High Speed Rail (Preparation) Bill

Written evidence from Dr Paul Harlow (HSR 17)


No contigent valuation has been made of the damage that HS2 will cause to the Chilterns AONB. Such a financial valuation should be made under best practice in order to make an appraisal of the scheme.

In light of the State of Nature Report we now know that all significant areas of ecological and environmental significance must now be viewed as being of National significance. The Chilterns AONB as an intact and well-preserved, protected landmass near its’ Metropoleis London and Birmingham deserves careful stewardship and the swift removal by Parliament of the risk that HS2 poses to it.


This is a response to the enormous, inadequate and poorly evidenced Draft Environmental Statement (DES) and proposed Paving Bill which if passed will accelerate HS2 before it can be adequately debated by Parliament.

I write as a Chilterns resident, but also as a scientist and retired specialist in psychological medicine and analytical psychology. The abuse of propaganda and the use of poorly evidenced ‘fact’ in the genesis, promulgation and justification of this scheme particularly concern me. It is reaching the point (where given the unparalleled costs of HS2 at a time of apparent austerity) such PR use (spin) by a Governmental Department rancor the public. It raises ethical issues when a policy of ‘ends justifying the means’ such as this is deployed, because the ends are unproven and unlikely, appear wildly exaggerated and most academic and policy centres disagree with them.

1.1 HS2 both conceptually and as planned has glaring economic, environmental and socio-geographic problems. Few academics and specialists support and most contest the claims made by the DfT and HS2ltd. HS2 was recently disclosed as being a political pre-election publicity project that required caution (Lord Mandelson),

1.2 I am concerned that the Paving Bill has been used to bypass the usual democratic process and the debate on the value, merits and risk assessment of HS2 by allowing huge expenses to occur which will deter adequate review, re-evaluation and the major revision that most commentators consider necessary when it reaches the Hybrid Bill stage.

If the Hybrid Bill is debated through Parliament under a whip this will only enforce this notion.

The public lacks confidence in the scheme despite the significant expenditure on propaganda by vested interests including HS2 ltd.

1.3 The psycho-dynamics of the DfT’s (and its spin-off HS2 Ltd) interaction with Parliament and the public are of concern and show lack of financial modeling, honesty and fairness in the presentation of evidence particularly the evidence of noise pollution and environmental damage.

The best exemplar of the covert practices (that continue in different form) was the divisive and false premised argument Nimby lawns versus jobs campaign.

This National (and damaging project) should not be managed as a ‘dark arts’

campaign as the impact and effect on many hundreds of thousands of victims will be considerable. HS2 is likely to result in later legal challenge and compensation claims.

1.4 The truth will inevitable become manifest and Parliamentary scrutiny of this scheme must be commensurate with the scale of the damage and disruption it will cause particularly given the quality and quantity of academic concern in respect of the project and the irreversible damage it will cause.

1.5 HS2 ltd has heralded "HS2- The Engine of Growth". Gone are discredited notions of speed and connectivity, which have determined the form and route from which arise many problems. So if these factors are now discredited, why has the route remained unmodified and damaging to the AONB?

By contrast the Chilterns Conservation Board has opposed High Speed 2 from the outset because of the damage it would do to the nationally protected Chilterns Area of Outstanding Natural Beauty (AONB).

Steve Rodrick, Chief Officer of the Conservation Board stated

"If the Government goes ahead with this massive vanity project, future generations will not wonder at fast trains but despair that we permanently despoiled our treasured natural heritage. It is ours to cherish and care for, not to squander."

David Harris (Chiltern Society) notes "HS2’s Environmental Statement details in cold, clinical terms, the devastating impact the project would have on what is supposed to be a protected environment".

These matters arise as the Government is presented with more information about the value of nature and protected environments

The State of Natural Capital Report:

"Natural capital assets are in decline and should be measured. Changes in natural capital should be included in national and corporate accounts, properly valued and those values effectively included in decision-making processes. Stewardship of natural capital is good for growth". The State of Nature Report (TSNR) offers clues to the fate of the UK's 59,000 species. 70 % in decline. On a day when it is reported that native flora and fauna are under threat and there is a decline in biodiversity habitats it is extra=ordinary that the Govt. .endorsed HS2 threatens so much.

