HS2 Ltd ‘2018 Working Draft Environmental Statement’ Consultation Response of Leicestershire County Council December 2018
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HS2 Ltd ‘2018 Working Draft Environmental Statement’ Consultation Response of Leicestershire County Council December 2018 Structure of this response This Response to the HS2 Ltd Working Draft Environmental Statement (WDES) by is split into four parts. These are as follows: PART 1: Document Introduction and Main areas of Concern PART 2: Response to WDES Vol 2 – Community Areas LA03, LA04 and LA05 PART 3: Response to WDES Vol 2 – Route-wide Effects PART 4: Response to WDES Vol 3 – Off-route Effects PART 5: Appendices For any enquires about this response, please contact: [email protected] 1 | Page PART 1: Document Introduction and Maim areas of Concern i) This document and its appendices comprise Leicestershire County Council’s (the Council’s) response to the Working Draft Environmental Statement (WDES) for HS2 Phase 2b (the proposed scheme). We issue this response in the spirit of contributing to the processes surrounding this vast infrastructure project, but must include the caveat that the Council can only respond to the material to hand and further intensive work with HS2 Ltd is required to fully understand the impacts for Leicestershire and the most appropriate mitigation. ii) The Council recognises that the WDES is a draft document. However, it is disappointing that even in draft; there is a distinct lack of information provided in sections of the WDES, especially regarding the proposed scheme’s constructional and operational impacts and in respect of its design. But, the Council have determined to use this as an opportunity to shape the design and mitigation across the County. Where clear mitigation is not yet defined, the Council will seek to secure assurances from HS2 Ltd that further work will be carried out to inform the preparation of the Hybrid Bill, including HS2 Ltd preparing an Interim Transport Assessment (including sensitivity testing), and during the Parliamentary processes. iii) HS2 Ltd issued the WDES on 11 October 2018. This material consists of local area reports, four route-wide volumes and a series of map books illustrating over 150 pages of detail for Leicestershire. The consultation period offered by HS2 Ltd is 10 weeks, closing on 21 December 2018. The Council wishes to express its disappointment that such a short period of time has been afforded to consulting on such vastly complicated and technical documentation. It is especially disappointing given that submission of the Hybrid Bill has been put back until 2020, which should have enabled a longer consultation period. iv) The eastern leg of the railway to Leeds (Phase 2b) runs through 28 kilometres of North West Leicestershire District from Appleby Parva to the Nottinghamshire border. The route is proposed to run through the parishes of Appleby Magna, Measham, Oakthorpe, Donisthorpe and Acresford, Packington, Ashby-de-la- Zouch, Coleorton, Staunton Harold, Isley cum Langley, Belton, Long Whatton and Diseworth, and Kegworth. Main areas of concern v) Whilst it is recognised that the published consultation documents are working drafts, it is the Council’s view that the proposed scheme requires further improvement in several key areas as summarised below. 2 | Page General concerns on the consultation documents: a) The lack of baseline data in the WDES; b) Lack of detail in the documentation on a variety of issues such as transport assessment; this has made drawing conclusions difficult about consideration of the proposed scheme’s construction impacts on local communities, services and transport system; c) The number of broad assumptions in the documentation and in many instances, a lack of supporting evidence, particularly the general paucity of detail about/consideration of the proposed scheme’s impacts, once built, including on the Strategic Road Network, local road network and classic rail network in Leicestershire; d) Failure to address the issue of additional maintenance liabilities imposed on the local highway authority, given that Department for Transport funding is no longer adjusted to reflect increase in asset size; e) Lack of consideration/assessment of the impacts of the scheme on the classic rail network in and serving Leicester and Leicestershire (including station infrastructure); this includes the impacts of the proposed Toton shuttle train services1 (the Council will expect this to be covered by the requested Interim Transport Assessment); f) The Council must also raise concerns about any lack of apparent coordination between national bodies over HS2 and wider rail and Strategic Road Network future development and programmes2. This seeming lack of a joined-up approach could have adverse effects on the wider transport networks; g) Use of out of date or incorrect baseline information; h) Downplaying of impacts; i) Lack of consideration of cumulative effects on communities, particularly as these were highlighted as important in the Draft Scope and Methodology; The extent to which comments made during previous consultations on the proposed scheme have not been considered and addressed in this consultation, such as design of the Mease and Gilwiskaw Brook viaducts, impacts on Measham and others; 1 As set out in Appendix 1, the Council will be seeking assurances that the frequency and journey times of services between Leicester and London on the Midland Main Line will not be downgraded after the opening on the scheme. 