HS2: Phase 1 Environmental Statement Consultation 27 February 2014 Submission by HS2 Action Alliance Contents Page 1. Introduction 4 2. Overview 5 3. Making Things Better 9 4. Public Participation 11 5. Hybrid Bill Process 16 6. Strategic Alternatives and Options 33 7. Volume 3 Route Wide Effects 52 7.1 Agriculture, Forestry & Soils 52 7.2 Air Quality 53 7.3 Climate 55 7.4 Community 65 7.5 Cultural Heritage 66 7.6 Ecology 67 7.7 Land Quality 72 7.8 Landscape 73 7.9 Socio economics 80 7.10 Sound, Noise & Vibration 81 7.11 Traffic & Transport 93 7.12 Waste 93 7.13 Water Resources 99 7.14 Electromagnetic Interference 100 8. Health 101 9. Code of Construction Practice 106 10. Conclusion 108 11. Appendixes 109 Appendix 1: Errors in ES Appendix 2: Carbon Study-SLR Consulting Appendix 3: Waste Study-SLR Consulting February 2014 2 www.hs2actionalliance.org Appendix 4: Landscape Assessment- Waterman Associates Appendix 5: Biodiversity - Treweek Consulting Appendix 6: HS2 October 2013 Strategic Case Appendix 7: Noise-Further Information February 2014 3 www.hs2actionalliance.org 1. Introduction 1.1 HS2 Action Alliance (HS2AA) is a not for profit organisation that oppose the proposals known as High Speed 2 (HS2) on economic, transport and environmental grounds. Established in 2010, HS2AA has made the case against HS2 in the courts, Parliament and the media. HS2AA is a voluntary organisation, with directors who serve without remuneration and work closely with a range of other groups, including environmental organisations, in connection with our work, making the case in communities against the scheme and pushing for appropriate mitigation. Over 100 organisations have become affiliates of HS2AA. Thousands of people from across the country who share our goals have also signed up as registered supporters of HS2AA. 1.2 HS2 has been promoted from the outset as a project with strong environmental credentials. The Environmental Statement provides official confirmation, over 50,000 pages, of just how inaccurate such claims are. The plans for Phase 1 of HS2 mean the destruction of 32 hectares of ancient woodland from 19 different sites, 4,800 hectares of farmland and 250 hectares of forest. 330 hectares of the land to be lost are deemed important habitats for wildlife, including 195 hectares of lowland woods and 60 hectares of lowland meadows. More broadly, highly negative impacts will be felt in urban, suburban and rural communities across the country. Phase 1 of HS2 is, in every sense, a highly damaging project for our environment. 1.3 It is to be regretted that having committed to such destructive proposals, HS2 Ltd appear determined to avoid meaningful engagement with those communities which would be most affected should these plans proceed. Suggestions made in the Community Forums across the route have been ignored. Requests from local authorities, environmental organisations and community representatives for discussion and engagement have not resulted in meaningful dialogue. Proposals made in the consultation on the Draft Environmental Statement have not made their way into the Environmental Statement. 1.4 Running alongside this reluctance to make decisions in line with accepted public participation norms is an Environmental Statement for Phase 1 of HS2 that is substandard and riddled with errors of fact. Even matters brought to HS2 Ltd’s attention prior to the publication of the Environmental Statement appear not to have been corrected. Given the scope and potential environmental damage arising from Phase 1 of HS2, this cannot be right. 1.5 We believe that HS2 Ltd must respond to the points raised in this submission and that there should not be a Second Reading of the Hybrid Bill for Phase 1 of HS2 until a new Environmental Statement is produced which complies with the relevant legislative requirements. 1.6 This document sets out what HS2AA believes are just some of the material failures with the Environmental Statement, the process by which development consent will be obtained by HS2 Ltd and the standards which HS2 Ltd should seek to meet should construction start. Given the importance of the matters covered by the Environmental Statement, HS2AA have sought objective expert advice on some of the most important themes covered in the Environmental Statement. Reports from SLR Consulting on waste and carbon, Waterman Group on landscape and Treweek Environmental Consultants on biodiversity are attached as appendices to this response. They provide an independent assessment on some of the key topics covered by the Environmental Statement and highlight just how much work is to be done if the environmental impacts of HS2 are to be properly mitigated. 