In the DES HS2 ltd pass the comment "of local parish or county/metropolitan interest only" when they are to damage landscape, flora and fauna, however, TSNR highlights such ecological ‘reservoirs’ are of national importance now.

1.6 The DES in respect of the AONB is quite cynical and is poorly researched. It would be, as the DES has been created as a permissive tool, as a means to justify HS2 passage through the Chilterns by those who will profit from its build. It was not written to address the real environmental issues in anyway that is adequate or fair to this National asset.

1.6a. HS2 ltd did not respond as promised about their research methodology and the DES authorship (within the promised 21 days or thereafter). This precluded full academic challenge and the date for response to the DES passed without their supplying this very simple and rudimentary information.

1.7 On reading this document (DES)it is difficult not conclude that HS2 is an irreversible engine of environmental, social and amenity destruction and that it will impair thousands of lives, disrupt businesses and whole communities essential to maintaining the nature of the Chilterns AONB.

In my opinion on the basis of the DES the HS2 project should be reconsidered and at a minimum the route altered (to transport corridors) outside of the AONB or be completely in tunnel bar a safety gap within the Chiltern AONB.

1.8 I advise everyone concerned to read the DES thoroughly. The electronic site is not particularly user friendly. The files are large and unwieldy. I experienced several crashes, could not open any of the maps and found the search engine unhelpful for detail.

1.9The division of the AONB into false ‘areas’ belies the truth the AONB’s ecological continuity. This is ploy to minimize the understanding of the AONB as a land mass and also it falsely represents a schema that suggests it can be managed as a series of part objects. This minimizes the negative impact of the HS2 project on the environment.

It is worth reading the two areas on either side of that one detailing areas of interest as the impacts are cumulative and the creation of artificial ‘fragments’ belies the truth of the major disruption to an area that examination in isolation suggests.

I am not sure from reading the document whether HS2 ltd has joined up the whole to model how much disruption construction will entail. Their own document does not suggest that they have.

1.10 The material references for the DES are documented and I am unsure how much de-novo research has been undertaken as opposed to meta-analysis of the referenced documents For clarity I asked HS2 ltd for authorship, key academics involved and who signed the document off as fit for distribution. I await their answer.

2.0 I am particularly concern with the Chiltern AONB from the Colne Valley where the so-called Chiltern Tunnel begins, through the "Mid-Chilterns" to Wendover and another viaduct in the lee of hills and emergence into the Vale.

I am particularly worried by HS2 ltd failure to seemingly comprehend and adequately factor the matters of landscape, noise and vibration and ecological impact.

2.1 It may be that these are inherent with the choice of route and that no real mitigation can be afforded and thus these would become political issues and the response to the dilemma would be better met by open Public Inquiry.

2.2 I will allow myself one aside just to note that Quainton and Waddesdon (outside of above zone) both towns lay within a specially demarcated quiet zone, recognised under European law, which is meant to preserve the area from developments that might adversely alter its special quiet status. HS2 will roar through the valley every 90 seconds.

2.3 Landscape and Noise

HS2 ltd state


...our approach has been to lower the railway into the landscape. Much of the proposed route would be in tunnels or cuttings. The main visual effects would occur where the route is on embankments or viaducts.

... We have considered possible mitigation measures, including ‘false cuttings’ - where the landscape is raised up around the track - and providing visual screening by planting

Noise and vibration

. Noise from trains will be reduced through the design of the railway and the trains themselves. Our aim is to design HS2 so that there will be no significant vibration or ground-borne noise effects .

It is predicted already that HS2 ltd will fail in their objectives both in respect of landscaping the line and in terms of noise and vibration save where it is in a tunnel.

2.4 Much of this knowledge has apparently been known to Government. Is it adequately known to Parliament? The notion of lowering the railway into the landscape has the same truth as lowering a brick into a gateau St Honoree. The material and physical incongruities prevent their being any semblance of compatibility. HS2 ltd should be honest about the true impact of the development.

The creation of 20 settlement ponds, which was announced ‘out of the blue’ in the DES, is equally unacceptable damage to the landscape as would be their safety and perimeter fences. Their polluted water would pose a risk to the Chilterns Aquifers, which supply a good proportion of London’s best quality water.

