Written evidence from The Chiltern Society (HSR81) Q1 What are the main arguments for or against HSR? 1.1 To answer this question meaningfully it is essential to distinguish between the concept of High Speed Rail (HSR), the proposed HS2 project and the issue of whether the latter is an effective response to the Government’s case for the former. 1.2 HSR covers a wide spectrum of different rail track and train design speeds1. If there is a demonstrable case for HSR, one key question is ‘what design speed concept(s) will provide the best strategic fit and value for money for England, Wales and Scotland?’ 1.3 The Chiltern Society is not opposed to the concept of HSR. It is though strongly opposed to the currently proposed HS2 project, which has been evolved through a highly flawed, and arguably unlawful, process. Moreover, the HS2 project has been proposed in the absence of a soundly developed national strategic context against which to test its soundness in terms of fitness for purpose. The Society is drawn into this debate because, as a direct result of these process failures, an HSR route through the Chilterns Area of Outstanding Natural Beauty (AONB) is proposed. This has been done without conclusive demonstration, as required by planning guidance2 and best practice, that no alternative that avoids the AONB is possible to meet the (currently undefined) ‘national interest’ need for an HSR network. 1.4 The Society is prepared to accept that there are prima facie arguments for reducing rail travel times between major cities and, importantly, improving connectivity to and between major centres in the English Midlands and the North. Achieving these objectives is likely to require the use of one or more forms of HSR. By definition, the overlaying of a separate network of new ‘dedicated’ Very High Speed Rail (VHSR) track proposed by HS2 Ltd (HS2L) and DfT severely limits the number of major centres that can access and benefit most from HSR. In contrast, an ‘integrated’ approach to accommodate slower speed HSR trains as part of the development of the existing national strategic rail network would eventually enable many more communities to benefit from HSR. This could still require sections of new HSR track, such as a strategic ‘spine’ route integral with the existing network. 1.5 The HS2L/DfT HS2 proposals were founded on the presumption of future capacity restrictions on the West Coast Main Line tracks. Value of time and ‘wider economic impact’ (WEI) assumptions have been used to justify these proposals. The value of time assumptions used have been discredited3 and there is no apparent robust evidence base to justify the WEI claims. At best, the HS2 economic case remains unproven. 1.6 Interestingly, the HS2 proposals are based on the ‘dedicated’ VHSR network concepts mainly used in non-European countries such as China where the populations served are separated by very long distances. In European countries where the major centres are not as closely located as they are in Britain, the preference has been for the ‘integrated’ network approach, with a consequent wider spread of benefits. By this comparison, the HS2L/DfT proposals do not seem fit for purpose. 1.7 It also seems perverse that the principal cause of the future capacity problems perceived for WCML arises mainly, not from the growth of long distance inter-city travel, but from rail industry responses to an increasing and extending demand for peak hour commuter services that are currently very heavily subsidised. This in turn distorts the sound economic provision of rolling stock assets and acts against the ‘work-closer-to-home’ trends, central to regional planning over recent years, of encouraging a reduction in commuting distances on sustainable development grounds4. Government policy on the sustainability of commuting and subsidised pricing of commuter train services should be part of the strategic context against which major rail development options are tested. 1.8 It is self evident that the ultra high investment required for a ‘dedicated’ VHSR network will be far more sensitive and vulnerable to ‘predict and provide’ traffic forecasts (as underpin the HS2 proposals) than applying the same risk factors to an ‘integrated’ model for strategic development of the national rail network. The latter would have far more scope and flexibility to adjust to failure to achieve estimated traffic levels and operating costs. Q2 How does HSR fit with the government’s transport policy objectives? 2.1 The short answer is that the Government has yet to produce a coherent set of transport policy objectives that would provide the comprehensive strategic context against which HSR proposals (such as HS2) can be tested and judged. 