House of Commons - Transport Committee

High Speed Rail - Transport Committee Contents

Written evidence from Buckinghamshire County Council (HSR 102)

This paper sets out Buckinghamshire Councils' response to the Transport Select Committee inquiry into High Speed rail. It is submitted on behalf of Buckinghamshire County, Aylesbury Vale District, Chiltern District, South Bucks District and Wycombe District Councils, in response to question 6.2 of the inquiry's questions:

Are environmental costs and benefits (including in relation to noise) correctly accounted for in the business case?

EXECUTIVE SUMMARY

— The Government's proposals for HS2 have not costed or accounted for the total environmental impacts and associated mitigation costs and therefore the business case will potentially be weaker, meaning neither the nation nor the Government can make an informed decision about the HS2 proposals.

— HS2 is apparently in "the national interest" and yet there is inadequate objective evaluation of all factors, work that other major scheme promoters would be expected to provide to inform the decision making process.

— The timetable for environmental surveys and assessments is unrealistic and seems to have been driven by "political expediency" to meet Parliamentary timescales, rather than an adequate evaluation timetable; this may be why national designations such as the Area of Outstanding Natural Beauty and the European Habitats Directive have not been sufficiently considered.

INTRODUCTION

HS2 proposals will cause major environmental damage both in the short term, during construction, and in the longer term, once operational. The Appraisal of Sustainability (AoS) prepared to support HS2 includes a series of objectives against which the proposals are measured, with scores ranging from highly unsupportive through to highly supportive.

HS2 is unable to score positively against any of the environmental objectives in the AoS, and whilst this is not unusual for any major development project at an early stage, since it indicates where mitigation is most required, HS2 Ltd has offered very few mitigation measures, but rather allocated an amount of funding for future investigations.

Further review of the AoS has highlighted that calculating total environmental costs and impact of the HS2 proposals is not possible, since not all the relevant information, surveys or supporting data has either been published or in many cases undertaken. This is at least consistent with HS2 Ltd's approach to mitigation.

It is perhaps unfortunate for the Government that expensive solutions will not mitigate all impacts, since in some cases these are not environmentally or economically sensible. It is also likely that many impacts may become highly contentious later in the project, particularly when bound by European legislation.

Since so little has been done to consider mitigation, everyone is being asked to respond to a consultation with insufficient information to make an informed and balanced judgement. Indeed the proposals have been defined by HS2 Ltd as contrary to the Government's environmental objectives since they fail to protect landscapes, water and the noise environment.

The Department for Transport stated in January 2011 that "further site surveys would not at this stage have offered any significant additional information". We do not agree with this statement and further site surveys at this stage would have enabled the environmental impacts to be more appropriately measured. It is essential information for the business case analysis and without it one must question the validity of the business case.

There is no evidence that the additional surveys, mitigation measures and consequent delays, to comply with legal requirements and the Government's own commitments have been adequately factored into the business case, and this further exacerbates the extent to which the environmental costs and benefits have failed to be correctly accounted for.

To support this submission, the Councils have tried to identify the environmental impacts of HS2 to let the Transport Select Committee review the strength of the business case.

HS2 PREFERRED ROUTE 3

Key facts about the Preferred Route:

— 40% of the route is in deep cutting, 9% on viaduct, about 13% in tunnels.

— More than 9% of the route passes through the Chilterns AONB.

— Less than 40% of the route through the Chilterns AONB is in tunnel.

Species and Habitats affected by the Preferred Route

HS2 runs through Camden, Hillingdon, Buckinghamshire, Oxfordshire, Northamptonshire, Warwickshire and Staffordshire between London and Birmingham. Buckinghamshire is nearly a third of the route and thus an initial environmental assessment was completed to identify species, habitats and significant features impacted.

Headline information is provided below and more detail can be found in the table in Appendix 1.

— HS2 travels through more than 25 km of Green Belt in Buckinghamshire.

