National Trust response to: HS2 Phase One Formal Environmental Statement
February 2014
National Trust Heelis Kemble Drive Swindon Wiltshire SN2 2NA
Contents
1. Overview...... 4
2. Structure of this Response...... 8
Executive summary...... 9
3. Route-wide (Volume 3: route-wide effects of HS2 Phase One) ...... 9
4. Dunsmore, Wendover and Halton (CFA10)...... 13
5. Aylesbury and Stoke Mandeville (CFA 11) ...... 15
6. Waddesdon and Quainton (CFA 12) ...... 21
7. Calvert, Steeple Claydon, Twyford and Chetwode (CFA 13) ...... 24
APPENDIX ONE: Detailed Observations by Community Forum Area...... 27
8. Dunsmore, Wendover and Halton (CFA 10) (National Trust Coombe Hill)...... 27
8.1. Ecology...... 27
9. CFA 11 Stoke Mandeville and Aylesbury (including Hartwell House)...... 29
9.1. Landscape and Cultural Heritage...... 29
9.2. Hartwell and Wider Mitigation: Key Principles...... 36
9.3. Noise...... 36
10. CFA 12 Waddesdon and Quainton...... 37
10.1. Landscape and Cultural Heritage...... 37
10.2. Ecology...... 39
11. CFA 13 Calvert, Steeple Claydon, Twyford and Chetwode...... 44
11.1. Landscape and ecology...... 44
11.2. Claydon – Calvert – Bernwood and Wider Mitigation...... 47
APPENDIX TWO: Questions/clarification/corrections on ES for HS2 Ltd ...... 49
12. Route-wide (Volume 3: route-wide effects of HS2 Phase One) ...... 49
13. Dunsmore, Wendover and Halton (CFA 10)...... 50
14. Stoke Mandeville and Aylesbury (CFA 11) ...... 51
15. Waddesdon and Quainton (CFA 12) ...... 57
16. Calvert, Steeple Claydon, Twyford and Chetwode (CFA 13) ...... 58
APPENDIX Three: National Trust Statutory Foundations...... 59
18. Contributors ...... 61
National Trust response to: HS2 Phase One Formal Environmental Statement
Overview
1.1. The National Trust for Places of Historic Interest and Natural Beauty (The National Trust) is pleased to offer these submissions on the HS2 formal Environmental Statement to the independent assessor and for their subsequent reporting to Parliament. In producing this we have paid close regard to the legislative guidance in EU Directive 85/337 (Environmental Assessment) at Annex III and UK Statutory Instrument 2011/1824 (Environmental Impact Assessment) and at Schedule 4 ‘information for inclusion in environmental statements.’
1.2. We embrace this methodology in relation to the National Trust’s geographical areas of concern which are: the Chilterns Area of Outstanding Natural Beauty / Coombe Hill (Dunsmore, Wendover and Halton CFA 10); Hartwell House (Aylesbury and Stoke Mandeville CFA 11); Waddesdon Estate (Waddesdon and Quainton CFA 12) and Claydon House (Calvert, Steeple Claydon, Twyford and Chetwode CFA 13).
1.3. We are neither for nor against the principle of high speed rail, but do believe that should it be built, it should be to the highest possible design and environmental standards. We believe that the route proposed for Phase 1 of HS2 will impact adversely on the conservation of special places which we are charged under statute to conserve for the nation, and on the operation of those places, affecting the experience of our visitors. Therefore we are committed to engaging with HS2 Ltd and the government in order to deliver the best possible outcomes in terms of mitigation for the impacts of the train line.
1.4. Following much engagement with HS2, a formal presentation was made of our vision for HS2 around Aylesbury (February 2013) and further promoted in our comprehensive July 2013 response to the draft Environmental Statement. Now, the National Trust calls for a reconsideration of the current mitigation remedy for the cultural and historic landscape at Hartwell House and its wider setting, which includes Aylesbury and the several nucleated settlements that surround it.
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1.5. Our own land bridge proposal, which has been rejected by HS2 Ltd, still provides the most appropriate means by which to offset the significant harm, caused by the proposed route and acknowledged by HS2 Ltd, and has received wide endorsement from local authorities and communities. A very sensitive interface exists between the historic parkland at Hartwell and the amenity space on the populated urban western edge of Aylesbury. The route of HS2 severs the Grade II* Registered Park and Garden and bisects the Hartwell Conservation Area. The land bridge offers appropriate mitigation, consistent with the requirements of Environmental Impact Assessment methods, by connecting the landscape and healing severance, greatly reducing noise, significantly reducing historic parkland wall removal and removing the need for an intrusive footbridge.
1.6. The Environmental Statement acknowledges the negative impacts for Hartwell and the wider area but deems the proposed remedy of some screen planting and acoustic fencing as sufficient. We would like to make the specific point that World Health Organisation guidelines on noise classify the stated daytime level of noise (after mitigation) of 50 dB(A) as still ‘moderately annoying ’.
1.7. We question the assessments of the cumulative effects identified at Hartwell from a noise, landscape and cultural heritage perspective. We submit that the cumulative impact on Hartwell has been ‘underweighted’ and a much more robust and enduring legacy is readily achievable. We submit that there can be no reasonable environmental objection to what we seek and HS2 themselves have, in discussions, confirmed that our proposal is technically feasible.
1.8. Our land bridge proposal would benefit the historic environment, improve the amenities enjoyed by many local residents, enhance connections for biodiversity and is a remedy to reduce the visual and noise impacts of the railway. Overall we would like to call for a more enduring legacy in connection with this national infrastructure project, one which is enshrined within a principle of high quality design to match HS2’s own stated desires to challenge industry design standards.
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1.9. Turning specifically to construction impacts, whilst much assurance is given on construction principles in the draft Code of Construction Practice within the Environmental Minimum Requirements on heritage and planning, it remains a matter of considerable concern to the Trust that physical shielding of construction activities is not proposed (in either principle or detail) to screen the inner Park and Hartwell House and its ensemble of listed structures. There is considerable sensitivity in running a hotel business at a fragile historic location at Hartwell, and maintaining an appropriate use of an historic building. We require a specific commitment that protection of the historic Parkland is secured in the construction phase by means of construction site screening, to be agreed, that effectively shields the hotel from the consequences of construction activity. Failure to do this would have a deleterious effect on the ability to operate the hotel. The use of Hartwell House as a hotel has both secured the property and given it a future viable use, consistent with good conservation and wholly in accordance with the National Planning Policy Framework and English Heritage Conservation Principles. We know that all parties to this project will wholeheartedly support the desire to continue that work and the generation of an income is highly relevant to delivery of that objective.
1.10. Elsewhere, the Environmental Statement arrives at the fundamentally incorrect conclusion that ‘the project is unlikely to result in any significant adverse effects on the special characteristics of the Chilterns AONB’ . Placing built structures above ground within the AONB must have such an effect. In our view, it justifies an extended bored tunnel. We repeat our support for the principle of an extended tunnel for the Chilterns AONB. We suggest there should be the best possible scheme of mitigation within the Vale of Aylesbury to minimise impacts on the setting of and views from the scarp.
1.11. We question the assessments of the cumulative effects identified at Calvert from an ecological perspective, principally bat foraging, and believe a different legacy design is required at each site. A strong consensus exists amongst ecologists that the ‘box like’ structure, as promoted by HS2, to protect
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Bechstein’s bats is not sufficient and that the evidence base for this needs exploring. The use of a box structure and moveable screens with relocated habitat is an approach entirely embryonic in its thinking and not based upon sound science. The findings therefore are entirely speculative. A better design approach is required and one that addresses Bechstein’s, wildlife crossings, habitat management and treatment of the Infrastructure Maintenance Depot and sustainable placement of spoil.
1.12. The cumulative impacts at Calvert are considerable, yet the mitigation of the Infrastructure Maintenance Depot (IMD) area is confined to planted embankments to shield Steeple Claydon. While some screening is welcome, we advocate a more area-wide designed mitigation. We also seek greater assurances (within an amended EMR) that construction vehicular movements in this area are limited by an operational travel plan (for site workers), a clear non- vehicular mode for waste movement on roads (i.e. movement via the railway ‘trace’) and much greater design detail on the IMD and photomontages of its effect, to assist a more worked up mitigation.
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2. Structure of this Response
2.1. A summary of our submissions is set out in the main part of this document (see ‘Geographic Area’ sections). We have structured this main part by dividing it into sections dealing with the different Community Forum Areas (CFAs) in which we have concerns. Then, within each of those sections, we set our comments against the various requirements of the EU Directive 2011/92/EU (Environmental Assessment) at Annex III and UK Statutory Instrument 2011/1824 (Environmental Impact Assessment) and at Schedule 4 ‘information for inclusion in environmental statements .’
2.2. Appendix One sets out our submissions in more detail, again subdivided into sections corresponding to the CFA areas in which we have an interest.
2.3. Appendix Two contains a set of questions in response to which we seek greater clarification from HS2.
2.4. A summary of our statutory foundations is at Appendix Three .
2.5. This response is without prejudice to any petition the National Trust may deposit against the Bill. Additional points relating to the Environmental Statement may be raised in our petition and at other stages of the process.
2.6. The National Trust has worked very closely with a number of principal partners and other key stakeholders. We deal with these various bodies in these submissions and would like to be very clear that we support the representations to be made by the Ernest Cook Trust, the Rothschild Foundation/Waddesdon Estate and the Verney Estate. We endorse the points made and have several similar representations, to which we draw attention.
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Executive summary
3. Route-wide (Volume 3: route-wide effects of HS2 Phase One)
National Trust properties Hartwell House, Waddesdon Manor, Claydon House affected by the proposals and Coombe Hill in Buckinghamshire. The Chilterns and other areas of concern AONB, including other National Trust properties at Hughenden, Bradenham, West Wycombe Park and Village.
