High Speed Rail (Preparation) Bill

Written evidence from Cllr Ray Puddifoot (Leader of Hillingdon Council) (HSR 25)

Thank you for the opportunity to provide comments on the High Speed Rail (Preparation) Bill.

We firmly believe that this Bill should not be progressed and our reasons for this are as follows:

i) Too much money has already been spent on a scheme that has no sound economic, social or environmental justification. A transport project requiring such massive expenditure (£50 billion including rolling stock) deserves to have proper justification. This concurs with the findings of the recent National Audit Commission report into HS2, which we strongly support.

ii) A number of good alternatives to HS2, such as the Optimised Alternative put forward by 51m and the M1 route have not been properly assessed. These are considered to offer far better value for money and do not impose such adverse environmental and social costs.

iii) HS2 should form part of an integrated national transport strategy. The proposal to link HS2 to Heathrow is premature given that the future of Heathrow is unknown.

iii) the impacts on Hillingdon and other communities in London and elsewhere are devastating; proper assessments have not been undertaken; and appropriate mitigation measures have not been included as part of the proposals.

We have set out further details on each of the four areas of concern mentioned above.

i) Irrational expenditure

We believe that too much money has already been spent on a project that has not been robustly proven to have an economic, social or environmental justification and we firmly believe this would be equivalent to throwing good money after bad. We believe that the Government is moving too quickly to promote a scheme it does not yet know enough about. The Preparation Bill is effectively seeking further validation of the merits of the project even though there is no evidence based justification.

With the recent announcement of an additional £10 billion to the costs, we are concerned about the escalating costs of the HS2 project. We have been led to understand that £6 billion of this is due to the inclusion of additional tunnelling through London although how this equates to the original announcement of a tunnel costing £40-50 million more than the original surface cost demonstrates the lack of transparency in the costs and how they have been reviewed.

Furthermore, we are concerned about how the contingency funds have been calculated. Normally as projects advance and more is known about the impacts, the less scope there is for uncertainty. This reduces the requirements for contingencies. However in contrast, HS2 Ltd has undertaken considerable amounts of work advancing HS2 yet contingencies for Phase 1 alone have risen by a further £2 billion. It is worth noting that the contingencies do not include route alterations such as tunnelling.

We are unable to support the rationale of authorising further spending through the Preparation Bill without more certainty on what is being promoted. The simple reality is that HS2 Ltd has a 30% contingency plan built into Phase 1. We would question why after 4 years of development, there is still so much uncertainty in the project that HS2 Ltd require nearly a third of budget for unforeseen events. This hugely inappropriate situation is worsened by the fact that the unforeseen changes to the routes such as the Ealing tunnel, are not even covered by contingencies.

ii) Lack of appropriate assessment of alternatives

We would question whether a Preparation Bill is needed to further develop the current HS2 proposals when there is so much uncertainty about whether it is the right option or even the right route. The Scrutiny Committee needs to be aware that a number of good alternatives to HS2, such as the Optimised Alternative put forward by 51m and the M1 route have not been properly assessed. These are considered to offer far better value for money and do not impose such adverse environmental and social costs. Recent court proceedings in the Court of Appeal have highlighted that the level of assessments of alternative schemes is currently unacceptable. Whilst we await the outcome of the Court of Appeal Judgement, what was promised in court by the Department of Transport is that the final Environmental Statement presented to Parliament will now include a full assessment of alternatives to HS2. It is totally unsatisfactory that this is being undertaken at such a late point in the progression of the scheme. We highlight two alternatives below which, if properly assessed, could have changed a) the principle of promoting a high speed rail scheme and b) the actual route.

a) 51m Optimised Alternative

This option of an alternative package of rail infrastructure upgrades and effective demand management measures to absorb peak time overcrowding could deliver more capacity than is needed at a much lower cost and can be implemented in a faster timescale. This has been unfairly and inadequately assessed. Given the large increases in costs of the HS2, options such as this should be properly re-assessed;

b) M1 high speed rail route

The M1 high speed rail route would have avoided the areas through Hillingdon and the AONB in Buckinghamshire but unfortunately it was rejected in the original Decisions and Next Steps document. The reasons for its rejection included the requirement for extensive tunnelling to avoid unacceptable impacts on communities which made it £2.2 billion more expensive than the preferred route costing £18.7 billion. The London portion of the route now includes significant tunnelling to avoid impacts on communities and the costs of Phase 1 have risen to £21.4 billion, as announced by Patrick McLoughlin. The M1 route would therefore appear to cost nearly £3 billion less, and because it follows an existing transport corridor it would have less environmental and social impacts. This recent increase in costs should trigger a review of all the original options.

iii) HS2 should form part of an integrated national transport strategy.

One of our key concerns throughout this process has been the lack of any integration of HS2 with the national transport strategy, and in particular aviation policy. The proposal to link HS2 to Heathrow is premature given that the future of Heathrow is unknown.

