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Response to HS2 Working Draft Environmental Statement 1.0

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Response to HS2 Working Draft Environmental Statement 1.0 NORTH WEST LEICESTERSHIRE DISTRICT COUNCIL – Response to HS2 Working Draft Environmental Statement 1.0 Introduction 1.1 This document and its appendices comprise North West Leicestershire District Council’s (the Council’s) response to the Working Draft Environmental Statement (WDES) for HS2 Phase 2b (the scheme). We issue this response in the spirit of contributing to the processes surrounding this vast infrastructure project but must include the caveat that the Council can only respond to the material to hand and further intensive work with HS2 Ltd is required. 1.2 There is a sense of disappointment in the paucity of information provided in sections of the WDES, especially in respect of the scheme’s constructional and operational impacts and in respect of its design. But, the Council have determined to use this as an opportunity to shape the design and mitigation across the County. Where clear mitigation is not yet defined, the District will seek to secure written assurances from HS2 Ltd that further work will be carried out to inform the preparation of the Hybrid Bill, including an interim transport assessment, and during the Parliamentary processes. 1.3 HS2 Ltd issued the WDES on 11 October 2018. This material consists of local area reports, four route-wide volumes and a series of map books illustrating over 150 pages of detail for Leicestershire. The consultation period offered by HS2 is 10 weeks, closing on 21 December 2018. The Council wishes to express its disappointment that such a short period of time has been afforded to consulting on such vastly complicated and technical documentation. It is especially disappointing given that submission of the Hybrid Bill has been put back until 2020, which should have enabled a longer consultation period. 1.4 The eastern leg of the railway to Leeds (Phase 2b) runs through 28 kilometres of North West Leicestershire from Appleby Parva to the Nottinghamshire border. The route is proposed to run through the parishes of Appleby Magna, Measham, Oakthorpe, Donisthorpe and Acresford, Packington, Ashby-de-la- Zouch, Coleorton, Staunton Harold, Isley cum Langley, Belton, Long Whatton and Diseworth, and Kegworth. 1 | Page 2.0 North West Leicestershire District Council’s main areas of concern 2.1 It is the Council’s view that the Proposed Scheme requires further improvement in several key areas. General comments on the Proposed Scheme: a) The extent of the land take across the District for the Construction Zone, which seems excessive at some points when viewed in the context of the footprint of the finished route; b) Lack of information about access to construction compounds; c) Reconsideration of construction assumptions, including to avoid any unacceptable long-term construction closures of the A444, Tamworth Road, B4116, A511 at Ashby, and the A6 Kegworth Bypass; d) Reconsideration of the amendments made to Public Rights of Way, bridle paths and cycleways where these are adjudged to be insufficient and/or impractical; e) The lack of baseline data in the WDES; Our general concerns on the consultation documents are as follows: f) The lack of detail in the documentation on a variety of issues such as transport assessment; this has made drawing conclusions difficult about consideration of the Proposed Scheme’s construction impacts on local communities, services and transport system; g) The number of broad assumptions in the documentation and in many instances, a lack of supporting evidence, particularly the general paucity of detail about/consideration of the Proposed Scheme’s impacts, once built, including on the Strategic Road Network, local road network and classic rail network in Leicestershire; h) Failure to address the issue of additional maintenance liabilities imposed on the local highway authority, given that Department for Transport funding is no longer adjusted to reflect increase in asset size; i) The Council must also join the County Council in their concerns about any lack of apparent coordination between national bodies over HS2 and wider rail and strategic road network future development and programmes. This seeming lack of a joined-up approach could have adverse effects on the wider transport networks; j) The use of out of date or wrong baseline information; k) Downplaying of impacts, both in the lifetime of construction and beyond; l) Lack of consideration of cumulative effects on communities, particularly as these were highlighted as important in the Draft Scope and Methodology; 2 | Page m) The extent to which comments made during previous consultations on Phase 2b have not been considered and addressed in this consultation, such as design of the Mease and Gilwiskaw Brook viaducts, impacts on Measham and others; n) Preference of lower cost vs. lower impact options, although it is recognised that the Proposed Scheme uses taxpayers’ money; Specific: