High Speed Rail - Transport Committee Contents

Written evidence from The Stop HS2 Kenilworth Action Group Ltd (HSR 49)


1.  What are the main arguments either for or against HSR?

The Kenilworth Action Group contends that there is no case for HSR per se. There is a clear need to manage the rail system, as part of an integrated transport policy, to achieve specific objectives. HSR is, in itself, not a credible objective and can only be considered where it is clearly the optimum solution to defined objectives. This has not been demonstrated.

2.  How does HSR Fit with the Government's transport policy objectives?

The terminology HSR is misleading and encourages a simplistic analysis. The UK needs a rail system that is fast, reliable, capacious, environmentally sensitive, comprehensive and affordable. HS2 satisfies only some of these and is in direct conflict with a number of Government and International policies and commitments.

3.  Business Case

The business case for HS2 is not robust against the majority of the criteria defined by the Committee. Specifically, passenger forecasts are optimistic compared with other, credible, estimates with no learning taken from eg HS1 forecasting. Cost estimates have not been revised since the original costs were published despite significant changes in the route. The basis for comparison is fundamentally flawed and is based on a "do minimum" analysis rather than a comparison of options.

The choice being presented is do nothing (unacceptable) or do HS2. There needs to be a clear and transparent evaluation of the potential solutions to meeting the nation's needs for rail travel. This is not being done.

4.  The strategic route

The strategic route presupposes HSR, with all its attendant restrictions. The question should therefore not be about the route as proposed but about what the nation's strategic requirements are and what the optimum solutions to these requirements are.

5.  Economic rebalancing and equity

The evidence provided in the Consultation documentation explicitly confirms that HS2 will not resolve the north south economic divide with the majority of permanent new jobs being created (or relocated) in London. There have been many claims of economic benefits along the length of the proposed line by Government and HS2's supporters. None have provided any substantive analysis to support those claims.

There will be a direct benefit only to those groups or business whose proximity to the limited number of planned stations will result in a net journey time saving compared to existing rail infrastructure and who will be able to afford the fares. This will be a relatively small number.

6.  Impact

Using the mean of the range of CO2 emissions projections, HS2 would appear to be inherently carbon neutral. However, when the support of major international airports (Heathrow, Birmingham, Manchester) is taken into account, HS2 is actively supporting the growth in long haul air travel with a consequent deterioration in CO2 emissions.

The impact on wildlife, natural habitat and amenity value has not been fully incorporated in the published analyses. Neither has the loss in property values by those people along the line (as distinct from those in the vicinity of the proposed stations who might conceivably benefit) been taken into account.


1.  What are the main arguments either for or against HSR?

1.1 The Kenilworth Action Group recognises the changing transport requirements of the UK population. An effective transport system is a pre requisite for a healthy, effective and dynamic economy. Developments in the transport infrastructure need to be sensitive to environmental, economic and human requirements.

1.2 The current road and rail systems need to keep pace with the nation's needs and the rail system specifically has limitations in capacity and reliability which need addressing now and which will become exaggerated if no action to address them is taken.

1.3 The current HS2 proposal fails to adequately address the challenges faced by the current rail system, the objectives the Government is aiming to achieve on behalf of the Nation and the options to do so. As a consequence, the issue of defining the optimums solution is unaddressed. Primary issues that need to be evaluated include:

—  Effectiveness of proposal vs objectives.

—  Timeliness of proposal relative to demonstrated needs.

—  Benefit to the Nation and the economy in particular.

—  Costs expressed in, human, environmental, ecological and cultural terms.

1.4 The consultation documentation does not include a clear, stable definition of the requirements to upgrade the rail system based on a focussed analysis of current and future needs leading to a clear recommendation via a careful and objective assessment of the potential alternatives.

1.4.1 This lack of focus and vision, which has changed frequently since HS2 was announced has seriously brought into question the validity of HS2 as an appropriate response to satisfy the interests of the nation.

1.5 The HS2 proposal appears to be a disingenuous attempt to force a conclusion on the result of the consultation ie it poses the proposition " If the current rail system does not meet the needs of it's users, then something must be done. The only proposal being considered is HS2, therefore HS2 must be done".

1.6 HSR gives advantages in terms of time savings and capacity. The true value of time savings is overstated and intangible. The capacity requirements can be satisfied by a number of means. In every other respect, HSR is demonstrably much worse. It is far too expensive relative to value, delivered too late (even if on time) and necessitates too great a cost in financial, human, environmental, ecological and cultural terms.