— Within 1 km of the HS2 route in Buckinghamshire there are:

— Almost 270 ha of Sites of Special Scientific Interest.

— 245 ha of Biodiversity Action Plan habitats & 474 ha of Ancient Woodland.

— 60 different Protected Species & 425 Protected Species records.

— 8 Scheduled Ancient Monuments & 590 Grade I, II*, or II Listed Buildings.

— 6 Registered Historic Parks & Gardens & 15 Conservation Areas.

— 141 Archaeological notification sites & 2568 Historic Environment Records.

— 56 Footpaths or Bridleways will be intersected / crossed by HS2 in Buckinghamshire.

Heritage assets, features and landscape also contribute to the character of the Chiltern AONB, protected by Planning Policy Statement 7 (PPS7—Sustainable Development in Rural Areas). We estimate that up to 7000 historic / heritage assets will be affected by Phase 1 of HS2 between London and Birmingham. However the AoS only identifies impacts on designated heritage assets. As such 90% of all assets may be overlooked.

The AoS also underestimates impacts on Rights of Way. It states that "there would be at least 27 paths potentially affected" but Buckinghamshire's baseline assessment shows that 56 will be affected, requiring 26 diversions and 30 bridges or tunnels. Whilst HS2 Ltd's Chief Executive, Alison Munroe, clarifies that "with respect to footpaths we do not envisage these being closed…" and "we would endeavour to avoid lengthy footpath diversions, and footbridges and underpasses would be provided to enable existing routes to be maintained, wherever practicable" (in reply to the Ramblers, February 2011), such a large underestimate suggests HS2 Ltd has failed to do its homework.

For biodiversity, no comprehensive ecological surveys have been undertaken to assess impacts on habitats and species. The data given above and in Appendix 1 is taken from the existing record, which particularly in the case of species, is incomplete.

APPRAISAL OF SUSTAINABILITY (AOS)

Buckinghamshire Councils believe that the AoS is an unsatisfactory compromise that tries to meet the needs of SEA, NATA, WebTag and other guidance, but singularly fails. HS2 Ltd and Dft state its proposals linking London and Birmingham are a "project", and subject to EIA. However proposals for Phase 2, linking to Heathrow, Manchester, and Leeds, suggest HS2 is a series of projects, or programme and therefore subject to SEA.

The AoS focuses on Preferred Route 3, without considering other options. It is suggested these were dismissed earlier, but such decisions were made without consultation or explanation. The scope of the AoS may have been determined without reference to Natural England, other stakeholders or consultees.

The AoS, asserts that costs for all options are broadly similar. It is therefore assumed that mitigation costs are also similar but this can only be an assumption without evidence. As such, expensive mitigation measures may be necessary for any option.

ENVIRONMENTAL COSTS

Noise and vibration

The assessment of noise in the AoS is limited to train operational noise at dwellings for an 18 hour daytime period (06:00-24:00) with no quantitative assessment of "night-time" noise impacts (23.00-07.00). The AoS does not identify impacts at non-residential receptors, such as schools or community buildings. Other potential adverse noise impacts, such as alterations to existing transport networks, have also not been considered. The noise criteria and assumptions in the AoS represent a significant risk. For example, the adoption of the noise threshold value for High Noise Levels is taken out of context and therefore flawed.

Further mitigation options need to be investigated once the true number and magnitude of noise impact at residential and non-residential receptors have been identified. Current noise mitigation is defined as standard noise barriers no higher than 3m and some reduction in train noise at source. In the absence of any measure to determine the residual impacts, there is major uncertainty about mitigation costs, especially where for example additional cut and cover tunnels or other extensive noise mitigation is needed. Unless more detailed work is completed, and more considered noise mitigation costs developed, future options for additional mitigation could be limited (by cost) to taller and more unsightly noise barriers or controls on train speed.

Land

The business case sets out land purchase costs, at £930 million. This does not seem enough to buy all the land needed for offsetting principles. Some impacts from ancillary construction facilities, landscape and ecological mitigation and waste disposal will extend the impact "footprint" way beyond the line, adding to costs.

