 Carbon emissions
6.1.1 The DfT's vision is to "target[ing]
investment in new projects that promote green growth"HS2
HSR does not fulfil this criteria. The 2008 Climate Change Act
sets out legally binding targets for an 80% reduction in greenhouse
gases by 2050. Already (May 2011) businesses say this is unrealistic.
HS2 will not help.
6.1.2 The Creating Growth, Cutting Carbon
White Paper 2011 recognises the need to reduce carbon impact
on longer journeys, but places dependence on modal shift from
car to achieve this. Convenience and cost will act against this.
HS2 Ltd estimate as little as 1% of motorway traffic will shift
to HS2. HS2 HSR requires a high load factor to be even broadly
carbon neutral (ref 6 p 53) and during the construction
stage will add to environmental pollution. Higher speeds consume
more energy and emit more carbon.
6.1.3 The first phase of HS2 will have fewer
carbon savings as lower shift from car to air and carbon emissions
from its construction are estimated at 0.3-2.1 million tonnes.
6.1.4 The Call for Evidence following
the White Paper states it is medium distance (10-25 mile) trips
which are responsible for the highest volume of carbon emissions
and some one-third of emissions come from journeys less than 10
miles. (ref 32, 2.15, fig 2.3) HS2 HSR will do nothing
to change this and indeed these figures indicate that investment
in regional and local options offer better carbon reduction potential.
6.1.5 By freeing up capacity at Heathrow, the
government's HS2 high-speed rail project is likely to increase
total UK carbon emissions. Further questions surround the scheme's
broader sustainability credentials. (ref 33)
Q6.2 Environmental costs and benefits
6.2.1 In designing the UK's high-speed railway
sufficient weight must be placed on conserving natural beauty
of designated land. The business case takes into account construction
costs. Those costs reflect design decisions which are driven by
key legislation, policy and objectives protecting AONBs and National
6.2.2 HS2 Ltd says its Appraisal of Sustainability
(AoS) (ref 34, p 7) is in line with SEA requirements
(ref 35). The developer's SEA Summary indicates its
AoS includes the relationship of its own plan (HS2) with other
relevant plans and programmes. However in its AoS documents (ref 34,
ref 36), relevant legislation, policy and objectives
(i) Not included.
(ii) Are insufficiently informative.
(iii) Or the government's obligation is not alluded
If the AoS is incomplete then costs to the natural environment,
and hence the potential monetary costs, cannot be correctly estimated.
6.2.3 Countryside and Rights of Way (CROW) Act
In the context of AONBs, the Definition of Sustainability
Term presented by HS2 in its Appraisal Process (ref 34,
Annex 2) is the CROW Act 2000. Although the developer states
"the single purpose of the AONB designation is to conserve
and enhance the natural beauty of the area" it fails to emphasise
that any Minister of the Crown has a duty of "regard to the
purpose of conserving and enhancing the natural beauty of the
Since the enactment in 2000, so far as we can see,
there have been no major infrastructure developments receiving
legal approbation in any AONB on the proposed scale of HS2. Nor
have there been any in National Parks on the scale of HS2 since
1995 when the same Ministerial duty was included in the Environment
Act section 62. Clearly HS2 Ltd needs to be aware of this duty
in making design decisions.
6.2.4 Planning Policy Statement 7
PPS7 states that AONBs and National Parks are confirmed
as having the highest status of protection in relation to landscape
and scenic beauty. The policy recognises major development may
have serious impacts on the natural beauty of such areas and recreational
opportunities they provide. It says major development should not
take place except in exceptional circumstances and the proposed
infrastructure should be demonstrated to be in the national interest.
6.2.5 In only a brief reference to PPS7 (ref 36,
p 41) in its AoS documents, HS2 Ltd does not describe
the status of protection of designated land, nor the Government's
recognition of the impact major development would have on such
land. In addition, HS2 Ltd has not referred to PPS7 in its Appraisal
Process document (ref 34) despite Government's "Practical
Guide to the SEA Directive" stating Planning Policy Statements
are relevant (ref 35, App 2). Hence the AoS is
insufficiently informative which could give rise to unplanned
increases in construction costs related to impacts on designated
6.2.6 Statutory Designation Criteria
HS2 Ltd's Appraisal Process (ref 34) does
not refer to the Statutory Designation Criteria (ref 38)
for AONBs (Countryside and Rights of Way Act 2000) and National
Parks (National Parks and Access to the Countryside Act 1949).