EU ANNEX III AND SI ES REPRESENTATIONS IN SUMMARY. 2011/1824 AND RELEVANT ES REQUIREMENT
1. 1 Description of the The formal ES sets the correct level of design goals project, including in seeking to ‘ avoid direct or indirect harm to valued particular: historic cultural resources, to mitigate adverse impacts, and to enhance such resources where practicable. (a) Description of the Measures to achieve this would be commensurate with physical characteristics of the sensitivity of the resource and their level of the whole project and the protection’ . We know it is a stated aim of HS2, in its land-use requirements reporting of a mitigation hierarchy, to exceed during the construction and (minimum) standards. However, we have serious operational phases. concerns as to how these commitments are delivered (b) Description of the main in the Chilterns AONB and with respect of western characteristics of the Aylesbury and within the Vale of Aylesbury. A high level production processes, for of policy aspiration must be met with tangible instance, nature and commitment in delivery. quantity of the materials We know that any mitigation hierarchy must follow an used. assessment of impacts and that ‘value for money’ can An estimate, by type and be material. Against this background, the National Trust quantity, of expected seeks a series of further design refinements. residues and emissions Many assurances are given as to how impacts are (water, air and soil controlled in future delivery by documents, such as pollution, noise, vibration, Environmental Minimum Requirements (EMR) and light, heat, radiation, etc.) (currently) draft Code of Construction Practice (CoCP). resulting from the operation
1 These paragraph numbers are consistent with guidance in the SI2011/1824
9 of 61 National Trust response to: HS2 Phase One Formal Environmental Statement of the proposed project. At Annex 2 Draft Planning Memorandum it is stated that (at 4.1.4) ‘ The Forum (planning forum) will consider common design items for certain structures associated with the railway (such as bridges, viaducts, acoustic barriers or retaining walls for example). Unless there are exceptional circumstances which dictate otherwise, there will be a presumption in favour of approval of such designs when submitted’. This prevents a qualifying body from making a meaningful contribution to the design process.
We can only realistically deal with the point regarding value for money , if and when such matters are placed in the public domain. Where HS2 rely on cost issues in rebuttal of alternatives, we request that matters of value for money are released into the public domain at the earliest opportunity so that scrutiny and discussion can be pursued.
4. A description of the likely Tranquillity is poorly defined and/or quantified and has significant effects of the not been adequately addressed. proposed project on the We have attributed weight to the tranquillity and rural environment resulting from character of CFA 12 and 13. We know this is an the existence of the project, the use of natural accepted part of the landscape character assessment and LVIA approach. To provide for rigour here we resources, the emission of pollutants, the creation of have given appropriate weight to the CPRE National Tranquillity Mapping Data. We seek that this approach nuisances and the elimination of waste; and and its methodology, as supported by previous work by University of Northumbria, is endorsed and confirmed the description by the as the most appropriate way of measuring tranquil developer of the areas. Our central submission here is that the Calvert- forecasting methods used Claydon area is one of the most tranquil parts of to assess the effects on the Buckinghamshire, as measured by quantitative environment. analysis. The ES relies upon qualitative analysis of tranquillity and far greater attention should be given to the work of CPRE.
6. A non-technical This document mentions the National Trust’s plans for summary of the information mitigation in the Hartwell and Aylesbury area and the setting implications for Claydon House and (Verney) Estate. It also deals with the distinctive landscape of the Chilterns AONB but arrives at the fundamentally
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incorrect conclusion that ‘the project is unlikely to result in any significant adverse effects on the special characteristics of the Chilterns AONB’ . We contest that placing built structures, viaducts, security fencing, land drainage areas above ground within the AONB must have such an effect. In our view, it justifies an extended bored tunnel. We support the work of Chilterns Conservation Board in this regard.
We cannot find any comprehensive details of route destinations for HGV movements beyond a limited radius of their operational locations. For example in ES Volume 2 CFA 11, as with many other such CFAs, the only construction impacts on local roads are those listed at paragraph 12.4.15. Construction of the Proposed Scheme will result in substantial increases in traffic flows (i.e. more than 30% for HGV or all vehicles) and these will cause a significant increase in traffic related severance for non-motorised users in the following locations (followed by a list extending some 5km radius). It would benefit many to know where ultimate route destinations are proposed to go. This should have been summarised in the non-technical summary. The National Trust as a custodian of whole areas of historic interest owns several outstanding villages at Bradenham, West Wycombe, and sections of western High Wycombe, which will be affected by HGV movements. Simple maps showing the principal routes for HGVs in these areas and assurances that diversions will only be in extenuating circumstances (as annotated) would be a beneficial addition to the CoCP and EMRs when this project commences. We submit that the ES is deficient in this respect.
We challenge the principle of Sustainable Placement on the basis that excavated material is waste material, and should be managed appropriately, regulated and controlled by the relevant Waste Planning Authority. We question the need for sustainable placement and cannot find any evidence in the ES to persuade us against this view.
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7. An indication of any The National Trust has allowed access for site surveys at difficulties encountered in all reasonable times during 2012 and 2013, to assist in compiling the required the production of the Environmental Statement. information.
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4. Dunsmore, Wendover and Halton (CFA10)
National Trust properties Coombe Hill lies within the Chilterns AONB and enjoys affected by the proposals panoramic, long distance views over Aylesbury Vale. and other areas of concern Once part of the Chequers Estate it is a SSSI with the iconic Grade II-listed Monument at the summit.
As a conservation charity, the National Trust also has a wider perspective than just the places we own. Our wider conservation remit means we care about all special places, including nationally designated landscapes, (AONBs and National Parks), and we have thus taken a view on mitigation options for the Chilterns AONB and offered comments regarding the route- wide impacts of the line.
EU ANNEX III AND SI ES REPRESENTATIONS IN SUMMARY. 2011/1824 AND RELEVANT ES REQUIREMENT
1. Description of the The maintenance loop will be clearly visible from project: Coombe Hill. Far reaching views from Coombe Hill are an acknowledged part of the special qualities of the Chilterns AONB, acknowledged in the Landscape Character Assessment section of Volume 5 (Landscape and Visual Impact Assessment).
5. A description of the Potential still exists for better mitigation as the measures envisaged to maintenance loop is still harmful in the wider prevent, reduce and where landscape. We repeat our support for the principle of possible offset any an extended tunnel for the Chilterns AONB. We believe significant adverse effects the best possible scheme of mitigation possible within on the environment. the Vale should be adopted, so as to minimise impacts on the setting of and views from the scarp . A landscape master-plan is required.
A factor in our support is our approval of the research put forward by Conserve the Chilterns and Countryside, ‘ High Speed Rail in the Chilterns: An Assessment of the Non-Market Effects of the Proposed Scheme compared to the Alterative Proposal’, which demonstrates that an economic appraisal of the
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environment and other factors associated with the benefits of an extended bored tunnel comprehensively adds to measurable financial benefits and offsets the additional cost of the extra bored section.
The harm to the AONB is underplayed and understated in the ES assessment of impacts and appears in the formal ES to be calculated on the magnitude of change when measured against the percentage of land affected as opposed to the intrinsic value of land that is protected in policy and law as of national importance for its scenic beauty.
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5. Aylesbury and Stoke Mandeville (CFA 11)
National Trust properties Hartwell House, located on the edge of Aylesbury, is a affected by the proposals Grade I listed building which means it is in the top 2.5% and other areas of concern of all listed buildings in terms of its significance. Hartwell has a remarkable international history and significance stretching back almost one thousand years to the reign of Edward the Confessor. Hartwell has one of the most historically significant parks and gardens in the country with the Grade II* Registered Park & Garden designed by Richard Woods a follower of Capability Brown and garden buildings designed by architect James Gibbs.
EU ANNEX III AND SI NATIONAL TRUST AREA OF GEOGRAPHIC INTEREST AND 2011/1824 AND RELEVANT ES REPRESENTATIONS IN SUMMARY. ES REQUIREMENT
1.Description of the project We accept the baseline reports put at Hartwell Aylesbury in respect of Cultural Heritage. However, we question the baseline assessment of ecology, water (which is based on Lidar data with no detailed surveys of the structures that affect water flows) and noise (where no acoustic fence designs are advanced and the assessment of nuisance accepts ‘ moderate annoyance’ under WHO guidelines). For matters of landscape details we also question the lack of photomontages and the subsequent consequences for cultural heritage assessments. The details of major adverse effects at Hartwell are acknowledged in respect of landscape and cultural heritage impacts and we agree with that attribution of harm. We suggest that there should be a different treatment of the permanent, cumulative and long term consequences (see below).
We accept the description of benefits following the diversion of the A418 but we question the noise projections at 2026 on the highway network as speculative and conjectural. We also make the point that WHO guidelines on noise find the 50 dB(A) daytime level (after mitigation) as ‘moderately annoying’ and thus in the historic landscape the
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railway exacts this effect.
At Hartwell House, the proposed route involves a footpath crossing the line on embankment adjacent to Rifle Spinney, within the Registered Park and Garden. This requires removal of a section of boundary tree- belt, which is very narrow at this point. If this happens, the views from inside the core park will be significantly adversely affected by this structure and it would destroy the enclosed and secluded atmosphere. We recommend this structure is removed but could be incorporated within our proposal for a land bridge (see below).
ES Volume 2 for CFA 11, paragraph 6.4.5 accepts this is a very sensitive area and acknowledges high adverse impact and major adverse effect over at least seven years.
It remains a matter of considerable concern that no physical shielding is proposed that screens the inner Park and Hartwell House and its ensemble of Listed Structures from the direct construction activities. We seek greater detail and assurances in respect of a construction screen to the inner park.
The National Trust has been a party to research, commissioned by Buckinghamshire County Council and undertaken by Oxford Economics, which reported a consequence of the construction to be a cost of £44m per year, resulting from travel delays and increased traffic. While some attempts are made to quantify socio-economic and related consequences in the ES, we have nothing to guide us on the consequences for Hartwell House as a hotel within a sensitive landscape, in other words no assessment of the implications for visitors during the construction period. For this reason we seek a construction screen to the inner park.
2. Where appropriate, an Considerable harm will be caused by severance and outline of the main proximity and noise, resulting in a major adverse effect. alternatives studied by the The ultimate assessment of cumulative effects gives
16 of 61 National Trust response to: HS2 Phase One Formal Environmental Statement developer and an insufficient weight to these consequences and indication of the main understates and underplays the severity of what will reasons for his choice, happen here in dismissing our alternative proposal for a taking into account the landbridge. The severance of the historic parkland by environmental effects. the railway and its impact upon an area of acknowledged high sensitivity is given insufficient weight, as is the issue of ecosystems, relationship between cultural heritage and landscape and the implications of noise on the setting of nationally significant historic assets. We promote a more holistic land-use mitigation plan with a short section of land bridge (green tunnel), as deployed along HS1 in similar circumstances. The benefits are clear and we can demonstrate these.
The remediation of the golf course is unresolved and while hinting at a solution in the ES, construction would, as currently proposed, render the golf course unable to operate properly and become unviable as a business. The value of the golf course as an important community resource is fully acknowledged in the text. To a very large extent the future of the golf course and associated green infrastructure around Aylesbury, remains a significant matter unresolved in the formal ES. The formal ES contains high level aspirations which have not been the subject of discussion with the landowners involved. We consider this a significant deficiency. Alternatives here require rigorous scrutiny and investigation. Fundamentally, proper liaison is required with landowners which has been thus far been lacking and has caused unnecessary frustration.
