HS2 Phase One Environmental Statement Consultation

HS2 Phase One environmental statement consultation

You can respond to this consultation by emailing your comments to:

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

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.

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.

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.

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. We request from HS2 more detailed dialogue as the TA is not fit for purpose at present. Various statements in the Baseline conditions report and the five community forum reports comment along the lines of “The scope of work and study area has been discussed with the key transport authorities including Warwickshire County Council and HA”. This has certainly not been the case for Warwickshire thus the statement in isolation is hugely misleading.

Traffic; Highways Volume, page Full ES comment and paragraph reference General WCC is disappointed at the level of detail showing the alterations to the comment existing highway network. The ES does not provide sufficient detail to enable a technical assessment to be made prior to submission of any detailed proposals for development work on the Highway.

General WCC has concerns about vertical and horizontal alignment – these comment concerns are given in the specific CFA comments for area 16-20 in respect to the Volume 2 Map Books and Community Forum reports.

General General comments on the Volume 5 Draft Code of Construction are comment applicable to all 5 community forums

General WCC needs to see robust travel plans/ arrangements to ensure that comment site staff can access the compound.

General WCC will also require safe areas to park in the compound when WCC comment staff visit the site for the various inspections

Water Resource & Flood Risk Volume, page Full ES comment and paragraph reference General This response to Flood Risk Management is from Warwickshire County comment Council as Lead Local Flood Authority and therefore relates to ordinary watercourses and surface water, with the assumption that the Environment Agency as a statutory consultee will be commenting on main river flood risk, Flood Zones, and all Water Framework Directive related matters.

General We have focussed our attention on the part of the route which comes comment closest to an area of significant flood risk from surface water and ordinary watercourses, which is CFA 16, Ladbroke and Southam. However, many of the comments we make are generic and therefore relevant to all other CFAs. We strongly recommend that HS2 uses this commentary to inform its plans across Warwickshire.

General In the documentation provided, HS2 gives little attention to comment groundwater flooding, yet acknowledges that there are areas of high risk. The route for HS2 Phase 1 passes near a number of known flooding locations, including Ladbroke, Cubbington, Offchurch, Kenilworth and Coleshill. From a flood risk perspective, HS2 must attend to surface water and sub-surface / groundwater hydrological regimes throughout the route. The only way to adequately do this is to undertake site-specific groundwater investigations – boreholes - to identify the risk of disturbing groundwater or subsurface flow routes, and to be able to mitigate these accordingly.

General There is no mention throughout any of the documents of where comment responsibility lies for ongoing maintenance of new drainage infrastructure, sustainable or otherwise, that is constructed by HS2. This is an unacceptable oversight and must be addressed.

General There is no commitment in the documents for HS2 to submit drainage comment strategies for all parts of the route to the EA (as statutory consultee) and WCC (as Lead Local Flood Authority with oversight for surface water flood risk). This must be done, and must include the following: - Calculations of pre- and post- development run-off rates from the sites. - A fully labelled network drawing showing all dimensions of all elements of the proposed drainage system including details of any on / offline structures. - Detailed network calculations that correspond to the above drawing.

- Modelled results for critical storms, including as a minimum 1yr, 30yr, and 100yr +30% cc events of various durations. A submerged outfall should be used for the modelling. - An electronic copy of the hydraulic model may be requested. - We require correspondence from Severn Trent Water confirming any points of connection, permitted discharge rates, and confirmation of sufficient capacity within the receiving networks. - If any drainage network is to be adopted, evidence of an agreement with the adopting body. - Evidence of overland flood flow routing in case of system failure. This should include the flow routes and depths/velocities of the flows. - Details of the long term maintenance of the drainage, including a maintenance regime and details of the maintenance companies. - Further site investigations need to be carried out at Detailed Design stage to determine if ground conditions are suitable for soakaways and to determine existing groundwater / sub-surface flow routes.

Use of at-source sustainable drainage methods such as a soakaway as detailed in Approved Document Part H of the Building Regulations.

The Non-technical summary. The council’s comments are addressed in the order they appear in the document and sub divided by topic to aid the reader’s understanding. Where the council has not provided comment, this should not be taken as agreement or consent for the text. The order of comments are:

a) Agriculture b) Air Quality c) Community – incorporating health related issues outside of the HIA. d) Culture and Heritage e) Ecology f) Land g) Landscape & visual assessment h) Socio Economic i) Noise j) Traffic & Transport, incorporating PROW, highway design and Traffic Safety

At this time the council has no comments to make in: a) Agriculture b) Air Quality c) Community – incorporating health related issues outside of the HIA. Document: Non-technical summary.

Non-technical The council disagrees with opening statement that “the summary. assessment of the effect on the community takes account of a 7.4 page 44 range of impacts, including demolition, or partial loss, of dwellings, community facilities and public open space, road closures.” It is the council view that these may have been identified by HS2 but a fair assessment of their local value has not been completed. It is disingenuous of HS2 not to include the community of Kingsbury and Bodymoor Heath in the list of significantly affected communities. This particular area will be subject to both the impact and disruption of Phase one and Phase two but appears to have been over looked by HS2 so far.

At this time the council has no comments to make in this section on: d) Culture and Heritage e) Ecology f) Land Quality g) Landscape & visual assessment h) Socio Economic Document: Non-technical summary.

Non-technical It is the council’s view that HS2 have significantly downplayed summary. the possible job losses in the summary document. 7.10 page 47

At this time the council has no comments to make in this section on: i) Sound, Noise & Vibration

j) Traffic & Transport; PROW Document: Non-technical summary.

Non-technical The number of footpaths affected is more than the three stated. summary. Pg. 5 footpaths are being realigned, 2 bridleways are being 114 Traffic and realigned, 1 footpath is being permanently closed. Radbourne Transport Lane is affected. Although some of the realignments appear relatively slight they still have an impact as the distances increase. Non-technical Is the 450m quoted the maximum diversion for one route or is it summary. Pg. the total for the three unknown routes? Any figures quoted must 114 Traffic and be accurate and meaningful. Consistency must exist throughout Transport the document. Other community areas do not have a distance quoted for diversions.

Non-technical This section concerns the construction of the railhead and the summary. Pg. impact that it will have on PROW. The information given in this 129 Traffic and section does not appear to match the more detailed information Transport given in Volume 2 Curdworth to Middleton. This section implies that the routes will be stopped up for a period of nine years and then be re-opened in the same manner as currently enjoyed. This is not consistently the case and there are significant differences between the before and after scenario including permanent replacement of a byway with a footpath and the total loss of one footpath. It is unclear whether the proposed new byway (upgrade of a bridleway and creation of a new byway) will be in operation before the closure of the railhead – thus leading to loss of access. Maintenance liability of the proposed byway is also unclear. This section would be better re-visited with the full implications of the railhead made clear and understandable. Non-technical New and diverted routes have been provided for existing summary. P125 PROW. The routes which fall within the Delta area in particular Traffic and have been of concern to WCC for a long period of time. Transport Although meetings with HS2 have taken place there has been no real opportunity to discuss the suitability or otherwise of the routes. The proposed solutions are still not satisfactory and will have an impact on management of the routes and on the safety of residents in the surrounding areas. More detail to be given under the appropriate Community Area.

It is the council’s view that throughout the non-technical summary sections 8.16 to 8.20 there is a systematic downplaying and individual assessment of the forum areas.

It is clear that the cumulative effects have been reported in series rather than as a cumulative impact on the community as a whole.

This is particularly apparent in section 8.20 page 127 where the linkage between the use of the railhead at Kingsbury Road for both Phases One and Two is completely ignored. The council finds this an unacceptable oversight.

Volume 1: Introduction to the ES and Proposed Scheme. The council’s comments are addressed in the order they appear in the document and sub divided by topic to aid the reader’s understanding. Where the council has not provided comment, this should not be taken as agreement or consent for the text. The order of the comments are:

a) Agriculture b) Air Quality c) Community – incorporating health related issues outside of the HIA. d) Culture and Heritage e) Ecology f) Land g) Landscape h) Socio Economic i) Noise j) Traffic, incorporating PROW, highway design and Traffic Safety

At this time the council has no comment to make in: a) Agriculture b) Air Quality c) Community- incorporating health related issues outside of the HIA Document: Vol. 1: Introduction to the Environmental Statement and the Proposed Scheme

ES 3.1.0

Volume, page and Full ES comment paragraph reference

8.3.2 Use of PROW in the community section is confusing as it does not appear to be referenced in the traffic / highways section

8.3.5 Baseline data of Census is too high level and does not give a true picture of the locality. Local authorities have data that could be used which would more fairly reflect the communities and their localities.

Page 136 The use of the term professional judgement without substantiating the credentials is unacceptably vague.

d) Culture & Heritage Document: Vol. 1: Introduction to the Environmental Statement and the Proposed Scheme

ES 3.1.0

Volume, page and Full ES comment paragraph reference

pg. 8 This paragraph states that the EMR will ‘impose requirements on the nominated undertaker to use 1.4.4 reasonable endeavours to adopt measures to reduce the adverse environmental effects reported in the ES’.

As we have detailed elsewhere, we are concerned that insufficient assessment has been undertaken to date to enable the adverse effects of this scheme upon known heritage assets to be sufficiently understood and presented in the ES.

In addition there is very limited information presented in the ES in respect of the potential for previously unidentified heritage assets (in particular archaeological remains) to be impacted by this scheme. Whilst it is our understanding that some detailed assessment of this has been ongoing, little of this is presented in the ES (for example, there is some (limited) reference in the ES to risk modelling and scoring having been undertaken, however, the results of that assessment is not included in the ES).

There is therefore insufficient information presented in the ES to enable an assessment to be made of the potential impact that the proposal will have upon the historic environment. This has implications for the accuracy of the estimated costs of mitigating the impacts that this scheme will have upon the historic environment – how accurate can the assessed costs of mitigating those impacts be if the potential impact is not yet sufficiently understood?

The requirements on the nominated undertaker to use reasonable endeavours to adopt measures to reduce the adverse environmental effects are subject to this not adding unreasonable cost or delay to the construction or operation of the proposed scheme. We are concerned that, should the potential cost of mitigating the impacts of this scheme on this historic environment be underestimated at this stage (see above), this may result in inadequate works to mitigate this impact being undertaken due to time and monetary constraints. pg. 8 Reference is made in this paragraph to using ‘reasonable endeavours’ and ‘unreasonable cost or delays’. It is not 1.4.4 clear who will determine what are ‘reasonable endeavours’ or ‘unreasonable costs or delays’. pg. 85 This paragraph makes reference to the nominated undertaker assessing potential settlement along the route of the railway, including the risk of damage to all buildings within the zone affected by settlement.

This assessment should also take into account any impacts upon any archaeological deposits with the zone affected by settlement. pg. 128 This paragraph acknowledges that it has not been possible to access all land required to carry out fully 7.7 comprehensive surveys, but concludes that ‘it is considered that the baseline is sufficiently robust to allow the assessment of the likely significant environmental effects of the scheme’.

As we have detailed elsewhere, whilst the results of the limited non-intrusive fieldwork which was undertaken are detailed in the ES, no information is included about the quantity of, and which, areas were identified as priority sites for survey and not surveyed.

This lack of information about the Archaeological Risk Model significantly limits our ability to critically evaluate the robustness of the information presented in the ES. In particular, we cannot assess the degree to which the lack of survey referred to in this paragraph has limited the assessment detailed in the ES.

15 pg. 137 Whilst para. 8.4.4 states that ‘Survey work was discussed with English Heritage and local authority archaeologists 8.4.4 on a case-by-case basis’ we would highlight that these discussions have, in our experience, been extremely limited to date, not least due to restrictions of the information provided, such as maps showing the areas to be subject to detailed survey etc., to the WCC Archaeologist.

Of particular note is that little discussion was held with the WCC Archaeologist regarding the geophysical surveys detailed in this ES; and, whilst the Scope and Methodology Addendum (ES. 3.5.0.15.2)) states that, prior to the implementation of fieldwork, ‘a Written Scheme of Investigation (WSI) shall be compiled… and shall be agreed for issue to Local Planning Authority (LPA) (County or Unitary Authority) Archaeologists’, the WSIs for these surveys was not provided to the WCC Archaeologist for comment.

. pg.145 This paragraph only references assessing the impacts of sound, noise and vibration on people. 8.9.1 As highlighted elsewhere in the ES, there is a potential for sound, noise and vibration to have an impact upon heritage assets – the need for this to be assessed should be highlighted in this section. pg. 166 This paragraph states that ‘where burial has occurred over 100 years ago consideration will be given to the need 9.7.7 for, and extent of, archaeological investigation’.

Whilst the scope of the appropriate excavation may vary, any burials over 100 years should be archaeologically investigated. pg. 166 Whilst we are reassured that the ES recognises the need for cross discipline working, there has been little example 9.7.8 of this to date (as presented in ES).

This cross discipline working should include sound, noise and vibration as well as landscape.

Ecology Document: Volume 1 Introduction to the Environmental Statement and the Proposed Scheme

Volume, page and Full ES comment paragraph reference

Vol.1: para 1.1.7, page Phase One is the subject of this Environmental Statement 2 (ES), and is referred to hereafter as the ‘Proposed Scheme’. It will involve the construction of a new railway approximately 230km (143 miles) in length between London and the West Midlands, and will include: practicable and cost-effective measures to mitigate adverse environmental impacts.

The council believes that there are a number of practicable and cost-effective measures to address the ecological impacts that have not been considered by HS2 Ltd.

1.1.8 Construction of the Proposed Scheme is expected to take place between 2017 and 2026 (including a period of testing and commissioning)… Some early works are planned for

2015 and 2016 (subject to any necessary agreements or consents) but this does not affect the validity of baseline assessments for 2017.

The council believes that the ecological compensation on undisturbed land should commence at the earliest time to reduce the temporal multiplier within the offsetting principles.

1.4.1 In order to ensure that the environmental effects of the Proposed Scheme will not significantly exceed those assessed in the ES, the Secretary of State will establish a set of controls known as Environmental Minimum Requirements (EMR). The EMR will be contained in a suite of documents that will sit alongside the provisions set out in the hybrid Bill itself.

The council is concerned that the powers proposed in the Bill do not require all the works and operations proposed to be implemented and, furthermore, there is no commitment as such to undertake the mitigation proposed or any independent basis to enforce their provision. This has possible implications on the validity of the ES in any such eventuality due to inter-dependencies and consequences of partial implementation.

1.4.2 During the passage of the hybrid Bill, the Secretary of State will confirm to Parliament the scope of, and the documents forming the EMR; and will make a commitment to Parliament to take whatever steps he/she considers reasonable and necessary to secure compliance with them.

1.4.3 The EMR, together with the controls in the hybrid Bill, will ensure that the impacts assessed in the ES will not be exceeded, unless this results from a change in circumstances

that was not foreseeable at the time the ES was prepared; or any such changes will be unlikely to have significant adverse environmental effects; or will be subject to a separate consent process and further EIA.

1.4.5  an Environmental Memorandum, which is a framework for HS2 Ltd and its contractors and stakeholders, such as the Environment Agency and Natural England, to work together to ensure that the design and construction of Phase One is carried out with due regard for environmental considerations;

The Environmental Memorandum must also include local specialists who understand the local area. The current Environmental Memorandum is only draft and therefore there are no assurances that the design and construction of Phase One is carried out with due regard for environmental considerations.

1.5.3 The Government’s commitment to sustainable development builds on the previous Government’s strategy: Securing the future, which set out five ‘guiding principles’ of sustainable development, namely:

 living within the planet’s environmental limits;  using sound science responsibly. The council believes that sound science has not been used to evaluate the impacts or form the compensation and mitigation and therefore the ES does not conform to the Government’s commitments to sustainable development.

1.5.4 The National Planning Policy Framework (NPPF) sets out the Government’s strategic guidance on development planning in England and Wales. The principles of sustainable development underpin the NPPF and its associated technical guidance. It identifies three dimensions to sustainable development, namely:

 environmental: contributing to protecting and enhancing our natural, built and historic environment and, as part of this, helping to improve biodiversity, use natural resources prudently, reduce waste and pollution, and mitigate and adapt to climate change (including moving to a low carbon economy). The Proposed scheme will have a significant negative impact on biodiversity and therefore is non-compliant with NPPF. Significantly, it will impact on ‘irreplaceable habitats’ that have particular protection within the NPPF, such as Ancient Woodlands.

Table 1: Sustainable Protect natural and cultural resources and enhance the design aims environment

Design Aim 3: protecting natural resources - The project shall seek to avoid direct or indirect harm to valued landscape, water and ecological resources, to mitigate adverse impacts and to enhance such resources where practicable. Measures to achieve this would be commensurate with the sensitivity of the resources and the level of their protection.

The council has clear evidence that this design aim has not been met and commensurate to the level of their protection. The council suggests that there has been a gross misrepresentation of known and potential biodiversity. Consequently, there has been a serious misrepresentation of the potential impacts of the Proposed Scheme and contrary to the precautionary principle and EcIA.

2.3.19 The HS1/ HS2 link will allow the possibility of direct trains from the HS2 network to the continent.

HS2 has downplayed the international importance since the publication of the Draft ES. The council suggests that this is due to an EU member states requirement with EU EIA regulations to consult EU partners on trans-national projects. The council is not aware that any trans-national consultation has taken place. The council would like to understand why HS2 Ltd suggests that the scheme is now not a trans-national project.

3.2.3 During preparation of the draft ES, engagement took place with the public through community forums, with NGO through the NGO environment forum, and with local and statutory authorities through planning and national environment forums and sub groups of these. This established a process of dialogue with relevant stakeholder groups. Engagement was undertaken in order to raise awareness of the programme, relevant policies and the documents being produced, and to encourage constructive participation in the consultation process.

Since 2012 the council requested a line-wide Ecology Technical Group to assist with ecological principles. This included official reporting of outcomes to HS2. However, this was finally rejected in January 2013 at a Country North Planning Forum. Therefore, there has been no officially minuted mechanism for LA Ecologists to feed into the consultation process. Local Authority Ecologists where only ‘officially’ consulted as a separate ‘body’ on 23rd September 2013.

3.2.4 The national environment forum involves national representatives of environmental statutory authorities and government departments. The forum meets quarterly and provides advice on environmental policy, including project- wide mitigation strategies and principles. Members of the forum include English Heritage, Natural England and the Environment Agency.

Since 2012 , the council recommended a LA representative on the Environment Forum that was also declined. Local Authority Ecologists where only ‘officially’ consulted as a separate ‘body’ on 23rd September 2013.

3.2.5 HS2 Ltd meets quarterly with the NGO environment forum to discuss technical environmental matters relating to programme, design, environmental impacts and mitigation. NGO forum members include such groups as the Campaign to Protect Rural England, the Campaign for Better Transport, the National Trust, the Wildlife Trust and the Ramblers, amongst others. The NGO forum provides the opportunity for open discussion about environmental and sustainability issues and considers how the Proposed Scheme could contribute to or enhance the environment it passes through.

Local Authority Ecologists where only ‘officially’ consulted as a separate ‘body’ on 23rd September 2013.

3.2.6 The Minister of State for Transport also holds a quarterly meeting with the NGO environment forum, staggered with those undertaken by HS2 Ltd. This forum allows the Minister to check on the progress of the meetings undertaken with HS2 Ltd and to discuss the concerns and aspirations of the attendant organisations.

Local Authority Ecologists where only ‘officially’ consulted as a separate ‘body’ on 23rd September 2013.

Figures 11, 12, 13 Notes: Any Channel Tunnel train services continuing onto the HS2 infrastructure would substitute for services out of London (Euston)

Reference to international significance of the route, please refer to comments under paragraph 2.3.19

4.3.6 Based on the current requirements, it is anticipated that the main route of the Proposed Scheme could operate up to 14tph in each direction during peak hours (Figure 12), increasing up to 18tph in each direction during peak hour once Phase Two becomes operational.

This equates to 36 trains per hour equivalent to one train every 1 minute and 40 seconds. This regularity of impact will be equivalent to a permanent impact to certain sensitive species that has not been appropriately considered within the ES. The council suggests that there has been a gross misrepresentation of potential biodiversity impact. Consequently, there has been a serious misrepresentation of the potential impacts of the Proposed Scheme and contrary to the precautionary principle and EcIA.

4.3.8 The operating speeds over each section of the route are anticipated to be as follows:

 between the Chilterns tunnel and Birmingham Interchange station – up to 360kph;

This is 225mph – barotrauma for bats (blade tip speeds range from 138–182 mph, National Wind Coordinating Collaborative, 2010). The council believes that the ES has not considered this potential impact on bats and other small mammals. Therefore there has been a gross misrepresentation of potential biodiversity impact. Consequently, there has been a serious misrepresentation of the potential impacts of the Proposed Scheme and contrary to the precautionary principle and EcIA.

Section 5 - Permanent features of the Proposed Scheme General – Section 5 WCC is disappointed in the lack of details presented in the ES documents regarding highway, public right of way (PROW) and “green- wildlife” bridges in Warwickshire.

The non-technical summary (ES 3.0.0) gives just one brief paragraph and one generic image of a viaduct on the important subject of permanent features such as highway and environmental bridges.

The CFA reports 16-20 and associated Vol 5 Maps convey only the most basic details of structures.

Section 5.9 Viaducts Sections 5.9 and 5.10 give little more than generic illustrations that convey limited attention to detail. The appearance, appropriate and geometry and detailing of bridges forms a very important functional 5.10 Bridges and community “public realm” asset. Phase 1 of HS2 proposals in Warwickshire includes the construction of some 43 viaducts, 25 new highway over-bridges, 4 highway under bridges, 11PROW footbridges and 7 farm accommodation structures.

The appearance of rural and urban bridges needs to respect the local setting as much as sympathetic and “impressive” viaduct crossings over rivers and lakes. Repetitive and “bland and cheap” structures must be avoided in developing the detailed design brief for either consultants or “Design and Build” contractors. The creation of adequate numbers and types of “green bridges” is vital

to sustain wildlife corridors and retention of local landscape and general community amenity.

WCC advocates that a Bridge Design Forum (BDF) is established early in 2014 to agree the design principles to ensure technical, aesthetic and best practice structures and associated approach infrastructure to structures such as vehicle safety fencing and signage is provided. Similarly, maintenance liabilities need to be clearly defined as it is not adequately covered in the Bill. Leaving design details open to interpretation at a late stage of the HS2 project, as would arise with a “Design and Build” contract, will miss the opportunity of delivering key stakeholder requirements and expectations. The BDF could represent the range of stakeholders along the full routes to share knowledge and views.

It is apparent from the details in the Vol 5 Map Books for Warwickshire, several of the outline bridges tend to be long and narrow structures across wide cuttings. It is considered that a review could find benefits in creating wider and short span structures in a number of rural cutting locations. The benefits include less intrusive tall concrete parapets, reduced spoil taken from site and reduced construction traffic, wider wildlife corridors to reduce conflicts between wildlife and traffic, reduced maintenance and whole-life costs (e.g. less bridge joints and waterproofing). Other factors to be considered with the introduction of so many new structures include the visual impact of general chain-link fencing and detailing in respect to objects being dropped from structures onto the HS2 line.

The consequence of long and deep cuttings over 1km length effectively direct larger wildlife to use relatively narrow highway structures as “corridors” to cross HS2. This situation potentially creates a safety hazard to road users, particularly in the rural section of HS2 to the east of the A46 – Kenilworth area to the County boundary near Wormleighton.

WCC request the following “green bridge” infrastructure requirements in addition to, or replacement of, those stated in the ES at the following locations:-

1) Green bridge at Stoneton Road and Wormleighton Road in proximity of Wormleighton Maintenance Loop.

2) Green Tunnel at Windmill Hill, Ladbroke Hill Farm (SP4261 5922)

3) Green Tunnel at South Cubbington Wood (SP3518 6847)

4) Substantial Green Bridge at A445 Leicester Lane (SP3405 2714)

5) Green Tunnel or substantial Green Bridge at Stoneleigh Road (SP3301 7126)

6) Green Bridge and Viaduct construction at A46 (SP3164 7274) to enable north-south and east-west ecological connectivity.

7) Other Green bridges maybe appropriate at farm accommodation bridges and other highway crossings as environmental needs are better understood.

5.10. – Bridges - Road Section 5.10 fails to consider the impact of a likely increase in road Noise noise associated with the change in road alignment with over- bridges. In many locations the local road noise is currently contained by mature hedges.

HS2 must use low noise road surfaces to mitigate any adverse changes in road noise at over-bridge sites.

5.10.2 Bridges Overbridges (i.e. bridges over the proposed route) will be constructed of concrete or weathering steel beams with reinforced concrete slab. Typical height clearances will be 7.15m (i.e. rail level to the underside of the bridge).

The council notes that there are no measurements indicating the typical width of these structures. Width is critical to calculate the pressure wave generated by high speed trains when passing under solid structures (Ogawa and Nishida, circa.2002). The council believes that without this measurement the potential impacts on bats and other sensitive species has not been adequately assessed and therefore the ES is contrary to the precautionary principle and EcIA and the finding misleading to a decision maker.

5.12.2 Maintenance When maintenance activities are being undertaken over a loop sidings number of nights, the maintenance train may be stabled on the loop sidings during the day, allowing work to be undertaken at night.

The council suggests that the additional light and noise disturbance in the tranquil area of Ladbroke has not been taken into consideration on the adjacent ecological receptors and therefore the ES has not adequately assessed the impact. The ES is subsequently contrary to the precautionary principle and EcIA and the finding misleading to a decision maker.

5.15.2 Site Restoration Land that was formerly under agriculture or forestry use will and landscape be restored to that use. Some additional/adjacent areas may treatment undergo restoration. This may include the provision of compensatory and replacement habitat for wildlife species/habitats or areas of valued landscape character adversely affected during construction. These areas will be established and monitored to maintain the long-term conservation status of the species/habitat in each case.

5.16.4 The choice of track form at different locations will be informed by further modelling and investigation of the ground conditions along the route. For the purpose of the assessment

(e.g. in relation to construction methods and noise and vibration), an assumption has been made that slab track will be used in bored tunnels and that whichever is the worst-case effect between ballast and slab will be used elsewhere.

It is known that the slab track generates more noise and vibration than ballast. The council is concerned that these additional impacts have not been considered when assessing the impacts on neighbouring ecological receptors as they are currently ‘unknowns’. Therefore, the ES has not adequately assessed the impact. The ES is subsequently contrary to the precautionary principle and EcIA and the finding misleading to a decision maker.

6.3.37 Excavated For the surplus excavated material which cannot be Material beneficially reused for the earthworks of the Proposed Scheme, the nominated undertaker will seek to provide surplus excavated material for:

 use in other local construction projects where opportunities arise at the time of construction; and/or

 use for restoration of mineral sites, where the transportation of that material does not result in significant environmental effects.

The council would like to suggest that the material could be used for nature conservation enhancement (especially if nutrient poor soils and or of calcareous/non-calcareous nature).

6.3.49 Noise and Noise insulation will be offered for qualifying buildings as vibration defined in the draft CoCP's Noise Insulation and Temporary Re-housing Policy. Noise insulation or ultimately temporary rehousing will avoid residents being significantly affected by levels of construction noise inside their dwellings. The assessment reported in this section provides an estimate of the buildings that are likely to qualify for such measures.

Noise and vibration has been covered in the respective CFA reports where they refer to species sensitivities. However, there have not been sufficient ecological surveys to ascertain the current and future baselines. ES has not adequately assessed the impact. The ES is subsequently contrary to the precautionary principle and EcIA and the finding misleading to a decision maker.

6.4.1 Advanced Works Advance works required before construction commences will generally include:

 further detailed environmental surveys; The council interprets this bullet as an admission that there has not been sufficient ecological surveys to ascertain the current and future baselines. ES has not adequately assessed the impact. The ES is subsequently contrary to the precautionary principle and EcIA and the finding misleading to a decision maker.

6.4.3 Further detailed Further detailed, site specific environmental surveys will also environmental Surveys be undertaken, which will include:

 ecological surveys to confirm the baseline in areas where no access has been possible to date, and to inform licence applications and proposed habitat/species translocation works;

 archaeological and built heritage evaluation surveys to confirm the character of assets and to inform the design of detailed mitigation strategies. Evaluation works may include desk-based research and historic building, geophysical and/or trial trenching surveys;

 hydrological and hydrogeological surveys to confirm flooding potential, water quality and groundwater conditions;

 geotechnical investigations to confirm ground and groundwater conditions; and  contaminated land surveys, including boreholes, probe holes and trial pits, supported by soil and groundwater sampling and testing for a suite of relevant chemicals, in order to confirm any possible contamination sources and pathways, and any remediation works that may be required. The council interprets these bullet points as an admission that there have not been sufficient ecological surveys to ascertain the current and future baselines. ES has not adequately assessed the impact. The ES is subsequently contrary to the precautionary principle and EcIA and the finding misleading to a decision maker.

6.4.7 Habitat creation Where translocation or relocation of protected species is and species/habitat required, this process may take up to two years prior to translocation construction.

The council suggests that the timetable of the main construction works are expected to take place between 2017 and 2026. … Some early works are planned for 2015 and 2016 (Volume 1: 7.2.2 Temporal scope for assessment scenarios) is unrealistic. This is evidenced by the admissions that the ‘translocation or relocation of protected species … may take up to two years prior to construction’ with these areas only being identified after the ‘further detailed ecological surveys’ (Volume 1: 6.4.3 )necessary to assess and determine where, when and what translocation and relocation is required plus the need to acquire land to carry out this operation with management contracts ‘to maintain the long-term conservation status of the species/habitat in each case‘(Volume 1: 5.15.2).

The council suggests that these constraints will significantly impact on the scheduled programme of the Proposed Scheme making the ES potentially unsound.

6.4.16 Utility diversions Some utility works will require temporary realignment of PRoW. As detailed in Section 6.3, this will be managed through a traffic management plan.

The council cannot determine the total impact caused by the utility diversions. There are no details of how utility companies will get to their infrastructure within the construction area and those outside of the construction area. The council suggests that these additional impacts on hedgerows, habitat and species has not been assessed and as such the ES contrary to the precautionary principle and EcIA and the finding misleading to a decision maker.

6.7.2 Prior to excavation, vegetation or structures will be removed or demolished as necessary and the resulting waste material recovered or removed to a permitted landfill site. Topsoil will be stripped down to the top of the subsoil layer and stored appropriately. Should subsoil need to be removed, this will also be stored appropriately. The surfaces of stockpiled material will be formed to prevent degradation of the material and will be managed to control weed growth. As far as reasonably practicable, stockpiles will be kept away from sensitive features (including natural and historic features), watercourses and surface drains. Elsewhere, stockpiles may be located near the site boundary, where they can help to provide temporary screening.

The council is concerned with the phrase ‘As far as reasonably practicable’ and that the powers proposed in the Bill do not require all the works and operations proposed to be implemented and, furthermore, there is no commitment as such to undertake the mitigation proposed or any independent basis to enforce their provision. This has possible implications on the validity of the ES in any such eventuality due to inter-dependencies and consequences of partial implementation.

6.9.5 Drainage and Watercourses that require horizontal realignment will watercourse generally be constructed in the following sequence: realignment a) temporary fencing of the route for realignment; b) excavation of the realigned channel to the required level, leaving existing ground at each end (a ‘plug’), or installation of sheet pile walling, sufficient to prevent inflow from the existing watercourse; c) stabilisation of side slopes and channel; d) lining of channel invert, if required; e) if necessary, sealing with clay or constructing a concrete base and walls; f) removal of plugs or sheet pile walls, allowing water to flow into the realigned channel; g) sealing up the ends of the original watercourse and backfilling the channel with h) suitable material; and i) landscaping or finishing as required. The council is concerned that no mention has been made to any pre-commencement ecological surveys and subsequent appropriate mitigation measures within this sequence. This omission implies that appropriate considerations to ecology has not been consistent throughout the ES.

6.12.16 Green Tunnels An illustration of this construction sequence is shown in (Option 1) Figure 37.

The council notes that ecological enhancement have not been depicted in the completed structure, highlighting that these structure are not being considered for biodiversity connectivity and functionality within the wider ecological landscape.

6.12.20 (Options 2) An illustration of this construction sequence is shown in Figure 38.

The council notes that ecological enhancement has not been depicted in the completed structure, highlighting that planting is for aesthetic purposes only and not being considered for biodiversity connectivity and functionality within the wider ecological landscape.

7 Environmental impact Assessment

7.1.2 Preparation of the The main steps in the preparation of the ES are set out below ES and are summarised in Figure 42.

The council notes that a preliminary stage of ‘literary research’ necessary to inform the baseline data gathering is missing from the diagram. This omission affects subsequent evaluation and conclusions of the Proposed Scheme’s impacts, and as such renders the ES unsound and contrary to the precautionary principle and EcIA and the finding misleading to a decision maker.

7.1.4.Baseline data Baseline studies have established the current baseline gathering conditions, i.e. the environmental conditions that exist in the vicinity of the Proposed Scheme and across the study areas for each topic. These studies comprised desk-top research to gather and evaluate previous environmental work and publicly available information, together with new environmental surveys and consultation with local groups. Relevant policies, guidelines and legislation, together with industry-accepted practice, were also identified at this stage.

The council has evidence to suggest that there has not been sufficient survey and data gathering to have established the current baseline conditions.

The council cannot find any references to scientific research papers to indicate that industry-accepted practice (ecological science) has been identified at the baseline data gathering stage.

7.1.6 Due to the inevitable uncertainty of predicting effects based on future baseline conditions, a reasonable worst-case approach has been adopted.

The council believes that there is certainty in predicting ecological future baselines. This analysis has not happened and therefore, the ES has not adequately assessed the impact of the Proposed Scheme. The ES is subsequently contrary to the precautionary principle and EcIA and the finding misleading to a decision maker.

7.1.7 Where future development may introduce new environmental receptors that could be significantly affected, these have been addressed in the assessment. In the event that the anticipated development does not take place, any mitigation proposed can be amended at a later date to reflect the change from the future baseline position.

The council believes that this statement includes the need to cater for new ‘species’ to move into habitat in the proximity to the route and not just limited to ‘development’. It is the intention that the Warwickshire, Coventry and Solihull Green Infrastructure Strategy is promoted during the 2017 – 2026 Proposed Scheme construction period and that core areas of habitat are more, bigger, better and connective (Natural Environment White Paper, 2012). To this affect the council believes that there is certainty in predicting ecological future baselines. This analysis has not happened and therefore, the ES has not adequately assessed the impact of the Proposed Scheme. The ES is subsequently contrary to the precautionary principle and EcIA and the finding misleading to a decision maker.

7.1.10 Mitigation Mitigation measures have been identified throughout the development and assessment of the Proposed Scheme. More information on the approach to mitigation is set out in

Section 9.

The council agrees with the Ecology Technical Group that mitigation and compensation are different things and that there are some habitats that cannot be compensated for (e.g. Ancient Woodland). Without the acceptance of this fact the ES remains contrary to the precautionary principle and EcIA and the finding misleading to a decision maker.

7.2.10 The assessment of environmental effects which cover a wider geographical area is reported in Volume 3. These route-wide effects have been considered at a regional or national level. The assessment of effects that may occur at locations remote from the Proposed Scheme (i.e. off-route effects) is presented in Volume 4.

The council has evidence to suggest that the impacts assessed in Volumes 3 and 4 are flawed with respect that the precautionary principle and EcIA principles have not been followed.

7.2.11 The ES does not address environmental effects that may occur outside the UK (i.e. transboundary effects). The only such effects that are likely to be relevant relate to changes in international travel that may occur once the Proposed Scheme becomes operational. These changes include additional high speed services using HS1, together with possible impacts on other international modes of transport, such as air. Such changes are very difficult to anticipate, due to the many variables involved (e.g. relative pricing between modes). However, the changes are unlikely to result in significant environmental effects.

HS2 has downplayed the international importance since the publication of the Draft ES. The council suggests that this is due to an EU member states requirement with EU EIA regulations to consult EU partners on trans-national projects. The council is not aware that any trans-national consultation has taken place. The council would like to understand why HS2 Ltd concludes that trans-national effects are not considered as Such changes are very difficult to anticipate yet HS2 is ‘unlikely to result in significant environmental effects’.

7.3.4 Variations to the definition of impacts that have been developed since the publication of the SMR are described in the SMR Addendum. Where it is not possible to quantify impacts or their consequential effects, qualitative assessments have been carried out, based on professional judgement. Where uncertainty exists, and assumptions have had to be made, these are explained in Section 8.

The council believes that this statement leads to pure conjecture. The ES is not referenced to documentation or scientific reasoning that professional judgement is based upon and that subsequently informs any assumptions made within the ES. The ES does not provide assurances and confidence in the predictive impact assessment. There is no ‘certainty assessment’ such as “x will have a definite low impact on the county important y”. This is not the precautionary approach and ecologically does not follow the EcIA guidelines.

7.3.5 Effects deemed to be significant have been evaluated against recognised standards and accepted criteria for each environmental topic, where these are available. Where no

recognised standards or criteria exist, professional judgement has been used, taking account of factors such as:

a) spatial extent (e.g. local, district, regional, national or international); b) magnitude; c) duration (whether short, medium or long-term); d) frequency of occurrence; e) nature of the effect (whether direct or indirect, permanent or reversible); f) whether it occurs in isolation, is cumulative or interactive; g) sensitivity and number of receptors affected; h) value of a resource affected; i) performance against environmental quality standards; and j) compatibility with environmental policies. The council believes that Local Spatial extent has not being appropriately assessed. The professional judgements have not been reference to any literary review papers or comparable studies. This is not the precautionary approach and ecologically does not follow the EcIA guidelines.

7.4.2 Cumulative effects Cumulative effects can be either temporary or permanent and can broadly arise from the following:

a) a number of individual environmental impacts (e.g. noise, dust and traffic) on a receptor that, in combination, are likely to have a significant effect; b) the accumulation of individual effects on a type of receptor (e.g. an ecological species) which when summed in a regional context or across the Proposed Scheme, are likely to result in an effect of greater significance than the sum of the c) individual effects; and d) the effects from other developments in the vicinity of the Proposed Scheme (during their construction and/or operation), which when combined with the effects of the Proposed Scheme are likely to have an incrementally significant effect on the receptors that experience both effects. The council believes that by only summing cumulative impacts up at a regional context is inappropriate and as many local impacts can result in a higher significance. The ES is subsequently contrary to the precautionary principle and EcIA and the finding misleading to a decision maker.

7.4.8 Phase one and A summary of the total combined impacts that may result Phase two from Phase One and Phase Two of HS2, focusing on those environmental topics that can be quantified, is presented in

Volume 3: Route-wide effects. Statistics are presented on Phase One and Phase Two alone and in combination (both Phase One and Phase Two) for property and settlements, employment and housing, noise, cultural heritage, biodiversity and wildlife, land use resource, waste and material use.

The council believes that the combined impacts cannot be extrapolated in this was as data has not been requested from the LRCs within Phase 2 and no predictive mapping or analysis of this data has been presented within the ES. The ES is subsequently contrary to the precautionary principle and EcIA and the finding misleading to a decision maker.

7.4.9 Phase One statistics are based on assessments undertaken as part of this EIA and on the assessments prepared in support of the AoS report for Phase One. Phase Two statistics are drawn from the Phase Two Sustainability Statement.

7.4.10 The operational effects of the Proposed Scheme are being assessed on the assumption that Phase Two will also be open, so as to provide a reasonable worst-case basis on which to assess effects such as those relating to train noise and traffic movements at stations. In this sense, these effects are cumulative, in that they reflect the combined operation of both phases of HS2.

7.5.2 Climate Change The approach to this assessment has been informed by good practice and guidance from the European Union and the Institute of Environmental Management and Assessment

(IEMA), however, a number of challenges have been encountered. These include:

a) establishing a future baseline that considers climate change for each topic. This is particularly difficult except in relation to flood risk because of the complexity of the b) interactions between climate change, the natural environment and human activity; and c) isolating the Proposed Scheme’s impact on the receiving environment and community within the broader context of climate change. The council notes that reference to the European Union (EU) (2013), Guidance on Integrating Climate Change and Biodiversity into Environmental Impact Assessment. However, there are no references to studies used to predict ecological current and future ecological receptors. The ES is subsequently contrary to the precautionary principle and EcIA and the finding misleading to a decision maker.

7.5.3 Climate Change The trends within the UKCP09 climate change projections trends indicate changes to long-term, seasonal averages such as warmer and drier summers, milder and wetter winters, an increase in annual average temperature, and fewer days with frost.

There are no references to studies used to predict ecological current and future ecological receptors. The ES is subsequently contrary to the precautionary principle and EcIA and the finding misleading to a decision maker.

7.5.7 Climate Change Outcomes of the preliminary consideration for all topics are Impact assessment contained in Volume 5: Appendix CT-009-000 and are summarised as follows:

a) agriculture, forestry and soils: climate change impacts have been considered primarily in terms of potential direct and indirect effects on the soil resource which, amongst other key functions, underpins the production of food and timber. Whilst most impacts of the Proposed Scheme on agriculture, forestry and soil resources will occur during the construction phase, climate change effects on the soil resource are likely to extend beyond this phase. However, there is insufficiently detailed evidence at the local level to be able to incorporate these future possible effects in the assessment and determine how, in combination, they may affect the impacts of the Proposed Scheme on agriculture, forestry and soil resources; b) ecology: potential climate change impacts include a series of complex and dynamic biological interrelations between animals and plants and the ecological features in which they live which makes them difficult to predict with certainty. Having considered this, it is not feasible to incorporate these future potential impacts and changes into the assessment and determine how, in combination, they may affect the impacts of the Proposed Scheme at the local level. Information on the potential impacts of climate change for ecological resources, based on a routewide assessment, is contained in Volume 3:Route- wide effects; The council believes that ecological predictive mapping can occur for agriculture, forestry and soils and ecology. Evidence of such modelling has been presented at UK landscape and spatial conferences. The council suggests that it is feasible to incorporate future potential impacts and therefore the ES is subsequently contrary to the precautionary principle and EcIA and the finding misleading to a decision maker.

7.7.1 General During the preparation of an ES, there are sometimes assumptions and circumstances in which the information available to inform the limitations assessment process is limited. For example, there is inevitably some uncertainty in predicting future baseline conditions, impacts and effects, especially since the Proposed Scheme will not be due to begin operating until 2026.

The council believes that HS2 should use predictive modelling to anticipate this future baseline at appropriate key milestones within the project e.g. Construction start date (Operational start date, (2026)). Evidence of such modelling has been presented at UK landscape and spatial conferences. The council suggests that it is feasible to incorporate future potential impacts and therefore the ES is subsequently contrary to the precautionary principle and EcIA and the finding misleading to a decision maker.

7.7.2 In addition, it has not been possible to access all land required to carry out fully comprehensive surveys. This applies to agriculture, forestry and soils, community, cultural heritage, ecology, land quality, landscape and visual, socio- economics, sound, noise and vibration, traffic and transport and water resources and flood risk. Nevertheless, it is considered that the baseline is sufficiently robust to allow the assessment of the likely significant environmental effects of the Proposed Scheme.

The council has calculated that only a third (596.72 ha) of the construction area in Warwickshire being accessible for surveys1 there is two thirds (1078.19 ha) unsurveyed and left to ‘assumptions’. However, The council (through the Warwickshire Biological Record Centre (WBRC) provided HS2 with both up-to-date and historical habitat and species data to assist in this lack of data. HS2 suggests that records ‘dated prior to 1 October 1997 will be considered as historic and unlikely to be relevant information to inform the baseline for the assessment’ (Volume 5: Technical Appendices – Scope and methodology report addendum (CT-001-000/2)); yet this is clarified in the following paragraph ‘Data from prior to the above dates will only be included in the ES where no more recent survey data are available’. This data has not been mapped on the Ecology CFA Volume 5 Map Books. Therefore, the ES is subsequently contrary to the precautionary principle and EcIA and the finding misleading to a decision maker.

1 Figures extrapolated from the areas accessible to conducting Breeding Bird Surveys Volume 5: Ecology Maps for CFA17, 18, 19, 20 etc.

8.1.8 It is also assumed that all agricultural soil resources generated by the Proposed Scheme will be used appropriately and on-site to fulfil one or more of the recognised functions of soil. The assessment assumes that all displaced ancient woodland soils will be translocated to form the basis of new woodland planting and that other woodland soils will be reused as appropriate, including as the basis for new woodland planting.

There is no evidence to show that this technique is successful for Ancient Woodlands. By following the Precautionary Approach the impacts and mitigation should be assessed as total loss. Similarly, this technique should be applied to other EU & UK Priority habitats e.g. unimproved grasslands. However, for this technique to be more successful it is necessary to assess the soil microbial community for estimating the success of restoration (Cranfield University, 2003). By not following this model increases the risk of failure and therefore the Proposed Scheme’s impact. Therefore, a true assessment of the impacts of the scheme presented in the ES is contrary to the precautionary principle and EcIA and the finding misleading to a decision maker.

8.1.10 It is assumed that farm buildings and dwellings to be demolished as part of the Proposed Scheme will not be replaced. Compensation for such loss will be available, but the decision to replace such buildings will rest with the affected party. The assessment also assumes that severed land will continue to be used by the holding where access is available to that land, and that, where required, new field accesses to severed parcels of land will be created from public highways.

The council cannot find evidence that these additional access requirements have been assessed and incorporated into the ES impacts. These accesses may be proposed in high value hedgerows causing additional breakages in connective corridors, especially if visual splays onto highways are required. Without these assessments the actual impacts have not been appropriately assessed and the ES is contrary to the precautionary principle and EcIA and the finding misleading to a decision maker.

8.3.5 Information has been collected on the current location and use of community resources and on the social characteristics of the communities that may be affected. Sources of

information have included the following:

a) published sources such as Census data and Office for National Statistics - Neighbourhood Statistics; b) existing studies such as open space and housing needs surveys; c) data from other relevant assessment topics; d) specific supplementary surveys (e.g. of open space or PRoW use); and e) consultation with community organisations, user groups and local/national government. The council would like to see the data sources used to identify accessible areas. For example, did it include HLS landholdings that allow access onto private land for educational purposes?

8.5.6 Ecology The ecological impact assessment has been guided by the methodology provided by the Chartered Institute of Ecology and Environmental Management (IEEM).

The council remains concerned that the ES continues to be ‘guided by’ (Volume 1, para 8.5.6) the IEEM guidelines on producing Ecological Impact Assessments (EcIA). It is our continued opinion that these guidelines should have been adopted and any deviations reported in the ES. In this way a known framework would have been established when assessing the ES plus for future contractors to adhere to when constructing the Proposed Scheme. However, survey techniques have not been consistent throughout the project and survey findings have not been verified with spatial referencing errors. The council has evidence to show that the EcIA has not been followed to an appropriate standard that leaves the ES unsound and is therefore, misleading to a decision maker.

8.5.9 Assumptions and Access was not obtained to all of the land where surveys limitations were proposed. In addition, delays to access have meant that some surveys could not be conducted or were not conducted according to the method laid out within the field survey methods and standards technical note included in the SMR Addendum. Therefore, in order to ensure that all likely significant effects of the Proposed Scheme have been identified, where baseline information is incomplete, a precautionary approach to valuation has been adopted, assuming a reasonable worst case.

The council is encouraged by the concession to adopt the ‘Precautionary Principle (Approach)’ and ‘worst case scenario’ referenced throughout the Ecology Sections of the Environmental Statement (ES). However, the council has evidence to show that the Precautionary Principle (Approach) has not been followed to an appropriate standard that leaves the ES unsound and is therefore, misleading to a decision maker.

8.5.10 Where precautionary valuations have been necessary, they have been based on all available information. This has included consideration of available field and desk study data (including aerial photography), a comparison with similar habitat areas occurring in the wider local area, and a qualitative consideration against any factors that indicate suitability for the particular habitat or species in question. The degree of precaution built into the assessment for each receptor reflects the level of confidence in the existing data available.

The council has evidence to show that the Precautionary Principle (Approach) and valuations have not been followed to an appropriate standard that leaves the ES unsound and is therefore, misleading to a decision maker. However, The council (through the WBRC) provided HS2 with both up-to- date and historical habitat and species data to assist in this lack of data. HS2 suggests that records ‘dated prior to 1 October 1997 will be considered as historic and unlikely to be relevant information to inform the baseline for the assessment’ (Volume 5: Technical Appendices – Scope and methodology report addendum (CT-001-000/2)); yet this is clarified in the following paragraph ‘Data from prior to the above dates will only be included in the ES where no more recent survey data are available’. This data has not been mapped on the Ecology CFA Volume 5 Map Books. Similar information has been provided for habitats, which does not appear to have been used to assess impacts on using Precautionary Principle (Approach) and valuations suggested in the ES. Therefore, the council considers the ES to be unsound and is therefore, misleading to a decision maker.

8.5.11 Other assumptions made for the purpose of the ecological impact assessment include the following:

construction of the Proposed Scheme will be lost. The reinstatement and landscaping of these areas on completion of construction are considered as part of the proposed 'other mitigation measures131, described in the Volume 2: CFA reports;

a) all construction activity will occur concurrently across the entire length of the Proposed Scheme and will start at the beginning of the construction period. This represents a worst-case scenario; b) the expansion in the range of otter will continue and by the time the Proposed Scheme is operational otter will be present in all watercourses suitable for the species; c) the operator will ensure provision of on-going management of all mitigation and compensatory habitat creation, either directly or through suitable legal and financial agreements with third parties; and d) the operator will commit to monitoring of both habitats and species in order to ensure that predictions of effects are accurate and that mitigation/compensation is successful. The council welcomes these assumption but they are tokenistic and not comprehensive. For examples; Why are only otters expected to ‘expand’ their range, what about other species?; Land will be monitored for success but no reference to changing management or additional compensation measures will be enacted should target habitat not be successful? The council suggests that a decision maker cannot be re-assured by these measures and they are not indicative of the measures necessary to fulfil the requirements laid out in the EU Precautionary Principle and the CIEEM EcIA and therefore, misleading to a decision maker.

