Branch response to the HS2 consultation July 2011

High Speed Rail: Investing in Britain's Future – Consultation

The following  is the response submitted to the formal consultation on behalf of the Branch on 27 July 2011.

Question 1. Do you agree that there is a strong case for enhancing the capacity and performance of Britain’s inter-city rail network to support economic growth over the coming decades?

NO. The business case is not as strong as the DfT claim. ·         Plans, already in place, will provide more seats to address current overcrowding and changes in technology may cause business travel to fall. We are not convinced demand will grow as the DfT predict.    ·         Improving inter-city capacity and performance cannot be assumed to deliver economic growth. ·         The DfT say HS2 will reduce the North/South divide. But every speed increase in the past half-century, from 100mph trains in the late Sixties through to 125mph a few years later and then 140mph, has been accompanied by a southward drift in economic activity and prospects. The regions will do a lot better with more reliable ordinary trains interconnecting with other regional cites as well as London. The Eddington report  shows that vanity projects can become politically unstoppable, even though all there is substantial evidence shows that targeted and progressive enhancement of the current network is the best option.

Question 2. Do you agree that a national high speed rail network from London to Birmingham, Leeds and Manchester (the Y network) would provide the best value for money solution (best balance of costs and benefits) for enhancing rail capacity and performance?

NO. We have studied the evidence and are not convinced of the HS2 case: §         Many experts argue that the benefits of the HS2 Y Network have been grossly overstated. This includes over-ambitious passenger forecasts, and unrealistic benefits from assuming that travel time is wasted time. §         Evidence submitted to the Transport Select Committee, 21 June 2011, indicates that it is capacity and reliability, but not speed, which are the primary needs of the railway network. Witnesses indicated the specification for a ultra high speed (250mph) railway as opposed to say a 180mph service has disproportionately increased the costs and eliminated from the analysis unnecessarily some more cost effective alternative routes such as  Rail Package 2 or  the ‘spine and spur’ High Speed North proposal submitted by Interlinking Transit Solutions Ltd. §         Witnesses at the select committee criticised the proposed HS2 strategy as not being part of a wider transport strategy or even just a strategic rail plan. If any benefit from HS2 is to be achieved it will be from releasing capacity on the ‘classic’ network to improve local services to intermediate cities. However the HS2 overall costing assumes a saving in the costs of running and maintaining the classic network which means the benefits of extra capacity will not actually be realised. §         Evidence submitted by Malcolm Griffiths, Bluespace Thinking Ltd,  indicates that based on the work carried out by Atkins for the DfT it is possible to develop a more optimal "Alternative scheme" that would meet the predicted demand at lower load factors than the HS2 Y scheme. §         It is not possible to assess the ‘best value for money’ of the proposal without fully understanding the environmental impacts. There has not been enough investigation of the real environmental costs, and specifically of impacts on the natural environment. §         We would also refer you to the evidence submitted by  Dr Sandra Tuppen (HSR 182)

Question 3. Do you agree with the Government’s proposals for the phased roll-out of a national high speed rail network, and for links to Heathrow Airport and the High Speed 1 line to the Channel Tunnel?

NO. The route through West London is dictated by the presence of Heathrow, but the London Underground and Heathrow Express already provide excellent services between Central London and Heathrow. This will be futher enhanced by Crossrail and (potentially) Airtrack. So more links to Heathrow Airport cannot be justified, therefore there is no reason to choose a route heading 10 miles west before heading north. There may be some justification to connect to High Speed 1 and onto Europe. On that basis, there seems no logic in choosing a route that does not enter London from the north and connect directly into London St. Pancras. HS2 Ltd should consider the proposal made by Ken Livingstone for HS2 to follow the existing track into Euston before going underground and coming up at Waterloo. This would allow trains from all over Southern England to pass through central London directly on to Birmingham and Manchester whilst massively increasing the capacity of both stations.  The problem of the existing plans to have HS2 loop into West London to pick up passengers from Heathrow airport (which has galvanised such local opposition) is then resolved by having an inter-change between Crossrail One at Tottenham Court Road with the trains running between Euston and Waterloo. As Crossrail One allows passengers to get from Heathrow to Tottenham Court Road in under half an hour there seems no point in building a loop which may be more expensive than a tunnel from Euston to Waterloo. The High Speed North proposal offers delivery of more and more widespread benefits more quickly and cheaper.

Question 4. Do you agree with the principles and specification used by HS2 Ltd to underpin its proposals for new high speed rail lines and the route selection process HS2 Ltd undertook?

