Written Evidence Submitted by Cambridge Approaches (MTP0039)

Written evidence submitted by Cambridge Approaches (MTP0039)

Introduction

1. This submission is made by Cambridge Approaches1 (“CA”) in relation to the Bedford to Cambridge section of the East West Railway (“EWR”). CA is a recently formed campaign group which is liaising with affected parish councils and other stakeholders in south western Cambridgeshire. It is now working with CamBedRailRoad2 (“CBRR”), a community-based, voluntary think-tank, which proposed an alternative route for the relevant section of EWR into the north of Cambridge in 2018. CBRR’s northern approach envisages new stations north of Cambourne and in Northstowe3.

2. To date, East West Railway Company (“EWR Co”) has not consulted on a northern route into Cambridge, only on five broad corridors into a proposed new Cambridge South station (a separate and independent Network Rail project4). CA is campaigning for a northern approach to be consulted on fully at the same time as EWR Co consults on alignment options in its chosen corridor5. Local MP, Anthony Browne, supports this call for a fair consultation and CBRR’s petition to this effect has attracted more than 5,470 signatures.

3. We are asking the Transport Select Committee to review EWR Co’s consultation practices, to review the Bedford to Cambridge section of the project generally and, in particular, against the strategic issues raised in 5 below and to ask EWR Co to delay its forthcoming consultation on route alignment options (within its chosen route Option E) so that it can include a northern approach to Cambridge in this consultation on a comparable basis.

4. This paper is intended to address issues arising under the “transport infrastructure strategy and priorities”, “appraisal and funding” and oversight, accountability and governance” headings in the Committee’s call for evidence. References in this paper to appendices are to its appendices, unless otherwise indicated.

Strategic issues

5. EWR is far more than a passenger transport project providing benefits to transport users. It is intended to:

(a) Support the delivery of new, affordable housing

1 https://cambridgeapproaches.org 2 http://www.cambedrailroad.org The organisation is led by two distinguished transport infrastructure civil engineers, with extensive experience in the UK and the Far East and chaired by Cambridgeshire County Councillor, Sebastian Kindersley 3 CBRR’s proposal is set out in more detail on this link - http://www.cambedrailroad.org/fluidcms/files/files/CamBedRailRoad-Proposal.pdf 4https://www.networkrail.co.uk/running-the-railway/our-routes/anglia/cambridge-south-station/ 5 EWR Co’s 2019 consultation document and accompanying technical report can be found on this page - https://eastwestrail.co.uk/haveyoursay/2019-bedford-cambridge-consultation. Its preferred option report and public feedback report can be found on this webpage - https://eastwestrail.co.uk/the-project/central-section “Partnering for prosperity: A new deal for the Cambridge-Milton Keynes – Oxford Arc”6 , a National Infrastructure Commission (“NIC”) report, identified the critical need for new housing in the Oxford-Cambridge Arc, given powerful evidence that house prices (especially in Oxford and Cambridge themselves) were hampering recruitment and so impacting on businesses’ competitiveness (see especially pages 3, 7 and 8). The Oxford Cambridge Arc Economic Prospectus (“the Economic Prospectus”)7, published in October 2020 by local enterprise partnerships, universities and local government leaders across the arc reiterates this need.

(b) Provide transport infrastructure coherence

The NIC’s report (pages 9 and 32) also noted the opportunity to run EWR contiguous with the Oxford-Cambridge Expressway (most relevantly the proposed dual carriageway upgrade of the A428 between the Black Cat roundabout and Caxton Gibbet) to create a multi-modal transport spine.

The Economic Prospectus shows how important it is for EWR to co-ordinate properly with more local transport proposals (page 14).

Both the NIC’s report and the Economic Report provide further detail on this, which is intimately linked with (a).

(d) Provide a new route for freight from Felixstowe and the other Haven ports

Both Network Rail and East West Rail Consortium, envisages EWR having an important role for freight and, in particular, routing it away from London8. This raises a second point; Cambridge is at the edge of EWR Co’s responsibility; EWR Co has little incentive to consider which approach route into Cambridge makes best strategic sense for EWR beyond Cambridge.

