Written evidence from The Chiltern Society
Q1. What are the main arguments for or against
1.1 To answer this question meaningfully it is
essential to distinguish between the concept of High Speed Rail
(HSR), the proposed HS2 project and the issue of whether the latter
is an effective response to the Government's case for the former.
1.2 HSR covers a wide spectrum of different rail
track and train design speeds.1 If there is a demonstrable
case for HSR, one key question is "what design speed concept(s)
will provide the best strategic fit and value for money for England,
Wales and Scotland?"
1.3 The Chiltern Society is not opposed to the
concept of HSR. It is though strongly opposed to the currently
proposed HS2 project, which has been evolved through a highly
flawed, and arguably unlawful, process. Moreover, the HS2 project
has been proposed in the absence of a soundly developed national
strategic context against which to test its soundness in terms
of fitness for purpose. The Society is drawn into this debate
because, as a direct result of these process failures, an HSR
route through the Chilterns Area of Outstanding Natural Beauty
(AONB) is proposed. This has been done without conclusive demonstration,
as required by planning guidance2 and best practice,
that no alternative that avoids the AONB is possible to meet the
(currently undefined) "national interest" need for an
1.4 The Society is prepared to accept that there
are prima facie arguments for reducing rail travel times
between major cities and, importantly, improving connectivity
to and between major centres in the English Midlands and the North.
Achieving these objectives is likely to require the use of one
or more forms of HSR. By definition, the overlaying of a separate
network of new "dedicated" Very High Speed Rail (VHSR)
track proposed by HS2 Ltd (HS2L) and DfT severely limits the number
of major centres that can access and benefit most from HSR. In
contrast, an "integrated" approach to accommodate slower
speed HSR trains as part of the development of the existing national
strategic rail network would eventually enable many more communities
to benefit from HSR. This could still require sections of new
HSR track, such as a strategic "spine" route integral
with the existing network.
1.5 The HS2L/DfT HS2 proposals were founded on
the presumption of future capacity restrictions on the West Coast
Main Line tracks. Value of time and "wider economic impact"
(WEI) assumptions have been used to justify these proposals. The
value of time assumptions used have been discredited3
and there is no apparent robust evidence base to justify the WEI
claims. At best, the HS2 economic case remains unproven.
1.6 Interestingly, the HS2 proposals are based
on the "dedicated" VHSR network concepts mainly used
in non-European countries such as China where the populations
served are separated by very long distances. In European countries
where the major centres are not as closely located as they are
in Britain, the preference has been for the "integrated"
network approach, with a consequent wider spread of benefits.
By this comparison, the HS2L/DfT proposals do not seem fit for
1.7 It also seems perverse that the principal
cause of the future capacity problems perceived for WCML arises
mainly, not from the growth of long distance inter-city travel,
but from rail industry responses to an increasing and extending
demand for peak hour commuter services that are currently very
heavily subsidised. This in turn distorts the sound economic provision
of rolling stock assets and acts against the "work-closer-to-home"
trends, central to regional planning over recent years, of encouraging
a reduction in commuting distances on sustainable development
grounds.4 Government policy on the sustainability of
commuting and subsidised pricing of commuter train services should
be part of the strategic context against which major rail development
options are tested.
1.8 It is self evident that the ultra high investment
required for a "dedicated" VHSR network will be far
more sensitive and vulnerable to "predict and provide"
traffic forecasts (as underpin the HS2 proposals) than applying
the same risk factors to an "integrated" model for strategic
development of the national rail network. The latter would have
far more scope and flexibility to adjust to failure to achieve
estimated traffic levels and operating costs.
Q2. How does HSR fit with the government's
transport policy objectives?
2.1 The short answer is that the Government has
yet to produce a coherent set of transport policy objectives that
would provide the comprehensive strategic context against which
HSR proposals (such as HS2) can be tested and judged.
2.2 The Government recently launched a scoping
consultation on its future sustainable aviation strategy.5
Its draft proposals for a National Policy Statement on National
Networks are still awaited. Other initiatives, including work
on delivering a sustainable railway, are understood to be in the
pipeline. These will eventually help create the framework of a
(currently non-existent) sustainable National Integrated Transportation
Strategy. It is foolhardy prematurely to propose what would in
effect become the spine of a national VHSR network for the next
century (ie Phase 1 of HS2 between London and Birmingham) and
take a decision on it prior to taking account of the outcomes
of this programmed range of new transport policies and consultations.
