Further written evidence from the Chiltern
Countryside Group (HSR 178A)|
THE ENVIRONMENTAL IMPACT OF HS2 ON THE CHILTERNS
AREA OF OUTSTANDING NATURAL BEAUTY
This report presented to the Transport Select Committee
is derived from Appendices C and D of the submission by the Chiltern
Countryside Group to the High Speed Rail Investing in Britain's
Future Consultation. These papers are available for inspection
on the Chiltern Countryside Group website www.chilterncountrysidegroup.org.
These are full papers with detailed maps, tables
of spoil volumes and complete reference lists. References provided
in this report presented to the Transport Select Committee are
numbered in accordance with those in the full papers.
(a) Purposes of an Area of Outstanding Natural
Beauty (AONB) are:
conserve and enhance the natural beauty of the landscape.
meet the need for quiet enjoyment of the countryside (Countryside
and Rights of Way Act 2000 s87).
These purposes clearly foster tourism as a function
(b) The Misbourne Valley currently has a high
amenity value in terms of tourism and is well-connected by road
and local rail services. This role would be severely impacted
by the HS2 project which travels on the surface for 14kms in the
(c) The scheme risks the permanent future use
of the Misbourne Aquifer as an amenity supplying water to a large
area of the northwest Home Counties. The Appraisal of Sustainability
fails to take into account the Department for Transport's WebTAG
requirement that the rarity of a water attribute must be
considered in designing transport infrastructure.
The HS2 scheme could also
potentially cause the River Misbourne - a globally rare chalk
stream -to run dry by lowering the water table.
(d) Nearly 11 hectares of ancient woodland in
the AONB will be lost to HS2. In total 46 hectares will be lost
or fragmented in the AONB. This habitat is irreplaceable.
HS2's plans conflict with
The Natural Choice White Paper (June 2011) where Government affirmed
its commitment to conserving priority habitats - such as ancient
woodland - "with no net loss".
(a) Research shows that HS2's route will generate
a potential surplus of 6.43 million cubic metres of solid spoil
in the Chilterns (see full paper for details www.chilterncountrysidegroup.org
) For comparison purposes, some four million cubic metres were
produced at the Kent coast from boring the Channel Tunnel.
(b) In designing transport infrastructure it
is normally assumed that spoil from cuttings and embankments cancel
one another out.
In the Chilterns, however,
only some 10% of the spoil generated will be needed for construction
purposes. There are few other requirements for local spoil:
roads that cross HS2 in the Chilterns will remain on the level,
and availability of sites for noise bunds in the AONB is
(c) When bulked, 6.43 million cubic metres of
solid spoil equate to over 11 million cubic metres (loose). Could
this be moved via the route? There are obstacles - non-patent
tunnels and HS2 crossing the Chiltern line/A413. Could it be moved
by rail? There would be limited capacity on local lines.
(d) Assuming the spoil is to be moved by 15 cubic
metre capacity trucks, this equates to over 1.5 million lorry
movements - a lorry movement every 30 seconds for 10 hours a day,
every working day for five years. The safety aspect of heavy lorries
needing to integrate with pedestrians and traffic on narrow rural
roads and village high streets would be considerable.
(e) A satisfactory disposal site is not apparent.
Current potential sites are limited by restricted vehicle movements,
lack of planning permission, site capacity and inadequate transport
(f) The developer has said that concerns over
spoil would be raised at a later stage, but the issues here raise
the question "Is the current route in the Chilterns viable?"
1. TOURISM AND
(a) Purposes of an Area of Outstanding Natural
Beauty (AONB) are:
conserve and enhance the natural beauty of the landscape.
meet the need for quiet enjoyment of the countryside (Countryside
and Rights of Way Act 2000 s87).
These purposes foster tourism
as a function of AONBs.
