Further written evidence from 51M (HSR
109B)
This supplementary evidence is submitted to update
the Committee on issues related to the "Optimised Alternative",
as described in Chapter 1 of our main submission, and to respond
to the supplementary evidence submitted to the Committee by DfT
and HS2 Ltd this week. Given the time constraints we have provided
a detailed response on the Optimised Alternative and overview
responses on a number of the issues raised in the DfT and HS2
Ltd supplementary evidence. We may provide a more detailed response
to the Committee on certain items of the supplementary evidence
in the near future.
OPTIMISED ALTERNATIVE
Neither DfT nor HS2 Ltd has made any attempt to engage
with us directly on our proposed approach or the Optimised Alternative.
DfT acknowledge that they have not carried out a
full analysis of 51m's alternative, despite its higher capacity
and its lower capital costs than Atkins' Rail Package 2. This
is somewhat surprising since it has now been in the public domain
for some three months.
Below we respond to the statements made by DfT and
HS2 Ltd in their supplementary evidence and the "Yes to
High Speed Rail" campaign paper from William Barter,
which purports to analyse the Optimised Alternative.
— Both
the DfT's supplementary evidence and the William Barter paper
assert that much of the 215% additional capacity set out in the
Optimised Alternative doesn't count, as any calculation of capacity
increases should be based on the capacity after completion of
the existing project to lengthen some of the current 52 Pendolino
trains from 9 to 11 cars. This is fundamentally wrong as the HS2
Ltd business case has a 2007-08 base, from which the HS2 forecast
of 102% background growth has been made, and any comparison clearly
has to start from this same base, the capacity available in 2007-08.
— In
addition the DfT response asserts that the Optimised Alternative
only provides around 30% more capacity than the capacity available
following completion of the committed Pendolino lengthening project.
However, the correct figure is 57%, as set out in Table 1.1 of
Chapter 1[79]
of our initial submission to the Committee.
— The
Barter paper claims that converting one first class car to standard
ignores peak first class loadings. But first class passenger numbers
have declined significantly in recent years, reflecting cut-backs
in travel costs by both the private and public sectors, even though
most first class passengers are now using discounted, advance
purchase fares - in some cases lower than standard class on the
same train. First class loadings are not high even in the business
peaks, and numbers on the great majority of trains don't fill
one first class coach, let alone four.
— We
are also accused of ignoring peak loadings generally. But the
Network Rail WCML Route Utilisation Strategy[80]
shows only two out of 287 trains daily with standing passengers
on the route, at around 1900 in the evening, reflecting time restrictions
for regulated off-peak ("saver") fares. This is an artificial
peak - are "Yes to High Speed Rail" really saying that
we should spend £32 billion on HS2 because of overcrowding
caused by time restrictions on off-peak fares?
The Optimised Alternative fully meets forecast background
growth in peak periods, with a 138% increase in standard class
capacity compared with the 2007-08 base.
The Optimised Alternative is described in detail
in Appendix 1 of 51m's consultation response at www.51m.co.uk.
- this updates and amplifies Chapter 1 of our original submission,
and includes a detailed analysis of peak capacity
51m are criticised for not costing or scoping investment
in additional vehicles, depot facilities, platform lengthening
and any necessary track and signalling alterations to enable 12
car operations. Similarly, we are criticised for not carrying
out a cost-benefit analysis of the alternative. We would strongly
argue that it is DfT's responsibility to ensure that all alternatives
are properly considered before embarking on a project of the scale
of HS2, and 51m do not have the technical and financial resources
to undertake such work. However, it is clear from analysis of
Atkins' previous work for DfT[81]
that 12 car operations (except to Liverpool) would be achievable
at a fraction of the cost of HS2.
DfT challenge our view that there would be no adverse
impact on performance as a result of increased services in the
Optimised Alternative. But we propose investment to eliminate
bottlenecks such as Ledburn Junction, and this approach is supported
by Atkins' previous work for DfT, which concluded:
"Even with higher levels of train frequency,
the packages may enhance train performance at a network level…..these
locations may more than compensate for other areas where there
will be an enhanced train frequency but no infrastructure enhancements"[82]
DfT's response contains factual inaccuracies: the
correct position is that (1) the illustrative service pattern
for the Optimised Alternative has fewer peak hour trains than
Rail Package 2 and (2) no additional trains are proposed on the
Coventry - Birmingham section of the route
We are criticised for assuming that no additional
platforms are necessary at Euston. However, HS2's supplementary
evidence claims that the current level of service can be maintained
during Euston reconstruction with only 14 platforms. Our proposal
only envisages an extra two to three peak trains an hour over
present levels with the current 18 platforms - on the basis of
HS2's own submission, this is clearly achievable.
