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Chiltern Society Final ES Response

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Chiltern Society Final ES Response HS2 Environmental Statement response by The Chiltern Society February 2014 Introduction The Chiltern Society is a registered charity with 6,800 members that works to promote, conserve and improve the unique character of the Chiltern Hills which stretch across parts of Oxfordshire, Buckinghamshire, Hertfordshire and Bedfordshire. This includes the Chilterns Area of Outstanding Natural Beauty (AONB). The Society is not opposed to high speed rail in principle. It strongly objects to the proposed HS2 route crossing the AONB. It believes the route is neither justified nor proven and that alternative routes have not been properly considered. However, if, by default, this route is selected by Parliament, the Society believes it is vital that the AONB should be fully protected by the construction of a tunnel under the entire Chilterns AONB. General comments on the Environmental Statement (ES) All of these points are expanded upon in other areas of the Society's response. 1. The ES pays no meaningful regard to the fact that the AONB is a nationally protected landscape that requires special consideration. • It contravenes Section 85 of the Countryside and Rights of Way Act 2000 spelling out the duty of public bodies to conserve and enhance the natural beauty of the AONB. • It dismisses the overall impact of HS2 on the AONB as of little significance without seemingly recognising that the Misbourne Valley, which will be directly affected, is at the centre of the AONB and at its widest part. • It fails to recognise that design of infrastructure in an AONB should be of the highest standard, overseen by an independent design panel • It fails to demonstrate an overriding public interest to justify crossing and damaging an AONB 2. The ES fails to evaluate a route that does not cross the Chilterns AONB. It has not considered the environmental or other advantages of constructing a tunnel under the entire AONB. 3. The ES has not considered the geology of the Chilterns in any detail. This is of particular concern because of the potential danger to water supplies and existing water courses. 4. The ES proposes dumping at least 12 million tonnes of spoil in the AONB, significantly changing the landform of a protected landscape. This completely undermines, either deliberately or through ignorance, the entire concept of protected landscapes in the UK. Page 1 of 147 5. The ES outlines a mitigation approach with a first priority to avoid adverse effects. This approach has been ignored in the Chilterns AONB. • The combination of proposed permanent constructions such as ventilation shafts, balancing ponds, viaducts, catenary towers, noise barriers, security fences, new roads and new bridges will have a severe negative impact on the AONB. • The disruption to nationally important public rights of way (PRoWs), such as the Ridgeway, the Icknield Way, the Chiltern Way and the network of PRoWs for which the Chilterns is famous is either ignored or treated with scant regard 6. The ES is poorly researched, hurriedly prepared and lacks transparency. • No account has been taken in this final version of comments made by parties to the draft version. • Too many "desk-top" exercises have been undertaken to assume likely impacts. • Assessors failed to gain access to some areas to conduct studies. • Ecology studies normally carried out over three years have been conducted in one year. • The Landscape Character Areas (LCAs) used to describe the impact of the proposals on the landscape are different from long established LCAs used by other bodies, including local authorities. • It fails to identify the rush hour period properly. • Its traffic calculations are often wrong and highly improbable. • It offers no safety or security recommendations. • Contributors to the ES include companies such as Arup and Atkins who are likely to have a financial interest in any HS2 construction. 7. The ES states that all mitigation measures are proposals. There are no commitments. • The Code of Construction Practice (CoCP) is only in draft form and is seriously flawed. • The ES does not lay down any rules of accountability for the principal undertaker who will be responsible for the construction of the railway and the implementation of mitigation measures. • The ES is full of vague and non-committal statements, indicating measures will be taken "where practicable" and "where reasonably practicable". This offers no reassurance whatsoever to a public concerned about the environmental impact of this proposal. To illustrate this there are 44 mentions of ‘reasonably practicable’ and 4 Page 2 of 147 ‘practicable’ in the CoCP. There are also approximately 20 mentions of ‘reasonably practicable’ and 4 ‘practicable’ in CFA 7, 8, 9 & 10. • There are no detailed proposals for the maintenance and management of affected land once construction is completed. 