2.3 Unlike the HS1 route, the "dedicated"
southern spine route of HS2 will not be available to slower speed
HSR trains. With an "integrated" approach based on slower
speeds, there would be far more flexibility to use HSR trains
to connect to intermediate stations and to cities linked to the
HSR spine via the classic railway network.
2.4 A core political argument of Government for
HS2 (in response to its policy decision not to build a third runway
at Heathrow) is that it will facilitate the transfer of passengers
to HS2 from domestic air services to Heathrow from the North of
England and Scotland. Whether the Government currently believes
it or not, its recently launched consultation on a sustainable
framework for UK aviation will inevitably lead to a review of
its decision to oppose additional runways at Stansted and Gatwick
airports. In which case, given the many challenges and likely
fundamental changes facing the global airline and airport industries,
it would be highly unwise to assume that, for example, the case
for a HSR link to a twin-runway Stansted post 2030 would be less
than that perceived for Heathrow in 2011. If the country needs
a new HSR spine track south of the Midlands, would it not be prudent
to locate its southern approach to London where it could facilitate
easier access from the North to a range of major transport nodes
in Southern England, including a London station on the HS1 route?
Such long term strategic scenarios should be an integral part
of the nation's HSR network strategy considerations. There was
no such consideration in the conception of the HS2 proposals,
because HS2L's remit was so heavily constrained by current thinking
influenced by the traditional dominance of a Heathrow hub airport.
This repeated a fundamental mistake made in the 2003 Aviation
Q3. Business Case
3.1 There remains considerable doubt as to whether
the highly constrained "dedicated" VHSR approach (eg
current HS2 proposal) with its very high risk profile, is an affordable
or safe strategy. Challenges to the HS2 business case by other
parties seem to confirm that.
3.2 By any standards, the HS2 passenger forecasts
are very bold, particularly the assumptions about new traffic
generation and transfer from air. Given the huge timescales involved,
over a period of inevitably uncertain change, traffic forecasting
is more an act of faith than a science.7 Over a 30
to 50 year period we can expect to see further life-changing communications
developments that will reduce the need to travel for business
purposes; and also cultural changes, such as more working from
home as an alternative to five-day commuting. This emphasises
the need to adopt infrastructure strategies that maximise the
flexibility to respond to change, rather than those which have
built-in inflexibility such as the current HS2 proposals.
3.3 There appears to be no clear Government policy
on the regulatory rail pricing regime that will apply once HS2
commences service. Statements by ministers seem to imply that
competitive pricing will be permitted between HS2 and operators
on the classic network. That seems both sensible and essential
for the late 2020s and beyond. The rail industry should by then
be using the more advanced inventory control pricing systems that
are now commonplace in the airline industry. However, given the
wide difference in the load factors between HS2 and WCML quoted
for 2043,8 this highlights an important weakness in
HS2 passenger forecasting. Learning from airline competition experience,
a 58% HS2 load factor would not be sustainable against promotional
pricing by slower competing WCML services, with 69% spare capacity
over the same sector. The same would apply with respect to pricing
competition on an improved Birmingham-London Chiltern Line.
3.4 Work by other parties on the possibility
of upgrading scenarios for the West Coast Main Line (WCML) draws
out several points. First, there is more optimism than assumed
by HS2L that capacity improvements on WCML and development of
the Chiltern Line could postpone any critical capacity point well
beyond that assumed by HS2L and DfT. Second, government institutional
thinking is heavily biased by the history of poor performance
and high cost of previous WCML upgrades and the additional risks
to sustaining service standards during construction.
3.5 Management of the Olympic and other recent
major projects suggests that the second point reflects undue caution.