The HS2 route has been predicated on the need to provide a link to Heathrow Airport as the UK hub airport. However, in 2011 the Government launched the Airports Commission to look at all options for progressing UK aviation policy, including options such as a new hub airport other than Heathrow. The recommendations from the Commission are expected in summer 2015. As has been seen this week with the publication of the Mayor of London’s proposals, if such an option is taken forward it may require the closure of Heathrow airport. It is ill-judged and premature to pave the way for a route with junctions to Heathrow prior to a decision on the future of UK aviation. We therefore believe that a Preparation Bill should not be progressed whilst there is so much uncertainty about the future of Heathrow Airport.

iv) Unacceptable impacts on Hillingdon and other communities elsewhere

HS2 Ltd have not properly assessed the devastating environmental impacts of HS2 and appropriate mitigation measures have not been included as part of the proposals.

The publication of the draft Environmental Statement has been the first public disclosure of a number of issues including the operation of HS2 and its impacts during construction. This has caused further concern about the HS2 project as a whole and the construction of the actual route, which will bring the area of west London in Hillingdon to a standstill for a duration of more than seven years. We would like to bring to your attention key elements from these concerns to show why this HS2 process should be halted and re-assessed, rather than escalated to authorise any further spending as the Preparation Bill would enable. These are set out in the attached Appendix.

The draft Environmental Statement contains the first public disclosure of the actual passenger usage of trains, yet the information is poor and inconsistent. The draft Environmental Statement has set out some information using completely different methodologies across the various stations, which shows that HS2 usage will not be at a level most would consider commensurate with a £21.4billion train line. The Council would urge the Committee to seek further assurances of the usage at a detailed level before HS2 Ltd continue to plough public money into the scheme.

The draft Environmental Statement lacks factual evidence on fairly straight forward matters, such as assessing how many jobs would be lost through the construction of HS2. There are inconsistencies and inaccuracies throughout the Statement and therefore the council rightly questions what information has been used in determining business cost ratios, and just how comprehensive the assessments by HS2 Ltd have been so far.

The draft Environmental Statement shows that so far HS2 had been purely advanced on its capital cost benefits alone. No consideration has ever been given to the environmental damage and costs, which alone should prompt further consideration of the alternatives.

As an example of how such costs have been inadequately accounted for we have summarised below our concerns from a Hillingdon perspective. This is no doubt replicated along the route now the construction impacts are slightly clearer.

The draft Environmental Statement gives slightly more information on where construction sites will be and where the accompanying construction routes are proposed. Even from the limited information available in the draft Environmental Statement documentation, it is apparent that the consequence of not tunnelling further under the Colne Valley will cause considerable hardship in the short term and it will cause long lasting damage which could be avoided if the proposed 3,840 m long viaduct were to be replaced by 5,780m of additional tunnelling. The result in Hillingdon without this additional tunnelling is that the tunnel portal will be just 2,210m away from the proposed viaduct and the area in between will become a massive construction site within a densely populated area with no easy access to the A40 or motorway network. As a council we are requesting that HS2 Ltd take the opportunity to extend the tunnel from London through to the western side of the Colne Valley.

Conclusion

To reiterate our concerns, we believe that the level of expenditure of HS2 Ltd to date is totally unacceptable. This is compounded by the fact that there is still an inadequate justification of the merits of the proposed scheme. The information presented to date is inadequate, based on undisclosed evidence and lacks a comprehensive understanding of the social, environmental and economic impacts.

Before any further money is spent, HS2 Ltd should present a sound case for HS2. We are concerned that so much public money is spent on a range of project related outcomes, from purchasing land to undertaking bat surveys without really interrogating the crucial elements of the project to see if it is the most suitable.

HS2 Ltd cannot be allowed to continue to spend huge sums of money without any focus. In the first instance, HS2 Ltd must get to grips with the business cost ratio and make a robust assessment of the economic, environmental and social impacts of all reasonable alternatives.

We therefore urge the Committee to fully reconsider the merits of this Bill whilst there are still huge uncertainties about the justification for the project. If there is a decision to move to the next Readings, we strongly urge the Committee to consider setting objective outcomes prior to any release of funding.

Once again we thank you for the opportunity to contribute our views and hope that these will be taken into account.

July 2013

APPENDIX: Inadequate draft Environmental Statement (dES)

The publication of the above has been the first public disclosure of a number of issues including the operation of HS2 and the impacts of construction. This has caused further concern in regard to the HS2 project as a whole and the construction of the actual route which will bring the area of west London in Hillingdon to a standstill for a duration of seven plus years. The council would like to bring to your attention key elements from these concerns as further example of why this HS2 process should be halted and re-assessed, certainly not escalated to authorise any further spending as the Preparation Bill would enable.