(b) The Countryside and Rights of Way Act 2000
s85 and Planning Policy Statement 7 (paragraphs 21 and 22) are
concerned with protecting AONBs. These are discussed in the Chiltern
Countryside Group's first submission to the Transport Committee.
Moreover, the Government indicated
its renewed commitment to protecting AONBs as recently as July
25 2011in the draft National Planning Policy Framework paragraph
(c) The Chilterns AONB is just 20 miles from
the capital. It is the only AONB between London and Birmingham.
(d) HS2's route in the AONB will travel for some
14kms on the surface in the Misbourne Valley north of Amersham.
This part of the Misbourne Valley functions as a readily accessible
tourist amenity. It offers rural tranquillity and yet is part
of the AONB well connected by local roads and the Chiltern line
to London, its conurbations and other towns.
(e) Current plans for HS2 will urbanise the AONB's
Misbourne Valley north of Amersham. Urbanising features include
two 500m viaducts; nine tunnel portals; a fully retained wall
section; and HS2 raised on embankment. Land from nearly 8km of
deep and very deep cuttings typically 65-90 metres wide at the
top and 15 metres deep will be removed from the AONB to build
(f) Under these plans HS2 would have a severe
impact on the use of the Misbourne Valley north of Amersham as
a rural amenity for walkers, cyclists, horse-riders and for those
seeking a tranquil respite away from urban life. The corridor
will effectively act as a steel and concrete barrier to these
activities and prevent the valley north of Amersham from providing
the natural scenic beauty that is its function in the AONB.
Thus HS2 will have the effect
- in the long term - of discouraging visitors to the Misbourne
Valley, unlike the A413 which brings them to the area.
(g) Twenty five rights of way would be severed
by HS2 in the AONB.1 These include national and regional
walking and cycle trails. Many more rights of way will be affected
due to loss of tranquillity and detrimental impacts on views.
(h) Scenic views and tranquillity currently offered
in the vicinity of five popular destinations will be severely
impacted by HS2: Great Missenden, Wendover, Old Amersham, Little
Missenden and The Lee. These destinations would lose their attraction
in terms of daytrips since the Misbourne Valley would become urbanised
if the current plans for HS2 went ahead.
2. THE MISBOURNE
(a) The Misbourne aquifer supplies drinking water
to a large area of the northwest Home Counties. In designing the
HS2 project the developer has failed to take into account the
Department for Transport's WebTAG requirement which state that
the rarity of a water attribute must be considered in designing
new transport infrastructure (2 HS2's Approach: Does
it Protect Groundwater Resources? Journal Inst. Water 169 64-65
Fletcher, M. 2011). The Appraisal of Sustainability (AoS) should
have taken into account the fact that southeast England currently
faces extreme water stress due to population pressure on current
water sources.3 Extreme water stress in SE England
was highlighted in the Cave Report (2009) http://archive.defra.gov.uk/environment/quality/water/industry/cavereview/documents/cavereview-finalreport.pdf
If HS2 goes ahead as planned
it potentially risks the use of the Misbourne Aquifer as a source
of drinking water to future generations.4
(b) The River Misbourne supports biodiversity
characteristic of chalk streams including nationally protected
species. Such water courses are globally rare.
The HS2 scheme could potentially
cause the river to run dry by lowering the water table.4
1 Statement of
Environmental Impact on the Chilterns AONB
2 WebTAG paragraph
3 How water availability
may change, as temperatures, population and industrialisation
4 Bailey, H Concerns
arising from the Geology and Hydrology of the ground underlying
the High Speed (HS2) routes through the Chilterns http://www.chilternsociety.org.uk/hs2/paper02.php
HS2 SPOIL IN
1. Chilterns Spoil Quantities
The author's research shows that HS2's route will
generate a potential surplus of 6.43 million cubic metres of solid
spoil in the Chilterns. For comparison purposes, the surplus amount
produced at the Kent coast from boring the Channel Tunnel was
some four million cubic metres.5
The developer originally claimed that the Chiltern
tunnels would produce just 0.68 million cubic metres of solid
material,1 but this was amended (15 July) just 14 days
before the end of the five month consultation period to produce
a similar estimate to that of the author.
