HS20056 - Evidence on HS2 and the environment

Supplementary written evidence submitted by Marilyn Fletcher

Omission of Major Alternative:

300kph maximum design speed not included in the HS2 Environmental Statement

Marilyn Fletcher B.Sc. Ph.D.

“The purpose of the Green Book is to ensure that no policy, programme or project is adopted without first having the answer to these questions:

Are there better ways to achieve this objective?
Are there better uses for these resources?”

Treasury Green Book paragraph 1.1

Executive Summary

Trains are currently planned to travel at a maximum speed of 360 kph on the proposed 400 kph design speed line.

Attention is drawn here to the omission in the Environmental Statement (ES) of a major alternative to the proposed scheme. A 300 kph maximum design speed option - which uses the proposed HS2 route corridor - has:

a) considerable environmental advantages over the current proposal; and

b) is less expensive than the present £50 billion scheme.[1]

A 300 kph maximum design speed option was included in the draft ES. However the option was omitted from the formal ES.

Why is this?

There are many benefits from a 300 kph maximum design speed for the Phase-1 route:

a) An Imperial College modelling study estimates that 23% more energy would be consumed if trains between London and Birmingham travel at 360 kph rather than 300 kph;

b) There would be a reduction in operational carbon. However the presentation of data in the ES lacks transparency;

c) The 300 kph maximum design speed option would result in reduced noise impacts;

d) The 300 kph design speed option would decrease the effect of the scheme on landscape from the need for less mitigation, for example noise barriers and bunds;

e) The 300 kph design speed option would provide opportunities to avoid environmental features and communities, and reduce embankments and viaducts due to the rail line being more sinuous and able to make tighter turns; and

f) There would be reduced construction and operational costs resulting from the 300kph maximum design speed option compared with the 400 kph maximum design speed proposal.

Despite the obvious environmental and financial benefits of a 300 kph maximum design speed, a 2012 appraisal of the option is brief and lacks transparency.

The Secretary of State announced in September 2013 that a 20 minute reduction in journey time between London and Birmingham is “almost irrelevant”. This contrasts with the emphasis placed - prior to September 2013 - on the importance of minimising journey time. This change in emphasis effectively constitutes re-orientation referred to in the Treasury Green Book. In the light of the Green Book requirements, the 300 kph maximum design speed option should have been re-appraised in the ES.

The ES Non-technical Summary conflicts with the detailed ES reports. The summary discusses a maximum 300kph design speed option between London and Birmingham. However, as noted, a maximum 300kph design speed option between London and Birmingham was not considered in the main body of the ES. [2] [3] Given that the Non-technical Summary constitutes a synopsis of the main ES documents, there is no basis for the claim in the Non Technical Summary that a 300kph design speed was taken into consideration at the ES stage.[4]

Introduction

Trains are currently planned to travel at a maximum speed of 360 kph on the 400 kph design speed line.

This evidence draws attention to the omission in the Environmental Statement (ES) of a major alternative to the proposed scheme. A 300 kph maximum design speed option - which uses the proposed HS2 route corridor - has:

a) considerable environmental advantages over the current proposal; and

b) is less expensive than the present £50 billion scheme.[5]

A 300 kph maximum design speed option was included in the draft ES. However the 300kph design speed option was omitted from the formal ES. [6]

Why is this?

Treasury Green Book requirements state:

“The relevant costs and benefits to government and society of all options should be valued.” [7]

“There is a risk that the process of short-listing will eliminate the optimal solution before it is given full consideration.” [8]

“The ultimate outcome of any appraisal is a decision whether or not to proceed with a proposal or a particular option. As these decisions will often have far reaching consequences, the presentation of the conclusions and recommendations to decision makers and key stakeholders can be as important as the analysis itself. In all cases, transparency is vital.” [9]

Benefits derived from a maximum 300 kph design speed

“Wider social and environmental costs and benefits for which there is no market price also need to be brought into any assessment. They will often be more difficult to assess but are often more important and should not be ignored simply because they cannot easily be costed.” Green Book [10]

Environmental Benefits of a 300 kph maximum design speed

Local reductions in line speed at locations along the route were examined. The ES states that these would only result in a marginal reduction in noise benefits.[11]

