High Speed Rail - Transport Committee Contents

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.

SUMMARY

1.  ENVIRONMENT

(a)  Purposes of an Area of Outstanding Natural Beauty (AONB) are:

—  To conserve and enhance the natural beauty of the landscape.

—  To 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 of AONBs.

(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 Chilterns AONB.

(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".

2.  SPOIL

(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 limited.

(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 links.

(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 THE CHILTERNS AREA OF OUTSTANDING NATURAL BEAUTY

(a)  Purposes of an Area of Outstanding Natural Beauty (AONB) are:

—  To conserve and enhance the natural beauty of the landscape.

—  To 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 167.

(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 HS2.

(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 AQUIFER AND RIVER

(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

REFERENCES

¹  Statement of Environmental Impact on the Chilterns AONB
http://www.chilternsaonb.org/downloads/high_speed_2/statement-of-environmental-impact-on-the-chilterns-aonb.pdf

²  WebTAG paragraph 1.2.9 http://www.dft.gov.uk/webtag/documents/expert/unit3.3.11.php 

³  How water availability may change, as temperatures, population and industrialisation increase
http://news.bbc.co.uk/1/hi/7821082.stm

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 THE CHILTERNS AREA OF OUTSTANDING NATURAL BEAUTY: IS THE ROUTE VIABLE?

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

Tunnels

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.

Cuttings

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 Appendix D).

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:

Table 1

VOLUME OF SURPLUS CUTTINGS SPOIL AFTER EMBANKING HAS BEEN ALLOWED FOR

Cuttings/Embanking	Volume of Spoil (solid)
Cuttings (9.2kms long incl. green tunnels)	5.25Mm3
Embanking Requirements	0.43Mm3
Volume of Surplus Cutting Spoil	4.82Mm3 (see Table 2*)

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)	0.19Mm3
Volume of Surplus Cutting/Embanking Spoil (see Table 1)*	4.82Mm3
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 five years.

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 Aylesbury Vale.

(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 zero.⁸

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 million.

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 Quantity

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 developer?

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. http://www.buckinghamshireexaminer.co.uk/south-bucks-news/local-buckinghamshire-examiner-news/2011/07/21/appalling-new-threat-from-hs2-114018-29095843/

ACKNOWLEDGEMENTS

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.

QUALIFICATIONS TO EXPRESS AN OPINION:

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 and sustainability.

20 August 2011

REFERENCES (NUMBERED IN ACCORDANCE WITH THOSE IN THE FULL PAPER)

¹  HS2 Appraisal of Sustainability Main Report volume 2 Plans and Appraisal Framework page 34
http://highspeedrail.dft.gov.uk/library/documents/appraisal-sustainability

⁵  Channel Tunnel Marine Works, Shakespeare Cliff http://www.maddrell-consultancy-services.co.uk/uk.php

⁶  HS2 Appraisal of Sustainability Main Report Volume 1, page 121
http://highspeedrail.dft.gov.uk/sites/highspeedrail.dft.gov.uk/files/hs2-aos-report01_0.pdf

⁸  HS2 AoS Appendix 2 Greenhouse Gas Emissions pages 11
http://highspeedrail.dft.gov.uk/sites/highspeedrail.dft.gov.uk/files/hs2-aos-appendix02.pdf

¹¹  Guidance for Assessing Landscapes for Designation as National Park or Area of Outstanding Natural Beauty on England, page 3 and Appendix 1
http://www.naturalengland.org.uk/Images/B1DesignationGuidanceMar11_tcm6-26242.pdf

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
http://www.official-documents.gov.uk/document/cm80/8082/8082.pdf paragraph 2.9.

²⁴  Corney, PM, Smithers, RJ, Kirby, JS, Peterken GF, Le Duc, MG & Marrs RH (2008) Impacts of Development on the Ecology of Ancient Woodland
http://www.woodlandtrust.org.uk/SiteCollectionDocuments/pdf/policy-and-campaigns/woodwatch/impacts-development-on-ecology-ancient-woodland.pdf

²⁷  The Appraisal Process Appendix 1 Appraisal of Sustainability page 7
http://highspeedrail.dft.gov.uk/sites/highspeedrail.dft.gov.uk/files/hs2-aos-appendix01.pdf

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Prepared 8 November 2011