However, HS2's amended spoil quantities do not include
any value for Chilterns cuttings which appear to generate vast
quantities of surplus waste: 4.82 million cubic metres (Table
1 below and Tables in full paper www.chilterncountrysidegroup.org
In designing transport infrastructure it is normally
assumed that spoil from cuttings and embankments cancel one another
out. The Appraisal of Sustainability (AoS) tells us this is the
assumption for the HS2 project.6
In fact, it is likely that only some 10% of spoil
generated in the Chilterns can be used in the area:
VOLUME OF SURPLUS CUTTINGS SPOIL AFTER EMBANKING
HAS BEEN ALLOWED FOR
||Volume of Spoil (solid)|
|Cuttings (9.2kms long incl. green tunnels)
|Volume of Surplus Cutting Spoil
(see Table 2*)
TOTAL VOLUME OF CHILTERN SURPLUS SPOIL
|Location||Volume of Spoil (solid)
|Amersham Tunnel (9.6kms long)||1.42Mm3
|Little Missenden Tunnel (1.26kms long)
|Volume of Surplus Cutting/Embanking Spoil (see Table 1)*
|Total Chiltern Surplus Spoil||6.43Mm3
2. How Much Spoil will be used for Construction Purposes
in the Chilterns area?
(a) There are few embankments. Total embanking within the
AONB, including the route north to Stoke Mandeville, is estimated
to use just 6.2% of the spoil the Chilterns route will generate
(of 6.86 million cubic metres gross, 0.43 million cubic metres
to be used for embanking).
(b) Engineers might expect spoil to be needed to build bridges
for roads that will cross the railway, but lanes in the AONB are
planned to remain at their present levels (HS2 Maps 7-9).
(c) Elsewhere on the route excess spoil is expected to make
bunds for noise and visual mitigation, but this raises concerns
within the AONB (see below).
3. Bulking-up Will Impact on Spoil Transport
When bulking-up is taken into account, the surplus 6.43 million
cubic metres of solid material equates to more than 11 million
cubic metres of loose spoil.
Assuming trucks carry 15 cubic metres, to move the predicted bulked
Chiltern spoil quantities by road would create over 1.5 million
lorry movements which is equivalent to a lorry movement every
30 seconds on local roads every working day, 10 hours a day for
4. Surplus Spoil cannot be Left by the Route in the AONB
The developer may be considering simply leaving spoil on nearby
land in the AONB. This would conflict with law, current and draft
Government policy, and objectives concerned with protecting the
landscape of designated land (Countryside and Rights of Way Act
2000 s85; Planning Policy Statement 7 paragraphs 21 and 22; draft
National Planning Policy Framework paragraph 167; Statutory Designation
Criteria - Guidance for Assessing Landscapes for Designation as
National Park or Area of Outstanding Natural Beauty.11
In addition, it is simply not conceivable considering the vast
quantities involved: if excess loose spoil were to be left as
a one metre deep layer in the AONB, it would occupy an approximate
500 metre-wide swathe on either side of HS2's surface route. This
would extend for some 15kms of the AONB (from Amersham to north
of Wendover, avoiding settlements and woodland).
The Department for Transport (DfT) intends that excess spoil should
be consumed by building bunds in the AONB.13 However
potential locations for bunds would be limited, for example by:
(a) Eighteenth century Shardeloes Registered Park;
(b) Eight ancient woodland sites;
(c) Setting of an earthworks Ancient Scheduled Monument;
(d) Being on a steep slope; and
(e) Lack of requirement due to green tunnels and viaducts.
Apart from a few exceptions, of the remaining sites where bunds
could potentially be built they would be of questionable use for
noise mitigation due to lack of nearby habitation and the route
being in deep cutting.