(e) Minimise environmental impacts

It is hard to see how the current proposal for a non-electrified line running diesel trains passes the first hurdle on this test (see, for example, paragraph 3.6 of the Treasury’s “Green Book Review 2020: Findings and response” (CP331)9). A recent

6 https://nic.org.uk/app/uploads/Partnering-for-Prosperty.pdf 7https://cambridgeshirepeterborough-ca.gov.uk/assets/Uploads/Oxford-CambridgeArcProspectus- Approved2.pdf 8 Network Rail Routeing of rail freight forecasts A study for Network Rail by MDS Transmodal August 2020 (pages 15 and 16) https://www.networkrail.co.uk/wp-content/uploads/2020/08/Routeing-of-rail- freight-forecasts.pdf, East West Rail Consortium January 2019 eastern section prospectus for growth https://www.eastwestrail.org.uk/wp-content/uploads/2019/02/29-Jan-2019-East-West-Rail-Eastern-Section- Rail-Prospectus-3.pdf and East West Rail Consortium January 2020 draft Invitation to Bid for Preliminary Strategic Outline Business Case for the Eastern Section of the East West Rail Link - https://www.eastwestrail.org.uk/wp-content/uploads/2020/01/East-West-Rail-Consortium-Strategic-Board- 300120-Agenda-Item-5-Eastern-Section-Annex-1.pdf 9 https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/937700/Green _Book_Review_final_report_241120v2.pdf NIC report “Rail needs assessment for the Midlands and the North”, indicates a need to “ensure the plan contributes to net zero” (page 65) and to “ensure the plan contributes to environmental net gain” (page 67).

6. The project must also be cost effective. In addition, it is widely expected that transport needs will change following the pandemic, and Government priorities have evolved as a result of the pandemic, for example, as regards levelling-up. A delay to review whether passenger forecasts and modelling used for the purposes of the project so far remain appropriate and whether EWR Co’s proposals and assessment to date “engage properly with the strategic context in which [the project] sits” (paragraph 1.10 of CP331) would seem to be in order.

Submission Points

EWR Co has not consulted effectively with the most affected local communities.

7. The problems for major infrastructure projects caused by failure to engage with affected communities are well-recognised. The NIC publication “Rail Needs Assessment for the Midlands and the North - Final report”10 notes at page 64 “in the past, long term plans have sometimes been subject to delay due to disagreement and appeals. To ensure the Plan endures the government should build consensus with local stakeholders.”

8. EWR Co’s 2019 consultation document says (at page 20) “all of the route options shortlisted for consultation approach Cambridge from the south by connecting to the West Anglia Main Line either at or slightly to the north of Shepreth Junction (where the Hitchin- Cambridge and West Anglia lines meet) or to the south of Great Shelford”. The route options are shown in Appendix 1.

9. EWR Co’s public feedback report sets out a list of the consultees to which it sent letters about the consultation11. A copy of that letter is included in Appendix 2.

10. Appendix 3 is a postcard that was sent out to (it is understood) 120,000 residents (out of an estimated 1.85 million living in the consolidated area covered by the five option corridors) to alert them to the consultation. Without more explanation this postcard would not have alerted anyone in the area centred on Great Shelford to the potential impact of every one of the options being considered on their respective villages. The combination of extremely wide corridor, plus the places in which public consultations were held, provides no clue to the central importance of Great Shelford and the immediately surrounding area to the project. It might well also have misled recipients into thinking that EWR Co was consulting on both northern and southern approaches to Cambridge.

11. Appendix 4 shows a diagram which is based on the responses from parish councils consolidated in Appendix 10 to EWR Co’s public feedback report. It is understood that at least some of the parish councils, critically Great Shelford, have no record of receiving EWR Co’s consultation letter and, in consequence, did not become aware of the consultation until after it had closed.