NO. Other investment possibilities, such as Rail Package Two, and appear to have been dismissed too quickly without fair comparison with the proposed Y Network. A route that heads 10 miles west out of London before turning north is illogical when speed and straight line design are routinely claimed to be the basic principles of high-speed rail. Consulting on one route is undemocratic and unfair, and improving rail infrastructure should be part of a broader national transport policy. The route has been chosen with no consideration of the full impact on local communities. Other routes and options (such as tunnels) have been considered and ruled out behind closed doors without public scrutiny. HS2 Ltd state they are in favour of creating sustainable communities – but in fact the chosen route will degenerate urban communities like Ruislip, Ickenham, Harefield and many other areas along the route which are very too close to homes and gardens, and schools.

Question 5. Do you agree that the Government’s proposed route, including the approach proposed for mitigating its impacts, is the best option for a new high speed rail line between London and the West Midlands?

No. The chosen route is the wrong route and the approach for mitigating impacts is not the best option, because: To quote The London Mayor,  Boris Johnson “"It is perverse that a section of the route through Greater London, clearly affecting large numbers of people, has been subject to so little environmental mitigation”. The Mayor has said that HS2 will lead a doubling of the current number of passengers arriving at Euston station every morning and that the Underground will not be able to cope". The best mitigation option for Ruislip and Ickenham on the proposed route would be a tunnel (subject to assessments of vibration effects on nearby homes). This option was considered in November 2010, with officials stating it offered major mitigation opportunities. However this option was ruled out and did not appear in the current consultation documents. Therefore the best mitigation option has clearly been ignored. For the proposed surface route, the approach for mitigating impacts is flawed, as train noise at speeds of 250- 300kmh have been downplayed whilst the mitigating effects of noise barriers have been exaggerated A shorter, more direct alternative route with less focus on an ultra high speed service would improve the energy efficiency of the locomotives and reduce the overall negative CO2 impact of the construction and service running costs With evidence that HS2 Ltd have chosen to ignore significant mitigation opportunities; and have underestimated impacts, it is likely that compensation, environmental costs, or alternative mitigation costs, are also underestimated at this point.

Question 6. Do you wish to comment on the Appraisal of Sustainability of the Government’s proposed route between London and the West Midlands that has been published to inform this consultation?

YES. The Appraisal of Sustainability is poor The generalised approach for mitigating impacts is flawed, as train noise at speeds of 250- 300kmh have been downplayed whilst the mitigating effects of noise barriers have been exaggerated. In particular the impacts of noise levels on residential areas and schools and the assessment of mitigation the measures are inadequate. Use of average noise levels does not give a realistic impact of noise indication as the trains are actually passing. The Appraisal of Sustainability does not take account of most of the impacts on the risks of flooding from water running off embankments and cuttings in residential areas along the route, some already identified at risk of flooding. The Appraisal of Sustainability does not take account of most of the impacts on wildlife along the route. The plight of many important local wildlife sites is completely ignored. The impact of a barrier to the movement of animals has not been assessed. The risks of flooding from water running off embankments and cuttings into wildlife sites, and the impacts of noise on wildlife were not included either. A full Strategic Environmental Assessment should be completed for the entire route and made public, looking at the impacts of reasonable alternatives, including other routes, before any further decisions are taken on this project.

Question 7. Do you agree with the options set out to assist those whose properties lose a significant amount of value as a result of any new high speed line?

NO. Once a preferred route is announced there is a real risk that communities along the route will degenerate rapidly during the planning and construction phases. The Government must ensure confidence is maintained in these neighbourhoods by urgently introducing compensation schemes immediately after the announcement which will entice existing residents to remain and new long term residents to move in. The compensation options proposed are very limited, do not go far enough and require further thought. The consultation presents the compensation schemes as options, which implies that a “one size fits all” option exists whereas different circumstances may require different methods of compensation if an unfair and disproportionate cost is not to be borne by those residents unfortunate to be living along the route. We suggest that there should be menu of compensation options available to each household. Further work is needed to design fair and transparent systems of assessing eligibility and property values. Compensation for long term (e.g.secure tenants) should also be available. We welcome in principle the property bond scheme which we believe will go some way underwriting local communities without necessarily resorting to public funding. However even with this form of support in place it is impossible to imagine that the local housing market will not be depressed compared to other localities.  The long period before compensation may be realised (at least 15 years) seems fundamentally unfair. For many people compensation will not be available during their lifetimes but they will suffer much of the inconvenience. This requires more thought. In addition to individual compensation there should be ‘community’ compensation which provide incentives (e.g. flood protection investment, open space management, public transport improvements, subsidised community facilities) which will  help sustain communities during the planning and construction.. .