o) the preservation of the Old Rectory at Appleby Magna and Park Farm at Willesley Woodside; p) the many impacts on Measham, including loss of properties, design of the Mease Viaduct, provision for the Ashby Canal, width of the transport corridor on the Measham Wharf – Fiveways Wood section; q) Consideration of reprovisioning of the Ashby Canal from Snarestone to south of Moira; replacement of the 1.1km portion in Measham village is not mitigation, but a base requirement (see benefits discussed in Volume 2 response); r) Consideration of a cut and cover tunnel over the railway on the Willesley Wood section to restore woodland and provide wildlife habitats; s) At Packington, to consider the suitability of a cut and cover tunnel over the Packington cutting, the height and design of the Gilwiskaw Brook viaduct and the temporary closure of the Ashby Road. It is concerning that roads in Packington are indicated for use by construction traffic. t) Notwithstanding s) above, the constructional impacts on the health, safety and wellbeing of Packington Residents; reconsideration as to the “in principle” approach to building of the scheme in this area, avoiding the unacceptable use for construction purposes of village and local roads; u) The need for early input from the Council and North West Leicestershire District Council on the design, placement and future site use for the Ashby railhead, including the potential impacts (and possible future benefits) on the existing Leicester to Burton freight line; v) Consideration of HS2’s impacts on the futureproofing of junctions on the strategic road network, including J11, J12, J13 and J14 of the M42 and M1 Junction 24 (see also Cross-border issues); w) Placement of the line on embankment alongside Westmeadow Brook; x) Consideration of flooding issues in Breedon, and Long Whatton and Diseworth; 3 | Page y) For Kegworth, the need for creative solutions to remedy the loss of potential sports pitches, preserve cycleways, rework the balancing pond to enable an access road for the Refresco factory, avoid the closure of the A6 Kegworth Bypass and move the AFTS structure at J24 of the M1; z) In addition to the Design Panel set up for Measham, the Council request a Design Panel for the length of the Trent Valley Viaduct. Cross-border: aa) In North Warwickshire, the onward impacts of the modification works at J10 of the M42 (see response to WDES by Warwickshire County Council); bb) In Nottinghamshire, the design of the Trent Valley Viaduct and the placement of construction compounds for these works and the impacts of the completed structure on flood capacity across the floodplain; cc) In agreement with Nottinghamshire and Leicestershire County Council, the Council also strongly request inclusion in the scheme of a classic compatible rail link (see Appendix A12 in WDES Volume 2 response); dd) It is important that the ES does not preclude any of the ambitions outlined in the East Midlands HS2 Growth Strategy, http://www.emcouncils.gov.uk/write/East_Midlands_HS2_Growth_Strategy _-_September_2017.pdf particularly in relation to the wider economic aspirations surrounding the Toton Hub site and including the East Midlands Gateway and to be decommissioned Ratcliffe Power Station site; ee) In the formal ES, greater clarification on the role of a local development corporation in relation to the environmental, economic impacts and mitigation would be helpful. 2.2 The accompanying appendices provide detailed analyses by the Council of these impacts and where possible makes suggestions for improvement to be included in the Environmental Statement which will accompany the Hybrid Bill. 2.3 As noted above, there is a lack of baseline data and other information in the WDES. By necessity this has limited the Council’s ability to respond fully and the opportunity is needed to carry on working with HS2 Ltd whilst the Hybrid Bill materials are being prepared. 2.4 The short timeframe attached to the consultation has also limited the analysis of the DWES. 3.0 Timescales and next steps 3.1 The Council understands that the consultation responses will be analysed by IPSOS MORI early in 2019 and comments which are accepted will be incorporated into the formal Environmental Statement. 4 | Page 3.2 Furthermore, the Council understands that in line with the Parliamentary process there will not be a separate consultation on the Full Environmental Statement. The scrutiny of the formal ES will be done via the Parliamentary process through the Select Committee sitting during the passage of the hybrid Bill. 4.0 Conclusion 4.1 The Council’s current overall position in respect of HS2 Phase 2b is to seek to maximise the economic and other benefits to Leicester and Leicestershire whilst seeking to minimise the scheme’s impacts on the area, its residents and its businesses. 4.2 The Council will continue to engage with HS2 Ltd on every aspect of the plans and scrutinise the work and proposals from HS2 Ltd to achieve the best possible outcomes in respect of its currently adopted position.
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