Criteria include intactness of landscape, presence of incongruous
elements, sense of remoteness, landform from vantage points, natural
looking woodland, presence of traffic noise, strong aesthetic
qualities, a relative lack of human influence, association with
written descriptions, a sense of return to nature, peace and quiet.
These are all qualities that may influence design decisions. These
serious omissions have led to concerns that the DfT, HS2 Ltd and
its consultants have failed to give sufficient weight to conserving
designated land in route design which may give rise to unplanned
6.2.7 When designing a route, it is important
to avoid, or minimise length of route, in AONBs and National Parks.
When a route through designated land is demonstrated to be in
the national interest, a tunnelled option throughout the length
of the designated land should be included for public consultation.
HS2 Ltd has failed to design such a route for phase 1 of the proposed
high-speed line (HS2). If the decision is made to proceed with
HS2, as this would create a precedent in an AONB (6.2.3 above),
it is imperative that any encroachment into the AONB be tunnelled.
The Secretary of State for Transport has said: £We will do
everything we can to mitigate the impacts on areas like the Chilterns".
6.2.8 HS2 Ltd designed a route with engineering
works on a massive scale in the Chilterns AONB with consequent
impacts on landscape. It will involve two viaducts each 500 metres
long and considerable land-take from deep cuttings. HS2 cuttings
are typically 15 metres deep and 70-90 metres wide even when partially
retained (ref 40). These deep cuttings total 9kms
in length. (ref 36, p 84)
6.2.9 Tunnelling produces much less spoil
than deep cutting per km, as well as producing a far superior
environmental landscape solution (although there would be tunnel
vents every 2kms). Because of the total length (9kms) of deep
cutting in the Chilterns AONB, the volume of spoil generated here
is massive: 12 million cubic metres (ref 41), 74%
of which is generated from deep cuttings.
6.2.10 HS2 Ltd estimated its scheme would generate
just 0.68 million cubic metres of spoil in the Chilterns. (ref 42)
This is not supported by recent more thorough research by
the Chilterns Conservation Board and Dr M. Fletcher of the Chiltern
Countryside Group (ref 41) which showed that in the
Chilterns alone the scheme will generate 12 million cubic metres
of spoil. The reasons for the discrepancy are HS2 Ltd did not
allow for the Amersham tunnel being twin-bore, it omitted the
spoil from deep cuttings and it did not include a bulking factor
(x1.75) for loose spoil. Less than 10% of the spoil generated
can be used in the Chilterns.
6.2.11 Spoil removal from the Chilterns
via the route seems likely to be problematic without doing excessive
damage to the AONB, due to the terrain, non-patency of adjacent
tunnels and the large amount of lorry traffic. To move 12 million
cubic metres of spoil by road would create over 1.7 million lorry
movementsie a journey on local roads every 26 seconds every
working day for five years. Thus spoil removal will involve financial
and environmental costs which have not been correctly assessed.
6.2.12 In the light of this discrepancy on spoil
in HS2's AoS, and omission of relevant objectives, policy details
and legal obligation of Government to the AONB, is its AoS reliable
in assessing other impacts of its scheme?
6.2.13 The DfT needs to re-appraise its preferred
route to allow for its impact on the Chilterns AONB and make commensurate
adjustments to its business case. Similar cases may arise when
the business case for the "Y" is considered. (ref 43)
(i) Appendix 5.4 (ref 35) contains
the noise aspect of the Appraisal of Sustainability. The Noise
examination needs to fulfill two essential requirements:
To inform all stakeholders and interested parties
of its extent and degree.
To define the sustainability noise impact in terms
of costs and benefits.
6.2.14 The AoS is a strategic document that is
not final. In terms of noise it concentrates on operational airborne
noise at residential areas. Other aspects have been appraised
at either quantitative or commentary level. No detailed work on
any subjective aspect of noise is included and the information
provided can only be indicative and not definitive.
6.2.15 The method of assessment of railway noise
is based upon a widely used, but not exclusive, method that equates
the actual varying noise levels over a period to a construct of
an equal energy constant noise level over the same period (LAeq,T).
