HS2 Phase One Environmental Statement Consultation
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1 HS2 Phase One environmental statement consultation You can respond to this consultation by emailing your comments to: [email protected] 2 Information about you First name: Sara-Louise Surname: Board Address: Warwickshire County Council, PO Box 43 Shire Hall, Warwick. Postcode: CV34 4SX Email: [email protected] Are you responding on behalf of an organisation? If so, please state your organisation’s name and your position below: Organisation: Warwickshire County Council Position: HS2 Project Manager 3 Introduction and general observations on the documents that form the EIA In this section the council’s comments refer to the overall structure of the documents and a number of general observations on the papers as a whole. To aid the reader we have where possible followed the sequence and order of issues raised and the methodology used by HS2 Ltd, namely: Agriculture Air Quality Community – incorporating health related issues outside of the HIA. Culture and Heritage Ecology Land Landscape Socio Economic Noise Traffic, incorporating PROW, highway design and Traffic Safety Water Resources & Flood Risk Where a comment by the council refers to a specific issue or map, a corresponding reference is included in the left hand column. Where a reference is not give, the comment applies to the document or subject area as a whole. The council does not have the capacity or the technical experience to comment in every area of the environmental statement. There are a number of areas within the documents where the council has not offered a comment, this should not be taken as agreement or consent for the text. General concerns with the documents There are a number of simple errors in the papers, spelling mistakes, incorrect cross referencing between sub chapters and volumes, missing words which in places render the ES statements nonsensical. Furthermore the suggestion that the documents are simple to understand and that the average person only needs to read the chapter pertinent to their locality to be assured that the assessment is sound is completely false. It is the council’s view that to make reasonable sense of the papers one needs to have open at least four and in some instances seven chapters/ maps of the ES at the same time. This level of cross referencing makes it almost impossible for the average reader to do this online and therefore discourages comment from the wider population. The council is dismayed that a number of documents were omitted in the early stages and that two addendums had to be issued. We welcome the extra time granted to review the additional papers but remain concern that this level of omission is symptomatic of the lack of care shown by HS2 Ltd. 4 Warwickshire County Council finds it wholly unacceptable that despite repeated requests by itself and many other local authorities, HS2 Ltd remain resolute in their refusal to convene a line wide planning sub forum on ecology and environment issues. The council believes that; a) That the ES significantly undervalues non-statutory sites. b) That there has been a gross misrepresentation of known and potential biodiversity as illustrated on the ES maps in Volume 5. Consequently, there has been a serious misrepresentation of the potential impacts of the Proposed Scheme and contrary to the precautionary principle and EcIA. c) That by 2026 there will have been significant changes to the operational baseline that has not been taken into account as part of the ES. d) That the Proposed Scheme will cause unacceptable fragmentation of the ecological landscape. e) That the Proposed Scheme will result in a net loss to biodiversity. It is the council’s conclusion that the ES is misleading to the decision maker. Throughout the documents there are repeated instances of inconsistent application of criteria and a systematic ‘downplaying’ of the impact of HS2 on Warwickshire. It would appear that there is not meaningful consideration of the cumulative effects by HS2 Ltd on the impact it will create. There is an overly simplistic view that pays no attention to the economic effects on the towns of Southam, Kenilworth and Coleshill, which are deemed not to be affected by the route, this is incorrect and must be addressed by HS2 Ltd if it is to avoid further confrontation with communities. The council is concerned with the recent GIS data release for Warwickshire. It appears that there is only one site “significantly” affected by HS2 namely; Stoneleigh Park. Despite the status of “significantly affected,” HS2 have to date not incorporated any mitigation recommendations supplied by the communities or the landowners that negate the impact on the site. There appears to be no methodology as to why this location has been highlighted in preference to any other location or what the criteria for selection are. It is the council’s view that this error needs to be addressed The following section identifies concerns and errors in the order it appears in the HS2 papers but is not specific to any one volume or reference. 5 Landscape & Visual Assessment Whole Both the landscape and visual effects are down played in significance document from year 1 of operation onwards. Sensitivity and magnitude are down played consistently. There are instances where the text states “substantial change” and yet only “medium magnitude” is given. General There is inadequate information of when and where advance planting is to take place. If the scheme commences in 2026 planting may not be mature enough to have any screening effect by the time it comes into operation. WCC require evidence of how HS2 have determined the growth rate predicted by 2026. General The council feel that the effect of lighting of the construction compounds and satellites has been significantly down played. General Inadequate consideration has been given to the impact of new planting on views. Planting can have an impact in its own right by blocking off existing views e.g. as illustrated in photomontage LV-01-249 (CFA 19). General The assessment makes only passing reference to the irreversibility of certain landscape effects, e.g. loss of ancient woodland, historic hedgerows and ridge & furrow; realignment of rural / historic roads; significant earthworks and major alterations to local landmarks such as Windmill Hill. These will result in significant changes to local landscape character and cannot be mitigated against. Despite this they are given minimal consideration in the ES which is unacceptable. Sound, Noise & Vibration Planning Forum Warwickshire County Council is a member of the HS2 Planning Forum Acoustics Sub- Acoustics Sub Group. One of the aims of the group is resolve and group Candidate narrow down technical noise and vibration issues. Below is a summary Issues Register of the group’s current unresolved issues as recorded in the sub group’s Candidate Issues Register. The council seek assurances from HS2 that these will be reviewed to ensure that all outstanding issues are addressed before any further detailed design and assessment work is carried out. 1. There is a disagreement with the criteria not to identify individual or small numbers of properties as a having a significant effect when criteria is met. Other regulatory regimes recognise the impact on the nearest single or small number of properties (Statutory Nuisance, Local Authority Planning etc.). We believe HS2 should amend its noise assessment policy to include the effects on single and small numbers of properties. 2. The significant impact criteria for LAFMax noise levels are not agreed. The maximum noise criteria are insufficient for rural areas. 3. The council seek assurances from HS2 that these will be reviewed to ensure that all outstanding issues are addressed before any further detailed design and assessment work is carried out. 6 4. The group are in disagreement with HS2 on the day and night time average noise levels LAeq 50 dB day / 40 dB night as 'lowest observed adverse effect level'. The night time level is deemed insufficient for rural areas with low background noise levels. 5. The noise contour maps within the ES should show the LAFMax level of noise. Contour levels have remained at 50 dB LAeq day and 40 dB LAeq night and we believe that the impact on rural locations has not been adequately conveyed. We are still concerned that the cumulative effect of LAFMax levels from the passing trains has not been fully taken into account due to use of LAFMax levels of 80 and 85 dB. The information on noise mitigation is still indicative and we maintain our view that it is difficult for communities to visualise the type of mitigation and provide ideas for alternatives. WCC expect HS2 to fully explore the opportunities in technological improvements to ensure that the impact is reduced at source and that the need for any localised mitigation, particularly noise insulation is minimised. We continue to believe all communities large and small are entitled to the same level of noise protection and that where an adverse noise impact occurs it is specifically identified whether it is an individual dwelling or forms part of a community. We are pleased that HS2 have recognised the potential problem of Rayleigh waves but seek assurances that where concern over soft ground conditions in certain locations exists, these areas are identified and full remediation measures made known. Traffic; Traffic Assessment Volume, page and Full ES comment paragraph reference General The level of communication from HS2 with WCC concerning the scope of the Transport Assessment (TA) has been wholly inadequate and WCC has no confidence that the information provided within the TA realistically reflects the likely impact on Warwickshire’s roads. The Transport Assessment takes a cosmetic view of the likely impact of construction activities and WCC’s comments reflect this.