The Government's 2010 Lawton report proposes biodiversity offsetting which recognises all habitat value and assigns costs to identify the scale of compensation. It also states that if compensation and /or mitigation is undeliverable within the existing footprint, compensatory offsetting should be provided, on a 1:1 ratio at minimum. Land purchase, habitat establishment and land management (in perpetuity) are not factored into costs.

Rights of Way

The AoS states it will maintain rights of way "in the long term where feasible". It must be noted that even if access is maintained, the ability to enjoy a tranquil walk through open countryside will be lost. A major underestimate of the number of affected footpaths (based on assessments) means the business case does not reflect the true costs.

Route engineering

Assessments show major disruption to a number of existing routes (road, rail, cyclist and pedestrian; man-made and natural) intercepted by HS2. Not all will be suitable for mitigation. Where routes can be diverted around, over, under or moved without permanent closure, the right solution will need to be sensitive to the environment and site appropriate. Such solutions may be costly and are not shown in the business case.

These impacts will be felt along the entire length of the route. Still to be measured are the costs of disruptions or diversions to other transport networks, during a lengthy build programme.

Water

The AoS admits that HS2 will affect groundwater, so failing to meet DfT sustainability objectives. Damage to groundwater could affect water supply that cannot be solved with expensive solutions (yet to be determined). Of particular concern is possible damage to the Chilterns AONB aquifer, which could limit water supply for many.

The AoS recognises this risk but fails to prove that it can be managed. Rather the AoS assumes that money set aside for mitigation will cover all eventualities even though the Catchment Abstraction Management Strategies (CAMS, 2007) suggested that the Colne catchment, including the Misbourne, Chess, Gade, and Bulbourne chalk streams was already "over-abstracted". If HS2 impacted public supplies, then any loss would need to be met from long distance imports of water.

OTHER ENVIRONMENTAL ISSUES

Potential delays

The consultation documents do not consider possible delays (and associated costs) that may be encountered. DfT say that HS2 is subject to Environmental Impact Assessment, so all ecological surveys must be completed ahead of the Hybrid Bill, set for submission to Parliament in 2013. Given the scale and complexity HS2 Ltd must provide assurance that sufficient time is built into the project plan, should the Secretary of State choose to proceed with HS2. This timetable must not be short circuited for political expediency.

Also, some surveys may need repeating if more than two years elapses between the Environmental Impact Assessment (EIA) and the start of construction. This is good practice that the Government should adopt to ensure data is contemporary, but could further increase costs and impact the cost benefit ratio.

Planning requirements

Designated Areas of Outstanding Natural Beauty (AONB) are protected by national legislation, with a presumption to refuse inappropriate development unless proposals identify "exceptional circumstances". It has yet to be proved that HS2 is in the national interest and therefore it does not demonstrate exceptional circumstances.

Planning Policy Statement 9 (PPS9) sets out how ecological impacts should be assessed and establishes the principle that all information presented, and impacts mitigated or compensated. Where this is not possible there is a presumption to refuse development. HS2 Ltd have proposed a single route, not assessed data, and assumed that all ecological issues can be overcome, inconsistent with PPS9.

Visual and landscape impacts

HS2 will cut through some of the most iconic, valuable and valued countryside between London and Birmingham. The first section outside London bisects the Mid Colne Valley; a nationally important conservation site, SSSI, and Country Park. The section crossed by high viaduct is an open expanse of water attracting 70 breeding and 80 wintering species of bird, making it of national importance and possibly the most significant wetland breeding bird community in the area.

The site is home to the Hillingdon Outdoor Activity Centre where residents, schools, and voluntary groups enjoy a variety of recreational facilities. These will be lost since the piers of the viaduct will interfere with the activities and the centre's operation.

