Written evidence submitted by Vincent Nolan
Personal
I am making this submission because the road I live in will be crossed by HS2 at ground level or above, at a distance of about 400 metres from my home, across open fields, resulting in major noise and visual impacts. HS2 trains will be running at the frequency of one every two minutes at speeds of 200 mph. There will be no significant mitigation of airborne noise from the overhead lines and pantographs, which at this speed are expected to be the most significant source of noise.
Summary
Assuming that the purpose of the Environmental Statement (ES) accompanying the HS2 Hybrid Bill is to enable MPs to make informed and knowledgeable decisions about the Environmental Impact of HS2, I believe that the ES is unfit for purpose and is misleading, contradictory and inaccurate, for the following reasons:
1. The NTS, section 2.4 Controlling Greenhouse Emissions states “high-speed rail is one of the most carbon-efficient means of transporting large numbers of people”. This is not true of HS2. 95% of HS2 passengers move from less polluting conventional rail or did not otherwise travel. Just 1% of HS2 passengers are taken to transfer from air and 4% from road 69% transfer from classic rail and 26% are entirely new journeys.
1.1 Speed is not green. A train making a journey at HS2’s initial design speed of 360km/hr uses three times as much energy as one travelling at the current intercity top speed of 200km/hr. Its environmental impacts such as noise also increase disproportionately with speed. HS2 will increase carbon emissions in operation and there will be substantial carbon emissions arising from the construction and maintenance of the line.
1.2 Despite assurances in the AoS (published to support the 2011 consultation) that a greenhouse gas assessment of the project would be completed, HS2 Ltd have failed to provide even an initial appraisal of climate aspects. HS2 will result in a net contribution in greenhouse gasses and is therefore incompatible with the Climate Change Act 2008.
2.0 NTS Section 6.4 Alternative Train Speeds “Whilst lower operating speeds would allow greater flexibility in the alignment of the route to avoid environmentally sensitive areas, operating at a maximum speed of 300 kph…would increase journey times….and reduce the economic benefits” This is only significant if you make the absurd assumption that time spent on trains is wasted. We are now being told, by the Transport Secretary, that savings of 20 minutes in journey times between London and Birmingham are not significant. An operating speed maximum of 300kph (as with HS1)would reduce airborne noise for which there is no effective mitigation.
3.0 Volume 1
Volume 1 is 2 years out of date! It only covers ‘local alternatives’ considered prior to January 2012. It implies that two years of Community Forums and Bilateral Meetings between communities and HS2 Ltd have had no effect on the scheme. However, in some areas, including my own CF11, significant changes were achieved in Bilateral Meetings i.e. the Stoke Mandeville Bypass.
3.1 However, there is no way of knowing where local alternatives considered after January 2012 have been incorporated into the scheme. They are referred to Volume 2: community forum area reports, which consist of 26 reports and associated map books. HS2 could remedy this defect by publishing a list of the ‘local alternatives’ that have been incorporated in the scheme since January 2012 – which would be interesting in its own right as evidence of how much (or little) attention has been paid to representations from local communities
4.0 Errors and Omissions
The ES is full of factual errors, omissions, contradictions and typos (which matter in a document designed for electronic search). A summary of those discovered in CF Area 11 is included later in this submission. This is only one of 26 CFAs and there is no reason to believe that standards of accuracy are any better in the other Areas.
4.1 HS2 Ltd. should publish an ES Corrections Document addressing all the errors identified in the responses to the ES
5.0 Draft Code of Construction Practice.
At this stage of the Project, the Government surely has enough experience of the operation of CoCPs, for the Olympics and Crossrail, to be able to produce a definitive CoCP for HS2. In fact, the draft seems to be based on the Olympic CoCP, but stripped of the main safeguards for communities. The draft CoCP in Volume 5: Appendix CT-003-000/1 is full of pious aspirations about protecting the interests of local communities during the (lengthy ) construction phase without any specific commitments about how these will be delivered, monitored and enforced. The language is full of weasel terms like ‘as far as is reasonably practical’. Who decides what is reasonably practical? How will the decision be enforced on the construction companies and, particularly, their sub-contractors?
6.0 Environmental Minimum Requirements (EMRs)
The EMRs, which will determine the primary environmental requirements of the scheme, have not been published and may not be consulted on or otherwise scrutinised.
6.1 Many aspects of mitigation remain undecided and will be decided “during the detailed design”, whenever that is;
6.2 Proposed compensation and mitigation measures will only be implemented “as far as reasonably practicable”. “The EMR will also impose requirements on the nominated undertaker to use reasonable endeavours to adopt measures to reduce the adverse environmental effects reported in the ES, provided that this does not add unreasonable cost or delay to the construction or operation of the Proposed Scheme.” Given the current a political imperative to control and reduce costs of building HS2, the obvious areas for cost-cutting are compensation and mitigation.