1.7 In short, it is too much, too late.

2.  How does HSR fit with the Government's transport policy objectives?

2.1 Disregarding the concerns over whether HS2 is a credible, optimised solution to rail transport needs, it is not part of coherent transport, economic and environmental policies.

2.2 As presented, it is difficult to rationalise what the public is being consulted on. HS2 is presented as a costed plan for the route between London and Birmingham, with suggestions about the route to Leeds and Manchester but no detail. There is an uncosted proposal for a Heathrow link (reportedly a minimum cost of £7.3-7.7 billion according to an unpublished ARUP report - Uxbridge Gazette, 11 May 2011). There is a hint of the ultimate goal with the lines running to Edinburgh and Glasgow but no information at all. Yet this is intended to be and integrated strategy. In reality, once Phase 1 is committed to, the whole strategy is committed to but the consultation is not on the whole scheme.

2.2.1 Without being able to consider the entire proposal for HS2, even if not all phases of the proposal are fully developed, it is impossible to arrive at a rational and considered conclusion.

2.3 HS2 bases it's justification on increased demand for travel with 22% of journeys undertaken simply because HS2 exists. Whilst arguable that this demand will be created, it is in direct conflict with the Government's own Carbon Plan which aims to reduce demand for travel in order to support the UK's commitment to reduce CO2 emissions. Paragraph 5.30 states "Modern technology" can provide fast and effective alternatives to travel, and can also provide greater flexibility, resulting in a number of benefits to staff and businesses" This is completely ignored in the HS2 analysis.

2.4 Also ignored are the increased energy requirements as a result of the significantly higher speeds than current (energy usage increase with the square of speed). The UK is still dependant to a significant degree on CO2 generating fuels. Renewable energy will not provide more than a small percentage of the UK's energy needs for the foreseeable future. The UK's energy policy is currently being reviewed in terms of generation sources. This means that the increased energy requirements of HS2's high speed will inevitably increase CO2 at a time where there is a commitment to seriously reduce it.

2.5 The small number of stations proposed by HS2 will inherently only directly benefit people in the immediate vicinity of the stations. By definition, this will be a small and finite number of people (HS2 Ltd have not been able to provide an analysis of this). Anybody outside of the catchment zones, by definition, will experience longer journey times as a result of increased travel to the limited number of HS2 stations ie will not benefit from the USP of HS2, it's increased speed.

2.6 Attempting to channel the projected passenger numbers (if true) through just four stations will significantly increase congestion in already congested areas and increase CO2 through longer journeys to the stations.

2.7 In addition, HS2 is geographically focussed, there are many areas not along the route which will not benefit at all from HS2, for example the South West and HS2 has a polarised effect. Indeed many areas along the HS2 route, not in the vicinity of the HS2 stations, will see no benefit. Many of these areas are suffering from lack of investment in both local and long distance rail travel.

2.8 Benefits of releasing capacity on the classic rail system have been clearly claimed but without quantification or definition of how those benefits will manifest themselves.

2.9 Arguably a more cost effective solution would allow the finite amount of available funding to be used in a more geographically diverse fashion, benefiting more people and regions.

2.10 Given the minor amount of modal shift from road transport, HS2 is unlikely to have any tangible effect on reducing road congestion taking into account the location of congestion vs the HS2 route. As already stated, there will be a significant increase in congestion in the vicinity of the four stations.

2.11 Perhaps the largest conflict of policy is air travel. Much is made of the modal shift from air to rail travel for domestic journeys being part of HS2's green credentials. It is therefore incomprehensible that HS2 is proposed to link up at least two and potentially more international airports with a view to promoting increased long haul travel. Even more so when Birmingham Airport has just received a grant to help it expand. Equally incomprehensible is that there currently is no domestic air travel between London and Birmingham and yet this modal shift is included in the overall analysis of benefits.

2.12 Most telling of all is the Appraisal of Sustainability report indicates that for the vast majority of parameters assessed, HS2 has a neutral or negative impact. For the very small number of positive benefits identified, these all relate to questionable or undemonstrated benefits (AoS Main Report, Volume 2 Framework Summary Table pages 1-4).

3.  Business Case

3.0 The business case is flawed or at best questionable for a wide variety of reasons including the following:

3.1 The case is based on a comparison vs a "Do Minimum" scenario, when any credible business evaluation would specifically compare all of the available and credible options.