8.6.10 Land Quality - No site specific intrusive site investigations have been Scope undertaken as part of the baseline data collection. Investigations will be undertaken during the detailed design process in order to provide contamination data for risk assessments and, where necessary, for detailed remediation design.

The council cannot find evidence that desk or land surveys have been carried out to determine geological sensitive areas that may contain significant geological interest that could be impacted upon by the Proposed Scheme. These include:

CFA 16: Ladbroke and The bedrock of this area is dominated by a poorly exposed Southam succession representing the transition from continental Triassic environments to the shallow marine environments of the Early Jurassic. Amongst Triassic sediments; exposures generated within the Arden Sandstone Formation and Penarth Group, in particular, would have great potential for geological and palaeobiological research and fossil discoveries. Overlying Jurassic strata (Saltford Shale, Rugby Limestone and Charmouth Mudstone) are poorly exposed but richly fossiliferous, as evidenced by former local quarries and pits (including local cement quarries) and specimens in existing museum collections. New exposures generated by the HS2 scheme would have great potential for palaeontological discoveries, with a bearing on Early Jurassic palaeoecology and biostratigraphy. Overlying Quaternary deposits (chiefly alluvium) have considerable potential for palaeoecological studies and palaeoenvironmental reconstruction.

CFA 17: Offchurch and This area includes geologically significant outcrops of Mercia Cubbington Mudstone including the Arden Sandstone and Blue Anchor formations; currently very poorly exposed in the area. Exposures within these strata generated by the HS2 scheme would have the potential to contribute significantly to knowledge of Late Triassic palaeoenvironments, palaeoclimates and events, with potential for significant palaeobiological (notably micropalaeontological and ichnological) discoveries. Overlying Quaternary (fluvial and glacial) deposits are similarly poorly exposed and have great potential for adding to our knowledge of local environments, climates and ecology over the last million years.

CFA 18: Stoneleigh, This area includes geologically significant outcrops of latest Kenilworth, Burton Carboniferous up to mid-Triassic sediments, preserved on the Green southern part of the Warwickshire Coalfield and currently very poorly exposed. Exposures within these strata generated by the HS2 scheme would have the potential to contribute significantly to knowledge of Late Palaeozoic – Early Mesozoic continental environments, climates and ecology, at a time when central England was dominated by hot, arid, desert-like conditions. Overlying fluvial and glacial deposits are similarly poorly exposed and have great potential for adding to our knowledge of local palaeoenvironments, palaeoclimates and palaeoecology over the last million years. Exposures within overlying river terrace deposits and alluvium would have considerable potential for geological and palaeontological discoveries.

CFA 19: Coleshill The local Mercia Mudstone bedrock is very poorly exposed. Junction The proposed HS2 scheme could generate significant exposures of these rocks in a fresh state. Field investigations and sampling would potentially yield data of significance for reconstructing late Triassic desert palaeoenvironments and climates. Similarly, the overlying glaciofluvial and glaciolacustrine deposits are poorly documented. Fresh excavations within these unconsolidated deposits could prove important for investigations into Quaternary palaeoenvironments.

CFA 20: Curdworth to As in other CFAs, the local Mercia Mudstone bedrock is very Middleton poorly exposed. The proposed scheme could generate significant exposures of these rocks in a fresh state. Investigations – including field documentation and sampling - would potentially yield important data with a bearing on late Triassic desert palaeoenvironments and climatic reconstruction. Local unconsolidated glacial, river terrace and alluvial deposits are of high potential significance for palaeoecology and palaeoenvieronmental reconstruction.

Without this assessment the council has serious concerns that the ES has not appropriately assess the potential impact of the Proposed Scheme and therefore is the Precautionary Principle (Approach) has not been followed to an appropriate standard that leaves the ES unsound and is therefore, misleading to a decision maker.

8.9.1 – 8.9.2 Sound, The assessment of sound, noise and vibration considers the noise and vibration – likely significant noise and vibration effects arising from the Scope construction and operation of the Proposed Scheme on: (8.9.2) people, primarily where they live ('residential receptors') in terms of a) on an individual dwelling basis and b) on a community basis, including any shared community open areas; and

 community facilities such as schools, hospitals, places of worship, and also commercial properties such as offices and hotels, collectively described as 'non- residential receptors' and 'quiet areas'.

The council is concerned that the’ community facilities ’listed does not include recreational areas e.g. accessible woodland or tranquil landscape. This is a community impact and may render these accessible areas ‘inaccessible’ e.g. The Fox Covert bird reserve (Ladbroke) will be impacted upon by noise and unwelcoming to visitors. These impacts have not be considered and therefore, the Precautionary Principle (Approach) has not been followed to an appropriate standard that leaves the ES unsound and is therefore, misleading to a decision maker.

The council is also concerned that the noise and vibration impacts on wildlife has not been assessed following accepted scientific research such as ‘flight and return’ assessments (EN Research Reports), have not been used to gauge the impact on more sensitive birds and their breeding successes. As these impacts have not be considered and therefore, the Precautionary Principle (Approach) has not been followed to an appropriate standard that leaves the ES unsound and is therefore, misleading to a decision maker.

8.12.17 Water The estimated zone of influence, and therefore the resources and flood risk assessment of the potential impact of dewatering on - Assumptions and receptors, is therefore based on a worst-case assessment limitations using available literature, values of hydraulic parameters and geological cross sections. Hydraulic conductivity values, obtained from available literature values, were used in conjunction with professional judgment to estimate the maximum extent of the zone of influence that is likely to be produced when dewatering of a cutting occurs. The hydraulic conductivity values used are generally in the high range of literature values to provide a realistic factor of safety to the estimated zone of influence.

The council is concerned that this approach has not been taken forward to assess the impacts on ecological receptors adjacent and further away from the Proposed Project. Through applying ‘professional judgement’ on a ‘worst-case assessment’ this indirect impact should be incorporated into the impact assessment for the ecological receptors and noted within the Biodiversity Assessments. This would then indicate to the decision maker a true impact assessment of the scheme. Without this assessment the Precautionary Principle (Approach) has not been followed to an appropriate standard that leaves the ES unsound and is therefore, misleading to a decision maker.

9.3.1 Restitution of Where there will be a temporary but significant effect on a open space and community resulting from the temporary loss of public open community facilities space or a community facility, mitigation is likely to take

one of the following forms:

a) improvements or alterations to the remaining portion of the public open space (in instances where the public open space is partially occupied) or community facilities, e.g. reconfiguring pitch layouts or relocating play areas; b) improvements to other public open spaces or community facilities in the area; c) improving accessibility to other existing public open space or community facilities; d) identifying land owned by the relevant local authority that could be brought into use as public open space or used to accommodate community facilities with its agreement; and/or e) where land used as open space or as a community facility is temporarily occupied by the Proposed Scheme, there will be a statutory requirement for the land to be restored in agreement with the relevant local authority The council is concerned that an accurate assessment of accessible natural greenspace has not been carried out and therefore insufficient mitigation has been incorporated into the scheme.

9.3.2 Where there is a permanent and significant community effect resulting from the permanent loss of public open space or a community facility, mitigation is likely to take one of the following forms:

a) improvements or alterations to the remaining portion of the public open space (in instances where the public open space is partially occupied) or community facility, e.g. reconfiguring pitch layouts or relocating play areas; b) provision of compensatory open space or community facilities as part of the design of the permanent works within the hybrid Bill limits; c) improvements to other public open spaces or community facilities in the area; and d) improving accessibility to other existing public open space or community facilities; e) identifying land owned by the relevant local authority that could be brought into use as public open space or used to accommodate community facilities with its agreement. The council is concerned that an accurate assessment of accessible natural greenspace has not been carried out and therefore insufficient mitigation has been incorporated into the scheme.

9.4.3 Agriculture, Land restoration will be followed by an aftercare period during forestry and soils - which the land will be managed to achieve the appropriate level of agricultural productivity.

The council is concerned with the lack of detail relating to the ‘appropriate level of agricultural productivity’. There is no temporal factor as to when the after period commences from i.e. 2017 (start date) or 2026 (operational start date); there is no target condition assessments from the current baseline or what the ‘appropriate level of agricultural productivity’ would have been in 2026 should the scheme not have commenced and if this has been taken into consideration. This evaluation will have a significant economically impact on the landowner and future land values. The council is concerned that this has not been accurately depicted in the ES and therefore the ES is unsound and is misleading to a decision maker.

9.4.5 The Proposed Scheme will inevitably sever some accesses within agricultural holdings and create new field layouts that will require new accesses. The scheme drawings included in the ES show the new accesses under or over the railway that are proposed to mitigate this impact. Where necessary, these accesses will be built as early as reasonably practicable, so that they can be used during construction. In addition, the contractor will be required to consult with the affected farmers to agree the phasing of the works so as to reduce severance. Where appropriate access arrangements cannot be provided during construction, the severed land will be acquired, subject to agreement between the appropriate parties.

The council is concerned that this land will not be shown within the land required for construction and should be seen as additional ecological impact (loss) following the precautionary (worst case) scenario. As a result the Precautionary Principle (Approach) has not been followed to an appropriate standard that leaves the ES unsound and is therefore, misleading to a decision maker.

9.6.2 Climate - Climate The HS2 Sustainability Policy defines that the approach is to change adaptation and “build a network which is resilient for the long-term and seek resilience to minimise the combined effect of the project and climate change on the environment”.

By 2026 it is anticipated that significant landscape enhancement will have taken place to enhance and link woodland, wetland and grassland core areas to enable species to migrate through the sub-region. The council has partnered with the University of York to model the sub-region to inform where best to direct enhancements to achieve the Warwickshire Coventry and Solihull Green Infrastructure (WCS GI) Strategy objectives.

HS2 Ltd has not taken advantage of this study to establish a future operational baseline. As a result the Precautionary Principle (Approach) has not been followed to an appropriate standard that leaves the ES unsound and is therefore, misleading to a decision maker. Despite HS2 Ltd.’s commitments to Green Infrastructure, Connectivity and Landscape Functionality (Volume 1: paragraph 9.6.4), the ES has not encompassed the WCS GI strategy to place connective features such as green bridges, underpasses, culverts, ‘hop-overs’ (Volume 5: Technical Appendices (CT- 001-00/2, paragraph 4.6.2) in the ideal places. The council offered this assistance in January 2013. Without this interpretation of data the ES is not scientifically driven and is, therefore not in accordance with the Precautionary Principal and IEEM EcIA. If HS2 is constructed as detailed in the ES it will cause unacceptable fragmentation that will need to be rectified by current and future generations.

9.6.4 Where possible, each topic area has identified appropriate mitigation based on the potential impacts of the Proposed Scheme in combination with a changing climate. This

includes:

a) a green infrastructure approach to address the landscape and visual assessment effects associated with the Proposed Scheme. This approach will result in a multifunctional b) landscape that will contribute to reduced vulnerability and increased resilience to climate change; c) the creation of 'stepping stones', buffer areas and transitional habitats around existing habitat to increase landscape connectivity and to provide wildlife with the d) opportunity for autonomous adaptation (e.g. allowing for changes in species distribution as average temperatures increase); and e) measures to ensure that there will be no increased risk of flooding and embankment/cutting erosion by creating suitable landforms/gradients, designing drainage and creating replacement storage areas for the one in 100 year annual rainfall probability event, with an allowance for climate change.

In December 2013 the WCS GI Strategy was launched and adopted by all Local Authorities and the sub-regional Local Nature Partnership. This strategy detailed how the sub-region has identified and subsequently will protect, restore and enhance its Landscape, Accessibility and Biodiversity assets. This strategy was made know to HS2 Ltd. Ecologically, The WCS GI Strategy contains mechanisms of delivery including agri-environment schemes, Biodiversity Offsetting and grant schemes. Two current HLF grant schemes include Tame Valley and Princethorpe Woods managed by Warwickshire Wildlife Trust; both will be impacted by the Proposed Scheme either directly or indirectly. By 2026 it is anticipated that significant landscape enhancement will have taken place to enhance and link woodland, wetland and grassland core areas to enable species to migrate through the sub-region. The council has partnered with the University of York to model the sub-region to inform where best to direct enhancements to achieve the WCS GI Strategic objectives. HS2 Ltd has not taken advantage of this study to establish a future operational baseline.

Despite HS2 Ltd.’s commitments to Green Infrastructure, Connectivity and Landscape Functionality (Volume 1: paragraph 9.6.4), the ES has not encompassed the WCS GI strategy to place connective features such as green bridges, underpasses, culverts, ‘hop-overs’ (Volume 5: Technical Appendices (CT-001-00/2, paragraph 4.6.2) in the ideal places. The council offered this assistance in January 2013. Without this interpretation of data the ES is not scientifically driven and is, therefore not in accordance with the Precautionary Principal and IEEM EcIA. If HS2 is constructed as detailed in the ES it will cause unacceptable fragmentation that will need to be rectified by current and future generations.

It is therefore clear that in 2026 there will have been significant changes to the management in Warwickshire that will affect the operational baseline and that the Proposed Scheme will result in an unacceptable fragmentation of the ecological landscape to the detriment of European Protected species and other nationally and locally important species and habitats.

9.7.6 Cultural Heritage The nominated undertaker will record, analyse, report and publish the results of all archaeological and built heritage investigations, and will archive the resulting records, artefacts and materials in suitable repositories.

The council is concerned that the depositing of the records, artefacts and materials will cause an unprecedented burden on the ‘suitable repositories’. This burden will be in perpetuity. This burden has not been considered within the ES.

9.8.1 Ecology Where mitigation and/or compensation is required, then these areas are included within the identified extent of the Proposed Scheme. This includes provision of areas to act as receptor sites for habitats and species which will be translocated prior to construction and thus require land that will not be subject to any construction works, and of areas where habitats of ecological value will be created following the completion of construction.

The council leads one of the Defra Biodiversity Offsetting pilots and has developed a Defra approved system to apply the national metrics to calculate biodiversity impacts. The Proposed Scheme has been entered into this system using the parameters outlined in the Volume 5: Technical Appendices Scope and methodology report addendum (Volume 5: Technical appendices (CT-001-000/2)). The council has applied a reasonable, pragmatic approach following the Precautionary Principle and the preliminary assessment suggests that the habitat value under the Proposed Scheme footprint is 5484.38 Biodiversity Units (BUs). When the construction mitigation and compensation has been taken into consideration there is a residual loss of 1780.98 BUs. To adequately compensate for the biodiversity impact of the Proposed Scheme on a Precautionary and worst case scenario a further 1389.5ha would be required. The council has also calculated that 70.38km of hedgerow will be lost with 59.4km being created; inferring a residual loss of 10.98km. According to the council’s metric between 26.4 and 79.2km of native species rich intact hedgerow with trees will be required to offset this loss.

The council clearly demonstrates that the Proposed Scheme will result in a Net Biodiversity Loss that will require a significant offset, which has not been depicted in the ES and therefore the ES is unsound and misleading to a decision maker.

9.8.4 Where SSSI will be affected mitigation and compensation provision for these sites is provided following discussion with Natural England. Prior to second reading HS2 Ltd will seek to obtain confirmation from Natural England that all effects on SSSIs have been adequately mitigated or compensated.

The council is concerned and disappointed that local stakeholders and land-owners / managers will not be involved in the SSSI discussions and therefore only the scientific interests of the SSSIs will be considered and not the sites regional and local important factors.

9.8.5 Mitigation and/or compensation requirements for non- statutory sites and other notable habitats have been developed and are described within the ES.

The council believes that the ES significantly undervalues non-statutory sites both in terms of their intrinsic value and the role they play in a functional landscape. These roles have not been made clear in the ES and therefore the ES is unsound and misleading to a decision maker.

9.8.6 The Proposed Scheme will seek to achieve a no net loss in biodiversity at a route-wide level as far as reasonably practicable. Habitat losses and gains will be measured using a modified version of the Defra biodiversity offsetting metric, which has been developed in consultation with Defra and Natural England.

The council continues to be concerned that the term ‘no net loss in biodiversity’ is used and then caveated with ‘as far as reasonably practical’. This objective is clearly not consistent with EU policies and UK Government strategies such as the Natural Environment White Paper, NPPF and the guiding principles behind biodiversity offsetting.

9.8.7 The proposed methodology to be used for the offsetting calculation is included as part of the SMR Addendum. Relevant parties will be provided with additional documentation to show the conclusions of the calculation. The calculation offers a framework to ensure that compensatory provision is suitably adjusted if any changes to design occur. The methodology considers changes in the type, extent and condition of habitats. In addition it considers the value of both existing and created habitats in relation to ecological networks. In doing so it has sought to promote mitigation provision that adheres to the Lawton report principles of 'bigger, better, more joined up' and that will increase robustness to the effects of climate change through promoting movement of species through the landscape.

The council applauds this approach however it has not been applied appropriately otherwise it would be clear that the Proposed Scheme will result in a significant biodiversity loss. The council suggests that for this reason the Biodiversity Offsetting report has not been consulted upon as part of the ES. It would appear that the council must assume that the offsetting strategy will defines where offsetting will be placed to adheres to the Lawton report principles of 'bigger, better, more joined up' that promotes ‘movement of species through the landscape’ and that this will include clear evidence as to where and how mitigation features along and further away from the route will be placed. The council has applied connectivity modelling in Warwickshire and has clear evidence that the proposed ecological mitigation features (Volume 1: 9.2.1) will not achieve the outcomes of the ES. This evidence clearly shows that the scheme as proposed in the ES will cause unacceptable fragmentation of the ecological landscape.

The council believes that without the opportunity to scrutinise the data and methodology associated with this offsetting calculations it and other decision makers cannot determine the ecological impact of the Proposed Scheme. Therefore, without this information the ES is unsound.

9.8.9 Mitigation and compensation to address effects on legally protected species will, where appropriate, include translocation or relocation of species, the provision of replacement habitat and provision of special measures such as underpasses, green tunnels and green bridges to facilitate the movement of species across the route.

The council believes that as only a third of the HS2 route has been surveyed and the WBRC data has not been used plus predictive mapping not applied the is no confidence in this statement. The finding is therefore speculative and as such the Precautionary Principle (Approach) has not been followed to an appropriate standard that leaves the ES unsound and is misleading to a decision maker.

9.8.10 Mitigation and/or compensation may be required as a result of impacts on protected species that may occur within areas where there has been no or limited access available for field surveys. Since a reasonable worst-case approach has been adopted in the assessment it is considered that any necessary mitigation and/or compensation can be provided within the ecological compensation areas that are shown in the Volume 2: Map Books CT-06. Mitigation provision within these areas would be undertaken in accordance with the principles of ecological mitigation set out in the SMR Addendum.

The council believes that there is not enough mitigation and/or compensation area available for the impacts on protected species within the ecological compensation areas identified in Volume 2: Map Books CT-06 based on a worst case scenario. Primarily, this is based on the fact that only a third of the HS2 route has been surveyed and the WBRC data has not been used to predict a worst-case scenario. This predictive mapping would be based on scientific evidence of protected species population densities to calculate the maximum area necessary to support the protected species concerned. As no scientific evidence has been cited a decision maker cannot be assured that the statement made by HS2 is correct. Therefore, the finding is speculative and as such the Precautionary Principle (Approach) has not been followed to an appropriate standard rendering the ES unsound and misleading to a decision maker.

9.8.11 As the scheme is yet to undergo detailed design, and there remains uncertainty over some elements of the baseline, mitigation and compensation provision for protected species within the ecological compensation areas will be secured through commitment to providing mitigation and compensation in accordance with the principles of ecological mitigation included as part of the SMR Addendum. This document describes the generalised approach to mitigation and compensation that will be implemented.

The council believes that this statement is a clear evidence and admission to the council’s conclusions to paragraph 9.8.10 above.

9.9.6 Land Quality There are few instances along the Proposed Scheme where geo-conservation resources are affected. In one location, where a local geological site is located just outside the construction area, provision will be made to ensure its protection during the construction period.

9.10.5 Mitigation will also seek to reduce the effects of construction; for example, through advance planting, temporary screening or earthworks. Where appropriate, temporary or permanent mitigation will be installed at the earliest opportunity. Planting away from the route will also be established to reduce adverse landscape and visual effects.

The council suggests that advanced planting to screen construction will need to be well in advance of the start of the construction period to enable it to reach maturity and be functional. Clearly, this is a contradiction to paragraph 8.5.11 that states that impacts will on the assumption that “all construction activity will occur concurrently across the entire length of the Proposed Scheme and will start at the beginning of the construction period. This represents a worst-case scenario”.

9.10.6 The nominated undertaker will maintain landscaped areas within the rail corridor to an appropriate horticultural standard, and will ensure that the maintenance of other landscaped areas is secured through agreement. The aim is to ensure that the planting scheme successfully establishes and develops, so that it achieves its mitigation objective and remains effective thereafter in perpetuity.

The council acknowledges the concept that mitigation will be for perpetuity yet cannot find this assurance in the bill once the Proposed Scheme becomes operational. These ongoing responsibilities will not be a matter of the ‘nominated undertaker’ and therefore the council would like to know how this statement will be made resolute so that landscaping and other mitigation works will be managed in perpetuity. Without this reassurance this statement is purely speculative and therefore misleading to a decision maker.

9.10.7 Areas of mitigation provided outside the rail corridor will, where reasonably practicable, be transferred to third parties, subject to agreements to ensure that the necessary management objectives are met.

The council suggests that the uncertainty of ‘where reasonably practicable’ does not give the necessary assurances to the decision maker to enable it to discharge its EU and UK duties regarding no net biodiversity loss. If this statement is to persist then additional compensation habitat will need to be provided to allow for future land-use changes that reduces the compensatory habitat. This additional habitat will ‘future proof’ such an eventuality. There is a potential that this can be evaluated within the Biodiversity Offsetting model as an ‘insurance’ multiplier (Defra 2012), however, the council has not had the opportunity to see this documentation and therefore this statement is speculative and as such the Precautionary Principle (Approach) has not been followed to an appropriate standard rendering the ES unsound and misleading to a decision maker.

Landscape maintenance will incorporate a risk assessment for vegetation in landscape areas. Visual inspections of mitigation planting (and/or existing planting in the vicinity of the Proposed Scheme) will be carried out on a regular basis to determine whether it poses a risk to the safe operation of the railway. Maintenance operations will ensure that trees within all operational land (and adjoining land if applicable) cannot fall onto the track, overhead lines or other line-side equipment.

The council continues to ask for clarification on maintenance procedures to understand how vegetation within all operational land and adjoining land will be managed. This clarification will enable any indirect impacts on biodiversity and landscape to be evaluated. Without this information the evaluation the ES is rendered unsound and misleading to a decision maker.

9.12.14 Noise and Tunnel portals will be designed to avoid any significant Vibration airborne noise effects caused by the trains entering the tunnel.

The council is aware of research that models these effects on other solid structure and high speed trains (Ogawa and Nishida, circa.2002). These effects being multiplied when trains pass each other. The council cannot find any reference to this phenomenon within the ES and therefore suggests that mitigation is potential flawed for certain nationally important protected species. To this effect the council believes that the impacts of the Proposed Scheme have not been appropriately evaluated and rendered the ES unsound and misleading to a decision maker.

9.12.19 Ground-borne Significant ground-borne noise or vibration effects will be noise and vibration avoided or reduced through the design and maintenance of the track and track-bed.

The council is aware of research that models these effects on ballast and high speed trains (Quinn et al, 2009). The council cannot find any reference to this phenomenon within the ES and therefore suggests that mitigation is potential flawed for certain nationally important protected species. To this effect the council believes that the impacts of the Proposed Scheme have not been appropriately evaluated and rendered the ES unsound and misleading to a decision maker.

9.14.7 Waste and Sites for sustainable placement have been selected on the mineral resources basis of their suitability for the disposal of surplus excavated material.

10.3.12 Strategic and The Proposed Scheme has been designed for a maximum route-wide alternatives - speed of 360kph, but with a capability to allow the operating Higher design speed speeds to increase to 400kph as high speed technology develops. Maximum speeds are lower where this is impractical, such as in tunnels and at junctions. As a desk exercise, HS2 Ltd explored the options of a higher design speed. It concluded that a higher speed would save little time because of the distance taken to accelerate between stations and the effect of features that permanently restrict speed. It concluded that 400kph represents a reasonable maximum design speed, given likely technology development over the coming decades.

The council recognises that the project is designed for speed to 400kph, however, it is concerned that these speed have not been carried forward between all disciplines and impacts modelled using this upper limit. The council particularly refers to its comments within paragraphs 9.12.14 and 9.12.19 above.

10.4.62 HS1 – HS2 link Following consideration of the issues and options the – Alternative alignments Government remains convinced of the strategic importance of a link between HS2 and HS1 and is committed to providing it in the Phase One scheme. It has also concluded that the Proposed Scheme is preferable to the alternatives, because it would require demolition of fewer residential properties and no loss of public open space as well as other environmental advantages.

The council notes that the Government is committed to a direct link between HS1 and HS2 and suggests that the Proposed Scheme there remains a trans-national proposal. HS2 has downplayed the international importance since the publication of the Draft ES. The council suggests that this is due to an EU member states requirement with EU EIA regulations to consult EU partners on trans-national project. The council is not aware that any trans-national consultation has taken place. The council would like to understand why HS2 Ltd suggests that the scheme in now not a trans-national project.

66 k) Water Resource & Flood Risk Document: Volume 1 Introduction to the environmental Statement and the Proposed scheme

Volume, page WCC previous comment Full ES comment and paragraph on Daft ES reference

V1, ‘We have also identified an During a short-notice site visit on opportunity for flood 17th July 2013 during which we Page 9, alleviation on the Lot Brook asked HS2 to consider, amongst paragraph 1.5.4 upstream of Ladbroke (at other things, betterment for the 443064, 258562). The flood-prone village of Ladbroke. village downstream of this This would involve minimal point is prone to flooding additional modelling, and could from the Lot Brook have the advantage of providing catchment and particular flood relief to the village of care will need to be taken Ladbroke while reducing that HS2 does not construction costs for HS2 and exacerbate this through new reducing the environmental impact drainage arrangements. (due to less material needing to be Furthermore, if drainage to sent off-site). the north-east of the no feedback proposed route could be There has been from stored, throttled, or re- the HS2 team on the suggestions directed with the assistance made by WCC and the EA during of the HS2 embankment, that meeting, in spite of promises that could offer significant from the HS2 team that this would benefits to the community be done, both during the site visit and in writing on 29th July 2013, (approximately half of the th th Lot Brook catchment 20 September 2013, and on 11 upstream of Ladbroke is October 2013, after repeated written requests from the EA on also upstream of the th nd proposed HS2 route).’ 14 August 2013, 2 September 2013, 20th September 2013, 11th October 2013 and 13th October 2013. There is no indication in any of the documentation relating to the Ladbroke section (CFA 16) that flood attenuation upstream of HS2 has ever been considered, or that it will ever be considered in the future.

Failure to consider this contravenes HS2’s stated sustainability policy of ‘contributing to protecting and enhancing our natural, built and historic environment’ (in Volume 1, paragraph 1.5.4). WCC does not find this an acceptable state of affairs.

Volume 2: Community Forum Area reports.

Warwickshire County Council wishes to provide comment on Community Forum Areas (CFA) 16,17,18,19, 20 and 24. To help the reader we have taken each CFA in turn from south to north, submitted comments based on the order of disciplines as they appear in the HS2 documentation. The exception to this is where there are health related concerns that cross technical areas. HS2 has not in the council’s opinion reasonably assessed the impact of its development of the health and welfare of the community. Therefore we have located these comments in the section HS2 have called “community.”

Volume 2 general comments and concerns:

Health: It is evident from the Community Forum Documents that little regard has been paid to the comments submitted by Public Health Warwickshire during the Draft ES consultation, it appears very few amendments have been incorporated by HS2 Ltd.

Public Health Warwickshire wishes HS2 to be aware of the following statement in conjunction with the previous observations and amendments made in the July 2013 submission.

“There is insufficient detail provided in HIA document or the new versions of the CFA reports to reduce or remove the concerns and deficiencies previously identified in the Draft ES.

There is no evidence to suggest the original mitigation comments have been considered, therefore HS2 MUST refer to original comments in the WCC comment/observations on the Draft ES Consultation. The avoidance of directly addressing these issues is negligent to the local population of Warwickshire and considered unacceptable by Public Health Warwickshire.”

For reference, the following web link will provide the reader/ assessor with the council’s previous commentary on the Draft ES: https://democratic.warwickshire.gov.uk/cmis5/CalendarofMeetings/tabid/128/ctl/ViewMeetingPublic/mid/645/Meeting/2671/Com mittee/468/Default.aspx

For those readers not able to access the internet, a hard copy of the July 2013 Cabinet document can be inspected at the reception of Shire Hall in Warwick. Alternatively a copy can be sent direct to you for a small administration fee. If this is the case please contact Janet Purcell on 01926 413716 for details.

PROW Volume 2 forum wide issues Document: All CFA reports 16,17,18,19 &20

Community In some map books temporary PROW diversions/alignments are areas – general indicated and in others they are not. It is unclear whether this is due to there being no temporary diversions, whether this is an oversight or whether the diversions are still to be determined. It would be helpful if clarity could be given. An example would be Stoneleigh, Kenilworth and Burton Green CT-05-095 and 2.3.37 where a temporary diversion for Public Footpath K29 is mentioned as being along Dalehouse Lane for 1 year and 4 months but there is no indication on the plan where this diversion starts and ends or even whether it is applicable on both sides of the HS2 line. Community A definition is provided of Temporary PROW areas – map diversion/alignments. HS2 uses terminology that is not books in consistent with the accepted PROW terminology and therefore general the mere use of some words deliberately creates confusion to the lay reader. It would be helpful if the definition could be firmer. It is unclear at what stage the diversions/alignments will become fixed and there it makes management difficult. It would also be helpful for the terminology to be consistent with PROW terminology which is now generally understood. This will stop the mis-understandings which will inevitably result. General Where diversions/re-alignments of PROW take place and cross ditches/rivers etc. either new or existing, there is a need to clarify who takes on maintenance liability for any new structures necessary and will HS2 be providing these structures to make routes usable. Will gates etc. be provided at hedge boundaries and who takes on the maintenance liability for these. Any structures must comply with the BS in existence at the time and with the Rights of Way Strategy.

CFA 16: Ladbroke & Southam

The council’s comments are addressed in the order they appear in the document and sub divided by topic to aid the reader’s understanding. Where the council has not provided comment, this should not be taken as agreement or consent for the text. The order of comments are:

5.2.3 The council disagrees with HS2’s assessment for Southam, this town is more important for commerce, social activities, social cohesion and access to local services that HS2’s assessment suggests. Therefore the mitigation proposal is deemed to be inadequate. 5.3.5 The council welcomes the identification of Wormleighton but is appalled that the community of Priors Hardwick appears to have been omitted. 5.3.10 The decision not to assess Southam is unacceptable, the impact of HS2 will be felt in the town even though the route of the rail line is on the edge of the town. This is another example of HS2 assessing each issue in series and failing to understand the cumulative effect of HS2 on the community. 5.4.14 The Dallas Burston polo ground is listed as being moderately affected but fails to appear on the GIS data outlining affected sites. This is an oversight that needs to be corrected. The report makes no reference to any other community asset in the Southam area- it is the council’s view that to list a commercial operation as a community asset is both incorrect and misleading.

5.4.24 The council disagrees with the assessment that Ufton will not be affected by the construction of HS2. The use of the A425 will increase traffic in this area and present additional nuisance to the community. This has not in the council’s view been correctly addressed at this stage and must be attended to is further confrontation with community is to be avoided.

The table below summarises Public Health Warwickshire’s comments and observations with respect to the CFA documents:

Document: Volume 2: Community Forum Area Report. CFA 16: Ladbroke and Southam. ES 3.2.1.16 Draft ES document WCC HS2 Public Health reference comment/observation on Mitigation Warwickshire Draft ES Consultation ES additional amendments comments on final ES

2.1.9 page 13 Further information is Insufficient detail There are a number needed regarding the provided in HIA. No of circular walking health and social impact on evidence to suggest routes around the the local communities on our original mitigation town of Southam, the any changes to these key comments have been most notable of which recreational walking routes, considered, therefore is the Harry Green pathways and open spaces, HS2 MUST refer to Way which extends either during construction or original comments for 34km and long term. This is under WCC connects eight particularly important comment/observation villages around the regarding the Harry Green on Draft ES town, including Way which connects eight Consultation (first Ladbroke, Ufton and villages supporting column). The Bascote Heath. community cohesion and avoidance of directly reducing social isolation. addressing these 2.1.16 page 14 issues is negligent to There are a number It is recommended that a the local population of of parks and open health impact assessment Warwickshire. spaces within the is conducted including the centre of Southam. impact on physical activity Elsewhere in the levels, weight, study area there is cardiovascular and relatively little public respiratory conditions and open space, mostly mental health and limited to small wellbeing. Pre-exiting amenity green spaces conditions such as in the villages or cardiovascular, arthritis, church yards. respiratory and back pain could be exacerbated 2.1.17 page 14 leading to increased use of There is a public health services if negative footpath that runs changes are made to the along the edge of the local walking routes. Ufton Wood (also forming part of the Harry Green Way)

which features in a number of local walking guides for the area. The Ufton Fields Nature Reserve (map CT-01- 44, I1 and J1) lies just south of Ufton village. The reserve, which extends to about 40ha in total, includes a number of waymarked footpaths providing access to varied habitats for observing birds, insects and wild flowers.

5.4.8 page 48 There are a number of circular walking routes around the town of Southam, the most notable of which is the Harry Green Way, which extends for 34km and connects eight villages around the town, including Ladbroke, Ufton and the Bascote Heath. The Proposed Scheme crosses the route of the Harry Green Way at Windmill Hill, Ladbroke and the footpath also passes through an area which is proposed for ecological mitigation at Bascote.

5.4.9 page 48 The Ufton Fields Nature Reserve (map CT-03-44, I1 and J1) lies just south of Ufton village. The reserve, which extends to about 40ha in total, includes a number of waymarked footpaths,

providing access to varied habitats for observing birds, insects and wild flowers.

5.4.10 page 48 In the study area, the Proposed Scheme crosses a number of public footpaths and bridleways, including the towpath for the Oxford Canal and the Harry Green Way public footpath, both of which are key promoted recreational routes in the area

2.3.15 page 21 While it is positive that light Insufficient detail The design of lighting pollution has been provided in HIA. No for site compounds recognised, sleep evidence to suggest during hours of disturbance can have an our original mitigation darkness would seek adverse effect on health comments have been to reduce light and so we would considered, therefore pollution to the recommend that light HS2 MUST refer to surrounding area as pollution be kept to original comments far as reasonably recommended standards under WCC practicable. rather than sought to. Local comment/observation policy PR8 does not permit on Draft ES development that would Consultation (first give rise to light pollution. column). The avoidance of directly addressing these issues is negligent to the local population of Warwickshire.

3.4.11 page 38 While it is positive to see Insufficient detail The whole area is a that measures have been provided in HIA. No Nitrate Vulnerable introduced to reduce evidence to suggest Zone where nitrate nitrogen losses from our original mitigation pollution is a potential agricultural sources to comments have been problem and water, further detail is considered, therefore measures have been required as to what these HS2 MUST refer to introduced to reduce measures are. As the area original comments nitrogen losses from is a Nitrate Vulnerable Zone under WCC agricultural sources to and is dominated by arable comment/observation water. food crops, we would on Draft ES recommend that measures Consultation (first taken prevent nitrogen column). The losses as far as possible avoidance of directly rather than only reduce it. addressing these issues is negligent to the local population of Warwickshire.

4.2.2 page 43 It is unclear how the HS2 Insufficient detail Stratford-on-Avon project is going to support provided in HIA. No District Local Plan the local policy, particularly evidence to suggest Review provide the PR8 regarding pollution. our original mitigation policies that are Further information is comments have been applicable in the required to demonstrate considered, therefore borough. The how the construction of the HS2 MUST refer to principal Local Plan Proposed Scheme will not original comments policy of relevance to adversely impact pollution under WCC air quality is Policy or soil contamination in the comment/observation PR.8: Pollution. This area. on Draft ES policy does not permit Consultation (first development that The health implications column). The would give rise to air, from pollution have not avoidance of directly noise, light or water been addressed in this addressing these pollution, or soil document and it is issues is negligent to contamination where recommended that a health the local population of the levels of impact assessment be Warwickshire. discharges or completed with regards to emissions are pollution and health. sufficiently significant to cause harm to other land uses, health or the natural environment. General policies relating to nature conservation also refer to the need to avoid development that could harm their quality.

8.2.3 page 67 The adopted Local Plan includes a policy

(PR8) on pollution control that does not permit development that could give rise to pollution, including soil contamination.

13.2.2 page 98 Policy PR.8 (Pollution Control) does not permit development that would give rise to pollution.

4.4.7 page 44 Air pollution, particularly 8.4.1: the Insufficient detail Several locations dust from construction, management provided in HIA. No have been identified could exacerbate existing of human evidence to suggest in the study area, respiratory or exposure for our original mitigation which are considered cardiovascular conditions both comments have been to be susceptible to leading to an increase in construction considered, therefore changes in air quality GP and acute hospital use. workers and HS2 MUST refer to and are in close A health impact people living original comments proximity to roads that assessment of the workers and working under WCC would be subject to on site and their living nearby (draft comment/observation realignments or used accommodation, as well as CoCP, on Draft ES by construction traffic. of the local community and Section 11 Consultation (first affected properties is column). The recommended. Continuous avoidance of directly monitoring of pollution addressing these levels at the site during issues is negligent to construction is also the local population of recommended, with the Warwickshire. implementation of further measures to mitigate any pollution exceeding minimum permitted levels.

4.5.1 page 45 It is positive that the impact 3.4.4: the Impacts from the from dust from construction adoption of construction of the has been assessed, measures to Proposed Scheme however it is unclear control the could arise from dust whether this assessment deposition of generating activities included an impact on the dust on and emissions from health of the local adjacent construction traffic. As community. If it didn’t then a agricultural such, the assessment health impact assessment is crops (draft of construction recommended as dust CoCP, impacts has been pollution can affect health. Section 7); undertaken for human receptors sensitive to 4.2.2: The dust and exposure to assessment NO2 and PM10, as has assumed well as ecological that the receptors sensitive to general dust and nitrogen measures deposition. detailed in Section 7 of 4.5.5 page 45 the The construction dust draft CoCP assessment (Volume 5: determined that of the Appendix seven locations CT-003-000) identified in the study will be area, which are implemented. considered to be These susceptible to include: changes and where  contractors residential properties being are present…be slight required to adverse due to the manage presence of dust, air residential properties pollution, within 20 metres of odour and the dust generating exhaust construction activities. emissions during construction works;  inspection and visual monitoring after engagemen t with the local authorities to assess the effectivenes s of the measures taken to

control dust and air pollutant emissions  cleaning (including watering) of haul routes and designated vehicle waiting areas to suppress dust;  using enclosures to contain dust emitted from construction activities; and

5.2.3 page 47 It is unclear how the HS2 Insufficient detail Other key policy project is going to support provided in HIA. No themes in the Local the local policy, particularly evidence to suggest Plan relate to: The Policy COM.9 regarding our original mitigation section of an area of walking and cycling routes comments have been countryside on the and CS13 regarding considered, therefore western side of accessible green networks. HS2 MUST refer to Southam along the Green spaces and an original comments River Stowe for its accessible outdoor under WCC open space value environment is important for comment/observation (Policy SOU.A); and health and wellbeing, on Draft ES Support for the particularly mental health Consultation (first provision of safe and and physical activity. column). The well-connected Further information is avoidance of directly walking and cycling needed detailing how the addressing these routes (Policy project will support local issues is negligent to COM.9). health policy to provide the local population walking and cycling routes, of Warwickshire. 5.2.4 page 47 and where it doesn’t what Green infrastructure measures will be put into principles that seek place to minimise any the protection, negative effect from the enhancement, Proposed Scheme on the restoration and population’s health. creation of a district- wide accessible green network which, amongst other things, would reinforce the distinctive landscape

and character of the area (Policy CS13),.

5.5.2 page 49 The health impact on these Insufficient detail It is assumed that the residents of the disruption provided in HIA. No occupiers of these due to construction and evidence to suggest properties would need being rehoused need to be our original mitigation to be rehoused explored. A health and comments have been temporarily for the social impact assessment is considered, therefore duration of recommended HS2 MUST refer to construction activities original comments likely to cause noise under WCC and disturbance, but comment/observation could then return to on Draft ES their homes upon Consultation (first completion of the column). The works. avoidance of directly addressing these issues is negligent to the local population of Warwickshire.

5.5.16 page 50 While it is positive that Insufficient detail The incidence of effects on community will be provided in HIA. No significant effects assessed, it is important evidence to suggest including in- that within this assessment our original mitigation combination effects the impacts on health and comments have been on community social aspects are considered, therefore amenity will be assessed. This includes HS2 MUST refer to assessed in the impact on mental health and original comments formal ES. wellbeing, social isolation under WCC and community cohesion. comment/observation 5.5.18 page 50 on Draft ES Multiple (in Consultation (first combination) column). The community effects will avoidance of directly be considered and addressing these where significant issues is negligent to reported in the formal the local population ES. of Warwickshire.

5.6.1 page 51 Within this study area, effects on the community resulting from the operation of the Proposed Scheme could potentially arise from significant changes to amenity.

5.6.2 page 45 While it is positive that Insufficient detail The assessment of impacts from transport, provided in HIA. No effects on amenity will traffic, air quality etc. have evidence to suggest draw upon other been recognised, it is our original mitigation

technical disciplines important that the health comments have been (e.g. air quality, noise effects of the Proposed considered, therefore and vibration, visual, Scheme are also HS2 MUST refer to transport and traffic) considered. A health and original comments findings to inform the social impact assessment is under WCC amenity assessment. recommended. comment/observation The presence of in- on Draft ES combination impacts Consultation (first from these other column). The disciplines could avoidance of directly result in significant addressing these amenity effects on a issues is negligent to number of community the local population facilities and of Warwickshire. resources in the area. This will be reported in the formal ES.

10.5.1 page 85 The assessment states that Insufficient detail No significant direct there will be no effect on provided in HIA. No effects on non- non-agricultural evidence to suggest agricultural employment yet fails to our original mitigation employment have state any effect on comments have been been identified within agricultural employment of considered, therefore this study area. It is which Stratford-on-Avon HS2 MUST refer to estimated that the has a higher than national original comments Proposed Scheme and regional average with under WCC would result in the 10% of businesses in the comment/observation displacement or area being of this business on Draft ES possible loss of type. Examination of any Consultation (first approximately 30 jobs effect from the project on column). The within this study area. agricultural business needs avoidance of directly further exploration. addressing these issues is negligent to The assessment states the local population displacement or possible of Warwickshire. loss of approximately 30 jobs within the study area, but does not take into account the rural nature of the area and difficulty in transport around it. If premises are moved this could lead to further job loss if new sites are inaccessible to staff or customers, leading to a reduced customer base and possibly closure of the business and unemployment if the relocated premises are inappropriate.

The rural nature of the area means that any job loss is

significant as other employment may not be accessible or available depending on the sector. It can lead to mental health issues, debt, increased alcohol consumption and associated ill health.

The cumulative effect over all Warwickshire affected areas from job losses are examined at the end of this response.

11.6.4 page 89 Some residential receptors Insufficient detail Residential receptors have been identified as provided in HIA. No within the daytime having a significant adverse evidence to suggest 65dB contour, and effect from day and night our original mitigation therefore the night- HS2 noise. Although Noise comments have been time 55dB contour, Insulation Regulations and considered, therefore have been identified WHO Night Noise HS2 MUST refer to as being likely to Guidelines are being used, original comments experience a we would recommend that under WCC significant adverse target noise levels be aimed comment/observation effect from HS2 noise below this threshold to on Draft ES alone. This is in line reduce the health and Consultation (first with the daytime wellbeing effects on column). The threshold in the Noise residents in this rural area. avoidance of directly Insulation Regulations addressing these and the Interim Target Measures taken to reduce issues is negligent to defined in the World noise nuisance need to be the local population Health Organization’s detailed with expected of Warwickshire. Night Noise effectiveness data given in Guidelines order to demonstrate they meet the permitted noise levels. We also recommend continued noise monitoring in this area during construction and after the project is complete.

11.6.11 page 90 Although it is stated that the Insufficient detail The envisaged envisaged mitigates will provided in HIA. No mitigation (especially substantially reduce the evidence to suggest landscape earthworks potential airborne sounds, it our original mitigation and noise barriers) is not stated or clear how comments have been described in this reduced the noises will and considered, therefore chapter substantially whether the noise levels will HS2 MUST refer to reduces the potential therefore fall below the original comments airborne sound permitted noise level. under WCC impacts and noise comment/observation effects that would Noise disturbance has on Draft ES otherwise arise from multiple negative effects on Consultation (first the Proposed the health and wellbeing of column). The

Scheme. individuals, particularly avoidance of directly Nonetheless, potential concerning mental health addressing these significant adverse and the effects of sleep issues is negligent to airborne noise effects disturbance. Additional the local population have been identified detail is needed on the of Warwickshire. effectiveness of the envisaged mitigates and what measures are going to be taken to in specific relation to the property identified as SV16-D01 on Maps SV-01 which will experience noise exceeding day and night time targets in order to minimise the health effects. It is recommended that monitoring of noise at this site continue during construction and after completion.

12.4.6 page 93 While a survey has been Insufficient detail All PRoW which completed it is unclear how provided in HIA. No would be intersected the survey was completed.. evidence to suggest by the route have The number of 60 people our original mitigation been surveyed, A per day using the facilities is comments have been total of 23 PRoW not necessarily a small considered, therefore have been identified number as implied, given HS2 MUST refer to consisting of public the rural nature and small original comments footpaths, bridleways populations in the under WCC and cycleways. The surrounding areas. It is comment/observation surveys indicate that recommended that a on Draft ES none of the roads, community consultation and Consultation (first footpaths, bridleways a health impact assessment column). The and cycleways that is completed in order to avoidance of directly would cross the route assess the true impact on addressing these are used by more health, including mental issues is negligent to than 60 people per health and wellbeing and the local population day walking, cycling the impact on community of Warwickshire. or riding. due to the loss of these routes in this rural area. 12.6.2 page 96 PRoW diversions as detailed are not deemed to be significant as the maximum number of people affected is no more than 60 per day per PRoW

82 d) Culture & Heritage Document: Volume 2: Community Forum Area Report. CFA 16: Ladbroke and Southam. ES 3.2.1.16 Volume, page and Full ES comment paragraph reference pg. 77 This paragraphs states that the assessment has considered the 6.2.3 intra-project effects of a number of technical topic assessments such as landscape and visual, ecology and water resources and flood risk and that these interactions have been included in the assessment of impacts and effects.

There is little evidence of this presented in the ES. Whilst landscape and visual assessments have contributed to the assessment of cultural heritage impacts (although this has primarily been in respect of the impacts upon the setting of heritage assets rather than impacts on buried archaeological remains), there is little reference in the cultural heritage chapters and documents to ecology and water resources and flood risk. pg. 78 Not all of the areas identified in the Archaeological Risk Model 6.2.4 as being priority sites for survey in order to inform the EIA were available for survey. This is identified in this paragraph as a limiting factor for the EIA.

Disappointingly, the Archaeological Risk Model referenced in this paragraph has not been reproduced in the ES.

This lack of information about the Archaeological Risk Model significantly limits our ability to critically evaluate the information presented in the ES. For example, we cannot determine how many ‘high risk’ areas were identified, and what proportion of these have been subject to detailed examination to date.

In particular, we cannot assess the degree to which the lack of survey referred to in this paragraph has limited the assessment detailed in the ES. pg. 78 Non-intrusive field survey is limited to two discreet areas 6.2.5 (CN004 Land off Windmill Lane near Ladbroke and CN006 Land off Welsh Road near Ufton) totalling just 11 ha. This represents a very limited sample of the areas to be disturbed by this scheme and does not provide sufficient information to characterise the likely extent and nature of potential sub surface archaeological assets across this CFA. pg. 78 The full extent (including which areas were visited) of the 6.3.2 walkovers and site reconnaissance undertaken to inform this assessment is not set out in the ES, nor the timing or ground conditions at the time of these visits. We cannot therefore assess the adequacy of this aspect of the Environmental Impact Assessment.

pg. 79 As set out in our comments on the Gazetteer of Heritage 6.3.6 Assets (ES 3.5.2.16.5), we disagree with the assessing of several of the heritage assets listed in para. 6.3.6 as being of ‘Low’ significance/value.

For example, there is insufficient information available to enable the significance of Stoneton cropmark enclosure No.1 (LBS003), to be determined at this time (e.g. we do not know its date, character, state of preservation etc.); it may be of significantly higher value than presented in this document. The same issue arises in respect of the Stoneton cropmark No. 2 (LBS009) and Wood Farm cropmark (LBS084). pg. 81 Whilst there are few heritage assets dating to the earlier 6.3.11 prehistoric periods recorded identified across this CFA, this may reflect a lack of previous extensive archaeological investigations across the wider area, along with the likely low level and dispersed character of such remains which would make these difficult to locate, rather than an absence of such features. We would therefore disagree that the potential for prehistoric heritage assets for the study area is low – rather we consider that it is unknown. pg. 90 We do not agree with the statement that ‘there will be no 6.5.2 physical impacts on buried archaeological remains or other heritage assets arising from the operation of the Proposed Scheme’.