2.2 The Government recently launched a scoping consultation on its future sustainable aviation strategy5. Its draft proposals for a National Policy Statement on National Networks are still awaited. Other initiatives, including work on delivering a sustainable railway, are understood to be in the pipeline. These will eventually help create the framework of a (currently non-existent) sustainable National Integrated Transportation Strategy. It is foolhardy prematurely to propose what would in effect become the spine of a national VHSR network for the next century (i.e. Phase 1 of HS2 between London and Birmingham) and take a decision on it prior to taking account of the outcomes of this programmed range of new transport policies and consultations. 2.3 Unlike the HS1 route, the ‘dedicated’ southern spine route of HS2 will not be available to slower speed HSR trains. With an ‘integrated’ approach based on slower speeds, there would be far more flexibility to use HSR trains to connect to intermediate stations and to cities linked to the HSR spine via the classic railway network. 2.4 A core political argument of Government for HS2 (in response to its policy decision not to build a third runway at Heathrow) is that it will facilitate the transfer of passengers to HS2 from domestic air services to Heathrow from the North of England and Scotland. Whether the Government currently believes it or not, its recently launched consultation on a sustainable framework for UK aviation will inevitably lead to a review of its decision to oppose additional runways at Stansted and Gatwick airports. In which case, given the many challenges and likely fundamental changes facing the global airline and airport industries, it would be highly unwise to assume that, for example, the case for a HSR link to a twin- runway Stansted post 2030 would be less than that perceived for Heathrow in 2011. If the country needs a new HSR spine track south of the Midlands, would it not be prudent to locate its southern approach to London where it could facilitate easier access from the North to a range of major transport nodes in Southern England, including a London station on the HS1 route? Such long term strategic scenarios should be an integral part of the nation’s HSR network strategy considerations. There was no such consideration in the conception of the HS2 proposals, because HS2L’s remit was so heavily constrained by current thinking influenced by the traditional dominance of a Heathrow hub airport. This repeated a fundamental mistake made in the 2003 Aviation White Paper.6 Q3 Business Case 3.1 There remains considerable doubt as to whether the highly constrained ‘dedicated’ VHSR approach (e.g. current HS2 proposal) with its very high risk profile, is an affordable or safe strategy. Challenges to the HS2 business case by other parties seem to confirm that. 3.2 By any standards, the HS2 passenger forecasts are very bold, particularly the assumptions about new traffic generation and transfer from air. Given the huge timescales involved, over a period of inevitably uncertain change, traffic forecasting is more an act of faith than a science7. Over a 30 to 50 year period we can expect to see further life-changing communications developments that will reduce the need to travel for business purposes; and also cultural changes, such as more working from home as an alternative to 5-day commuting. This emphasises the need to adopt infrastructure strategies that maximise the flexibility to respond to change, rather than those which have built-in inflexibility such as the current HS2 proposals. 3.3 There appears to be no clear Government policy on the regulatory rail pricing regime that will apply once HS2 commences service. Statements by ministers seem to imply that competitive pricing will be permitted between HS2 and operators on the classic network. That seems both sensible and essential for the late 2020s and beyond. The rail industry should by then be using the more advanced inventory control pricing systems that are now commonplace in the airline industry. However, given the wide difference in the load factors between HS2 and WCML quoted for 20438, this highlights an important weakness in HS2 passenger forecasting. Learning from airline competition experience, a 58% HS2 load factor would not be sustainable against promotional pricing by slower competing WCML services, with 69% spare capacity over the same sector. The same would apply with respect to pricing competition on an improved Birmingham-London Chiltern Line. 3.4 Work by other parties on the possibility of upgrading scenarios for the West Coast Main Line (WCML) draws out several points. First, there is more optimism than assumed by HS2L that capacity improvements on WCML and development of the Chiltern Line could postpone any critical capacity point well beyond that assumed by HS2L and DfT. Second, government institutional thinking is heavily biased by the history of poor performance and high cost of previous WCML upgrades and the additional risks to sustaining service standards during construction.