3. A description of the The in-combination / cumulative / residual assessment aspects of the environment of impacts is under-weighted in the ES. Proposed likely to be significantly mitigation of impacts is insufficient in respect of cultural affected by the proposed heritage / setting / landscape impacts and noise project, including, in evidence points to a potentially flawed baseline / particular, population, projection in the inclusion of future road noise in the fauna, flora, soil, water, air, assessment. At the moment it is a matter of great climatic factors, material concern that we do not have detail of noise barrier assets, including the effects. We understand that the pantograph/catenary architectural and will project noise above the 3-5m high barriers, and
17 of 61 National Trust response to: HS2 Phase One Formal Environmental Statement archaeological heritage, that this will result in a noise consequence absent in the landscape and the inter- ES. relationship between the We accept the line must be continuously fenced for above factors. security but a landbridge avoids further such intrusions within a sensitive area. We want to see further details about fencing, including a statement of key design principles, and a better assessment of the effect of the fencing.
The ecological baseline here reports bat migration in the Hartwell – Stone area and promotes a precautionary approach to ecology. The lake and woodland at Hartwell are important foraging sites for bats yet no significant effects are reported on the barbastelle population which utilise habitats between Hartwell House and Fleet Marston Spinney. We question the baseline on ecology because we think the impacts have a significant effect.
5. A description of the A planted tree screen does not provide any mitigation measures envisaged to to noise transmission / reception. The visual impact prevent, reduce and where requires in excess of 60 years for effective maturity. We possible offset any call for a different designed mitigation with a section of significant adverse effects land bridge. This has the local support of Fairford Leys on the environment. (west of Aylesbury); Coldharbour Parish; Stone, Bishopstone and Hartwell Parish; Stoke Mandeville Parish; Lower Hartwell residents and Sedrup residents. It also has the support of the Buckinghamshire County Council, Aylesbury Vale District Council and Ernest Cook Trust.
In essence, a land bridge proposal still provides for the most appropriate measure by which to offset significant adverse effects, by connecting the landscape, reducing noise, reducing parkland wall removal and deleting an intrusive footbridge. The regulations seek avoidance, reduction and, if possible, remedy for significant adverse effects, contained in the EU Directive and UK Statutory Instrument, which our proposal will deliver. The National Trust seeks a reconsideration of this mitigation, on the basis of the evidence considered. The foundation of this is based
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upon a reappraisal of the individual effects arising as a result of the proposed development.
The judgements made around Aylesbury in CFA 11 appear based on an assessment of the engineered structure only and do not take into account the wider landscape plan as previously tabled by the National Trust to HS2 in February 2013, which would help mitigate these impacts. A very sensitive interface exists between the historic parkland at Hartwell and the western edge of Aylesbury. The route bisects the Registered Park and Garden and runs through the centre of the Landscape Character Area and Hartwell Conservation Area. The grassland habitat creation between Hartwell and Aylesbury is without any rationale or justification. This extends across a considerable area, both south of and north of the A418 and it is entirely unclear as to why this is being pursued.
HS2 Ltd has confirmed to the National Trust, in discussion, that a land bridge is technically feasible but that they dismiss it in preference to a combination of slight cutting / planting and acoustic fencing. We advocate a more enduring legacy which is based upon the high quality design that HS2 Ltd themselves promote.
Expert opinion has been sought, in an attempt to evaluate our own preferred design. That expert opinion has offered the view that:
• Pursuing the National Trust proposal of a land bridge at Hartwell would not alter the formal ES assessments of likely significant effects in respect of hydrology / water. We have taken an independent view on water / hydrology in the ES and, in relation to the question of whether there would be any additional significant effects resulting from our landbridge proposal. ‘It should be noted that if a green tunnel were to be constructed in the Hartwell area, with an appropriate drainage system along its western wall, then a very similar situation should apply
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(compared to the HS2 preferred design in the ES) – with no additional impacts. The information presented would suggest that groundwater would not be a significant issue if a green tunnel were to be provided’ .
• It also demonstrably improves the position as regards likely significant effects in respect of noise within the landscape.
• Of considerable importance it avoids severance within a historic landscape of high sensitivity and materially improves the setting and the appreciation of cultural heritage significance.
We require HS2 Ltd to clarify these points and release their own cost calculations.
The Construction impacts at Hartwell are set out and mitigation here is heavily dependent upon compliance with the EMR (heritage and planning memorandums) and CoCP / Local Environmental Management Plans (LEMPS). The hotel use at Hartwell is a wholly appropriate use of a historic building within its historic landscape. We require specific commitment that at construction phase the protection of the parkland is secured by means of construction site screening , to be agreed, that effectively shields the historic landscape from the consequences of construction activity. Failure to do this would have a deleterious effect on the ability to operate the hotel and therefore protect the buildings and its landscape.
Reference to ‘tall screening’ in the Code of Construction Practise is not explained or defined and in similar vein ‘tall noise barriers’ (in CFA10) are mentioned but not defined.
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6. Waddesdon and Quainton (CFA 12)
National Trust properties Waddesdon Manor and Estate was built in the 1870s by affected by the proposals Baron Ferdinand de Rothschild to display his and other areas of concern outstanding collection of art treasures and to entertain the fashionable world. The house is surrounded by views of Oxfordshire, the Chilterns Hills and the Vale of Aylesbury. It contains historic French furniture and decorative arts from the 18th century with magnificent English portraits and Dutch Old Masters. Waddesdon has one of the finest Victorian gardens in Britain. It attracts around 350,000 visitors a year, making Waddesdon the third most visited National Trust property in the country.
EU ANNEX III AND SI NATIONAL TRUST AREA OF GEOGRAPHIC INTEREST AND 2011/1824 AND RELEVANT ES REPRESENTATIONS IN SUMMARY. ES REQUIREMENT
1. Description of the project We support the A41 road realignment and deletion of the previous proposal for an A41 flyover structure, which was far more intrusive. We seek more visual evidence (photomontages) and design detail in mitigation of impacts on historic landscape (see below). We ask that serious consideration is given to placing the railway under the A41, as it is accepted in the ES that the route now chosen has a greater impact on the Waddesdon Estate than the alternatives. The footbridge (to accommodate the rights of way) to the east of the A41/HS2 crossing should also be contained in a short tunnel. In the absence of this necessary design amendment it will stand some 12m above the existing landscape and be wholly intrusive on the Vale floor that surrounds.
The Vale is an open landscape, in this area framed by the Winchendon Hill Area of Attractive Landscape. Past attention to the visual intrusion created by an A41 flyover (over the path of HS2) has been considered and the scheme altered to that now proposed. However we do not feel that the proposed scheme sufficiently mitigates the extent of damage on the
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beautiful and extensive area of Aylesbury Vale and seek provision of a tunnel or underpass for the crossing of the A41. We support the Waddesdon Estate in this regard. Furthermore, if a tunnel underneath the A41 is not implemented and the scheme is delivered as is shown in the formal Environmental Statement, concerns exists over the layout of proposed road network to the south of HS2, its link to the A41 and connections to the Upper Winchendon road. We feel that the existing alignment reads uncomfortably with the setting of the historic Grand Lodge and its importance as the original entrance to Waddesdon Manor. The proposed road alignment could be improved to reduce the impact of HS2 to an acceptable level.
Grand Lodge was originally designed as a key feature on the cross roads and announced the arrival of visitors to Waddesdon and will, if the proposed scheme is implemented, sit in an unbalanced configuration of roads within the landscape. We suggest that this arrangement is realigned so as to reduce the impact on the existing road network and Grand Lodge. The National Trust and the Waddesdon Estate would be grateful to be involved in this design work.
5. A description of the We seek further design details related to planting and measures envisaged to remedial landscaping and attention to Blackgrove prevent, reduce and where Roundabout and left-over sections of the A41. In possible offset any addition to the road realignment at Waddesdon significant adverse effects (removing the previously proposed A41 fly-over on the environment. structure), we submit that in comparison with the draft ES, a greater impact is predicted on the Waddesdon Estate where the alignment is now higher at Fleet Marston. We seek more engagement on this, with a view to reducing the impacts on the Grand Lodge at Waddesdon. Placing the railway under the A41 would achieve this as a necessary element of mitigation, as would the design amendment to the public right of way. We call for photomontages and details of the impact upon the Vale landscape and from within the registered park and garden (Lady Alice Walk and
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beyond). The focus of the mitigation planting here is far too localised. A linear (in effect green line) planting buffer is proposed. The track can only be concealed through careful planting and this is not currently proposed. Similar to our observations for CFA 13, we seek a more landscape-led approach, in which views and vistas are given greater attention and identified parcels of planting in the wider landscape are used instead of a linear screen.
Looking to ecological mitigation we remain concerned (as also set out in CFA 13) that this is confined to a narrow corridor around the railway. The points in respect of individual species are the same for CFA 12 as for CFA 13 (below).
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7. Calvert, Steeple Claydon, Twyford and Chetwode (CFA 13)
National Trust properties The Grade I-listed Claydon House near Buckingham affected by the proposals was built in the eighteenth century when Sir Ralph and other areas of concern Verney set out to create a country house of extraordinary grandeur that would dazzle his wealthy neighbours and outdo his political rivals. Claydon has been occupied by the Verney family for more than 550 years and they still manage the Estate today; the place is a testament to their fascinating fluctuating fortunes, from their close involvement in the English Civil War to the family connection with Florence Nightingale.
EU ANNEX III AND SI NATIONAL TRUST AREA OF GEOGRAPHIC INTEREST AND 2011/1824 AND RELEVANT ES REPRESENTATIONS IN SUMMARY. ES REQUIREMENT
1. Description of the project In the formal ES HS2 Ltd does accept an impact here on the National Trust at Claydon House and Estate but tends to underplay the consequence of a combination of projects that impact upon this area. We consider this to be a matter which deserves further attention and one that should be the subject of a landscape – land use scale approach/ master-plan, which presents a more integrated approach to the Claydon-Calvert - Bernwood Area.
As with Hartwell, we also suggest that there should be a better treatment of the permanent, cumulative and long term consequences. We see this landscape-led approach as a more robust way of dealing with the long term legacy of the railway on an area which is considerably affected by three new projects (of which HS2 is one and the others being the Energy from Waste Plant and East-West Rail). In this regard the description of and weight given to existing planned projects in this area, is insufficient in the ES.
The proposed Infrastructure Maintenance Depot (IMD) is a significant undertaking involving 37 hectares and extending 3km to the east of the line. It will operate 24 hours a day in an area which is currently deeply rural,
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very tranquil and the benefactor of ‘dark sky’. Design details are very broad in the content of the ES and no illustration or photomontages are provided. The IMD sits next to the sustainable placement area for one million cubic metres of surplus excavated material. Both the construction implications and the operational consequences of this are unresolved, with limited design detail provided in the ES. As mentioned previously, we oppose the principle of sustainable placement of excess excavated material.