3.2 The business case as presented for consultation is extremely confused, the scheme is essentially one integrated high speed system up to Scotland, yet only being consulted on 1 phase out of three.

3.3 HS2 is a high risk strategy - essentially it is a single decision based on a suspect and highly incomplete analysis with tenuous long term projections - but with huge ramifications

3.4 Taking an incremental approach would be a safer and more rational approach - all potential gains on existing infrastructure should be exploited before big bang approach - many are low cost, low impact and importantly available immediately - when the problem exists not in 15 years time.

3.5 If an incremental line is genuinely required at some stage, need to consider design brief ie:

—  It does not need to be highest planned speed in the world - as current 400kph proposal.

—  Reducing design speed will increase route flexibility and environmental impact while reducing cost.

—  Reduced design speed increases potential to use existing transport corridors.

—  Could be used to target & bypass only the bottlenecks on the current system.

—  Take learning from other Countrys' experiences eg China downgrading top speeds due to safety & practical considerations.

3.6 Passenger forecasts used are at odds with other reputable forecasts and increasingly incoherent with respect to associated projections on the Classic system.

3.7 It is impossible to forecast with any degree of certainty over the projected time periods.

3.8 Passenger forecasting methods are not correlated with most recent similar benchmarks eg HS1 to ensure confidence.

3.9 Fare levels assumed to be equivalent to current levels yet the net cost of Y network to Gov't (ie Taxpayers) is between £14.1 billion to £20.2 billion & £10.3 billion for London - Birmingham (P12 & p43 of Economic case for HS2) This has to be funded by subsidies (apparently contrary to current Gov't direction) or by higher fares if the user bears the cost - which will result in lower passenger figures and undermines the business case.

3.10 Phase 1 benefits amount to £20.6 billion (comprising £11.1 billion business user time value, £6.4 billion other user time value, £0.4 billion other quantifiable benefits, -£1.3 billion loss of indirect taxes, £4.0 billion WEIs) - 85% of this benefit is derived from a highly questionable assignment of the value of time. Additionally this is compared with the current Classic system not one enhanced with the possible and highly cost effective improvements. (eg Virgin Trains identify potential to upgrade current WCML to within 11 minutes of HS2, compared with the 35 minute saving currently claimed). Without this, there would be no business case.

3.11 The assumptions used in assessing the time value are incorrect because:

—  Much time on trains is productive.

—  More would be productive if capacity issues were resolved.

—  The value attributed per minute is questionable.

—  No distinction is drawn between commuting travel (savings being unlikely to result in increased working time but increased leisure time) and business travel during working hours (where there could arguably be a financial benefit).

3.12 If there genuinely are more tangible economic benefits as currently being claimed - why do they not appear in the business case?

3.13 The government need to decide whether it's policy is to suppress demand for travel or encourage it to ensure a coherent policy and once the ambiguity is eliminated, modify the business case as appropriate.

3.14 Suppressing demand by pricing on the current system has the benefit of potentially limiting major capital investment and would make the users accountable for covering the costs of the service they use (a principle applied to road and air travellers currently). It would also have to disbenefit of making the service more unaffordable for lower income people. (c46% of long distance rail journeys are undertaken by those in the top income quartile).

3.15 Other tactics eg deliberately restricting capacity could be effective but undesirable. However, the Gov't should advise on how it plans to implement it's own policies.

3.16 HS2 is demonstrably not the best means to generate growth eg £94 million allocated to the Midlands from the Regional Growth Initiative is said to generate the same number of jobs as HS2 at a fraction of the cost (40,000 - of which 9,000 are temporary in the case of HS2)) - repeating this around the Country could not only be more effective at addressing economic imbalances but could reach all areas of the country, not just those along the line.

3.17 65% of HS2 passengers are predicted to switch from classic rail, freeing up capacity with an implication of reduced services - naively assuming that competitive action is not taken by Classic rail operators. This also leaves Classic (therefore the whole system) severely over capacitised. Mr Hammond is now also claiming that the freed up capacity on classic rail will generate more demand and more services on classic rail this is highly implausible, illogical and inconsistent.

3.18 22% of HS2 travellers are only travelling because HS2 makes it attractive to do so - highly implausible and if true is in conflict with Gov't policy on reducing travel demand.

3.19 The costs have not been modified despite major changes in the route since the original proposal, especially in the vertical alignment which does not seem credible.