10https://nic.org.uk/app/uploads/RNA-Final-Report-15122020.pdf#Final%20report 11 In its Appendix 2a 12. South Cambridgeshire District Council (“SCDC”) did respond to the consultation, but it was careful to say “the consultation does not make clear how the East West rail line would join the West Anglia Main Line south of Cambridge, and it is therefore difficult to comment on the implications of this for communities and the environment”.

13. Despite this, EWR Co has not contacted the parish councils of any of the most immediately affected parishes, including Great Shelford, to seek to understand any concerns they may have. Recently Great Shelford Parish Council has asked EWR Co to meet with it. The parish council has just received a response, after some delay, and EWR Co have indicated that they are only prepared to meet the parish council and not with villagers as well.

14. At least one parish council (Sawston) was not included and should have been because any route to join the West Anglia Main Line south of Great Shelford will inevitably cross land in the parish of Sawston.

Lack of clarity in the consultation

15. The 2019 consultation involved essentially three important and easy-to-express questions:

(i) should EWR go to Bedford Midland or Wixams? (ii) should EWR go to Bassingbourn or Cambourne? (iii) should EWR approach Cambridge from the north or the south?

These questions were not clearly articulated and were conflated through the use of route corridors and the failure to include a northern approach to Cambridge in any of the corridors.

16. It is true the that the consultation did ask “Do you agree that EWR Co are right to prioritise route options that approach Cambridge from the south rather than from the north?”. EWR Co’s feedback summary on this question was “people’s views were split evenly” (paragraph 1.5.3 of its public feedback report). Paragraph 7.12.3 of Appendix 1 discloses that, in fact, there was a small majority against the southern route with 37 per cent of people saying they strongly disagreed or disagreed and 35 per cent saying they strongly agreed or agreed.

17. Responses in favour of Options B and E, which involved Cambourne, appear to have been interpreted as a preference for a southern approach to Cambridge, even if no express preference was stated. This is despite the fact that the 2019 consultation document says (at page 20) “Of the five route options that are being taken forward for consultation, Routes B and E could alternatively approach Cambridge from the north if new information is provided that suggests this would be better than approaching Cambridge from the south”.

18. Appendix 5 sets out an analysis of parish council responses consolidated in Appendix 10 to EWR Co’s public feedback report and shows a clear majority in favour of a northern approach. This does not include the views from the parish councils of the most directly affected villages which did not respond to the consultation (see 11 above).

EWR Co’s treatment of a northern approach in its consultation 19. Appendix 6 includes a key section of EWR Co’s 2019 consultation document and a short supplementary extract from its preferred option report which together explain why it has not consulted on a northern approach. EWR Co’s treatment of a northern approach to date appears rather cursory and unconvincing. Appendix 7 includes a letter emailed to the CEO of EWR Co on 23 December 2020 which critiques its assessment and to which no reply has yet been received.

A comparison of northern and southern approaches on the basis of the strategic issues set out in §5

(a) Supporting the delivery of new, affordable housing

20. EWR Co is not proposing any stations between Cambourne and Cambridge South. The communities in south western Cambridgeshire are adequately served by existing stations at Foxton, Shepreth, Meldreth, Royston and Great Shelford or will be by the new Cambridge South station (accessed via Trumpington Park and Ride and the guided busway).

21. Option E envisages a station to the south of Cambourne. Appendix 8 includes a recent letter from Cambourne Town Council seeking parish council views on its proposal that the station should instead be sited north of the town. A northern location is also supported by members of SCDC and Anthony Browne MP for the reasons given in Appendix 8.

22. SCDC and Cambridge City Council made clear, in their responses to EWR Co’s 2019 consultation, that the then forthcoming call by Greater Cambridge Planning (“GC Planning”) for development sites was relevant to EWR Co’s route alignments and close liaison was needed. More than 650 sites have been submitted12. Of those offered, few are within the Option E area and none are significant, other than a controversial new town proposal which Anthony Browne MP has already publicly opposed and members of SCDC have formed an action group against. A far greater number of the sites submitted align with a station to the north of Cambourne and another in Northstowe, as envisaged by the CBRR proposals (see Appendix 9). This is in addition to a significant number of existing, and in progress, development proposals along that corridor, together with the new draft North East Cambridge Area Action Plan13 (arising from the relocation of the Cambridge Waste Water Treatment Plant) and the announced closure of Cambridge Airport (also in the north of the city) and plans to redevelop it14.