We seek clarification that the operational requirement of the IMD does not involve night time delivery of materials, as appears to be suggested in the ES.
4. A description of the likely We question the in combination/cumulative significant effects of the assessments at Hartwell and Calvert – Claydon and proposed project on the endorse a different legacy design. The Bechstein’s bat environment resulting from is one of the UK’s rarest mammals. Any adverse the existence of the impacts on the conservation status of Bechstein’s bat project, the use of natural will always be at a national level. The forecasting resources, the emission of methods in respect of ecology at CFA 12 and CFA 13 pollutants, the creation of Calvert-Claydon are not based on sound science. The nuisances and the use of a box structure and moveable screens with elimination of waste; and relocated habitat is an approach entirely embryonic in the description by the its thinking. The findings are entirely speculative. We developer of the make this submission in respect of both CFA 12 and 13 forecasting methods used as the point on forecasting applies equally across both. to assess the effects on the environment.
5. A description of the A better design here is a clear way forward and one measures envisaged to supported by adopting a far more precautionary prevent, reduce and where approach to mitigation. We conclude that there will be possible offset any a cumulative, long term, permanent and negative significant adverse effects effect on ecology and seek an integrated long term on the environment. landscape solution as an appropriate remedy of those significant adverse effects.
The cumulative impacts here are considerable yet the mitigation of the IMD area is confined to planted embankments to shield Steeple Claydon. While some screening is welcome, we promote a more area-wide
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designed mitigation. We also seek some assurances (within an amended EMR) that construction vehicular movements in this area are limited by an operational travel plan (for site workers), a clear non-vehicular mode for waste movement on roads (i.e. movement via the railway ‘trace’) and much greater design detail on the IMD and photomontages.
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APPENDIX ONE: Detailed Observations by Community Forum Area In this Appendix, more detailed points about the ES are set out in relation to each CFA area as it affects National Trust property.
8. Dunsmore, Wendover and Halton (CFA 10) (National Trust Coombe Hill)
8.1. Ecology
8.1.1. We are aware that Bacombe Hill LNR / Coombe Hill SSSI will be within 25 metres of the temporary road diversion that will link Bacombe Lane with Ellesborough Road. It is stated that ‘there will be no significant increases in air pollution (dust deposition) that could affect the habitats for which both sites are designated. Therefore the integrity of both sites will remain unaffected’ . 2 We ask that the rationale and justification behind this are revealed. 8.1.2. We accept the assessment for the Chilterns Scarp Landscape Character Assessment (LCA) (Coombe Hill). The importance of the scarp and its far reaching views across Aylesbury Vale are recognised as one of the special qualities of the Chilterns AONB and we submit that it is perfectly reasonable to argue that the effect of HS2 (construction and operation) will be greater than anticipated in the ES. The tranquillity of Coombe Hill is readily acknowledged in the assessment of impacts. 8.1.3. The National Trust agrees with the baseline assessment in the ES in relation to Coombe Hill, which says that the tranquillity is high 3. This is corroborated by the Landscape Character Assessment on the Chiltern Scarp (Coombe Hill) 4 which also notes the high sensitivity to change here, with the Part 3 Assessment Matrix noting a ‘ moderate adverse’ impact of views NE of
2 ES Volume Two CFA 10 at 7.4.4.
3 ES Volume Two CFA 10 section 10 on landscape and visual impact, at page 139.
4 ES Volume 5 Technical Appendices CFA 10 landscape and visual assessment LV-001-10).
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Coombe Hill. It is accepted that the Wendover Green tunnel will be visible in the context of an agricultural landscape 5. We accept all these points.
5 ES Volume Two and reference to photomontage from the summit of Coombe Hill and also at paragraph 9.5.181.
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9. Stoke Mandeville and Aylesbury (CFA 11 - including Hartwell House)
9.1. Landscape and Cultural Heritage
9.1.1. We accept the evidence baseline for cultural heritage (the gazetteer and baseline assessment). Under matters of landscape and visual impact we agree that ‘ the grounds of Hartwell House are recognised as one of Buckinghamshire’s finest estates’ 6 together with a high level of tranquillity and perceived as ‘ a quiet area of retreat’ 7 albeit that in our draft ES comments (July 2013) we referred to this as ‘a place of quiet retreat’ , an important distinction. We also note, in the Landscape Character Assessment work that the tranquillity of the parkland will be affected during year one of the operation and with a high magnitude of change in year 15 of operation (e.g. setting, permanent loss of woodland, alteration to landform and changes to tranquillity) and that this will not reduce to a ‘ medium ’ magnitude of change until year 60. 8 We are also aware that while the ES reports that 25% of the golf course (20 hectares) will be required during construction, reducing to 15% (12 hectares) during operation, the loss is more consistent with 43 hectares out of a total of 69 hectares (or 62%). The creation of a grassland and wetland habitat (some 114 hectares) is tabled without explanation and justification.
9.1.2. Our own independently commissioned review of the Landscape and Visual Impact Assessment, by Land Use Consultants , reports that the methods for appraisal of visual effects adopted are appropriate. In addition technical Appendix 5 sets out the criteria for determining sensitivity, magnitude of change for landscape and visual receptors and definitions of
6 ES Volume 2 CFA 11 at chapter 9 on Landscape and Visual Impact at paragraph 9.3.11.
7 ES Volume 2 CFA 11 at chapter 9 at paragraph 9.3.10.
8 ES Volume 2 CFA 11 at chapter 9 at paragraph 9.5.27.
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significance of effects. These are generally considered to be appropriately defined. Major and moderate categories are considered to comprise a significant effect. We endorse the decision taken by HS2 to ensure that the visual assessment of impacts is defined by the maximum extents of the Zone of Theoretical Visibility (ZTVs). As concerns the baseline assessment here, the information used to establish the landscape baseline is clearly set out and this adopts an appropriate scale drawing on the existing district level landscape character assessments. The assessment process makes judgement on condition, tranquillity and landscape value and with reference to these establishes landscape sensitivity. Sensitivity is therefore, based on a transparent analysis of characteristics and attributes which provides a clear rationale for judgements. On visualisations and montages generally, we conclude that a greater number of photomontages would be useful as part of the ES in order to provide a fuller representation of the impacts of the scheme.
9.1.3. In the CFA 11 Report 9 the National Trust is pleased to see the commitment to working together in relation to the land between HS2 and Aylesbury and is pleased to note the general commitment to include land to enable additional landscape integration, recreational open space and ecological benefits. However, we could not endorse a proposed strategy that caused the demise of the golf course and the ES offers little reassurance here, nor could we support a strategy that did not carry the consent of the Ernest Cook Trust. Any further discussions dealing with the delivery of wider objectives around Hartwell-Aylesbury must be the subject of discussion with all relevant landowners.
9.1.4. Information on route section main alternatives is provided in section 2.6. With regard to the alignment between Aylesbury and Hartwell House, we are pleased to note the changed reinstated alignment of the A418 consistent with the proposed land bridge scheme, although it notes that the
9 ES Volume 2 CFA 11 at chapter 2 at paragraph 2.2.5
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proposed land bridge is not included with option (A) cutting and embankment adopted as part of the proposed scheme. We restate our requirement that our land bridge proposal is adopted.
9.1.5. Under CFA 11 paragraph 2.6.47 onwards, the ES notes the reasons why the cut and cover land bridge option was not adopted. While it recognises the benefits of reduced severance and landscape restoration offered by the land bridge option, it notes that adverse effects would include larger loss of trees associated with the RPG, increased effects associated with the introduction of a portal structure and permanent loss of a larger section of the curtilage wall. We have asked for clarification as to the amount of tree loss as calculated by HS2 . (Please refer to our Question 6 in Appendix Two)
9.1.6. A matter of great concern for the National Trust remains the unresolved implications for the golf course and the seemingly vague nature of a future green infrastructure / grassland habitat creation commitments here. The severity of this issue is manifest in the fact that 43ha of the total golf course operation of 63ha will be taken as well as the loss of the playing fields leased to the local authority by the Ernest Cook Trust. CFA 11 paragraph 5.4.15 acknowledges that the route corridor means …’ that the Golf Club will not be able to continue operating during construction’, and continues that ‘the long term viability will depend on the delivery of a reconfigured golf course’ . Such an aspiration (i.e. reconfiguration) is entirely speculative and no evidence is advanced in the ES to substantiate how it would be achieved and how the existing golf course could re-establish itself after such a long period of closure and thereafter continue.
9.1.7. The landscape baseline for Hartwell as set out in the Map book and described in CFA 11 Vol. 2 is, we submit, appropriate and corresponds to up to date landscape character information for Buckinghamshire County, Aylesbury Vale District and Wycombe District. Volume 5 Appendix LV-001-
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011 10 describes all the 12 LCA identified within the study area, and sets out information on their condition, tranquillity, landscape value and sensitivity. The LCA of most interest to the National Trust is “Hartwell House and Golf Course”. We agree with the description of a landscape in good condition, with high levels of tranquillity and of national value, and the associated high sensitivity to change.
9.1.8. On the assessment of impacts and effects for construction (on landscape), the construction impacts on the four LCAs are described in Volume 2. Of these three are considered to be Moderate adverse and one (Hartwell House and Golf Course) as Major adverse . This is an appropriate overall conclusion. There are considered to be significant effects on 4 LCAs and a relatively detailed visual assessment is provided for the 28 viewpoints, all of which are expected to receive at least Moderate adverse, with 12 being Major adverse. The National Trust agrees with the assessment that the following visual receptors will receive a Major adverse effect during construction; (a) views within Hartwell House Estate (view north along main tree avenue) and (b) views west from open space (part of Aylesbury Park Golf Club).
9.1.9. On the assessment of impacts and effects during operation (on landscape), effects are described at 1, 15 and 60 years of operation. On landscape, significant effects on landscape character are forecast to occur within four LCAs: Stoke Mandeville Vale (year 1), Haddenham Vale (year 1 and 15), Hartwell House and Golf Course (year 1, 15 and 60) and Fleet Marston Vale (year1). The NT concurs that Hartwell House and Golf Course LCA will receive the highest level of effects due to its high sensitivity and high magnitude of change. The main changes will be the engineered landforms across a relatively flat landscape, presence of overhead line equipment, regular high speed trains and associated noise, direct loss of
10 ES Volume 5 CFA 11 Landscape & Visual Assessment: Stoke Mandeville and Aylesbury Ref Vol 5 Appendix LV- 001`-011
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registered parkland land including severance of the avenue, loss of tranquillity and impacts on the setting of the house.