There is a potential for vibrations etc. associated with the operation of the railway to have a direct impact upon buried and upstanding heritage assets.

There is insufficient information available at this time to enable any such impacts to be ruled out. pg. 92 Ladbroke Open fields (LBS100) is stated as being of “Low 6.5.3 value”; this is inconsistent with ES 3.5.5.16.5 Gazetteer of Heritage Assets which states the significance/value of this asset is ‘Moderate’. Given the ‘Moderate’ value of this historic landscape and the ‘High Adverse’ impacts during both construction and operation, the effect of the proposal upon this landscape will be greater (‘Major Adverse’) than the ‘Moderate Adverse’ presented in this document.

6, Throughout There is limited consideration throughout this document to the impacts that the proposed development may have upon the historic landscape character of this CFA.

e) Ecology The council has made its views on this section known in the commentary submitted for volume 1, f) Land Quality The council has no comment to make at this time in this section

84 g) Landscape & visual assessment Document: Volume 2: Community Forum Area Report. CFA 16: Ladbroke and Southam. ES 3.2.1.16 Volume, page and Full ES comment paragraph reference Paras 9.4.3 (p.148) & No mention has been made of the maintenance loop near Wormleighton and it is 9.5.2 (p.160) unclear whether the impact of this has been assessed.

Para 9.5.1, p.160 No mention has been made of the loss of ancient woodland from Long Itchington and Ufton Woods. Para 9.5.8 (p.162) No mention has been made as to whether the Proposed Scheme will have an impact on the remnant ridge & furrow in the Radbourne Ironstone Fringe LCA. Para 9.5.8 (p.162) “… partial alteration of Windmill Hill … … partial loss of the key characteristic landform” - this severely understates the effect of the cutting at Windmill Hill which will be major. Para 9.5.123 (p.173) This should say summer year 15, not summer year 1.

h) Socio economic Document: Volume 2: Community Forum Area Report. CFA 16: Ladbroke and Southam. ES 3.2.1.16 10.4.6 The statement that local companies may benefit from local contract is too bland to be meaningful or provide any assurance of local economic benefit. 10.4.12 Cumulative effects. It is the council’s view that the true cumulative effects of traffic congestion, rat running to avoid congestion, increase waiting times and increased pollution have not reasonably been assessed i) Sound, Noise & vibration Document: Volume 2: Community Forum Area Report. CFA 16: Ladbroke and Southam. ES 3.2.1.16 Volume, page and paragraph Comment reference Volume 2. CFA The Council have concerns for the potential for vibration impact 16. Page 190. from the TBM during construction of the Long Itchington Wood 11.4.5 tunnel. A number of individual dwellings are located in the vicinity of the route of the tunnel and the Council seek assurances that advanced structural surveys are carried out in advance of any construction work commencing.

CFA 16. Page The tunnel at Long Itchington Wood tunnel will require 192. 11.5.10 appropriate design of the portals to ensure that noise impact from trains leaving the tunnel is minimised.

CFA 16. Page Commitment to use resilient materials for reducing noise and 193. 11.5.18 vibration impact. Details of the type and how they work needs to be provided to give confidence in their effectiveness.

CFA 16. Page Five dwellings in the vicinity of Starbold Farm and Banbury Road 194. 11.5.24 have been identified as experiencing a moderate to major adverse effect. The council seeks an assurance from HS2 that work will continue in seeking to improve the mitigation measures that reduces the impact on these dwellings. If for engineering reasons this is not achievable the council request that noise insulation is provided.

Previous comment made in the DES: The route passes through the area of Priors Hardwick, known for its tranquillity, the introduction of noise from HS2 will have a damaging effect on the area and the County council seek assurances from HS2 that suitable and effective mitigation will be provided in keeping with the location.

The county maintains the view that the route could introduce an unacceptable level of noise. Mitigation measures proposed do not ensure that this impact is eliminated. j) Traffic, incorporating PROW, Highway design and Traffic Safety Document: Volume 2: Community Forum Area Report. CFA 16: Ladbroke and Southam. ES 3.2.1.16 2.2.4 and 2.2.9 The Green Bridge for SM101 is an additional feature since the draft ES. WCC has had no opportunity to discuss the implications/suitability of such a decision. See comment regarding Green Bridges in the earlier section of general comments. 2.2.6 No mention is made of Radbourne Lane and its re-alignment. General. There is concern about the safety of users of PROW where these cross or are along the same alignment as construction routes (SM101, SM116a, Ridgeway Lane as examples but affects routes across the County). The vehicles using these routes will be large and will leave users of the PROWs particularly vulnerable. The combined use of the routes will discourage users of PROW and for the number of years these routes will be in use will be the effective equivalent of stopping up the routes. A safe, clearly marked alternative or parallel route must be provided to ensure continuity of use and the safety of users.

2.2.11 And CT-05-082 Radbourne Lane. Despite being raised at various meetings with HS2, no provision has been made for that section of Radbourne Lane which runs from the bridleway near Hodnell Manor to Lower Radbourne Farm and then to the junction with SM96 and SM96a. It would be assumed that it continued on its existing route but this does not fit with the HS2 scheme. HS2 must ensure that there is provision for all routes even if not directly crossed by the proposed HS2 route. 2.2.11 And CT-05-082 Radbourne Lane. It is unclear which section (close to its junction with SM96 and SM96a) has actually been re-aligned. One section (shown as an existing PROW) has a junction with a farm road but not with a public highway (this appears to be the current alignment of Radbourne Lane which is an Unclassified County Road and not a PROW). A new section of Radbourne Lane is shown in the same area, and a section which falls outside the HS2 area but is still affected by the proposal is not shown. It would have to cross a new ditch and go through a new hedge – for which no provision has been made. It is still unclear whether SM96/SM96a actually meet Radbourne Lane – the map book does not have the necessary clarity. The whole area is a mess and must be corrected. Currently the proposed solution is completely unacceptable to WCC.

The route as shown in the CA map book is also reflected in the Plans associated with the deposited Bill – Sheet 2-94 of Plans Volume 2.2. This must be corrected as it forms part of the Bill before Parliament and is wrong. CT-06-81 SM96a now runs through a new area of Wetland Habitat creation. This is a change from the Draft ES. No detail is provided as to how wet this would be, the provision for the footpath and the ongoing maintenance liability. HS2 must not expect WCC to take on maintenance liability for a route with such significant surface changes. 2.2.12 and CT-06- Windmill Lane had become a Green Bridge since the Draft ES. 083 SM90 now follows this route of Windmill Lane. There has to be adequate provision for pedestrians once the hedges have grown. See general comment on Green Bridges.

Volume 2 CFA 16 – Ladbroke to Southam - Community Forum Reports (ES 3.2.1.16), Maps (ES3.2.2.16) and related Traffic Assessment ( Vol 5 ES 3.5.0.12.7) Volume, page and Full ES comment paragraph reference CFA 16 - Volume 2 – Map Book (ES3.2.2.16)

CT-06-079b The proposed road realignment crosses the Warwickshire and Northamptonshire General County Boundary and involves a lengthy diversion of some 700m between Wormleighton and Priors Hardwick. The present details take up much of the mature woodland at the Glynn Davies Nature Reserve

The CFA 16 group, farmer/owner of Hill Farm and WCC/NCC consider a second Green bridge is required to minimise the local impact of HS2.

CT-06-079b We suggest the maintenance access to be offset from Claydon Rd so as to avoid Grid Ref: J7 see through effect.

CT-05/06-081-L2 & CFA A temporary access to the main compound off the A423 Banbury Rd is to be 16 Report Section 12.4.9 provided, for the estimated 5yr construction period. Upon completion, this will Table 21 then become the permanent access/egress for Willes Pastures Rd. The proposed haul route M42/A422/A423 indicates Average Annual Daily Trips totalling of 305 Construction Access to worst-case scenarios, each making a right turn. It is our opinion a right turn main compound harbourage is required to offset construction traffic from the main line during this construction period. Upon completion of the works we would expect the road to be reinstated to its former arrangement as unnecessarily over widened carriageways can be hazardous. We are unclear of HS2’s full intentions for this junction. This junction is believed not to have been subject to a Stage 1 RSA.

A stopping up order is required for the redundant access.

CT-05-081L1 Wills Pastures Road offline upgrade needs to be extended beyond the entrances to Glebe farm and Lower New House Farm to avoid conflict with construction vehicles and the public as this section is well used. CT-05/06-081-L2 The plan shows possible severance of field accesses. Appropriate consideration Grid ref: D6 to E6 and consultation with landowners required that ensures access to pasture land is Temporary Construction maintained. Access main compound

Volume 2 CFA 16 – Ladbroke to Southam - Community Forum Reports (ES 3.2.1.16), Maps (ES3.2.2.16) and related Traffic Assessment ( Vol 5 ES 3.5.0.12.7) Volume, page and paragraph Full ES comment reference CT-05-082-R2 The Council has previously comments that the construction traffic route using the lane past Upper Radbourne Farm is thought to be a private road, and we cannot therefore comment on its suitability

CT-05-082 Radbourne Lane realignment. The proposed radii will present issues for forward visibility.

CT-05,06-084 A423 Banbury Road. It is assumed that geometry will comply with DMRB. However, it appears that land take to accommodate earthworks is insufficient for the level differences suggested.

CT-05/06-087 & Section Proposed haul route/s are not detailed on the two plans. 12.4.9 of CFA report Separate accesses are proposed for the material transfer station, main compound, and access road to the tunnel portal. We would seek a single point of access to all sites wherever possible.

Access for tunnel portal provides no forward visibility for vehicles Grid Ref: D4/D5 - Tunnel approaching eastbound with the potential for right turn type collisions. Portal Compound Access Alternative position to be sourced.

Visibility eastwards on egress is below that of the standard required for a highway with a design speed of 50mph. Alternative position for access to be found that strikes a better balance.

CT-05-087-L1- Secondary A secondary construction access is proposed to serve the Long Itchington Construction Access. Grid Ref: portal with access gained off the A425 Southam Road at Ufton. No details G8 have been provided on vehicular trip rates or distribution of these trips and duration of use. Irrespective of this, access to the site is inadequate with poor forward visibility towards stationary vehicles turning right and similar issues on access / egress. The land allocated for remedial measures is unlikely to offer any meaningful improvements to address WCC concerns in this regard.

CT-05-088a No construction routes are shown on this plan which makes it difficult to comment on the acceptability of routes to be used.

Volume 2 CFA 16 – Ladbroke to Southam - Community Forum Reports (ES 3.2.1.16), Maps (ES3.2.2.16) and related Traffic Assessment ( Vol 5 ES 3.5.0.12.7) Volume, page and paragraph Full ES comment reference Community forum report 16: The council previously made the following comment in the July 2013 Ladbroke to Southam draft ES: Map book CT-06-079b, to 087 WCC are disappointed at the level of detail showing the alterations to the existing highway network. WCC feel that it is not possible to provide any constructive comments on the acceptability of the designs given that there is no information to its geometric layout . Of particular concern it is not clear what standards the alterations have been designed to.

GENERAL HIGHWAY DESIGN COMMENTS The ES still does not provide sufficient detail to enable a technical assessment to be made prior to submission of any detailed proposals for development work on the Highway.

The following comments relate to specific development proposals and should be incorporated into the further development details at locations where approval applications will be submitted to the Highway Authority.

CFA 16 Report Volume 2 (ES Construction of the proposed scheme and effects during construction:- 3.2.1.16 In respect to WCC having significant reservations regarding the accuracy of parts of the traffic assessment, the Authority requires assurances that Sections 2.3 and Section 12.4 construction will be carried out in such a way as to minimise the impact on the existing highway network for all users. It is essential that HS2 engages fully with WCC and local stakeholders and emergency services to ensure the details set out in the Draft Code of Construction are followed and effectively monitored during development and construction of HS2. Any advance highway works should be completed before 2017 wherever possible to mitigate the impact of high HGV construction traffic flows.

12.2.3 Clarification as to which version of TEMPRO was used in the traffic forecasts. (However, forecast figures in table 7-182 of Vol5 – Traffic Assessment-Part 7 are correct. 12.3.5 Section 12.3.5 gives no description of what constitutes a significant accident problem, nor is there any reference to route related problems. There is no evidence behind the current statement.

The council has previously pointed out that: Local intervention level for a cluster site is 6 in 3 years and for route consideration accs/km are applied. WCC request that the intervention level is lowered and analysis of route issues considered. The final analysis of accidents risk at a junction or route is based solely on the assumed rise in construction traffic of which no predicted accident modelling has been referred to make the statement robust. No account is made of type of junction, geometry, non-motorised user usage that will provide greater acceptance of this statement. Further it is unclear as to whether Haul routes and there interface with the major have been included in the assessment

It is apparent this point has been ignored by HS2 in the Full ES documentation WCC sets a local intervention level for a cluster site of 6 in 3 years and for route consideration accs/km are applied. WCC request that theHS2 intervention level is lowered and analysis of route issues considered. The final analysis of accidents risk at a junction or route is based solely on the assumed rise in construction traffic of which no predicted accident modelling has been referred to make the statement robust. No account is made of type of junction, geometry, non-motorised user usage that will provide greater acceptance of this statement. Further it is unclear as to whether Haul routes and there interface with the major have been included in the assessment

k) Water Resources & Flood risk

Document: Volume 2, Map books CFA16: Ladbroke

Water Resource & Flood Risk

Volume, page Full ES comment and paragraph reference The latest set of maps show more balancing ponds than previous maps, although the reasoning for the locations of the ponds is unclear relative to topography, and the arrows indicating the direction of drainage between ponds / areas of hard-standing often appear to be entirely random. For example, on map number CT-06-084 (in Ladbroke and Southam, ES 3.2.2.16) showing the section north of Ladbroke, the balancing ponds have been located on the upstream side of the proposed railway, nearest to the flood-prone village of Ladbroke, and there is no clear route for the water to drain to the downstream side of the railway

CFA 17: Offchurch & Cubbington The council’s comments are addressed in the order they appear in the document and sub divided by topic to aid the reader’s understanding. Where the council has not provided comment, this should not be taken as agreement or consent for the text. The order of comments are:

The council does not wish to make comments on the following sections at this time: a) Agriculture b) Air Quality

C) Community- incorporating health related concerns Document: Volume 2: Community Forum Area Report. CFA 17: Offchurch and Cubbington ES 3.2.1.17 Volume, page and paragraph Full ES comment reference 5.2.2 The council does not agree with HS2’s assessment that the worker Worker accommodation accommodation will create no “significant effect.” Furthermore the cross reference to the CoCP does not afford sufficient additional detail for this concern to be mitigated at this time. There HS2 must provide additional detail of protection for the community.

5.3.10 HS2 appear to have omitted the Catholic primary school from their assessment in Cubbington. This oversight needs to be addressed. 5.4.10 The council does not agree with the statements in this section. If HS2 accept there will be significant adverse effects on the Greenway during construction. Whilst this is listed as temporary, Hs2 seem to have made no link between the significance of the effect and the duration. This is another example of a linear appraisal and a failure to consider the cumulative effects on the community ad users. Again the council reiterates its position that that where an opportunity to mitigate and issue it is incumbent on HS2 to do so and not diminish the value of the Greenway to users. 5.4.14 The proposed crossing (for cyclists) is not considered acceptable. The HS2 proposal does not take advantage of the existing Greenway alignment, the opportunity to connect the greenway at the Fosse and achieve a long term strategic aim of Sustrans (the UK leading sustainable transport charity).

Document: Volume 2: Community Forum Area Report. CFA 17: Offchurch and Cubbington ES 3.2.1.17 Volume, page and paragraph Full ES comment reference Furthermore the current proposal fails to return the agricultural field to its former state (reduces the economic viability of that land) and offers no opportunity to create a safe wildlife corridor and ecological connectivity. The council does not consider the treatment of the Offchurch Greenway reinstatement acceptable in its current form and requires HS2 to reconsider the current design.

5.4.22 The statement that “severe adverse effects” do not require further measures of mitigation appears to be counter institutive. This is unacceptable.

Health related issues Document: Volume 2: Community Forum Area Report. CFA 17: Offchurch and Cubbington ES 3.2.1.17 Draft ES document WCC HS2 Mitigation Public Health reference comment/observation on ES Warwickshire Draft ES Consultation amendments additional comments on final ES 2.1.7 page 13 It is unclear how the Insufficient detail A well-established Proposed Scheme will provided in HIA. No network of public impact upon these vital evidence to suggest footpaths, byways networks of public our original mitigation and bridleways footpaths that link the comments have been provide connections small communities within considered, therefore between the villages this area. Further HS2 MUST refer to in the area. information is needed original comments regarding the impact that under WCC may occur with respect to comment/observation social isolation, community on Draft ES cohesion and health and Consultation (first wellbeing if the routes column). The were to be negatively avoidance of directly affected by the Proposed addressing these Scheme. issues is negligent to the local population of Warwickshire. 2.1.10 page 13 While it is recognised that Insufficient detail The villages of residents in the area are provided in HIA. No Offchurch, dependent upon travelling evidence to suggest Hunningham and to other areas for services, our original mitigation Weston-under- further assessment is comments have been Wetherley share a needed as to the effect the considered, therefore limited range of project may have on HS2 MUST refer to facilities, comprising accessing these services. original comments a church, a public For example, if GP under WCC house, a village hall surgeries and healthcare comment/observation and some areas of access is negatively on Draft ES public open affected A & E admissions Consultation (first space...Many may increase due to its column). The residents in the area use as an alternative (and avoidance of directly

are dependent upon possibly inappropriate) addressing these travelling to the source of health care. Ill issues is negligent to larger village of health in the community the local population Cubbington, or to may deteriorate if access of Warwickshire. other main centres to healthcare is outside the area for compromised so when access to day-to-day care is sought the outcome services. is poorer for the individual. These could increase A & E waiting times and admission to the acute sector. 2.1.13 page 14 Further information is Insufficient detail There is also a needed regarding the provided in HIA. No recreation ground at health and social impact evidence to suggest Offchurch, which is on the local communities our original mitigation approximately 900m on any changes to these comments have been west of the Proposed key recreational walking considered, therefore Scheme. The routes and pathways, HS2 MUST refer to Shakespeare’s Avon either during construction original comments Way and the or long term. under WCC Millennium Way comment/observation public footpaths, It is recommended that a on Draft ES which run through health impact assessment Consultation (first South Cubbington is conducted including the column). The Wood, are popular impact on physical activity avoidance of directly local walking routes levels, weight, addressing these as well as forming cardiovascular and issues is negligent to part of a long respiratory conditions and the local population distance trail. mental health and of Warwickshire. wellbeing. Pre-exiting 5.4.4 page 42 conditions such as There are a number cardiovascular, arthritis, of open spaces and respiratory and back pain recreational routes in could be exacerbated the area to the south leading to increased use of and east of health services if negative Offchurch. changes are made to the local walking routes. 5.4.6 page 42 The Centenary Way A social impact and Grand Union assessment on social Canal Walk run isolation and community along the southern cohesion is also boundary of the recommended. area, following the towpath of the canal to Leamington Spa. The Centenary Way is a 157km long distance route, which runs from the Gloucestershire borders in the south to Kingsbury in the

north, passing through Leamington Spa, Kenilworth and Stoneleigh to the north. The Grand Union Canal Walk is part of a 230km trail from London to Birmingham following the route of the canal. Both routes cross through the temporary and permanent land take areas for the Proposed Scheme

5.4.11 page 43 There are also a number of open spaces, recreational facilities and routes to the north and east of Cubbington. To the north, are the Coventry Road allotments and Waverley Equestrian Training Centre…The Shakespeare’s Avon Way and the Millennium Way long distance footpaths share the same route through Cubbington and are crossed by the Proposed Scheme at South Cubbington Wood…The Millennium Way is a 160km marked trail which runs from Worcestershire to Northamptonshire, passing through Hunningham, Cubbington, Leamington Spa and Kenilworth. This footpath is also a popular local walking route as well as forming part of the

two long distance trails. 2.3.14 page 20 While it is positive that light Insufficient detail Lighting of site pollution has been provided in HIA. No compounds during recognised, sleep evidence to suggest hours of darkness disturbance can have an our original mitigation would seek to adverse effect on health comments have been reduce light pollution and wellbeing, and so we considered, therefore to the surrounding would recommend that HS2 MUST refer to area. light pollution be kept to original comments recommended standards under WCC rather than sought to. comment/observation on Draft ES Consultation (first column). The avoidance of directly addressing these issues is negligent to the local population of Warwickshire. 3.2.2 page 31 It is unclear how the Insufficient detail Relevant saved Proposed Scheme will provided in HIA. No policies of the support the local policies evidence to suggest adopted WDC Local which aim to protect rural our original mitigation Plan protect best land from pollution and comments have been and most versatile agricultural land which is considered, therefore (BMV) agricultural used for food production in HS2 MUST refer to land (Policy DP3(g)) the local area. It is also original comments and support unclear what under WCC measures to protect compensatory measures comment/observation rural land from will be put into place from on Draft ES pollution (DP9) and the predicted adverse Consultation (first flooding (DP11), impacts from the Proposed column). The which are indirectly Scheme. avoidance of directly linked to the addressing these protection of The health implications issues is negligent to agricultural land and from pollution have not the local population soil quality. been addressed in this of Warwickshire. document and it is 8.2.3 page 60 recommended that a The adopted WDC health impact assessment Local Plan includes be completed with regards a policy (DP9) on to pollution and health. pollution control, including soil contamination, which requires developers to ensure that land is made fit and does not pose an unacceptable risk of contamination. General Policy DP3 and the linked Policy DAP.3 include

provisions to protect features of geological and geomorphological value, requiring developers to consider mitigation and compensatory measures if adverse impacts are predicted to arise from development.

9.2.2 page 65 Policy DP2: Amenity requires developers to consider and seek to avoid adverse impacts on amenity from noise, pollution, general disturbance and mature tree loss.

13.2.2 page 89 Policy DP9 (Pollution) restricts permission to new developments if unsuitable levels of pollution are produced, thus contributing to safeguarding surface water quality. 3.2.3 page 31 It is unclear how the Insufficient detail Local Plan -Policies Proposed scheme will provided in HIA. No for the conservation support the policies which evidence to suggest of rural landscapes stress the importance of our original mitigation and woodland are the outdoor environment comments have been contained in Section and its benefits. It is considered, therefore 15, Green recommended that when HS2 MUST refer to Infrastructure, which exploring the impact on the original comments stresses the environment that the under WCC importance of the impact on health from loss comment/observation natural and outdoor of the outdoor environment on Draft ES environment and the is explored. Consultation (first benefits it can bring column). The for people and avoidance of directly nature. addressing these issues is negligent to the local population of Warwickshire. 3.4.13 page 33 While it is positive to see Insufficient detail The whole area is a that measures have been provided in HIA. No Nitrate Vulnerable introduced to reduce evidence to suggest

Zone, where nitrate nitrogen losses from our original mitigation pollution is a agricultural sources to comments have been potential problem water, further detail is considered, therefore and measures have required as to what these HS2 MUST refer to been introduced to measures are. As the area original comments reduce nitrogen is a Nitrate Vulnerable under WCC losses from Zone and is dominated by comment/observation agricultural sources arable food crops, we on Draft ES to water. would recommend that Consultation (first measures taken prevent column). The nitrogen losses as far as avoidance of directly possible rather than only addressing these reduce it. issues is negligent to the local population of Warwickshire. 3.5.8 page 35 Air pollution, particularly 12.4.1: Insufficient detail Irrigated crops are dust from construction, provision of on- provided in HIA. No likely to be sensitive could exacerbate existing site evidence to suggest to dust. In addition, a respiratory or accommodation our original mitigation number of holdings cardiovascular conditions and welfare comments have been have diversified leading to an increase in facilities to considered, therefore enterprises, GP and acute hospital use. reduce daily HS2 MUST refer to including letting of A health impact travel by site original comments surplus buildings and assessment of the workers workers. under WCC a marquee hire on site and their living comment/observation business, where accommodation, as well as 4.4.2: on Draft ES dust, noise and of the local community and contractors Consultation (first vibration could cause affected properties is being required column). The problems. However, recommended. Continuous to manage avoidance of directly the emission of dust, monitoring of pollution dust, air addressing these noise and vibration levels at the site during pollution, odour issues is negligent to during the construction is also and exhaust the local population construction phase recommended, with the emissions of Warwickshire. would be controlled implementation of further during by implementing measures to mitigate any construction best practice set out pollution exceeding works; in the CoCP and minimum permitted levels. these issues are considered not to be significant. 5.2.3 page 41 It is unclear how the HS2 12.5.1: Insufficient detail Other key policy project is going to support retaining the provided in HIA. No themes - Support to the local policy, particularly majority of evidence to suggest protecting the Policies DP6 and SC4 roads crossing our original mitigation continuity of existing regarding protecting the the Proposed comments have been pedestrian and cycle continuity of existing and Scheme in, or considered, therefore routes and the improvement of pedestrian very close HS2 MUST refer to improvement of and cycling networks. The to their current original comments walking and cycling good availability of walking location under WCC networks throughout and cycling networks are resulting in no comment/observation WDC (Policies DP6 linked to good health significant on Draft ES and SC4). including physical activity, diversions of Consultation (first weight management and traffic onto column). The mental health and alternative avoidance of directly wellbeing. Further routes; and addressing these

information is needed retaining PRoW issues is negligent to detailing how the project crossing the the local population will support local health Proposed of Warwickshire. policy to provide walking Scheme, with and cycling routes, and localised On this issue, the where it doesn’t what realignments council does not measures will be put into kept to a believe HS2 have place to minimise any minimum. reasonably mitigated negative effect from the for a safe cycle/ Proposed Scheme on the pedestrian crossing population’s health. of the Fosse 5.4.8 page 42 While it has been Insufficient detail Whilst the village is recognised that the provided in HIA. No some distance away scheme cuts across routes evidence to suggest from areas of that provide access from our original mitigation temporary and Hunnington to health care, comments have been permanent land take, education and other considered, therefore the Proposed services in Cubbington HS2 MUST refer to Scheme cuts across and Leamington Spa, original comments routes that provide consideration needs to be under WCC access from given to the importance of comment/observation Hunningham to good access in the area in on Draft ES facilities at relation to the social Consultation (first Cubbington and impact including isolation, column). The Leamington Spa to mental health and avoidance of directly the west. wellbeing, public transport addressing these routes and availability and issues is negligent to emergency vehicle access. the local population Further assessment is of Warwickshire. needed to assess the health and wellbeing impact of reduced access to this rural area. 5.5.1 page 43 While it is positive to see 4.4.2: Insufficient detail Specific measures in that measures to minimise contractors provided in HIA. No relation to air quality amenity impacts are to be being required evidence to suggest and noise would also put into place, it is also to manage our original mitigation serve to minimise recommended that the dust, air comments have been amenity impacts on impact to health from air pollution, odour considered, therefore the neighbouring and noise pollution is and exhaust HS2 MUST refer to communities. explored. emissions original comments during under WCC construction comment/observation works; on Draft ES Consultation (first column). The avoidance of directly addressing these issues is negligent to the local population of Warwickshire. 5.5.5 page 43 It is stated that Insufficient detail Residents at construction disruption to provided in HIA. No Hunningham and journeys from evidence to suggest

Weston-under- Hunningham, Weston- our original mitigation Wetherley, who are under-Wetherley and other comments have been dependent upon areas to Cubbington and considered, therefore travelling to Leamington Spa is limited. HS2 MUST refer to Cubbington and Evidence is required as to original comments Leamington Spa for how the impact being of under WCC access to services only limited disruption was comment/observation such as schooling obtained and further on Draft ES and health care, research into the effect of Consultation (first would experience delays over several column). The some disruption to months (and longer if avoidance of directly their journeys via works are not completed addressing these Hunningham Road on time) on healthcare issues is negligent to and the B4453 appointments, schooling, the local population Rugby Road. employment, emergency of Warwickshire. vehicle access, public transport and mental health and wellbeing through stress and anxiety. 5.5.16 page 45 It is recommended that a 3.4.31: Other Insufficient detail The significant health impact assessment mitigation provided in HIA. No residual effects of is conducted including the measures that evidence to suggest the scheme during impact on physical activity are proposed our original mitigation construction would levels, weight, include comments have been be as follows: The cardiovascular and drainage works considered, therefore possible temporary respiratory conditions and at three HS2 MUST refer to postponement of the mental health and holdings original comments Wolf Run cross- wellbeing. Pre-exiting (CFA17/1, under WCC country running conditions such as CFA17/5 and comment/observation event on land at cardiovascular, arthritis, CFA17/6), on Draft ES Welsh Road Farm, respiratory and back pain provisions for Consultation (first at Offchurch due to could be exacerbated the outdoor column). The construction of the leading to increased use of pursuit course avoidance of directly route through the health services if adverse called the Wolf addressing these centre of the course changes are made to the Run at issues is negligent to resulting in an local walking routes. CFA17/1 (see the local population adverse effect on Section 5) and of Warwickshire. participants and access spectators; and the provision for temporary closure of South the Shakespeare’s Cubbington Avon Way and Wood Millennium Way at (CFA17/6). South Cubbington Wood, which would have an adverse effect on walkers, both locally and those following the promoted long distance routes. 5.6.2 page 45 While it is positive that See separate Insufficient detail The assessment of impacts from transport, comments on provided in HIA. No effects on amenity traffic, air quality etc. have HIA evidence to suggest will draw upon other been recognised, it is our original mitigation

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technical disciplines important that the health 5.4.1: provision comments have been (e.g. air quality, effects of the Proposed of noise considered, therefore noise and vibration, Scheme are also barriers around HS2 MUST refer to visual, transport and considered. A health and the worksites to original comments traffic) findings to social impact assessment the east of under WCC inform the amenity is recommended. Cubbington to comment/observation assessment. The reduce noise on Draft ES presence of in- impacts on Consultation (first combination impacts Cubbington column). The from these other Church of avoidance of directly disciplines could England addressing these result in significant Primary School issues is negligent to amenity effects on a and on the local population number of Oakdene Day of Warwickshire. community facilities Nursery; and a and resources in the 50m long area. This will be cutting at Ash reported in the Beds less than formal ES. 0.5m deep with raised earthworks on both sides of the rail line to provide visual and noise screening;

5.4.1: visual and noise screening.

5.4.2: specific measures in relation to air quality and noise will also serve to reduce impacts for the neighbouring communities including discretionary noise insulation for sensitive community resources and, in special circumstances, temporary rehousing (draft CoCP, Sections 7 and 13); and 9.4.2 page 66 It is recommended that a Insufficient detail The historic Fosse health impact assessment provided in HIA. No Way and Grand is conducted including the evidence to suggest

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Union Canal also impact on physical activity our original mitigation cross the area. levels, weight, comments have been PRoW include three cardiovascular and considered, therefore long distance routes respiratory conditions and HS2 MUST refer to and the Offchurch mental health and original comments Greenway (Sustrans wellbeing. Pre-exiting under WCC NCR 41). Land from conditions such as comment/observation south of Offchurch cardiovascular, arthritis, on Draft ES northwards to respiratory and back pain Consultation (first Weston Wood is could be exacerbated column). The designated green leading to increased use of avoidance of directly belt. The eastern health services if adverse addressing these section of the area is changes are made to the issues is negligent to designated by WDC local walking routes. the local population as a Special of Warwickshire. Landscape Area. 11.5.1 page 80 While it is positive that the Insufficient detail The assessment has potential effects on provided in HIA. No considered the occupants from evidence to suggest potential effects on construction noise has our original mitigation all community been assessed, it is comments have been receptors within the unclear whether this considered, therefore spatial scope, their assessment also explored HS2 MUST refer to occupants and their the health impact from original comments use (including noise including sleep under WCC annoyance and disturbances, stress and comment/observation activity disturbance) mental health. A health on Draft ES arising from impact assessment is Consultation (first construction noise recommended. column). The and/or vibration. avoidance of directly addressing these issues is negligent to the local population of Warwickshire. 11.5.5 page 81 While it is positive to see Insufficient detail Further work is being that further work regarding provided in HIA. No undertaken to the effect of noise is being evidence to suggest confirm significant undertaken, it is unclear our original mitigation construction noise whether this includes any comments have been and vibration effects, work to examine the health considered, therefore including any effects from the HS2 MUST refer to temporary effects construction noise and original comments from construction vibration for the local under WCC traffic. community. A health comment/observation impact assessment is on Draft ES recommended. Consultation (first column). The avoidance of directly addressing these issues is negligent to the local population of Warwickshire. 11.6.4 page 81 Residential receptors have Insufficient detail Residential receptors been identified as having a provided in HIA. No

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within the daytime significant adverse effect evidence to suggest 65dB contour, and from day and night HS2 our original mitigation therefore the night- noise. Although Noise comments have been time 55dB contour, Insulation Regulations and considered, therefore have been identified WHO Night Noise HS2 MUST refer to as being likely to Guidelines are being used, original comments experience a we would recommend that under WCC significant adverse target noise levels be comment/observation effect from the aimed below this threshold on Draft ES Proposed Scheme. to reduce the health and Consultation (first wellbeing effects on column). The residents in this rural area. avoidance of directly addressing these Measures taken to reduce issues is negligent to noise nuisance need to be the local population detailed with expected of Warwickshire. effectiveness data given in order to demonstrate they meet the permitted noise levels. We also recommend continued noise monitoring in this area during construction and after the project is complete. 12.4.6 page 85 While a survey has been Insufficient detail All PRoW which completed it is unclear provided in HIA. No would be intersected how the survey was evidence to suggest by the proposed completed.. The number of our original mitigation route have been 60 people per day using comments have been surveyed... A total of the facilities is not considered, therefore 13 PRoW have been necessarily a small HS2 MUST refer to identified consisting number as implied, given original comments of public footpaths, the rural nature and small under WCC bridleways and populations in the comment/observation cycleways. The surrounding areas. It is on Draft ES surveys indicate that recommended that a Consultation (first none of the roads, community consultation column). The footpaths, bridleways and a health impact avoidance of directly and cycleways that assessment is completed addressing these would cross the in order to assess the true issues is negligent to proposed route, are impact on health, including the local population used by more than mental health and of Warwickshire. 60 people per day wellbeing and the impact walking, cycling or on community due to the riding. loss of these routes in this rural area.

103 d) Cultural Heritage Document: Volume 2: Community Forum Area Report. CFA 17: Offchurch and Cubbington ES 3.2.1.17 Volume, page and paragraph Full ES comment reference pg. 70 This paragraphs states that the assessment has considered the intra-project 6.2.3 effects of a number of technical topic assessments such as landscape and visual, ecology and water resources and flood risk and that these interactions have been included in the assessment of impacts and effects.

There is little evidence of this presented in the ES. Whilst landscape and visual assessments have contributed to the assessment of cultural heritage impacts (although this has primarily been in respect of the impacts upon the setting of heritage assets rather than impacts on buried archaeological remains), there is little reference in the cultural heritage chapters and documents to ecology and water resources and flood risk. pg.70 Not all of the areas identified in the Archaeological Risk Model as being 6.2.4 priority sites for survey in order to inform the EIA were available for survey. This is identified in this paragraph as a limiting factor for the EIA [we have assumed that the word ‘not’ was inadvertently missed off the second bullet point, as had access be available to all areas for survey, this would not have been raised as a limitation].

Disappointingly, the Archaeological Risk Model referenced in this paragraph has not been reproduced in the ES.

In particular, we cannot assess the degree to which the lack of survey referred to in this paragraph has limited the assessment detailed in the ES. pg. 70 Whilst paragraph 6.2.5 states that non-intrusive field survey has been 6.2.5 undertaken in a number of areas, it should be noted that this has been limited to walkover, LiDAR and hyperspectral surveys. No other non-intrusive fieldwork across this CFA is detailed in this ES. pg. 70 The full extent (including which areas were visited) of the walkovers and site 6.3.2 reconnaissance undertaken to inform this assessment is not set out in the ES, nor the timing or ground conditions at the time of these visits. We cannot therefore assess the adequacy of this aspect of the Environmental Impact Assessment.

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pg. 78 We do not agree with the statement that ‘There will be no physical impacts 6.5.2 on buried archaeological remains or other heritage assets arising from the operation of the Proposed Scheme’.

There is a potential for vibrations etc. associated with the operation of the railway to have a direct impact upon buried and upstanding heritage assets.

There is insufficient information available at this time to enable any such impacts to be ruled out.

6, Throughout There is limited consideration throughout this document to the impacts that the proposed development may have upon the historic landscape character of this CFA.

e) Ecology The council has made its views on this section known in the commentary submitted for volume 1,

f) Land Quality Document: Volume 2: Community Forum Area Report. CFA 17: Offchurch and Cubbington ES 3.2.1.17 Volume, page and Full ES comment paragraph reference 8.3.29 There Neither report makes reference to the Underground Coal Gasification licence application are no current made by Cluff Natural Resources PLC near Weston under Weatherly/Bubbenhall/Marton/ plans for Birdingbury. Please refer to the information on the Coal Authority website: unconventional http://coal.decc.gov.uk/assets/coal/news%20and%20notices/licensing/7568-licensing- deep mining in this notice-0566.pdf area e.g. by underground coal Please note that this is a conditional license application only and a planning application gasification, and it has not been submitted. If the license application is approved by the Coal Authority, all is considered other necessary permissions and approvals would need to be secured. That is likely to unlikely that plans include planning permission from Warwickshire County Council, as well as approval from to mine this area the Environment Agency, Health and Safety Executive etc. However, given the location will be developed approx. 1km east of the route, the potential area of working and the nature of the in the foreseeable activity, we consider that this potential project should be recognised by HS2 Ltd. In doing future. so, the potential environmental impacts from, and upon, the HS2 should be assessed.

105 g) Landscape and visual assessment Document: Volume 2: Community Forum Area Report. CFA 17: Offchurch and Cubbington ES 3.2.1.17 Vol. 2 CFA Report no. The impact of the loss of ancient woodland at South Cubbington Wood is severely 17 and Vol. 5 SMR played down and not addressed adequately. The Landscape Sensitivity table in the (CT-001-000/1) para SMR states that “components that are not easily replaced or substituted e.g. mature 12.2.14 trees” have high sensitivity, and ancient woodland falls under this criterion.

h) Socio economic Document: Volume 2: Community Forum Area Report. CFA 17: Offchurch and Cubbington ES 3.2.1.17 Volume, page and paragraph Full ES comment reference 10.4.6 This appears to be a standard text paragraph and gives no useful data to the reader of the community. 10.5.4 The suggestion that operational employment will be generated in this area is nonsense as there are has no depots, stations or access to the rail line.

i) Sound, Noise & Vibration Document: Volume 2: Community Forum Area Report. CFA 17: Offchurch and Cubbington ES 3.2.1.17 Volume, page and paragraph Comment reference

CFA 17. Page A significant effect during construction of the re-aligned Rugby 192. 11.5.10 Road of up to 80 dB has been identified at Metcalf Timbers. The council are concerned that there is a nearby dwelling which has not been identified as having a significant impact and seek assurances from HS2 that this dwelling will be appropriately mitigated.

106 j) Traffic & Transport incorporating PROW, Highway and Traffic Safety Document: Volume 2: Community Forum Area Report. CFA 17: Offchurch and Cubbington ES 3.2.1.17 PROW

CA – Offchurch- 2.2.4. Green bridges for the Offchurch Greenway and Mill Lane. Cubbington See comment on Green Bridges in general. It should be noted that the bridge provided for the Offchurch Greenway is also provided for users of Public Footpath W192 and therefore has to be suitable for cyclists and pedestrians. The provision of hedges across the bridge leads to issues of maintenance and sufficient width for all users. CA – Offchurch- Table 1. Public Bridleways W129a and W129x will be used as Cubbington haul routes to the River Leam viaduct construction compound. As per other areas there are issues with use by and safety of the public. Public safety must be ensured. CA – Offchurch- Public Footpath W130b has been diverted to further east along Cubbington the B4453 Rugby Road to close to North Cubbington Wood. At its original junction with Rugby Road it continues on the other side of the road). Provision for pedestrians must be provided along the Rugby Road to allow the PROW network to function in the same way as before. The provision must be safe and separate from the vehicles. CA – Offchurch- 9.3.13. Although a trivial point, the Offchurch Greenway appears Cubbington to be numbered as W192. W192 is a Public Right of Way and runs parallel to the Offchurch Greenway. The description is misleading. HS2 must ensure that all labels of PROW are accurate.

CFA 17 – Offchurch to Cubbington (Community Forum Reports / Maps/ Transport Assessment)

CFA 17 - Volume 2 – Full ES Comments Map Book (ES 3.2.2.17) CT-05-088b The construction traffic route along Welsh Road is still considered unacceptable given the number and size of the compounds along its length. There will be a significant adverse effect on the junctions. The narrow brick bridge over the Grand Union Canal is unsuitable for high HGV flows. These points were raised in the Draft ES in July 2013 and are still to be addressed

CT-06-088b Ridgeway Lane is shown to be diverted below the Longhole viaduct. There is insufficient detail shown in the ES to determine whether there is any conflict in headroom heights with the adjacent Grand Union Canal.

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CT-05-089 WCC has previously stated that it objects to the closure of Long Itchington Road (Cabinet July 2012) and has made HS2 aware of this directly and in the Draft EE. WCC awaits fresh details on the mitigation measures to ensure road users, walkers and cyclists are safely served.

WCC would wish to discuss with HS2 what the final arrangements of detailed design include before it removes its objection to the scheme . Phasing of works in this area essential to mitigate impact of construction CT-05/06-089 Facilities for cyclists along this nationally recognised cycle route still fall short of Sustrans route 41 reasonable expectations. WCC require an overbridge / under-pass to be included in Grid Ref: E2 the design which allows the safe crossing of the B4455 Fosse Way for cyclists, walkers and equestrian users. CT-05-089 The combined traffic flows from each of these compounds at peak periods could Main compound / reach 445 daily movements. The indication on plan is that access for the railhead will Road Head. directly oppose Long Itchington Rd and 200m northeast of this will be the access for the main compound. Between each is the national cycle network route 41 (NCN 41). We have concerns that safety is being compromised by the road head proposals and deem a single point of access appropriately positioned from Long Itchington Road serving both sites as desirable.

In addition, NCN 41 will run in parallel with construction vehicles with no obvious diversion. It is not clear how phasing of works will avoid conflict between these users.

CT-05-089 WCC has previously highlighted its concern regarding the suitability of Welsh Road in Haul Route Welsh terms of width to support a large number of HGV’s movements (Draft ES 2013) Road Localised widening of Welsh Road will be needed in order to support the expected increase in construction traffic. WCC must see the planned highway works (roundabout) alignment completed prior to its use in the construction phase.

CT-06-089 Access must to be brought off the Welsh Road and not the Fosse Way. Balancing Pond Access The number of accesses served off the Fosse Way must be limited wherever possible. Grid Ref: G8

CT-06-089 Welsh Road is a primary haul route between two major compound sites. HS2 have Grid Ref: G4 highlighted that it could take in excess of 85 movements / hour, and WCC are Welsh Road concerned at its structural and geometric capabilities of maintaining these vehicles safely and effectively. WCC expect localised widening and kerbing of Welsh Road

CT-06-089 With the closure of Long Itchington Road and increase in traffic along Welsh Road Greenway cycle combined with the proposed realignment and boundary treatments at the junction crossing point. of the Greenway may present hazards to cyclists crossing Welsh Road. Additional Grid Ref: D9 measures are required to ensure cycle safety is not compromised along this nationally recognised route.

CT-05-090 & CT-06-90 Hunningham Road is wholly unsuitable road for construction traffic to use regularly Hunningham Rd and damage to the highway is inevitable despite assurances in the CoCP. Haul Route. The full extent of the construction route is not shown on the SS plans. Additional provisions are required along the route to prevent damage to the highway (passing bays, strip widening).

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CT-05-090 Realignment of Hunningham Road. The proposed vertical alignment may present visibility issues.

Opportunity to create “Green Bridge” site to make better provision for wildlife corridor

CFA 17 Report Volume 2 ES 3.2.1.17 Sections 2.3 and Construction of the proposed scheme and effects during construction:- Section 12.4 WCC has significant reservations regarding the accuracy of various parts of the traffic assessment, WCC requires assurances that construction will be carried out in such a way as to minimise the impact on the existing highway network for all users. The council expects HS2 to engage fully local stakeholders and emergency services to ensure the details set out in the Draft Code of Construction are followed and effectively monitored during development and construction. Any advance highway works must be completed before 2017 to mitigate the impact of high HGV construction traffic flows.

12.3.4 WCC consider the A423 / A425 to be strategic routes.

12.3.5 12.3.5 of the final ES sets out the roads that will be effected in CFA17 and mitigation measures in Section 12.4.1 WCC requires accurate Traffic Assessment details and highway detailed designs prior to the approval of any access or alteration to the highway. 12.3.6 Section 12.4.11 refers to the use of the M40 for a strategic route for HGV movements. However, no details are provided in text or shown on plan (TR-03) to indicate which junction. Junctions 12/13 of the M40 would be the obvious routes and in both cases, significant accident problems have been identified. Measures required to address our concerns in this regard, should be considered in advance of 2017/18 timescale. 12.4.17 Use of the B4100 Banbury Road would infer M40 J13 will be affected. 4th Bullet point 12.4.20 J13/J12 M40 accident problems and likely to be affected 12.4.26 Jaguar Land Rover has extant planning permission for expansion of their Gaydon site. To facilitate this WCC and the Highways Agency are undertaking a major highway improvement scheme to address congestion and safety in the vicinity of M40 J12. No reference to this development is made in the TA and this needs to be incorporated in the document and the TA adjusted accordingly. 12.4.27 These figures don’t add much to the document unless WCC can be provided with a clear indication of where these linked trips are distributed between CFA areas, and across the network.

Transport Assessment Volume 5 (ES3.5.0.12.7)

7.13.13 Considering the proposed haul route we are of the opinion the M40 J13 would be affected. WCC requires that this junction is assessed.

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7.13.42 The reported figures of construction traffic using the junction of B4455/Welsh Road of 85 movements per hour are considered to be significant. WCC requires that this junction is modelled. 7.13.43 We request that this statement is evidenced.

k) Water resources & Flood Risk

The council has no comment to make on this section at this time.

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CFA 18 Stoneleigh, Kenilworth & Burton Green

a) Agriculture b) Air Quality c) Community – incorporating health related issues. d) Culture and Heritage e) Ecology f) Land quality g) Landscape and visual assessment h) Socio Economic i) Sound, Noise & Vibration j) Traffic, & Transport; incorporating PROW, highway design and Traffic Safety k) Water Resources & Flood Risk a) Agriculture The council has no comment to make on this section at this time. b) Air Quality The council has no comment to make on this section at this time. c) Community, incorporating health related issues Document: Volume 2: Community Forum Area Report. CFA 18: Stoneleigh, Kenilworth and Burton Green ES 3.2.1.18 Volume, page and paragraph Full ES comment reference 5.2.2 The council does not agree with the assessment that there will be no significant effects associated with construction and worker accommodation. 5.3.3 & 5.3.9 It is the council’s view that limiting the study area such that it excludes the commercial centre of Kenilworth belies the impact the construction phase will have on the community as whole. The council finds this methodology unacceptable. 5.3.10 The council is pleased to see that the Connect to Kenilworth route is now correctly identified as the Sustrans National Network Route 52. However the apparent lack of mitigation to protect this national route and the missed opportunity to secure a truly sustainable commuter route for Kenilworth residents, is an unacceptable oversight that is contrary to the DfT policy for sustainable commuting. 5.3.20 The council does not agree with assessment that Nailcote Hall Hotel is a community asset. Whilst accepting that the public can make use of the facilities is it a commercial venture and not a community one. 5.4.2 This appears to be a standard section that repeats throughout the documentation but is of little value to the community as it fails to identify local sensitivities in any meaningful manner.

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5.4.4 The loss of land at Stoneleigh Park is considered by the council to be a matter for the socio economic section as the site offers significant employment and innovation opportunities for the local and sub-regional economy. 5.4.9 To identify a loss of 1.9 ha of public open space and not the not identify and mitigation later in the document or chapter is unacceptable to the council and is disingenuous to the communities directly affected by the rail line. 5.4.11 The council finds the acceptance that the PROW will be moderately adversely effected and no proposed solution or mitigation an unacceptable position. It is incumbent on HS2 to mitigate the damage they will cause during the construction period and not just identify the issue. 5.4.24 It is the council’s view that HS2 cannot currently predict what the travel patterns or disruption will be for the 64% of primary school children from outside the village. To suggest that there are no isolation effects at this stage is not grounded in fact. 5.4.26 The council welcomes the commitment for engagement on the school and awaits HS2’s invitation on this issue. 5.4.28 The council remains concerned with shared space of construction traffic and pedestrian/ cycle users over a 5 year period and will wish to see greater detail from HS2 on what additional mitigation will be offered in this area. 5.4.33 Whilst the council welcomes the acceptance that the village hall will need to be re-provided it is deeply concerned that HS2 has without any consultation or engagement chosen a site that is already in community use as part of the school. Had HS2 enquired of the council, they would be aware that the playing field was acquired in 2011 and brought up to standard only recently. To remove one community asset to replace another is not acceptable to the council or the community of Burton Green 5.4.36 It is unacceptable that having stated that the Greenway will be “moderately adversely affected, which is significant.” HS2 do not see it necessary to provide direct or associated mitigation for the effect on overall enjoyment of the Greenway. 5.4.45 The council finds it unacceptable that HS2 identify the village as suffering from “significant adverse effects and then go on to state that they intend to do nothing to mitigate the situation.