However there are many environmental benefits from a 300 kph maximum design speed for the Phase-1 route:

A reduction in energy consumption during construction and operation. An Imperial College modelling study estimates that 23% more energy would be consumed if trains between London and Birmingham travelled at 360 kph rather than 300 kph;[12]

A reduction in carbon emissions during construction and operation (see below);

A reduction in peak noise. As noted (Written Evidence Part I Addendum Marilyn Fletcher Table 5), omitting HS2 in tunnel, only 9 miles of the total 65 mile distance of the proposed scheme between the peripheries of London and Birmingham travel within 200m of an “A” road or railway line. Furthermore, of the 9 miles, 5 miles travels within 200m of a single track railway line. Accordingly noise peaks from each passing HS2 train will be potentially considerably intrusive. This is because of the relatively low background noise levels where HS2 travels between the peripheries of London and Birmingham.

The loss of prevalent aerodynamic noise at speeds of 300 kph and below;[13]

A reduction in noise impacts when trains are travelling on viaduct. The height of noise barriers on viaducts is lower than elsewhere;[14]

A reduction in HS2’s effect on tranquillity from a 300 kph maximum design speed option;

A reduction in HS2’s effect on recreation from a 300 kph maximum design speed option;

A decrease in the effect of the scheme on landscape from the need for less mitigation, for example noise barriers and bunds. The presence of this mitigation is apparent in HS2 Ltd’s noise data.[15]

Opportunities to avoid environmental features and communities, and to reduce embankments and viaducts. This is because turns can be tighter and the line more sinuous when trains travel at lower speeds;[16] and
A likely reduction in maintenance impacts including lighting and noise from the 300 kph maximum design speed option. Maintenance would principally be carried out between midnight and 5am Monday to Saturday and between midnight and 8am on Sundays.[17]

Reduced Monetary Costs

Reduced construction and operational costs from a 300kph design speed option would result from:

a) Less energy consumption during construction and operation;

b) Less mitigation requirements;

c) Narrower tunnel bores;

d) Less maintenance requirements;

e) Less waste generated and less energy consumed during construction;

f) Less expensive rolling stock; and

g) Less need to carry out research.

Carbon savings not compared on a like-for-like basis

The ES compares the proposed scheme’s total operational carbon footprint when changes are made to the average speed on the track.[18] However the comparison is not made on a like-for-like basis.

As noted, trains on the proposed scheme will travel at a maximum speed of 360kph. In the ES study, the total operational carbon footprint of trains travelling between 330 kph and 360 kph was compared with that of trains travelling at 300 kph. A 7% reduction was found. This is inadequate because a comparison is being made between a speed range and a single speed.
When a like-for-like assessment is made by comparing the total operational carbon footprint when trains travel at 360 kph with the total operational carbon footprint when trains travel at 300 kph, the values in the ES Table 3 indicate an 11% reduction.

Furthermore, when comparing the effect of varying train speed, it is pertinent to compare operational carbon due to train trips rather than total operational carbon. This is a further shortcoming. An earlier appraisal appears to show greater percentage reductions than 11% when train trips only are considered. [19]

The fastest and most frequent trains worldwide

Due consideration must be given to the fact that the trains on the proposed scheme would be the fastest and most frequent in the world (Written Evidence Part I, Marilyn Fletcher paragraphs 34 to 36).
Chief Engineer Andrew MacNaughton tells us the most complicated engineering problems concern the track bed. [20] It is believed that these problems relate to speed.

Assessment to date of the 300 kph maximum design speed

Despite the obvious environmental and financial benefits of a 300 kph maximum design speed, a 2012 appraisal of the option is brief (less than one page in length in total).[21]

Furthermore the appraisal of the 300 kph maximum design speed option lacks transparency. Careful reading shows that the two scheduled monuments highlighted in the 300 kph appraisal were identical to those impacted by the 400 kph maximum design speed, and that the potential number of major river diversions was in fact less for the 300 kph design speed option than for the 400 kph maximum design speed proposal. [22] [23] In addition, there would be a reduction in spoil from tunnels whose diameter would decrease due to a lower design speed (for example the 13.5 kms Chilterns Tunnel). The appraisal lacks transparency in discussing these points.