9.1.10. On visual impacts , photomontages have been produced of the proposed scheme from two viewpoints of particular interest to the NT:
Viewpoint 121.3.003 View north along the main tree avenue, Hartwell House
Viewpoint 122.3.001 View south-west from the public right of way within Aylesbury Park Golf club
9.1.11. We note that the impact on this receptor as a cultural heritage asset is detailed separately. However we do not agree that the visual impacts on the view along the main tree avenue will not be significant . We agree that that the effect on the golf club viewpoint will be significant (year 1, 15 and 60).
9.1.12. It is recognised in the CFA 11 that Hartwell suffers a host of in-combination / cumulative impacts, essentially severance of historic land, noise, tranquillity, archaeology, water -hydrology and some ecology. The National Trust agrees with that assessment. The difficulty of placing the line through this tight corridor west of the town of Aylesbury renders the impacts as cumulatively of a high consequence. The Impact Assessment Tables accurately reports that the combination of changes to setting and permanent construction impacts will result in a ‘Major adverse impact’ upon Hartwell House and its Grade II* Registered Historic Park and Garden. 11 The impact involves demolition of 50 metres of perimeter wall to the parkland, severing the avenue to the north of Hartwell House and encroachment of the designed tree belt that forms the east boundary of the core part of the historic landscape. Holistically the cultural heritage impact is reported as
11 ES Volume 5 CFA 11 Survey Reports on Cultural Heritage (CH-004-011) at Impact Assessment Tables.
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‘This is an asset grouping of high value. This will constitute a high adverse impact and a major adverse effect’ . 12
9.1.13. The landscape character assessment includes language such as the route will ‘ degrade the integrity of this landscape’ (landscape summary of likely residual effects 13 ). Alongside these impacts the ES reports further discussions about reconfiguring the golf course 14 and the removal of archaeology of mediaeval settlement within the parkland 15 .
9.1.14. The visual baseline photomontages include no viewpoint looking east taking in the designed view to Aylesbury (St Mary’s Church). The significance of the house and parkland is partly related to these key views. Further, the historic avenue between Hartwell and Quarrenden is severed permanently and views out from the Registered Park and Garden are affected. The visual baseline for this effect in photomontage 003 16 with the view along the tree avenue deemed minor adverse effects (not significant) anticipated in year 1 with minor beneficial effects year 20 and moderate beneficial effects year 60. The National Trust do not agree with this assessment and disagree with the professional judgement here that the visual impacts on the views from within Hartwell House RPG will not be significant.
9.1.15. On ecology, especially at paragraph 7.4.32 (no significant effects as to bat collision with trains), we cannot find evidence of bat tracking to
12 ES Volume 2 CFA 11 at chapter 6 and paragraph 6.4.19.
13 ES Volume 2 CFA 11 at 9.5.94.
14 ES Volume 2 CFA 11 at chapter 5 and paragraph 6.3.29.
15 ES Volume 2 CFA 11 at chapter 6 and paragraph 6.4.22
16 ES Volume 5 CFA 11 at Appendix LV-001-011 (descriptions of viewpoints) and photomontage 121.3.003 view north along the main tree avenue Hartwell House. The principal receptors are recreational views with a high sensitivity to change.
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ascertain movements, nor anything on the effects of turbulence. As with CFA 12/13 (below) we cannot find a definition of ‘temporary’.
9.1.16. The National Trust proposes the inclusion of its land bridge as first put in its draft ES consultation response (July 2013). As stated previously, this designed mitigation enjoys a broad support. As is currently put in the ES the judgements made on the assessment of impacts confine themselves to the engineered structure only and do not take into account the wider landscape. At operational level, the cultural heritage section notes the changed setting of Hartwell due to the movement of trains and increase in noise. The comparatively quiet environment of the park is highlighted as a feature of the original design contributing to the appreciation of the setting and significance of the park. The change here is noted to remove the peaceful ambience of the inner park resulting in a major adverse effect. We agree that the proposal will result in a significant effect on the park for at least 60 years . This suggests that there is an opportunity to seek to continue to develop a scheme and detailed design that reduces impacts on this nationally important landscape and its setting.
9.1.17. It cannot be denied that, under the current scheme, visitors to the hotel and parkland will know they are staying on the edge of a high speed railway. Our reworked land bridge brings many benefits to Hartwell, Lower Hartwell, Sedrup and Fairford Leys near Aylesbury. We have taken independent advice on noise matters and water/hydrology to the effect that our proposed land bridge option has material benefits regards noise– spill into the Park and towards Aylesbury / Sedrup and that the landbridge need not affect the hydrology/water environment, compared to the existing embankments – culverts. We are in possession of an independent professional opinion by Sound Analysis Consultants which is clear that the planting of trees will not significantly reduce noise levels. We know that a barrier will have an effect on noise reduction but that this can never be as effective as a land bridge / cut and cover proposal. While we do seek more
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details on the design of the barrier and on other noise issues, our submission here is that the land bridge offers by far the best way forward and the most robust solution.
9.2. Hartwell and Wider Mitigation: Key Principles.
9.2.1. We submit that the NT’s land bridge proposal can be engineered and acceptably configured into the landscape. While we seek further clarification on this point we are not aware that any technical reasons stand in the way of this scheme. If it is because of cost that our proposal has been rejected then we seek that information.
9.2.2. If it is not a matter of cost then we must conclude that it is ultimately a professional conclusion that the cutting – planting and noise fencing suffices as a means of noise mitigation, albeit with a serious visual impact of no less than 60 years duration.
9.2.3. Following the mitigation hierarchy promoted by HS2 and the stated desire to challenge standards in the EMR reports, we commend this National Trust scheme again and ask that the Secretary of State reassesses the current proposals and our own proposed vision here in relation to construction and operational environmental impacts.
9.3. Noise
9.3.1. We propose to deal with Noise matters separately, as they affect many matters within CFA 11. For ease of reference these are all matters of clarification as set out in Questions 12 and 13 of Appendix Two .
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10. Waddesdon and Quainton (CFA 12)
10.1. Landscape and Cultural Heritage
10.1.1. The ES reports that the chosen route option (at B) would potentially have visual and noise impacts on the landscape character of the Waddesdon Registered Park and Garden 17 (Grade II*) and at Claydon House (Grade I) will sever the relationship between Claydon House and parts of its former estate (Grade II Landscape) (deemed low adverse and moderate adverse). The assessment of landscape and visual impact makes the point that the replacement of the A41 overbridge will, to some extent, reduce the landscape impact on the Waddesdon Parkland 18 . As a design consequence the newly proposed A41 Blackgrove Road roundabout requires greater screening in the landscape. An assessment of this in the context of Grand Lodge (Grade II) requires that consideration is given to mitigation of light spill (as this roundabout will be three metres above existing ground level) as well as some more general concealment of its impacts on the wider landscape. Additional mitigation must address the amended, more elevated section of the route at Fleet Marston, which also affects Grand Lodge. Additionally we seek the further amendment that the railway is put under the A41 at Fleet Marston.
10.1.2. Further, the ES reports that the road sections truncated by the new layout are landscaped to prevent a wholly ‘ left over’ appearance in the wider landscape. We cannot find any details on the landscape design of water ditches, culverts and ponds, for example. Some acknowledgment of this failing and some future design thinking would be very beneficial, with design details of ditches, culverts and ponds, even if of indicative quality .
17 ES Volume Two CFA 12 at paragraph 2.6.6.
18 ES Volume Two CFA 12 at chapter 9 and paragraph 9.5.2.
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10.1.3. We propose that consideration of the impacts at Claydon should form part of the wider Calvert – IMD master-plan or landscape scale approach within CFA 13. We note here that within the Claydon Bowl LCA, tranquillity is deemed to be high and the area has a high level of sensitivity to change 19 . Claydon House itself is located around 3 km north-east of the proposed railway. For the Claydon Bowl LCA, the National Trust notes that the description highlights the association of this landscape with Claydon House and its associated historic landscape. The National Trust agrees here that the landscape is in good condition, with high tranquillity and of national value and associated high sensitivity to change. Other LCAs including Blackgrove Vale LCA and Westcott Claylands LCA have a close association with the registered parkland and landscape setting of Waddesdon (e.g. adjoining the boundary of the RPG). We note that this is not noted in the description and that, for both, sensitivity is identified as medium. We suggest that their function as the rural landscape forming the setting for Waddesdon may raise sensitivity and this should be considered as part of the assessment.
10.1.4. It appears accepted in the papers that the Infrastructure Maintenance Depot (IMD) will impact on the night-time character around Steeple Claydon. Ecology is of considerable importance here and we note at CFA 12 the importance of Sheephouse Wood and matters of habitat fragmentation between foraging and roosting 20 . We simply make the point here that temporary harm is ill defined and has not been properly explained since the draft ES (July 2013).
10.1.5. CFA 12 on ecology deals with cumulative effects and after mentioning the committed development of the East-West rail and Energy from Waste plant at Greatmoor, states that “ no major developments have been identified which are likely to have a cumulative effect with the proposed
19 ES Volume Two CFA 12 at chapter 9 and paragraph 9.3.10.
20 ES Volume Two CFA 12 at chapter 7 and paragraph 7.5.5.
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scheme ” 21 At odds with this, the CFA continues later to mention potential in- combination and cumulative effects, that these two developments will exert an effect but with no discussion as to avoidance or mitigation 22 .
10.1.6. We request more information on the implications for the wider landscape setting and this can be most readily addressed by greater deployment of photomontages [Please also refer to Question 17 of Appendix Two ]. We cannot find any photomontages of the IMD. Aware of the effects of engineered embankments, the presence of overhead power lines within the Vale and elevated footbridges over the A41 and noise fence and security fencing, a potentially adverse effect on the setting of the Waddesdon Registered Park and Garden is a cause for concern. Given the national significance of this landscape and the importance of the views out from this hilltop house and parkland, we consider that at least one photomontage here would have been helpful in order to help understand the impacts identified. [Please refer to Question17 of Appendix Two ]. We seek greater photomontage assistance here.
10.2. Ecology
10.2.1. We submit that more mitigation crossing points are required between Waddesdon and the proposed Adams Underbridge. We say this because the reported findings of the Bernwood Forest Bechstein’s Project (Bucks Bat Group) demonstrate evidence of Bechstein’s bats foraging up and down the line and crossing the proposed route, with demonstrable evidence of a radio tracked bat travelling from Doddershall House to Waddesdon (i.e. traversing the route corridor). The proposed stripping and replanting of some vegetation may work in some cases (i.e. Bechstein’s prefer to forage amongst scrub) but this is less effective for other species and in any event
21 ES Volume Two CFA 12 at paragraph 2.1.22
22 ES Volume Two CFA 12 at paragraph 7.3.30.
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evidence exists of Bechstein’s crossing the route. This is accepted in Volume 3 Route Wide Effects, where it states that:
8.1.30 A population of Bechstein's bat comprising of at least three colonies, is associated with a network of woodlands located either side of the Proposed Scheme in the Waddesdon and Quainton (CFA12) and Calvert, Steeple Claydon, Twyford and Chetwode (CFA13) areas. These woodlands collectively form remnants of the former Bernwood Forest. Field survey has confirmed that the Bechstein's bat population commutes both across and along the route of the Proposed Scheme. The Bechstein's bat population, which is associated with the Bernwood Forest, is of national value . (Our emphasis.)