3.0 Route:

The Coalition Cabinet decided this route. Prior to the 2010 election it was not certain and several routes were considered but no reasoned argument as to why this route was chosen has been given. It appears that the Chilterns Board was surprised at this choice of route.

This route was considered seriously flawed by this government and its advisors when in opposition.

In power they have adopted it and it is certainly the worst option for the Chilterns AONB bisecting it at its widest point. Alternative routes with the same degree of tunnel may have saved the Chilterns. There has been no explanation or rational for the choice of this route which was not that one first advocated by Arup.

HS2 ltd have vaguely suggested (through an unnamed representative) in the press that this route was taken in order ‘to protect more tranquil areas of the ANOB’ and rural countryside. (Again their belief an AONB can be divided). Yet it runs through very tranquil areas also later through EU recognized special areas of tranquility.

Further comments have talked of a route to avoid payment of compensation. If this is the case the AONB has been sacrificed and no calculation of it asset value, its contigent value has not be considered or appraised and made public.

HS2 ltd have not disclosed whether they have undertaken a valuation of the Environmental Impact.

Defra (2007a) in An Introductory Guide to Valuing Ecosystem Services , which seeks to ensure that the true value of ecosystems and the services they provide are taken into account in policy decision-making.

Assessment of the impacts of policies should be consistent and transparent

The results of the considerable ‘consultation’ that arose after the Cabinet choice of this route were essentially ignored; it appeared an unexplained ‘done deal’ and so the ‘consultation’ became irrelevant or could be cynically viewed as E.U. box ticking.

It leaves statutory bodies with no real voice or power to protect the very resource that they are charged with protecting.

3.1 Comparisons with HS1

Favourable comparisons by HS2ltd and Ministers of this route with the route of HS1 are entirely fallacious and seek to make a justification out of disaster. HS1 follows motorways in the main, skirts around the AONB except for a small intrusion in the North Kent Marshes.

HS2 will not be like HS1, there are considerable engineering works to make it possible for the train to pass through the Chiltern Hills which are essentially the least obvious place to route a High Speed track,

3.2 There will be significant damage to ancient woodland; there will be major damage to the environment and tranquility of the AONB. The land mass will be dissected.

Flora and Fauna will be adversely impacted.

Many HS2 pundits allude to it being a single track wide. However the truth is that the width of plant free margin has just been increased and the swathe will be wide, in addition there will be embankments, bunds, security fences, pylons, roads etc that will make the impact greater.

3.3 HS2 ltd has created some ‘representative visuals’ in which much of the additional and ugly clutter has been removed. Essentially a visual lie. Such dishonest actions must be stopped.

It is the largest infrastructure proposal since the Victorian period and as such it will consume and damage the areas it passes through and a significant margin around it will bear the brunt of noise and inconvenience.

It is to be very busy and very fast compared to HS1 and so the noise will be essentially constant and enhanced by the doppler shift which makes the noise variable as opposed to a background constant to which the brain accommodates more quickly.

The service is scheduled to run from 5am to midnight plus servicing so essentially 80% + of all time. I am sure it will be a matter of time when ‘capacity’ issues force it to be used at night or for adapted freight wagons especially when it links with Scotland.

4.0 The Engine of Destruction

Whilst the rationale or HS2 mutates from speed, to capacity to growth .The DES has plumped for the "engine of growth" something we now understand is likely to be academically untrue. HS2 is a DfT and Cabinet sanctioned juggernaut of rural and environmental destruction. A punt or gamble with the nations natural assets in a game of post post-modern brinkmanship. I find it concerning that this has been billed as the UK’s attempt to keep up (with the environmental nightmare of totalitarian) China’s pace in the global race.

HS2 ltd had no well-founded design concept for this unique environment. This was the route that Arup did not originally advocate, so one has the sense that it is ill formed, ill thought out and experimental. Indeed the only plan is to ‘sink the line in the landscape’ in cuttings, green tunnels and bunds not the easiest plan for a hilly environment and a train that needs straight rails.

HS2 Ltd suggested that their landscaping may improve on nature and be beautiful surely the most arrogant of conceits. The evidence of proposed scheme is that it is not beautiful nor sympathetic to the Chilterns.