5. How Will Spoil be transported from the Chilterns?
Research to-date has detected no safe or practical method of transporting
large spoil quantities from the Chilterns:
(a) Via the route:
There are obstacles to building HS2 from the embryonic route in
the Chilterns. The non-patent Little Missenden and Amersham Tunnels,
and the need to cross the Chiltern line at Little Missenden would
appear to prevent spoil generated between the two tunnels from
being transferred via the route (HS2 Map 7).
Spoil produced from AONB cuttings north of Little Missenden Tunnel
cannot apparently be moved via the route unless a means for transporting
heavily laden earthmovers is built over the combined Chiltern
line/A413 crossing south of Wendover (HS2 Maps 8 and 9).
In addition there are environmental objections to conveying Chilterns
spoil to the Aylesbury Vale (item 6 below).
(b) By rail:
This appears highly unlikely considering the disruption to Chiltern
lines, the volumes of spoil involved, and the destruction of yet
more of the AONB to put in the necessary branch lines.
If the destination for the Chilterns spoil was Calvert landfill,
the branch line to Calvert from north of Aylesbury is too constrained
- being single track - to take the required volume of traffic
for the carriage of over 11 million cubic metres of loose spoil.
(c) By Road:
The impact from transport of spoil on local roads - particularly
on lesser roads leading to disposal sites - would be massive.
The safety aspect of heavy lorries - one every 30 seconds 10 hours
a day each working day for five years - having to integrate with
pedestrians and traffic on narrow rural roads and village high
streets would potentially have serious consequences on the numbers
of road accidents and casualties.
6. Can the Developer Make Use of Chilterns Spoil Elsewhere
on the HS2 Route?
Concerns have been raised over the use of Chilterns spoil for
making bunds elsewhere:
(a) There will be obstacles - the Chiltern line and non-patent
tunnels as noted previously - to using the route to carry spoil
away from construction work in the Chilterns.
(b) The carriage of 11 million cubic metres of loose spoil
to distant locations will impact on HS2's carbon case. Carbon
from construction plant equipment is currently set at zero in
the AoS (item 9 below) so the environmental cost of such an exercise
has not been included.
(c) It is likely that 90% or more of Chiltern spoil will be
chalk. Concerns have been raised over vast quantities of chalk
affecting the pH - and therefore the biodiversity - of adjacent
water courses, wildlife sites or other important habitats in the
(d) The construction of noise bunds must not impede the flow
of flood water in the Vale.
(e) There could be potential problems with interim spoil storage.
(f) Is chalk a viable material for constructing bunds? In
a response to a Freedom of Information (FOI11-204) request HS2
says "the use of chalk spoil for landscaping is dependent
on the type encountered. Generally we would expect to be able
to use chalk spoil for the construction of bunds, but HS2 Ltd
recognises that this might not always be possible."
(g) There may be excess spoil generated from the many deep
cuttings in Warwickshire and Northamptonshire which would provide
a further source of spoil for HS2 in the Aylesbury Vale.
7. Where will the Chilterns Spoil be Dumped?
Research into potential sites in Buckinghamshire and Chinnor Quarry
in South Oxfordshire shows that there are no obvious sites for
disposal of HS2 spoil: lack of planning permission, insufficient
site capacity, inadequate transport links and restrictions for
consented vehicle movements on access roads being the reasons.
8. Impact of Cuttings on Ancient Woodland
Nearly 11 hectares of ancient woodland will be destroyed in the
Chilterns AONB and in total over 46 hectares of ancient woodland
will either be lost or fragmented. This woodland is irreplaceable.
In addition literature shows HS2 is highly likely to cause drying
up of soil from the construction of nearby deep cuttings.24
There are also concerns over pollution of ancient woodland from
the hundreds of thousands of construction vehicle movements from
generating and transporting Chilterns spoil.