23. Housing to the north of Cambridge tends to be more affordable than housing to the south. This point is not limited to housing in and around Cambourne.

24. There is no public evidence of any iterative consultation between EWR Co and Greater Cambridge Planning (GC Planning) as EWR Co works to develop its route alignments and Greater Cambridge Planning assesses the 650 sites submitted. Perhaps EWR Co’s position on housing is better reflected in a conclusion drawn from a dinner attended by its chairman in 2017 - “it was also generally felt that the best value for money may be achieved by building the railway first and then financing (using private finance) later. This

12https://www.greatercambridgeplanning.org/emerging-plans-and-guidance/greater-cambridge-local-plan/ 13 https://consultations.greatercambridgeplanning.org/document/213 14https://www.fr24news.com/a/2020/10/cambridge-airport-marshalls-confirms-move-out-of-county-as-it-signs- 150-year-lease.html

would give the scheme time to bed down, to work out where any additional finance from land value uplifts would be coming from and remove some of the risks around construction (which can lead to more expensive financing)”15.

(b) Providing transport infrastructure coherence

25. CBRR’s northern route into Cambridge was designed to meet the NIC’s implicit recommendation of a multi-modal transport spine and to integrate with proposed local transport schemes.

26. The Option E proposals do not do so. As a result, EWR is not mentioned at all in Highways England’s 2020 consultation on the Black Cat to Caxton Gibbet upgrade. Highways England plans to submit its Development Consent Order application for the A428 Black Cat to Caxton Gibbet upgrade on 29 January 2021.

27. There are a large number of transport proposals under consideration at the moment - please see the diagram in Appendix 10. Almost none are without controversy - for example, the Cambridge to Cambourne busway is being reviewed by an independent expert, following a disagreement between the Mayor of Cambridgeshire and Peterborough Combined Authority (“CPCA”) and the Greater Cambridge Partnership (“GCP”). Further, there are at least two infrastructure proposals immediately local to Great Shelford (an alternative route supported by Great Shelford and Stapleford parish councils for the Cambridge South East Busway and a proposal, supported by Matt Hancock MP and implicitly by Anthony Browne MP, to reinstate the old railway from Great Shelford to Haverhill), which EWR Co is almost certainly unaware of, due to its failure to consult effectively at parish council level.

28. EWR Co will need to integrate with them. There is no published output of any collaboration with either CPCA or GCP. CBRR’s northern route has, by contrast, been designed to run in tandem with light rail alternatives and to complement the guided busway.

29. EWR Co’s approach to this seems to start, and stop, at Cambridge’s Biomedical Campus, which the new Cambridge South station is designed to serve. There is far more to Cambridge than this - science parks, tech employers and the university are found in locations all around the city, including in the north and west. EWR’s precise arrival point in Cambridge seems much less important than effective local transport links in and around the City and EWR’s effective integration with those links (see (b) above).

(d) Freight

30. EWR’s arrival point in Cambridge is of critical importance to travel beyond Cambridge and into East Anglia. An approach into Cambridge South would see freight trains travelling through the centre of Cambridge and then out to the east on the existing Newmarket line. This will inevitably involve freight travelling through populated areas (including at night) and around a challenging curve (no-one has identified a viable alternative freight route from Cambridge South).

15 https://www.shlegal.com/insights/rob-brighouse-dinner-east-west-railway-10-key-points 31. EWR Consortium has expressed concern about the lack of capacity of existing track, especially on the Cambridge to Newmarket section of the line16. If new track is likely required anyway, a northern approach into Cambridge would allow for a different routing away from populated areas of this section of the line for freight.

32. Even if the routing of the line remains where it is, a northern approach would minimise the populated areas of the City of Cambridge affected by night-time freight noise.

