Written evidence from the National Trust
(HSR 32)
INTRODUCTION
1. The National Trust welcomes the Committee's
inquiry and we are pleased to offer this response to your consultation.
2. The National Trust looks after special places
"for ever, for everyone". We protect and manage, on
behalf of the nation, over 270,000 ha of countryside and over
700 miles of unspoilt coastline and estuary. Our coast and countryside
open spaces attract more than 100 million visits per year. We
are also responsible for many hundreds of buildings and gardens
of historic or cultural significance. The Trust is a major business,
with an annual operating budget of more than £350 million
and some 5,500 employees. We are a major provider of tourist facilities,
and own Europe's largest network of holiday cottages and gift
shops. Over 3.8 million people are now members of the National
Trust which is over 5% of the UK population.
THE NATIONAL
TRUST'S
BROAD POSITION
3. The Trust is directly affected by a range
of transport issues such as aircraft noise which blights some
of our sites, the quality of local road and rail services and
in the past we have been heavily affected by road building programmes.
The current HS2 proposals directly affect the Trust through a
requirement to take land at Hartwell House which is held inalienably
under our acts of parliament. There is also potential that an
expanded network north of Birmingham or any other HSR scheme would
impact our property.
4. Having said this, the Trust is not in principle
opposed to investment in a high quality rail network which could
provide benefits in terms of delivering a low carbon transport
system.
5. Whilst not opposed to HSR the National Trust
believes there are some key principle that should be at the heart
of any HSR programme:
(a) It should be part of a wider transport strategy
that seeks to reduce travel where possible and to decarbonise
the network. It would be helpful if the Government more clearly
articulated how HSR relates to the future management of the road,
air and wider rail network. Starting from the principle of the
need to decarbonise the network also means that the measures of
success and therefore the design criteria of any scheme would
not be based on in principle decisions to run at a predetermined
speed. Instead the design criteria would be based on delivering
the optimum outcome for a range of indicators including carbon
emissions, speed, noise, economic regeneration and critically
from the National Trust's perspective the impacts on natural and
historic landscapes. We believe that by applying this principle
from the start any scheme would be more adaptable and more acceptable
to the general public.
(b) Any HSR programme should have a range of
options which should be assessed against the criteria of sustainable
development. This means that an overall judgement on the social,
environmental and economic benefits and impacts of each option
should determine decisions around the scheme rather than narrow
economic perspectives.
(c) It is a long held principle that public involvement
is a critical factor in making sustainable decisions. Any HSR
proposals should therefore involve genuine and early public participation.
Whilst major rail projects will always generate some "losers",
in our experience a truly participatory approach almost always
leads to improved proposals and greater public support. Whilst
we recognise the issues of blight, the first phase of the current
proposals have fallen well short in this respect. However, we
are encouraged by the relationship we now have with HS2 Ltd and
the indication that the Government will approach the second phase
of the scheme differently.
(d) Finally, we believe that any HSR scheme should
be the greenest possible which means the impacts should be mitigated
to the greatest degree possible. Whilst this might have an adverse
impact on the narrow economic case the adoption of the principles
of sustainability means that this can be justified because of
the value that should be attached to the protection and enhancement
of the environment and people's quality of life.
RESPONSES TO
THE COMMITTEE'S
SPECIFIC QUESTIONS
1. What are the main arguments either for
or against HSR?
6. The National Trust has in the past argued
that it is unsustainable on both environmental and social grounds
to have significant amounts of domestic air travel. A high quality
rail network could be a valuable contribution to a low carbon
transport system. The aim of decarbonising transport more generally
and of minimising other environmental and social impacts such
as the impacts on designated landscapes, noise or habitat loss
should be reflected in any success measures and should inform
the route, detailed design and operational parameters of any scheme.
7. Not least because of the direct impact on
our own property and that of communities in the Chilterms, we
are acutely aware that there are always losers in schemes of this
nature. One of the key disadvantages of any HSR programme is the
impact on places where property, habitat, livelihoods or precious
tranquillity is to be lost. We sympathise with the natural reaction
of individuals and local groups and believe that they are unhelpfully
characterised as NIMBYs. This is generally a result of a lack
of engagement at the early stages and a sense of being disenfranchised
from the decision making process.
2. How does HSR fit with the Government's
transport policy objectives?
8. The lack of a national strategic plan for
transport means it is difficult to determine the inter-relationships
between the Government's transport objectives. However the Government's
vision for "a transport
system that is an engine for economic growth but one that is also
greener and safer and improves quality of life in our communities"
is to be broadly welcomed, in particular
the emphasis on a system that is greener which clearly implies
they will be seeking environmental gains. Is it clear from the
Government's vision statement that the rail system and HSR in
particular is a key priority for delivering their ambition.
9. Having said this, the current HSR proposals
have not been framed in such a way as to deliver the outcomes
that the Government is seeking. For example, the Government's
own consultation document on HS2 makes clear that the scheme may
in fact be a net contributor to carbon emissions and it is clear
that there are unacceptable impacts on important natural and historic
designated landscapes. This appears to be because an operating
speed was set as an outcome of the project rather than the outcome
being framed in line with the Government's overall vision to deliver
environmental as well as economic gains which means the line cannot
be finessed sufficiently to minimise local environmental impacts.
10. If the decisions around HSR were taken in
line with the principles of sustainable development it could be
entirely justifiable to reduce the speed, reduce the return on
investment, reduce the impact in carbon and wider environmental
and social terms and still deliver a project with significant
benefits.
3. Business case
11. The National Trust is not best placed to
comment on the details of the business case, however, we would
reiterate the point made above that any scheme should be based
on a much broader set of economic, social and environmental factors.
12. In addition to this we would argue that a
marginal economic case increases the importance of ensuring environmental
and social gains are maximised.
4. The strategic route
13. The National Trust has only a peripheral
interest in the choice of stations along the route. However, we
are in principle opposed to the route passing through the Chilterns
AONB. We also believe that the impacts on the built and natural
environment and the potential to improve these should be central
criteria in any decisions.
5. Economic rebalancing and equity
14. The National Trust does not have the expertise
to answer this question.
6. Impact
15. It is very clear that whilst the current
proposals recognise that there are environmental and social impacts
these have not been accounted for in a robust way. There is no
thorough assessment of the impacts on social and environmental
capital both positive and negative.
16. We believe that if HSR is to proceed the
environmental and social impacts should be mitigated to the greatest
possible degree especially if the economic case is considered
marginal.
17. We are encouraged by the approach of the
Department for Transport and HS2Ltd in terms of engaging over
mitigation measures and an apparent desire to use mitigation to
deliver environmental gains where possible. However we believe
they could go further and we would encourage the committee to
recommend bold and innovative approaches to mitigation and where
the most sensitive historic and natural environments are impacted
an increased use of tunnels which are the most effective way of
mitigating the impacts.
May 2011
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