Probable results would be a reduction in biodiversity and size
of nearby ancient woodland sites.
Since the date the route was published (February 2011), the Government
has affirmed its commitment to conserving priority habitats -
such as ancient woodland - "with no net loss" in The
Natural Choice White Paper (June 2011).22
9. Embedded Carbon - Usage of Construction Plant Equipment
Set at Zero
The AoS tells us its embedded (construction) carbon has been estimated
from carriage of construction materials, from carriage of spoil
from tunnelling, from operating tunnel boring machines, from the
manufacture of materials such as concrete and steel and from the
manufacture of trains.8
However, HS2's AoS says the estimate for carbon emitted from the
usage of construction plant equipment- such as earthmovers, lorries,
grabbers, diggers, bulldozers and dump trucks - has been set at
There are 90kms of deep and very deep cuttings (10-20 metres deep)
on HS2's phase 1 route.13 This length amounts to virtually
half (49%) the phase 1 route. At such cuttings, construction plant
equipment will be involved in massive spoil generation, its transferral
along the route to where it might be needed, and then finally
using the spoil for construction purposes.
The omission of carbon from usage of construction plant equipment
from the total quoted embedded carbon is not referred to in the
government's Consultation document: Investing in Britain's Future.
10. Financial Cost of Chilterns Spoil Disposal
In a response to FOI requests (FOI11-220 and FOI11-220B) the developer
states it has assumed disposal of excavated spoil at the rate
of £75-80 per cubic metre where:
(a) The cost includes landfill tariff and spoil carriage.
(b) The cost relates to the disposal of un-bulked solid material.
Based on these assumptions the cost of disposal of 6.43 million
cubic metres of solid material is £482 million to £514
This would be an increased cost of nearly £½ billion
(£431 million to £460 million) on the developer's cost
of its original estimated waste quantity for the Chilterns (0.68
million cubic metres).
11. The Developer's Miscalculations and Amended Total Spoil
The Appraisal of Sustainability (AoS) is a comprehensive 782-page
report produced to support the case for HS2 and is the result
of years of work led by highly qualified teams of civil engineers,
environmentalists and economists. Yet it contains an extraordinary
series of simple errors and miscalculations on waste which were
detected by the author less than three months after its publication.
Out of a total of eight sites listed in the February 2011 AoS
where spoil would be generated, five were wrong. HS2 originally
estimated that the total spoil generated by the London-Birmingham
route was just 1.83 million cubic metres of spoil (solid).1
On 15 July - just 14 days before the end of the five month public
consultation period - an erratum was issued. HS2's estimate for
total spoil was now almost three million cubic metres.
Why did the DfT wait to publish the erratum until 14 days before
the end of the public consultation period despite the errors in
the Chilterns and Warwickshire tunnelling being pointed out to
the developer in May (Chiltern Conservation Board and FOI11-238)?
This amounts to with-holding relevant information from consultees
for nine weeks and then not given them a chance to respond in
their submissions. An amendment, made on this basis and at such
a stage, conflicts with paragraph 3.5 of The Government's Code
of Practice on Consultation.
In addition, despite the developer amending its data, the spoil
generated from excavating for the subterranean Old Oak Common
Station box - which amounts to nearly 1 million cubic metres
- as well as potentially the Chilterns cuttings, as described
previously, have been omitted from the 15 July amended value for
the project.1 Altogether the author estimates the phase
1 route between London and Birmingham could potentially produce,
including surplus from the Chilterns cuttings, a total of 8.72
million cubic metres of spoil (solid).
HS2 tells us that its AoS is "in line with" the requirements
of the EU's Strategic Environmental Assessment (SEA) (27). In
stating this, it is accepted by government and the public that
information in the AoS is of a standard that can be relied on
for accuracy and transparency. Clearly this is not the case.