HM Treasury Green Book

Re-orientation

The Green Book states that it is to be applied whenever a programme or project is re-orientated. [24]

The benefits of a 4.5 minute journey time saving [25] between London and Birmingham of the proposed 400 kph design speed scheme compared with a 300kph design speed option have been exaggerated. The Secretary of State announced in September 2013 that a 20 minute reduction in journey time between London and Birmingham is “almost irrelevant”.[26] This is in contrast with the emphasis placed - prior to September 2013 - on the importance of minimising journey time.

This change in emphasis effectively constitutes re-orientation.

The change in emphasis is not picked up/reflected in the ES.[27]

In the light of the requirements of the Secretary of State’s announcement and the Treasury Green Book, a 300 kph maximum design speed option should have been re-appraised in the ES.

Non-technical Summary misinformed

The ES Non-technical Summary conflicts with the detailed ES reports. The Summary discusses a maximum 300kph design speed option between London and Birmingham. However, as noted, a maximum 300kph design speed option between London and Birmingham was not considered in the main body of the ES. [28] [29] Given that the Non-technical Summary constitutes a synopsis of the main ES documents, there is no basis for the claim in the Non-technical Summary that a 300kph design speed was taken into consideration at the ES stage.[30]

The Non-technical Summary claims that a 300 kph maximum design speed would result in little environmental gain. This written evidence indicates that the claim is misleading.

The Non-technical Summary states that the scheme will be constructed with a 400 kph maximum design speed. It says that this is because the route would allow train speeds of 400 kph in the future should there be a commercial case to do so and should technology allow this to be achieved without additional significant adverse environmental effects.[31]

However, the reason put forward for proposing a 400 kph maximum design speed does not sit easily with the Secretary of State’s announcement that journey time savings between London and Birmingham of 20 minutes are “almost irrelevant”. In the light of this, the environmental and financial benefits of a 300 kph maximum design speed option should be re-assessed. This concurs with Green Book requirements.

Note: Misprint in Volume 5 Alternatives Report

Volume 5 Alternatives report refers to a 300kph speed. However, this is apparently a mis-print. Paragraph 5.1.5 of the Alternatives report says “At 300kph, this number reduces to around 1,100 properties.” It should read “At 200kph, this number reduces to around 1,100 properties”. This is because a conventional 200kph design speed is being discussed. The source of the correct statement can be found in a 2011 appraisal [32] and was repeated at the Government’s January 2012 announcement.[33]

14 March 2014

[2] ES Volume 1 Introduction to the Environmental Statement and Proposed Scheme page 182 and 183

[6] Draft ES Volume 1 Introduction to the Draft Environmental Statement and the Proposed Scheme page 94 paragraph 7.4.4

[13] HS2 London to the West Midlands Appraisal of Sustainability Appendix 5 – AoS technical Reports February 2011, page 40, paragraph 2.2.1

[15] High Speed 2 London to West Midlands Appraisal of Sustainability – Route Corridor and Design Speed Review January 2012 page 10 Table 4-1

[16] High Speed 2 London to West Midlands Appraisal of Sustainability – Route Corridor and Design Speed Review January 2012 pages 11-13

[17] ES Volume 1 Introduction to the Environmental Statement and the Proposed Scheme page 46, paragraph 4.3.2

[19] High Speed 2 London to West Midlands Appraisal of Sustainability – Route Corridor and Design Speed Review, page 7 paragraph 3.4.1 and page 10, Table 4-1 Consultation Route – Speed Sensitivity, Noise and Carbon.

[21] High Speed 2 London to West Midlands Appraisal of Sustainability – Route Corridor and Design Speed Review, paragraph 3.4 and page 10

[22] High Speed 2 London to West Midlands Appraisal of Sustainability – Route Corridor and Design Speed Review paragraph 3.4.2

[25] Draft ES Volume 1 Introduction to the Draft Environmental Statement and the Proposed Scheme page 94 paragraph 7.4.4

[28] ES Volume 1 Introduction to the Environmental Statement and Proposed Scheme page 182 and 183

[32] High Speed 2 London to West Midlands Appraisal of Sustainability – Route Corridor and Design Speed Review, page 10, Table 4-1 Consultation Route – Speed Sensitivity, Noise and Carbon.