This is both confusing to the layman and can be argued as removing
any significance of the varying character of the noise to aggravate
6.2.16 The World Health Organisation expressly
state that for situations where distinct noise events are present,
such as aircraft or railway noise, measures of individual events
should be obtained. In short LAeq,T should be augmented with Lamax.
If it is accepted that LAeq,T is the best metric to use, HS2 Ltd
have taken the period 0600:2400 whereas in other contexts 0700:2300
is used to define daytime. The selection of a shorter night time
period reduces the amount the HS2 traffic will seem to intrude
into this sensitive period. This reduces the consideration of
the noise impact and the effects in the early morning or late
6.2.17 HS2 Ltd have indicated the areas of potential
impact by reference to the dwellings that would be exposed to
their chosen criteria:
(a) High Noise Level > 73 dB LAeq, 18hr
(b) Qualification for noise insulation > 68
(c) In an area of noticeable increase in railway
criteria are misleading in their relevance to this AoS:
(a) is taken out of its defined context and is
expressly excluded from use outside this context; and
(b) for a dwelling to be subject to noise insulation
should not be taken that the noise is mitigated. Noise within
gardens and outside areas is ignored.
6.2.18 This criterion is very confusing.
For areas already exposed to railway noise the judgement line
is taken as the level of the existing railway noise + 3 dB. For
areas with a low railway noise the value taken is 53 dB. For areas
with no railway noise the value is taken as 50 dB. There is no
consideration for areas with a background level of say 45 dB which
would be required to have a 5 dB penalty imposed rather than the
suggested 3 dB if railway noise already present. There is also
the factor that it is now accepted that a change of level of greater
than 1dB increases the likelihood that there will be an adverse
reaction to the noise.
6.2.19 The AoS does not set out the nature of
airborne noise at residential dwellings. There is no description
of the possible effects of the noise during the day and scant
reference to night time noise.
6.2.20 There is concern as to the data used to
calculate the HS2 Ltd Noise maps. Source levels for the trains
assume future improvements of train set noise. Assumptions are
made about the effectiveness of noise barriers that are at best
first approximations. Given the level of assumptions made and
the inherent degree of accuracy of any computational modelling
exercise it is considered that the noise levels calculated could
be 5-10 dB different from reality.
6.2.21 The information is on daytime exposure
and exposure only to dwellings. Night time noise will occur and
the WHO Night Noise Guidance Levels seek to impose much reduced
levels at this time and would additionally weight night time railway
movements. Both of these factors have been ignored in the AoS.
No consideration has been given to areas of quiet that presently
exist along the route or of the special areas that are held in
trust for the nation. The AONBs must be considered sacrosanct
and warrant a much greater degree of consideration than has been
applied in the AoS.
first requirement of a noise examination is therefore seen not
to have been met.
Without full and exhaustive information on noise and its effects
no sensible analysis of the environmental costs and benefits can
therefore follows that the second requirement is not met.
The information that has been made available does not allow a
proper consideration to be made as to whether the project should
go forward to the next stage. A full Environmental Impact Analysis
can be the only basis for such a decision.
6.2.22 It will be appreciated that this submission
can only raise the questions of the inadequacies of the AoS and
thus the validity of the costs and benefits that have been assumed.
These points can be expanded in a verbal presentation to the Committee.
6.3.1 Released capacity for the "classic"
rail network is one of the given benefits for HS2 HSR. But, if
as suggested, this capacity will be filled by more passenger trains,
the opportunity to increase freight will be limited. However,
as the need for additional capacity has been identified at solely
peak times, if this is resolved, then freight trains can still
be increased outside peak hours. We question whether current freight
trains on the WCML are operating at their maximum load - many
flatbed wagons are often empty.
6.3.2 The CCG believes there are opportunities,
not yet fully considered, to provide more scope for rail freight;
releasing freight from main transport corridors (road & rail)
onto designated freight lines with properly planned HS1, Channel
& Northern sea ports connectivity has many advantages.
6.4.1 HS2 will cause considerable disruption
to existing services at Euston as it will need to be completely
rebuilt over seven to eight years (ref 6, p 54; ref 44,
p 39); to GWML services due to reconstruction of Old
Oak Common station and to Chiltern Railways services with work
between Northolt and West Ruislip. These are significant.
In its vision statement, the DfT specifically refers
to seeking "the best possible advice ... on impacts..investment
and [the] objective to seek good value for money".