Health Document: Volume 2: Community Forum Area Report. CFA 18: Stoneleigh, Kenilworth and Burton Green ES 3.2.1.18 Draft ES document WCC HS2 Mitigation Public Health reference comment/observation on ES Warwickshire Draft ES Consultation amendments additional comments on final ES 2.1.4 page 11 It is recommended that a 10.4.20: The Insufficient detail Further south is health impact assessment assessment provided in HIA. No Stoneleigh Abbey is conducted including the has concluded evidence to suggest (map CT-01-47, E9), impact on physical activity there are our original mitigation an historic country levels, weight, significant comments have been house and important cardiovascular and adverse effects considered, therefore visitor attraction set respiratory conditions and arising during HS2 MUST refer to in a registered mental health and construction. original comments historic parkland. wellbeing. Pre-exiting Businesses under WCC Other estate conditions such as displaced by comment/observation parkland around cardiovascular, arthritis, the Proposed on Draft ES

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Stoneleigh is respiratory and back pain Scheme will be Consultation (first accessible to the could be exacerbated fully column). The public and is well leading to increased use of compensated avoidance of directly used for local walks. health services if adverse within the addressing these Abbey Park (map changes are made to the provisions of issues is negligent to CT-01-47, E9), local walking routes. the National the local population which is a modern Compensation of Warwickshire. business campus in A social impact Code. HS2 Ltd a parkland setting, is assessment on social recognises the located just to the isolation and community importance of south of Stareton cohesion is also displaced and alongside the recommended. businesses Stoneleigh Deer being able to Park Golf Course An economic impact relocate to new (map CT-01-47, C9). assessment is also premises and In the northern part recommended regarding will therefore of the area adverse effects from provide agriculture is the construction and long term additional main land use, with of the Proposed Scheme support over the exception of the on local business and and above National Grid tourist attractions. These statutory transformer include Stoneleigh Deer requirements to compound just north Park Golf Course, facilitate this of Burton Green and Stoneleigh Abbey, Abbey process. the golf course for Park, Nailcote Hotel, the Nailcote Hall Kenilworth Golf Club and Hotel (map CT-01- Crackley Wood. The 50, E8). economic impact assessment should also 2.1.10 page 13 include any adverse The Coventry Way effects on the employment long-distance of local residents and footpath and income spent in the area Centenary Way long- from tourism and local use distance footpath of the facilities. wind their way through the area.

5.4.11 page 51 There are a number of other public open spaces in the countryside separating Kenilworth from Coventry, the most notable being Kenilworth Golf Course and Crackley Wood. The Kenilworth Golf Club (map CT-03-48, F4) is immediately west of the route of the Proposed Scheme

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and the proposed area of temporary and permanent land take encroaches into the northern edge of the course along its boundary with Dalehouse Lane. Crackley Wood, which is located about 370m south of the Proposed Scheme, is designated as a local nature reserve and has a number of trails or walks that are accessible to the public. 2.1.19 page 14 Because of the limited 10.4.20: The Insufficient detail Burton Green in the range of community assessment provided in HIA. No north of the area has facilities it is important that has concluded evidence to suggest a limited range of any impact on the there are our original mitigation community facilities. community from significant comments have been construction or long term is adverse effects considered, therefore explored. Particularly arising during HS2 MUST refer to regarding the health and construction. original comments wellbeing effects and Businesses under WCC social effects from displaced by comment/observation increased social isolation the Proposed on Draft ES due to closure of roads Scheme will be Consultation (first and footways etc. fully column). The Attendance at A & E may compensated avoidance of directly increase if residents are within the addressing these not able to easily access provisions of issues is negligent to their local GP if access the National the local population routes are altered or Compensation of Warwickshire. removed. Code. HS2 Ltd recognises the importance of displaced businesses being able to relocate to new premises and will therefore provide additional support over and above statutory requirements to facilitate this process. 2.3.13 page 23 While it is positive that light Insufficient detail

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Lighting of site pollution has been provided in HIA. No compounds during recognised, sleep evidence to suggest hours of darkness disturbance can have an our original mitigation would seek to adverse effect on health comments have been reduce light pollution and wellbeing, and so we considered, therefore to the surrounding would recommend that HS2 MUST refer to area. light pollution be kept to original comments recommended standards under WCC rather than sought to. comment/observation on Draft ES Consultation (first column). The avoidance of directly addressing these issues is negligent to the local population of Warwickshire. 3.2.5 page 36 It is unclear how the HS2 Insufficient detail The emerging SMBC project is going to support provided in HIA. No Local Plan policies the local policy, particularly evidence to suggest are similar to those Policy P18: Health and our original mitigation in the SUDP and key Well Being. Further comments have been themes relating to information is needed considered, therefore environmental detailing how the project HS2 MUST refer to protection are will support local health original comments retained. Policy P17: policy and where it doesn’t under WCC Countryside and what measures will be put comment/observation Green Belt continues into place to minimise any on Draft ES to protect BMV negative effect from the Consultation (first agricultural land from project on the populations column). The development. Policy health. avoidance of directly P18: Health and Well addressing these Being introduces a issues is negligent to series of measures, the local population one of which is to of Warwickshire. provide opportunities for growing local produce and resisting the loss of areas currently available for such cultivation. 3.4.12 page 39 While it is positive to see Insufficient detail The whole area is a that measures have been provided in HIA. No Nitrate Vulnerable introduced to reduce evidence to suggest Zone in which nitrate nitrogen losses from our original mitigation pollution is a agricultural sources to comments have been potential problem water, further detail is considered, therefore and measures have required as to what these HS2 MUST refer to been introduced to measures are. As the area original comments reduce nitrogen is a Nitrate Vulnerable under WCC losses to water from Zone and is dominated by comment/observation agricultural sources. arable food crops, we on Draft ES would recommend that Consultation (first measures taken prevent column). The

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nitrogen losses as far as avoidance of directly possible rather than only addressing these reduce it. issues is negligent to the local population of Warwickshire. 3.5.10 page 41 Air pollution, particularly 8.4.1: The Insufficient detail Irrigated crops, dust from construction, construction provided in HIA. No including salad could exacerbate existing assessment evidence to suggest produce, are respiratory or takes in to our original mitigation sensitive to dust. In cardiovascular conditions account the comments have been addition, a number of leading to an increase in mitigation considered, therefore holdings have GP and acute hospital use. measures HS2 MUST refer to diversified A health impact contained original comments enterprises, assessment of the workers within the draft under WCC including horse on site and their living CoCP (Volume comment/observation stables/liveries, accommodation, as well as 5: Appendix on Draft ES letting of surplus of the local community and CT-003-001). Consultation (first buildings and car affected properties is The draft CoCP column). The parking for events at recommended. Continuous sets out the avoidance of directly Stoneleigh Park, monitoring of pollution measures and addressing these where dust, noise levels at the site during standards of issues is negligent to and vibration could construction is also work that will the local population cause problems. The recommended, with the be applied to of Warwickshire. emission of dust, implementation of further the noise and vibration measures to mitigate any construction of during the pollution exceeding the construction phase minimum permitted levels. Proposed would be controlled Scheme. Its by implementing requirements in measures set out in relation to work the draft CoCP. in contaminated areas will ensure the effective management and control of the work. Such requirements include the following: the management of human exposure for both construction workers and people living and working nearby (draft CoCP Section 11);

12.4.1: The

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following measures (as described in Section 2.3) have been included as part of the engineering design of the Proposed Scheme in the Stoneleigh, Kenilworth and Burton Green area and will avoid or reduce effects on transport users: provision of on- site accommodation and welfare facilities to reduce daily travel by site workers. 4.2.4 page 44 It is unclear how the HS2 Insufficient detail Air quality policy project is going to support provided in HIA. No (EM9)… all major the local policy, particularly evidence to suggest development EM9 regarding air quality. our original mitigation proposals will have Air pollution causes ill comments have been to demonstrate that health and further considered, therefore they do not information is required to HS2 MUST refer to adversely impact on demonstrate how the original comments air quality. construction of the under WCC Proposed Scheme will not comment/observation The policy adversely impact on air on Draft ES encourages quality in the area. Consultation (first development where column). The it can easily be Further information is avoidance of directly accessed by public needed detailing how the addressing these transport, walking project will support local issues is negligent to and cycling. health policy particularly the local population concerning sustainable of Warwickshire. transport with accessing walking and cycling routes, and where it doesn’t what measures will be put into place to minimise any negative effect from the project on the populations health. 5.2.3 page 49 It is unclear how the HS2 Insufficient detail Other key policy project is going to support provided in HIA. No themes in the WDLP the local policy, particularly evidence to suggest

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relate to Rural Area Policies DP6, SC4, T16 our original mitigation Policies which seek and T17 regarding comments have been to restrict protecting existing and considered, therefore development only to improving walking and HS2 MUST refer to that...Protecting cycle routes and networks. original comments existing pedestrian The good availability of under WCC and cycle routes and walking and cycling comment/observation the improvement of networks are linked to on Draft ES walking and cycling good health including Consultation (first networks throughout physical activity, weight column). The Warwick District management and mental avoidance of directly (Policies DP6 and health and wellbeing. addressing these SC4). Further information is issues is negligent to needed detailing how the the local population 5.2.6 page 49 project will support local of Warwickshire. Other potential health policy to provide impacts of the walking and cycling routes, Proposed Scheme and where it doesn’t what relate to measures will be put into development and place to minimise any land uses that cross negative effect from the the boundary Proposed Scheme on the between Solihull and population’s health. Warwick District, such as PRoW and areas of nature conservation value. Policies T16 and T17 promote the maintenance and improvement of the walking and cycling network, including the co-ordination of route planning across borough boundaries. Nature conservation assets are protected by Policies ENV11, ENV13 and ENV14. 5.4.3 page 51 Although these urban 10.4.20: The Insufficient detail Whilst Kenilworth areas are away from the assessment provided in HIA. No and Coventry are the Proposed Scheme, further has concluded evidence to suggest focus for shopping, investigation is needed there are our original mitigation education, health into the impact during significant comments have been care, employment construction in the adverse effects considered, therefore and recreational accessibility of the arising during HS2 MUST refer to activities in the area, healthcare and other social construction. original comments most of the facilities facilities as travel is Businesses under WCC in these urban areas required to reach them. displaced by comment/observation are some distance the Proposed on Draft ES away from the Scheme will be Consultation (first Proposed Scheme. fully column). The compensated avoidance of directly

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within the addressing these provisions of issues is negligent to the National the local population Compensation of Warwickshire. Code. HS2 Ltd recognises the importance of displaced businesses being able to relocate to new premises and will therefore provide additional support over and above statutory requirements to facilitate this process. 5.4.11 page 43 It is recommended that a Insufficient detail There are a number health impact assessment provided in HIA. No of open spaces and is conducted including the evidence to suggest recreational facilities impact on physical activity our original mitigation in the southern part levels, weight, comments have been of the study area cardiovascular and considered, therefore around Stoneleigh. respiratory conditions and HS2 MUST refer to Much of the estate mental health and original comments parkland, which wellbeing. Pre-exiting under WCC wraps around the conditions such as comment/observation eastern edge of cardiovascular, arthritis, on Draft ES Stoneleigh Park, is respiratory and back pain Consultation (first publicly accessible. It could be exacerbated column). The comprises a mix of leading to increased use of avoidance of directly natural and semi- health services if adverse addressing these natural green changes are made to the issues is negligent to spaces, crossed by a local walking routes. the local population number of public of Warwickshire. footpaths and other established walking routes. The parkland extends to both sides of the B4113 Stoneleigh Road, with a small section falling within the proposed area of permanent land take for the Proposed Scheme. 5.5.5 page 54 The health impact on 10.4.20: The Insufficient detail A total of 27 these residents of the assessment provided in HIA. No residential properties disruption due to has concluded evidence to suggest in this area would be construction and being there are our original mitigation

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situated adjacent to rehoused need to be significant comments have been substantial explored. A health and adverse effects considered, therefore engineering or social impact assessment arising during HS2 MUST refer to demolition works or is recommended. construction. original comments would be surrounded Businesses under WCC by land required displaced by comment/observation temporarily for the the Proposed on Draft ES construction of the Scheme will be Consultation (first Proposed Scheme. It fully column). The is assumed that the compensated avoidance of directly occupiers of these within the addressing these properties would provisions of issues is negligent to need to be rehoused the National the local population temporarily for the Compensation of Warwickshire. duration of any Code. HS2 Ltd construction recognises the activities likely to importance of cause significant displaced noise and businesses disturbance, but being able to could then return to relocate to new their homes upon premises and completion of the will therefore works. provide additional support over and above statutory requirements to facilitate this process. 5.5.17 page 55 While it has been Insufficient detail At Stoneleigh, the recognised that the provided in HIA. No Proposed Scheme permanent land take at the evidence to suggest would result in the Stoneleigh Estate and our original mitigation permanent loss of alterations during the long comments have been publicly accessible construction process at considered, therefore parkland from the Kenilworth Greenway and HS2 MUST refer to Stoneleigh Estate. Sustrans cycle route would original comments This land is required have a significant adverse under WCC to facilitate effect on recreational comment/observation realignment of the users and walkers, it has on Draft ES B4113 Stoneleigh not been detailed how the Consultation (first Road and Stareton Proposed Scheme will column). The Road junction and to mitigate the adverse avoidance of directly accommodate effects, particularly as local addressing these earthworks for the policy is to protect and issues is negligent to Proposed Scheme. improve local walk and the local population Whilst the area cycle routes. of Warwickshire. affected represents only a small Local policy also states proportion of the that projects will need to total estate, this demonstrate that they will particular section is not have an adverse effect well used by on air quality. The closure

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walkers. It includes a of the cycle networks and pathway connecting the commute link between the open space back the University and to the Stoneleigh Kenilworth will have a Road and appears to significant impact on be used as part of an users. If the option to cycle informal circular walk or walk is removed for up around the estate, to two years users may be via the historic Stare forced into cars to get to Bridge area to the work or education. This north. This loss of would lead to an increase land would, in the local air quality and therefore, result in a increase congestion in an significant adverse already heavily congested effect on recreational area. It is recommended users. that an air quality impact assessment be completed. 5.5.19 page 56 The Proposed It is recommended that a Scheme would also health impact assessment cross the Centenary is conducted including the Way, Coventry Way impact on physical activity and Millennium Way levels, weight, long distance cardiovascular and footpaths and both respiratory conditions and the Kenilworth mental health and Greenway and the wellbeing. Pre-exiting Connect2 Kenilworth conditions such as footpath/cycleway. cardiovascular, arthritis, respiratory and back pain 5.5.20 page 56 could be exacerbated Just north of leading to increased use of Kenilworth, the health services if adverse construction of the changes are made to the Proposed Scheme local walking routes. would require a temporary closure of A social impact the recently assessment on social completed Connect2 isolation and community Kenilworth public cohesion is also footpath, bridleway recommended given the and cycleway, which adverse effect on the local also forms part of the community, particularly at Sustrans National Burton Green. Cycle Network (route No. 52). Given the extensive nature of works in this area associated with the realignment of Canley Brook, a 6-12 month closure could be necessary. This would result in a significant adverse

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effect on users, particularly having regard to its value as a commuter link between Kenilworth and the University area to the north. The Proposed Scheme makes provision for a permanent diversion of the route to bridge over the new rail line.

5.5.21 page 56 At Burton Green, the construction of the Proposed Scheme would necessitate a temporary closure of the Kenilworth Greenway for a period of up to two years, giving rise to a significant adverse effect on the local community and on recreational users of the Kenilworth Greenway (which also forms part of the Coventry Way between Crackley and Berkswell). Access to the Kenilworth Greenway from Cromwell Lane would also be lost during the construction period with limited suitable alternative access points in the area. The Proposed Scheme makes provision to divert the Kenilworth Greenway permanently over the line of the cut-and- cover tunnel through Burton Green and then alongside the

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route of the new rail line to the north

5.5.22 page 56 To the north of Burton Green, the construction of the Proposed Scheme would require the temporary closure of the Millennium Way public footpath, to the north of the B4101 Waste Lane. This closure could last for about 6-12 months, giving rise to a significant adverse effect on recreational users. The Proposed Scheme makes provision for a permanent diversion of the route to cross the railway via the Waste Lane overbridge, but given that the existing Waste Lane Bridge would need to be demolished and rebuilt, this diversion would not be available during the construction period. 5.6.2 page 57 While it is positive that Insufficient detail The assessment of impacts from transport, provided in HIA. No effects on amenity traffic, air quality etc. have evidence to suggest will draw upon other been recognised, it is our original mitigation technical disciplines important that the health comments have been (e.g. air quality, effects of the Proposed considered, therefore noise and vibration, Scheme are also HS2 MUST refer to visual, transport and considered. A health and original comments traffic) findings to social impact assessment under WCC inform the amenity is recommended. comment/observation assessment. The on Draft ES presence of in- Consultation (first combination impacts column). The from these other avoidance of directly disciplines could addressing these result in significant issues is negligent to amenity effects on a the local population number of of Warwickshire. community facilities

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and resources in the area. This will be reported in the formal ES. 9.2.1 page 80 It is unclear how the HS2 Insufficient detail Policy DP2: Amenity project is going to support provided in HIA. No requires developers the local policy, particularly evidence to suggest to consider and seek DP2 regarding pollution. our original mitigation to avoid adverse Further information is comments have been impacts on amenity required to demonstrate considered, therefore from noise, pollution, how the construction of the HS2 MUST refer to general disturbance Proposed Scheme will not original comments and mature tree loss. adversely impact pollution under WCC or soil contamination in the comment/observation 13.2.3 page 107 area. The health on Draft ES Policy DP9 implications from pollution Consultation (first (Pollution) restricts have not been addressed column). The permission for new in this document and it is avoidance of directly developments if recommended that a addressing these unsuitable levels of health impact assessment issues is negligent to pollution are be completed with regards the local population produced, thus to pollution and health. of Warwickshire. contributing to safeguarding of surface water quality. 9.2.2 page 80 It is unclear how the HS2 Insufficient detail Policy P18: Health project is going to support provided in HIA. No and Well Being the local policy, particularly evidence to suggest references the role Policy P18: Health and our original mitigation of green Well Being. Further comments have been infrastructure in information is needed considered, therefore supporting health; detailing how the project HS2 MUST refer to and seeks to will support local health original comments safeguard and policy and where it doesn’t under WCC increase what measures will be put comment/observation opportunities for into place to minimise any on Draft ES local food production negative effect from the Consultation (first across the borough project on the populations column). The health. avoidance of directly addressing these issues is negligent to the local population of Warwickshire. 10.5.2 page 94 The assessment states 10.4.17: Taking Insufficient detail It is estimated the displacement or possible into account provided in HIA. No Proposed Scheme loss of approximately 30 the availability evidence to suggest would result in the jobs within the study area, of alternative our original mitigation displacement or but does not take into premises and comments have been possible loss of account the rural nature of the total considered, therefore around 30 jobs the area, disruption to an employed HS2 MUST refer to within this area. already congested traffic within the original comments Taking into account area and difficulty in district under WCC the availability of transport around it. If (approximately comment/observation

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alternative premises premises are moved this 40,000), the on Draft ES and the relatively could lead to further job displacement or Consultation (first healthy local loss if new sites are possible loss of column). The economy, the inaccessible to staff or jobs is avoidance of directly displacement or customers, leading to a considered to addressing these possible loss of jobs reduced customer base be modest issues is negligent to is considered to be and possibly closure of the compared to the local population relatively modest business and the scale of of Warwickshire. compared to the unemployment if the economic scale of economic relocated premises are activity and activity and inappropriate. opportunity in opportunity in the the area. area. The cumulative effect over all Warwickshire affected areas from job losses are examined at the end of this response. 11.6.4 page 97 Residential receptors have Insufficient detail Residential receptors been identified as having a provided in HIA. No within the daytime significant adverse effect evidence to suggest 65dB contour, and from day and night HS2 our original mitigation therefore the night- noise. Although Noise comments have been time 55dB contour, Insulation Regulations and considered, therefore have been identified WHO Night Noise HS2 MUST refer to as being likely to Guidelines are being used, original comments experience a we would recommend that under WCC significant adverse target noise levels be comment/observation effect from HS2 aimed below this threshold on Draft ES noise alone. to reduce the health and Consultation (first wellbeing effects on column). The residents in this rural area. avoidance of directly addressing these Measures taken to reduce issues is negligent to noise nuisance need to be the local population detailed with expected of Warwickshire. effectiveness data given in order to demonstrate they meet the permitted noise levels. We also recommend continued noise monitoring in this area during construction and after the project is complete.

11.6.11 page 97 Although it is stated that Insufficient detail The envisaged the envisaged mitigates provided in HIA. No mitigation (especially will substantially reduce evidence to suggest landscape the potential airborne our original mitigation earthworks and sounds, it is not stated or comments have been noise barriers) clear how reduced the considered, therefore described in this noises will and whether the HS2 MUST refer to chapter substantially noise levels will therefore original comments reduces the potential fall below the permitted under WCC airborne sound noise level. comment/observation

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impacts and noise on Draft ES effects that would Consultation (first otherwise arise from column). The the Proposed avoidance of directly Scheme. Noise disturbance has addressing these multiple negative effects issues is negligent to Nonetheless, on the health and the local population potential significant wellbeing of individuals, of Warwickshire. adverse airborne particularly concerning noise effects have mental health and the been identified for effects of sleep residential receptors disturbance. Additional detail is needed on the effectiveness of the envisaged mitigates and what measures are going to be taken in specific relation to the multiple communities identified as SV18-C01 on maps SV- 01, SV18-C02 on maps SV- 01, SV18-C03 on maps SV-01, SV18-C04 on maps SV-01, SV18-D01 and Sv18-D02 on maps SV-01, who will experience noise exceeding day and night time targets during construction and on a long term basis from railway operation, in order to minimise the health effects. It is recommended that monitoring of noise at this site continue during construction and after completion. 12.4.6 page 101 The number of 200 people Insufficient detail All PRoW which per day using the facilities provided in HIA. No would be intersected is not a small number as evidence to suggest by the route have implied, given the rural our original mitigation been surveyed. A nature of the areas. Local comments have been total of 26 PRoW policies advocate considered, therefore have been identified improving cycling and HS2 MUST refer to consisting of public walking networks and well original comments footpaths, bridleways used ones such as this are under WCC and cycleways. The in contrast to the local comment/observation surveys indicate that policy. It is recommended on Draft ES none of the roads, that a community Consultation (first footpaths, bridleways consultation and a health column). The and cycleways that impact assessment is avoidance of directly would cross the completed in order to addressing these route are used by assess the true impact on issues is negligent to

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more than 200 health, including mental the local population people per day health and wellbeing and of Warwickshire. walking, cycling or the impact on community riding. due to the loss of these routes in this rural area. d) Cultural Heritage: Document: Volume 2: Community Forum Area Report. CFA 18: Stoneleigh, Kenilworth and Burton Green ES 3.2.1.18 Volume, page and paragraph Full ES comment reference pg. 94 This paragraphs states that the assessment has considered the intra-project 6.2.3 effects of a number of technical topic assessments such as landscape and visual, ecology and water resources and flood risk and that these interactions have been included in the assessment of impacts and effects.

There is little evidence of this presented in the ES. Whilst landscape and visual assessments have contributed to the assessment of cultural heritage impacts (although this has primarily been in respect of the impacts upon the setting of heritage assets rather than impacts on buried archaeological remains), there is little reference in the cultural heritage chapters and documents to ecology and water resources and flood risk. pg. 94 Not all of the areas identified in the Archaeological Risk Model as being 6.2.4 priority sites for survey in order to inform the EIA were available for survey. This is identified in this paragraph as a limiting factor for the EIA.

Disappointingly, the Archaeological Risk Model referenced in this paragraph has not been reproduced in the ES.

In particular, we cannot assess the degree to which the lack of survey referred to in this paragraph has limited the assessment detailed in the ES. pg. 70 Non-intrusive field survey is limited to two discreet areas (CN015, land off 6.2.5 Coventry Road (A429), near Kenilworth and CN016, land off Coventry Road (A429), near Kenilworth). This represents a very limited sample of the areas to be disturbed by this scheme and does not provide sufficient information to characterise the likely extent and nature of potential sub surface archaeological assets across this CFA. pg. 94 The full extent (including which areas were visited) of the walkovers and 6.3.2 site reconnaissance undertaken to inform this assessment is not set out in the ES, nor the timing or ground conditions at the time of these visits. We cannot therefore assess the adequacy of this aspect of the Environmental Impact Assessment.

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pg. 97 They state that “no assets have been identified in the study area from the 6.3.13 Late Palaeolithic to the Bronze Age”. However, a number of prehistoric finds have been recovered from within the area required for construction. A case in point is a flint scatter dating to the Mesolithic period 600m east of Crackley Wood (recorded on the Warwickshire Historic Environment Record as MWA8354) which lies within the land required for construction. pg.103 As noted elsewhere, the ES presents insufficient information to support its 6.4.27 - 6.4.28, conclusions in respect of the impacts of this proposal upon the Stoneleigh Abbey registered park and garden. We would expect the ES to present a more detailed discussion about the scale and effect of the impacts, including the likely impact on physical landscape features, the setting of the remaining parkland, and the overall legibility of this asset of high importance. pg. 106-7 We do not agree with the statement that ‘There will be no physical impacts 6.5.2 on buried archaeological remains or other heritage assets arising from the operation of the Proposed Scheme’.

There is a potential for vibrations etc. associated with the operation of the railway to have a direct impact upon buried and upstanding heritage assets.

There is insufficient information available at this time to enable any such impacts to be ruled out.

6, Throughout There is limited consideration throughout this document to the impacts that the proposed development may have upon the historic landscape character of this CFA.

e) Ecology The council has made its views on this section known in the commentary submitted for volume 1,

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f) Land Quality Document: Volume 2: Community Forum Area Report. CFA 18: Stoneleigh, Kenilworth and Burton Green ES 3.2.1.18 Volume, page and paragraph Full ES comment reference 8.3.29 There Neither report makes reference to the Underground Coal Gasification are no current plans for licence application made by Cluff Natural Resources PLC near Weston unconventional deep mining in under Weatherley/Bubbenhall/Marton/ Birdingbury. Please refer to the this area e.g. by underground information on the Coal Authority website: coal gasification, and it is http://coal.decc.gov.uk/assets/coal/news%20and%20notices/licensing/756 considered unlikely that plans 8-licensing-notice-0566.pdf to mine this area will be developed in the foreseeable Please note that this is a conditional license application only and a planning future. application has not been submitted. If the license application is approved by the Coal Authority, all other necessary permissions and approvals would need to be secured. That is likely to include planning permission from Warwickshire County Council, as well as approval from the Environment Agency, Health and Safety Executive etc. However, given the location approx. 1km east of the route, the potential area of working and the nature of the activity, we consider that this potential project should be recognised by HS2 Ltd. In doing so, the potential environmental impacts from, and upon, the HS2 should be assessed.

g) Landscape & visual assessment Document: Volume 2: Community Forum Area Report. CFA 18: Stoneleigh, Kenilworth and Burton Green ES 3.2.1.18 para 9.5.13, p.186 No mention has been made of the severance of the Registered Park & Garden of Stoneleigh Abbey and the effect the Proposed Scheme will have on its setting and the landscape character.

para 9.5.26, p.188 Why has this LCA been assessed as high magnitude of change whereas others are only moderate? What is more special about this LCA than, say, Radbourne Ironstone Fringe, or others? This again appears to be an inconsistency.

h) Socio economic Document: Volume 2: Community Forum Area Report. CFA 17: Offchurch and Cubbington ES 3.2.1.17 Volume, page and paragraph Full ES comment reference 10.3.13 The council is concerned that HS2 have incorrectly assessed the current baseline employment on Stoneleigh Park. It is the council understands that there are 1154 employees on site as of February 2014. Therefore any future assessment must be based on current baseline data. 10.4.6 This appears to be a standard text paragraph and gives no useful data to the reader of the community.

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10.4.8 It is the council’s view that this section is incorrect. The development plans at Stoneleigh park are well established and have been in the public domain for a number of years. Furthermore both the developers and the council have made HS2 Ltd aware of the employment plans and significance of the site in sub regional economic terms. 10.4.11 The council does not agree with HS2’s assertion that there is no real impact on the employment opportunity on this site. Furthermore it is clear that HS2 Ltd. has failed to understand the current town and country planning regime. 10.5.4 The suggestion that operational employment will be generated in this area is nonsense as there are has no depots, stations or access to the rail line. 10.5.5 This appears to be a standard paragraph that takes no account of local character or access to the stations and depots on the line. It is meaningless for the community and economy of Stoneleigh, Kenilworth and Burton Green.

i) Sound, Noise & vibration Document: Volume 2: Community Forum Area Report. CFA 18: Stoneleigh, Kenilworth and Burton Green ES 3.2.1.18 Volume, page and paragraph Full ES Comment reference CFA 18. Page The construction of the tunnel at Burton Green has identified 218. 11.3.13 over 70 properties where an adverse effect will occur through both noise and vibration for a 12-16 months period. The Council have major concerns about the effect on residents of this area and also the lack of information on how this will be mitigated and managed. It is noted that four dwellings will be offered noise insulation, however, the Council seek assurances from HS2 that the work on addressing these problems will continue to ensure the impact is minimised for all properties.

CFA 18. Page Significant construction noise and vibration effects have been 219. 11.3.16 identified at Two Oakes Day Nursery from works associated with the Bockenden cutting. The Council are concerned about the impact this will have on the children and expect HS2 to work on providing further measures to mitigate the impact.

CFA 18. Page We believe that at the locations of the four dwellings identified 223. 11.4.17 as being entitled to noise insulation, there is the opportunity for HS2 to make further enhancements to the proposed mitigation that would lead to lower external level of noise.

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CFA 18. Page We have a major concern about the adverse impact from 224. 11.4.22 operational noise at Burton Green where there are some 35 properties identified as having a moderate effect. We believe that there is scope in the design of the green tunnel to provide a greater level of noise mitigation that would reduce the noise impact on the residents of Cromwell Lane and Hodgetts Lane.

The council made the following comment in the draft ES: “The route passes through the Stoneleigh Park, a site of national importance. The route of HS2 severs this site and will introduce noise and vibration to this site which houses rare and valuable livestock. The County Council urge HS2 to accurately analyse noise and vibration in this area, and where an increase in noise is identified or vibrations present, appropriate mitigation be provided.”

It is apparent that this point has not been addressed and the council reiterates its comment; The council has major concerns about the impact on Stoneleigh Park particularly during the construction phase. Although some mitigation proposals have been indicated, we urge HS2 to consider improving on these to ensure that a high degree of mitigation is obtained for a site of national importance. The council made the following comment in the draft ES: “We are concerned that where the proposed line runs through the Burton Green, train movements on this section will have a severe impact on the community and in particular on Burton Green Primary School. The County Council urge HS2 to accurately analyse noise in this area, and where an increase in noise is identified appropriate mitigation provided.”

It is apparent that this point has not been addressed and the council reiterates its comment; The council have major concerns about the effect on residents of this area and also the lack of information on how this will be mitigated and managed. We are concerned about the effect the construction of the green tunnel and expect HS2 to carry out a thorough structural survey of nearby dwellings and also to work closely with WCC to ensure that the noise impact is appropriately mitigated.

131 j) Traffic & Transport, incorporating PROW, highway design and traffic safety Document: Volume 2: Community Forum Area Report. CFA 18: Stoneleigh, Kenilworth and Burton Green ES 3.2.1.18 CA – CT-06-095. The B4115 Ashow Road has been re-aligned. As a Stoneleigh, result Public Footpath W158 no longer terminates on a public Kenilworth and highway. This makes the route an un-useable cul-de-sac. The Burton Green route must be continued to meet with the re-aligned road. CA – 5.4.11. The temporary re-alignment of W164 (the Kenilworth to Stoneleigh, Warwick University Connect 2 link) during construction is Kenilworth and unclear. It appears to be described as following the Kenilworth Burton Green Greenway and then Bridleway W165x although the numbering in the section suggests W165 (which does not exist). There is no indication on the associated plan CT-05-097 of the proposed temporary diversion. It is proposed by HS2 that W164 is diverted over the new bridleway bridge. Will this be in place at the start of construction to allow use of both W164 and W165x which are due to share the same crossing or is it the intention that both routes will be shut during construction, or that the diversion for W164 follows the existing route of W165x (and Cryfield Road) until such a time that the bridge is in place. The proposed temporary diversion of this important route needs to be clarified. The numbering of PROW must be accurate. CA – CT-05-098. PROW W167 has a significant re- Stoneleigh, alignment/diversion on both sides of HS2. At South Hurst Farm Kenilworth and there remains a stub which is not extinguished as part of the re- Burton Green alignment. This stub must be removed as it will leave an anomalous situation. CA – CT-06-098. The re-aligned W167 is not indicated on the plan on Stoneleigh, the opposite side of HS2 to South Hurst Farm. It is presumed Kenilworth and that if follows the line of new hedgerow planting. All routes must Burton Green be shown on plans and in such a situation it is unacceptable that they are not. CA – CT-06-098 and CT-06-099. The re-aligned W169 to the west of Stoneleigh, HS2 is shown differently on both plans with that on CT-06-098 Kenilworth and ending at the edge of the new Landscape Mitigation planting. Burton Green Consistency must exist throughout the drawings, particularly when used for reference purposes for longer routes.

k) Water Resources and Flood risk

The council has no comments to make on this section at this time

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CFA19: Coleshill Junction The council’s comments are addressed in the order they appear in the document and sub divided by topic to aid the reader’s understanding. Where the council has not provided comment, this should not be taken as agreement or consent for the text. The order of comments are:

The council does not wish to make comments on the following sections at this time: a) Agriculture The council has no comments to make on this section at this time. b) Air Quality The council has no comments to make on this section at this time. c) Community- incorporating health related issues Document: Volume 2: Community Forum Area Report. CFA 19: Coleshill Junction ES 3.2.1.19 Volume, page and paragraph Full ES comment reference

5.2.3 The council does not agree with HS2’s assessment that the worker accommodation will create no “significant effect.” Furthermore the cross reference to the COCP does not afford sufficient detail or transparency for this concern to be mitigated at this time 5.3.3 The council find it unacceptable that the town of Coleshill is largely excluded from the assessment. This decision does not reflect the reality of the cumulative effects that Coleshill will suffer 5.3.6 Gilson; the statements listed here fail to adequately express the damage to the village and significantly done play the impact on the residents of this area. The council find this approach to be unacceptable. 5.3.8 Again the exclusion of Water Orton as a community in the study belies the importance of the services to the community. 5.4.1 The council welcomes the acceptance that the Primary school will be 8th bullet point affected but feels that the commitment to date is insufficient mitigation for the impact on the school. Furthermore it expects HS2 to engage directly with the council to address this issue as a matter of urgency. 5.4.2 HGV movements near to the school are considered to be inappropriate due 6th bullet point to the safety issues and potential for damage to educational attainment from noise and vibration disruption. 5.4.4 The suggestion that Coleshill will not the affected during construction is incorrect and not grounded in fact.

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5.4.9 It is the council’s view that the treatment of Gilson as a community falls significantly short of what should be expected of from a national infrastructure project. 5.4.18 The council finds the definition of Grimstock Country House Hotel as a community asset unusual as it is a commercial business. This use of businesses in the sections concerning communities suggests lack of understanding by the report authors and a misrepresentation of the actual community assets. The council expects HS2 to address this. 5.4.36 The council find it unacceptable that HS2 identify long term isolation effects on the PROW and the school but fail to adequately mitigate the issues faced by the community. Furthermore there are areas of land identified by HS2 for replacement of the school appears to have not been assessed for suitability, nor has HS2 meaningfully engaged with the council on its proposals or plans. Therefore the council cannot accept this as appropriate migration. 5.5.2- 55.8 The council does not agree with HS2 Ltd.’s assessment that “no further mitigation measures are required.” It is the council’s view that it is incumbent on HS2 to demonstrate that its development has been fairly and reasonably mitigated. The ES does not provide that level of protection.

Health Draft ES document WCC HS2 Mitigation Public Health reference comment/observation on ES Warwickshire Draft ES Consultation amendments additional comments on final ES 2.1.9 page 13 It is unclear how the Insufficient detail There is a network of Proposed Scheme will provided in HIA. No public rights of way impact upon these vital evidence to suggest (PRoW) within the networks of public our original mitigation area including public footpaths that link the comments have been footpaths and small communities within considered, therefore byways that provide this area. Further HS2 MUST refer to connections information is needed original comments between the edge of regarding the impact that under WCC Birmingham (in may occur with respect to comment/observation Solihull) and both social isolation, community on Draft ES Coleshill and Water cohesion and health and Consultation (first Orton, linking to the wellbeing if the routes column). The hamlet of Gilson. were to be negatively avoidance of directly Recreational routes affected by the Proposed addressing these for walking and Scheme. issues is negligent to cycling also traverse the local population the area at Coleshill of Warwickshire. Road/Gypsy Lane. In the north of the area, there are local PRoW that skirt around the edge of fields to provide circuitous connections to Smith’s Wood from

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Gilson and Coleshill (footpaths M54 and M56). Green Lane (footpaths M77, M72, and M75) provides the main east-west route between Coleshill and Chelmsley Wood. Hall Walk (footpath M76) links Coleshill with the Birmingham Road area over a distance of approximately 1.5km via an existing bridge over the M42 carriageways and a subway beneath the M6. 2.1.18-2.1.22 page Adopted Local Plan and Insufficient detail 14 UDP policies strictly limit provided in HIA. No Coleshill open development in the green evidence to suggest spaces and belt to maintain the our original mitigation recreational facilities openness of the landscape comments have been and sports areas. and prevent coalescence considered, therefore Gilson rugby sports between the settlements HS2 MUST refer to pitches and, in the Solihull area, original comments Water Orton multiple the parishes of Smith’s under WCC recreation provisions Wood and Chelmsley comment/observation Lanchester Park and Wood. on Draft ES Bosworth’s Wood Consultation (first together comprise a Local policy P10 and P14 column). The large publicly requires developers to avoidance of directly accessible open maintain a healthy natural addressing these space and woodland environment and aims to issues is negligent to area in Smith’s protect and enhance the the local population Wood supporting a amenity of existing and of Warwickshire. range of activities proposed users. It is including children’s unclear how the Proposed play, skateboarding, Scheme will support these football and other and mitigate any losses to ball sports, dog- open spaces, playing walking and informal fields and woodlands. recreation through the woodland on It is recommended that a marked paths. There health impact assessment are also small areas is conducted including the of amenity green impact on physical activity space within the levels, weight, various residential cardiovascular and areas, as well as respiratory conditions and formal sports and mental health and playing fields linked wellbeing. Pre-exiting to educational conditions such as

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facilities. cardiovascular, arthritis, respiratory and back pain could be exacerbated leading to increased use of health services if adverse changes are made to the local walking routes. 2.3.13 page 23 While it is positive that Insufficient detail Lighting of site light pollution has been provided in HIA. No compounds during recognised, sleep evidence to suggest hours of darkness disturbance can have an our original mitigation would seek to adverse effect on health comments have been minimise light and wellbeing, and so we considered, therefore pollution to the would recommend that HS2 MUST refer to surrounding area. light pollution be kept to original comments recommended standards under WCC rather than sought to. comment/observation on Draft ES Consultation (first column). The avoidance of directly addressing these issues is negligent to the local population of Warwickshire. 3.2.3 and 3.2.5 It is unclear how the HS2 Insufficient detail page 37 project is going to support provided in HIA. No The emerging SMBC the local policy, particularly evidence to suggest Local Plan policies Policy P18: Health and our original mitigation are similar to those Well Being and NW11 and comments have been in the SUDP and key NW12 protection of the considered, therefore themes relating to natural environment. The HS2 MUST refer to environmental natural environment and original comments protection are access to the outdoors, under WCC retained. Policy P17: green spaces and comment/observation Countryside and recreational facilities are on Draft ES Green Belt continues important for health. Consultation (first to protect BMV column). The agricultural land from Further information is avoidance of directly development. Policy needed detailing how the addressing these P18: Health and project will support local issues is negligent to Well Being health policy and where it the local population introduces a series doesn’t what measures will of Warwickshire. of measures, one of be put into place to which is to provide minimise any negative opportunities for effect from the project on growing local the populations health. produce and resisting the loss of areas currently available for such cultivation.

Woodland and

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forestry are covered within Policies NW11 and NW12 dealing with nature conservation and the protection of the natural environment. 3.4.12 page 39 While it is positive to see Insufficient detail The whole area is a that measures have been provided in HIA. No Nitrate Vulnerable introduced to reduce evidence to suggest Zone where nitrate nitrogen losses from our original mitigation pollution is a agricultural sources to comments have been potential problem water, further detail is considered, therefore and measures have required as to what these HS2 MUST refer to been introduced to measures are. As the area original comments reduce nitrogen is a Nitrate Vulnerable under WCC losses from Zone and is dominated by comment/observation agricultural sources arable food crops, we on Draft ES to water would recommend that Consultation (first measures taken prevent column). The nitrogen losses as far as avoidance of directly possible rather than only addressing these reduce it. issues is negligent to the local population of Warwickshire. 3.5.8 page 41 Air pollution, particularly 5.4.2: The draft Insufficient detail Certain diversified dust from construction, CoCP includes provided in HIA. No enterprises such as could exacerbate existing a range of evidence to suggest such as office; respiratory or provisions that our original mitigation storage and cardiovascular conditions will also help comments have been manufacturing units; leading to an increase in mitigate considered, therefore and horse liveries, GP and acute hospital community HS2 MUST refer to would be particularly use. A health impact effects original comments sensitive to dust, assessment of the workers associated with under WCC noise and vibration on site and their living construction comment/observation during accommodation, as well within this area on Draft ES construction…these as of the local community (see Volume 5 Consultation (first issues are and affected properties is Appendix CT- column). The considered to be not recommended. 003- avoidance of directly significant. Continuous monitoring of 000), including: addressing these pollution levels at the site  appointment issues is negligent to during construction is also of the local population recommended, with the community of Warwickshire. implementation of further relations measures to mitigate any personnel pollution exceeding (draft minimum permitted levels. CoCP, Section 5);  community helpline to handle enquires from the public (draft

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CoCP, Section 5);  sensitive layout of construction sites to minimise nuisance (draft CoCP, Section 5);  where reasonably practical, maintenanc e of PRoW for pedestrians, cyclists and equestrians around the perimeter of construction sites and across entry and exit points (draft CoCP, Section 5);  specific measures in relation to air quality and noise will also serve to reduce impacts for the neighbourin g communitie s including discretionar y noise insulation for sensitive community resources and, in special circumstanc es, temporary

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rehousing (draft CoCP, Sections 7 and 13); and  where practicable, the avoidance of large good vehicles operating adjacent to schools during drop off and pick up periods (draft CoCP, Section 14).

4.4.2: contractors being required to manage dust, air pollution, odour and exhaust emissions during construction works;

8.4.1: the management of human exposure for both construction workers and people living and working nearby (draft CoCP Section 11); 4.2.3 page 43 It is unclear how the HS2 Insufficient detail The adopted Solihull project is going to support provided in HIA. No UDP sets policies to the local policies, evidence to suggest ensure that any new particularly Policy P10 on our original mitigation development a health environment and comments have been contributes positively P14 regarding protecting considered, therefore towards the the amenity of existing and HS2 MUST refer to

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Council’s proposed users. A good original comments environmental healthy natural under WCC objectives....the environment is vital to comment/observation importance of health and wellbeing. More on Draft ES improving air quality detailed information is Consultation (first in the borough is needed on how the project column). The addressed in will support local policies, avoidance of directly Policies P10, particularly focussing on addressing these requiring developers the health aspects and issues is negligent to to maintain a healthy where it doesn’t what the local population natural environment; measures will be put into of Warwickshire. and P14 regarding place to minimise any protecting and negative effect from the enhancing the project on the populations amenity of existing health. and proposed users. 4.4.12 page 46 Air pollution, particularly 5.4.2: The draft Insufficient detail Several locations dust from construction, CoCP includes provided in HIA. No have been identified could exacerbate existing a range of evidence to suggest in the study area, respiratory or provisions that our original mitigation which are cardiovascular conditions will also help comments have been considered to be leading to an increase in mitigate considered, therefore susceptible to GP and acute hospital community HS2 MUST refer to changes in air use. A health impact effects original comments quality and are in assessment of the workers associated with under WCC close proximity to on site and their living construction comment/observation roads that would be accommodation, as well within this area on Draft ES subject to as of the local community (see Volume 5 Consultation (first realignments or used and affected properties is Appendix CT- column). The by construction recommended. 003- avoidance of directly traffic. Continuous monitoring of 000), including: addressing these pollution levels at the site  appointment issues is negligent to during construction is also of the local population recommended, with the community of Warwickshire. implementation of further relations measures to mitigate any personnel pollution exceeding (draft minimum permitted levels. CoCP, Section 5);  community helpline to handle enquires from the public (draft CoCP, Section 5);  sensitive layout of construction sites to minimise nuisance (draft

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CoCP, Section 5);  where reasonably practical, maintenanc e of PRoW for pedestrians, cyclists and equestrians around the perimeter of construction sites and across entry and exit points (draft CoCP, Section 5);  specific measures in relation to air quality and noise will also serve to reduce impacts for the neighbourin g communitie s including discretionar y noise insulation for sensitive community resources and, in special circumstanc es, temporary rehousing (draft CoCP, Sections 7 and 13); and where practicable, the avoidance

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of large good vehicles operating adjacent to schools during drop off and pick up periods (draft CoCP, Section 14). 4.4.2: contractors being required to manage dust, air pollution, odour and exhaust emissions during construction works;

8.4.1: the management of human exposure for both construction workers and people living and working nearby (draft CoCP Section 11); 5.2.3 page 48 Further detail is required Insufficient detail There are also new as to the support of these provided in HIA. No policy themes, which policies by the Proposed evidence to suggest include the active Scheme and the measures our original mitigation promotion and that will be taken to avoid comments have been development of a disrupting or removing considered, therefore comprehensive access to the green HS2 MUST refer to network of high spaces and walking and original comments quality and cycling networks which are under WCC multifunctional green important in this rural area comment/observation spaces and corridors for both health and on Draft ES (Policy NW13). reducing social isolation. Consultation (first column). The 5.2.5 page 48 avoidance of directly Adopted Solihull addressing these UDP Policies T16 issues is negligent to and T17 promote the the local population maintenance and of Warwickshire. improvement of the

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walking and cycling network, including the co-ordination of route planning across borough boundaries.

9.2.3 page 74 Policy NW13 looks to developers to contribute to the maintenance, enhancement and/or creation of green infrastructure, defined as high quality, multifunctional green spaces, corridors and other environmental features. 5.2.6 page 48 Further information is 5.4.2: The draft Insufficient detail Smith’s Wood, required as to the impact CoCP includes provided in HIA. No Kingshurst and of the Proposed Scheme a range of evidence to suggest Fordbridge are both during construction provisions that our original mitigation located in a and on a long term rail will also help comments have been designated operation basis on this mitigate considered, therefore regeneration regeneration zone. community HS2 MUST refer to zone...which effects original comments commenced with the associated with under WCC construction of construction comment/observation Smith’s Wood within this area on Draft ES Community Primary (see Volume 5 Consultation (first School and would be Appendix CT- column). The completed with a 003- avoidance of directly new high street, 000), including: addressing these shops, community  appointment issues is negligent to facilities (including a of the local population health centre) and community of Warwickshire. offices. Allied to this, relations the emerging SMBC personnel Local Plan (draft envisages further CoCP, regeneration of Section 5); existing housing  community areas and helpline to redevelopment of handle the existing enquires community facilities from the public (draft CoCP, Section 5);  sensitive

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layout of construction sites to minimise nuisance (draft CoCP, Section 5);  where reasonably practical, maintenanc e of PRoW for pedestrians, cyclists and equestrians around the perimeter of construction sites and across entry and exit points (draft CoCP, Section 5);  specific measures in relation to air quality and noise will also serve to reduce impacts for the neighbourin g communitie s including discretionar y noise insulation for sensitive community resources and, in special circumstanc es, temporary rehousing (draft CoCP,

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Sections 7 and 13); and where practicable, the avoidance of large good vehicles operating adjacent to schools during drop off and pick up periods (draft CoCP, Section 14). 5.4.5 page 49 However, the adverse Insufficient detail Gilson has no other effect of the isolation on provided in HIA. No services and the community and an evidence to suggest residents are reliant individual level including our original mitigation upon neighbouring mental health and comments have been settlements for the wellbeing, social support, considered, therefore provision of essential employment, emergency HS2 MUST refer to services and vehicle access and access original comments facilities including to services needs further under WCC schools, assessment. A&E comment/observation convenience admissions could increase on Draft ES shopping and due to no GP or health Consultation (first healthcare. care access, causing column). The additional strain on the avoidance of directly acute health service. It is addressing these recommended that a issues is negligent to health impact assessment the local population be conducted, assessing of Warwickshire. all health and social aspects of the isolation due to the project.