12. Is HS2's Route Viable?
There is insufficient evidence that the preferred HS2 route in
the Chilterns is viable in the light of: the potential vast surplus
spoil quantities; the resulting massive impact on safety on local
roads; the paucity of landfill sites; and the viability of transporting
vast quantities of spoil from the Chilterns to the Aylesbury Vale.
Correspondence (20 July) from Secretary of State Philip Hammond
to David Lidington MP (Ref MC/4916) states:
"We have not attempted at this stage to calculate the
total amount of spoil that would need to be transported, or over
what distance, as it would depend on the amount we could re-use
along the route and how much spoil we could move within the railway
corridor rather than on local roads. If the Government goes ahead
with the line we would do the detailed design work and would calculate
the amount of spoil produced and how and where it would be disposed
of or re-used."
"Should a decision be taken to proceed, the relevant work
on construction logistics would be done at the next stage of design,
and would form part of the Environmental Impact Assessment."
As outlined here and in detail in the full paper www.chilterncountrysidegroup.org,
spoil volumes can be estimated using the developer's own dimensions
of cuttings and embankments from HS2's detailed maps. As discussed,
observations can be made on features which would restrict Chiltern
spoil usage and transport.
The Government's response appears to be grossly inadequate in
addressing the concerns raised about the viability of the Chilterns
route with regard to spoil, and the developer - to date - seems
unwilling/unable to refute the evidence presented in this paper.
Considering the concerns raised here over the potential vast quantities
involved, it would appear to be sensible planning for the developer
to be asked to provide further information at this stage as to
how and where it plans to dispose of the surplus spoil generated
in the Chilterns.
13. Are concerns over Chiltern Spoil recognised by the
The author understands that kilometres-long deep cuttings in the
Chilterns are giving HS2 cause for concern.
The evidence for this is an HS2 Ltd seminar held for local councillors
in mid-July. On this occasion HS2's Senior Engineer John Castle
was quoted as saying:
HS2 are "seriously considering extending the (Amersham) tunnel"
towards Great Missenden. "The more we look at the cutting,
the more problems we see".
HS2's Alison Munro, Chief Executive, was present at the meeting.
Fellow of the Institution of Civil Engineers Derek Godfrey has
provided technical information and commented in a professional
capacity on the full paper which is gratefully acknowledged.
I would also like to thank Steve Rodrick, Chief Officer of the
Chilterns Conservation Board, for his encouragement and advice,
and Neil Jackson, Conservation and Landscape Officer of the Chilterns
Conservation Board, for producing all the raw data and maps in
the full paper and advising me on AONB features.
Marilyn Fletcher B.Sc. Ph.D.
Dr. Fletcher is a researcher in Biology and graduate of the University
of Sheffield. After qualifying for her Ph.D. at the University
of London, Dr. Fletcher lectured to under-graduates at
the university for 15 years. She also supervised post-graduate
students for Ph.D. and has published papers in Biology.
She is now an independent researcher specialising in the environment
20 August 2011
1 HS2 Appraisal of Sustainability Main Report volume
2 Plans and Appraisal Framework page 34
5 Channel Tunnel Marine Works, Shakespeare Cliff
Appraisal of Sustainability Main Report Volume 1, page 121
8 HS2 AoS Appendix 2 Greenhouse Gas
Emissions pages 11
11 Guidance for
Assessing Landscapes for Designation as National Park or Area
of Outstanding Natural Beauty on England, page 3 and Appendix
13 High Speed Rail: Investing in Britain's
Future Consultation pages 108, 109 http://highspeedrail.dft.gov.uk/sites/highspeedrail.dft.gov.uk/files/hsr-consultation.pdf
22 The Natural Choice: Securing the
Value of Nature, White Paper
24 Corney, PM, Smithers, RJ, Kirby,
JS, Peterken GF, Le Duc, MG & Marrs RH (2008) Impacts of Development
on the Ecology of Ancient Woodland
27 The Appraisal Process Appendix
1 Appraisal of Sustainability page 7