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
Are environmental costs and benefits (including
in relation to noise) correctly accounted for in the business
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.
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.
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.
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
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
Key facts about the Preferred Route:
of the route is in deep cutting, 9% on viaduct, about 13% in tunnels.
than 9% of the route passes through the Chilterns AONB.
than 40% of the route through the Chilterns AONB is in tunnel.
Species and Habitats affected by the Preferred
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
Headline information is provided below and more detail
can be found in the table in Appendix 1.
travels through more than 25 km of Green Belt in Buckinghamshire.
1 km of the HS2 route in Buckinghamshire there are:
270 ha of Sites of Special Scientific Interest.
ha of Biodiversity Action Plan habitats & 474 ha of Ancient
different Protected Species & 425 Protected Species records.
Ancient Monuments & 590 Grade I, II*, or II Listed Buildings.
Historic Parks & Gardens & 15 Conservation Areas.
Archaeological notification sites & 2568 Historic Environment
Footpaths or Bridleways will be intersected / crossed by HS2 in
Heritage assets, features and landscape also contribute
to the character of the Chiltern AONB, protected by Planning Policy
Statement 7 (PPS7Sustainable 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
" 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.
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
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.
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.
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.
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
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.
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.
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
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
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
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:
destruction or harm during construction.
noise or visual intrusion on the setting of assets.
of historic character by severing landscape patterns or linear
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
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.
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.
KEY ENVIRONMENTAL FEATURES IN BUCKINGHAMSHIREINITIAL
Within 50m buffer
Within 1km buffer
|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
|No of different Protected Species (in 1 km)
|Designated Heritage Assets
Within 50m buffer
Within 1km buffer
|Scheduled Ancient Monument||0.03 km (1)
||3.5 ha (8)|
|Listed buildings (Grade I or II*)||N/A (0)
|Listed buildings (Grade II)||(7)
|Registered Parks and Gardens||2.31 km (2)
||416.1 ha (6)|
|Conservation area||0.09 km (1)
||295 ha (15)|
|Undesignated Heritage Assets
Within 50m buffer
Within 1km buffer
|Archaeological notification sites||(25)
|Ancient woodland||1.54 km (7)
|Other significant historic landscape types:|
Pre-18th C fields
18th / 19th C fields
|ALL HISTORIC ENVIRONMENT RECORDS
|Rights of Way||Buckinghamshire|
Number intersected by HS2 route
|Footpaths and Bridleways intersected||56
HERITAGE IMPACTS IN BUCKINGHAMSHIREINITIAL APPRAISAL
HS2 in cutting 200m+ from village conservation area and listed buildings
HS2 in cutting 75m from Grade II listed house and 300m from Grade I medieval church. Conservation area, medieval moats and priory affected.
HS2 on embankment 125m N of Grade I listed St.Mary's medieval church and 80m from Grade II listed medieval vicarage.
18th century Grade II listed Shepherd's Furze Farm < 100m S of depot
Remote and distinctive landscape south of Claydon House, formerly part of medieval Bernwood Forest.
HS2 on embankment 400m from 16/17th century Grade II* listed house & park
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
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
HS2 cuts through Grade II listed Hyde Farm and barns - barns destroyed by cutting and farmhouse left within 25m of cutting edge
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
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
PROTECTED SPECIES ALONG HS2 PREFERRED ROUTE 3
plants (some nationally scarce).
296 Planning Policy Statement 5 (PPS5) defines designated
heritage assets as "A building, monument, site, place, area
or landscape identified as having a degree of significance meriting
consideration in planning decisions" and may be of archaeological,
architectural, artistic or historic interest. Back
The majority of heritage assets are not designated but will still
be of archaeological, architectural, artistic or historic interest. Back