Further information is required on how the construction phase will be handled to ensure minimal impact on the community, particularly concerning access to essential services and facilities that are located outside of the area. 5.5.1 page 49 While it is positive to see Insufficient detail Specific measures in that measures to minimise provided in HIA. No relation to air quality amenity impacts are to be evidence to suggest and noise would also put into place, it is also our original mitigation serve to minimise recommended that the comments have been amenity impacts on impact to health from air considered, therefore the neighbouring and noise pollution is HS2 MUST refer to communities. explored. original comments

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under WCC comment/observation on Draft ES Consultation (first column). The avoidance of directly addressing these issues is negligent to the local population of Warwickshire. 5.5.9 page 51 It is encouraging to see 5.4.2: The draft Insufficient detail At Gilson, 50 that the effect of CoCP includes provided in HIA. No properties are construction and the a range of evidence to suggest accessed via Gilson ensuing isolation of the provisions that our original mitigation Road.. Road access community of Gilson has will also help comments have been to Gilson would been recognised. mitigate considered, therefore experience However, the adverse community HS2 MUST refer to sequential disruption effect of the isolation on effects original comments during the the community and an associated with under WCC construction works individual level including construction comment/observation as the surrounding mental health and within this area on Draft ES roads are wellbeing, social support, (see Volume 5 Consultation (first temporarily employment, emergency Appendix CT- column). The closed...The vehicle access and access 003- avoidance of directly combination of to services needs further 000), including: addressing these construction activity assessment. A&E  appointment issues is negligent to on all sides of the admissions could increase of the local population community and the due to no GP or health community of Warwickshire. disrupted access care access, causing relations could result in additional strain on the personnel impacts on the acute health service. It is (draft community if not recommended that a CoCP, managed health impact assessment Section 5); appropriately to be conducted, assessing  community reduce severance all health and social helpline to from the nearest aspects of the isolation handle schools, childcare, due to the project. enquires healthcare and from the shops. Further detail is also public (draft required on the proposed CoCP, methods of how the Section 5); construction will be  sensitive managed appropriately in layout of order to minimise the construction impact on the community sites to in terms of health, social minimise and economic aspects. nuisance (draft CoCP, Section 5);  where reasonably practical, maintenanc

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e of PRoW for pedestrians, cyclists and equestrians around the perimeter of construction sites and across entry and exit points (draft CoCP, Section 5);  specific measures in relation to air quality and noise will also serve to reduce impacts for the neighbourin g communitie s including discretionar y noise insulation for sensitive community resources and, in special circumstanc es, temporary rehousing (draft CoCP, Sections 7 and 13); and where practicable, the avoidance of large good vehicles operating adjacent to schools during drop off and pick up periods

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(draft CoCP, Section 14). 5.6.2 page 52 While it is positive that Insufficient detail The assessment of impacts from transport, provided in HIA. No effects on amenity traffic, air quality etc. have evidence to suggest will draw upon the been recognised, it is our original mitigation findings of other important that the health comments have been technical disciplines effects of the Proposed considered, therefore (e.g. air quality, Scheme are also HS2 MUST refer to sound, noise and considered. A health and original comments vibration, landscape social impact assessment under WCC and visual, traffic is recommended. comment/observation and transport). The on Draft ES presence of in- Consultation (first combination impacts column). The from these other avoidance of directly disciplines could addressing these result in significant issues is negligent to amenity effects on a the local population number of of Warwickshire. community facilities and resources in the area. This will be reported in the formal ES. 6.4.10 page 54 It is recommended that a Insufficient detail The former medieval health impact assessment provided in HIA. No park at Coleshill and is conducted including the evidence to suggest Hall Walk, a historic impact on physical activity our original mitigation avenue, lie within the levels, weight, comments have been area of temporary cardiovascular and considered, therefore and permanent land respiratory conditions and HS2 MUST refer to take. mental health and original comments wellbeing. Pre-exiting under WCC conditions such as comment/observation cardiovascular, arthritis, on Draft ES respiratory and back pain Consultation (first could be exacerbated column). The leading to increased use of avoidance of directly health services if adverse addressing these changes are made to the issues is negligent to local walking routes. the local population of Warwickshire. 9.2.6 page 74 It is unclear how the HS2 Insufficient detail Policy P18: Health project is going to support provided in HIA. No and Well Being the local policy, particularly evidence to suggest introduces a Policy P18: Health and our original mitigation package of policy Well Being. Further comments have been considerations information is needed considered, therefore aimed at improving detailing how the project HS2 MUST refer to community health. will support local health original comments The policy includes policy and where it doesn’t under WCC reference to the role what measures will be put comment/observation of green into place to minimise any on Draft ES

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infrastructure in negative effect from the Consultation (first supporting health; project on the populations column). The and seeks to health. avoidance of directly safeguard and addressing these increase issues is negligent to opportunities for the local population local food production of Warwickshire. across the borough. 11.5.5 page 92 While it is positive to see 5.4.2: The draft Insufficient detail Further work is being that further work regarding CoCP includes provided in HIA. No undertaken to the effect of noise is being a range of evidence to suggest confirm significant undertaken, it is unclear provisions that our original mitigation construction noise whether this includes any will also help comments have been and vibration effects, work to examine the health mitigate considered, therefore including any effects from the community HS2 MUST refer to temporary effects construction noise and effects original comments from construction vibration for the local associated with under WCC traffic. community. A health construction comment/observation impact assessment is within this area on Draft ES recommended. (see Volume 5 Consultation (first Appendix CT- column). The 003- avoidance of directly 000), including: addressing these  appointment issues is negligent to of the local population community of Warwickshire. relations personnel (draft CoCP, Section 5);  community helpline to handle enquires from the public (draft CoCP, Section 5);  sensitive layout of construction sites to minimise nuisance (draft CoCP, Section 5);  where reasonably practical, maintenanc e of PRoW for

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pedestrians, cyclists and equestrians around the perimeter of construction sites and across entry and exit points (draft CoCP, Section 5);  specific measures in relation to air quality and noise will also serve to reduce impacts for the neighbourin g communitie s including discretionar y noise insulation for sensitive community resources and, in special circumstanc es, temporary rehousing (draft CoCP, Sections 7 and 13); and where practicable, the avoidance of large good vehicles operating adjacent to schools during drop off and pick up periods (draft CoCP, Section 14).

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11.6.4 page 93 Residential receptors have 5.4.2: The draft Insufficient detail Residential been identified as having a CoCP includes provided in HIA. No receptors within the significant adverse effect a range of evidence to suggest daytime 65dB from day and night HS2 provisions that our original mitigation contour, and noise. Although Noise will also help comments have been therefore the night- Insulation Regulations and mitigate considered, therefore time 55dB contour, WHO Night Noise community HS2 MUST refer to have been identified Guidelines are being used, effects original comments as being likely to we would recommend that associated with under WCC experience a target noise levels be construction comment/observation significant adverse aimed below this threshold within this area on Draft ES effect from HS2 to reduce the health and (see Volume 5 Consultation (first noise alone. wellbeing effects on Appendix CT- column). The residents in this rural area. 003- avoidance of directly 000), including: addressing these Measures taken to reduce  appointment issues is negligent to noise nuisance need to be of the local population detailed with expected community of Warwickshire. effectiveness data given in relations order to demonstrate they personnel meet the permitted noise (draft levels. We also CoCP, recommend continued Section 5); noise monitoring in this  community area during construction helpline to and after the project is handle complete. enquires from the public (draft CoCP, Section 5);  sensitive layout of construction sites to minimise nuisance (draft CoCP, Section 5);  where reasonably practical, maintenanc e of PRoW for pedestrians, cyclists and equestrians around the perimeter of construction sites and across entry

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and exit points (draft CoCP, Section 5);  specific measures in relation to air quality and noise will also serve to reduce impacts for the neighbourin g communitie s including discretionar y noise insulation for sensitive community resources and, in special circumstanc es, temporary rehousing (draft CoCP, Sections 7 and 13); and where practicable, the avoidance of large good vehicles operating adjacent to schools during drop off and pick up periods (draft CoCP, Section 14). 11.6.13 page 98 It is recommended that the Insufficient detail Improvements in the health impacts from provided in HIA. No performance of airborne noise are also evidence to suggest mitigation that may assessed so that they are our original mitigation further reduce or taken into account when comments have been avoid the potential considering the mitigation. considered, therefore significant airborne HS2 MUST refer to

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noise effects are original comments being considered for under WCC the formal ES. comment/observation on Draft ES Consultation (first column). The avoidance of directly addressing these issues is negligent to the local population of Warwickshire. 12.5.15 page 98 While a survey has been Insufficient detail A total of seven completed it is unclear provided in HIA. No PRoW would either how the survey was evidence to suggest be diverted or completed. The number of our original mitigation temporarily closed 70 people per day using comments have been during the the facilities is not an considered, therefore construction period insignificant number as HS2 MUST refer to (subject to implied, given the rural original comments consultation with the nature and small under WCC Local Authority). The populations in the comment/observation numbers of users surrounding areas. It is on Draft ES have been identified recommended that a Consultation (first during surveys community consultation column). The undertaken in and a health impact avoidance of directly August and assessment is completed addressing these September 2012 as in order to assess the true issues is negligent to noted above. Of impact on health, including the local population these seven PRoW, mental health and of Warwickshire. five have been wellbeing and the impact identified with user on community cohesion, numbers below ten particularly social isolation, per day. The due to the loss of these remaining two which routes in this rural area. are used more frequently are detailed below:M43 – Attleboro Farm with 19 pedestrian and nine cycle users; and M77 – Link from Ryeclose Croft under the M6 (Green Lane Track) with 19 pedestrian and one disabled user.

12.5.16 page 98 The length of the diversions will be kept to a minimum where reasonably practicable. The impact of all

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diversions is not considered significant because of the few people that would be affected (less than 70 people per day per PRoW).

12.4.6 page 96 All PRoW which would be intersected by the proposed route were surveyed. As appropriate, these covered weekday and weekend use. A total of 23 PRoW have been identified consisting of public footpaths, bridleways and cycle ways. The surveys indicate that none of the roads, footpaths, bridleways and cycle ways that would cross the proposed routes are used by more than 70 people per day walking, cycling or riding. d) Culture & Heritage Document: Volume 2 CFA19 Coleshill Junction, Community Area Forum Report ES 3.2.1.19 Volume, page and Full ES comment paragraph reference pgs. 89-90 This paragraphs states that the assessment has considered the 6.2.3 intra-project effects of a number of technical topic assessments such as landscape and visual, ecology and water resources and flood risk and that these interactions have been included in the assessment of impacts and effects.

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pg. 90 Not all of the areas identified in the Archaeological Risk Model 6.2.4 as being priority sites for survey in order to inform the EIA were available for survey. This is identified in this paragraph as a limiting factor for the EIA.

Disappointingly, the Archaeological Risk Model referenced in this paragraph has not been reproduced in the ES.

In particular, we cannot assess the degree to which the lack of survey referred to in this paragraph has limited the assessment detailed in the ES. pg. 90 Non-intrusive field survey is limited to five discreet areas 6.2.5 (CN020 Land off Birmingham Road (B4114), near Coleshill, CN022 Land off Manor Drive, between Kingshurst, CN023 Land between Manor Drive and the M42, near Coleshill, CN025 Land off Gilson Drive, near Coleshill and CN026 Land off Sutton Road (A429), near Drayton Bassett). This represents a very limited sample of the areas to be disturbed by this scheme and does not provide sufficient information to characterise the likely extent and nature of potential sub surface archaeological assets across this CFA. pg. 90 The full extent (including which areas were visited) of the 6.3.2 walkovers and site reconnaissance undertaken to inform this assessment is not set out in the ES, nor the timing or ground conditions at the time of these visits. We cannot therefore assess the adequacy of this aspect of the Environmental Impact Assessment. pg. 100 We do not agree with the statement that ‘There will be no 6.5.2 physical impacts on buried archaeological remains or other heritage assets arising from the operation of the Proposed Scheme’.

There is a potential for vibrations etc. associated with the operation of the railway to have a direct impact upon buried and upstanding heritage assets.

There is insufficient information available at this time to enable any such impacts to be ruled out.

6, Throughout There is limited consideration throughout this document to the impacts that the proposed development may have upon the historic landscape character of this CFA.

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e) Ecology The council has made its views on this section known in the commentary submitted for volume 1,

156 f) Land Quality Document: Volume 2 CFA19 Coleshill Junction, Community Area Forum Report ES 3.2.1.19 Volume, page and Full ES comment paragraph reference 8.4.35 Mitigation of A large section of the route in this CORRECTION – The mineral the effects on CFA appears to be underlain by sand planning authority is mineral resources and gravel. WCC strongly disagrees Warwickshire County Council can include prior that there would be a minor adverse (WCC), not Staffordshire extraction of the impact upon the sand and gravel County Council (SCC). resource for use resource. To prevent the unnecessary within the project sterilisation of the resource for or elsewhere…A posterity, WCC (as a Minerals plan will be Planning Authority) expects to see an discussed and assessment that examines whether agreed in advance prior extraction of the mineral in of the construction advance of the development is works with the “practicable and environmentally landowner, the feasible” (para. 143, NPPF). WCC mineral planning would expect borehole evidence to be department at SCC used as part of the assessment to and any other provide an indication of quality and interested parties depth of the deposit, particularly when to assist in such areas may be considered as achieving an borrow pits. This is particularly effective important given that most MPAs along management of the route are unable to meet the minerals within the minimum 7 year sand and gravel affected location of landbank, as required in the NPPF the MSA. (Warwickshire’s is currently around 3 years). Every effort should therefore be made to extract the mineral in advance of the development in order to prevent the sterilisation of the resource for posterity. This approach would accord with the adopted development plan policies for both Warwickshire County Council and Solihull Metropolitan Borough Council.

157 g) Landscape & visual assessment Document: Volume 2 CFA19 Coleshill Junction, Community Area Forum Report ES 3.2.1.19 Volume, page Full ES comment and paragraph reference para. 9.3.4 and Map references do not tie in with the Map Book. 9.4.13 para. 9.4.9 - This down plays the magnitude of change and with the anomaly 9.4.10 and in sensitivity (see note for Vol. 5 Technical Appendices (LVIA) 9.5.12-15 CFA 19, p.12) may result in an incorrect categorisation of overall effect. para 9.5.18 Error – this says “medium sensitivity of the character area …” and yet the baseline description says “high” sensitivity. para 9.5.65 This makes no reference to the fact that the Proposed Scheme will be viewed against the skyline and will therefore be more prominent and have a higher magnitude. This will be the case for all viewpoints in all CFAs where the scheme is viewed against the skyline. para 9.5.91 This refers to the magnitude of change being reduced by vegetation bordering the school. However it appears from the maps that the existing vegetation is likely to be removed. If this is correct then it can’t be relied upon to reduce the magnitude of change.

h) Socio Economic Document: Volume 2 CFA19 Coleshill Junction, Community Area Forum Report ES 3.2.1.19 10.4.3 & 10.4.4 The council does not agree with the assertion that no none agricultural businesses will suffer the effects of isolation.

The HS2 sturdy area fails to take account of the cumulative impact of the rail head at its southern side on the road network and people’s tolerance for traffic queues to access tourism businesses located at Kingsbury Water Park. Whilst the park is outside of the study area, it is served by J9 of the M42 and the A446 and the b road in and around the area. The council has previously made representation to HS2 under the Phase 2 consultation to treat this area as a Special Management Zone because of the intensity and duration of the works for HS2.

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The consistent down playing of the effects in this area belies the real impact that will be felt by the business community; furthermore the suggestion that there are no ongoing effects is incorrect.

i) Sound, Noise & vibration Document: Volume 2 CFA19 Coleshill Junction, Community Area Forum Report ES 3.2.1.19 Volume, Full ES comment page and paragraph reference

CFA 19. We have concerns about the significant impact during construction Page 193. works associated with the Attleboro Lane overbridge and 11.3.5 embankment works at Coleshill Junction on the south side of Water Orton. We expect HS2 to fulfil the commitment to provide taller noise barriers as detailed in the draft CoCP to ensure the impact at Water Orton Primary school and Attleboro Lane is minimised.

CFA 19. We have concerns about the significant impact during construction Page 194. from the works associated with the Gilson cutting and Gilson 11.4.6 embankment and from construction traffic using Gilson Lane. Increases in noise of 7 dB and levels of up to 75 dB are not acceptable and we expect HS2 to incorporate within the scheme design additional measures to improve the level of mitigation. Previously in the DES, the council stated: it is concerned that where the proposed line runs adjacent to the village of Water Orton, we believe that the train movements on this section will have a severe impact on the community and in particular Water Orton Primary School. The County Council urge HS2 to accurately analyse noise in this area, and where an increase in noise is identified, significant appropriate mitigation be provided.

It would appear that no new evidence has been presented and therefore, the council expects HS2 to carry out a full assessment of the noise impact on the school and to ensure that the proposed “taller” screening as identified in 5.4.1 page 78 is fit for purpose and ensures that noise levels meet the criteria as detailed in the Acoustic Performance Standards for the Priority Schools Building Programme. Where that is not the case, the council expects an alternative resource and provision to be provided.

159 j) Traffic & Transport incorporating; PROW, highway design and traffic safety. Document: Volume 2 CFA19 Coleshill Junction, Community Area Forum Report ES 3.2.1.19 Volume, page Full ES comment and paragraph reference

CA – Coleshill General – Although on first sight the proposed PROW appear to Junction enhance the network of routes in the delta area there are issues with them. The proposed bridleway has no adjacent bridleways and is a route around the edge of the M42/M6 link and therefore provides very little amenity value. It is unclear what the value of this route is and in the area has the potential to be abused. The PROW in the area are allegedly used as crime escape routes and any extra connectivity would be unwelcome from the perspective of crime prevention personnel in the area (apparently). WCC would like the proposed bridleway removed from the plans and would like other routes reconsidered and removed, particularly any new routes. CA – Coleshill CT-06-110. Footpath M54 is not indicated as being stopped up Junction where it crosses the proposed line of HS2 presumably because it passes under the viaduct. The Hybrid Bill plans and sections books Sheet no 6-22 do show it as being stopped up. Hence a mis-match between different areas of HS2. Which one is correct? General Where PROW co-exist with new private routes/drives or new haul routes etc. there must be some indication of where about the PROW actually exists or the whole width will have to be assumed for the purposes of the information held in the Definitive Map and Statement. General When PROW are diverted/re-aligned, the width, surface and any limitations must be agreed in advance with WCC and should be specified in any Orders so that the Definitive Map and Statement contains as much information as necessary. Any width must conform to or exceed the requirement given in the Rights of Way and Recreational Highway Strategy which forms part of the Local Transport Plan. Appropriate policies can be found within the Strategy and include (but not limited to) RW2, RW2a, RW5c and RW6. k) Water resources and Flood Risk The council has no comments to make on this section at this time

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CFA 20: Curdworth – Middleton The council’s comments are addressed in the order they appear in the document and sub divided by topic to aid the reader’s understanding. Where the council has not provided comment, this should not be taken as agreement or consent for the text. The order of comments are:

5.2.2 – worker The council is not satisfied that the statement suggesting that there will be no significant accommodation effects associated with the construction worker encampments in this area is accurate. The interface of Phase One and Phase Two will mean a generation of disruption based on the current published timetable. This duration will mean that there are inevitable significant effects. 5.3.19 The assessment of Bodymoor Heath fails to take account of the cumulative effects of HS2 and makes no mention of the impact of the rail head and the subsequent Phase two development. This linear approach to assessment again significantly down plays and belies the true impact on the community in North Warwickshire 5.3.20 The decision not to assess the impact on the tourism assets near to and at Kingsbury Water Park demonstrate a completely disregard for the value these bring to the local community and economy. Furthermore to suggest that HS2’s activity in this area will have no effect on tourism demonstrates a complete failure to understand the operation and sensitivity of users to disruption.

It is the council’s view that HS2’s assessment in this matter is deficient and derelict.

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5.4.32 - .35 Middleton – temporary effects; it is the council’s view that HS2 have incorrectly assessed the temporary impact on Middleton as a community. By identifying individual properties HS2 have failed to consider the effect it will have on the community as a whole.

Health related Issues Document: Volume 2: Community Forum Area Report. CFA 20: Curdworth to Middleton ES 3.2.1.20 Draft ES document WCC HS2 Mitigation Public Health reference comment/observation on ES Warwickshire Draft ES Consultation amendments additional comments on final ES 2.3.19 page 22 While it is positive that light Insufficient detail Lighting of site pollution has been provided in HIA. No compounds during recognised, sleep evidence to suggest hours of darkness disturbance can have an our original would seek to adverse effect on health mitigation minimise light and wellbeing, and so we comments have pollution to the would recommend that been considered, surrounding area. light pollution be kept to therefore HS2 recommended standards MUST refer to rather than sought to. original comments under WCC comment/observati on on Draft ES Consultation (first column). The avoidance of directly addressing these issues is negligent to the local population of Warwickshire. 3.2.2 page 34 It is unclear how the HS2 Insufficient detail The adopted NWBC project is going to support provided in HIA. No Local Plan Core the local policy, particularly evidence to suggest Policy 10: Agriculture Policy 10 and ENV6 our original and the Rural regarding supporting and mitigation Economy supports protecting agricultural land comments have agriculture and and maintaining soil been considered, promotes agricultural quality. Further information therefore HS2 diversification is required to demonstrate MUST refer to activities where they how the construction of the original comments can help to underpin Proposed Scheme will not under WCC the rural adversely impact pollution comment/observati economy...Policy or soil contamination in the on on Draft ES ENV6: Land area, particularly in terms Consultation (first Resources includes of food production. column). The protection of the best avoidance of and most versatile It is unclear what impact directly addressing (BMV) agricultural the Proposed Scheme will these issues is land, as well as have upon the open green negligent to the

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setting out a series spaces and community local population of of pollution facilities. It is important to Warwickshire. prevention measures recognise the health that would contribute impact of these spaces to to maintaining soil physical activity, quality. Forestry and respiratory condition woodland are management, weight included in policies management and mental relating to health. conservation and recreation in the countryside... dealing with nature conservation and the protection of the natural environment. 3.4.11 page 37 While it is positive to see Insufficient detail The whole area is a that measures have been provided in HIA. No Nitrate Vulnerable introduced to reduce evidence to suggest Zone where nitrate nitrogen losses from our original pollution is a agricultural sources to mitigation potential problem water, further detail is comments have and measures have required as to what these been considered, been introduced to measures are. As the area therefore HS2 reduce nitrogen is a Nitrate Vulnerable MUST refer to losses from Zone and is dominated by original comments agricultural sources arable food crops, we under WCC to water. would recommend that comment/observati measures taken prevent on on Draft ES nitrogen losses as far as Consultation (first possible rather than only column). The reduce it. avoidance of directly addressing these issues is negligent to the local population of Warwickshire. 3.5.10 page 38 Air pollution, particularly 4.4.2: The Insufficient detail The three holdings dust from construction, assessment has provided in HIA. No that use irrigation for could exacerbate existing assumed that evidence to suggest crops, including respiratory or the general our original potatoes, are cardiovascular conditions measures mitigation sensitive to dust. In leading to an increase in detailed in comments have addition, a number of GP and acute hospital use. Section 7 of the been considered, holdings have A health impact draft CoCP therefore HS2 diversified assessment of the workers (Volume 5: MUST refer to enterprises, on site and their living Appendix CT- original comments including varied accommodation, as well as 003-000) will be under WCC commercial uses of of the local community and implemented. comment/observati farm buildings and affected properties is These include: on on Draft ES yards, a farm shop, recommended. Continuous  contractors Consultation (first stabling and a carp monitoring of pollution being column). The fishing lake (Cuttle levels at the site during required to avoidance of Mill) where dust, construction is also manage directly addressing noise and vibration recommended, with the these issues is

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could cause implementation of further dust, air negligent to the problems. measures to mitigate any pollution, local population of pollution exceeding odour and Warwickshire. minimum permitted levels. exhaust emissions during construction works;  inspection and visual monitoring after engagement with the local authorities to assess the effectiveness of the measures taken to control dust and air pollutant emissions;  cleaning (including watering) of haul routes and designated vehicle waiting areas to suppress dust;  keeping soil stockpiles away from sensitive receptors where reasonably practicable, also taking into account the prevailing wind direction relative to sensitive receptors;  using enclosures to contain dust emitted from

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construction activities; and  undertaking soil spreading, seeding and planting of completed earthworks as soon as reasonably practicable following completion of earthworks. 4.2.2 page 41 It is unclear how the HS2 Insufficient detail The NWBC Local project is going to support provided in HIA. No Plan provide the the local policy, particularly evidence to suggest policies that are ENV9 regarding air quality. our original applicable in the Air pollution causes ill mitigation borough. The health and further comments have principal adopted information is required to been considered, Local Plan policy of demonstrate how the therefore HS2 relevance to air construction of the MUST refer to quality is Policy Proposed Scheme will not original comments ENV9: Air Quality. adversely impact on air under WCC This policy is quality in the area. comment/observati committed to on on Draft ES safeguarding and Consultation (first enhancing air quality column). The in the Borough and it avoidance of includes reference to directly addressing not permitting these issues is polluting forms of negligent to the development within local population of or adjacent to Air Warwickshire. Quality Management Areas (AQMAs). Policy ENV11: Neighbour Amenities does not permit development where it entails significant loss of amenity for nearby occupiers, citing dust or fumes within the list of factors to be considered. 4.4.6 page 42 Air pollution, particularly 4.4.2: The Insufficient detail Several locations dust from construction, assessment has provided in HIA. No have been identified could exacerbate existing assumed that evidence to suggest in the study area that respiratory or the general our original

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are considered cardiovascular conditions measures mitigation susceptible to leading to an increase in detailed in comments have changes in air quality GP and acute hospital use. Section 7 of the been considered, and are in close A health impact draft CoCP therefore HS2 proximity to roads assessment of the workers (Volume 5: MUST refer to that would be subject on site and their living Appendix CT- original comments to realignment or accommodation, as well as 003-000) will be under WCC used by construction of the local community and implemented. comment/observati traffic. affected properties is These include: on on Draft ES recommended. Continuous  contractors Consultation (first monitoring of pollution being column). The levels at the site during required to avoidance of construction is also manage directly addressing recommended, with the dust, air these issues is implementation of further pollution, negligent to the measures to mitigate any odour and local population of pollution exceeding exhaust Warwickshire. minimum permitted levels. emissions during construction works;  inspection and visual monitoring after engagement with the local authorities to assess the effectiveness of the measures taken to control dust and air pollutant emissions;  cleaning (including watering) of haul routes and designated vehicle waiting areas to suppress dust;  keeping soil stockpiles away from sensitive receptors where reasonably

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practicable, also taking into account the prevailing wind direction relative to sensitive receptors;  using enclosures to contain dust emitted from construction activities; and undertaking soil spreading, seeding and planting of completed earthworks as soon as reasonably practicable following completion of earthworks. 5.2.2 page 45 It is unclear what impact Insufficient detail The adopted NWBC the Proposed Scheme will provided in HIA. No Local Plan policies have upon the open green evidence to suggest generally seek to spaces and community our original resist the loss of facilities. It is important to mitigation existing community recognise the health comments have facilities, open space impact of these spaces to been considered, and formal sports physical activity, therefore HS2 and recreation respiratory condition MUST refer to provision except management, weight original comments where they are management and mental under WCC shown to be surplus health. comment/observati to requirements on on Draft ES and/or would be Consultation (first replaced to at least column). The equivalent quality avoidance of and quantity as part directly addressing of development these issues is proposals (Policies negligent to the ENV5, COM2 and local population of COM3). Warwickshire.

5.2.4 page 45 There are also new policy themes, which include the active

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promotion and development of a comprehensive network of high quality and multifunctional green spaces and corridors (Policy NW13). 5.4.6 page 46 While it is recognised that Insufficient detail Lea Marston lies residents in the area are provided in HIA. No within the study area dependent upon travelling evidence to suggest to the east of the to other areas for services, our original Proposed Scheme further assessment is mitigation and is primarily a needed as to the effect the comments have residential village project may have on been considered, that lacks any day- accessing these services. therefore HS2 to-day facilities, For example, if GP MUST refer to meaning that surgeries and healthcare original comments residents are reliant access is negatively under WCC upon neighbouring affected A & E admissions comment/observati settlements for the may increase due to its on on Draft ES provision of essential use as an alternative (and Consultation (first services and possibly inappropriate) column). The facilities, including source of health care. avoidance of schooling, Health in the community directly addressing convenience may deteriorate if access these issues is shopping and to healthcare is negligent to the healthcare. compromised so when local population of care is sought the outcome Warwickshire. is poorer for the individual. These could increase A & E waiting times and admission to the acute sector. 5.4.10 - 5.4.14 page Further information is Insufficient detail 47 required as to how the provided in HIA. No Outdoor space, impact on these facilities evidence to suggest public footpaths, will be mitigated, our original recreation facilities particularly with regards to mitigation and tourist the health benefits of such comments have attractions. facilities, and the been considered, alternatives that will be therefore HS2 provided if there is an MUST refer to unavoidable loss of open original comments spaces and community under WCC facilities. Some of the comment/observati paths connect local on on Draft ES villages and the loss of Consultation (first these could lead to column). The increased social isolation, avoidance of reduced community directly addressing cohesion and increased these issues is mental health conditions. A negligent to the health and social impact local population of assessment is Warwickshire.

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recommended. 5.5.2 page 48 While it is positive to see Insufficient detail Specific measures in that measures will be provided in HIA. No relation to air quality taken in relation to air evidence to suggest and noise would quality and noise, we our original serve to reduce would recommend that it is mitigation amenity impacts on ensured that measures comments have the neighbouring ensure levels of noise and been considered, communities. air pollution are below the therefore HS2 recommended level rather MUST refer to than solely reducing them. original comments A health impact under WCC assessment is also comment/observati recommended. on on Draft ES Consultation (first column). The avoidance of directly addressing these issues is negligent to the local population of Warwickshire. 5.5.10 page 49 It is encouraging to see Insufficient detail At Middleton, more that the effect of provided in HIA. No than 50 construction and the evidence to suggest properties...would ensuing isolation of the our original experience community of Gilson has mitigation sequential disruption been recognised. comments have during the However, the adverse been considered, construction works. effect of the isolation on therefore HS2 The combination of the community and an MUST refer to construction activity individual level including original comments to the east and south mental health and under WCC of the village and the wellbeing, social support, comment/observati interrupted access employment, emergency on on Draft ES would result in vehicle access and access Consultation (first isolation of the to services needs further column). The community, assessment. A&E avoidance of particularly from the admissions could increase directly addressing nearest schools, due to no GP or health these issues is healthcare and care access, causing negligent to the supermarkets, which additional strain on the local population of are in Kingsbury to acute health service. It is Warwickshire. the south-east. This recommended that a would be a moderate health impact assessment adverse isolation be conducted, assessing effect and is all health and social therefore considered aspects of the isolation to be significant in due to the project. the context of the community. Further detail is also required on the proposed methods of how the construction will be managed appropriately in

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order to minimise the impact on the community in terms of health, social and economic aspects. 5.5.14 page 50 It is unclear what Insufficient detail Dunton Stables is a measures will be taken by provided in HIA. No well-used resource the Proposed Scheme to evidence to suggest that relies on the mitigate the significant our original availability of outdoor adverse effects of the mitigation exercise space and temporary and permanent comments have the ability to access loss of land. The been considered, and use the bridleways and towpath therefore HS2 continuous network are important parts of MUST refer to created by the outdoor space, which are original comments surrounding important for good health under WCC bridleways and canal and wellbeing, particularly comment/observati towpath to deliver for physical activity and on on Draft ES teaching and mental health. The impact Consultation (first trekking activities. on the local economy, column). The The land take would including to the owners avoidance of impair the and local employment, is directly addressing functionality of the also important in this rural these issues is operation and have a area. A health, social and negligent to the moderate adverse economic impact local population of effect on users of the assessment is Warwickshire. stables and this is recommended as to the considered effects of the land loss. significant in the local context. 5.5.17 page 50 It is recommended that a Insufficient detail At Middleton, there community consultation provided in HIA. No are several and a health impact evidence to suggest community assessment is completed our original facilities… A in order to assess the true mitigation proportion of regular impact on health, including comments have users originating mental health and been considered, from outside wellbeing and the impact therefore HS2 Middleton are likely on community cohesion, MUST refer to to rely on access particularly social isolation, original comments from the A4091 via due to the loss of these under WCC Church Lane or Park routes in this rural area. comment/observati Lane and Vicarage on on Draft ES Hill/Crowberry Lane. Consultation (first Road access column). The between the village avoidance of and the A4091 would directly addressing experience these issues is sequential disruption negligent to the during the local population of construction works Warwickshire. as surrounding roads are temporarily closed for the erection of bridging structures…The

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combination of construction activity to the east and south of the village and the interrupted access would result in partial isolation of these three community resources from some of the relevant users that they typically serve on at least a weekly basis. This would be a moderate adverse isolation effect and is therefore considered to be significant in the context of the community. 5.5.19 page 50 While it is positive that Insufficient detail The incidence of impacts on community provided in HIA. No significant effects, amenity have been evidence to suggest including in- recognised, it is important our original combination effects, that the health effects of mitigation on community the Proposed Scheme are comments have amenity will be also considered. A health been considered, considered and, and social impact therefore HS2 where significant, assessment is MUST refer to reported in the recommended. original comments formal ES. under WCC comment/observati on on Draft ES Consultation (first column). The avoidance of directly addressing these issues is negligent to the local population of Warwickshire. 5.6.2 page 51 While it is positive that Insufficient detail The presence of in- impacts from transport, provided in HIA. No combination impacts traffic, air quality etc. have evidence to suggest from these other been recognised, it is our original disciplines could important that the health mitigation result in significant effects of the Proposed comments have amenity effects on a Scheme are also been considered, number of considered. A health and therefore HS2 community facilities social impact assessment MUST refer to and resources in the is recommended. original comments area. under WCC This will be reported comment/observati in the formal ES. on on Draft ES Consultation (first

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column). The avoidance of directly addressing these issues is negligent to the local population of Warwickshire. 9.2.3 page 76 It is unclear how the HS2 Insufficient detail Local plan Policy project is going to support provided in HIA. No NW13 looks to the local policy, particularly evidence to suggest developers to NW13 on the maintenance our original contribute to the and creation of green mitigation maintenance, spaces. Green spaces are comments have enhancement and/or important for health, been considered, creation of green particularly physical therefore HS2 infrastructure, activity, weight MUST refer to defined as high management and mental original comments quality, health and wellbeing. under WCC multifunctional green Further information is comment/observati spaces, corridors needed detailing how the on on Draft ES and other project will support this Consultation (first environmental policy and where it doesn’t column). The features, with the what measures will be put avoidance of Birmingham and into place to minimise any directly addressing Fazeley Canal and negative effect from the these issues is Kingsbury Water project on the populations negligent to the Park within the list of health. local population of green infrastructure Warwickshire. assets. 11.5.5 page 94 While it is positive to see Insufficient detail Further work is being that further work regarding provided in HIA. No undertaken to the effect of noise is being evidence to suggest confirm significant undertaken, it is unclear our original construction noise whether this includes any mitigation and vibration effects, work to examine the health comments have including any effects from the been considered, temporary effects construction noise and therefore HS2 from construction vibration for the local MUST refer to traffic. community. A health original comments impact assessment is under WCC recommended. comment/observati on on Draft ES Consultation (first column). The avoidance of directly addressing these issues is negligent to the local population of Warwickshire. 11.6.4 page 94 Residential receptors have Insufficient detail Residential receptors been identified as having a provided in HIA. No within the daytime significant adverse effect evidence to suggest 65dB contour, and from day and night HS2 our original

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therefore the night- noise. Although Noise mitigation time 55dB contour, Insulation Regulations and comments have have been identified WHO Night Noise been considered, as being likely to Guidelines are being used, therefore HS2 experience a we would recommend that MUST refer to significant adverse target noise levels be original comments effect from HS2 aimed below this threshold under WCC noise alone. to reduce the health and comment/observati wellbeing effects on on on Draft ES residents in this rural area. Consultation (first column). The Measures taken to reduce avoidance of noise nuisance need to be directly addressing detailed with expected these issues is effectiveness data given in negligent to the order to demonstrate they local population of meet the permitted noise Warwickshire. levels. We also recommend continued noise monitoring in this area during construction and after the project is complete. 11.6.10 page 95 Although it is stated that Insufficient detail The envisaged the envisaged mitigates provided in HIA. No mitigation (especially will substantially reduce evidence to suggest landscape the potential airborne our original earthworks and sounds, it is not stated or mitigation noise barriers) clear how reduced the comments have described in this noises will and whether the been considered, chapter substantially noise levels will therefore therefore HS2 reduces the potential fall below the permitted MUST refer to airborne sound noise level. original comments impacts and noise under WCC effects that would comment/observati otherwise arise from on on Draft ES the Proposed Consultation (first Scheme. Noise disturbance has column). The multiple negative effects avoidance of Nonetheless, on the health and directly addressing potential significant wellbeing of individuals, these issues is adverse airborne particularly concerning negligent to the noise effects have mental health and the local population of been identified for effects of sleep Warwickshire. residential receptors disturbance. Additional detail is needed on the 11.6.13 page 96 effectiveness of the It is estimated that envisaged mitigates and two dwellings – what measures are going marked SV20-D01 to be taken in specific on maps SV-01 – relation to communities would potentially identified as SV20-C01 on experience noise maps SV-01 who will levels higher than experience noise the insulation trigger exceeding day and night

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level. time targets during construction and on a long term basis from railway operation, in order to minimise the health effects.

It is recommended that monitoring of noise at this site continue during construction and after completion. 12.4.6 page 99 While a survey has been Insufficient detail All PRoW which completed it is unclear provided in HIA. No would be intersected how the survey was evidence to suggest by the proposed completed. The number of our original route have been 50 people per day using mitigation surveyed. A total of the facilities is not comments have 17 PRoW have been necessarily a small been considered, identified consisting number as implied, given therefore HS2 of public footpaths, the rural nature and small MUST refer to bridleways and populations in the original comments cycleways. The surrounding areas. It is under WCC surveys indicate that recommended that a comment/observati none of the roads, community consultation on on Draft ES footpaths, bridleways and a health impact Consultation (first and cycleways that assessment is completed column). The would cross the in order to assess the true avoidance of proposed route are impact on health, including directly addressing used by more than mental health and these issues is 50 people per day wellbeing and the impact negligent to the walking, cycling or on community cohesion, local population of horse riding. particularly social isolation, Warwickshire. due to the loss of these routes in this rural area. d) Culture & Heritage Document: Volume 2: Community Forum Area Report. CFA 20: Curdworth to Middleton ES 3.2.1.20 Volume, page Full ES comment and paragraph reference p.91 It is not clear to what the statement “any assets within the 10mm settlement contour are 6.2.2 included within the assessment” refers.

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pg. 92 This paragraphs states that the assessment has considered the intra-project effects of a 6.2.3 number of technical topic assessments such as landscape and visual, ecology and water resources and flood risk and that these interactions have been included in the assessment of impacts and effects.

There is little evidence of this presented in the ES. Whilst landscape and visual assessments have contributed to the assessment of cultural heritage impacts (although this has primarily been in respect of the impacts upon the setting of heritage assets rather than impacts on buried archaeological remains), there is little reference in the cultural heritage chapters and documents to ecology and water resources and flood risk. pg.88 Not all of the areas identified in the Archaeological Risk Model as being priority sites for 6.2.4 survey in order to inform the EIA were available for survey. This is identified in this paragraph as a limiting factor for the EIA.

Disappointingly, the Archaeological Risk Model referenced in this paragraph has not been reproduced in the ES.

In particular, we cannot assess the degree to which the lack of survey referred to in this paragraph has limited the assessment detailed in the ES. pg. 92 Non-intrusive field survey is limited to two discreet areas (CN031 Land south of Middleton 6.2.5 House Farm, Tamworth Road, Middleton, CN027 Land off Faraday Avenue, near Curdworth and CN029 Land off Lichfield Road and Faraday Road, near Curdworth). This represents a very limited sample of the areas to be disturbed by this scheme and does not provide sufficient information to characterise the likely extent and nature of potential sub surface archaeological assets across this CFA.

Pg. 88 The full extent (including which areas were visited) of the walkovers and site 6.3.2 reconnaissance undertaken to inform this assessment is not set out in the ES, nor the timing or ground conditions at the time of these visits.

There is also no information presented about which areas were highlighted for survey, but not examined.

We cannot therefore assess the adequacy of this aspect of the Environmental Impact Assessment. pg.92 The Scheduled Monument extent buffer of CWM027 appears to extend partially across 6.3.3 the land required for construction; this asset should therefore be considered as part of this section. The direct material impact on this monument (as opposed to its setting) is not considered at all in this assessment. It is clear that associated deposits/earthworks survive within the immediate vicinity of this monument, as indicated in CH-004-020.

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pg.97 The report claims that “the alignment avoids encroaching on North Wood Scheduled 6.4.2 Monument” (CWM027). However, the ES mapping indicates that the land required for construction extends does extend across the Scheduled Area buffer.

It is clear that associated deposits/earthworks survive within the immediate vicinity of this monument, as indicated in CH-004-020, which could be impacted by this scheme. This should be assessed, and the results of that assessment detailed in this report. pg.97 The exact nature of works at Dunton Hall (CWM059) needs clarifying; it is unclear how all 6.4.2 Listed Buildings and curtilage Listed Buildings will be affected. pg. 103 We do not agree with the statement that ‘There will be no physical impacts on buried 6.5.2 archaeological remains or other heritage assets arising from the operation of the Proposed Scheme’.

There is a potential for vibrations etc. associated with the operation of the railway to have a direct impact upon buried and upstanding heritage assets.

There is insufficient information available at this time to enable any such impacts to be ruled out.

6, Throughout There is limited consideration throughout this document to the impacts that the proposed development may have upon the historic landscape character of this CFA.

e) Ecology The council has made its views on this section known in the commentary submitted for volume 1,

176 f) Land Quality Document: Volume 2: Community Forum Area Report. CFA 20: Curdworth to Middleton ES 3.2.1.20 Volume, page WCC previous comment (if appropriate) Full ES comment and paragraph reference Para 8.3.18 ………….. “The draft ES also does not take Para 8.3.18 underplays the importance of “Dunton Island account……… The site has processed up to the Dunton Material Recovery Facility. It is landfill is 500,000 tonnes per annum (tpa) in the unclear within the ES whether the site will understood to past and the site is considered to be of continue in its current form as it falls within accept only inert County (and arguably regional) the HS2 Safeguarding Area but not in an waste related to a importance in terms of delivering C&D area of land take. Notwithstanding, the site minerals waste recycling capacity. Therefore, WCC is considered to be of County and arguably processing facility requires that all operational or permitted regional importance given the capacity of at this location.” waste management facilities are the site (up to 500,000tpa) and its potential recognised and that any impacts from HS2 contribution to meeting landfill diversion are reduced to the fullest extent possible targets for construction, demolition and or are appropriately mitigated to ensure excavation (C,D&E) wastes. If the site is their continued operation. This would be likely to sterilised by HS2 and unable to in accordance with Policy CS8 continue to operate, additional C,D&E waste (Safeguarding of Waste Management treatment capacity is likely to be needed to Sites) of the Warwickshire Waste Core be provided elsewhere to meet the shortfall. Strategy. This will have an environmental impact which has not been considered in the ES. 8.3.22 The CORRECTION - Policies MPS1 and MPS5 are Minerals Local not in the adopted Warwickshire Minerals Plan for Local Plan (1995). It is likely that Policies M1 Warwickshire and M5 should be referred to. Policy M5 of aims to safeguard the adopted Warwickshire Local Plan (1995) parcels of land states that “the County Council will seek to where there are secure the winning of proven and potentially mineral resources workable minerals prior to the of economic or implementation of development which conservation would otherwise sterilise them.” Para 143 of value (Policies the NPPF also states that “LPAs…should MPS1 and define Minerals Safeguarding Areas and MPS5). adopt appropriate policies in order than known locations of specific minerals resources of local and national importance are not needlessly sterilised by non-mineral development” and “encourage the prior extraction of minerals where practicable and environmentally feasible if it is necessary for non-mineral development to take place”. This wording should therefore be referred to in the ES.

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8.4.36 There are A large section of the route in this CFA The council disagrees that there are no anticipated to be appears to be underlain by sand and significant cumulative effects on the mineral no significant gravel. WCC strongly disagrees that there resource. cumulative would be a minor adverse impact upon effects from the sand and gravel resource. To prevent If sterilisation of a viable deposit occurs, construction or the unnecessary sterilisation of the additional material will need to be sourced operation on the resource for posterity, WCC (as a Minerals from elsewhere. Given that the majority of mineral resource. Planning Authority) expects to see an Minerals Planning Authorities struggle to assessment that examines whether prior meet a 7 year landbank, it is possible that extraction of the mineral in advance of areas meeting any shortfall are likely to be the development is “practicable and more remote from end markets. Given the environmentally feasible” (para. 143, scope for increased haulage, this is likely to NPPF). WCC would expect borehole have a negative environmental impact which evidence to be used as part of the has not been assessed through the ES. assessment to provide an indication of quality and depth of the deposit, particularly when such areas may be considered as borrow pits. This is particularly important given that most MPAs along the route are unable to meet the minimum 7 year sand and gravel landbank, as required in the NPPF (Warwickshire’s is currently around 3 years). Every effort should therefore be made to extract the mineral in advance of the development in order to prevent the sterilisation of the resource for posterity. This approach would accord with adopted development plan policies

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8.4.39 Mitigation WCC strongly recommends that every WCC strongly supports the prior extraction of the effects on effort is taken to extract all mineral that of any mineral that is likely to be sterilised mineral resources may be sterilised in advance of the by the project. However, this should not just can include prior development. In particular, the Lea be restricted to allocated sites for mineral extraction of the Marston site, allocated as PA2 in the extraction as there may be viable mineral resource for use Warwickshire Minerals Local Plan (1995) reserves that have not been promoted within the project has been subject to interest in the past; through mineral plans. or elsewhere. planning applications have been Extraction may be submitted previously for this site (see Prior extraction of allocation PA2-Lea limited to NW/01/CM011) and it has also been Marston will go someone to mitigating landscaped areas promoted as a potential allocation in the sterilisation of a proven sand and gravel within the emerging Warwickshire Minerals Plan resource. However, we are disappointed to Proposed Scheme (‘Minerals Core Strategy Revised Spatial see no specific reference to potential prior adjacent to rather Options Site 21 – Hams Lane, Lea extraction of the estimated 107,000 tonnes than beneath the Marston’). There also appears to be of material at Dunton Landfill - this will need trackbed, which unworked material at Middleton Hall to be explored. will require good quarry – see ‘Minerals Core Strategy founding Revised Spatial Options Site 2’. WCC The council would welcome early conditions would like to continue to engage with HS2 discussions to facilitate prior extraction. We Preferred Areas on this issue to ensure that all mineral wish to see a firm commitment that and the MSA. that may be sterilised is extracted prior to specifies the stage at which the plan for the development taking place. This is prior extraction will be produced. In the particularly important given that interests of extracting the maximum amount Warwickshire’s landbank is only 3 years, of mineral, this must be undertaken as early well below the minimum 7 year landbank on in the process as possible. required in the NPPF.

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A plan will be The draft ES does not appear to consider discussed and impacts upon Dunton quarry, operated by agreed in advance KSD Recycling Ltd. The eastern boundary of the of the site lies approx. 40m west from the construction route and therefore falls within the works with the safeguard area. Although extraction landowner, the appears to have ceased, permission was mineral planning granted in March 2012 for the extraction department at of the remaining 107,000 tonnes. WCC WCC and any would therefore expect the prior other interested extraction of the mineral to be parties to assist in investigated prior to the development achieving an taking place. effective management of minerals within the affected location of the

8.3.29 All the Although not technically a ‘committed’ or committed ‘proposed’ development, the Mullensgrove developments Farm site (located at the proposed ‘y’ described in junction) has been subject to enforcement Section 2.1, action in relation to the unauthorised Overview of the deposit, storage and processing of wood and area and green waste. We understand that description of the discussions between HS2 Ltd and the Proposed Scheme landowner are ongoing following the serving are expected to of a Blight Notice in November 2013. be complete by However, the environmental effects 2017 when associated with the above activity and construction potential site clearance may therefore need starts. to be taken into account by HS2 Ltd. Committed developments are HS2 Ltd need to look at unauthorised also listed in activity across the entire route as there will Volume 5: be environmental implications that need to Appendix CT-004- be assessed. 000.

180 g) Landscape & visual Assessment Document: Volume 2: Community Forum Area Report. CFA 20: Curdworth to Middleton ES 3.2.1.20

Vol. 2 CFA Report no. There are no specific design measures (mitigation measures) given for this CFA as there 20, para 9.5.2, p.178 are for the other CFAs.

The council considers this omission be deficient and unacceptable.

h) Socio Economic Document: Volume 2: Community Forum Area Report. CFA 20: Curdworth to Middleton ES 3.2.1.20 10.4.3 The assertion that no none agricultural businesses will be effected may be correct based on the parameters that HS2 have used. However the exclusion of Kingsbury Water Park removes the businesses who operate from the site and significantly down plays the possible impact on the 13 businesses directly related to the site.

This is an unacceptable oversight by HS2 10.4.5 The suggestion that 3,100 years of employment will be created in this area does not automatically create local employment for North Warwickshire residents. This could create a net inward migration of workers at the same time as displacing local employment. It is the council’s view that a much more detailed assessment of skills is necessary if any local economic benefit is to be derived from the proposed rail line. 10.4.10 The assessment of 17 business accommodation units does not include the effect that will be felt at Kingsbury Water Park which is home to13 independent businesses. The omission of this is unacceptable and significantly down plays the potential job losses in the area.