1.7 Lastly, we would extend our sincere thanks to our affiliates and supporters who helped put this response together. February 2014 4 www.hs2actionalliance.org 2. Overview 2.1 A train making a journey at HS2’s initial design speed of 360km/hr uses three times as much energy as a train travelling at the current intercity top speed of 200km/hr1. Environmental impacts such as noise, visual amenity and land take also increase disproportionately with speed. This, in simple terms, is the reason why HS2AA believes the environmental costs set out in the Phase 1 Environmental Statement (ES) of HS2 are unacceptably high. 2.2 HS2 is uniquely damaging to the natural environment. It passes through the Chilterns Area of Outstanding Natural Beauty, the “Meridien Gap” of greenbelt separating Coventry and Birmingham, as well as tranquil rural and suburban areas, cutting a swathe through previously unspoilt countryside. Its negative effects are equally pronounced in urban communities too. These high levels of damage are an inevitable consequence of the demand for HS2 to run at the highest possible speed, meaning a route so straight as to be incapable of following existing transport corridors. 2.3 The justification for this destruction and energy profligacy is the value of speed to business. HS2AA believe it is important to note the close relationship between the flawed methodology used by the Department for Transport in successive business cases for HS2 and the high levels of environmental damage detailed in the ES. HS2’s business case remains critically dependent on discredited values of time for business passengers. However the case that the on-board journey time savings are worth, in economic terms, what the Government claim, simply isn’t backed up by the evidence. It is plain that shortening on-board journey times does not yield an equivalent increase in productive time. 2.4 Given the requirements of the Climate Change Act, HS2AA believes investment in trophy infrastructure should be consistent with the country’s decarbonisation agenda. However HS2 Ltd’s latest forecasts, issued in October 2013, conclude 95% of its passengers would move from less polluting modes of travel or wouldn’t otherwise travel at all2. Just 1% of HS2’s passengers are forecast to transfer from air (previously 3%), and 4% from road (previously 8%). 69% of the passengers using HS2 will transfer from classic rail and 26% are entirely new journeys (previously 24%). These figures are for the full Y network, figures are not given for Phase 1, but it is likely that the numbers would be even lower. HS2 therefore cannot, in any sense, be described as contributing to the wider carbon reduction and sustainability agenda. 2.5 The ES and associated consultation reflect the requirement that the HS2 project must comply with the Environmental Impact Assessment Directive. This European legislation requires that an environmental statement should include information to enable the assessment of environmental effects of any development, including an assessment of alternatives. An objective review of the ES indicates that neither the likely significant effects on the environment, the alternatives or the proposed mitigation measures have been adequately described. In many instances, no mitigation is offered or what little mitigation is referenced to the draft Code of Construction Practice, with no assurances that this will actually be secured. 1 Transport Policy Statement 09/03, High Speed Rail Table 1, Institute of Mechanical Engineers 2 Table 12 page 83, ‘Economic Case for HS2’ October 2013 February 2014 5 www.hs2actionalliance.org 2.6 The principles that led the design of HS1 ensured the new route followed existing routes where possible, thereby minimising the environmental harm. HS2 adopts that principle for only the first 15 miles. The route emerges above ground in West Ruislip and then travels on a new line that does not follow an existing route all the way to the West Midlands. This causes a significant level of destruction to well established and highly diverse habitats. Beyond the route, the level of construction disruption and the placement of excavated material will give rise to the loss of further highly important ecological features. This has not been clearly shown in the ES, where the focus in the consultation documentation is on “selling” the case for HS2 rather than dispassionately reviewing and assessing environmental impacts and does not comply with relevant legal requirements. 2.7 HS2AA believe effective public participation has been stymied given the confusing drafting and structure of the ES. It is very difficult for a reader of the ES documents to develop a clear understanding of what is being lost and where. Instead consultees are expected to piece together the various maps, cross reference these with the descriptive text and then determine for themselves what is expected to be lost. 2.8 To provide a complete list of our concerns with the ES is beyond the resources or expertise of a voluntary organisation like HS2AA. But we have identified the following concerns with the ES: The ES has a significant number of errors and inconsistencies.