Written evidence from The Stop HS2 Kenilworth
Action Group Ltd (HSR 49)|
1. What are the main arguments either for or
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
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.
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:
of proposal vs objectives.
of proposal relative to demonstrated needs.
to the Nation and the economy in particular.
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
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
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:
does not need to be highest planned speed in the world - as current
design speed will increase route flexibility and environmental
impact while reducing cost.
design speed increases potential to use existing transport corridors.
be used to target & bypass only the bottlenecks on the current
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:
time on trains is productive.
would be productive if capacity issues were resolved.
value attributed per minute is questionable.
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
what proportion would represent new job opportunities
in the rail sector") and 30,300 new jobs around the High
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
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.
6.1 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
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.