Written evidence from WPCSTOPHS2 (HSR
33)
1. INTRODUCTION
1.1 This submission represents the views of the
WPCSTOPHS2 Group, a group formed amongst residents of Whittington
and Lichfield District to consider the impact of proposals for
High Speed Rail (HSR). As our name suggests, our group was initially
formed in opposition to HS2, not unnaturally given our proximity
to the proposed route. However this vantage point has enabled
us to study the proposals in much more detail than other UK residents
have felt necessary, and it is very clear to us that the proposals
make little overall sense for the UK as a whole. We therefore
remain firmly opposed to the project.
1.2 We welcome the review by the Transport Select
Committee, and agree with many of the issues and questions the
Committee are planning to pursue. We comment specifically on some
of the issues raised in our evidence below. In general however,
our overriding concerns about the proposals for HSR are as follows:
(i) The huge project cost, and the net public
subsidy (£17.1 billion for the "Y" phase alone)
are an unnecessary waste of public funds and do not address the
shortcomings of public transport in the UK. We are not convinced
by the demand or benefit case as presented by the Department for
Transport (DfT)—if the benefits really exist, why is a public
subsidy required?
(ii) Much better, more flexible and cheaper alternatives
exist to satisfy demand for intercity travel, which have not been
properly represented by the DfT. These can give much earlier relief
for overcrowding, and the lower cost would give scope to address
other weaknesses in transport infrastructure.
(iii) The proposals will mean unnecessary destruction
of the environment and cause hardship and blight to local communities.
This has not been properly considered and is ignored in the business
case.
(iv) We are concerned about the role of HS2 Ltd,
and the lack of process for managing consultation responses. We
have found HS2 Ltd analysis to be unclear and selective in favour
of the project, and consultation questions to be carefully crafted
for a positive response with no clear procedure for review. It
is disingenuous for a consultation to be conducted about High
Speed Rail in general whilst so little has yet been published
for routes north of Birmingham and there has been so little engagement
of the general public beyond the HS2 route. Whilst we recognise
this may not fall within the Committee's normal line of enquiry,
we strongly believe that a much more independent public consultation
process is necessary for a project of this importance.
1.3 We have tabled our specific comments below
to reference the issues being addressed by the Committee.
2. ISSUE 2: HSR
FIT WITH
GOVERNMENT TRANSPORT
OBJECTIVES
2.1 We are concerned at the apparent lack of
a comprehensive transport strategy and the failure to develop
rail as part of an integrated approach. We share the desire to
improve inter-urban transport links in the UK, and recognise the
important place that fast, efficient rail services have in this
infrastructure. Our major concern however is that the scale of
expenditure proposed on HSR will soak up all available transport
funding, starving other transport services of maintenance and
development for many years to come, as appears to have been the
case in France. This will benefit relatively few travellers on
HSR and deprive many more on other routes.
2.2 There are a wide range of transport needs
that are not adequately provided at present, and these vary by
region and individual. From our local station at Lichfield we
currently have a very good peak time service to London, with a
fast journey time of 69 minutes. Our rail needs are to improve
station facilities and to improve journey times to other destinations
(currently 126 minutes to Bristol, 170 minutes to Cambridge etc).
Instead, HSR will bypass Lichfield, leaving us with fewer, slower
rail services to London or the environmentally damaging prospect
of driving to Birmingham to join HSR. Many other cities and towns
are also in this position, with HSR not addressing real issues
and creating worse services despite rising demand.
2.3 The reality is that we already have fast
rail connectivity with London in the UK, comparing favourably
with Europe. Our major problems are capacity (addressed by HSR
but at great cost) and the wider transport network (not addressed
by HSR, and probably damaged by it). Average journey times between
the capital and each country's five largest cities are:[31]
Germany 4hrs 04m; France 3hrs 41m; Italy 3hrs 04m; Spain 2hrs
31m; UK 2hrs 25m.
2.4 A real alternative to HS2 is available and
was initially developed for the Department of Transport by Atkins
as part of the March 2010 case for HS2.[32]
We believe that this alternative, known as RP2, has not been adequately
presented or had the consideration by the DfT that it merits,
receiving only cursory review and rejection when reappearing in
part as Scenario A in the latest consultation papers.[33]
In effect, RP2 represents an upgrade to the existing WCML by extending
trains and removing pinch points, thereby meeting capacity demands
and generating the same fare income at a fraction of the cost
of HS2. Furthermore, this approach can be evolved as demand rises,
delivering benefits sooner, and to take advantage of new signalling
technology as this becomes available to increase speeds and capacity
further. Information on this alternative has been presented by
HS2 Action Alliance,[34]
has never been refuted, and deserves full and detailed consideration.