10.4.17 The council disagrees with this statement and believes HS2 is incorrect in its assessment. 10.5.7 The council does not share HS2’s assessment that there will be only negligible or beneficial effects in this area.

The suggestion that mitigation is unnecessary is flawed.

181 i) Sound, Noise & Vibration Document: Volume 2: Community Forum Area Report. CFA 20: Curdworth to Middleton ES 3.2.1.20 Volume, page and paragraph Full ES Comment reference CFA 20. 11.3.2, The railhead adjacent to Kingsbury Road has been identified Page 210. as having a significant impact on nearby dwellings at Marston. The council are extremely concerned that far from being temporary, this impact will be a long term that will affect a generation if it is used for Phase Two as suggested. It is the council’s view that this longer term impact has not been fully assessed, furthermore the council expects HS2 to commit to the SMZ as detailed in other parts of this submission and the Phase Two route consultation, provide substantial mitigation measures to ensure that the Marston, Kingsbury and Bodymoor Heath communities receive the mitigation now and not to have to wait for Phase 2 to commence before their concerns are addressed.

CFA 20. Page The statement that some short term night time working may 210. 11.3.4 occur but noise effects are not considered significant is not acceptable. WCC believe that extensive night time working is unavoidable due to the lack of day time rail possessions being available and this impact should be fully assessed and appropriately mitigated.

CFA 20. Page WCC find it unacceptable that noise levels at Dunstall Hall of 212. 11.3.17 up to 80 dB for a period of three years during construction will occur. We believe that the offer of noise insulation is insufficient in mitigating the full impact and expect HS2 to re- evaluate the construction assessment to incorporate additional mitigation measures.

182 j) Traffic & Transport incorporating PROW, highway design and traffic safety Document: Volume 2: Community Forum Area Report. CFA 20: Curdworth to Middleton ES 3.2.1.20 CA – Curdworth CT-06-119. M14 is stopped up before the re-aligned section to Middleton starts thus leaving a gap between the existing, unaffected section of the path and the new section of path. A complete route must be provided. General In some instances Canal towpaths are shown in the same format as PROW. Although there may be some cases where a PROW does utilise the tow path, in most instances this is not the case and it is therefore misleading to show a towpath as a PROW (for an example see CA – Curdworth to Middleton CT- 06-119). CA – Curdworth CT-05-0119 and 12.4.39. Byway M450 is being stopped up and to Middleton a ‘replacement’ byway created by upgrading M23a Seeney Lane and creating a new section of byway. Will this new byway be in place before the section of byway M450 is stopped up so that access can continue to be provided for the properties that take access off M450. Unless the new access is provided before the closure, there will be a major unacceptable impact on landowners and users. CA – Curdworth 12.4.39. M13 is to be permanently stopped up and not stopped to Middleton up for a period of nine years. This section is not correct. CA – Curdworth 12.4.39. A period of nine years for a stopping up would be to Middleton regarded as permanent by the public. In respect of PROW M23 is there a possible temporary diverted route that could be made available. CA – General The dispersion of information about PROW through different sections of the Community Forum Area books makes determination of the impact of HS2 on PROW very difficult and in some cases impossible to determine. CA – Curdworth CT-06-114. The ‘diverted’ section of T17 must link up with the to Middleton existing T17. Currently there is a gap indicated which leaves two cul-de-sac routes.

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CA – Curdworth Upgrading Seeney Lane to the status of byway will result in to Middleton motor vehicles there will be a knock on of motorised vehicles attempting to use bridleway M23a/T154 as a way of reaching byway T179 and then the A4091 as a short cut. This will have a major impact on the maintenance of M23a and the safety of the entire route. Byways are routes that are open to motor vehicles but is mainly used for the purposes for which footpaths and bridleways are used. HS2 must ensure that motor vehicles are prevented from using M23a whilst still keeping it open for legitimate use. All highway authorities have issues with illegal use of PROW by motor vehicles and this area will be particularly prone to this due to the its through route nature. The impact on the route will be significant and must be avoided.

It is recommended that the access to the properties is re- examined and the need for the upgrade of Seeney Lane re- evaluated. Access should be considered from Cuttle Mill Lane as an alternative. There would be no necessity then to provide a new byway with all its associated issues. k) Water Resources and Flood Risk

The council has no comments to make on this section at this time

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CFA Reports 24 (Birmingham Interchange)

Health Document: Volume 2: Community Forum Area Report. CFA 24: Birmingham Interchange ES 3.2.1.24 Draft ES WCC HS2 Mitigation ES Public Health document comment/observatio amendments Warwickshire reference n on Draft ES additional Consultation comments on final ES 2.1.16 and 2.1.17 It is unclear what Insufficient detail page 14 impact the Proposed provided in HIA. No Green spaces and Scheme will have evidence to suggest outdoor amenities upon the open green our original in the local spaces and mitigation comments community community facilities. It have been is important to considered, recognise the health therefore HS2 impact of these MUST refer to spaces to physical original comments activity, respiratory under WCC

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condition comment/observatio management, weight n on Draft ES management and Consultation (first mental health. They column). The are also important as avoidance of directly a community meeting addressing these place and encouraging issues is negligent to social cohesion. the local population of Warwickshire. 2.3.14 page 23 While it is positive that Insufficient detail The design of light pollution has provided in HIA. No lighting for site been recognised, evidence to suggest compounds during sleep disturbance can our original hours of darkness have an adverse effect mitigation comments would seek to on health and so we have been reduce light would recommend that considered, pollution to the light pollution be kept therefore HS2 surrounding area as to recommended MUST refer to far as reasonably standards rather than original comments practicable. sought to. under WCC comment/observatio n on Draft ES Consultation (first column). The avoidance of directly addressing these issues is negligent to the local population of Warwickshire. 3.2.3 page 41 It is unclear how the 11.3.5: lead Insufficient detail The NWLP has HS2 project is going to contractors will seek provided in HIA. No three applicable support the local to obtain prior evidence to suggest policies. Policy 10 policy, particularly consent from the our original supports agriculture Policy 10 and ENV6 relevant local mitigation comments and promotes regarding supporting authority under have been agricultural and protecting Section 61 of CoPA considered, diversification agricultural land and for the proposed therefore HS2 activities where maintaining soil construction works. MUST refer to they can help to quality. Further The original comments underpin the rural information is required consent application under WCC economy. Policy to demonstrate how will set out BPM comment/observatio ENV6 includes the construction of the measures to n on Draft ES protection of BMV Proposed Scheme will minimise Consultation (first quality land, as well not adversely impact construction noise, column). The as setting out a pollution or soil including control of avoidance of directly series of pollution contamination in the working hours, and addressing these prevention area, particularly in provide a further issues is negligent to measures, which terms of food assessment of the local population indirectly benefit production. The construction noise of Warwickshire. agriculture through economic impact in and vibration safeguarding soil agricultural changes including quality. also needs further confirmation of noise exploration and insulation/temporary assessment. re-housing provision;

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3.4.10 page 43 While it is positive to Insufficient detail All the areas see that measures provided in HIA. No affected by have been introduced evidence to suggest construction are to reduce nitrogen our original classified as a losses from mitigation comments nitrate vulnerable agricultural sources to have been zone (NVZ). NVZ water, further detail is considered, are areas in which required as to what therefore HS2 nitrate pollution is a these measures are. MUST refer to potential problem As the area is a original comments and measures have Nitrate Vulnerable under WCC been introduced to Zone and is comment/observatio reduce nitrogen dominated by arable n on Draft ES losses from food crops, we would Consultation (first agricultural sources recommend that column). The to water. measures taken avoidance of directly prevent nitrogen addressing these losses as far as issues is negligent to possible rather than the local population only reduce it. of Warwickshire. 3.5.9 page 45 Air pollution, 4.4.2: The Insufficient detail Farm or diversified particularly dust from assessment has provided in HIA. No enterprises, such as construction, could assumed that the evidence to suggest housed livestock exacerbate existing general measures our original units, horticulture, respiratory or detailed in Section 7 mitigation comments farm shops or cardiovascular of the have been visitor conditions leading to draft CoCP (Volume considered, accommodation, an increase in GP and 5: Appendix CT-003- therefore HS2 could be particularly acute hospital use. A 000) will be MUST refer to sensitive to dust, health impact implemented. These original comments noise or vibration assessment of the include: under WCC during construction. workers on site and  contractors comment/observatio their living being n on Draft ES 4.4.6 page 42 accommodation, as required to Consultation (first Several locations well as of the local manage dust, column). The have been identified community and air pollution, avoidance of directly in the study area affected properties is odour and addressing these that are considered recommended. exhaust issues is negligent to susceptible to Continuous monitoring emissions the local population changes in air of pollution levels at during of Warwickshire. quality and are in the site during construction close proximity to construction is also works; roads that would be recommended, with  inspection subject to the implementation of and visual realignment or used further measures to monitoring by construction mitigate any pollution after traffic. exceeding minimum engagement permitted levels. with the local authorities to assess the effectiveness of the measures taken to

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control dust and air pollutant emissions;  cleaning (including watering) of haul routes and designated vehicle waiting areas to suppress dust;  keeping soil stockpiles away from sensitive receptors where reasonably practicable, also taking into account the prevailing wind direction relative to sensitive receptors;  using enclosures to contain dust emitted from construction activities;  and undertaking soil spreading, seeding and planting of completed earthworks as soon as reasonably practicable following completion of earthworks.

11.3.5: lead contractors will seek to obtain prior consent from the

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relevant local authority under Section 61 of CoPA for the proposed construction works. The consent application will set out BPM measures to minimise construction noise, including control of working hours, and provide a further assessment of construction noise and vibration including confirmation of noise insulation/temporary re-housing provision; 4.2.5 page 47 While it is positive to Insufficient detail An Air Quality see that local air provided in HIA. No Action Plan (AQAP) quality action plans evidence to suggest has been have been recognised, our original developed by it is unclear how the mitigation comments NWBC with the aim Proposed Scheme will have been of improving local support the plans and considered, air quality in the the AQMA. Further therefore HS2 designated Coleshill information is required MUST refer to AQMA. As the as to how the scheme original comments AQMA only affects will mitigate any under WCC one property the effects due to comment/observatio AQAP focuses pollution caused by it n on Draft ES particularly on this Consultation (first area and explores column). The possible initiatives avoidance of directly to mitigate the addressing these effects of air issues is negligent to pollution at the the local population property. These of Warwickshire. include continuing to gather air quality monitoring data from within the AQMA and exploring the reuse of the property in ways which do not conflict with the air quality objective.

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5.2.2 page 51 While it is positive that 2.2.4: Since the draft Insufficient detail Other relevant relevant local policies ES was published provided in HIA. No policies of the have been recognised, the following evidence to suggest SUDP include: it is unclear how changes have been our original Policy ENV19 Proposed Scheme will introduced to the mitigation comments seeks to protect the support the policy. Proposed Scheme: have been amenity of Particularly regarding the size of Coleshill considered, residential and providing opportunities Heath Road satellite therefore HS2 shopping areas; for recreational and compound in Heath MUST refer to community facilities; physical activity, Park was reduced to original comments and open spaces including PRoW and minimise the loss of under WCC from potentially cycling routes, open space; comment/observatio harmful, or bad allotments for food n on Draft ES neighbour production and loss of Consultation (first development...Polic community and social column). The y R2 and Policy R7 infrastructure. Further avoidance of directly seek to protect and information is required addressing these enhance public as to how the issues is negligent to parks, open spaces, Proposed Scheme will the local population PRoW and cycling support the policy and of Warwickshire. routes…Policy P18 the alternatives that addresses the need will be provided if to support strong, there is an vibrant and healthy unavoidable loss of communities by open spaces, PRoW, providing cycling routes and opportunities for community and social formal and informal infrastructure in order recreational and to minimise any physical activity. negative effect from Loss of community the Proposed Scheme and social on the population’s infrastructure will be health. resisted unless there are commercial or operational reasons for ceasing, or an alternative is provided. Policy P20 states that the loss of existing open space, sports and recreational It is unclear how the facilities will be HS2 project is going to resisted unless it support the local can be policy P14 regarding demonstrated that it air, noise and light is surplus to pollution. These requirements, or the pollutions can cause ill benefit of the health and a health development impact assessment is outweighs the loss. recommended to Allotment gardens assess how the are protected in line construction and long

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with Policy R5; term use of the Proposed Scheme will Policy P14 seeks to impact on pollution protect the amenity and health in the area. of areas by permitting development that would not contribute to air, noise or light pollution and protect the tranquillity and local distinctiveness of Solihull Borough. 5.2.6 page 52 While it is positive that 2.2.4: Since the draft In regard to relevant local policies ES was published community facilities, have been recognised, the following Policy NW17 states it is unclear how the changes have been that proposals that Proposed Scheme will introduced to the would result in the support NW17 Proposed Scheme: loss of an existing regarding access to the size of Coleshill services or facilities community facilities. Heath Road satellite which contribute to Further information is compound in Heath the functioning of a required as to how Park was reduced to settlement will only they will be supported, minimise the loss of be supported where particularly with open space; the facility is regards to the health replaced elsewhere benefits of such or proven that it will facilities, and the not harm the vitality alternatives that will be of the settlement. provided if there is an unavoidable loss of open spaces and community facilities. 5.6.2 page 55 While it is positive that Insufficient detail The presence of in- impacts from provided in HIA. No combination transport, traffic, air evidence to suggest impacts from these quality etc. have been our original other disciplines recognised, it is mitigation comments could result in important that the have been significant amenity health effects of the considered, effects on a number Proposed Scheme are therefore HS2 of community also considered. A MUST refer to facilities and health and social original comments resources in the impact assessment is under WCC area. recommended. comment/observatio This will be reported n on Draft ES in the formal ES. Consultation (first column). The avoidance of directly addressing these issues is negligent to the local population of Warwickshire.

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9.2.1 page It is unclear how the 2.2.4: Since the draft Insufficient detail 79 HS2 project is going to ES was published provided in HIA. No The SUDP contains support the local the following evidence to suggest eight policies that policies, particularly changes have been our original are relevant to C9 regarding light introduced to the mitigation comments landscape and pollution. While it is Proposed Scheme: have been visual assessment positive that light the size of Coleshill considered, in terms of pollution has been Heath Road satellite therefore HS2 determining the recognised, sleep compound in Heath MUST refer to value and sensitivity disturbance can have Park was reduced to original comments of LCA and an adverse effect on minimise the loss of under WCC assessing the health and so we open space; comment/observatio effects on these would recommend that n on Draft ES character any effects on health 11.3.5: lead Consultation (first areas...Policy from light pollution be contractors will seek column). The ENV14 covers trees mitigated. to obtain prior avoidance of directly and woodlands. consent from the addressing these Policy R6 seeks to It is also unclear how relevant local issues is negligent to promote waterways policies ENV14 and authority under the local population as a recreational R6 will be supported Section 61 of CoPA of Warwickshire. feature whilst by the scheme. Open for the proposed safeguarding the spaces and access to construction works. natural and heritage the environment is The environment. Policy important for health, consent application C9 concerns light particularly in terms of will set out BPM pollution and is of physical activity levels measures to relevance when and mental health and minimise determining effects wellbeing. Further construction noise, arising from information is required including control of additional lighting at to demonstrate how working hours, and night-time on visual the construction of the provide a further receptors. Proposed Scheme will assessment of not adversely impact construction noise upon health. and vibration including confirmation of noise insulation/temporary re-housing provision; 9.2.3 page 79 It is unclear how the 2.2.4: Since the draft Insufficient detail Policy P18: Health HS2 project is going to ES was published provided in HIA. No and Well Being support the local the following evidence to suggest introduces a policy, particularly changes have been our original package of policy Policy P18: Health and introduced to the mitigation comments considerations Well Being and Policy Proposed Scheme: have been aimed at improving 20 regarding open the size of Coleshill considered, community health. spaces and outdoor Heath Road satellite therefore HS2 The policy includes recreation facilities. compound in Heath MUST refer to reference to the role Further information is Park was reduced to original comments of green needed detailing how minimise the loss of under WCC infrastructure in the project will support open space; comment/observatio supporting health; local health policy and n on Draft ES and seeks to where it doesn’t what Consultation (first safeguard and measures will be put column). The increase into place to minimise avoidance of directly opportunities for any negative effect addressing these

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local food from the Proposed issues is negligent to production across Scheme on the the local population the Borough. Policy populations health. of Warwickshire. P20 relates to the provision of open space and outdoor recreation and sport facilities. 10.5.2 page 90 The assessment Insufficient detail It is estimated that states displacement or provided in HIA. No the Proposed possible loss of evidence to suggest Scheme would approximately 20 jobs our original result in the within the study area, mitigation comments displacement or but does not take into have been possible loss of a account the disruption considered, total of around 20 to an already therefore HS2 jobs within this congested traffic area MUST refer to study area. and difficulty in original comments transport around it. If under WCC premises are moved comment/observatio this could lead to n on Draft ES further job loss if new Consultation (first sites are inaccessible column). The to staff or customers, avoidance of directly leading to a reduced addressing these customer base and issues is negligent to possibly closure of the the local population business and of Warwickshire. unemployment if the relocated premises are inappropriate.

The cumulative effect over all Warwickshire affected areas from job losses are examined at the end of this response. 11.5.5 page 93 While it is positive to 11.3.5: lead Insufficient detail Further work is see that further work contractors will seek provided in HIA. No being undertaken to regarding the effect of to obtain prior evidence to suggest confirm significant noise is being consent from the our original construction noise undertaken, it is relevant local mitigation comments and vibration unclear whether this authority under have been effects, including includes any work to Section 61 of CoPA considered, any temporary examine the health for the proposed therefore HS2 effects from effects from the construction works. MUST refer to construction traffic. construction noise and The original comments vibration for the local consent application under WCC community. A health will set out BPM comment/observatio impact assessment is measures to n on Draft ES recommended. minimise Consultation (first construction noise, column). The including control of avoidance of directly working hours, and addressing these

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provide a further issues is negligent to assessment of the local population construction noise of Warwickshire. and vibration including confirmation of noise insulation/temporary re-housing provision; 11.6.4 page 94 Residential receptors 11.3.5: lead Insufficient detail Residential have been identified contractors will seek provided in HIA. No receptors within the as having a significant to obtain prior evidence to suggest daytime 65dB adverse effect from consent from the our original contour, and day and night HS2 relevant local mitigation comments therefore the night- noise. Although Noise authority under have been time 55dB contour, Insulation Regulations Section 61 of CoPA considered, have been identified and WHO Night Noise for the proposed therefore HS2 as being likely to Guidelines are being construction works. MUST refer to experience a used, we would The original comments significant adverse recommend that target consent application under WCC effect from the noise levels be aimed will set out BPM comment/observatio Proposed Scheme below this threshold to measures to n on Draft ES alone. reduce the health and minimise Consultation (first wellbeing effects on construction noise, column). The residents in this area. including control of avoidance of directly working hours, and addressing these Measures taken to provide a further issues is negligent to reduce noise nuisance assessment of the local population need to be detailed construction noise of Warwickshire. with expected and vibration effectiveness data including given in order to confirmation of noise demonstrate they insulation/temporary meet the permitted re-housing provision; noise levels. We also recommend continued noise monitoring in this area during construction and after the project is complete. 11.6.7 – 11.6.10 During the further 11.3.5: lead Insufficient detail page 94 assessment of the contractors will seek provided in HIA. No Noise pollution effects of noise for the to obtain prior evidence to suggest formal ES, it is consent from the our original recommended that the relevant local mitigation comments health implications are authority under have been also considered and a Section 61 of CoPA considered, health impact for the proposed therefore HS2 assessment is construction works. MUST refer to recommended. The original comments consent application under WCC will set out BPM comment/observatio measures to n on Draft ES minimise Consultation (first construction noise, column). The

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including control of avoidance of directly working hours, and addressing these provide a further issues is negligent to assessment of the local population construction noise of Warwickshire. and vibration including confirmation of noise insulation/temporary re-housing provision; 11.6.11 page 94 Although it is stated Insufficient detail The envisaged that the envisaged provided in HIA. No mitigation mitigates will evidence to suggest (especially substantially reduce our original landscape the potential airborne mitigation comments earthworks and sounds, it is not stated have been noise barriers) or clear how reduced considered, described in this the noises will and therefore HS2 chapter whether the noise MUST refer to substantially levels will therefore fall original comments reduces the below the permitted under WCC potential airborne noise level. comment/observatio sound impacts and n on Draft ES noise effects that Consultation (first would otherwise column). The arise from the avoidance of directly Proposed Scheme. Noise disturbance has addressing these multiple negative issues is negligent to Nonetheless, effects on the health the local population potential significant and wellbeing of of Warwickshire. adverse airborne individuals, particularly noise effects have concerning mental been identified for health and the effects residential of sleep disturbance. receptors Additional detail is needed on the 11.6.13 page 95 effectiveness of the It is estimated that envisaged mitigates one dwelling – and what measures marked as SV24-01 are going to be taken on Map SV-01 – in specific relation to would potentially the community experience noise identified as SV24-01 levels higher than on map SV-01-53, the insulation who will experience trigger level. noise exceeding day and night time targets during construction and on a long term basis from railway operation, in order to minimise the health effects.

It is recommended

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that monitoring of noise at this site continue during construction and after completion.

d) Culture & Heritage The council has no comments to make on this section at this time e) Ecology The council has made its views on this section known in the commentary submitted for volume 1,

196 f) Land Quality Document: Volume 2: Community Forum Area Report. CFA Reports 24 (Birmingham Interchange)

ES 3.2.1.24 Volume, page WCC previous comment (if appropriate) Full ES comment and para ref Table 9 (ref Although the site is referenced, the draft ES does The Warwickshire Waste Core Packington not consider the specific environmental impacts of Strategy was adopted on 9th July Landfill) the project on all waste activities at the Packington 2013. Policy CS8 (Safeguarding of site operated by Sita UK. There are numerous waste Waste Management Facilities) The site also operations at the site. The western boundary of the therefore forms part of the contains ancillary permitted landfill area lies approx. 210m east of the development plan for waste operations, proposed route but the safeguarding area appears Warwickshire. WCC would like including an to adjoin the permitted area of the site…………… assurance that no permitted anaerobic …………… The Council requires that all operational or waste facilities, such as those at digestion plant, permitted waste sites are recognised as part of the Packington, will be sterilised by composter, wood environmental impact assessment process and that HS2. Such sites make a significant shredder, any impacts from HS2 are reduced to the fullest contribution to the County’s leachate extent possible or are appropriately mitigated to waste treatment capacity treatment plant ensure their continued operation. This would be in requirements. Sterilisation of such and landfill gas accordance with Policy CS8 (Safeguarding of Waste sites may mean that additional plant. Management Sites) of the Warwickshire Waste Core capacity may be required Strategy. This policy is likely to be adopted as part of elsewhere, which is likely to have The landfill is due the statutory development plan on 9th July 2013. an indirect environmental impact. to cease If these operational sites are likely accepting waste to be sterilised, the environmental in 2014 and will impacts (and their significance) be restored to a will need to be adequately park. assessed

g) Landscape & visual assessment The council has no comments to make on this section at this time h) Socio economic The council has no comments to make on this section at this time

i) Sound, Noise & Vibration The council has no comments to make on this section at this time j) Traffic & Transport incorporating highway design and traffic safety The council has no comments to make on this section at this time k) Water Resources and Flood Risk The council has no comments to make on this section at this time

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Volume 3: Route-wide effects.

The council only wishes to comment on two elements in this volume:

Cultural Heritage Document: Volume 3: Route Wide Effects

ES 3.3.0

Volume, page and Full ES comment paragraph reference

pg. 69 Direct damage to heritage assets can include their partial disturbance / damage, not just physically removed. 7.1.1

General Comments Whilst this document states how many designated monuments will be physically impacted, it does not list:

- those designated monuments whose settings will be impacted.

- the number of non-designated known heritage assets (including those which are of demonstrably equivalent significance to scheduled monuments) which will be impacted by the scheme.

the potential for as yet unidentified heritage assets to be impacted upon by the scheme. These may include heritage assets of at least national or international significance (for example, a high potential for nationally important Lower Palaeolithic archaeological remains associated with the pre-Anglian Bytham River has been identified in CFA 18 (see para. 8.1.1 of ES 3.5.2.18.4).

Whilst the potential impacts on heritage assets is presented elsewhere in the Environmental Statement, referencing just the direct impacts upon designated monuments only in this chapter presents a biased view of the overall route-wide impact of this scheme upon the historic environment.

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Document: Volume 3 – Route-wide effects (Waste and Material Resources)

Volume, page & WCC previous comment Full ES comment paragraph ref

14.1.7 The movement of The lack of detail on excavated The approach of dealing with waste from source to final material arisings means that it waste, excavated material and destination is a complex is impossible to determine how spoil as a 'route wide' issue is process as waste is often much excavated material could considered wholly inadequate. transferred across waste be used ‘on-site’ as part of the According to 'Volume 5 planning authority works (which could be located Technical Appendix WM-001- boundaries for treatment some distance from where the 000 -Waste and material and disposal according to material arises), or how much resources assessment ()', and the type of waste and the would be transported to Tables 22 and 28 of this nature of the waste appropriate disposal facilities document, c34 million tonnes of management facility ‘off-site’ excavated material and spoil will require management in 14.1.11 This route-wide Warwickshire alone. approach takes into Furthermore, over 132 million account waste arisings tonnes of excavation, demolition and waste infrastructure and construction materials will capacity data available at require management across the county and regional level. route. Even if all material surpluses and shortfalls are balanced route wide (at worst) or at CFA level (at best), there will be an inevitable environmental impact associated with managing the material which has not been assessed through the ES.

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14.1.16 This assessment . As the ES does not provide The ES has not identified: takes account of the likely potential volumes or significant environmental destinations, the ES has not - the exact locations of where effects associated with taken into account the potential the major sources of excavated the off-site disposal to environmental impacts (direct, material will arise below the landfill of solid waste that indirect or cumulative) of CFA level will be generated by transporting such material. - the exact location for the end construction and WCC strongly recommends destination of the material (and operation of the that further detail is provided demonstration of case for Proposed Scheme. on this to ensure that these use/disposal at that location) impacts are fully considered to ensure that the final ES is fit As a result, the ES has not for purpose. assessed the likely significant effects from the management of excavated material and spoil. The ES needs to cover the direct effects and any indirect, secondary, cumulative, short, medium and long-term, permanent and temporary, positive and negative effects of the development.

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Document: Volume 3 – Route-wide effects (Waste and Material Resources)

Volume, page & paragraph ref Full ES comment

Paras 14.6.3 & 14.6.4, Tables 22 & 28An Table 22 of Volume 3 (Route-wide effects – integrated design approach has been Waste and Material Resources) states that developed that seeks to minimise the 91% of excavated material generated by the quantity of surplus excavated material scheme will be reused for engineering and generated, reuse that which is generated to environmental mitigation earthworks. However, the ES does not demonstrate why the quality or satisfy the necessary engineering and quantities of materials are appropriate for their environmental mitigation earthworks intended end use, or indeed why use at the end requirements for the Proposed Scheme and location is appropriate. WCC strongly supports minimise off-site disposal to landfill. This the use of environmental mitigation earthworks includes reuse of all topsoil and agricultural where they are necessary, however the quality subsoil as close to the point of excavation and quantities of materials used within the as practicable. scheme must be appropriate for their end use in order to constitute "re-use" or “recovery”. Without such a justification, it could be argued that there is solely the deposition of material on land with no demonstrated benefits, which would constitute "disposal" under the Waste Hierarchy.

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A CL:AIRE Code of Practice Materials Under Policy CS7 of the Adopted Warwickshire Management Plan will be prepared at a Waste Core Strategy, such disposal operations later stage of design to support are required to demonstrate that significant implementation of the integrated design environmental benefits would result from the approach180. This will enable suitable proposal at that location and that it does not excavated material to be used as a divert significant quantities of material away resource within the construction of the from the restoration of mineral working or Proposed Scheme with the additional permitted landfill sites. WCC has supplied benefit of reducing the quantity of imported details of permitted/licensed waste fill required. management facilities in Warwickshire, although the Environment Agency should be able to supply details of licensed waste management facilities in each CFA area. Although the genuine re-use/recovery of material to provide necessary environmental mitigation is strongly supported, the Council would not wish to see unnecessary dumping of surplus material to minimise project costs. Therefore any surplus materials should be managed at appropriately permitted and licensed waste management facilities. Indeed, a legacy of mineral extraction and higher recycling rates has resulted in unrestored mineral workings in Warwickshire. HS2 may provide a unique opportunity for supplying inert material to restore such voids so we would wish to see this option explored as it may, in some cases, be the most sustainable option for managing surplus materials.

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Table 28 / para 14.6.58 Table 28 indicates that 4.9 million tonnes of In accordance with the significance criteria , material is likely to be disposed to landfill. the likely significant environmental effects Although this only represents 4% of the total associated with the off-site disposal to excavation, demolition and construction landfill of inert surplus excavated material materials arising during the proposed scheme, generated by construction of the proposal the transfer, storage and disposal of 4.9 million scheme will be minor adverse tonnes is likely to have an associated environmental impact. Again, the lack of detail in terms of end destinations for disposal means that the environmental impacts (and their significance) have not been adequately assessed through the ES. In the absence of this information/assessment, we would question how the impacts associated with disposal are considered to be “minor adverse”.

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Volume 4: Off-route effects.

The council has no comments to make at this time on this section

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Volume 5: Appendices and map books.

l) Agriculture m) Air Quality n) Community – incorporating health related issues. o) Culture and Heritage p) Ecology q) Land quality r) Landscape and visual assessment s) Socio Economic t) Sound, Noise & Vibration u) Traffic, & Transport; incorporating PROW, highway design and Traffic Safety v) Water Resource & Flood Risk a) Agriculture The council has no comment to make on this section at this time. b) Air Quality The council has no comment to make on this section at this time. c) Community – incorporating health related issues. The council has no comment to make on this section at this time.

d) Culture & Heritage Document: Volume 5: CFA 16: Ladbroke and Southam. Gazetteer of heritage assets (CH-002-016). Cultural Heritage

ES 3.5.2.16.5

Volume, page and Full ES comment paragraph reference

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pg. 3 This undated cropmark complex, which may represent settlement of late prehistoric or Roman date has been assigned Table 1 a ‘Low’ significance/value. There is insufficient information LBS003 available to enable the significance of this site to be determined at this time (e.g. we do not know its date, character, state of preservation etc.); it may be of significantly higher value than presented in this table. pg. 3 This document assigns the site of Stoneton Manor and gardens a ‘Low’ significance/value. The table does not reference the Table 1 medieval moat in which it sits, nor the potential for LBS008 archaeological deposits associated with the medieval manor site to survive across this area. This complex should be allocated at least a ‘Moderate’ significance/value. pg. 19 This table assigns the parkland landscape around Stoney Thorpe Hall a ‘Low’ significance. A detailed analysis of this Table 1 parkland as part of an English Heritage funded project, which LBS068 reviewed historic parks and gardens across Warwickshire has recommended that this be included on the ‘Local List’. This parkland should be assigned a ‘Moderate’ significance/value. pg. 21 These as yet undated enclosure cropmarks have been assigned a ‘Low’ significance/value. There is insufficient Table 1 information available to enable the significance of this site to be LBS084 determined at this time (e.g. we do not know its date, character, state of preservation etc.); it may be of significantly higher value than presented in this table. pg. 23, Table 1 We are pleased to note that a moderate value has been assigned to this significant historic landscape. LBS100 pg. 23 These as yet undated geophysical anomalies, which are of probable archaeological origin, have been assigned a ‘Low’ Table 1 significance/value. There is insufficient information available to LBS102 enable the significance of these features to be determined at this time (e.g. we do not know their date, character, state of preservation etc.); they may be of significantly higher value than presented in this table. pg. 23 It is unclear why this heritage asset has been assigned a ‘Not Significant’ significance/value, when LBS108, which appears to Table 1 be similar in character has been assigned a ‘Low’ LBS107 significance/value.

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Table 1 There is limited referencing to the specific aerial photographs referred to in this document (e.g. in relation to LBS007, General Comments LBS009, LBS011, LBS017, LBS022, LBS035, LBS071, LBS072, LBS078). This makes it difficult for us to identify and examine these photographs ourselves in order to assess the conclusions reached.

Table 1 Heritage asset LBS088, which is referenced in the Impact Assessment Tables (ES.3.5.2.16.6) is not detailed in this General Comments document.

Table 1 The inclusion of National Grid References in this document would aid the analysis of the data presented. General Comments

Table 1 Cross-referencing against the Warwickshire HER numbers throughout this document is inconsistent. General Comments

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Document: Volume 5: Technical Appendices. CFA 16: Ladbroke and Southam. Impact Assessment Tables (CH-003-016). Cultural Heritage

ES 3.5.2.16.6

Volume, page and Full ES comment paragraph reference

p 1 This undated cropmark complex, which may represent settlement of late prehistoric or Roman date has been assigned Table 1 a ‘Low’ significance/value. There is insufficient information LBS003 available to enable the significance of this site to be determined at this time (e.g. we do not know its date, character, state of preservation etc.); it may be of significantly higher value than presented in this table.

The effect of the proposal upon these remains may therefore be greater than the ‘Moderate Adverse’ presented in this table. pg. 3 This document assigns the site of Stoneton Manor and gardens a ‘Low’ significance/value. The table does not reference the Table 1 medieval moat in which it sits, nor the potential for archaeological deposits associated with the medieval manor LBS008 site to survive across this area. This complex should be allocated at least a ‘Moderate’ significance/value. pg. 5 There is insufficient evidence presented in support of the assertion that there will be a minimal impact upon the setting of Table 1 this nationally significant Scheduled Monument. We cannot therefore determine whether or not the conclusion that the LBS038 effect of the proposal upon this heritage asset will be ‘Minor Adverse’ is accurate. pg. 5 The Gazetteer of Heritage Assets (ES 3.5.2.16.5) assigns a ‘Low’ significance/value to this heritage asset, not the ‘Not Table 1 Significant’ value presented in this table. This table should LBS041 present the value as ‘Low’ and effect ‘Minor Adverse’. pg. 5 The effect of the proposal should be rated as ‘Minor/Negligible Adverse’ rather than ‘Negligible’ as presented here. Table 1 LBS043 pg. 6 The Gazetteer of Heritage Assets (ES 3.5.2.16.5) describes this as upstanding earthworks, not just the below-ground Table 1 features as described in this document. LBS049

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pg. 6 The effect of this proposal upon this heritage asset is likely to be ‘Minor/Negligible’ not ‘Negligible’ as presented in this table. Table 1 LBS056 pg. 8 This table assigns that parkland landscape around Stoney Thorpe Hall as of ‘Low’ significance. A detailed analysis of this Table 1 parkland as part of an English Heritage funded project, which reviewed historic parks and gardens across Warwickshire has LBS068 recommended that this be included on the ‘Local List’. This parkland should be assigned a ‘Moderate’ significance/value.

There is insufficient evidence presented in support of the assertion that there will be a ‘Low Adverse’ impact upon the setting of this historic park. Given the likely ‘changes to the setting of the asset and its relationship to the wider landscape’ as referenced in this table, and the ‘Moderate’ significance/value of this heritage asset, it is likely that the overall effect will be at least ‘Moderate Adverse’. pg. 8 The Gazetteer of Heritage Assets (ES 3.5.2.16.5) states that there are earthworks associated with this heritage asset, not Table 1 just the buried remains suggested by this table describing it as LBS069 being ‘archaeological in nature’. The proposal could have an impact upon the setting of these earthworks; this does not appear to have been assessed. It should be. It is likely that impact will be greater than the ‘neutral’ effect presented in this table. In addition, further assessment may be necessary to establish whether any buried archaeological remains associated with this settlement extend across the areas to be disturbed by this proposal. pg. 8 This ridge and furrow survives as extant earthworks, not just as “below-ground features” as described in this table. Table 1 LBS071 pg. 8 This ridge and furrow survives as extant earthworks, not just as “below-ground features” as described in this table. Table 1 LBS072 pg. 9 These as yet undated enclosure cropmarks have been assigned a ‘Low’ significance/value. There is insufficient Table 1 information available to enable the significance of this site to be determined at this time (e.g. we do not know its date, character, LBS084 state of preservation etc.); it may be of significantly higher value than presented in this table.

The effect of the proposal upon these remains may therefore be greater than the ‘Moderate Adverse’ presented in this table.

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pg. 11 The Gazetteer of Heritage Assets (ES 3.5.2.16.5) correctly identifies this historic landscape as being of ‘Moderate’ Table 1 significance/value, rather than the ‘Low’ value stated in this LBS100 document. Given the ‘Moderate’ value of this historic landscape and the ‘High Adverse’ impacts during both construction and operation, the effect of the proposal upon this landscape will be greater (‘Major Adverse’) than the ‘Moderate Adverse’ presented in this table. pg. 11 These as yet undated geophysical anomalies, which are of probable archaeological origin, are described in this document Table 1 as having a ‘Low’ significance/value. There is insufficient LBS102 information available to enable the significance of these features to be determined at this time (e.g. we do not know their date, character, state of preservation etc.); they may be of significantly higher value than presented in this table.

The effect of the proposal upon these remains may therefore be greater than the ‘Moderate Adverse’ presented in this table. pg. 11 It is unclear why this heritage asset has been assigned a ‘Not Significant’ significance/value, when LBS108, which appears to Table 1 be similar in character, has been assigned a ‘Low’ significance/value. LBS107 pg. 11 The Gazetteer of Heritage Assets (ES 3.5.2.16.5) assigns a ‘Low’ significance/value to this heritage asset, rather than the Table 1 ‘Not Significant’ value presented in this table. Given that the proposal will require the removal of a large part of this asset, LBS109 the effect will be greater than the ‘Negligible Adverse’ impact presented in this table. pg. 11 The loss of this heritage asset will have at least a ‘Minor’ effect, that that the ‘Neutral’ effect presented in this table Table 1 LBS112

Table 1 Heritage asset LBS001 (Boddington cropmarks) is not referenced in this document, despite having been identified in General Comments the Gazetteer of Heritage Assets (ES 3.5.2.16.5).

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ES 3.5.2.18.7

Volume, page and Full ES comment paragraph reference

pg. 3 This document states that some parts of the land required by this scheme were not surveyed by LiDAR. No explanation is 2.2.8 given for the absence of survey across these areas.

We do not consider that this is satisfactory. LiDAR survey should be undertaken, and assessed by the cultural heritage specialists, across the whole of the area to be disturbed by this proposal, at the earliest opportunity. Additional survey should also be undertaken across those areas which are outside of the land take for this scheme, but could provide information which would aid in the assessment of the potential archaeological impacts within the areas of land take. pg. 3 Whilst a written description is given of the across which LiDAR survey was undertaken, the survey area is not defined on a 2.2.8 plan. This limits our ability to assess the results of the survey. For example, we cannot determine whether the lack of potentially significant earthworks across certain areas is due to an absence of earthworks, or a lack of survey. pg. 3 The document states that the hyperspectral data provided did not include the mid-infrared range, which is regarded as 2.2.11 holding particularly high potential when attempting to identify archaeological features. This is unsatisfactory.

Section 2 As the full results of both the LiDAR and Hyperspectral survey are not included, i.e. the original LiDAR and Hyperspectral General Comments datasets, it is difficult to fully evaluate the conclusions of the survey report.

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pg. 13 This paragraph references this site having been selected for geophysical survey as it was assessed as having a risk model 3.1.2 score of 3/2 (medium/borderline high risk).

Disappointingly, the Archaeological Risk Model referenced in this paragraph has not been reproduced in the ES. As we have detailed elsewhere, this lack of information about the Archaeological Risk Model significantly limits our ability to critically evaluate the information presented in the ES. pg. 13 This paragraph references a Written Scheme of Investigation having been produced for this geophysical survey. 3.1.8 The Geophysical Survey Technical note which is appended to the Scope and Methodology Addendum (ES. 3.5.0.15.2) states that, prior to the implementation of fieldwork, ‘a Written Scheme of Investigation (WSI) shall be compiled detailing the methodologies to be used for all stages of the works…. and shall be agreed for issue to Local Planning Authority (LPA) (County or Unitary Authority) Archaeologists’.

The Written Scheme of Investigation for this survey was not provided to the Warwickshire County Council Planning Archaeologist; this survey was not therefore undertaken in accordance with the Scope and Methodology Addendum. pg. 20 This paragraph states that ‘for a full account of the recorded heritage assets the appropriate Desk-Based Assessment 3.2.7 (DBA) should be consulted’.

This is not possible as these important documents, which would provide detailed information to support the assertions made throughout the ES, have not been included in the ES. pg. 21 This paragraph references a Written Scheme of Investigation having been produced for this geophysical survey. The 3.2.16 Geophysical Survey Technical note which is appended to the Scope and Methodology Addendum (ES. 3.5.0.15.2) states that, prior to the implementation of fieldwork, ‘a Written Scheme of Investigation (WSI) shall be compiled detailing the methodologies to be used for all stages of the works…. and shall be agreed for issue to Local Planning Authority (LPA) (County or Unitary Authority) Archaeologists’.

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Document: Volume 5: Technical Appendices. CFA16: Ladbroke and Southam. Baseline Report (CH-001-016). Cultural Heritage.

ES 3.5.2.16.4

Volume, page and Full ES comment paragraph reference

pg. 2 The full extent (including which areas were visited) of the walkovers and site reconnaissance undertaken to inform this 1.5.1 assessment is not set out in the ES, nor the timing or ground conditions at the time of these visits. There is also no information presented about which areas were highlighted for survey, but not examined.

We cannot therefore assess the adequacy of this aspect of the Environmental Impact Assessment. pg. 49 This should mention that the landscape adjoining Long Itchington Wood and Print Wood exhibits characteristics of Table 1, woodland assarting and “squatter” type encroachments No.23 (LBS101). pg. 51 Whilst this states that there is “no known archaeology”, LBS091 ‘The Ridgeway’ crosses this area, as detailed in CH-002-016. Table 1 This possibly pre-Roman road is now a green lane and is st No. 26 marked on the 1 ed. OS. pg. 51 We are pleased to note that this paragraph acknowledges that further work is necessary to ‘determine, and confirm, why there 8.1.5 is a lack of evidence’ for the early prehistoric periods.

Pg. 53-54 The selection of the initial research questions identified in section 8.2 should have been informed by the results of the Section 8.2 English Heritage funded ‘Archaeological Resource Assessment of the Aggregates Producing Areas of Warwickshire and Solihull’2 project in addition to the West Midlands Research Framework.

Section 7 The Warwickshire Landscape Guidelines do not appear to have been used when defining the Archaeological Character Areas General comments and Sub-Zones. They should have been.

2 Published in: Alexander, M. Palmer, S. and Chadd, L. (2008) Archaeological Resource Assessment of the Aggregates Producing Areas of Warwickshire and Solihull. English Heritage Project Number 4681. Warwickshire County Council: Warwick.

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Document: Volume 5: Technical Appendices. CFA16: Ladbroke and Southam. Baseline Report (CH-001-016). Cultural Heritage.

ES 3.5.2.16.4

Volume, page and Full ES comment paragraph reference

Section 7 The extent of the Archaeological Character Areas and the Archaeological Sub-Zones are not mapped with the other General comments heritage asset information. This makes it difficult to analyse these in sufficient detail.

214

Document: Volume 5: Technical Appendices. CFA 17: Offchurch and Cubbington. Gazetteer of Heritage Assets (CH-002-017). Cultural Heritage. ES 3.5.2.17.5 Volume, page and Full ES comment paragraph reference Table 1 This paragraph states that table 1 lists the identified non- General Comments designated heritage assets ‘located within the land required to construct the proposed scheme and within the 500m buffer zone’. There are, however, a number of heritage assets which are recorded on the Warwickshire Historic Environment Record but have been omitted from table 1. This may have been a deliberate choice, however, if that is the case, the selection criteria for the inclusion of heritage assets on the list should be fully detailed in this report.

Known heritage assets not included in this gazetteer include:  MWA10208 - Site of Stone Pit, Offchurch  MWA1361 - Possible Site of St Modwenna's Well  MWA2534 - Quarry

[please note, this is not a definitive list, but representative of the range of sites omitted from the assessment] pg. 6, Table 1 The wrong aerial photograph references are given. OFC014 pg. 6, Table 1 The wrong aerial photograph references are given. OFC023 pg. 11, Table 1 The mapped extent of this historic settlement is not clear. OFC049 pg. 11, Table 1 This does not reference the garden associated with OFC051 Weston Hall (HER MWA12987). Detailed analysis of this garden as part of an English Heritage funded project which reviewed historic parks and gardens across Warwickshire has recommended that this be included on the ‘Local List’.

215

Table 1 There is limited referencing to the specific aerial General Comments photographs referred to in this document (e.g. in relation to OFC009, OFC016, OFC0027, OFC028, OFC029, OFC047, OFC048). This makes it difficult for us to identify and examine these photographs ourselves in order to assess the conclusions reached.

Table Cross-referencing against HER numbers throughout this General Comments document is inconsistent

Table 1 The inclusion of National Grid References in this General Comments document would aid the analysis of the data presented.

216

Document: Volume 5: Technical Appendices. CFA 17: Offchurch and Cubbington. Impact Assessment Tables (CH-003-017). Cultural Heritage. ES 3.5.2.17.6 Volume, page and Full ES comment paragraph reference pg. 3, Table 1 Some of the text is missing under ‘Operational impacts – OFC010 nature of impact including mitigation’ pg. 4 This document describes heritage asset OFC016 as Table 1 ‘cropmarks of probable field boundaries shown on aerial OFC016 photographs’. The Warwickshire HER has recorded a cropmark possibly indicating the original line of the Roman road, which appears to divert from the current line of the B4455 at this point (MWA 4759). This potential Roman feature is not referenced by any of the Cultural Heritage reports.

We have not been able to determine whether or not this cropmark is the same as that referred to as OFC016 as insufficient information has been provided to enable us to identify the photographs referred to in this document.

This document also states that heritage asset OFC016 lies outside of the area required for the Proposed Scheme, however, the mapping in the Cultural Heritage Map Books3 shows it lying inside of that area. Should it lie within the construction area then the potential impact of the proposed scheme on this heritage asset should be assessed. If not, the mapping should be amended to more accurately show the extent of this heritage asset. We have been unable to locate the full extent of cropmarks OFC016 ourselves as insufficient information has been provided to enable us to identify the photographs on which this cropmark is shown.

3 Volume 5: Map Books - Cultural Heritage Country North (ES 3.5.1.4.3)

217 pg. 4, Table 1 The text description of the impact references a medium OFC017 adverse, albeit temporary, impact. The ‘Scale of Impact’ and ‘Effect’ fields states that there will be ‘No Change’ and a ‘Neutral Effect’. This is incorrect; these should be corrected to reference the temporary impact detailed in the text description. pg. 7 This states that there is no evidence of above-ground Table 1 remains, which contradicts the Gazetteer of Heritage OFC042 Assets (ES 3.5.2.17.5) which states there are upstanding earthworks. We would agree, however, that there are unlikely to be any operational impacts on this asset. pg. 8 As set out in our comments on the Gazetteer of Heritage Table 1 Assets (ES 3.5.2.17.5), OFC051 does not reference the OFC051 significant garden associated with Weston Hall (HER MWA12987). Any potential impacts upon this garden should be assessed and presented in this document. pg. 8 The ridge and furrow referred to in this document is not Table 1 included in the relevant Gazetteer of Heritage Assets (ES OFC054 3.5.2.17.5), nor is mapped on the relevant cultural heritage maps. It should be.

218

Document: Volume 5: Technical Appendices. CFA 17: Offchurch and Cubbington. Survey Reports (CH-004-017). Cultural Heritage. ES 3.5.2.17.7 Volume, page and Full ES comment paragraph reference pg. 4 There are some sites (e.g. WA17.3, 17.8, 17.11, 17.16, Section 2.3 17.22) identified in the LiDAR and hyperspectral surveys that are not discussed elsewhere. They are not mapped on the relevant Cultural Heritage Map Books (ES 3.5.1.4.3), nor are they listed on the Gazetteer of Heritage Assets for this area (CH-002-017) or the relevant Impact Assessment Tables (CH-003-017).

This is not acceptable, they should be detailed in both the relevant Gazetteer of Heritage Assets and the Impact Assessment Tables. pg. 3 This document states that some parts of the land required 2.2.8 by this scheme were not surveyed by LiDAR. No explanation is given for the absence of survey across these areas.

The document also highlights that there was only limited survey undertaken across the 500m study area.

Additional LiDAR survey should also be undertaken at the earliest opportunity across those areas which are outside of the land take for this scheme, but could provide information which would aid in the assessment of the potential archaeological impacts within the areas of land take.

219 pg. 3 Whilst a written description is given of the across which 2.2.8 LiDAR survey was undertaken, the survey area is not defined on a plan. This limits our ability to assess the results of the survey. For example, we cannot determine whether the lack of potentially significant earthworks across certain areas is due to an absence of earthworks, or a lack of survey.

Pg. 4 This paragraph makes reference to the limitations in the 2.2.13 hyperspectral bandwidth recovered by this survey. This suggests that, as in the other Warwickshire CFAs, the hyperspectral data provided did not include the mid- infrared range, which is regarded as holding particularly high potential when attempting to identify archaeological features. If this is the case, this is unsatisfactory.