10.2.2. We would seek the outcome of any post development study of such crossings used at HS1. In coming to this assessment we have noted three multi-use green over bridge crossing points, while we note that it is stated that HS2 have increased the ’number of over bridge crossing points from three to five’ and enhanced ‘ two existing under bridge crossings currently used by wildlife to cross under the Aylesbury link railway line’ . 23
10.2.3. We submit that the bat mitigation structure at Sheephouse Wood needs considerable detailed work to its design so that a dedicated crossing point is established at the northern end (currently proposed as a green overbridge with footpath) and at the southern end (currently a green bridge with footpath underpass). Any construction of such a structure (subject to design amendments proposed) must be clarified, especially the timeframe of implementation i.e. corridor planting / bridges / underpasses are all constructed first before construction of the Quainton and Doddershall embankments , which it is reported will take 3 years and 6 months. There are no dedicated crossing points for bats at the ends of this structure, instead a green over-bridge with footpath at the northern end
23 ES Volume Two CFA 12 at paragraph 2.6.61.
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and nothing at the southern end except a footpath underpass which is not designed as ecological mitigation and a green bridge around 800 metres away.
10.2.4. The ES advances the ‘ precautionary principle’ at various points but this would not support an approach based upon an unproven hypothesis, notably that vegetation removal will sufficiently and successfully deter bats from following existing flightlines. Insufficient evidence exists to support this and it is not, therefore, based upon a precautionary approach. To compound matters here the ES here relies upon just over one year’s baseline data.
10.2.5. The ES does seek to address severance as a consequence of construction. It is accepted that ‘the proposed planting will not be sufficiently mature to provide habitat linkages immediately. As such fragmentation of habitats used by Bechstein’s bats and other species will still arise in the years following construction’. 24 The ES Volumes Two CFA 13 at paragraph 7.4.50 proposes a series of measures designed to ensure that the temporary habitat severance that could fragment habitat for bats is addressed, comprising retention of existing corridors for as long as possible and use of moveable screens. With construction set at 7 years or more and a likely timeframe of around 5-10 years for scrub habitats to establish, a long gap of severance is, therefore, proposed which will exert a significant effect as Bechstein’s are slow breeding and do not breed at all in poor weather years.
10.2.6. We seek greater assurances here, including acknowledgement that evidence exists that Bechstein’s do cross the proposed route corridor from a roost in Doddershall House garden. We also seek greater information on how the ‘headwall’ on the underpass will ensure bats are funnelled through it.
24 ES Volume Two CFA 12 at paragraph 7.4.50.
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10.2.7. On construction monitoring, we ask that a potential review of impacts on Bechstein’s works both ways, for example the ES states that ‘ HS2 will continue to monitor the Bechstein’s population in this area of the route during the period up to construction, and if it is demonstrated that any of the above measures are not required to maintain conservation status of local populations, then the mitigation provision may be reduced accordingly’ . 25 The reverse is equally plausible, i.e. that measures may need to be increased if found that measures are not sufficient.
10.2.8. On matters of residual and cumulative impact the use of ‘ temporary ’ adverse is still not defined (a submission we made against the draft ES of July 2013). the summary of likely residual significant effects 26 exclude barn owls from the regime of measures that ‘ reduce the residual ecological effects during operation to a level that is not significant’ For barn owls, the summary concluded that ‘ if the proposed mitigation measures for barn owl are implemented through liaison with landowners, the residual effect on barn owl would be reduced to a level that is not significant’ . We would ask that “significant” is defined here and that some clarification is given as to the impact on Barn Owls.
10.2.9. We also think that great weight must be given to the cumulative effect of committed development (Energy from Waste and East-West Rail). Section 7.3.30 27 mentions the in combination / cumulative effects from these two developments but we need more assessment as to the cumulative effects on ecology. Also, the point is made that HS2 have previously acknowledged that such a combined impact exists is at odds with an earlier point (at 2.1.22) that ‘ no major developments have been identified which are likely to have a cumulative effect with the proposed scheme ’.
25 ES Volume Two CFA 12 at paragraph 7.4.56.
26 ES Volume Two CFA 12 at reference summary at 7.5.16
27 ES Volume Two CFA 12 at 7.3.30
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10.2.10. Peer reviewed and published evidence from Germany and France suggests that large, fast moving vehicles travelling in isolation (comparable to a high speed train) are most likely to cause bat mortality on motorways as higher volumes of traffic are more likely to deter bats from using infrastructure corridors through increased light and noise. 28 .
10.2.11. The ES acknowledges the operation of the proposed scheme has the potential to result in a variety of impacts on bat populations including those as a result of collision with passing trains, turbulence and noise. The point at which such impacts are considered to result in a significant adverse effect on the conservation status of the population concerned will differ between species. HS2 must provide an assessment of the likely mortality rates to assess whether they are likely to be significant and detrimental to the favourable conservation status of the bat species concerned. (Please refer to Q17 of Appendix One).
28 For work in Germany relating to Bechstein’s and roads, see Kerth, G. & Melber, M., (2008). Species-specific barrier effects of a motorway on the habitat use of two threatened forest-living bat species. Biological Conservation 142 (2009) 270-279. For work on M6, see Altringham, J.D. & Berthinussen, A., (2012). The effect of a major road on bat activity and diversity. Journal of Applied Ecology 2012, 49, 82–89.
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11. Calvert, Steeple Claydon, Twyford and Chetwode (CFA 13)
11.1. Landscape and ecology
11.1.1. A point of submission, to which we will return, is that a better proposal for this area, advanced by NT/BCC and Aylesbury Vale DC in 2012 has not been advanced. On matters of detail we seek greater photomontage information of the IMD and its relationship to the surrounding landscape, including our land at Claydon and that of the Verney Estate.
11.1.2. The wider area within CFA 13 is greatly affected by a series of cumulative and incremental changes, with the IMD (of 37 ha area, extending 3km eastwards and a 24 hour operation, with external lighting) and sustainable placement for HS2 (one million cubic metres raised by 5 metres in topography) within an area of rural tranquillity and dark sky, combined with the Energy from Waste Plant, East-West rail proposal and loss of ancient woodland at Sheephouse Wood as well as significant consequences for Bechstein’s movement. We agree with the assessment for Claydon Bowl which indicates a major adverse effect. The emerging engineering profiles will be uncharacteristic. The magnitude of change will be high and there will be a major adverse effect. The landscape assessment does not include any mention of the severance of Claydon and the effect on its setting. Such latterly identified development is a part of the planning baseline and must be given attention. We overlay those considerations with an area of high ecological value and connectivity, including an assemblage of bats and a population of Bechstein’s bats as well as Daubenton’s, brown long-eared, Natterer’s, common pipistrelle, soprano pipistrelle bats, Whiskered Bat, and Brandts Bat reported as of national value. 29 .
29 ES Volume Two CFA 12 at Table 11 and 7.3.34 where Bechstein’s are recorded as of national value but are also of international EU protected status.
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11.1.3. We find the ecological evidence in pursuit of an alternative, to be overwhelming. The ES accepts that habitat fragmentation ‘may ’ also disrupt the activity of the Bechstein’s 30 and that mitigation is, principally designed, in the realms of overbridges and underpasses, some habitat removal (to assist in reconfiguration of movement) and an 800m long by 10m high box shaped enclosure with some lighting to inhibit movement across the route corridor. 31 We are aware that the Secretary of State when considering the upgrade of the Wolvercote Tunnel (Chiltern line upgrade from Bicester to Oxford) deferred implementation because the sonic system proposed to prevent bats entering that tunnel was deemed untested.
11.1.4. The National Trust submits that the embryonic idea of a box like structure would be far more effective as a ‘ box tunnel’ and this would represent an evolution of the current design as opposed to a radical departure, however, it is necessary as no evidence is advanced in the current formal ES to reassure on the balance of submitted evidence that what is currently proposed delivers a systematic and evidence based mitigation proposal.
11.1.5. The National Trust has seen an independent opinion as sought by BBOWT and produced by two eminent researchers and practitioners at the University of Leeds. This work provides unequivocal foundations to the central submission that the research base and mitigation proposed by HS2 is inadequate. Paragraph 3.4 (conclusions) is clear that, ‘ There is no evidence to suggest that bats can be effectively channelled to crossing points with vegetation plantings’ and ‘There is very little evidence to support the success of overbridges as effective crossing points for bats .’ Section 9 (summary) challenges the concept of ‘ temporary adverse ’ effects on Bechstein’s bats, concluding that ‘ These effects are unlikely to be temporary……populations would be unlikely to recover after this
30 ES Volume Two CFA 12 at 7.4.15.
31 ES Volume Two CFA 12 at 3.5.2
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time……and any damage done is likely to be irreversible’ . This work, based on the most comprehensive review, to date, of empirical work in peer reviewed journals and other literature searches, is clear in dismissing the design and proposals currently being proposed. The National Trust finds this work to be of overwhelming importance and the most significant body of evidence as produced, to date, to produce a conclusion that the existing mitigation proposals in CFA 12 and 13 represents the wrong approach. This work serves to reinforce the central conclusion that a different mitigation approach must be adopted. 32
11.1.6. From a review of the map books these vegetation management zones appear set back by 20 metres and along the eastern side of the proposed scheme in two blocks between the Adam’s Accommodation under-bridge and the Footpath CAG/2 under-bridge and then between Bridleway QUA/36 green over-bridge and Bridleway GUN/28 green over-bridge. This design siting / location assumes that no bats will use more open habitats. Some species prefer cluttered habitat (vegetation and understory), but others and even those with a preference, will fly in open spaces. Evidence exists to show that Bechstein’s have been radio tracked across open spaces.
11.1.7. CFA 12, ecology chapter - 7.3.28 table – dormouse – gives the presence (or rather potential presence) of Dormouse negligible value. Dormouse are European Protected Species and the CFA then goes on to say they were unable to access the woods in the area to survey them and their assumption of a population of negligible value is based on surveys of hedges nearby and remnant woodland at Calvert landfill. This is insufficient foundation of research to support this conclusion. CFA 12 ecology chapter -
32 Appraisal of HS2 Ltd Environmental Statement in relation to the bat community in the Bernwood Forest area, with particular reference to Bechstein’s bat (2013). Report for Berks, Bucks, Oxon Wildlife Trust (BBOWT). By Dr Anna Berthinussen & Professor John Altringham, University of Leeds. Professor John Altringham does provide advice to the National Trust but the National Trust had no involvement in the commissioning of this report.