Certainly the Government is dedicated to improving risk management
in major projects.9 Arising from the first point, one
must seriously question whether it is essential, as the Government
implies, for a decision on the proposed HS2 southern spine to
be taken before the end of 2011 and before the Government has
considered the outcomes of its major national transportation investigations
referred to above. The Government should resist pressure from
the rail industry lobby for such an early decision, when there
is so much uncertainty on critical strategic issues and the potential
environmental harm to special protected areas, such as the Chilterns
AONB, would be devastating, as the previous government's transport
minister admitted in Parliament.10
Q4. The strategic route
4.1 The proposed HS2 southern spine route alignment
stems from the very narrowly drawn and highly constrained remit
given to HS2L. Hence, this, and the Coalition Government's political
commitment to an early decision, has meant that a proper comprehensive
strategic review of feasible scenarios and options has not been
4.2 The original "Adonis" remit for
HS2L, which the present Government essentially adopted, was focussed
on a London to West Midlands route.11 Among the "Absolute
requirements" of that remit were: a "Heathrow International
station"; a "Connection to HS1"; "no intermediate
stations between Heathrow International and West Midlands".
Those requirements determined that any southern HSR spine route
must approach London from the West. With those constraints, alternative
scenarios that might have approached a London terminal from the
north were effectively outside HS2L's remit. That remit also denied
HS2L the opportunity to investigate fundamental changes to the
distribution of rail services into London that might have facilitated
better passenger service in the post-Crossrail era and achieve
a far more direct and speedier HS2 connection to HS1. It also
effectively ruled out in-depth consideration of an "integrated"
model of HSR network provision that could, in future, have provided
for slower HSR services to intermediate stations in the South
Midlands Sub-Regional Growth Area (and beyond) and, for example,
HSR services between that area and the London Gateway Growth Area
4.3 HS2L's first report made it clear that HSR
services between London and Birmingham alone would not be economically
viable. That has been stated subsequently on several occasions
by HS2L's former Chairman and its Chief Engineer. Yet HS2L places
great weight on achieving a straight line connection between London
and the West Midlands (Birmingham). The real benefit of HSR is
over greater distances, eg London to Manchester and Leeds/Sheffield.
Had the original remit been prioritised to link those cities to
HS1 and London, the "straight line" philosophy would
have suggested a more easterly alignment for the southern HSR
spine that would have passed through the South/East Midlands.
4.4 This fundamental failure initially to commission
a much broader high level strategic rail network review has severely
precluded a proper comprehensive evaluation of alternative HSR
scenarios and spine route options. Since the current HS2 proposals
also pre-empt the outcomes of other major strategic transportation
studies and consultations, that project, including the proposed
Y configuration, should at least be put on hold until a
more comprehensive and coherent assessment is possible. The current
HS2 proposals are widely perceived as unsound.12
4.5 In terms of priorities for a HSR spine route
over the last three-quarters of this century, there can be little
doubt that effective HSR through-service capability to the Continent
from the Midlands and beyond will be essential. It is far less
certain over that timescale that an HSR connection to Heathrow
will still be perceived as important as it is now. Indeed, with
all of its inherited shortcomings and constraints, it is inconceivable
that Heathrow will still retain such a dominant role over other
UK and near European airports, making speedier HS2-HS1 connections
far more important. Another priority is clearly the need for interconnectivity
improvements between cities in the Midlands and the North of England.
The phasing of the development of the national HSR network strategy
should take these priorities into account.
Q5. Economic rebalancing and equity
5.1 We have already referred to the lack of a
substantive evidence base for WEI. However, it seems self-evident
that the more flexibility there is eventually to deliver HSR connections
to more cities in the Midlands and North, with their classic rail
connections to their sub-regional hinterlands, the greater the
prospects for regeneration and greater modal shift to rail. This
points strongly towards an "integrated" network strategic
approach. In contrast, the "dedicated" VHSR network
approach of the current HS2 project is concentrated only on the
country's major city conurbations, where arguably the need for
regeneration support is much less. The wider rail network improvement
is, the broader will be the benefit to a wider range of socio-economic
groups. Concentration on the HS2L dedicated network could detract
from sound investment in the development of sub-regional rail
6.1 Even HS2L seem to accept that its project
proposals will be no more than carbon neutral. This is particularly
because of its fixation on a business model based on an exclusive
400kph VHSR, dedicated track network. Slower HSR speeds would
reduce carbon emissions substantially. They would also reduce
energy consumption. Slower speeds permit greater track curvatures
and reduced tunnelling and associated costs, as well as significantly
reduced embedded carbon impacts. They also make it, in stark contrast
to the HS2 proposals, far more feasible to align any new HSR track
within the environmental envelope of existing major transport
corridors. The latter seems to be accepted good practice in the
most densely developed European countries.