Given that their real intention (to keep control of costs) is to push the line through the Chilterns as cheaply as possible; the real issue is to lose the spoil and not have to truck it away.

It is unlikely that the embankments/earthworks will do much to reduce noise pollution in the complexity of valley systems.

4.1 Tunnels versus cuttings

Reading the DES I am of the opinion that when the lines are in tunnels there will be mitigation of the worst impact, although vibration and sound may well escape.

The environmental impact of tunneling the aquifers (supplying London with 30% of its water will be yet another experiment for which there is little precedence and potential disaster. Further water extraction takes place in the Colne and Misbourne systems.

Tunnel build will create massive disruption for a decade at least to the AONB.

The necessary shafts and shaft heads, transformers, power lines and access roads will cause problems for the AONB. This is clear from the DES.

4.2 These noted problems are glossed over, mitigation is always promised By HS2 ltd and more interestingly true damage appears to be always offset by alluding to existing roads or built structures i.e. so the area was damaged anyway. (For example the peripheral to site of SSI M25 in the Colne Valley).

The Chilterns are surprisingly undamaged for what is an acknowledged rural area so close to London. That is the point of it being an AONB.

4.3 The M40 is the biggest existing scar and it is interesting that HS2 does not follow it or the M1, as was the practice with HS1.

4.4A full tunnel approach to the Chilterns was discounted because of cost. It is evident that Tunnels are being used elsewhere to preserve businesses, development potential, to protect people from noise, but this degree of protection and care has been deemed too expensive to protect the Chilterns which has a huge tourist industry much bigger numerically and financially than the Lake District.

4.5 The real problems occur when there is no tunnel.

Where there are no tunnels the DES reveals the impact HS2 on the AONB will be unacceptable both in respect of disfigurement of the landscape and destruction of the tranquility.

The sounds maps already indicate that the noise pollution is to be far worse than was originally proposed to parliament. It is also likely if these maps are based on demonstrations that Arup toured with that they are also inaccurate. (i.e. not having Doppler shift but a constant tone. At high speed DS is greater).

The constant tone intensity is likely to be nor representative of the true sound.

Care was taken to use areas with background noise in excess of most of the Chilterns, which are tranquil.

The impact of HS2 even with its mitigating bunds, ugly 4 M barriers etc is going to disturb the peace and sleep of thousands of Chiltern and Buckinghamshire residents and ruin a national much used resource. It is the only AONB between London and Birmingham.

I suggest as an exercise that you explore 4 areas: the Colne Valley, Chalfonts and Amersham, Mid Chilterns and Wendover. Look at the adverse impacts of the build and of the operational HS2.

Only one area is tunnel and where the impact of operational HS2 will be mitigated.

The other areas demonstrate considerable major adverse impacts on waterways flora and fauna, landscape, natural environment and landscape business and residents of the AONB.

4.6 I believe the sound contour maps are flawed in the documentation; they do not represent the true noise pollution of the train, but have already added calculations regarding sound barriers and mitigation that is as yet unproven.

They are also based on db means that include the hours when no trains run.

The noise levels are such that they are likely to impair health and welfare of many affected citizens and would be contrary to EU law.

The DES sound maps appear to have been altered (worse) from those previously discussed in Government and on which Parliament formed its decision.

I direct you to the work undertaken by the Ladbroke Action Group on the noise pollution of HS2 http://wcchs2.files.wordpress.com/2012/08/hs2_envher_report_compressed1final.pdf

4.7 I would urge the committee to request Raw and Mitigated sound Maps provided by a fully independent body separate to Arup or HS2 ltd.

4.8 Failure by HS2 ltd to provide accurate maps or to subsequently ensure mitigation in accord with the Maps should have legal consequence.

4.9 A feature of the DES is that whenever there is damage HS2 ltd state that the feature is of local, parish, county or metropolitan interest only. They miss the significance of an AONB as a whole and their ‘division’ aids their purpose.

5.0 In light of the State of Nature Report we now know that all areas are of National significance and the Chilterns AONB as an intact and well-preserved protected landmass near its Metropoleis London and Birmingham deserves careful stewardship and the swift removal by Parliament of the risk that HS2 poses to it.

July 2013

Prepared 16th July 2013