High Speed 2 Working Draft Environmental Statement Consultation Response HS2 Phase 2B WDES Consultation Response Sheet i i | P a g e HS2 Phase 2B WDES Consultation Response Sheet ii Contents 1. Introduction ................................................................................................... 1 2. The Impact of the Proposed Scheme on Businesses .................................... 3 3. The Impacts of the Proposed Scheme on Residential Properties ................. 5 4. The Continuity of Highways Across the Proposed Route .............................. 6 5. The Impacts of the Proposed Scheme in the Clayton Area .......................... 7 6. Archaeology and Heritage Assets ................................................................. 9 7. Ecology and Biodiversity ............................................................................. 10 8. Landscape and Visual Impacts ................................................................... 12 9. Construction Traffic Routes ......................................................................... 13 10. Improvement of the A635 Corridor .............................................................. 14 Annex 1: Composite Issues Log ....................................................................... 15 Annex 2: Report of the Director of Public Health ii | P a g e HS2 Phase 2B WDES Consultation Response Sheet iii iii | P a g e HS2 Phase 2B WDES Consultation Response Sheet 1 HS2 WDES Consultation Response 1. Introduction Doncaster Council’s opposition to the Government’s Preferred Route for HS2 has already been well documented through its response to the Government’s consultation on the route in 2017. The Council’s position has not changed. However, the Council wants to work with the Government and HS2 Limited in whatever ways it can to secure the best outcomes for the Council, its residents and businesses, and also the wider region. To that end, the Council welcomes the opportunity to comment on the HS2 Working Draft Environmental Statement presented. Our response to the HS2 Consultation identifies the Council’s concerns with HS2 Limited’s design of the route through the Borough, its presentation of the impacts associated with the route and its suggested mitigation of those impacts. The Council’s response to the three consultation questions posed (see below) are all incorporated within this document. 1. What comments do you have on the information presented in the working draft Environmental Statement? 2. Do you have any suggestions about additional information or assessments that should be included in the Environmental Statement? 3. Do you have any other comments? Whilst the Council has done its best to respond to the Working Draft Environmental Statement [WDES] Consultation within the limited time available, this response should in no way be seen as either comprehensive, or as a final statement of the Council’s position. The Council welcomes continual meaningful engagement on the proposals over the coming months as the proposal develops to ensure that the impact of the proposal on people, places and valuable assets in Doncaster is minimised, and that opportunities are taken to enhance provision wherever possible. Having said this, the impact of the proposed Scheme in Doncaster is severe and for that impact and pain, Doncaster receives no benefit at all. The Council deplores the attempts in the WDES to underplay that impact; to be less than honest about the impacts to residents and businesses; and to economise on mitigation, for example with the closure of Red Hill Lane. 1 | P a g e HS2 Phase 2B WDES Consultation Response Sheet 2 The Council’s response identifies a series of headline issues in the main body of the report, but more detailed feedback, identifying a plethora of specific issues, is included in the Annexes. In light of the ever growing volume of information casting doubt on the HS2 project as a whole, the Council urges HS2 Limited and the Government to carry out an honest reappraisal of the scheme, and especially for the Eastern Leg of HS2 Phase 2B. This information includes: . Spiralling costs o National Audit Office report in 2016 about Phase1 being £204m over budget; o Infrastructure and Projects Authority widely publicised ‘secret’ report that costs may have increased by as much as 60%; o Alleged £2b cost overrun on property acquisition costs; o Incorrect assumptions in the modelling for HS2 Phase 2B where 8 train paths per hour are assumed between York and Newcastle, where there in fact are only 6 available unless £millions are spent on increasing rail capacity north of Northallerton. This cost is not included in HS2’s cost envelope, and yet HS2 is effectively claiming the benefit; o The estimated £825m cost of making Sheffield