Written evidence from the Ramblers' Association
(HSR 37)
1. The Ramblers' Association ("the Ramblers")
is a registered charity and a company limited by guarantee registered
in England and Wales, founded as a voluntary body in 1935. Its
registered office is at 2nd Floor, Camelford House, 87-90 Albert
Embankment, London SE1 7TW. It has approximately 115,000 members
and is the largest organization concerned with the interests of
walkers. By "walkers" we mean anybody who walks for
any legitimate reason, such as, for example, ordinary transport
from home to work or amenities; thus we are not concerned solely
with recreational walking or with rural locations.
2. The Ramblers' charitable aims include, in
summary: the protection of public footpaths and other routes used
mainly for walking; the protection of the beauty of the countryside;
the improvement and enhancement of the walking environment; and
the promotion of walking for health, recreation and as part of
an integrated system of transport. This submission will focus
chiefly on matters relevant to these objectives and thus on issue
6, "Impact", and especially on question 2 of that section.
Our objectives can be viewed in full at: www.ramblers.org.uk/aboutus/charitableobjects.
3. The Ramblers supports the principles of "The
Right Lines Charter—A Charter for High Speed Rail",
published on 7 April 2011 by the Campaign to Protect Rural England.
We urge the government to adopt them. We believe that the government's
proposals and consultation procedures do not meet these principles
and believe they should be implemented before construction of
any high speed rail project commences.
4. However, with regard to issue 2, the Ramblers
supports improved public transport, in particular insofar as it
advances our object of promotion of walking, i.e by taking people
to places from which they might wish to walk. It is not clear
that a system designed for rapid transport between cities is relevant
to this criterion, unless by allowing for improved local services
to intermediate destinations. Before supporting the current proposal
on these grounds we would need to be convinced: (i) that the same
objective could not be achieved by a less environmentally damaging
scheme; and (ii) that resources would still be available for improved
local services.
5. Our direct answer to issue 6 question 2 is
that we do not believe that anything in the documents published
by the government demonstrates that environmental costs and benefits
have been correctly accounted for. Very little weight appears
to have been given to environmental considerations.
6. The proposed route crosses the Chilterns Area
of Outstanding Natural Beauty. AONBs are expected to enjoy special
protection except in rare circumstances. It is not clear that
a case that such circumstances apply has been made. While it is
true that a direct route from London to the West Midlands would
almost inevitably pass through the AONB, the constraints imposed
by the underlying assumptions about speed and route have precluded
less damaging options.
7. It has been claimed that the route through
the Chilterns uses an existing transport corridor. However the
impact on the environment, and on the enjoyment of the area by
walkers, of a conventional, half-hourly rail service on the Chiltern
Line and of traffic on the only moderately busy A413 are not in
the same league as the potential impact of HS2.
8. Similar considerations apply to the impact
of the scheme on the London and West Midlands green belts. The
constraints that limit choice of route have not been adequately
balanced against the impact on hitherto undeveloped landscape.
9. The countryside traversed by other parts of
the route, even if it does not enjoy special protection, is generally
tranquil. Here too the constraints imposed by seeking to achieve
the highest possible speeds, without consideration of whether
this is the best all-round option, appears to have ruled out the
environmentally preferable option of a route alongside existing
railways or motorways.
10. It is a matter of particular concern to us
that the impact on footpaths, bridleways and other rights of way
on foot appears to have received little attention. These are highways,
in law, as much as roads. Diverting a footpath causes a user of
that highway considerably greater inconvenience than a road diversion
of similar length would cause a driver. We estimate that 150 paths
will be crossed by the proposed route, but the Appraisal of Sustainability
mentions only 27 of them—those referred to by HS2 Ltd as
"promoted routes" or "strategic routes". HS2
Ltd have explained to us[59]
that it is only the effect on these routes, and not the effect
on the likely 120 other rights of way affected, that has been
taken into account. So the effect on most public rights of way
has not been considered. This aspect of the consultation is therefore
fundamentally flawed.
11. We have received assurances from HS2 Ltd
that it is their intention to avoid path closures (other than
temporarily during construction). However it appears from what
we have been told by HS2 Ltd—see previous paragraph—that
little thought can have been given to how this will be achieved;
and we are concerned lest the assurances should prove impossible,
or too expensive, to deliver.
12. Even if all paths remain open, public enjoyment
of them will be severely reduced by the noise levels on bridges
over, or paths close to, the route. Once again we return to the
point that the route traverses currently tranquil countryside,
whereas if it could be sited alongside existing major railway
lines or motorways the impact of additional noise would be more
acceptable. We suppose that in some cases, it will be necessary
to divert public paths to convenient crossing-points. For example,
where a farm is severed, and provision is made for an accommodation
crossing such as a bridge or cattle-tunnel for the benefit of
the occupier, such a provision could also be the means of crossing
the line by nearby public paths, provided the resulting diversion
to the path is reasonably convenient without significant adverse
effect on enjoyment. In our view, provision must be made so that
diversions follow desire-lines away from the railway; they should
not simply be routes within the limits of deviation which run
as unnatural, "dog-leg" diversions hard alongside the
line from the point of severance to the new crossing-point.
13. In summary, we do not consider that the government
has made a convincing case to the public, or allowed sufficiently
wide-ranging public consultation under the principles of The Right
Lines Charter, that the current HS2 proposals are so much better
than possible alternatives as to override the greater impact,
compared to such alternatives, on enjoyment of nearby footpaths
and on the beauty of the countryside.
The Ramblers asks the Committee to take these concerns
into account.
May 2011
59 E-mail from HS2Enquiries to Adrian Morris, Head
of Walking Environment at the Ramblers, 12 May 2011: "All
of our work at this stage in the route development is based at
a strategic level assessment. We would not undertake further,
more detailed local assessments until we have confirmation that
the Government agrees to continue its strategy for high speed
rail and that it plans to continue with the proposed Route for
consultation alignment as described.... Therefore, if this project
progresses, HS2 Ltd would be required to undertake detailed localised
assessment and would work with the local highways authority on
the rights of way detail detailed in definitive maps." Back
| 