When the route emerges from tunnel (close to Old Amersham, a conservation area with listed buildings and not far from a primary school) it cuts through the Chilterns AONB, on a range of tunnels, cuttings, viaducts and embankments. Claims that the A413 is a major transport route overstate the true nature of this single carriageway road through unspoilt countryside.

Once beyond the AONB, it travels across open countryside, impacting on landscape and tranquillity, effects difficult to monetise but valued nonetheless by visitors, residents and businesses. Protection given to Hartwell House does recognise the value of designated assets, but there seems to be scant regard for undesignated but valued landscapes.

Integrating a railway into any landscape can mean looking well beyond the rail corridor depending on visibility, landscape sensitivity and key receptors, to create the right landscape. HS2 Ltd show road and rail crossings but fail to give sufficient details about vertical realignments in critical areas, such as the Princes Risborough crossing, that will have major impacts on the landscape and setting and cost and disruption implications.

It is not just the current proposals that have major landscape and visual impacts, but also Phase 2 linking to Manchester, Leeds and Heathrow. Effects north of Birmingham are unclear, but a number of Heathrow options show routes that cut directly through two Country Parks within the Colne Valley. Black and Langley Parks attract more than half a million visitors each year, and offer filming locations for the adjacent Pinewood Studios.

Historic environment and heritage impacts

Historic environment and heritage assets will be impacted by the route with effects being:

— Physical destruction or harm during construction.

— Adverse noise or visual intrusion on the setting of assets.

— Loss of historic character by severing landscape patterns or linear features.

— Harm from vibration, or alteration of water table.

The AoS does not consider historic landscape patterns, a key feature of the AONB. It makes little mention of impact on undesignated assets or any mitigation. To suggest that: "Where practicable, the vertical alignment could be adjusted to avoid any identified deposits of archaeological significance" fails to account for engineering constraints. We believe most archaeological sites will be destroyed. Information about heritage impacts in Buckinghamshire can be found in Appendix 2.

Biodiversity and habitat impacts

The Government's Lawton Report (2010) stressed the need for wildlife corridors, showing that to rebuild ecological networks, better connections between, or joining sites, through physical corridors, or stepping stones was needed. As a result the Government announced plans to protect wildlife, halving the loss of habitats. It appears, however, that the HS2 proposals contradict such good intentions. Severing hundreds of wildlife corridors will have serious consequences for many species, not assessed in the AoS.

HS2 will affect important species along the route; many internationally, nationally and locally protected species are already identified. Bechstein's bats (protected by the EU Habitats Directive) are present in an area bisected by the route, (although further surveys are needed to confirm the population). Such effects must be fully investigated and reported in the EIA. Other species known to be impacted are detailed in Appendix Three.

The AoS provides too little information about biodiversity and habitat impacts, and does not properly consider protected species. It fails to determine how cumulative impacts may be mitigated and key species protected. We believe this is a major omission.

CONCLUSION

It is hard to believe that any infrastructure project, of similar significance, size or effects as HS2, here or abroad, would be subject to such little environmental impact assessment or scrutiny before choosing whether to progress the project and create such major blight.

Technically, the consultation documents show HS2 does not meet DfT's sustainability objectives and there is grave concern that the Government is applying double standards; requiring less scrutiny for its own scheme compared to those promoted elsewhere. Other infrastructure projects would be expected to look at all impacts at the earliest stage.

HS2 will create major environmental damage that cannot be mitigated. Arguing the project is in the "national interest" cannot justify ignorance or non-quantification of that damage. As presented HS2 is an unsustainable and indefensible infrastructure project that admits huge environmental risks, but fails to show these can be mitigated, even at a strategic level, with no costs included in the business case.