DFT SUPPLEMENTARY
EVIDENCE (30 AUGUST)
Oxera question 3—Reliability of Conventional
Services
We would reiterate that the published service plans
for HS2 have major reliability risks. In contrast, the Optimised
Alternative envisages investment at key locations to remove conflicting
movements (Ledburn Junction) and improve segregation between InterCity
and freight trains (Colwich/Stafford). The reliability impacts
are set out in Chapter 4 of our original submission.[83]
Oxera question 7—Productive Time on Trains
DfT imply in their response that HS2 will reduce
crowding. This may be true on average, but we have shown (Chapter
8),[84]
that HS2's planned capacity on key routes (Manchester [Phase1],
Preston/Glasgow and York/Newcastle) is clearly inadequate, almost
certainly resulting in a higher proportion of overcrowded trains
overall, with inadequate capacity on some routes balanced by massive
over-capacity to Birmingham as detailed in the 51m's consultation
response - Appendix 17.
Oxera question 14—Disruption Impacts
The Optimised Alternative will result in significantly
less overall disruption because of the impact of HS2's major reconstruction
construction at Euston (Chapter 10).[85]
HS2 SUPPLEMENTARY
EVIDENCE (30 AUGUST)
HS2's evidence starts with the statement that "the
Committee asked a question on the proposed 18 trains per hour
service level. We are aware that this has been raised as an issue
during the consultation and we have begun further work in this
area". The delivery of 18 trains per hour is clearly a vital
part of the HS2 business case, and we consider that it is extraordinary
that HS2 Ltd and DfT had not satisfied themselves on the deliverability
of the claimed capacity of HS2 prior to commencing consultation.
Question 1—When will WCML capacity be exhausted?
HS2 state that actual growth on Virgin has been around
10% per year between 2008 and 2011, and imply that this high level
of growth is likely to continue. We believe this is wrong; the
route upgrade was completed in 2008, with major reductions in
journey time and frequency increases, so high levels of growth
would certainly be expected for three or four years, particularly
after years of disruption during the upgrade - but this level
of growth is most unlikely to continue.
HS2 seek to dismiss pricing as a means of smoothing
demand on the basis of a 2006-07 AECOM study for DfT - but it
appears that this was focussed on commuter, not long distance
flows, which have different characteristics.
Question 4—Implications of Evergreen 3
HS2 Ltd confirms they have not modelled the impact
of Evergreen 3. This project, completed on 4th September, provides
an attractive alternative to the WCML route to the West Midlands,
with only slightly longer journey times and peak fares little
more than half Virgin's. Evergreen 3 has been carried out at the
franchisee's risk, at no cost to the taxpayer, and will certainly
free up capacity on the current Virgin service, yet this significant
upgrade has effectively been dismissed as irrelevant. HS2 Ltd
also state that the Chiltern route is only a viable alternative
for passenger travelling from London to Birmingham but this is
vitally important as the first phase of HS2 is only from London
to Birmingham and is the only phase upon which HS2 have produced
any information or detailed analysis
Question 7—Disruption Impacts of HS2 Euston
Works
We note that, in contrast to their previous evidence
of July 2011 which identified that they would be able to provide
the off peak service during the reconstruction, this in itself
being a 40% reduction from the peak service (ref), HS2 Ltd are
now saying that they expect to maintain current service levels
throughout the Euston reconstruction period, except for major
closures at Bank Holiday periods, despite a reduction from 18
to 14 platforms and wholesale reconstruction of the approach tracks.
It seems surprising that HS2 Ltd has changed its view on this
within a very short period of time and we would suggest it needs
further scrutiny
Question 8—Any Capacity Problems on WCML
north of Lichfield
We note HS2 Ltd's response, but would reiterate that
Atkins proposed in its alternative RP2 that major capital investment
north of Lichfield should be provided for the same level of additional
services which HS2 Ltd now claim can be accommodated on the existing
network without these works, while at the same time improving
reliability.
On a detailed point, HS2 Ltd specifically claim that
an additional path per hour can be provided between Stoke-on-Trent
and Cheadle Hulme while still accommodating the local service
"from Macclesfield to Manchester"; this in fact operates
from Stoke-on-Trent to Manchester, a much more challenging problem.