220

Document: Volume 5: Technical Appendices. CFA 17: Offchurch and Cubbington. Baseline Report (CH-001-017), Cultural Heritage ES 3.5.2.17.4 Volume, page and Full ES comment paragraph reference pg. 2 This CFA is described as being in North Warwickshire 1.3.1 District – it is actually in Warwick District. pg. 24 As set out in our comments on the Gazetteer of Heritage 6.2.1 Assets (ES 3.5.2.17.5) and the Impact Assessment Tables (ES 3.5.2.17.6) the historic garden associated with Weston Hall (MWA12987) has not been identified as a heritage asset, or the impacts that this scheme will have upon it assessed. Reference to this significant heritage asset is also, unsurprisingly, missing from this document. This should be resolved at the earliest opportunity. pg. 24 The map references in this paragraph are wrong. The 6.3.1 map referenced, CH-01-046, does not exist in the documents submitted with this ES.

Pgs. 25-26 The extent of the Archaeological Character Areas and the Section 7 Archaeological Sub-Zones are not mapped with the other General comments heritage asset information. This makes it difficult to analyse these in sufficient detail.

Pg. 28, Table 1 It is unclear what (A2024-5) is referring to. Should this No. 4 read OFC028 and OFC029? pg. 28 This incorrectly states “No sites have yet been recorded Table 1 within the subzone”. Heritage asset OFC31 is located No. 5 within this area.

Pg. 28, Table 1 This incorrectly states “No sites have yet been recorded No 6 within the subzone”. Heritage asset OFC38 is located within this area

Pg. 26, Table 1 This incorrectly states “No sites have yet been recorded No. 7 within the subzone”. Heritage assets OFC36 and OFC037 are located within this area.

221

Pg. 26, Table 1 This incorrectly states “No sites have yet been recorded No. 8 within the subzone”. Heritage assets OFC35 and OFC36 are located within this area.

Pg. 32-33 The selection of the initial research questions identified in Section 8.2 section 8.2 should have been informed by the results of the English Heritage funded ‘Archaeological Resource Assessment of the Aggregates Producing Areas of Warwickshire and Solihull’4 project in addition to the West Midlands Research Framework.

Section 7 The extent of the Archaeological Character Areas and the General comments Archaeological Sub-Zones are not mapped with the other heritage asset information. This makes it difficult to analyse these in sufficient detail.

Section 7 The Warwickshire Landscape Guidelines do not appear to General comments have been used when defining the Archaeological Character Areas and Sub-Zones. They should have been.

4 Published in: Alexander, M. Palmer, S. and Chadd, L. (2008) Archaeological Resource Assessment of the Aggregates Producing Areas of Warwickshire and Solihull. English Heritage Project Number 4681. Warwickshire County Council: Warwick.

222

Document: Volume 5: Technical Appendices. CFA 18: Stoneleigh, Kenilworth and Burton Green. Gazetteer of Heritage Assets (CH-002-018). Cultural Heritage. ES 3.5.2.18.5 Volume, page and Full ES comment paragraph reference Pg. 1, 1.2.1 This paragraph states that table 1 lists the identified non- designated heritage assets ‘located within the land required to construct the proposed scheme and within the 500m buffer zone’. There are, however, a number of heritage assets which are recorded on the Warwickshire Historic Environment Record but have been omitted from table 1. This may have been a deliberate choice, however, if that is the case, the selection criteria for the inclusion of heritage assets on the list should be fully detailed in this report.

Monuments which have not been included in this gazetteer include:

 The possible site of a watermill, HER ref. MWA2903. A detailed assessment should be undertaken of this possible site as it may form part of a much larger system of historic water management which could be impacted by this scheme.  Medieval drain recorded on site of NAC (MWA MWA2914)  Quarry 250m west of Stareton (MWA2875)  Site of Anti-Aircraft Operations Room, Stoneleigh Park (MWA9174)  Site of Possible Brick Kiln 300m NW of Coventry Road Barn (MWA2528)  Site of Brickworks 400m S of Villiers Hill Farm (MWA3287)  Undated cropmark enclosure (MWA2926)  Medieval holloway located 800m north of Glasshouse Wood (MWA12252)

[please note, this is not a definitive list, but representative of the range of sites omitted from the assessment]

223 pg. 3, Table 1 This has assigned a value of ‘Moderate’ to the OFC041 significance of the River Bytham prehistoric site. This should be assigned a value of ‘High’ due to the national importance of this site. pg. 4, Table 1 The ‘Significance/Value’ of this heritage asset should be STN008 ‘Low’ rather than ‘n/a’. pg. 4, Table1 The ‘Significance/Value’ of this heritage asset should be STN013 ‘High’ rather than n/a. pg. 5, Table1 This record refers to this being the site of a possible STN018 windmill, however, it is not clear where this information has come from (is it perhaps referring to the possible watermill recorded as monument MWA 2903 on the Warwickshire HER?).

The possible former quarry identified by the LiDAR and referred to here is also recorded on the HER, ref MWA2875. This should be referenced in this table. pg. 5, Table1 This does not reference the corresponding HER reference STN019 numbers.

This states the heritage assets across this area are medieval, however, there is a potential that some of the as yet undated features are pre-medieval (see Warwickshire HER MWA 2939).

This does not reference any probable relationships between these heritage assets and Stoneleigh Abbey.

A number of heritage assets which are recorded on the Warwickshire HER and fall within the area defined as STN019 on map CH-01-108 are not referenced in this gazetteer.

224 pg. 8 The assignment of a low value to this site is clearly Table1 incorrect. Whilst the site is named ‘Ridge and furrow south STN044 of Milburn Grange’ the description references other earthworks including possible enclosures and a possible moat having been identified by the LiDAR. These may be associated with the deserted medieval settlement remains to the north-west (STN047).

This would indicate at least a ‘Moderate’ (if not ‘unknown’), rather than ‘Low’ potential. pg. 9, Table1 The association between this asset and the medieval site STN047 of Milburn Grange needs further assessment (only the late 18th century buildings are mentioned in STN045). pg. 10, Table1 Source not identified; extent not accurately mapped. In STN057 the absence of this information, it is difficult to independently assess the significance value of this asset as ‘Low’. pg. 13, Table1 It is unclear how an assessment of ‘Low’ significance was STN103 determined; their possible association with the Crew Lane Romano-British enclosure could indicate a higher significance.

Table 1 Cross-referencing against HER numbers throughout this General Comments document is inconsistent

Table 1 The inclusion of National Grid References in this General Comments document would aid the analysis of the data presented.

Table 1 Various map references are incorrect. General Comments Table 1 This document does not take into account the results of General Comments the geophysical surveys detailed in Section 3 of the CFA18 Survey Reports (CH-0040018). It does not therefore present the full data available at the date of publication. This is unsatisfactory.

Table 1 Para. 3.3.3, pg. 10, of the CFA18 Baseline report General Comments references a Roman flint scatter which is not referred to in this document.

225

Table 1 There is limited referencing to the specific aerial General Comments photographs referred to in this document (e.g. in relation to STN072, STN091). This makes it difficult for us to identify and examine these photographs ourselves in order to assess the conclusions reached.

226

Document: Volume 5: Technical Appendices. CFA 18: Stoneleigh, Kenilworth and Burton Green. Impact assessment tables (CH-003-018). Cultural heritage ES 3.5.2.18.6 Volume, page and Full ES comment paragraph reference pg. 2, Table 1 This asset lies partially within the land required for STN002 construction; the scale of impact and affect must therefore be assessed accordingly. pg. 2, Table1 It is not clear whether the potential impact of noise during STN010 construction and operation upon the setting of these heritage assets has been assessed.

Given that the ‘nature of impact’ summary states that views from the village will change, and that this will only be ‘lessened’ by the proposed planting, it seems unlikely that there will be ‘No Impact’ on significance during operation as stated in this table. Further evidence should be provided to support this conclusion.

In addition, consideration should be given as to whether the proposed ‘extensive new planting’ referenced would result in a negative impact, for example through foreshortening the existing views. pg. 3, Table 1. The extent of this monument is poorly defined, and it lies STN011 very close to the required land take for this scheme. Further assessment of the full extent of this monument should be undertaken in order to determine that it is fully outside of the areas to be disturbed by this proposal, and will not therefore be impacted.

227 pg. 3, Table1 The assessment of the direct material impact as well as STN012 impact on the setting of the Grade II* Registered Park is poor. Key issues are: 1. The assessment fails to take into account the full scope of works associated with the construction and operation of the scheme. For instance, the balancing ponds, pumping station, retaining wall and compound construction and tree planting shown on CT-05-094 and CT-06-094 need to be fully assessed, as does the replacement floodplain storage identified to the east of the proposed route. 2. The overall changes to the legibility of the parkland need to be assessed, beyond just considering the increased “visual severance between the two larger elements of the parkland”. 3. The assessment splits the analysis of impact between the Registered Park and Garden, and other designated and undesignated buildings (e.g. Stare Bridge, STN013; East Lodge, STN015; Parkland buildings, STN016; Ranges around courtyard to west of Gilbert’s Spinney, STN021) and landscape features (e.g. Hedgerow adjacent to Stare Bridge, STN014). This makes is very difficult to assess the cumulative impact of the proposed scheme on the historic estate as a whole. pg. 4, Table1 The assessment of the impact of the proposed scheme on STN013 this asset fails to effectively consider its interrelationship with the wider historic parkland. See comments on STN012. pg. 4, Table1 The assessment of the impact of the proposed scheme on STN014 this asset fails to effectively consider its interrelationship with the wider historic parkland. See comments on STN012. pg. 4, Table1 The assessment of the impact of the proposed scheme on STN015 this asset fails to effectively consider its interrelationship with the wider historic parkland. See comments on STN012.

228 pg. 5, Table This site appears to correspond with MWA2903, Site of STN018 Possible Watermill 300m NW of Park Farm. LiDAR suggests a quarry in this area, but the interpretation given here is of a windmill. This needs further assessment as this site is probably connected to a much larger system of historic water management, which would need to be assessed in its entirety. pg. 5, Table1 The name of STN019 in this impact table and the STN019 Gazetteer of Heritage Assets (ES 3.5.2.18.5) differ. The assessment of impacts presented in this table only references the mill, however, the Gazetteer of Heritage Assets (ES 3.5.2.18.5) also mentions a possible settlements and fish ponds.

It is not clear whether the impact of this proposal upon all of these features, not just the mill referenced in this table, has been undertaken.

In addition, as set out in our comments on the Gazetteer of Heritage Assets (ES 3.5.2.18.5), a number of heritage assets which are recorded on the Warwickshire HER and fall within the area defined as STN019 on map CH-01-108 are not referenced in that gazetteer. The impact of the proposal on those potential heritage assets should also be assessed and presented in this table. pg. 7, Table1 These earthworks are correctly assigned a ‘Moderate’ STN041 significance/value in the gazetteer, but their significance is incorrectly presented as ‘Low’ here.

229 pg. 7, Table1 The assignment of a ‘Low’ value to this site is clearly STN044 incorrect. Whilst the site is named ‘Ridge and furrow south of Milburn Grange’ the description references other earthworks including possible enclosures and a possible moat having been identified by the LiDAR. These may be associated with the deserted medieval settlement remains to the north-west (STN047).

This would indicate at least a ‘Moderate’ (if not ‘unknown’), rather than ‘Low’ potential.

In addition, buried deposits associated with this complex of sites could well extend beyond the area outlined on the mapping and across the area to be disturbed by the scheme; this requires further assessment. pg. 8, Table1 No mention is made of those archaeological features STN052 which have been identified in this ancient woodland through the LiDAR and hyperspectral surveys (see CH- 002-018 Table 1.STN052) – it is not clear whether or not the impact of this proposal upon these heritage assets, rather than just the woodland, has been assessed. pg. 9, Table1 The document concludes that, as the asset lies on the STN055 fringe of the area required for construction, it will not be physically impacted. However, the full extent of this site is presently unknown, and buried deposits associated with this site could extend across the area to be disturbed. Further assessment is necessary to determine the extent of this site before it can be concluded that the proposal will not have an impact upon it. pg. 9, Table1 No mention is made of the ridge and furrow earthworks STN060 identified in the woodland – it is not clear whether or not the impact that the proposal will have upon these earthworks has been assessed.

230 pg. 11, Table1 The description in the relevant Gazetteer of Heritage STN086 Assets (ES 3.5.2.18.5) references features associated with this complex being identified by the LiDAR survey, suggesting they are upstanding, not just the buried remains referenced in this table. We cannot assess the results of the LiDAR survey ourselves as the original plot is not reproduced in the ES. Given that this site is within the proposed route land take, we would expect to see further evidence of why it has been concluded that site will not be impacted by this proposal. pg. 12, Table1 The description in the relevant Gazetteer of Heritage STN095 Assets (ES 3.5.2.18.5) references features associated with this complex being identified by the LiDAR survey, suggesting they are upstanding, not just the buried remains referenced in this table. We cannot assess the results of the LiDAR survey ourselves as the original plot is not reproduced in the ES. Given that this site is within the proposed route land take, we would expect to see further evidence of why it has been concluded that site will not be impacted by this proposal. pg. 12, Table1 The description in the relevant Gazetteer of Heritage STN099 Assets (ES 3.5.2.18.5) references features associated with this complex being identified by the LiDAR survey, suggesting they are upstanding, not just the buried remains referenced in this table. We cannot assess the results of the LiDAR survey ourselves as the original plot is not reproduced in the ES. Given that this site is within the proposed route land take, we would expect to see further evidence of why it has been concluded that site will not be impacted by this proposal.

231 pg. 12, Table1 The description in the relevant Gazetteer of Heritage STN100 Assets (ES 3.5.2.18.5) references features associated with this complex being identified by the LiDAR survey, suggesting they are upstanding, not just the buried remains referenced in this table. We cannot asses the results of the LiDAR survey ourselves as the original plot is not reproduced in the ES. Given that this site is within the proposed route land take, we would expect to see further evidence of why it has been concluded that site will not be impacted by this proposal. pg. 13, Table1 The description in the relevant Gazetteer of Heritage STN107 Assets (ES 3.5.2.18.5) references features associated with this complex being identified by the LiDAR survey, suggesting they are upstanding, not just the buried remains referenced in this table. We cannot assess the results of the LiDAR survey ourselves as the original plot is not reproduced in the ES. Given that this site is within the proposed route land take, we would expect to see further evidence of why it has been concluded that site will not be impacted by this proposal.

Table 1 The potential for the proposed development to impact General Comments upon deposits associated with the prehistoric River Bytham has not been presented in this document. This is a major omission, as any archaeological deposits associated with it are likely to be of national or international significance (see CH-001-018).

This table also omits heritage assets OFC053, which is referenced in the relevant Gazetteer of Heritage Assets (ES 3.5.2.18.5).

Table 1 Whilst this table presents an assessment of the impacts of General Comments this scheme on the historic buildings associated with the Stoneleigh Abbey, little impact has been undertaken of the impact of the proposal upon the wider monastic estate, including any associated buried archaeological remains.

232

Table 1 This document does not take into account the results of General Comments the geophysical surveys detailed in Section 3 of the CFA18 Survey Reports (CH-0040018). It does not therefore present the full data available at the date of publication. This is unsatisfactory.

233

Document: Volume 5: Technical Appendices. CFA18: Stoneleigh, Kenilworth and Burton Green. Survey Reports (CH-004-018). Cultural Heritage ES 3.5.2.18.7 Volume, page and Full ES comment paragraph reference pg. 3 This document states that some parts of the land required 2.2.8 by this scheme were not surveyed by LiDAR. No explanation is given for the absence of survey across these areas.

We do not consider that this is satisfactory. LiDAR survey should be undertaken, and assessed by the cultural heritage specialists, across the whole of the area to be disturbed by this proposal, at the earliest opportunity. Additional survey should also be undertaken across those areas which are outside of the land take for this scheme, but could provide information which would aid in the assessment of the potential archaeological impacts within the areas of land take (for example, LiDAR survey across the potential site of the Stareton deserted medieval settlement (STN011, ES 3.5.2.18.5), could help assess the likely extent of this heritage asset, and whether any archaeological deposits associated with it are likely to extend across the area of to be disturbed by this proposal). pg. 3 Whilst a written description is given of the across which 2.2.8 LiDAR survey was undertaken, the survey area is not defined on a plan. This limits our ability to assess the results of the survey. For example, we cannot determine whether the lack of potentially significant earthworks across certain areas is due to an absence of earthworks, or a lack of survey.

234 pg. 3 The document states that the hyperspectral data provided 2.2.11 did not include the mid-infrared range, which is regarded as holding particularly high potential when attempting to identify archaeological features. This is unsatisfactory.

Section 2 As the full results of both the LiDAR and Hyperspectral General Comments survey are not included, i.e. the original LiDAR and Hyperspectral datasets, it is difficult to fully evaluate the conclusions of the survey report. pg. 11 This paragraph references a Written Scheme of 3.1.9 Investigation having been produced for this geophysical survey.

The Geophysical Survey Technical note which is appended to the Scope and Methodology Addendum (ES. 3.5.0.15.2) states that, prior to the implementation of fieldwork, ‘a Written Scheme of Investigation (WSI) shall be compiled detailing the methodologies to be used for all stages of the works…. and shall be agreed for issue to Local Planning Authority (LPA) (County or Unitary Authority) Archaeologists’.

235 pg. 22 This paragraph references a Written Scheme of 3.2.12 Investigation having been produced for this geophysical survey.

Section 3 The results of the geophysical surveys detailed in Section General Comments 3 have not been included in either the CFA18 Gazetteer of Heritage Assets (CH-002-018), nor the Impact Assessment Tables (CH-003-018). These tables do not therefore present the full data available at the date of publication. This is unsatisfactory.

Document: Volume 5: Technical Appendices. CFA18: Stoneleigh, Kenilworth and Burton Green. Baseline Report (CH-001-018). Cultural Heritage ES 3.5.2.18.4 Volume, page and Full ES comment paragraph reference pg. 2 The full extent (i.e. which areas have been visited) of the ‘site 1.5.1 reconnaissance field inspections’ undertaken to date ‘to review the setting of historic assets and the character and form of the historic landscape’ is not set out in the ES, nor the timing or ground conditions at the time of these visits. We cannot therefore assess the adequacy of this aspect of the Environmental Impact Assessment. pg. 10 The source for the information about the scatter of Roman finds 3.3.3 referenced in paragraph should be included, particularly as it appears neither in the relevant Gazetteer of Heritage Assets (CH-002-018), nor on the mapping.

236

pg. 15 There is no reference to the WW2 usage of this CFA e.g. 3.7 MA9174 - Royal Artillery Anti-Aircraft Operations Room at Stoneleigh Park pg. 28 This section should present a much fuller assessment of the 6.2.1 impact of the proposed scheme on the Stoneleigh registered park. As previously discussed in this, and other CFA documents, the proposed scheme bisects the registered park; we would, therefore, expect much more detailed discussion about the scale and effect of the impacts, including the likely impact on physical landscape features, the setting of the remaining parkland, and the overall legibility of this important heritage asset.

Table 1.14, ASZ 18-14 is not mapped on CH-03-109. 7.3.1 General Comment No reference is made to the Historic Landscape Character data previously provided by the Warwickshire Historic Environment Record. It is not clear whether or not that data informed the Historic Landscape Characterisation analysis presented in Section 6 of this document.

Section 7 The Warwickshire Landscape Guidelines do not appear to have General comments been used when defining the Archaeological Character Areas and Sub-Zones. They should have been.

Pg. 37-38 The selection of the initial research questions identified in Section 8.2 section 8.2 should have been informed by the results of the English Heritage funded ‘Archaeological Resource Assessment of the Aggregates Producing Areas of Warwickshire and Solihull’5 project in addition to the West Midlands Research Framework.

General Comment There are occasional references to planting schemes to reduce the impact on the setting of some heritage assets, and these are shown extensively on construction and operational drawings; the impact of these is not considered within this document.

5 Published in: Alexander, M. Palmer, S. and Chadd, L. (2008) Archaeological Resource Assessment of the Aggregates Producing Areas of Warwickshire and Solihull. English Heritage Project Number 4681. Warwickshire County Council: Warwick.

237

Coleshill

Document: Volume 5: Technical Appendices. CFA19: Coleshill Junction. Gazetteer of Heritage Assets (CH-002-019). ES 3.5.2.19.5 Volume, page and Full ES comment paragraph reference pg. 1 This paragraph states that table 1 lists the identified non- 1.2.1 designated heritage assets ‘located within the land required to construct the proposed scheme and within the 500m buffer zone’. There are, however, a number of heritage assets which are recorded on the Warwickshire Historic Environment Record but have been omitted from table 1. This may have been a deliberate choice, however, if that is the case, the selection criteria for the inclusion of heritage assets on the list should be fully detailed in this report. pg. 5 These as yet undated cropmarks have been assigned a Table 1 ‘Low’ significance/value. Whilst they may be former field COL004 boundaries, there is insufficient information available to enable their significance to be determined with any confidence at this time (e.g. we do not know its date, character, state of preservation etc.); they may be of higher value than presented in this table. pg. 6 This as yet undated cropmark enclosure has been Table 1 assigned a ‘Moderate’ significance/value. There is COL017 insufficient information available to enable the significance of this site to be determined with any confidence at this time (e.g. we do not know its date, character, state of preservation etc.); it may be of higher value than presented in this table. pg. 7 These as yet undated cropmarks have been assigned a Table 1 ‘Low’ significance/value. Whilst we would agree that they COL022 may be former field boundaries, there is insufficient information available to enable their significance to be determined with any confidence at this time (e.g. we do not know their date, character, state of preservation etc.); they may be of significantly higher value than presented in this table.

238 pg. 10 The relevant HER reference for this heritage asset is Table 1, missing (MWA6408) COL067 pg. 13 Confirmation is necessary as to whether or not the ridge Table 1 and furrow across this site is still extant before it is COL094 assigned a significance/value of ‘not significant’.

Table 1 The inclusion of National Grid References in this General Comments document would aid the analysis of the data presented.

239

Document: Volume 5: Technical Appendices. CFA19: Coleshill Junction. Impact Assessment Tables (CH-003-019) ES 3.5.2.19.6 Volume, page Full ES comment and paragraph reference pg. 2 These as yet undated cropmarks have been assigned a ‘Low’ Table 1 significance/value. Whilst they may be former field boundaries, COL004 there is insufficient information available to enable the significance of this site to be determined with any confidence at this time (e.g. we do not know its date, character, state of preservation etc.); it may be of significantly higher value than presented in this table.

The effect of the proposal upon these remains may therefore be greater than the ‘Moderate Adverse’ presented in this table. pg. 2 We agree that this proposal will have a major adverse impact Table 1 upon this potentially nationally significant archaeological site. A COL014 detailed mitigation strategy, including large scale detailed excavation, will be required. pg. 3 We agree that the proposal will have a major adverse impact Table 1 upon this heritage asset during both the construction phase and COL015 during the operation of the railway. Every effort must be made to minimise the permanent impact that the proposal will have upon this historic park and associated features. pg. 3 This as yet undated cropmark enclosure has been assigned a Table 1 ‘Moderate’ significance/value. There is insufficient information COL017 available to enable the significance of this site to be determined with any confidence at this time (e.g. we do not know its date, character, state of preservation etc.); it may be of higher value than presented in this table.

240 pg. 3 These as yet undated cropmarks have been assigned a ‘Low’ Table 1 significance/value. Whilst we would agree that they may be COL022 former field boundaries, there is insufficient information available to enable their significance to be determined with any confidence at this time (e.g. we do not know their date, character, state of preservation etc.); they may be of significantly higher value than presented in this table.

The effect of the proposal upon these remains may therefore be greater than the ‘Moderate Adverse’ presented in this table. pg. 10 Confirmation is necessary as to whether or not the ridge and Table 1 furrow across this site is still extant before it is assigned a COL094 significance/value of ‘not significant’.

The effect of the proposal upon these remains may therefore be greater than the ‘Negligible’ presented in this table.

Document: Volume 5: Technical Appendices. CFA19: Coleshill Junction Survey Reports (CH-004-019) ES 3.5.2.19.7 Volume, page and Full ES comment paragraph reference 2.2.8, pg. 3 Whilst a LiDAR survey was undertaken across the majority of the land required for this scheme, a small area of Chelmsley Wood was not. No explanation is given for the absence of survey across this area.

This area should be surveyed and assessed by the cultural heritage specialists at the earliest opportunity. Additional survey should also be undertaken across those areas which are outside of the land take for this scheme, but could provide information which would aid in the assessment of the potential archaeological impacts within the areas of land take.

2.2.8, pg. 3 Whilst a written description is given of the across which LiDAR survey was undertaken, the survey area is not defined on a plan. This limits our ability to assess the results of the survey. For example, we cannot determine whether the lack of potentially significant earthworks across certain areas is due to an absence of earthworks, or a lack of survey.

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2.2.11, pg. 3 The document states that the hyperspectral data provided did not include the mid-infrared range, which is regarded as holding particularly high potential when attempting to identify archaeological features. This is unsatisfactory.

A full survey using the appropriate infrared ranges for identifying archaeological features should be undertaken at the earliest opportunity, and the data gathered provided to the cultural heritage specialists for analysis. pg. 21 This paragraph references a Written Scheme of Investigation 4.1.9 having been produced for this geophysical survey.

The Written Scheme of Investigation for this survey was not provided to the Warwickshire County Council Planning Archaeologist; this survey was not therefore undertaken in accordance with the Scope and Methodology Addendum. pg. 28 This paragraph references a Written Scheme of Investigation 4.2.6 having been produced for this geophysical survey.

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pg. 34 This paragraph references a Written Scheme of Investigation 4.3.6 having been produced for this geophysical survey.

The Written Scheme of Investigation for this survey was not provided to the Warwickshire County Council Planning Archaeologist; this survey was not therefore undertaken in accordance with the Scope and Methodology Addendum. pg. 41 This paragraph references a Written Scheme of Investigation 4.4.21 having been produced for this geophysical survey.

The Written Scheme of Investigation for this survey was not provided to the Warwickshire County Council Planning Archaeologist; this survey was not therefore undertaken in accordance with the Scope and Methodology Addendum. pg. 47 This paragraph references a Written Scheme of Investigation 4.5.9 having been produced for this geophysical survey.

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Document: Volume 5: Technical Appendices. CFA 19: Coleshill Junction. Baseline Report (CH-001-019). Cultural Heritage ES3.5.2.19.4 Volume, page and Full ES comment paragraph reference pg. 2 The full extent (including which areas were visited) of the 1.5.1 walkovers and site reconnaissance undertaken to inform this assessment is not set out in the ES, nor the timing or ground conditions at the time of these visits.

There is also no information presented about which areas were highlighted for survey, but not examined.

We cannot therefore assess the adequacy of this aspect of the Environmental Impact Assessment.

Section 7 The Warwickshire Landscape Guidelines do not appear to have General comments been used when defining the Archaeological Character Areas and Sub-Zones. They should have been.

Section 8.2 The selection of the initial research questions identified in section 8.2 should have been informed by the results of the English Heritage funded ‘Archaeological Resource Assessment of the Aggregates Producing Areas of Warwickshire and Solihull’6 project in addition to the West Midlands Research Framework.

6 Published in: Alexander, M. Palmer, S. and Chadd, L. (2008) Archaeological Resource Assessment of the Aggregates Producing Areas of Warwickshire and Solihull. English Heritage Project Number 4681. Warwickshire County Council: Warwick.

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245

Curdworth to Middleton

Document: Volume 5: Technical Appendices. CFA 20: Curdworth to Middleton. Gazetteer of heritage assets (CH-002-020). Cultural Heritage

ES 3.5.2.20.5

Volume, page and Full ES comment paragraph reference pg. 1 This paragraph states that table 1 lists the identified non- designated heritage assets ‘located within the land 1.2.1 required to construct the proposed scheme and within the 500m buffer zone’. There are, however, a number of heritage assets which are recorded on the Warwickshire Historic Environment Record but have been omitted from table 1. This may have been a deliberate choice, however, if that is the case, the selection criteria for the inclusion of heritage assets on the list should be fully detailed in this report.

Known heritage assets which have not been included in this gazetteer include:

a) Features recorded during the excavation of the Birmingham Northern Relief Road (MWA9098, MWA9099) b) Hams Hall Garden (MWA12547) c) Site of Clay Pit N of Marston Field Bridge (MWA66000) d) Ridge and Furrow in parish of Middleton (MWA12004) e) Undated gully south of Coneybury Wood (MWA12688) f) Boundary ditch west of Coneybury Wood, Middleton (MWA12689) g) Undated or Early Modern linear features (MWA8039) h) Palaeolithic stone handaxe found in Middleton (discussed in CH-001-020, but not listed in gazetteer) (MWA111) i) Pit surrounded by earth bank (MWA12009) j) A number of findspots e.g. MWA4882, MWA4979, MWA5121, MWA5122, MWA111. [this is not a definitive list, but representative of the range of sites omitted from the assessment] pg. 9 This group of 18th-19th century cottages has been assigned a ‘Not Significant’ significance/value. These Table 1, CWM060 should be assigned a ‘Low’ significance/value. pg. 11, Table 1, The full extent of Dunton Hall Gardens is not mapped (i.e. CWM060 it needs to extend to the East, and across the line of the proposed route) on the relevant maps in this ES.

246 pg. 14, Table 1, The link between this site and CWM021 (the historic mill) CWM077 needs greater emphasis, as this interrelationship has historical significance, particularly given that some buildings are late 18th century in date. This would suggest a ‘Moderate’ rather than ‘Low’ significance/value. pg. 15 This 19th century farmhouse has been assigned a ‘Not Significant’ significance/value. These should be assigned Table 1, CWM082 a ‘Low’ significance/value. pg. 18 This feature is described in CH-001-020, where its possible origin in the reign of Charles II is discussed, as a Table 1 patte d’oie system of rides and landscape features within th CWM108 Middleton Hall Park; this 17 century date would suggest at least a ‘Moderate significance’ (see Aggregate Assessment7 p.189) rather than the ‘Not Significant’ significance/value assigned in this table. This heritage asset is also not shown on the relevant mapping in this ES.

Table 1 There are a number of heritage assets which comprise as yet undated cropmarks (e.g. CWM026, CWM030, General Comments CWM0034, CWM0041, CWM044, CWM050, CWM116). Whilst these have generally been assigned a ‘Moderate’ significance/value, it should be noted that these sites haven’t been examined in detail and there is therefore insufficient information available to enable the significance of these sites to be confidently determined at this time. Some of these heritage assets may therefore be of higher value than presented in this table.

Table 1 There is limited referencing to the specific aerial photographs referred to in this document (e.g. in relation General Comments to CWM001, CWM009, CWM010, CWM029, CWM031, CWM050). This makes it difficult for us to examine these photographs ourselves in order to assess the conclusions reached.

7 Alexander, M., Palmer, S. and Chadd, L. 2008 Archaeological Resource Assessment of the Aggregates Producing Areas of Warwickshire and Solihull Warwickshire Museum Field Services Unpublished Report. Available from http://www.warwickshire.gov.uk/Web/corporate/pages.nsf/Links/F9B702ADF1A7738B802571950047 EE1D/$file/Final+Report_v2_HQ.pdf

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Table 1 A number of the heritage assets detailed in this document are not shown on the relevant mapping in this ES, General Comments including: CWM007, CWM110, CWM112, CWM133, CWM134.

Table, General Cross-referencing against HER numbers throughout this Comments document is inconsistent

Table 1 The inclusion of National Grid References in this document would aid the analysis of the data presented. General Comments

Table 1 The map references in this table are occasionally incorrect. General Comments

Table 1 There is limited referencing to the specific aerial photographs referred to in this document (e.g. in relation General Comments to CWM001, CWM006, CWM010, CWM014, CWM026, CWM030, CWM034, CWM041, CWM050, CWM116, CWM). This makes it difficult for us to identify and examine these photographs ourselves in order to assess the conclusions reached.

Document: Volume 5: Technical Appendices. CFA20: Curdworth to Middleton. Impact Assessment Tables (CH-003-020). Cultural Heritage

ES 3.5.2.20.6

Volume, page and Full ES comment paragraph reference

pg. 2 Whilst this table states that this heritage asset is not within the land required for the construction of the proposed Table 1 scheme, map CH-01-114b shows that the land potentially CWM011 required during construction does, in fact, partially cut across this area. The impact of the proposal on this heritage asset should be re-assessed, taking this into account.

248 pg. 3 Cuttle Mill may lie within an area of land excluded from land required for construction; however, the boundary is Table 1 extremely tight around this site and the impact of the CWM021 proposal on the setting of this heritage asset does not appear to have been assessed. pg. 4 The Scheduled Monument extent buffer appears to extend partially across the land required for construction. Table 1 The material impact on this monument (as opposed to its CWM027 setting) is not considered at all in this assessment. It is clear that associated deposits/earthworks survive within the immediate vicinity of this monument, as indicated in CH-004-020 which could be impacted by this scheme. pg. 4 Whilst this table states that this heritage asset is not within the land required for the construction of the proposed Table 1 scheme, map book ES 3.5.1.4.3 shows that the land CWM029 potentially required during construction does, in fact, partially cut across this area. The impact of the proposal on this heritage asset should be re-assessed, taking this into account. pg. 4 Whilst this table states that this heritage asset is not within the land required for the construction of the proposed Table 1 scheme, map book ES 3.5.1.4.3 shows that the land CWM030 potentially required during construction does, in fact, partially cut across this area. The impact of the proposal on this heritage asset should be re-assessed, taking this into account.

249 pg. 5 The Gazetteer of Heritage Assets (ES 3.5.2.20.5) has assigned a value of ‘Moderate’ to the significance/value of Table 1 this site, however, this table incorrectly states its CWM047 significance/value as ‘Not Significant’. We would strongly disagree with the likely effect of this proposal being ‘Negligible Adverse’ as stated in this table.

As the precise location of the Ironworks at Middleton is unknown, its condition and value has not yet been determined.

The impact of the proposal upon this heritage asset should be categorised as having either an ‘Unknown’ effect, or, given the ‘High Adverse’ impact that the proposal is likely to have on it (as stated in this table), and its likely ‘Moderate’ value should remains associated with it survive across this area, at least a ‘Moderate Adverse’, if not greater, effect should be noted. pg.7 The text description of the nature of the impact references a ‘Major Adverse’ effect, which differs from the ‘Moderate Table 1 Adverse’ effect presented in the ‘Effect’ field.

CWM060 The likely effect of this proposal during both construction and operation should be clarified. pg. 8 Further evidence should be presented to support the assertion that the distance between the proposed scheme Table 1 and the asset “is such that there is not considered to be CWM072 any impact to the setting or structure of this asset”. pg. 9 As detailed in our comments on the Gazetteer of Heritage Assets (ES 3.5.2.20.5), this heritage asset should be Table 1 assigned a ‘Moderate’ significance/value rather than the CWM077 ‘Low’ significance/value presented in this table. pg. 19 As detailed in our comments on the Gazetteer of Heritage Assets (ES 3.5.2.20.5), this heritage asset should be Table 1 assigned a ‘Low’ significance/value rather than the ‘Not CWM082 Significant’ significance/value presented in this table. The assessment of the effect should be updated to take this into account, it is likely to result in a greater impact both during construction and operation than the ‘Negligible Adverse’ impacts presently identified.

250 pg. 11 The interrelationship between these two assets, interdependent elements of the historic landscape should Table 1 be considered, together with the cumulative impact upon CWM099 and CWM100 setting. pg. 11 The heritage assets referred to by ref. CWM103 include a Scheduled Monument. This should be noted in this table. Table 1 Given the national importance of these heritage assets, CWM103 further evidence should be presented to support the assertion that the proposal will only result in a ‘Minor Adverse’ effect upon the setting of these heritage assets.

Document: Volume 5: Technical Appendices. CFA 20: Curdworth to Middleton. Survey Reports (CH-004-020). Cultural Heritage

ES 3.5.2.20.7

Volume, page and Full ES comment paragraph reference

pg. 3 Whilst a written description is given of the across which LiDAR survey was undertaken, the survey area is not 2.2.8 defined on a plan. This limits our ability to assess the results of the survey. For example, we cannot determine whether the lack of potentially significant earthworks across certain areas is due to an absence of earthworks, or a lack of survey. pg. 3 The document states that the hyperspectral data provided did not include the mid-infrared range, which is regarded 2.2.11 as holding particularly high potential when attempting to identify archaeological features. This is unsatisfactory.

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Pg. 3 Whilst a written description is given of the across which LiDAR survey was undertaken, the survey area is not 2.2.8 defined on a plan. This limits our ability to assess the results of the survey. For example, we cannot determine whether the lack of potentially significant earthworks across certain areas is due to an absence of earthworks, or a lack of survey.

Pgs. 3-5 As the full results of both the LiDAR and Hyperspectral survey are not included, i.e. the original LiDAR and Section 2 Hyperspectral datasets, it is difficult to fully evaluate the General Comments conclusions of the survey report. pg. 11 Digital photography has been used to record the heritage assets being surveyed. We normally recommend that 3.1.13 standard film photography be used during archaeological projects across Warwickshire as Warwickshire does not presently have an appropriate digital archive.

The ES does not detail where any digital archives generated throughout this project are to be stored. We would recommend that HS2 identify an appropriate digital archive at the earliest opportunity. If an appropriate digital archive has already been identified, the Local Planning Authority Archaeologists should be advised of the arrangements at the earliest opportunity. pgs. 11-13 The reference numbers for several of the heritage assets referred to in this section are incorrect, with the prefix Section 3 ‘WA5.’ being used instead of the correct ‘WA20.’.

Pg. 13 This paragraph is contradictory. It initially states that “all of the features in the LiDAR interpretation were present on 3.1.40 the ground”, however it subsequently references ridge and furrow in the north of the wood not having been identified due to access issues.

252 pg. 23 This paragraph references this site having been selected for geophysical survey as it was assessed as having a 4.1.2 risk model score of 2 (high risk).

Disappointingly, the Archaeological Risk Model referenced in this paragraph has not been reproduced in the ES.

As we have detailed elsewhere, this lack of information about the Archaeological Risk Model significantly limits our ability to critically evaluate the information presented in the ES. pg. 23 This paragraph states that ‘for a full account of the recorded heritage assets the appropriate Desk-Based 4.1.6 Assessment (DBA) should be consulted’.

253 pg. 30 This paragraph references this site having been selected for geophysical survey as it was assessed as having a 4.2.2 risk model score of 2/3 (medium risk).

Disappointingly, the Archaeological Risk Model referenced in this paragraph has not been reproduced in the ES.

As we have detailed elsewhere, this lack of information about the Archaeological Risk Model significantly limits our ability to critically evaluate the information presented in the ES. pg. 30 This paragraph references a Written Scheme of Investigation having been produced for this geophysical 4.2.7 survey.

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Document: Volume 5: Technical Appendices. CFA 20: Curdworth to Middleton. Baseline Report (CH-001-020). Cultural Heritage

ES 3.5.2.20.4

Volume, page and Full ES comment paragraph reference

pg. 2 The full extent (including which areas were visited) of the site reconnaissance visits undertaken to inform this 1.5.1 assessment is not set out in the ES, nor the timing or ground conditions at the time of these visits.

There is also no information presented about which areas were highlighted for survey, but not examined.

We cannot therefore assess the adequacy of this aspect of the Environmental Impact Assessment. pg. 4 This paragraph should refer to the HER reference number for this Lower Palaeolithic hand axe (MWA111) and/or 3.1.4 any other relevant sources of information about it.

This findspot is omitted from the relevant gazetteer (CH- 002-020).

Pgs. 31-33 The extent of the Archaeological Character Areas and the Archaeological Sub-Zones are not mapped with the other Section 7, General heritage asset information. This makes it difficult to comments analyse these in sufficient detail.

Pgs. 31-33 The Warwickshire Landscape Guidelines do not appear to have been used when defining the Archaeological Section 7, General Character Areas and Sub-Zones. They should have been. comments

Pg. 41-42 The selection of the initial research questions identified in section 8.2 should have been informed by the results of Section 8.2 the English Heritage funded ‘Archaeological Resource Assessment of the Aggregates Producing Areas of Warwickshire and Solihull’8 project in addition to the West Midlands Research Framework.

8 Published in: Alexander, M. Palmer, S. and Chadd, L. (2008) Archaeological Resource Assessment of the Aggregates Producing Areas of Warwickshire and Solihull. English Heritage Project Number 4681. Warwickshire County Council: Warwick.

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E) Ecology The council has no comment to make on this section at this time f) Land Quality Document: Waste and material resources assessment Appendix WM-001-000

Volume, page and Full ES comment paragraph reference

Paras The ES is inadequate in providing detail on how much 17.2.4/18.2.4/19.2.4/2 material is likely to be “beneficially incorporated” within 0.2.4/21.2.4 each CFA area. Given the volumes of excavated material arising across the scheme (or indeed at CFA level), there will be an inevitable environmental impact of managing The construction of the such material. The ES has not adequately quantified these Proposed Scheme amounts, or identified specific end uses/locations of the within the material so the inevitable environmental impacts that would [Warwickshire CFA] arise have not been adequately considered and/or area may also be able assessed. to beneficially incorporate selected types of excess excavated material from other areas along the route.

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g) Landscape & visual assessment Document:

Volume, page WCC previous comment Full ES comment and paragraph (if appropriate) reference Baseline No mention has been Photos have now been included to photographs, given as to whether there illustrate views apart from those Vol. 5 Technical is a photographic record of from private properties. Views from Appendices existing views. Stoneleigh Abbey (CFA 18) are (LVIA) recorded as not publicly accessible and therefore have no photo, however there is access during specified opening times.

Baseline In some instances photographic photographs, Vol. reproduction is poor quality. 5 Technical Appendices Some ‘coloured dots’ are missing (LVIA) from the viewpoint location maps e.g. viewpoint 248.4.002 (CFA 17).

Some of the stated direction of views are wrong as they look in the opposite direction to the Proposed Scheme.

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Photomontages – The direction of view of the The following photomontages still Vol. 5 Map Book photo montages needs appear to be labelled incorrectly: checking to ensure they are labelled correctly. CFA 16: LV-01-110 and LV-01-196: text says north-east but arrows show south-east. CFA 18:

LV-01-121, LV-01-200 and LV-01-247: text says north- west but arrows show north- east. CFA 19:

LV-01-125 and LV-01-128: text says north-east to south-west but arrows show north-east to south-east. CFA 20:

LV-01-132 and LV-01-252: text says north-east but arrows show north-west.

Photomontages – It would be helpful to have The photomontage viewpoints have Vol 5. Map Book the angle and direction of been marked on the maps but in view of photomontages most cases they are not labelled marked on the map. with either the viewpoint reference number or the photomontage number.

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Photomontages – Some of the It is difficult to know the rationale Vol 5. Map Book photomontages appear to for choosing photomontage lessen the impact, locations. especially those where the viewpoint is quite distant At least one is taken from a PRoW from the proposed line. It that will be diverted and therefore is necessary for HS2 Ltd. the viewpoint is irrelevant (LV-01- to produce further 110 and LV-01-196). montages at closer Others are taken in a direction viewpoints, as well as where the Proposed Scheme is in additional ones in the most cutting and will therefore have less sensitive areas. impact, e.g. LV-01-114.

There are some highly sensitive views that do not have a photomontage.

Photomontages – Some photomontages (and Vol. 5 Map Book baseline viewpoint photos) give a distorted appearance when showing a 180o view of a straight road, canal etc. making it appear to have a bend in it. This can be very misleading for the average reader. E.g. photomontage LV-01-132(CFA 20).

Vol. 5 Technical Reference needs to be No reference has been made to the Appendices made to the existing Stratford-on-Avon Special (LVIA) Landscape Character Landscape Areas Study (June Assessments that have 2012) carried out for SDC, which CFA 16, been used. identifies and describes the p.4 Ironstone Hill Fringe LCA (despite this being brought to the attention of HS2 at a meeting with WCC officers in July 2013).

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Vol. 5 Technical There is inconsistency in the Appendices assessment of LCA sensitivity. The (LVIA) River Tame Floodplain LCA has only fair condition and low CFA 16, tranquillity but high sensitivity, p.4 and whereas the Radbourne Ironstone CFA 19 Fringe LCA has good condition, p.12 high tranquillity but only medium sensitivity.

Vol. 5 Technical Inconsistency – Bubbenhall Plateau Appendices Farmlands LCA is described as (LVIA) having low tranquillity but under the sensitivity heading it says medium CFA 18, tranquillity. p.9

Vol. 5 Technical Map references don’t correspond to Appendices the numbers on the maps. (LVIA) CFA 18, p.14

Vol. 5 Technical There appears to be some Appendices inconsistency in the assessment of (LVIA) landscape value. Balsall Common Rural LCA is valued at Borough CFA 18, p.13 level due to its network of PRoWs, whereas in other LCAs a PRoW network only results in a local value.

Vol. 5 Technical M42 Corridor LCA doesn’t appear Appendices to be shown on the aerial (LVIA) photograph LCA maps in Vol. 5 Map Book. CFA 19, p.4

Vol. 5 Technical Missing word at end of sentence: Appendices (LVIA) “Both rivers are narrow and are generally fringed by.” By what?! CFA 19, p.7

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Vol. 5 Technical Inconsistency – River Tame Appendices Floodplain LCA is assessed to (LVIA) have high sensitivity whereas other LCAs with the same (or higher) CFA 19, p.12 condition, tranquillity and value are only assessed as medium sensitivity, e.g. Marton Vale Farmlands, Leamington Plateau Fringe, Bubbenhall Plateau Farmlands, Stoneleigh Parklands, Cole Valley, Middleton to Curdworth Tame Valley Farmlands, Tame Valley Wetlands, Wishaw to Trickley Coppice Wooded Uplands.

Vol. 5 Technical Inconsistency – Tame Valley Appendices Wetlands LCA is assessed as (LVIA) CFA 19, having medium sensitivity but the pages 7, 65 and tables in Part 4, Chapters 7 and 8 69 state it has high sensitivity.

This is the same for CFA 20, and Blythe Valley Parkland Farmlands in CFA 19 (Permanent effects table).

Vol. 5 – Scope & Only a brief rationale has been Methodology given for the timeframe of the Report, para assessment, i.e. 1, 15 and 60 12.5.7, p.122 years. Further information is required, especially with regard to the reason for a 60 year assessment as this looks a long way into the future and it is unclear as to the relevance of this.

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Vol. 5 Technical Bubbenhall Plateau Farmlands Appendices LCA is assessed to have low (LVIA) tranquillity due to Coventry Airport, Middlemarch Business Park & a CFA 17, p.9 sewage works. However, these are distant from the Proposed Scheme and do not influence the LCA near to the scheme e.g. in the Cubbington area.

h) Socio Economic The council has no comment to make on this section at this time i) Sound, Noise & Vibration The council has no comment to make on this section at this time

j) Traffic, & Transport; incorporating PROW, highway design and Traffic Safety Volume 5 – Offchurch Chapter 4. The method of surveying PROW does not take into account the typical and Cubbington as an use or transient nature of use of PROWs. It is stated in the results that the duration example of the survey was 15 minutes with at least 2 hours between surveys (4.4.5 for e.g.) despite the introduction to the survey process stating that the surveys were continuous (4.1.3). There appears to be a serious contradiction between the stated process and the actual survey with a mis-match between PROW survey and open space survey. It is not clear which survey was actually carried out and therefore any results have to be viewed with scepticism.

HS2 gives a verdict on the usage of the routes as being low or high etc. (e.g. 4.4.7) but it is not clear whether this verdict is based on the PROW industry figures or survey methods or whether it was based on comparisons with urban routes and takes into account the actual location.

This is not a satisfactory method of determining use of a PROW. In some cases, particularly on promoted routes, the survey may show use but on other routes no users may be spotted in those 15 minutes despite the route in general being well used (and potentially heavily used in the other 1 hour 45 minutes between surveys). The survey results published in volume 5 are only of selected named routes which does not reflect the PROW network within Warwickshire. Volume 5 – HS2, within Section 2 Community, comments on the impact of HS2 on some select Community PROW and how it will be of minor adverse effect and not significant. The effect of users of a route having to pass through a construction site must not be underestimated. The perception of lack of safety, noise, dust etc. have a detrimental effect on the amenity value for users and will stop use of the routes.

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Traffic Document: ES Volume 5:- Traffic and Transportation / Road Safety Audits (ref Vol 5 – Traffic Assessment – Part 7 ES3.5.0.12.7)

ROAD SAFETY

Prior to the submission of the full Environmental Statement (ES), Warwickshire County Council (WCC) as the Local Highway Authority were in receipt of a complete set of Stage 1 Road Safety Audits (RSA). These have been examined in parallel to the ES. The following matters have arisen :

It is noted that the Audit Team/s were given specific instructions not to visit any locations/highways affected by the route of HS2 as required by the relevant standard (HD19/03). WCC consider this to be an wholly unacceptable approach, the consequences of which could have implications for road user safety and land take required to address these concerns; e.g. junction type, tie-ins.

The Forum maps enclosed in the ES supersede those examined in the RSA. As a consequence, the drawings and chainage points referenced in the RSA do not correlate with the plans being examined on the Forum Maps enclosed with the ES. As the Road Safety Audits reports have only provided plans where safety concerns have been identified it is not possible to ascertain what alterations the auditors examined. WCC are therefore of the opinion that a number of alterations to the highway have not been Safety Audited.