(e) Cost effectiveness

33. Estimated costs rose by 300% between the 2019 consultation and the preferred option report without adequate explanation and without triggering a major project review. EWR Co have so far not answered questions about this and hence cannot justify their choice of Option E on BCR grounds as compared with either Options A to D or the CBRR northern approach.

34. In its 2019 consultation document, EWR Co estimated the indicative upfront construction cost of Option E as £3.4 billion (2015 prices) 17. It was the most expensive of the five options considered. Footnote 29 of EWR Co’s preferred route option report said “the cost estimates presented in the consultation suggested that Route E would incur the highest upfront capital costs. However, the revised cost estimates that have informed the final decision on a preferred route suggest that Route E would incur the second lowest upfront capital costs.” Paragraph 14.12 says “Route E is estimated to incur upfront capital costs of £3.7 billion (2019 prices)”.

35. There is no detailed explanation of the significant changes between the 2019 consultation document and the preferred route option report. The revised cost estimate requires detailed explanation and justification. In addition, CA has carried out a general analysis of EWR Co’s cost estimates here and an analysis of its cost comparison with CBRR’s northern route here.

36. In comparison with European Commission costings18 (of €7.2 million per km non- high-speed dual track) the cost of the EWR Co proposals appears to be extremely high, with no clear justification. It cannot be cost-effective to build EWR and electrify it later (see 5(e) above)

37. We have been unable to find evidence of effective cost control at gate reviews.

38. There is a lack of effective competitive tender e.g., global suppliers including from Asia or even Europe.

(f) Strategic case

39. The project and both approaches should be subject to a “back to basics” review (see 6).

16 See documents linked at footnote 8. 17 The Technical Report accompanying the 2019 consultation document gives estimated upfront capital costs of £2.8 billion (2010 prices) 18 https://ec.europa.eu/regional_policy/sources/docgener/studies/pdf/assess_unit_cost_rail_en.pdf, figure 4.

Lack of effective oversight and governance.

40. The NIC report referred to in 5(a) made it clear that there should be ministerial oversight, including collaboration between Ministry of Housing Communities and Local Government and the Department for Transport. There are no visible signs of this happening, nor of the appointment of an independent business Chair for the Oxford-Cambridge-Milton Keynes Arc recommended in the same report. Many of the points made in this paper suggest that EWR would benefit from independent, holistic scrutiny of EWR Co’s planning, assessment, and management of the project.

January 2021 Appendix 1: the route options consulted on in 2019 (for a larger version of these maps see - https://eastwestrail.co.uk/haveyoursay/2019-bedford-cambridge-consultation). Appendix 2: Consultation letter and map sent to parish councils and others P1 - page 15 of this document Appendix-1.pdf (eastwestrail-production.s3.eu-west-2.amazonaws.com)

Appendix 2: Consultation letter and map sent to parish councils and others P2 - page 15 of this document Appendix-1.pdf (eastwestrail-production.s3.eu-west-2.amazonaws.com)

3. Appendix 3 - postcard sent to 120,000 people - page 31 of https://eastwestrail- production.s3.eu-west-2.amazonaws.com/public/Preferred-Route-Option- Announcement/Files/5261ff3319/Appendix-1.pdf Appendix 4: map of parish council responses Appendix 5: analysis of parish council responses Appendix 6: East West Rail Bedford to Cambridge - Preferred Route Option Report EWR-Consultation-Document.pdf (eastwestrail-production.s3.eu-west-2.amazonaws.com) P20 Route-Option-Report.pdf (eastwestrail-production.s3.eu-west-2.amazonaws.com) P108

Appendix 7: Letter to Simon Blanchflower P1 Appendix 7: Letter to Simon Blanchflower P2

Appendix 7: Letter to Simon Blanchflower P3 Appendix 7: Letter to Simon Blanchflower P4 Appendix 8 Cambourne town Council’s letter P1 Appendix 8 Cambourne town Council’s letter P2 Appendix 9 existing, approved, proposed and putative settlements. Appendix 10 Major local transport infrastructure projects- https://consultcambs.uk.engagementhq.com/cea-consultation- 2020/widgets/17230/photos/4158