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7.5.16 in reference to the Summary of likely residual significant effects –The ES states: The mitigation, compensation and enhancement measures described above reduce the residual ecological effects during operation to a level that is not significant, except for barn owl . Train strike is likely to result in the loss of barn owls that nest close to the route resulting in a residual significant effect. However, if the proposed mitigation measures for barn owl are implemented through liaison with landowners, the residual effect on barn owl would be reduced to a level that is not significant. There is a clear acknowledged of significant effect that is unmitigated.
11.2. Claydon – Calvert – Bernwood and Wider Mitigation
11.2.1. We agree with the conclusion in the ES that the Claydon Bowl Landscape Character Area is ‘ significantly affected’ during operation 33 and that the IMD will exert a likely residual significant effect on the Claydon Bowl LCA 34 and it must be accepted between all parties that the magnitude of change in this rural area will be considerable. The IMD alone at 3km lateral extension of the east-west route is a considerable new intervention and for operational reasons must include lighting of external areas. In this respect our appraisal of the EIA again reflects that greater weight must be attributed to the permanent, long-term and negative, cumulative – residual impacts and with considerable regard to the ecological evidence base and in particular the characteristics of potential impact. A landscape led master plan approach is required. This requires a more joined up approach in which the box structure is to be replaced by a box tunnel, specific wildlife only green bridges and dedicated crossing points with less emphasis on habitat relocation and more on a holistic design based on ecology and landscape. The building of a linear infrastructure project will, inevitably,
33 ES Volume 5 CFA 13 Calvert, Steeple Claydon, Twyford and Chetwode Landscape Report.
34 ES Volume Two CFA 13 at 9.5.131
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create a relatively sterile barrier to movement to many species, with additional risk of mortality through train strike and the effects of turbulence. Whilst habitat creation will form (in time) well, connected linear corridors either side of the proposed scheme that may be beneficial to some species, assuming that an appropriate mechanism can be put in place to secure, maintain and managed appropriately in perpetuity. This lack of ecological permeability justifies a design approach as we advocate that seeks to connect section and corridors across the route and especially so where the ecological value is as high as it is in CFA 13.
11.2.2. The in-combination and cumulative impact of HS2 and its Infrastructure Maintenance Depot, the Energy from Waste plant (now being constructed) and the East-West Rail route (for completion 2017) must be acknowledged and accepted by HS2.
11.2.3. The Register of Local effects at Volume 5 of the Technical Appendices (CFA7-15, Colne Valley to Lower Boddington – Register of local level effects, EC-005-002 Ecology) includes rows that have a lack of mitigation for bat collisions (and by inference acknowledges some incidental collisions).
These are contained and as:
• CFA 10 page 8 row 7
• CFA 13 page 15 last row
• CFA 14 page 18 row 7
• CFA 15 page 21 rows 5 and 7
11.2.4. Our concern over this point is also compounded by the fact that there is no risk assessment in connection with bat collisions , in the paperwork.
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APPENDIX TWO: Questions/clarification/corrections on ES for HS2 Ltd
The National Trust seeks some points of clarification in its understanding of the ES.
12. Route-wide (Volume 3: route-wide effects of HS2 Phase One)
[1] Clarification required on costing of options.
We would invite HS2 to agree costing as appropriate for our proposals for designed mitigation. This will benefit all parties.
[2] Clarification of and further explanation as to the application of biodiversity offsetting and application of the Lawton Principles.
In the work of HS2 and the DEFRA (2011) Biodiversity Offsetting – Guiding Principles, which includes that offsetting is… ‘ at the bottom of the mitigation hierarchy and requiring avoidance and mitigation of impacts to take place first’ . In view of the Government’s further development of biodiversity offsetting with continuing development work by Natural England, we seek greater explanation of the strategic application of biodiversity offsetting and explanation of where it applies within the frame of the CFA reports and how it has been justified, with reference to the above.
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13. Dunsmore, Wendover and Halton (CFA 10)
[3] Clarification on construction/air pollution impacts Coombe Hill / Bacombe Hill.
To consider treatment of Nash Lee Lane and greater visibility of maintenance loop / gantries.
The National Trust has consistently supported the principle of a fully bored Chilterns tunnel as consistent with our own core purpose of protection of conservation and access.
[4] Clarification required
To seek underlying justification for the assertion that construction works / air pollution near Coombe Hill / Bacombe Hill will result in no effect on these nationally important ecological designations
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14. Stoke Mandeville and Aylesbury (CFA 11)
[5] Clarification on technical feasibility of National Trust Land Bridge
To clarify in writing that a land bridge is technically possible. To acknowledge that the land bridge is also supported by the Ernest Cook Trust, Bucks CC and Aylesbury Vale DC .
[6] Clarification on the amount / area of extra tree loss. To seek clarification (i.e. some form of quantification) if the land bridge / cut and cover proposal is advanced over the formal ES proposal, just how much more trees are required for removal.
[7] Clarification that the Hartwell landscape extends into the golf course as the Registered Parkland / Conservation Area extends eastwards beyond the land leased to the National Trust by the Ernest Cook Trust.
[8] Clarification on long-term implications for the Golf Club
A matter unresolved in the formal ES being the long term implications for the golf course and construction implications on the viability of the existing operation. No evidence is advanced to support the future uses and green infrastructure/grassland habitat creation aspirations as advanced. We would seek much clarification on the future aspirations for the golf course and the underlying evidence to support those aspirations . We share the opinion also expressed by the Ernest Cook Trust in respect of this issue.
[9] Clarification on Green Infrastructure aspirations.
The green infrastructure between the route and the edge of Aylesbury cannot be achieved at the expense of the golf course which is an existing and viable use from which a considerable amenity and public benefit is derived. Again, we seek clarification as to the future of the golf club.
[10] Clarification that Secretary of State will reconsider the NT land bridge option.
The National Trust seeks more design refinements and invites the Secretary of State to reconsider the four options put in the Environmental Statement at its 2.6.45. It is stated that these options (i.e. NT land bridges of two lengths) ‘ had to be re-engineered to meet engineering standards’ . We seek more detail on this point (as below)
The current ES proposal (compared to draft Environment Statement of July 2013) proposes removal of one additional residential property and encroachment of the designed tree belt (east boundary of core part of designed landscape). The ES notes that the tunnel proposed by the NT (our land bridge submission, also supported by
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Ernest Cook Trust, AVDC, Bucks CC and Parishes, including Stone PC and the Sedrup Green Residents Association and submissions from Lower Hartwell residents) would not correspond with the section of route where the greatest numbers of potentially significant residual effects are predicted. This appears at odds with the assessments of landscape and cultural heritage, as we report above. ES Volume One accepts, when reporting the assessment of environmental effects, that professional judgement can be employed. We submit that, with regard to the baselines as reported and the sensitivity and magnitude of change, much greater weight must be given to the cumulative and permanent effects upon this area. The ES, at many junctures, accepts that the Hartwell landscape, including lower Hartwell, is of high sensitivity to change. We fully acknowledge that the relocation of the A418 reduces traffic noise around the Park fringe but the current scheme, deemed ‘in the spirit of the National Trust proposals’ by HS2 [an expression used in the autumn 2013 community forum meetings] essentially comprises greater planting and noise acoustic fencing. The proposal results in a loss of 50m of parkland wall and near the Rifle Spinney the footpath crossing over the railway requires removal of a tree belt and construction of intrusive footbridge. The footpath crossing becomes, at this point, a jarring feature within the setting of the landscape.
We seek additional photomontages of eastern avenue and views of footbridge at Rifles Spinney and more details of footbridge and its impact on RP&G.
[11] Clarification as to ecological impacts at Hartwell and how biodiversity is or is not relevant to Hartwell.
On ecology, especially at paragraph 7.4.32 (no significant effects as to bat collision with trains), we cannot find evidence of bat tracking to ascertain movements, nor anything on the effects of turbulence. As with CFA 12/13 (below) we cannot find a definition of ‘ temporary ’ effects on ecology. The discovery of Barbastelle bat within the grounds of Hartwell House is significant and warrants further investigation.
[12] Clarification required on noise calculations and other noise matters.
We seek clarification that examples of the HS2 noise calculations pertinent to Hartwell, taken from source to receiver, are made available to the National Trust .
(i) We would seek clarification that the desired barrier height will need to be designed with a number of parameters in mind, namely; individual noise source levels, (track at low level, motors and pantograph noise), height selected to screen the identified maximum source, internal acoustic lining, which is to prevent noise increase inside the barrier enclosure, and avoid adverse acoustic reflections taking place, over the barrier. We see this as common ground but welcome this clarification.
(ii) We would seek clarification that the National Planning Practice Guidance – Noise and Noise Policy Statement for England are documents of broad principle. In our own
52 of 61 National Trust response to: HS2 Phase One Formal Environmental Statement submissions on the scope and methodology consultation (of May 2012) we made the point that, ‘The NPSE requires the identification of significant adverse noise impacts, which should be avoided and adverse impacts which should be mitigated. It also requires that development should contribute to the improvement of health and quality of life, where possible, by reducing noise impact’ . We also made the point then that and following EIA regulations on screening, noise impacts would need to be considered against magnitude, complexity, probability, duration, frequency and reversibility. Such criteria provide a very useful benchmark for any assessment of impacts.
(iii) We would like to agree, in clarification, that the inclusion of local traffic noise calculated to 2026 levels is based on a number of variables, which are highly speculative. We would point out that HS2 in their own documentation, at their Sustainability Statement (at Volume One paragraph 4.7.12) state that existing traffic is not taken into account in the assessments and at 14.3.16 of the September 2012 Scope and Methodology Report, states that Spatial scope for indirect effects - a qualitative assessment will be made where the increase or decrease in road or rail traffic volumes or traffic types caused by the Proposed Scheme would be likely to cause a change in the baseline sound level (LpAeq,T) exceeding 1 dB during either the day (07:00 to 23:00) or night time periods (23:00 to 07:00). The National Trust is independently advised that projected future road vehicular noise is not a reasonable factor in local traffic noise calculations to 2026 and that we would respectfully point out that in other documents HS2 state that existing traffic is not taken into account in the assessments (i.e. compare with, Sustainability Statement Volume 1, paragraph 4.7.12 when dealing with ‘additional considerations’ , states that, ‘The AoS has predicted potential impacts based on a consideration of HS2 within the context of rail noise. There are other sources of existing noise, such as road, aircraft and industry that have not been considered at this stage, but which would in practice moderate the relative effects of HS2train noise. Consideration of these other background noise sources could alter the identified potential impacts and in general, impacts are likely to be lower than identified here as any increases in noise attributable to HS2 may be less noticeable’ . As a point of clarification we would seek traffic noise matters at 2026 to be deleted from noise assumptions in this ES.