Passenger Usage

The dES Volume 1 (3.3.5) states there would be 11 trains per hour in one direction during the peak hour which is taken as being 8-9am and 5-6pm. Trains could be 200m (single units) or 400m (double units) depending on demand. The Camden Community forum volume is the only place where the dES set outs the types of trains running at peak hours:

On opening, Phase One would run up to 14 trains per hour (tph) . HS2 trains would be up to 400 metres (m) long with 1,100 seats during peak hours.

To understand passenger dispersal from these 11 trains, which is important to assess the cumulative environmental effects on specific location, readers would have to turn to the service specification set out in the Decisions and Next Steps accompanying reports. The information is not contained in the dES.

The service specification being used to explain the operation of HS2 shows just 3 trains per hour serving Birmingham (4 at peak times) from London. There would be the same amount of trains moving in the opposite direction. The 4 peak time trains (8 in both directions) could carry up to 1,100 passengers each. This means there is a potential for 8,800 people to move to and from Birmingham.

The Curzon Community Forum Volume 26 states:

12.7.3 ...The Proposed Scheme will result in approximately 2,800 passengers using Curzon Street station in the morning peak hour and approximately 3,200 passengers using Curzon Street station in the evening peak hour in 2026. These numbers increase to approximately 7,000 passengers using Curzon Street station in the morning peak hour and approximately 8,000 passengers using Curzon Street station in the evening peak hour in 2041 (HS2 Phase Two) through increased train frequency and additional national rail destinations. It is expected that over half of the travellers on the Proposed Scheme at Curzon Street station would have an onward rail journey.

Birmingham Interchange Community Forum Volume 24 states:

12.6.3 With the introduction of the Proposed Scheme in 2026, there would be approximately 1,550 rail passengers boarding, alighting and interchanging at Birmingham Interchange station in the morning peak hours and around 1,750 rail passengers boarding, alighting and interchanging at Birmingham Interchange station evening peak hours. These passengers are forecast to generate around 950 two way vehicle trips in the morning peak hour and 950 two way vehicle trips in the evening peak hour.

In the second extract, the figure refers to ‘morning peak hours’ implying the passenger dispersal is taken against the whole three hours in morning (7-10am as set out in the Camden assessment). This results in just 516 passengers for the morning peak hour 8-9am.

What this shows is a problematic correlation between the capacity on the trains and those who will actually use it. A potential of 8800 passengers equates to actual passenger numbers of just 3316 in the morning peak hour combined across the two Birmingham stations. It could be that initially the trains will only run as single units, in which case there would be just 4400 passenger capacity. Either way, the picture is bleak; the trains are over half empty or the £21.4billion pound phase 1 will only have the smaller capacity one carriage trains in the peak hour.

The situation does not improve come the second phase. The numbers using both stations increases to 14,000 in the morning peak. However, there will be 32 train movements across the two Birmingham stations. This equates to a minimum capacity of 17600, but this would require no double unit trains to be used.

No information is provided as to how many off peak users there will be, or how many will be on the 7 trains leaving London to go north.

This assessment is the first public disclosure of the actual usage of trains. Whilst there are a number of demand forecast reports and business case analysis, none of them present the information in a simple manner. The dES has to set out some of the information, and although using completely different methodologies across the various stations, it does show that HS2 usage will not be at a level most would consider commensurate with a £21.4billion train line.

What this shows is that HS2 Ltd has not yet proven the merits of the scheme at non-strategic or theoretical level. In practice, the scheme presented in the dES does not meet the extensive rhetoric. The Council would urge the committee to seek further assurances of the usage at a detailed level before HS2 Ltd continue to plough public money into the scheme.

Lack of factual evidence

The dES further demonstrates the lack of quality with the assessment of HS2 undertaken so far. It contains details on jobs but there are significant discrepancies across the documents. For example Report 27 on the Site Wide Effects of HS2 states:

So in total approximately 2,190 jobs could be lost route-wide from businesses affected during the construction phase, which would be a moderate adverse effect and therefore considered to be significant.

However, Report 1 which considers impacts solely around Camden states:

It is estimated that the Proposed Scheme would result in the displacement or possible loss of a total of 2,570 jobs within this area.

Report 26 refers solely to the West Midlands area, and states:

Across all the employment areas reviewed, an estimated 2,850 jobs will either be displaced or possibly lost in the wider West Midlands region.

There are 25 other individual reports each setting out a number of jobs lost or displaced. Across London and the West Midlands nearly 7000 jobs are estimated to be displaced or lost. This does not account for the route between London the West Midlands. There is a substantial difference from the site wide total, to the individual totals.

The Council would be right to question what information has been used in business cost ratios, and just how comprehensive the assessments by HS2 Ltd have been so far.

No costing of the environmental damage

Another area of concern relates to the lack of costing regarding the environmental effects of HS2. The dES sets out a range of impacts, but admits a lot more work is required before accurate assessments can be undertaken.

So far, HS2 had been purely advanced on its capital cost benefits alone. No consideration has ever been given to the environmental costs, which alone should prompt further consideration of the alternatives.