Many of the highway alignments particularly at over-bridges will necessitate the creation of embankments. A Road Restraint Risk Assessment procedure will be required on any roads affected the recommendations from which will need to be implemented in full.

The approach taken to conducting RSA’s at an appropriate point in the planning of the scheme is wholly unacceptable to WCC.

HS2 have sought to provide their own justification of an accident location which if likely to be impacted on would require further investigatory work (Intervention level) of 9 Personal Injury Accidents in a 3 year. WCC Policy sets an intervention level of 6 in 3 yrs. In addition, there has been no consideration of route wide accidents along identified haul routes. WCC request further dialogue with HS2 in this regard.

WCC request a reappraisal of potential or known accidents sites /

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routes nearer to key dates of construction activities.

WCC consider that the Road Safety Audits should have been an appended item within the ES submission.

Greater consideration also needs to be given to the impact on cyclists and pedestrians from construction activities

k) Water Resource & Flood Risk Document: Volume 5, Route-wide appendix (WR-001-000) Water Resources

Volume, page Full ES comment and paragraph reference

Page 99, Paragraph 4.3.7 on page 99 states that a ‘drainage paragraph 4.3.7 management plan *could* be compiled for each railway system…to record the strategy for achieving prescribed levels of serviceability and maintenance of drainage system(s)’ [our emphasis]. This must be included as part of the drainage strategy which must be done for each railway system to be sure that ‘the works will have no impact on surface water flood risk’.

Water Resource & Flood Risk Document: Volume 5, CFA 16, Ladbroke and Southam Flood risk assessment (WR-003-016)

Volume, page Full ES comment and paragraph reference

Page 9, Culvert openings in the existing embankments are all assumed paragraph 2.6.6 to be 5 metres wide. This is a gross assumption, which is not justified and which could have major consequences. There are not a great number of these openings, and since the whole project is costing the taxpayer around £43 billion, it would be worth investing a day or two of someone’s time identifying the size of these openings.

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Page 10, The document states that ‘The calculations for the proposed paragraph 2.6.18 drainage design have been completed in line with the requirements in Volume 1, Section 9.’

The only relevant requirements stated in Vol 1 Section 9 are in 9.15.1 and 9.15.2. These state that the Proposed Scheme design will include SuDS and follow NPPF. There is no evidence of any drainage calculations having been undertaken, nor any commitment that they will be undertaken in the future.

Page 13, The document states that ‘In line with NPPF technical guidance, paragraph 3.2.2 increases in peak rainfall intensity and peak river flow of 20%, as a result of climate change, have been allowed for as per the period 2085 to 2115.’ This is incorrect. Table 5 on Page 11 of the NPPF technical guidance states that an allowance of 30% for increases in peak rainfall intensity should be made to account for climate change between 2085 and 2115. It would therefore appear that this flood risk assessment has not accounted adequately for climate change.

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Page 19, There are various references to the ‘Local Lead Flood Authority’ paragraph 5.2.2 (for example, paragraph 5.2.2). This should read ‘Lead Local Flood Authority’. The documents claim that HS2 have already engaged with LLFAs – this would suggest otherwise. Our engagement from HS2 consisted of a short-notice site visit on 17th July 2013 during which we asked HS2 to consider, amongst other things, betterment for the flood-prone village of Ladbroke. This would involve minimal additional modelling, and could have the advantage of providing flood relief to the village of Ladbroke while reducing construction costs for HS2 and reducing the environmental impact (due to less material needing to be sent off-site). There has been no feedback from the HS2 team on the suggestions made by WCC and the EA during that meeting, in spite of promises from the HS2 team that this would be done, both during the site visit and in writing on 29th July 2013, 20th September 2013, and on 11th October 2013, after repeated written requests from the EA on 14th August 2013, 2nd September 2013, 20th September 2013, 11th October 2013 and 13th October 2013. There is no indication in any of the documentation relating to the Ladbroke section (CFA 16) that flood attenuation upstream of HS2 has ever been considered, or that it will ever be considered in the future. Failure to consider this contravenes HS2’s stated sustainability policy of ‘contributing to protecting and enhancing our natural, built and historic environment’ (in Volume 1, paragraph 1.5.4).

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Page 38, The Ladbroke (CFA 16) boldly states that ‘the works will have paragraph 8.2.10 no impact on surface water flood risk’ due to the fact that ‘The potential impact of the Proposed Scheme on surface water movement, not identified as above, will be incorporated within the scheme design.’ There is no evidence to back this up. It is expected that a drainage strategy will be undertaken for each section of the railway, although there is no indication of a commitment: (i) that this will be done, (ii) how this will be done, (iii) whether these will be submitted for approval to planning authorities and statutory and non-statutory consultees. Furthermore, Paragraph 4.3.7 on page 99 of the Water Resources Route-wide appendix (WR-001-000) states that a ‘drainage management plan *could* be compiled for each railway system…to record the strategy for achieving prescribed levels of serviceability and maintenance of drainage system(s)’ [our emphasis]. This must be included as part of the drainage strategy which must be done for each railway system to be sure that ‘the works will have no impact on surface water flood risk’.

Page 40, 8.2.19 and 8.2.20 glibly state that, although there is a high risk paragraphs 8.2.19 at several locations of temporary works stated in Table 9 and and 8.2.20 paragraph 8.2.16 on the same page, ‘the works will be completed in line with the CoCP and hence the design of the temporary works will prevent an unacceptable level of surface water flood risk on site…and will not cause an increased risk elsewhere from surface water flooding’. The word ‘unacceptable’ is not defined in this context here or elsewhere in the ES. The CoCP does not provide for adequate mitigation of this high risk (see separate section on the CoCP).

Page 40, Paragraph 6.5.2 of the same document concedes that the paragraph 8.3.1 overall risk of groundwater flooding is high around the River Itchen, to the north of the Oxford Canal and south of Ladbroke, yet without any evidence paragraph 8.3.1 states that ‘The proposed Scheme within this study area overlies multiple aquifers however the works proposed are not expected to increase groundwater flood risk’. HS2 must undertake groundwater investigations in areas of high risk to ascertain water levels and therefore ensure that existing groundwater flow routes will not be interrupted, or if they are interrupted that an adequate mitigation is put in place and maintained.

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Page 47, The document quotes that an internal headroom of 300mm will paragraph 9.2.7 be used in culverts to minimise the risk of blockage. This must not be a replacement for proper silt management and well- designed and maintained / cleared trash screens upstream of these culverts.

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Code of Construction Practice

The council wishes to provide comments on a number of sections in the CoCP. Where the council has not provided comment, this should not be taken as agreement or consent for the text.

Section 3 – Policy and environmental management principals Document: Volume 5: Technical Appendices. Draft Code of Construction Practice (CT-003-000)

ES 3.5.0.17 3.4.1 – Environmental WCC requests that the EMS is developed with key Management Systems stakeholders at the earliest opportunity to allow adequate (EMS) time to establish baseline monitoring and adoption of local changes in project details for activities in Section 6-16 of the CoCP.

Section 4 Implementation Document: Volume 5: Technical Appendices. Draft Code of Construction Practice (CT-003-000) ES 3.5.0.17 4.2 – Local Environment WCC requests early development of a pilot Local Management Plans Environmental Management Plan (LEMP) to ensure the thoroughness of the environmental and community protection measures associated with Sections 6-16 of the CoCP.

The development of a sample LEMP will aid contractor’s in their bidding for work and ensure greater consistency on a route wide basis. 4.3 Site Management - The large extent of self-monitoring by the lead Monitoring contractor appears inappropriate.

It is imperative that for all activities of Sections 3-16 of the CoCP are effectively monitored. Where appropriate stakeholders, including communities and WCC, will require independent monitoring to be carried out to ensure all activities are done to best practice and relevant statutory requirements.

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Section 8: Cultural Heritage Document: Volume 5: Technical Appendices. Draft Code of Construction Practice (CT-003-000)

ES 3.5.0.17

Volume, page WCC previous DES Full ES comment and comment paragraph reference pg. 9, 4.3.3 We are pleased to note that the nominated undertaker ‘will require all contractors to employ an appropriately qualified and suitably experienced workforce, where appropriate, this will include holding a registration with relevant recognised competence schemes’. pg. In order to help reduce the likelihood of accidental damage to any heritage 5.3.1 assets this list of measures should include the provision of map(s) showing those areas which contain, or potentially contain, heritage assets. These map(s) should clearly define any areas across which no groundworks, material storage (e.g.. bunding, site huts etc.), and/or vehicle movements are to take place (for example, across archaeologically sensitive areas, in the vicinity of sensitive historic structures etc.).

We note that para. 3.1.3 does reference the provision to contractors of locations and descriptions of all known cultural heritage assets within and adjacent to, construction work, however we consider that it is also appropriate to reference the provision of cultural heritage information in this section.

270 pg. 30 Paragraphs 8.1.2 should This paragraph should make make reference to the reference to relevant Codes of 8.1.2 relevant Codes of Conduct Conduct in addition to accepted in addition to accepted industry practice and guidance. We industry practice and would expect this section to include guidance. We require this reference to specific relevant section to include guidance, including the IFA Standards reference to specific and Guidance documents and Code relevant guidance, of Conduct, English Heritage including the IFA specialist guidance9 etc. Standards and Guidance documents and Code of Conduct, English Heritage pg. 30 Paragraph 8.1.3 makes The first bullet point makes reference reference to the protection to the provision of information 8.1.3 of all known heritage (including locations) to the relevant assets where these have contractors of all known heritage been identified in the ES. assets where these have been As already stated in this identified in the ES. Further survey section, further survey work is to be undertaken prior to, and work is to be undertaken during, construction which may prior to, and during, identify further heritage assets or construction. This may areas of potential archaeological identify further heritage sensitivity which have not been assets which may require specifically identified by the ES but protection, despite not will require protection. having been specifically identified by the ES. A strategy must be in place The contractors should be provided to protect any such with locations and descriptions of all features, and this section (not just those identified in the ES) must state that these known cultural heritage assets and features will also be areas of potential archaeological protected as necessary. sensitivity, within and adjacent to, construction works, including restrictions to construction methods to protect cultural heritage assets.

9 for example, ‘Environmental Archaeology: A Guide To The Theory And Practice Of Methods, From Sampling and Recovery to Post-Excavation’, ‘Geophysical Survey in Archaeological Field Evaluation’,

271 pg. 31 The wording of para. 8.1.4 The wording of the first bullet point suggests that, should suggests that, should damage due to 8.1.4 damage due to settlement settlement occur despite the occur despite the implementation of controls at each implementation of controls site to avoid this, the effects would be at each site to avoid this, recorded only, rather than the cause the effects would be of the impact being assessed and the recorded only, rather than controls amended if possible. Whilst the cause of the impact we presume that the mitigation being assessed and the strategy (including the implementation controls amended if of controls etc.) will be continuously possible. reviewed throughout the project, we would have more confidence in this if this document specifically stated so.

Whilst we presume that the mitigation strategy (including the implementation of controls etc.) will be continuously reviewed throughout the project, we would have more confidence in this if this document specifically stated so. pg. 31 There are references This paragraph references the throughout this document ‘implementation of controls at each 8.1.4 to things being undertaken site to avoid damage by settlement ‘where practicable’. It is where ‘reasonably practicable’. Who not clear what or who will determine what is ‘reasonably would define something as practicable’? ‘practicable’ or otherwise. WCC is concerned that time and monetary constraints may unduly influence this definition. WCC seeks assurance that corners will not be cut and ‘practicable’ is not used as an excuse for cost saving.

272 pg. 31 The fifth bullet point of The fifth bullet point should state that paragraph 8.1.4 needs to any materials related to the demolition 8.1.4 state that any materials of buildings which are to be re-erected related to the demolition of will be securely stored and protected. buildings which are to be re-erected will be securely stored and protected pg. 31 This section should make reference to implementation of controls at each 8.1.4 site to avoid damage by vibration to any archaeological deposits or structures of historic importance or interest both within and outside of the HS2 landtake. This should include any heritage assets which could be impacted, not just those lying within the 50m referenced in para. 13.2.27 of this document (chapter 13: Noise and Vibration).

273 pg. 31 Paragraph 8.1.5 makes This paragraph makes reference to no reference to no metal metal detecting being undertaken 8.1.5 detecting being within areas of identified/defined undertaken within areas of archaeological interest. It is not yet identified/defined clear when these defined areas will be archaeological interest. It identified, and whether the term is not yet clear when these ‘areas of identified/defined defined areas will be archaeological interest’ will include identified, and whether the areas across which survey works term ‘areas of have not yet been undertaken, in identified/defined particular those areas of ‘unknown’ archaeological interest’ will archaeological potential. include areas across which survey works have not yet been undertaken, Metal detecting across the HS2 land in particular those areas of take or any other groundworks (apart ‘unknown’ archaeological from that being undertaken as part of potential. Metal detecting the evaluative and/or mitigative across the HS2 land take archaeological works), should be or any other groundworks restricted until an appropriate, (apart from that being identified, post holder has formally undertaken as part of the confirmed that an area is of no evaluative and/or archaeological interest. mitigative archaeological works), should be restricted until an area has

been formerly ‘signed off’ by an appropriate, identified, post holder.

This paragraph also makes reference to the Project Manager being informed should artefacts of archaeological interest or expected interest be located. It is not clear what will happen next.

WCC wishes to see a more robust statement in the next draft.

274 pg. 32 Whilst paragraph 8.3.1 Whilst paragraph 8.3.1 states that states that monitoring will monitoring will be undertaken 8.3.1 be undertaken throughout throughout the project, it fails to state the project, it fails to state what will be undertaken should the what will be undertaken monitoring identify a problem. It should the monitoring should confirm that actions will be identify a problem or the taken to investigate and address the remedial actions. cause of the problem.

General There are references There are references throughout this Comments throughout this document document to things being undertaken to things being undertaken ‘where practicable’ or ‘reasonably ‘where practicable’. It is practicable’. It is not clear who will not clear what or who determine whether or not something would define something as is reasonably practicable – there is a ‘practicable’ or otherwise. concern that time and monetary WCC is concerned that constraints may unduly influence this. time and monetary constraints may unduly influence this definition. WCC is concerned that time and WCC seeks assurance monetary constraints may unduly that corners will not be cut influence this definition. WCC seeks and ‘practicable’ is not assurance that corners will not be cut used as an excuse for cost and ‘practicable’ is not used as an saving. excuse for cost saving.

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General It is likely that there will be It is likely that there will be parts of the Comments parts of the scheme (such scheme (such as the construction of as the construction of site site compounds, temporary access compounds, temporary tracks etc. requiring no or minimal access tracks etc. groundworks), whose construction will requiring no or minimal be unlikely to have an impact upon ground works), whose any underlying archaeological construction will be deposits (either previously identified unlikely to have an impact or not) and hence will not require any upon any underlying evaluative or mitigative fieldwork prior archaeological deposits to, or during, their construction. We (either previously identified would recommend that the document or not). Hence they will not references ensuring that the require any evaluative or reinstatement of any such areas (in mitigative fieldwork prior addition to their original construction) to, or during, their be undertaken in such a way to construction. We would minimise any inadvertent impact upon recommend that the any underlying archaeology. document references the need to ensure that the reinstatement of any such areas (in addition to their original construction) be undertaken in such a way as to minimise any inadvertent impact upon any underlying archaeology.

Section 12: Landscape & visual Assessment Document: Volume 5, Draft Code of Construction Practice, CT-003-000

Code of This is very general and is not site specific at all – it could have Construction been written for any scheme. Practice – The references made to it in each CFA report (vol. 2) don’t give general confidence that every effort will be made to retain as much existing vegetation as possible, or any indication of what vegetation will be retained or removed. Code of This says the landscape will be maintained “throughout the Construction Construction Period”, however WCC require it to be maintained Practice, para for a minimum of 5 years post completion of the scheme, and any 12.4.3 failures replaced.

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Section 13: Sound, Noise & Vibration Document: Volume 5, Draft Code of Construction Practice, CT-003-000

Volume, page Full ES comment and paragraph reference The Code of Construction Practise is an important document and is made reference to throughout the ES as the primary method of controlling construction impacts on communities. It is the key document in controlling construction noise, dust and land contamination. It details how local environmental teams will liaise with the communities and develop local solutions to control construction impacts. The document’s credibility is borne from the proposal to place these measures into a legal consent as agreed by the local authority (s61 Control of Pollution Act 1974). However, there are additional construction controls that are not being made available for open consultation. These are contained in Schedule 25 of the Hybrid Bill and are provisions that weaken the credibility of the CoCP. These provisions change the s61 consent appeal process by moving it from the jurisdiction of the courts and referring it directly to Government. The provisions also make the project immune from Statutory Nuisance if a S61 is in place. We believe that diverting the appeal procedure of a Government sponsored project from the independence of a court procedure to the Government leaves the CoCP with a lack of credibility. We believe HS2 should remove the Schedule 25 provisions from the Hybrid Bill in order to retain the integrity of one of the most important documents of the ES.

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Section 15; Minerals and Waste Document: Volume 5, Draft Code of Construction Practice, CT-003-000

Volume, page Full ES comment and paragraph reference Page. 39, para. 11.1.1 “The nominated undertaker will Previous comments in July Draft ES: require that its WCC considers that the sterilisation of important mineral resources contractors will adopt must be considered as a potential route wide issue. Most adopted appropriate measures mineral plans, if not all, contain policies that seek to prevent the to protect geological sterilisation of mineral resources and secure the prior extraction of the resources, to mitigate mineral where practicable and environmentally feasible. the sterilisation or severance of mineral The CoCP does not specify what measures HS2 consider would areas and to assess be “appropriate” in terms of mitigating the potentially sterilisation/severance of mineral areas. We consider that in contaminated land, accordance with national policy, HS2 should undertake a and where necessary detailed mineral assessment for the entire route examining: undertake - permitted mineral sites on/in proximity of the route remediation.” - potential/allocated mineral sites on/in proximity of the route - areas of mineral resource on/in proximity of the route Where mineral resource is identified, detailed borehole information should be produced to determine the depth and quality of the resource. Consultation should be undertaken with MPAs and the minerals industry to determine whether the volume and quality of the material is of potential value, and whether the prior extraction is “practicable and environmentally feasible” (para 143, bullet point 5 of the NPPF). Such an approach would embody the principles of sustainable development set out in Government national planning policy guidance.

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Page 39, para. Where excavated material is to be reused within the scheme for 11.2.2 “The embankments, environmental mitigation earthworks or agreed third nominated party use, we would like to see a detailed justification in the Material Management Plan that demonstrates that the quality and quantity of undertaker and its material in that location is the most appropriate and that the use contractors will be represents the most sustainable method of managing the material. In required to consult the case of the third party use, an inspection and monitoring schedule with the Mineral should be established to ensure that the material is used in Planning Authority accordance with the purpose and methods of working prescribed. and other relevant stakeholders with regard to mitigating the loss of mineral resources by appropriate prior extraction of them for use within construction.” Page 46, para 12.3.5 Where excavated material is to be reused within the scheme for “Reusable excavated embankments, environmental mitigation earthworks or agreed third material will be party use, we would like to see a detailed justification in the Material handled in an Management Plan that demonstrates that the quality and quantity of appropriate manner material in that location is the most appropriate and that the use to ensure it is of represents the most sustainable method of managing the material. In sufficient quality to be the case of the third party use, an inspection and monitoring schedule should be established to ensure that the material is used in used for either accordance with the purpose and methods of working prescribed. structural embankments, environmental mitigation earthworks or agreed third party use. Appropriate construction good practice in handling all material re-use will be followed, and controls set out in Sections 7.2 and 9 of the CoCP will apply.”

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Section 14; Traffic and Transport General Traffic – The CoCP sets out many meaningful actions to manage the delivery CoCP and related of HS2. However, it is evident that that the cumulative traffic impact of suite of ES well over 100 constructions sites in Warwickshire appears documents underestimated. An example is the movement of excess spoil from CFA’s 16,17 and 18 which could cause significant congestion on the highway network and communities. HS2 have failed to date to effectively show the scale of HGV movements around communities such as Ladbroke, Southam and Coleshill. Construction traffic will inevitably result in wider “off-route” effects causing “rat runs” which will warrant actions that need to be considered well in advance of 2017.

Construction traffic associated with the scale of HS2 project is near universally felt a very significant concern of residents, businesses and the highway authority in its role of proving a safe environment for all road users and ensuring “Warwickshire is open for business”

WCC requires that construction traffic and transport needs to be reviewed at both sub-regional and local level.

3.4.1 – WCC requests that the EMS is developed with key stakeholders at Environmental the earliest opportunity to allow adequate time to establish baseline Management monitoring and adoption of local changes in project details. Systems (EMS) – Traffic and Transport related 4.2 – Local WCC requests early development of a pilot Local Environmental Environment Management Plan (LEMP) to ensure the thoroughness of the Management Plans environmental and community protection measures associated with – Traffic and Sections 6-16 of the CoCP. Transport related The development of a sample LEMP will aid contractor’s in their bidding for work and ensure greater consistency on a route wide basis. 4.3 Site The extent of self-monitoring by the lead contractor appears Management - inappropriate. Monitoring It is imperative that for all activities of Sections 3-16 of the CoCP are effectively monitored. Where appropriate stakeholders, including communities and WCC, will require independent monitoring to be carried out to ensure all activities are done to best practice and relevant statutory requirements.

14.2.4 Traffic WCC requires early development of a pilot Traffic Management Plans Management Plans for all the CFA 16-20. (TMP’s) To date, the engagement with highway authorities in considering suitable haulage routes has been very limited. Since the draft ES, HS2 Ltd has identified some 40 construction traffic “pinch-points” in the ES which will need to be reviewed and appropriate actions taken well in advance of major HS2 earthwork movements.

Section 6.3.33 of Vol 1 – Introduction to the Environmental Statement

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and the Proposed Scheme (Vol1ES) rightly sets out that “highway works required to accommodate construction traffic will be identified”. Required works need to be agreed at the earliest opportunity and included in the local TMP and LEMP documents.

Special attention is required for the safety of pedestrians and cyclists in respect to the very high construction HGV flows. The design for all new highway bridges in Warwickshire for HS2 needs to consider adequate lane width for both pedestrians and cyclists to mitigate the general reduction in sight visibility compared to existing “At-Grade” conditions.

14.3.1- Monitoring WCC requires that a traffic control system and appropriate resources are established to monitor traffic with real time information shared across the sub-region highway authorities (Warwickshire, Coventry, Solihull, Birmingham, Staffordshire and Northamptonshire), contractors, emergency services and media.

The condition of the Warwickshire highway network will need to be assessed before, during and after the construction of HS2 to assess and agree appropriate works and cost liabilities related to the HS2 project

Section 16: Water resources and flood risks Document: Volume 5, Draft Code of Construction Practice, CT-003-000

Volume, page Full ES comment and paragraph reference General comment This response with respect to Flood Risk Management is from Warwickshire County Council as Lead Local Flood Authority and therefore relates to ordinary watercourses and surface water, with the assumption that the Environment Agency as a statutory consultee will be commenting on main river flood risk, Flood Zones, and all Water Framework Directive related matters.

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Document: Volume 5, Draft Code of Construction Practice, CT-003-000

Volume, page Full ES comment and paragraph reference Page 69, The document states that ‘The contractors will consult with the paragraph 16.3.2 relevant regulatory bodies and other relevant risk management authorities.’ While this should be reassuring, if the consultation is similar to that already undertaken (see above) then I will not expect to hear from HS2. The CoCP should clearly state that Flood Defence Consents on Ordinary Watercourses will be sought from Lead Local Flood Authorities (following the 2010 Flood and Water Management Act amendments to the 1991 Land Drainage Act), and Flood Defence Consents on main rivers will be sought from the Environment Agency.

Page 69, The document states that ‘The contractors will submit, where paragraph 16.3.4 appropriate, a report on flood risk to the nominated undertaker every three months.’ [our italics]. There is no indication of what ‘appropriate’ means. This level of ambiguity is not acceptable

Page 69, The document states that ‘The contractors will submit, where paragraph 16.3.5 appropriate, a report on flood risk to the nominated undertaker every three months.’ [our italics]. There is no indication of what ‘appropriate’ means. This level of ambiguity is not acceptable

Page 70, Paragraph 16.4 seems to suggest that contractors will be left to paragraph 16.4.3 monitor themselves during the construction. This is unacceptable – monitoring must be undertaken by HS2 or independent third parties.

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Scope & Methodology Report:

Culture & Heritage Document: Volume 5: Technical Appendices. Scope and methodology report (CT-001- 000/1) ES 3.5.0.15.1 VOL Volume, page WCC previous comment (if Full ES comment and paragraph appropriate) reference pg. 73 The baseline data collated The baseline data collated should 8.2.7 should include: include:  the assessment reports  the assessment reports produced during produced during landscape landscape character character assessment assessment projects, projects, rather than just the rather than just the mapping presently proposed. mapping presently  Information held by Local proposed. Planning Authority  Information held by Local Conservation Officers. Planning Authority Conservation Officers.

Document: Volume 5: Technical Appendices. Scope and methodology report (CT-001- 000/1) ES 3.5.0.15.1 VOL Volume, page and Full ES comment paragraph reference pgs. 73-74 Para. 8.2.9 is missing some of its text. 8.2.9 pg. 73 Whilst this paragraph states that data collected during the EIA 8.2.8 process would include ‘Data from intrusive techniques, for example trial trenching and building survey’, there is no reference in the ES to either trial trenching or building survey having been undertaken in Warwickshire.

It is not clear whether the data in respect of the zone of theoretical visibility (ZTV) also referenced has been used during the cultural heritage assessment.

General Comments The project should be informed by any relevant local, regional and national research agendas.

General Comments Any work associated with the project should be undertaken by appropriately qualified and experienced specialists, in accordance with industry standards and best practice guides, including, for example, those published by the Institute for Archaeologists, English Heritage, the Institute for Historic Building Conservation etc.

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General Comments The surveys (including archaeological fieldwork) undertaken during the assessment and mitigative phases of this project will generate a substantial amount of data and finds which will require detailed analysis. The results of these surveys will require publication and the archives generated will require storage in appropriate museums etc. in perpetuity, with displays for public benefit as appropriate. These factors will have cost and other implications which should be planned for from an early stage.

General Comments We would strongly recommend that a strategy for engaging the public throughout the project be developed. This could include engaging and informing local communities through the creation of public displays of the results of the fieldwork, holding open days to enable members of public to view exemplar sites being investigated, and the use of social media and other new technologies.

General Comments Para. 1.1.2 of this document states that it ‘sets out the proposed scope of the environmental effects to be considered during the EIA’.

As the ES has now been published, we are concerned that there is no obligation upon the nominated undertaker to follow the approach detailed in this document.

Landscape & visual Assessment Vol. 5 – Scope & Only a brief rationale has been given for the timeframe of the Methodology assessment, i.e. 1, 15 and 60 years. Further information is Report, para required to define these categories, especially in relation to the 12.5.7, p.122 60 year assessment which seems to span too far into the future.

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SMR Addendum

Document: Volume 5: Technical Appendices. Scope and Methodology Report Addendum (CT-001-000/2) ES 3.5.0.15.2

Volume, page and Full ES comment paragraph reference

General Comments Para. 1.1.1 of this document states that this document sets out the ‘proposed scope and methodology for the Environmental Impact Assessment (EIA) for Phase 1 (London-West Midlands) of HS2’.

As the ES has now been published, we are concerned that there is no obligation upon the nominated undertaker to follow the approach detailed in this document.

Appendix C. This technical note sets out a ‘A zone-based methodology for the assessment of archaeological risk for the EIA’. The first phase of this comprises the defining of ‘archaeological Cultural Heritage character zones’ and the level of archaeological risk they Technical Note – hold (para. 2.1.2). Risk based The technical note states that ‘the known information and approach to predicted archaeology from the character zones’ would be archaeological used ‘to assess ‘the need, appropriateness and feasibility’ of assessment. field surveys’ across each location and that this ‘will allow for a robust understanding of the decision making process during the EIA process as well as providing an audit trail’ General comment (para. 3.3.1) .

Critical questions to be answered include:

 Can a robust commentary be provided on the extent/value of archaeological assets based on existing sources?

 What info is needed to provide a robust commentary?

 What are the questions requiring answers?

 What field survey techniques are available to answer outstanding questions?

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A ‘risk rating’ was to then be assigned to each location. Areas that met a risk rating of 1 and 2 were to be taken forward for field work as a priority to inform the EIA (para. 3.4.2).

Whilst the ES details the archaeological character zones that have been defined, and there is the occasional reference in the survey reports to the ‘risk rating’ of those areas which have been subjected to geophysical survey, no further information on the results of this study are presented in the ES.

Whilst Appendix A of the technical note included an example of the table to be used to present the results of the initial assessment, no such table is included in the Warwickshire CFA reports

There is therefore insufficient information presented in the ES to enable us to have a ‘robust understanding of the decision making process’.

The lack of information significantly limits our ability to critically evaluate the information presented in the ES. For example, we cannot determine how many ‘high risk’ areas were identified, and what proportion of these have been subject to detailed examination to date

Appendix C This table does not appear have a category for those areas where there is no known information due to lack of previous Cultural Heritage research. It should have. Technical Note – Risk based approach to archaeological assessment. pg. 5, 3.4.1, Table 1

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ES 3.5.0.15.2

Volume, page and WCC previous Full ES comment paragraph comment reference

Appendix C [Comments on draft This paragraph should define who is technical notes to monitor the fieldwork and provided to HS2 reporting outputs and how this is to Cultural Heritage 17/05/13] be facilitated. Technical Note – Fieldwalking. The [draft] technical notes detail (section pg. 2 8) the monitoring to be undertaken by the 8.1.1 EOC on behalf of HS2. There is an expectation that reasonable access will also be allowed to LAPAs throughout the course of the project - the technical note should acknowledge this and make clear how this is to be facilitated

Appendix C We are pleased to note that it is expected that the appropriately qualified specialists will be referring Cultural Heritage to relevant national and local pottery Technical Note – type series. Fieldwalking. pg. 5, 10.1.4

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Appendix C This paragraph should confirm who will be reviewing the draft copies of the site and artefact distribution Cultural Heritage plans referred to. Technical Note – Fieldwalking. pg. 5, 11.1.5

Appendix C [Comments on draft We expect hard copies of the technical notes fieldwalking reports to be provided provided to HS2 to the relevant Local Authorities Cultural Heritage 17/05/13] (and English Heritage if appropriate), as well as the digital Technical Note – Fieldwalking. copy referred to in this paragraph. We would request pg. 5 that three final hard 11.1.6 copies and a digital copy of the reports be provided to this office, two of which will be placed with the relevant HERs.

Appendix C This paragraph states that prior to the implementation of the fieldwork a Written Scheme of Investigation Cultural Heritage (WSI) shall be compiled detailing Technical Note – the methodologies to be used for all Geophysical Survey stages of the works including a site plan/s and shall be agreed for issue to Local Planning Authority Archaeologists. We are pg. 1 disappointed that we did not receive 2.2.1 any detailed WSIs for the geophysical surveys undertaken to date.

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Appendix C [Comments on draft This paragraph states the fieldwork technical notes and reporting outputs are to provided to HS2 monitored and reviewed by the Cultural Heritage 17/05/13] routewide geophysics specialist. There is an expectation that Technical Note – Geophysical Survey reasonable access will also be The technical notes allowed to LAPAs throughout the detail (section 8) the course of the project - this technical note should acknowledge this and pg. 2 monitoring to be undertaken by the make clear how this is to be 8.1.1 EOC on behalf of facilitated. HS2. There is an

expectation that reasonable access will also be allowed to LAPAs throughout the course of the project - the technical note should acknowledge this and make clear how this is to be facilitated.

Appendix C [Comments on draft This paragraph should confirm who technical notes is to undertake the independent provided to HS2 analysis of the data processes Cultural Heritage 17/05/13] referenced. Technical Note – Geophysical Survey Who will be doing the independent analysis pg. 5 of the data processes referenced in 11.1.3? 10.1.3 Is this the monitoring referenced in Section

Appendix C [Comments on draft We expect hard copies of the technical notes geophysical survey reports to be provided to HS2 provided to the relevant Local Cultural Heritage 17/05/13] Authorities (and English Heritage if appropriate), as well as the digital Technical Note – Geophysical Survey copy referred to in this paragraph.

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We would request that three final hard pg. 6 copies and a digital 11.1.5 copy of the reports be provided to this office, two of which will be placed with the relevant HERs

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Health impact Assessment Report

It is Warwickshire County Council’s understanding that the Health Impact Assessment (HIA) is not being consulted upon in the same way as volumes 1-5. However, as the HIA has been published in conjunction with volumes 1-5 and appears on the gov.uk website as one of the documents supporting the hybrid Bill, it is Public Health Warwickshire’s view that the shortcomings in the document are brought to the attention of Parliament and the residents of Warwickshire.

General overall comments of the HIA

 The Health Impact Assessment has been conducted on a national and regional level and has not been conducted in depth at a local level as recommended. All sections on the route have different populations, needs and issues; and a national level HIA does not take into account these differences. It is utterly unacceptable that the recommendations made by Public Health Warwickshire for a detailed HIA specific for our affected local area have not been taken and HS2 must complete this before progressing further.

 The HIA only engaged with public health officials and did not conduct any stakeholder engagement with local communities or other roles and organisations. This is contrary to standard practice when completing a HIA.

 The use of qualitative terms without explanation of what it means is unhelpful. This includes the use of ‘moderate effect’ and ‘no significant effect’. Unless a detailed local HIA has been undertaken and results presented it is impossible to gauge the true impact of HS2.

 Very few recommendations for mitigation have been provided. The lack of methodology/ process is a dereliction of duty. Considering mitigation is a part of a Health Impact Assessment and must be discussed with Warwickshire County Council and added to the Health Impact Assessment to complete it.

 It is unclear whether the HIA has assessed the impact of the project on all residents including groups such as the young, elderly, those with disabilities or from ethnic minorities.

 The HIA fails to take account of the impact on sexual health and it has not been considered at all in the HIA. This is wholly unacceptable and demonstrates that a full and through HIA has not been undertaken. (See additional briefing regarding the impact of large construction sites on sexual health).

3.5 Community Liaison

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 This section lacks an assessment to other services that should be included and as such is incomplete. The Nominated Undertaker and its contractors must ensure that they inform not only communities and residents of planned works but also that all relevant organisations are notified in advance. Relevant organisations are broader than those of listed of local authorities and include other key services such as GP’s, Acute hospital services (NHS), Ambulance Service, Fire and Rescue, Police, Community Transport, Practice Nurses and Midwives and Social Care providers. Enough notice must be given to enable those services and organisations to work around the planned works which may be months.

4 and 5 Potential health effects nationally and along the route

5.2 Employment and Income

 Yet again the HIA has been conducted looking at the project from a national context and has failed to do a HIA at a local Warwickshire level to assess the impact on the local population. No details have been provided as to how or where the job opportunities will be available in Warwickshire. HS2 must provide details on how many jobs will be created at which sections of the route, where the staff will be recruited from and how Warwickshire will benefit from these. A strategy is being written however this needs to be incorporated in the HIA to ensure that all groups are included e.g. young people, older people, those with disabilities and the long term unemployed. Further detail is also needed of the number of low skilled jobs to be created as they are those that are supposedly to be accessed by the local population. If this number is low in comparison to highly skilled jobs recruited to from outside of the Warwickshire area there is again little positive employment impact for the county. We strongly recommend that local residents be given priority to jobs than those outside of the county and surrounding areas.

 Little consideration has been given to how the job losses and displacement will affect our local population, particularly rural communities’, ability to access work despite this recommendation being made previously.

 The HIA fails to take account of the wider impact of travel disruption from construction the construction will impact on an area greater than the roads directly affected due to the works and this has not been recognised. The impact has only examined those directly involved in works and a more detailed traffic assessment is vital. Diversions and closures will increase traffic on other local and major trunk roads, causing wider disruption, traffic delays, congestion, air pollution and stress.

5.3 Residential property

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 There is no mitigation provided regarding the impact on the relocation of rural residents, the community effects in Stoneleigh from the loss of a significant number of properties. This is a dereliction of duty and the format for a Health Impact Assessment has not been followed correctly.

 The impact on rural schools and their student numbers from residents relocating has not been explored.

5.4 Local environment

 The use of qualitative terms without explanation of what it means is unhelpful. There is no definition of what is meant by short to medium term and long term duration in regards to the adverse effect of construction during its peak phase.

 Significant adverse effects have been mentioned for Burton Green regarding the visibility of construction works. However no further detail is given as to the adverse effect specific to this community nor how it will be mitigated.

 It is stated that adverse effects on views will lessen after construction in many cases but has not been stated whether this lessening will apply to residents in Warwickshire or whether they will suffer permanently. No mitigation has been provided which is a dereliction of duty.

 HS2 must also consult Warwickshire County Council and Public Health Warwickshire when discussing the impact of the project on Island Project School, a specialist school for those with autism. The impact may more than adverse visual effects and may include noise, air quality and transport effects which require further health impact assessment.

 Warwickshire County Council finds it utterly unacceptable that the diversion to Kenilworth Greenway during works will still have adverse effects visually and from HGV traffic.

 The original route once due to be reinstated must be returned to its previous useable state. Warwickshire County Council insists that any works needing to be carried out that would not have been able to during closure or that have occurred as a result of the being a construction haul route for five years must be completed by HS2 before being reinstated so that it can be used safely by the public. This may include hedge/tree clearance, fence work, path maintenance, replacement of benches, cycle routes etc.

 There is not enough information provided to determine the health impact of the fear of crime surrounding construction sites. There is no information provided on how the areas will be appropriately secured, whether security lighting is provided, guards etc. and how this will be managed.

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 No consideration has been given to possible crime and antisocial behaviour once the route is in operation e.g. graffiti on bridges, paths crossing lines etc. There is no information provided regarding the maintenance of the line including tree and hedge clearance, litter removal etc.

5.5 Air quality

 Experiencing dust deposition at their home may lead to mental health stresses. Warwickshire County Council expects that local residents experiencing dust deposition from construction on their properties will be fully compensated for any expenses occurred e.g. window cleaning, ground and building washing, replacement of plants etc. We also expect to be compensated for any additional street and light maintenance and cleaning costs that the county council incurs as a result of dust deposition from construction.

5.6 Noise and vibration

 The HIA gives no indication of where the 3,300 homes that will suffer from an increase in noise levels. Again, the HIA does not state which of these are based in which area. If this detail is provided elsewhere in theHS2 documents, it is almost impossible for the average reader to understand the local impact as it has not been stated here.

5.7 Physical activity

 It is utterly unacceptable that there is no mitigation planned for the Connect2 route from Kenilworth to the University, despite HS2 acknowledging this as a commuter link. We insist that a diversion be put into place so that this well used route is still available. Closing this will also force more traffic onto the roads, increasing traffic and travel times.

 For all routes diverted, prior to reinstatement they must be returned to its previous useable state. Warwickshire County Council insists that any works needing to be carried out that would not have been able to during closure or that have occurred as a result of the being a construction haul route for five years must be completed by HS2 before being reinstated so that it can be used safely by the public. This may include hedge/tree clearance, fence work, path maintenance, replacement of benches, cycle routes etc.

 Yet again no Warwickshire specific impact assessment has been made, in this case for the effect on active travel from construction HGVs. This is despite HS2’s acknowledgement that they have the potential to reduce active travel in rural areas of which Warwickshire is a rural county, we find this wholly unacceptable.

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5.8 Access to services

 HS2 has recognised the difficulties some communities in Warwickshire will face yet no mitigation has been provided for those that will struggle to reach healthcare and other services such as schools, shops etc. due to disruption from the long road closures. This was requested by Public Health Warwickshire and it is unacceptable that this has been ignored.

5.9 Traveller stress

 The use of qualitative terms without explanation of what it means is unhelpful. This includes the use of ‘low intensity and extent of exposure’ and ‘low-medium extent and medium intensity exposure’. Unless a detailed local HIA has been undertaken and results presented it is impossible to gauge the true impact of HS2.

 The impact on altering bus routes and timetables in particularly the rural areas of Warwickshire has not been assessed. This may affect employment, education, healthcare and it is unacceptable that this has not been completed.

5.11 Social capital

 It is noted that land has been identified that in HS2’s view could be used as a replacement for Burton Green Village Hall. However, no account appears to have been taken regarding its current purpose (within the primary school curtilage). It is not clear if HS2 will provide sufficient funding for an equivalent replacement village hall or whether this will be in place before the existing one is demolished. The commitment to mitigation prior to the destruction of the hall is essential to ensure the social fabric of Burton Green is maintained.

General

 Any assumptions made within the HIA on particulate matter and the exacerbation of respiratory conditions, eye, nose or throat irritation should be referred back to Public Health for expert advice on mitigation.

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Environmental Minimum Requirements. Document: Draft Environmental Memorandum

Volume, page and Full ES comment paragraph reference

1.1.1 Introduction – This Memorandum relates to the environmental aspects of the General design and construction of Phase One of HS2. It will build Introduction upon discussions which have taken place between HS2 Ltd and representatives of the National Environmental Forum comprising the Agencies (English Heritage, Environment Agency and Natural England) and representatives from relevant Government Departments. These parties intend to continue to have clear and open discussion during the ongoing design and construction phases of the Project.

1.1.2 The terms of this Memorandum have also been discussed with the local authorities along the route.

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4.2.2 Principles - Through the EMS the nominated undertaker will develop, and Sustainability keep under regular review, environmental objectives which address this sustainability agenda. Achievement of these objectives during ongoing design and construction stages will be monitored and periodically reported to the National Environmental Forum.

The council is concerned that this infers that the monitoring and reporting will be carried out by the same organisation who delivers the project. It is a ‘self-monitoring’ contract. The council believes that an independent assessor is essential to ensure that all standard have been met and truly and accurately assessment.

4.8.2 Nature In pursuance of this aim, HS2 Ltd in conjunction with Natural conservation England will calculate the biodiversity value of habitats lost and gained. This will be based on the mitigation and compensation measures set out in the HS2 Phase One Environmental Statement. Further iterations of the calculation may be appropriate to reflect any modifications made through the Parliamentary process.

The council assumes that this is using the biodiversity offsetting metrics. However, as the detailed documents outlining this criteria has not been published the council reserves comment to its effectiveness. The council is also concerned that the monitoring period to measure ‘no net loss to biodiversity” (4.8.1) will exceed that outlined in the Mechanisms (Chapter 3, para 3.1.1) that states that the ‘A National Environmental Forum will continue to meet throughout the design and construction period and up to one year post-commissioning, unless agreed by the Forum that further meetings are no longer required.’ Surely, as the creation and restoration of some habitats will take over 32 years there is a clear need for a body to continue to scrutinise report of these habitat mitigation. Clearly, resources will need to be allocated for this purpose, which has not been detailed in the ES.

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4.8.5 The nominated undertaker will maintain or make provision to maintain and monitor the new or managed habitat, for a sufficient period to ensure that the nature conservation objectives of the proposals are achieved. The details for specific locations will be identified by the nominated undertaker. The principles for habitat creation and translocation are set out in the document ‘Ecological principles of mitigation for HS2 LWM’, which is part of the Environmental Statement.

The council sees this paragraph as an admission of the failure to establish a process to continually monitor habitat mitigation over the appropriate timescales. It does not state who the statutory undertaker will report to and any mechanisms of accountability or remediation should mitigation not work.

The council sees this as a clear example of a dereliction of duty under the Natural Environment and Rural Communities Act and contrary to the CIEEM EcIA guidelines and EU Precautionary Principle.

4.9.1 Geological Should a geological deposit or feature of high scientific value features be discovered, the nominated undertaker will carry out appropriate recording and, if reasonably practicable, protection of such deposits. If necessary and where practicable, the material may be removed for study and preservation.

This statement does not demonstrate how any geological deposit or feature will be discovered. Will this be the responsibility of non-experts in the course of construction? The council is therefore concerned that significant deposits and features will be recklessly destroyed through ignorance and without further reassurance it suggests that these measures ore a clear dereliction of duty and inconsistent with NPPF and the CIEEM EcIA guidelines and EU Precautionary Principle.

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4.11.6 Agricultural To ensure that the objectives of the above works are and forestry land achieved, the nominated undertaker will, where appropriate, manage or support the recovery of reinstated agricultural land during an appropriate aftercare period.

There is no mention of monitoring regimes that would trigger any additional ‘recovery of reinstated agricultural land’ and this does not apparent relate to forestry land. For example, the proposed translocation of ancient woodland soils will require long-term monitoring and management to increase any chances of success in what is essentially an untried and tested procedure. Without monitoring how will the nominated undertaker know when and how to act to remediate any recovery that is not going according to plan? Without this clarification the council suggests that these measures ore a clear dereliction of duty and inconsistent with NPPF and the CIEEM EcIA guidelines and EU Precautionary Principle.

5.1.1 [Table 5.1] identifies key worksites along the Phase One of Environmentally HS2 route that are environmentally sensitive in terms of sensitive worksites nature conservation, terrestrial and aquatic ecology, water resources, geomorphology, recreation and amenity, landscape, public open space and agricultural land. The criteria for inclusion in [Table 5.1] are:

Worksites where a key significant impact (that has been agreed with the NEF members) is generated in any of the environmental topics in paragraph 5.1.1.

The council cannot locate Table 5.1 referred to in this paragraph. Therefore, it cannot make comments on this section. Without this information it has serious concerns that the local impacts have not been appropriate considered and evaluated. The council suggests that this omission is a significant flaw in the consultation process and is a gross dereliction of duty to enable local experts the opportunity to inform the ES.

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5.1.4 [Table 5.1] also indicates key statutory consultees who, along with relevant local authorities will also be consulted on the LEMP for these environmentally sensitive worksites. It is intended that these environmental management plans will be submitted for information with relevant Schedule 16 and, where appropriate, heritage applications, recognising that the grounds for consideration of Schedule 16 applications are those set out in the Bill.

The council cannot locate Table 5.1 referred to in this paragraph. Without this information it has serious concerns that the local impacts have not been appropriate considered and evaluated. The council suggests that this omission is a significant flaw in the consultation process and is a gross dereliction of duty to enable local experts the opportunity to inform the ES.

Document: Draft Environmental Minimum Requirements. Annex 3: Draft Heritage Memorandum

ESA 4.4

Volume, page and Full ES comment paragraph reference

pg. 2 Para. 2.1.3 refers to ‘The arrangements in relation to human remains and burial monuments over 100 years old where 2.1.3 archaeological investigation may be undertaken.

th 5 bullet point Para. 8.1.5 further states ‘Where burial has occurred over 100 years ago consideration will be given to the need for, and extent of, archaeological investigation’.

Whilst the scope of the appropriate excavation may vary, any Also: burials over 100 years should be archaeologically investigated. pg. 8, The Heritage Memorandum should confirm that any human remains over 100 years will be archaeologically investigated. 8.1.5

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pg. 4, Para. 5.2.1 states that ‘Mitigating the impact of the HS2 works on the setting of heritage assets is addressed in the 5.2.1 Environmental Memorandum’. This in incorrect – the Environmental Memorandum only references mitigating impacts upon historic landscapes; it does not reference mitigating the setting of individual heritage assets. pg. 4 We are pleased to note that para. 5.3.2 recognises the need to maximise the opportunities for dissemination and outreach the 5.3.2 information obtained during this project about the historic environment. pg. 4 We are pleased to note that this paragraph confirms that all works affecting heritage assets will be carried out by suitably 5.4.1 qualified, experienced and competent professionals and that these works will have appropriate regard to the national planning policy, accepted industry practice, national guidelines and codes of practice, including those published by English Heritage, the Institute for Archaeologists and the Institute for Historic Building Conservation. pg. 5 The historic environment related fieldwork undertaken throughout this project will result in a large archive which will 5.6.5 require permanent storage. There may not be sufficient space for the archives in the existing repositories along the route; in addition some areas do not presently have appropriate repositories.

Whilst para. 5.6.5 states that ‘the nominated undertaker will work with English Heritage and local authorities to identify suitable repository/ies to enable the deposition of the artefacts and records generated by the heritage works’, this document does not make any commitments as to what will happen with the archives should appropriate repositories not be identified. It should. pg. 6 Whilst this document (section 6) sets out what will happen should unexpected nationally significant remains be identified Section 6 during construction, it does not detail what will happen should unexpected remains of less than national significance be identified during construction.

The heritage memorandum should set out what will take place should unexpected remains of less than national significance be identified during construction.

We would expect any such remains to be recorded to a level commensurate with their significance.

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pg. 6 Section 6 of this document sets out what will happen should any nationally significant remains be unexpectedly identified 6.1.2 during construction.

Para. 6.1.2 states that ‘the nominated undertaker will allow a period commensurate with the construction timetable, but not

less than 28 days, for heritage works to be undertaken on the site for preservation by record’ should unexpected nationally significant remains be discovered during construction which cannot be preserved.

We are reassured that this document confirms that time will be allowed to enable archaeological recording to take place, however, we are concerned that it specifically references the time available being ‘commensurate with the construction timetable’.

Given the importance of the remains referred to in para. 6.1.2, and that the governments considers that, as stated in the NPPF, that substantial harm to or loss of heritage assets of the highest significance should be ‘wholly exceptional’ (para. 132, see also 139), we would expect sufficient time to be allowed for an appropriate programme of heritage works to be undertaken irrespective of the development timetable.

As we have stated elsewhere, we would highlight the need for sufficient archaeological evaluative works to be undertaken at the earliest opportunity in order to reduce the risk of unexpected remains being identified during the construction works. pg. 8 8.1.5 See comments on 2.1.3 above.