The CCG find that the DfT in its response has not adequately addressed
the recommendations made by the Transport Select Committee following
the 2010 Inquiry into Transport & the Economy, particularly
with regard to recommendation 9 concerning regeneration benefits.
Information in HS2's Appraisal of Sustainability
is insufficient, or in some instances incorrect, to allow a reliable
assessment of the environmental impact of HS2 HSR to be made.
This is likely to impact on its business case.
The Government has a National Infrastructure Plan
(2010). The CCG suggests that the DfT and the Coalition Government
do not appear to have a cohesive, considered and integrated approach
to transport planning or forward vision linked to agreed objectives.
The HS2 HSR project plans to spend billions on a
new route which is questionable in terms of sustainability and
economic benefits and, to be financially viable, encourages travel.
It will be accessible physically and financially to a UK minority.
The White Paper "Creating Growth, Cutting
Carbons" asks businesses and commuters to reduce
travel, seek green alternatives and advocates investment in local
These two visions are contradictory. In the present
global financial situation, it would be wise to identify priorities
which are complementary and realistically achievable.
It may well be in our technologically fast-moving
world that the UK has missed the optimum "window" for
investment in HSR. As people find new ways of communicating and
doing business there is a risk that HSR could be out of date by
the time it comes on stream. A lesson may be learnt from the planning
of the new city of Milton Keynes est. 1967. This "state of
the art" city now has one of the slowest broadband connections
in the UK for, at the time, its planners did not place sufficient
weight on technological and demand changes. (ref 45)
1. Transport & the Economy: Government response
to the Committee's Third Report of Session 2010-12 HC473.
2. Gourvish, T (2010) The High Speed Revolution:
History and Prospects.
3. Comparison of High Speed Lines CAPEX Nov 2009/DfT
HS2 Economic Case p 38.
4. Virgin Trains Euston-Birmingham 1h11m/wikipedia
5. HS2 Report to Government March 2010, 3.5.14.
6. High Speed Rail: Investing in Britain's Future.
Consultation Feb 2011, p 53 and 54.
7. Delivering a Sustainable Transport System
8. www.networkrail.co.uk/north 16.2.11.
9. Conservative Party Conference 4.10.10.
11. CBI News Release 9.5.11.
12. Gilligan, Daily Telegraph 4.4.11;
12a Evening Standard 4.5.10.
13. Independent 9.4.11.
14. Guardian 25.1.11, Transport Times
16. Public Accounts Committee Conclusion 3 Increasing
Passenger Rail Capacity 9.11.10.
17. Passenger Focus 11.5.11.
18. Daily Telegraph 31.12.10.
19. Milward, Daily Telegraph 31.12.10.
21. Passenger Focus 2010c; http://www.dft.gov.uk/about/vision
22. Reuters 1.2.11.
23. Chiltern Countryside Group submission to
TSC Inquiry into Transport & the Economy:
24. http://www.ft.com/ 20.9.09.
25. Chris Stokes, rail consultant, Bucks. CC
HS2 Summit 15.4.11.
26. Forrester Research, Computer Weekly Nov 2010.
27. Public Accounts Committee Conclusion 6 Increasing
Passenger Rail Capacity.
28. Gilligan, Daily Telegraph 4.4.11/Office of
29. Secretary of State Philip Hammond, Conservative
Central Office 14.4.11.
30. Birmingham Post 16.3.11.
32. Creating Growth, Cutting Carbon White Paper:
Call for Evidence 2.15, fig 2.3.
33. http://www.endsreport.com/28048/ 28.3.11.
34. HS2 Appraisal of Sustainability The Appraisal
Process Appendix 1.
35. A Practical Guide to the SEA Directive
36. HS2 Appraisal of Sustainability Main Report
37. Planning Policy Statement 7 Sustainable Development
in Rural Areas paragraphs 21,22.
38. Guidance for Assessing Landscapes for Designation
as National Park or Areas of Outstanding Natural Beauty in England
page 3 and Appendix 1
40. HS2 maps 7 and 8.
41. HS2over 1 million lorry movements
42. HS2 Appraisal of Sustainability Main Report
volume 2 Plans and Appraisal Framework page 34.
43. High level assessment of the wider network
optionsReverse "S" and "Y" network,
44. InterCity West Coast Consultation January
2011 p 39.