6.2 An HS2 connection to Heathrow is unlikely
to have significant impact on reducing carbon emissions from aviation.
Any runway slots released would be reutilised by larger long-haul
aircraft, unless prohibited by regulation. Domestic flights into
Heathrow are becoming less economic. When bmi recently pulled
out of its Heathrow-Glasgow services, British Airways responded
by increasing its services from London City Airport to Glasgow
and easyjet increased its Glasgow-Gatwick services.13
International transfer traffic to/from Manchester
and Scottish airports would be far more likely to transfer to
connecting flights to/from Continental hubs, enabling them still
to check in their baggage at their originating airport, rather
than carrying it onto an HSR train and then via additional modal
interchanges to reach their departure terminal at Heathrow.
6.3 Note that the Government does not intend
to publish its draft policy on a sustainable framework for aviation
until March 2012. It will adopt the framework in March 2013.14
6.4 The true environmental impact cost of HS2
has yet to be fully assessed. There are huge gaps in the environmental
evidence base so far produced by HS2L,15 and therefore
in the account taken of environmental costs in the HS2 business
6.5 The major concern for the Chiltern Society
is the Government's proposal for a VHSR route right across the
heart of the Chilterns AONB. The Chilterns is a unique example
of ancient English countryside16 and, as a result,
one of only two AONBs to have a statutory conservation board.
The Chilterns is the most easily accessible large area of designated
special countryside close to London and the only AONB between
London and Birmingham. AONBs share the distinction with the National
Parks of representing the finest quality of English landscape.
Driving a VHSR route through the Chiltern Hills is the equivalent
for people in the many growth areas surrounding this tranquil
ancient countryside to driving such a route through the fantastic
National Parks that people in the cities of Yorkshire and the
North of England rightly value, enjoy and protect. If there are
alternatives to such devastating harmful abuse of these national
assets, they must be used.
6.6 The highly restricted nature of HS2L's original
and extended remit made it inevitable that the company would recommend
a HSR route straight through the Chilterns. We are confident that
a more well founded and comprehensive strategic assessment of
the nation's future rail transportation needs, including HSR,
would identify other feasible solutions with much wider benefits,
without causing irreparable harm to the Chilterns.
1 For example
see EU definitions - http://www.uic.org/spip.php?article971
2 See Planning
Policy Statement PPS7 para. 22 and related legislation.
3 Analyses by
HS2 Action Alliance and others.
4 For examplesee
para.23.7 of South East Plan.
5 Developing a
sustainable framework for UK aviation: Scoping documentDfT
6 Future of Air
Transport White Paper 2003.
7 The NAO report
into Channel Tunnel 2005Found that passenger volumes and
revenue forecasts were too optimistic. The Public Accounts Committee
report on the Channel Tunnel Rail Link, 2005-06concluded
that "Where future income from passengers is expected
to provide a major element of the revenue needed to repay the
cost of constructing transport infrastructure, it is crucial that
realistic forecasts are prepared from the start. Downside risks
need to be given due weight, drawing on both UK and international
experience, in considering future projects."
8 Economic case
for HS2Figure 4 p 21.
10 Mr Sadiq KahnHansard
11 March 2010 Column 458.
11 HS2 Ltd remit.
Sir David Rowlands letter to Lord Adonis 13 February 2009 and
Lord Adonis' reply of 9 March 2009.
12 See, for exampleThe
Right Lines Charter for High Speed Rail
13 ABERT Newsletter
25 April 2011.
a sustainable framework for UK aviation: Scoping documentDfT
March 2011para 1.17.
15 As admitted
by HS2L staff/consultants at an HS2L Technical Seminar on 17 March
16 Chiltern Society
paper by Alison Doggett - http://www.chilternsociety.org.uk/hs2/paper01.php