2 This includes ensuring a common alignment of bodies’ future assumptions about and proposals for the Strategic Road Network and classic rail network, so that there is a common working basis. 3 | Page j) Preference of lower cost vs. lower impact options, although it is recognised that the proposed scheme uses taxpayers’ money; k) Lack of consideration/assessment of the potential impacts of construction workers on local services, such as schooling (where workers bring their families) and healthcare; General comments on the Proposed Scheme: l) The extent of the land take for the Construction Zone; m) Lack of information about access to construction compounds; n) Reconsideration of construction assumptions, including to avoid any unacceptable long-term3 construction closures of the A444, Tamworth Road, B4116, A511 and A512 at Ashby, and the A6 Kegworth Bypass; o) Reconsideration of the amendments made to Public Rights of Way, bridle paths and cycleways where the Council considers these to be insufficient and/or impractical; Specific comments on the Proposed Scheme: p) The preservation of the Old Rectory at Appleby Magna; q) The many impacts on Measham, including loss of properties, design of the Mease Viaduct, provision for the Ashby Canal, width of the transport corridor on the Measham Wharf – Fiveways Wood section; r) Consideration of re-provisioning of the Ashby Canal from Snarestone to south of Moira; replacement of the 1.1km portion in Measham village is not mitigation, but a base requirement (see benefits discussed in Volume 2 response); s) Consideration of a cut and cover tunnel over the railway on the Willesley Wood section to restore woodland and provide wildlife habitats; t) At Packington, to consider the suitability of a cut and cover tunnel over the Packington cutting, the height and design of the Gilwiskaw Brook viaduct and the temporary closure of the Ashby Road. It is concerning that roads in Packington are indicated for use by construction traffic. u) Notwithstanding the above, the constructional impacts on the health, safety and wellbeing of Packington residents; reconsideration as to the “in principle” 3 For the purposes of this response, the Council consider a short-term closure to be no more than 48 hours, to enable, for example, temporary diversions to be put in place; a long-term closure to be no more than 14 days, to allow, for example, statutory undertaker’s work, or to allow a bridge deck to be lifted into place. 4 | Page approach to building of the proposed scheme in this area, avoiding the unacceptable use for construction purposes of village and local roads; v) The need for early input from the Council and North West Leicestershire District Council on the design, placement and any future site use for the potential Ashby railhead, including the potential impacts (and possible future benefits) on the existing Leicester to Burton freight line; w) Lack of consideration/assessment of the proposed scheme’s impacts on the futureproofing of junctions on the Strategic Road Network, including J11, J12, J13 and J14 of the M42 and M1 Junction 24 (see also Cross-border issues); (the Council will expect this to be covered by the requested Interim Transport Assessment); x) Placement of the line on embankment alongside Westmeadow Brook; y) Consideration of flooding issues in Breedon, and Long Whatton and Diseworth; z) For Kegworth, the need for creative solutions to remedy the loss of much- needed sports pitches, preserve cycleways, rework the balancing pond to enable an access road for the Refresco factory, avoid the closure of the A6 Kegworth Bypass and move the AFTS structure at J24 of the M1; aa) In addition to the Design Panel set up for Measham, the Council request a Design Panel for the length of the Trent Valley Viaduct, which will be a very significant feature of the landscape. Cross-border matters: bb) In North Warwickshire, the onward impacts of the modification works at J10 of the M42 (see response to WDES by Warwickshire County Council); cc) In Nottinghamshire, the design of the Trent Valley Viaduct and the placement of construction compounds for these works and the impacts of those and the completed