May 2011

APPENDIX ONE

KEY ENVIRONMENTAL FEATURES IN BUCKINGHAMSHIRE—INITIAL APPRAISAL

Feature	Buckinghamshire Within 50m buffer Length (No.)	Buckinghamshire Within 1km buffer Area (No.)
Green Belt	25.03 km	4569.7 ha
Site of Special Scientific Interest	0.80 km (2)	269.6 ha (8)
Biodiversity Action Plan habitat	0.51 km (10)	245.1 ha (27)
Local Wildlife Site	2.26 km (10)	328.5 ha (36)
Local Nature Reserve	0 (0)	30 ha (3)
Local Geological Site	0 (0)	11 ha (4)
Open Access Land	0 (N/A)	33.5 ha
Village greens	0 (0)	1.2 ha (2)
Protected Species Records (in 1km)	N/A	(425)
No of different Protected Species (in 1 km)	N/A	(60)

Designated Heritage Assets[296] Buckinghamshire
Within 50m buffer
Length (No.) Buckinghamshire
Within 1km buffer
Area (No.)

Scheduled Ancient Monument 0.03 km (1) 3.5 ha (8)

Listed buildings (Grade I or II*) N/A (0) (37)

Listed buildings (Grade II) (7) (553)

Registered Parks and Gardens 2.31 km (2) 416.1 ha (6)

Conservation area 0.09 km (1) 295 ha (15)

Undesignated Heritage Assets[297] Buckinghamshire
Within 50m buffer
Length (No.) Buckinghamshire
Within 1km buffer
Area (No.)

Archaeological notification sites (25) (141)

Ancient woodland 1.54 km (7) 474.0 ha

Other significant historic landscape types:
Orchard
Historic meadow
Historic settlement
Historic parkland
Pre-18th C fields
18th / 19th C fields
(3)
(12)
(8)
(2)
(53)
(43) Not quantified

ALL HISTORIC ENVIRONMENT RECORDS 118 2,568

Rights of Way Buckinghamshire
Number intersected by HS2 route

Footpaths and Bridleways intersected 56

APPENDIX TWO

HERITAGE IMPACTS IN BUCKINGHAMSHIRE—INITIAL APPRAISAL

	Turweston: HS2 in cutting 200m+ from village conservation area and listed buildings
	Chetwode: HS2 in cutting 75m from Grade II listed house and 300m from Grade I medieval church. Conservation area, medieval moats and priory affected.
	Twyford: HS2 on embankment 125m N of Grade I listed St.Mary's medieval church and 80m from Grade II listed medieval vicarage.
	Steeple Claydon: 18th century Grade II listed Shepherd's Furze Farm < 100m S of depot
	Upper Bernwood: Remote and distinctive landscape south of Claydon House, formerly part of medieval Bernwood Forest.
	Doddershall House: HS2 on embankment 400m from 16/17^th century Grade II* listed house & park
	Waddesdon: HS2 on embankment 350m from registered park, affecting views from village conservation area, park and Grade I listed country house (National Trust).
South ? North	Fleet Marston: HS2 cuts through Akeman Street beside largest Roman settlement in county
	Hartwell: HS2 cuts through Grade II* Hartwell Park, 370m from Hartwell House (Grade I) with major loss and severance of historic parkland. Grade II listed Glebe House lies within 20m of HS2 in cutting
	Old Stoke Mandeville: HS2 passes on viaduct 40m from ruined St Marys medieval church with major impact on setting and affecting archaeological remains of deserted village
	Grims Ditch, The Lea: HS2 destroys 90m of Grims Ditch, a scheduled prehistoric boundary bank
	East of Great Missenden: HS2 passes in cutting through Chilterns AONB severing field patterns, ancient woodland, lanes and harming setting of monuments and listed buildings
	Hyde End: HS2 cuts through Grade II listed Hyde Farm and barns - barns destroyed by cutting and farmhouse left within 25m of cutting edge
	Shardloes Park: HS2 in cutting 1.3 km long and up to 110m wide through part of Grade II* historic landscape park, set around Grade I listed country house
	Old Amersham: Cutting and tunnel entrance 300m N of town affects setting of conservation area
	Denham, Savay Farm: HS2 on viaduct 260m from Grade I listed medieval manor house