7.0 Unsubstantiated Opinions and Judgements
Throughout the ES, no evidence is provided for the opinions expressed or the criteria that have been applied. The ES appears to have been rushed through to meet unrealistic timetables, downplays all the negative effects of the project, and exaggerates the willingness of HS2 Ltd. to assess facts and engage and listen to experts and communities.
Part Two
8.0 Errors, Omissions and Contradictions in CFA 11
8.1: the severity of issues is described in terms such as "a medium adverse impact and a moderate adverse effect". There is no definition in the glossary of terms book or anywhere else what these statements actually mean. Without a detailed definition it is impossible to gauge the impact of any of the issues highlighted.
8.2 All references to 'Old Moat Farm' should read "Old Moat Farmhouse" as this is the actual name of the property. There is no property in Stoke Mandeville called Old Moat Farm. Point 6.3.27 page 100 mentions various moated properties including 'Moat Farm'; in fact Moat Farm is not a moated property but 'Old Moat Farmhouse' is.
8.3 Point 6.4.8 page 104 – the paragraph on Old Moat Farmhouse has parts that reference Hall Farm not Old Moat Farmhouse.
8.4 Point 9.5.62 page 180 reports on the visual aspects of the scheme to Moat Farm - Old Moat Farmhouse should also be mentioned in the visual assessment as we will be able to see the line to the south of the property and as it is a heritage property this needs to be noted.
8.5 Point 11.5.16 page 211 indicates four residential buildings close to the proposed scheme which would be adversely affected by noise - it includes Old Moat Farmhouse (correctly referred to!) but does not include Moat Farm (which is 100m closer to the line) and also does not include Brook Farm/Cottage which is also closer to the line.
8.6 Point 13.3.23 page 240 onwards - river flooding – the whole area of flood analysis and effects during constructions and in operation needs reviewing in light of the current extreme flood conditions. Are the safeguards sufficient to ensure the line does not make the flood situation worse for the area in the future?
8.7 Reporting only five secondary schools in Aylesbury – there are actually six
8.8 Failing to accurately report the number of GP surgeries
8.9 Missing out key town-wide bus services impacted during the construction phase
8.10 Stating that properties closer to the line than others will be less affected by noise
8.11 Stating Booker Park School may need to curtail outdoor activities and classifying this as “a minor inconvenience”
8.12 Many place names on the maps are incorrectly sited. On map CT-06-041, Stoke Farm is positioned on the site of the new Stoke Mandeville Care Home, which does not even merit a mention!
8.13 Non-agricultural businesses appear to have been largely ignored or forgotten in the ES. For example, only Bucks Goat Centre (just one of 13 businesses at Layby Farm) gets a mention in the ES. The scheme will have a major not "minor" adverse effect on the Bucks Goat Centre (page 74)
8.14 All residential and business properties in Old Risborough Road (not "up to 10" as stated page 90) will be seriously affected both during construction and operation of the proposed railway.
8.15 The title captions on Figure 1, page 1, and Figure 2, page 2 are transposed.
8.16 Incomplete surveying: NTS, page 3,“As required by law and Parliamentary rules, the Government has provided Parliament with a detailed statement assessing the likely significant effects of the Phase One project on the environment - the ES.” Paragraph 7.7.2 of volume 1 states: “it has not been possible to access all land required to carry out fully comprehensive surveys.” Therefore, the ES is not as detailed as we (and Parliament) are led to believe.
8.17 The section on Sound, Noise and Vibration makes no reference to the Stoke Mandeville Combined School. This school accommodates the regional hearing impaired department. There is little doubt that the school and this department in particular will be affected, particularly in its outdoor activities, by the noise of both the construction and operation of the scheme.
8.18 In Section 7.9, Landscape and visual assessment. page 47 contains the commitment that “HS2 Ltd and its contractors will maintain and monitor these newly planted and landscaped areas.” There is no explanation of the duration of the monitoring and maintaining of the newly planted areas, who will pay for this – hopefully – long term maintenance project. Assuming the answer to be HS2 Ltd, does the published cost of the project include all the costs of long term maintenance of the landscaping all along the route for at least the 60 years used to measure the integration of the scheme into the landscape?
8.19 In Section 7.14, Page: “Sustainable drainage has been incorporated into the design, such as balancing ponds to control the rate, volume and quality of runoff.” Balancing ponds need to be maintained. Does HS2 Ltd expect to put the liability for this maintenance onto the local authorities and / or landowners? We have not been able to locate a statement from HS2 Ltd saying that they will bear the costs of maintaining such features during the lifetime of the railway. Are such costs included in the overall costs of the project? Lack of maintenance of such landscape features will significantly affect their environmental impact.