Midland and Chesterfield Stations HS2 ready – none of this money is included in HS2’s cost envelope. Increasing impacts on residential property with 137 reported demolitions in the WDES where only 35 demolitions were reported at Route Consultation Stage . Increasing impacts on employment with 170 job losses now estimated just on the Ravenfield to Clayton (LA13) section alone. Any one of these factors would trigger a review in the business case development of a major scheme because they would affect the scheme’s overall Benefit Cost Ratio. However, this process seems not to apply in the case of HS2. An urgent review is required to restore public confidence that the Proposed Scheme offers UK plc value for money. 2 | P a g e HS2 Phase 2B WDES Consultation Response Sheet 3 2. The Impact of the Route on Businesses The Council notes that in total for the section of the Proposed Scheme between Ravenfield and Clayton, there is an impact on an estimated 170 jobs (Para 12.4.15), either displaced or lost. The Council considers that these jobs are lost, being no clear rationale expressed in the WDES of how these jobs will be displaced citing only possible employment opportunities in the construction of the scheme. This assumes a skills match which may or may not be possible. 170 job losses in Doncaster is unacceptable, given that 8 of the 10 Business Units identified as being affected by the Proposed Scheme are located in areas of high deprivation. The WDES seriously underplays the impacts of the Proposed Scheme on businesses. Whilst the Council understands that Environmental Impact Assessments are carried out to a defined methodology to ensure comparability, it appears that HS2 Limited has used the methodology to mask some of the real impacts of the route on businesses within the Borough. Not only this, but the text does not follow its own rationale, is inconsistent, and gives a wholly misleading view. Figure 1: Impacts on Denaby Industrial Estate As an example, using the maps provided in Volume 2, the impact of the route on Denaby Industrial Estate in the permanent situation appears to affect just one ‘Business Unit’ (HS2 Limited terminology). In the temporary situation (ie during construction), the HS2 satellite compound located on the Estate requires the demolition of five ‘Business Units’. 3 | P a g e HS2 Phase 2B WDES Consultation Response Sheet 4 In the permanent situation, the Proposed Scheme actually directly affects two business premises on the Binder Industrial Estate, although this could be mitigated by the construction of retaining walls. In the temporary situation, there are not only 11 business premises affected in the Binder Industrial Estate, but also a multiple occupancy office/warehousing block (Denaby Point), United Carpets and a further premise between Denaby Point and Binder Industrial Estate (see Figure 1 above), giving a total of a minimum of 18 business premises. The WDES text states that there are “six units” affected on Denaby Industrial Estate (Para 12.4.9 and Table 31), and yet describes “Four businesses” experiencing direct impacts as a result of the Proposed Scheme (Para 12.4.14). This is clearly wrong, whether in the number of units affected, or in the number of businesses impacted, but it also underplays the real impact of the route which is that 5 business units are being demolished equating to a minimum of 18 business premises being directly affected. The associated loss of jobs is wholly unacceptable. The Council calls on HS2 Limited to locate its Satellite Construction Compound/Systems Compound elsewhere. There are similar issues relating to the Doncaster Road area where for example no temporary effects are described for businesses within The Croft eg Cock of the North Poultry, whose access off Pastures Court is wholly contained with the Consolidated Construction Boundary [CCB]. Barnburgh Lakes Fishery is identified as a business that would experience direct impacts as a result of the Proposed Route, being one of the four ‘resources’. However, such is the confusing terminology and inconsistency about what terminology is used in the WDES and where, Barnburgh Lakes Fishery is not listed in Table 31 as a resource “which would potentially experience significant direct effects”. It clearly will experience “significant direct effects”, as the business, which includes both the lakes and the café/shop will no longer be able to operate. Not taking account of the lakes element of the business as being an ‘agricultural route-wide effect’ is a nonsense. The business is the lakes, the café and the shop together, and the devastating effect on the entirety of this business needs to be at least acknowledged in the WDES. This underplaying of impacts similarly applies to the two identified businesses on