Question 9—Ability to Run 18 trains per
hour
We consider that this response is little more than
an apparently plausible smokescreen. It remains the case that
no high speed railway in the world achieves anything like 18 trains
an hour, and to do so would require undeliverable precision for
trains travelling over busy mixed traffic two track sections of
railway and starting from as far away as Glasgow and Newcastle.
Scepticism about the claimed capacity is supported
by a recent paper "Rules for High Speed Line Capacity"
by Piers Connor, an independent rail industry consultant, who
concludes that 12 trains per hour is the practical maximum.[86]
This conclusion is also consistent with the evidence to the Committee
of Pierre Messulam of SNCF, a company recognised as a world leader
in high speed operation. Separately, as set out in Chapter 4 of
our initial submission, Greengauge 21 and Network Rail have previously
published assessments indicating a maximum capacity of 14 trains
per hour. HS2 appears completely isolated in it view that 18 trains
per hour can be realistically achieved.
Question 15—Fare Competition
HS2 Ltd's response does not deal with the impact
of price competition on existing routes. Yet from Birmingham to
London, the key route for the first phase of HS2, it is already
the case that three operators (Virgin, Chiltern and London Midland)
offer between them eight trains an hour, with journey times ranging
from 1 hour 24 minutes (Virgin), 1hour 30 minutes (Chiltern) to
2 hours 14 minutes (London Midland) and different fare levels
with Chiltern and London Midland being approximately half WCML
fares. Yet the potentially major financial impact of this competition
has not been modelled: HS2 Ltd state "more work would
be needed in all these areas if the Government decides to proceed
with the scheme following the public consultation".
FREEDOM OF
INFORMATION REQUESTS
51m has recently received partial replies to a number
of requests under the Environmental Information Regulations/Freedom
of Information Act requests, albeit significantly later than the
statutory deadline, and too late for incorporation in our consultation
response.
Our questions covered a number of areas:
— Capacity
and load factors to Manchester prior to the opening of Phase 2
in 2033.
— Capacity
to Preston and Glasgow, together with related infrastructure enhancements.
— Capacity
to York and Newcastle.
The answers in all cases were unsatisfactory; use
of continued conventional services was cited as meeting capacity
needs, but it is clear that this would not be adequate to meet
HS2 Ltd's growth forecasts, and no information was provided on
projected load factors. Additional services were postulated on
existing congested mixed traffic routes such as York to Newcastle
without any proper analysis of whether this was realistic and
deliverable. It is also apparent from HS2 Ltd's response to question
15 in their Supplementary Evidence that no analysis has been carried
out of the pricing policy needed to encourage use of conventional
services, nor of the impact of this on HS2 revenue forecasts.
HS2 Ltd declined to respond to the following questions,
on the surprising grounds that the answers would represent environmental
information which was still in the course of completion:
— Services
to Edinburgh (none are shown in the published documentation).
— Services
diverted from Euston to Heathrow and mainland Europe.
HS2 Ltd stated "we do not hold this information"
in relation to questions on:
— The
cost benefit case for the "Y" network as a result of
operation of Heathrow and mainland Europe services and the consequential
reduction in capacity to Euston.
— Details
of planned service reductions on the existing West Coast, East
Coast and Midland Main Lines when HS2 is implemented. This is
particularly concerning given that HS2 Ltd have included a £5.4
billion NPV saving from these reductions in the business case
for HS2.
51m is extremely concerned and surprised with the
inadequate responses to these important questions.
NATIONAL PASSENGER
SURVEY
We would also draw the Committee's attention to the
latest National Passenger Survey[87]
carried out by Passenger Focus. This shows that Virgin Trains
has the second highest satisfaction score for all franchised operators
(just behind Merseyrail) in relation to crowding ("sufficient
room for passengers to sit/stand"), indicating that overcrowding
on the West Coast route is a less serious problem than on many
other parts of the rail network - yet construction of HS2, at
a cost of £32 billion, is certain to constrain potential
investment on other routes with much more acute capacity problems.
CONCLUSION
Neither DfT nor HS2 Ltd has demonstrated any significant
flaw in the Optimised Alternative, which potentially offers a
faster, more flexible means of providing additional capacity,
at much less cost. However, it is clear that Government has, as
yet, not been prepared to evaluate this alternative objectively.
7 September 2011
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