8.20 In Paragraph 4.2.17: “A maintenance loop … will be constructed at this location, alongside both of the HS2 tracks, to support the efficient maintenance of the railway. The route will then continue north-west passing on the surface to the south-west of Stoke Mandeville where local highway diversions will create a new southern bypass to the town.” But in Paragraph 2.6.35 “the Proposed Scheme will be close to existing ground level in a series of shallow cuttings and embankments.” And in Section 2.2.7 introductory paragraph “The Proposed Scheme will leave the Dunsmore, Wendover and Halton area (CFA 10) on the Stoke Mandeville south embankment which continues for approximately another 1.4 km in this area and is up to 5m high. The route will then descend into the Aylesbury south cutting which is approximately 2 km long and up to 7m deep.” We do not accept that ‘5 metres high’ is ‘close to ground level’ or ‘on the surface. It is an example of inconsistent information based on opinion and lack of updating to latest information
8.20 Paragraph 11.2.3 – Alternatives to the consultation route. According to Table 8, the consultation issue considered in CFA 11 was reportedly dealt with by the plan to “lower the alignment past Aylesbury and Stoke Mandeville.” In Stoke Mandeville in CFA11, we now find ourselves faced with maintenance loops on an embankment up to 5metres high (see reference above). It will therefore be exceedingly difficult to provide adequate noise protection across Stoke Mandeville and the south western corner of Aylesbury around Hawkslade and Walton Court. So the original concern remains to be effectively dealt with.
8.21 Work still to be done: We find it surprising that at this stage of proceedings when an environmental statement is submitted to Parliament in support of a bill that there is still work remaining such as is outlined in paragraph 6.4.3. A general admission that fully comprehensive surveys have not been carried out is made in paragraph 7.7.2 of volume 1 which states: “In addition, it has not been possible to access all land required to carry out fully comprehensive surveys. This applies to agriculture, forestry and soils, community, cultural heritage, ecology, land quality, landscape and visual, socio-economics, sound, noise and vibration, traffic and transport and water resources and flood risk. Nevertheless, it is considered that the baseline is sufficiently robust to allow the assessment of the likely significant environmental effects of the Proposed Scheme.” On whose authority “it is considered that the baseline is sufficiently robust” and what percentage of planned surveys has not been completed. If the information exists in the documentation, where is the cross reference to it?
8.22 In Paragraph 2.2.7 the second bullet point leads into a paragraph referring to the Nash Lee Lane auxiliary substation located to the south of the existing A4010 Risborough Road at the north end of the maintenance loop. On map CT-06-041, there is a blank space labelled Nash Lee Package Substation. It is obvious that these two locations are one and the same though differently described. When we enquired about the details of the substation and its purpose at our final bilateral meeting with HS2 Ltd, we were told that the space on the map is blank because the exact dimensions of the substation are not yet known, though we were told that it could be up to 5 metres high. How can either HS2 Ltd or we then assess its environmental impact on this area – especially given its location so near to residential and commercial property?
8.23 Removal of remains of Old Church of St Mary: in Paragraph 6.4.34, there are a number of references to the former site of the Church of St Mary’s, Stoke Mandeville and its associated archaeological site and remains. These remains are thought to include up to 2,600 people buried in the former churchyard. Most of the references are to the “removal” or “loss” of these assets as in paragraph 6.4.34 which states: “A range of archaeological assets will be permanently lost due to the construction of the Proposed Scheme. These assets include: the remains associated with the former site of the Church of St Mary's, Stoke Mandeville (SMA003) …” These references are in conflict with the third bullet point on page 14 which states “which will also provide for the creation of wetland and grassland habitats and for the translocation of headstones and buried remains from the former site of St Mary’s Church;”
8.24 Sound, noise and Vibration: in Paragraphs 11.2.4 and 11.2.5 it is stated the daytime sound levels in Risborough Road are “typically around 65dB with increased sound levels at locations very close to the road.” Our readings of daytime sound levels on Risborough Road are rather lower than this at a location some 20-25 metres from the road. Our analysis of the readings quoted in Volume 5 Appendix SV-002-011, Table 1, provides no evidence for this assertion with only 4 of the13 Risborough Road readings being above 60dB and only 2 of the 13 being above 65dB. A simple mathematical average of the readings produces a figure of 57.3dB daytime operational average and 57.5dB daytime construction average. Only daytime average sound levels are quoted. There appears to be no recognition of daytime peak levels having an environmental effect.
8. 25 In Sound Map SV-05-021, it seems inconceivable that Booker Park School will have a minor adverse daytime effect from a combination of the new railway, the realigned A4010 and the Princes Risborough railway line, whereas the Stoke Mandeville Combined School with the regional hearing impaired department appears to suffer no effect at all thanks to a curve in the outline of the noise profile.
8.26 Thornbrook House on Risborough Road, a residential receptor, sits squarely within the sound profile for 50 – 65dB effects but is not shown to suffer even a minor adverse effect. It is located closer to the line than other properties which are deemed to be suffering minor adverse effects.
8.27 in Paragraph 12.3.8 “Frequent rail services operate along the Princes Risborough to Aylesbury Line, serving stations within the area including Stoke Mandeville, Aylesbury and Aylesbury Vale Parkway. In reality
Conclusion
The above list of errors, omissions and contradictions refer to one CFA only. It is not unique – similar levels of inaccuracies exist in the remaining 25 CFAs. The Environmental Statement does not provide an accurate assessment of the Environmental Impact of HS2
8 March 2014