(iv) We would like to clarify that reference to future traffic noise is based upon a number of variables and is speculative in its nature. Therefore, we would ask that the conclusion based on projected traffic noise are specifically revisited and re-assessed in the light of this. At the very minimum we would ask that they are qualified by a suitable caveat that they are based upon future speculation that traffic density will increase on the A418, that future car engine systems will be quieter (and demonstrably so) and that tyre noise will not alter (which may not be the case as new surfaces are reducing this element of vehicle noise). The safe assumption here is that the current noise level will not decrease. We would invite HS2 to comment on this aspect of the ES. We submit that
53 of 61 National Trust response to: HS2 Phase One Formal Environmental Statement to increase the traffic noise level to 2026, in an attempt to reduce the application of mitigation measures, should not be an option.
[13] Clarification required on noise methodology. We seek clarification that these points are correct.
(i) Daytime noise levels that are predicted to exceed Leq 50 dB(A) by 3dB or more are being identified as impact ONLY IF the increase level exceeds the absolute figure of 50 dB(A)
(ii) Night-time noise levels that are predicted to exceed Leq 40 dB(A) by 3dB or more are being identified as impact ONLY IF the increase level exceeds the absolute figure of 40 dB(A)
(iii) This assessment appears to be based primarily on the WHO Guidelines, The daytime level chosen of 50 dB(A) is still rated as moderately annoying.
(iv) The level of 45 dB(A) outside bedrooms causes sleep disturbance, and HS2 have selected a level 5 dB(A) lower.
(v) A reduction of 15 dB(A) is proposed for a partly open window, and so the internal bedroom level becomes 25 dB(A).
(vi) A maximum event level of 60 dB(A) Leq is also proposed by WHO, but does not appear to be applied as a criterion, by HS2 for Impact. Assessment. ?
(vii) The only maximum mentioned is Leq 68dB(A) stated in Sustainability Statement Appendix E6 Noise and Vibration 4.9.2, but even this does not seem to be considered in the Operational Impact Assessment Tables.
(viii) WHO Guidelines at Table 4.1 of guidance noise levels, sets the level of 45 dB(A) outside bedrooms causes sleep disturbance. HS2 have selected a level 5 dB(A) lower. The National Trust would like to be reassured on this point.
(ix) We would seek an assurance that the above assumptions / understandings are all indeed correct and that WHO guidelines denote 50 dB(A) as moderately annoying
(x) The National Trust would seek clarification on the design detail before being able to comment more fully. Details of the noise barrier design are highly material to the assumptions made in the ES.
(xi) We would seek clarification that a design level is sought that achieves 10dB below the lowest background level.
(xii) Paragraph 11.2.5 interestingly indicates daytime levels of 43-50dB(A) with Night time levels 5-10dB lower, which would be a low of 33dB(A). We would seek clarification that
54 of 61 National Trust response to: HS2 Phase One Formal Environmental Statement this indeed is correct.
(xiii) Paragraph 11.2.10 shows that traffic noise assessment is not appropriate, and has some assumptions that are very arguable. We would invite HS2 to agree this detail, in clarification, as identified above.
(xiv) We would suggest that WHO guidelines are considering relatively “stable “noise levels and not regular intermittent high noise levels. For example, BS4142 would impose a 5dB correction for tonal and intermittent noise. We would invite HS2 to agree this detail is correct.
(xv) We seek clarification that HS2 accept that the planting of trees will not significantly reduce noise levels.
[14] Correction: Water Resources Assessment (WR-002-011)
This document provides an overview of water resource issues, being supplemented by the flood risk assessment report (WR-003-011) and by a hydraulic modelling report for Stoke Brook (WR-004-003).
One thing noted is some confusion regarding some of the local watercourses. We understand that the Hartwell Ditch used to drain to the Stoke Brook, which in turn flowed into the Bear Brook, through the north-western edge of Aylesbury. However, in 1977/78 drainage improvements were carried out and the Hartwell Ditch was connected directly into the Bear Brook. Thus it no longer flows into the Stoke Brook. However, in Table 1 it is stated that the Hartwell Ditch joins the Stoke Brook. It is not known if this is an error in the wording or reflects incorrect understanding on someone’s part. Although the consequences of this error may not appear to be particularly significant it is important that such local details are correctly understood. This is important during modelling work and when specific issues and potential solutions are considered. Clarification is thus sought.
[15] Correction: Appendix CH-001-011– Gazetteer of cultural heritage assets at Hartwell House
At 4.3.5 a list of sixteen listed buildings and structures includes reference to ‘a pair of statues to the west of Hartwell House: Grade II listed. A pair of statues possibly part of a James Gibbs design and depicting a classical god and goddess, each with a large bird. These statues originally flanked the now filled in canal.’
This pair of statues, Juno and Zeus, are in fact located to the west of Hartwell House, just to the east of the Gibbs Archway, analogous to their original canal setting and moved to their current position in 1989.
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This is a material error and we draw this to the attention of HS2.
[16] Clarification as to the exact meaning, definition and further detail of ‘tall screening’ and ‘tall noise barriers’.
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15. Waddesdon and Quainton (CFA 12)
[17] Clarification of landscape treatment of A41.
We readily accept the benefits of a bypass at Waddesdon instead of the draft ES flyover structure, across the A41 but still seek consideration of the route passing under the A41. We would want to clarify that a landscape scale – master plan approach is feasible. We also want to agree (as set out below) that the baseline of existing planning commitments in this area, demonstrates a considerable in-combination / cumulative / residual effect in a place that was previously very rural and highly tranquil. We would want to clarify that the wider landscape treatment will be the subject of further detail.
We seek additional photomontage views from within the RP&G looking into the Vale of Aylesbury.
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16. Calvert, Steeple Claydon, Twyford and Chetwode (CFA 13)
[18] Clarification of our proposed landscape-led approach.
To agree that a landscape scale / master plan approach for Calvert – Claydon – Bernwood is technically feasible (as proposed by NT, BCC and AVDC November 2012) and to agree that the box structure proposed is unproven (against evidence).
We would like these issues of lack of landscape led approach and lack of science to justify the box structure, to be revisited and reviewed. The cumulative impacts from HS2, Energy from Waste and East-West Rail are easily quantifiable, creating cumulative, long-term, permanent negative effects and this involves impacts upon landscape and visual assessment, ecology and cultural heritage, at the very least. Combining with this the sensitivity of the surrounding area, notably ancient woodlands and protected habitats and species as well as the very tranquil rural areas that surround, (especially Steeple Claydon) and cultural heritage assets (especially NT Claydon House and Parkland), we conclude that HS2 must re-visit this element of the design.
[19] Clarification required on multi use bridges.
We seek that evidence is forthcoming to demonstrate how the multi-purpose use of these structures can be effective. We also seek clarification on the application of the precautionary principle and scientific foundations for the box structure, relocation of vegetation and moveable waffle screens during construction. We would seek more detail and further clarification of what is meant by ‘temporary’ when assessing impacts, in respect of ecology and a risk assessment report as to bat injury/mortality.
Additional photomontages of IMD are required to assess its’ impact on Steeple Claydon.
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17. APPENDIX Three: National Trust Statutory Foundations
17.1. The National Trust is a charity, established in 1895 to promote a core purpose of conservation and public access, promoting the preservation “for the benefit of the nation” of places on account of their historic interest, natural beauty or wildlife. This purpose is translated into contemporary language as ‘Caring for special places, for ever, for everyone’.
17.2. Today the National Trust protects through ownership 742 miles of coast, 250,000 hectares of countryside and in excess of 300 properties as well as tenanted properties, including historic and rural communities and managed estates. Currently it has a membership in excess of 4 million people.
17.3. National Trust legislation confers special powers to protect its places, including declarations of inalienability (1907 Act), which means that land cannot be mortgaged or sold, or subject to compulsory purchase other than with the approval of Parliament. Although the Trust is primarily focused on the special places in its ownership, its role extends to places it does not own (1937 Act) and over covenanted land (1937 Act). In respect of ecology and landscape the conservation of “…natural aspect features and animal and plant life” was embedded in the Trust’s purpose from the original Articles of Association in 1895 and was subsequently enshrined in the 1907 National Trust Act.
17.4. It is within the remit of the National Trust to comment where development proposals affect our land or property, or other special places. Decisions on this are informed by our published planning principles. The National Trust is therefore neither ‘for’ nor ‘against’ the principle of high speed rail or indeed extensions of the ‘classic’ (i.e. conventional speed) network.
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17.5. The National Trust has formed a view on the HS2 proposals, informed by its ownership and interests, as well as local engagement, recognising that a scheme of this scale has wide-ranging impacts and taking the opportunity to establish shared goals for mitigation among our neighbouring communities.
17.6. Phase One affects four properties at Coombe Hill (gifted 1918 by public subscription and within in the Chilterns AONB), Hartwell House (operated by Historic House Hotels, a wholly owned subsidiary of the National Trust, as gifted in September 2008 and involving a leasehold interest from the Ernest Cook Trust), Waddesdon Manor (gifted 1957 and operated by the Rothschild Foundation who own and manage the wider landscape and estate alongside the Waddesdon Estate) and Claydon House (gifted 1956 and with an important partner in the Verney family who own and manage the wide estate). All four properties have been declared inalienable under the 1907 Act and at Hartwell, the lease itself is declared inalienable (with the Ernest Cook Trust).
17.7. As a conservation charity, the National Trust also has a wider perspective than just the places we own. Our wider conservation remit means we care about all special places, including nationally designated landscapes, (AONBs and National Parks), and we have thus taken a view on mitigation options for the Chilterns AONB and offered comments regarding the route-wide impacts of the line.
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18. Contributors
National Trust: Steve Field, Project Officer Claire Graves, Senior Project and Stakeholder Manager Jo Hodgkins, Wildlife and Countryside Adviser Gary Marshall, Archaeologist Tim Nicholson, Legal Manager Dr Ingrid Samuel, Historic Environment Director Dr Michael Stubbs, Land Use Planning Adviser
Consultants : Kate Ahern, Land Use Planning Consultant, LUC Mike Briggs, Hydrologist, HR Wallingford Dominic Cole, Landscape Architect, DCLA Alastair Lewis, Parliamentary Agent, Sharpe Pritchard LLP Alan Nethersole, Acoustic Consultant, Sound Analysis Timothy Straker QC, 4-5 Grays Inn Square Richard Spoors, High Speed Rail Engineering Consultant
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