8. The ES shows a lack of understanding of the Chilterns community in assessing the social and economic impacts. • It fails to appreciate how its communities are inter-linked: how frequent journeys are made to other communities for education, health, leisure and social facilities. • It does not consider the impact on tourism to the area. • It fails to consider the impact on local business, especially during the lengthy construction period. • It does not consider the impact on ambulances and other emergency services, especially during the construction period. • It does not analyse the cumulative impact the proposals will have on the thousands of walkers, cyclists and horse riders the Chilterns attracts. 9. The ES downplays the historical, geological and woodland importance of the Chilterns AONB • It fails to recognise the global importance of the area's chalk streams. • It fails to refer to threatened species first recognised in the draft ES. • It undervalues nationally important ancient woodland. • It understates the amount of woodland and hedgerow loss, and incorrectly assesses that loss to be insignificant. • It trivialises or ignores the area's archeological significance (a number of archeological sites will be destroyed by the HS2 project), the loss of ancient sunken lanes, the destruction of part of Grim's Ditch, a scheduled ancient monument, or the fact that 550 Grade 1 or Grade 2 listed buildings in the Misbourne Valley alone will be impacted to some degree by the project. 10. The ES misinterprets the environmental impacts - either by design or accident - partly because of a lack of local knowledge. • It uses noise levels that are higher than the World Health Organisation guidelines. • It fails to recognise the extent to which the tranquillity of the Chiltern valleys will be disturbed. Page 3 of 147 • It treats the loss of Best and Most Versatile (BMV) land as an incidental issue and fails to illustrate the total and cumulative impact on farmland. • It pays no regard to potential water pollution or potential risk to water supply locally or to the London area. Conclusion Despite its enormous length and complexity the Environmental Statement is highly unsatisfactory if it is meant to answer people's questions about the environmental impact of HS2 and reduce their fears by proposing meaningful mitigation measures. It fails on all counts. It often reads like a marketing document rather than an independent examination. Next steps If the Government believes a new high speed rail network should be developed, it should: 1. Properly evaluate routes from London to the Midlands and the North that do not cross the Chilterns AONB - the only AONB to be directly affected by the HS2 project as currently proposed (including Phase 2 where AONBs have been avoided and major transport corridors like motorways or existing intercity railways have been followed.) 2. Properly evaluate the construction of a two bore or three bore tunnel under the entire length of the Chilterns AONB in order to fulfil its obligations under the Countryside and Rights of Way Act. 3. Develop a National Infrastructure Plan, including the rail network, once it has agreed the future development of Britain's airports, following the Davies Report. 4. Once 1 and 2 above have been completed, undergo a national consultation over the entire proposed high speed routes which would enable the public to properly consider alternative routes and comparative costings. 5. Ensure that any environmental impact assessment carried out for the national consultation is thoroughly researched by truly independent bodies which will not be influenced by any potential involvement in the eventual construction of the project. The benefits of avoiding the AONB, whether by varying the route or by a fully bored tunnel: • The loss of 11 hectares (ha) of ancient woodland would be avoided • The loss of 188ha of farmland would be avoided • The loss of other woodland would be avoided • The loss of 38km of hedgerows would be avoided Page 4 of 147 • The loss or severe impact on PRoWs would be avoided • There would be no cuttings, viaducts or embankments in the AONB • There would be no balancing ponds in the AONB • There would be no need for a spoil dump in the AONB • There would be no loss of 16 properties and 30 outbuildings • There would be no impact on Grim's Ditch • There would be no impact on 550 Grade 1 and Grade 11 listed buildings • There would be a greatly reduced impact on barn owls, bats, crested newts, and other wildlife • There would be no disruption to animal migration trails • There would be a greatly reduced traffic impact • There would be a greatly reduced impact on schooling • There would be a greatly reduced impact on the communties of Amersham, Beaconsfield, Great Missenden, Little Missenden, Little Kingshill, Prestwood, Hyde Heath, South Heath, Potter Row, Dunsmore and Wendover. • There would be a greatly reduced impact on local business and tourism. Page 5 of 147 THE NON-TECHNICAL SUMMARY (NTS) Fundamental points affecting the Environmental Assessment Lack of regard to Chilterns AONB (Area of Outstanding Natural Beauty) considerations AONBs are designated areas of high scenic quality that have statutory protection in order to conserve and enhance the natural beauty of their landscapes.
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