2.5 We would also add an obvious point that transport
needs in the UK cannot be met by inter-urban train services alone.
A more integrated efficient infrastructure is required. In the
West Midlands there are many areas where business is inhibited
by traffic congestion that could be relieved by improvements to
the road network, and many opportunities to relieve congestion
through improvements to local transport facilities (such as local
bus and train services, or expansion of Birmingham Airport to
avoid journeys to Heathrow). The Government transport strategy
should be providing a lead, and funding, to support regional schemes.
3. ISSUE 3: THE
BUSINESS CASE
3.1 We find the business case presented for HSR
to be deficient and surprisingly uncommercial. It is puzzling
that the proposals are presented with so little detail on sections
north of Birmingham, without reference to a realistic alternative,
and without a full examination of a downside case and sensitivities.
We note that the base demand forecast has already been substantially
reduced by HS2 Ltd, but that this reduction has been masked by
extending the demand growth assumption by 10 years until 2043.
We doubt the justification for this, and question the outdated
modelling assumptions used to estimate and value the potential
benefits. We fully support the analysis prepared by HS2 Action
Alliance to review the updated business case.[35]
3.2 We believe the committee should probe deeply
into the costs and affordability of HSR. There is a history of
underestimating the cost of infrastructure projects, and at this
early stage of HSR we believe there should be greater clarity
on the future overall cost. Whilst the DfT talk in terms of £32
billion construction cost, we also see estimates of £112
billion[36]
for the whole network. In addition, the DfT seem to accept that
the opportunity for grants or private funding is relatively minor,
such that virtually all funding and risk will be met by the public
finances, at a time of very high national debt. We find it surprising
that the Government should wish to commit to a long term strategic
venture that forces the country to an ongoing subsidy of selective
rail services, estimated at £17.1 billion for the "Y"
route alone. Is HSR such a poor commercial venture, or such a
vital strategic project, to require high public subsidy and leave
such a legacy of debt?
3.3 We also believe the Committee should probe
the demand case, which appears to us to defy common sense. We
wonder what research has been done to understand why people want
to travel, and why travel to London is something this nation wants
to encourage. We have seen in previous projects (eg HS1 and the
M6 Toll) serious overestimation of demand, and a failure to consider
the competitive reactions to major projects. We know that other
transport modes are striving to become greener and cheaper. We
see a rapid advance in the impact of technology and communications
reducing the need for business travel. We see also the issue of
price dominating so many discretionary purchases, and consumers
seeking real value. Yet it is proposed to commit huge expenditure
for a 60 year project which relies on a doubling of demand in
a mature and saturated market.
We are particularly concerned about the impact of
rail fares, which are critical to demand levels and return on
investment. We are told that the HS2 analysis has been based on
the concept of fares rising at RPI +1% pa, yet that demand is
so sensitive to price that a fare rise of RPI +2% pa will reduce
demand by 24%, and lower the Benefit Cost Ratio from 1.6 to 0.9.[37]
This is a massive sensitivity and risk.
With uncertainty over demand, fares and construction
costs, it is uncommercial to opt for the high risk, expensive
fixed system solution of HSR when more flexible alternatives exist.
3.4 The evaluation of the purported benefits
of HSR is subjective and fails to convince on many levels. Whilst
the notion of valuing time savings from faster journeys has some
logic, no attempt has been made to justify this in real fares.
In addition we see little detail given to explain figures, the
use of out of date data, and simple errors such as not recognising
that time spent on trains can now be very productive, using modern
technology, and not wasted. We also find it incredible that the
benefit case should introduce subjective user benefits such as
agglomeration, whilst the costing completely ignores widespread
hardship, blight and environmental damage.
We trust that the Committee will examine the benefit
case in more detail, or force the DfT to accept that the Benefit
Cost Ratio analysis is largely meaningless and that the more robust
numbers to focus on are the gross expenditure and the lifetime
public subsidy. At the end of the day, if the benefits presented
by the DfT were real, customers would be prepared to pay higher
fares; HSR could operate without subsidy, and could be funded
by the private sector.
3.5 Most importantly, we believe that any analysis
should be undertaken against a direct and meaningful comparator
(see 2.4). A comparator based on evolving the RP2 package, upgrading
existing facilities at lower cost, would be a more relevant alternative
against which to properly judge HSR. This would enable real incremental
costs to be compared against real incremental fare revenue, and
a conventional commercial financial evaluation to measure this
project in the real world.