4.  The strategic route

4.1 The strategic route presupposes that the HS2 decision has in effect already been taken (as no other options have been put forward). This should not be the case, although it is difficult to believe otherwise.

4.2 Birmingham Curzon Street and especially Birmingham International are not ideal sites as they will have a limited catchment zone (defined as being people who live/work closely enough to benefit from a NET reduction in overall, not rail, journey time) This has not been factored into the analyses ie by limiting the number and position of stations, a large number of potential passengers will have a longer journey to the station and a potentially longer overall journey time. As stated this will severely increase congestion in the vicinity of the stations. The Birmingham Interchange area, for example, is poorly served by public transport.

4.3 Presuming that a major objective is, as stated to reduce the North- South divide, a structured and targeted analysis needs to be conducted on which areas require and can generate growth, what will promote that growth (ie is HS2 an effective means of doing so vs eg Regional Growth Initiatives).

4.4 It is also required to take a long term strategic view of the country's economy eg should we be less dependant on financial services and more on manufacturing etc both of these points will determine which cities should be connected. This is not explicitly evident in the analysis.

5.  Economic rebalancing and equity

5.1 There is no evidence presented in the consultation documents to support significant economic regeneration. The only data presented relates to 40,000 jobs being created of which 9,000 are construction (ie temporary), 1,500 are running HS2 ("not clear…what proportion would represent new job opportunities in the rail sector") and 30,300 new jobs around the High Speed Stations.

5.2 It is questionable whether the jobs losses at eg The National Agriculture Centre have been taken into account.

5.3 The evidence in the consultation documents refutes the suggestion that HS2 will bridge the N-S divide - ignoring construction and operational jobs, c 73% of the new jobs created are in London.

5.4 The shape of the rail network (not just HS2 as proposed) should be determined entirely by the needs of the population as a whole, including the requirements to regenerate certain areas to ensure a balanced overall economy.

5.5 If a new rail system is required, Government is correct to build it in stages. However, it is entirely wrong to determine an overall long term strategy a piece at a time as it is currently doing. By definition, that is a tactical proposal, not a strategy. The whole must be considered if the strategy is to be robust.

5.6 We agree that beneficiaries should contribute but doing anything other than covering costs in the fares is fraught with problems. We do not see an effective and equitable means of allocating costs and risks to local authorities/business interests, particularly given the limited involvement in decision making of those stakeholders, not to mention the widespread opposition of local authorities along the route - nb based on HS1 experience, the economic risks are high.

5.7 There is a real risk that some people will pay multiple times (business costs/profitability, council tax, negative effect on property values, loss of amenity, disruption etc) without potentially getting any benefit. This needs to be taken into account alongside the benefits to HS2 passengers, though is not currently included.

5.8 Funding should not be sought for the EU TEN-T initiative unless it can be guaranteed that by doing so, the funding agreement will not place requirements on the UK that will fundamentally compromise the ability to meet it's objectives, including the costs effectiveness of any resultant schemes.

6.  Impact

6.1 Based on DfT data, the average of HS2 projections is that it is carbon neutral. This is based in part on a claimed modal shift from air to rail (despite there being no air travel on the equivalent route to phase 1).

6.2 Taking into account support for the UK's international airports (and their long haul growth plans) as part of the plan, it is clear that HS2 will therefore support an increase in CO2 generation.

6.3 High speed rail will by definition require more energy that one running at lower speeds (400 kph cruising requires four times as much energy as 200kph etc) for trains of an equivalent technology level - a significant proportion of UK energy comes from fossil fuels. Recent events are reportedly causing the Government to reconsider it's nuclear policy (Sunday Times 30-4-11).

6.4 HS2 is therefore not supportive of the legally binding requirements of the Climate Change Act 2008 to reduce UK greenhouse gas emissions by at least 80% by 2050 (HS2 will have an adverse impact on the associated target of reducing CO2 by at least 26% by 2026 due to the construction derived CO2 although it is impossible to evaluate this against the alternatives with available data).

6.5 Specific details of noise mitigation have not been defined and cannot be specifically identified.

6.6 The environmental, social and ecological impacts do not appear to have been included in the business case - many elements are such that a monetary value does not apply and yet there is a real and tangible value that can be assigned.

6.7 Loss in property values have not been included in the business equation (eg Knight Frank are currently indicating a 15% reduction in property values along the length of the line). As yet, details of the full compensation scheme are not available, only the temporary Extraordinary Hardship Scheme.

May 2011

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Prepared 8 November 2011