4. ISSUE 4: THE
STRATEGIC ROUTE
4.1 Our existing train network has been developed
over many years to meet our population needs and is already largely
a best fit solution, which can easily be modernised to provide
links to Heathrow, HS1 and Crossrail. The proposed route is irrational
in that it fails to link into existing stations at Birmingham
New Street (with links to the rest of the West Midlands) and Birmingham
International (with excellent links to Birmingham Airport and
other facilities). We have no information on how local services
will connect with the new Birmingham stations, or of the cost
to provide adequate links. It is also irrational that the proposed
route doesn't immediately take in Heathrow, that it overloads
Euston and does not easily link to HS1 and Europe.
4.2 We are concerned that the proposed route
will significantly worsen regional services. We currently benefit
from long distance services which stop in our region—these
will bypass us on HSR, and with usage of the remaining WCML being
more than halved (on HS2 Ltd estimates) our service will disappear
without a significant increase in subsidy. Whilst central Birmingham
may welcome the new route, all other areas of the midlands (where
most people live and work) will be worse off, with longer journeys,
more car usage and environmental damage.
We see little consideration of the impact HSR will
have on the viability of existing services, and no substance to
support the notion that extra investment will be attracted to
regenerate facilities that are disadvantaged by HSR.
4.3 A significant lesson from rail travel over
the years has been that twin track routes are very inflexible.
Trains need to travel at the speed of the slowest. We have benefited
from the four tracking and modernisation of the WCML in recent
years, and we see the same approach working for roads. To consider
building a new HSR facility with only two tracks seems old fashioned
and short sighted.
5. ISSUE 5: ECONOMIC
REBALANCING AND
EQUITY
5.1 We see no evidence that HSR will assist economic
regeneration and help to bridge a north south divide. If anything,
we believe it will lead to further dominance of London and possibly
a few large cities which are directly on the route, to the detriment
of the regions. This is confirmed in a paper published by Greengauge
21 in July 2009 which states the need for complementary action
(for which we believe there are no plans, processes or funding
in place) without which "HSR on its own could increase the
dominance of the Greater South East within the UK".[38]
5.2 We have seen suggestions that more jobs and
services will be created in the West Midlands, but on deeper analysis
it appears that these will largely depend on yet further unspecified
investment. The DfT Consultation Summary is at least clear in
suggesting that 22,000 of the 30,000 jobs that could arise from
regeneration following HS2 would be in London. There are surely
many better and less expensive ways, in a modern society, to regenerate
regions and improve national prosperity.
5.3 There does seem to be evidence, confirmed
from what we understand of the DfT benefit case, that the major
beneficiaries of HSR will be more wealthy individuals who are
able to afford a leisure trip to London. In essence this will
mean the public subsidy for HSR benefiting the wealthy at the
expense of the poor.
5.4 We are aware that there are supporters of
HSR and, to some extent, we can understand the point if such a
facility is provided free of charge. Recognising the challenge
in the Committee's question 5.4 we would propose that:
— HSR
should be forced to operate without public subsidy—ie fares
should be set to meet development and operating costs. Adopting
this principle could potentially allow full privatisation of the
route.
— Local
authorities should be required to meet the cost of new HSR stations
built in their area, so that they can integrate local redevelopment
and contribute to regeneration.
Should such financing not be viable, we need to understand
better why we are meeting these costs from public funds.
SUMMARY
1. This is an unnecessary high risk project with
doubtful benefits and requiring permanent public subsidy which
will leave a legacy of debt.
2. Better alternatives exist to meet rail passenger
forecasts and wider transport priorities which can be introduced
sooner, more flexibly, and at much lower cost.
3. We do not understand the strategic imperative
of this project and the business case is weak. We suggest that,
if the proposed benefits were realistic, the project could be
undertaken in the private sector without the need for public funds.
4. We welcome the scrutiny of the project provided
by the Select Committee, but remain concerned by the lack of clarity
in detail provided by the DfT and by the lack of independent review
and impartiality in the public consultation process.
May 2011
31 Source: More Capacity on WCML : an alternative to
HS2, prepared by HS2 Action Alliance February 2011 Back
32
Source: HS2 Strategic Alternatives Study, Strategic Outline Case,
prepared by Atkins March 2010 Back
33
Source: Strategic Alternatives to the Proposed Y Network, prepared
by Atkins February 2011 Back
34
Source: More Capacity on WCML : an alternative to HS2 prepared
by HS2 Action Alliance February 2011 Back
35
Source: Review of the February 2011 Consultation Business Case
for HS2 prepared by HS2 Action Alliance and updated May 2011 Back
36
Source: Staffordshire County Council quoting HS2 Ltd Back
37
Source: Economic Case for HS2 (section 7.2.18) published by Department
for Transport February 2011 Back
38
Source: Complementary measures to facilitate regional economic
benefits from High Speed Rail prepared by Urban & Regional
Policy for Greengauge 21 Back
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