Phase 1 Environmental Update

1. What is the Environmental Statement?

On 25th November 2013 Parliament published the Environmental Statement for Phase 1 of High Speed 2 (London to Birmingham). An Environmental Statement (ES) is a detailed review of the environmental impacts expected to arise as a result of the construction and operation of Phase 1 of HS2. It is required to be produced for any large scale project with implications for the environment.

The ES consists of:

  • A Non-Technical Summary of the Environmental Impacts
  • Volume 1: An introduction to the Environmental Statement and the project
  • Volume 2: Community Forum Area (CFA) reports
  • Volume 3: Route-wide effects
  • Volume 4: Off-route effects
  • Volume 5: Appendices and map books

2. Why Has The Environmental Statement Been Published?

Unlike ordinary planning applications, the approval required to construct and operate HS2 will be undertaken by Parliament (through a process known as the Hybrid Bill).

A public consultation on the Environmental Statement is designed to enable members of the public to draw to the attention of Members of Parliament any concerns about the environmental impact of HS2 prior to any binding vote on the Hybrid Bill. You can respond to this consultation as an individual or as part of a community group (eg school, church, sports club).

The consultation process is an important opportunity for you to share your views. The time frame for consultation has been set by the Government and cannot be changed. All responses to the consultation must be submitted by 27th February 2014 at the very latest. Anything submitted after this date will not be considered.

You can access the Environmental Statement here

You can respond to the Environmental Statement Consultation by

Email:        HS2PhaseOneBillES@dialoguebydesign.com

Post:          FREEPOST RTEC-AJUT-GGHH, HS2 Phase One Bill Environmental Statement, PO Box 70178, London WC1A 9HS

Anyone residing in the UK can respond to this consultation-you don’t need to live near the line. In view of the highly adverse environmental impacts set out in the ES, everyone who cares about our environment should respond to this consultation.

3. How To Review The ES and Draft Your Own Consultation Response

The Environmental Statement is 55,000 pages long and covers communities from Euston to Staffordshire so it covers a huge breadth of issues.

If you live in a community impacted by Phase 1 of HS2 and you wish to make a detailed assessment of the ES and respond to the consultation we would recommend you locate the section of the ES which deals with the area where you live and then review this section of the documentation in line with the questions noted below.

(a) Is the development properly described? Including in particular:

  1. Is there a description of the physical characteristics of the whole development and the temporary and permanent land use requirements during the construction and operational phases?
  2. Is there a description of the main characteristics of the construction methods, for instance, nature and quantity of the materials used?

(b) Is there an estimate, by type and quantity, of expected residues and emissions (water, air and soil pollution, noise, vibration, light, heat, etc.) resulting from the construction and operation of HS2 in your area?

(c) Is the description of the aspects of the environment likely to be significantly affected by HS2 in your area, including, in particular, population, fauna, flora, soil, water, air, climatic factors, material assets, including the architectural and archaeological heritage, landscape and the interrelationship between the above factors accurate and been properly described?

(d) Have any structures such as culverts, construction compounds, balancing ponds or access roads been placed inappropriately in your area?

(e) Can you suggest better mitigation options to those being suggested by HS2 Ltd?

(f) Do the conclusions drawn about the severity of the impact in your area from the construction and operation of HS2 look right?

(g) Have all the main alternatives been outlined and all the reasons for the choice given, taking into account the environmental effects?

(h) Have all the likely significant effects on the environment been described?

(i) Are you content with the mitigation measures proposed and have they been adequately described?

(j) If mitigation measures are offered, is it clear how HS2 will make them happen? (If not, ask or suggest the way you consider would be most effective for you)

(k) Do you agree with the forecasting methods used?

(l) Have the cumulative effects of HS2 alongside other development and proposed development been assessed adequately?

If HS2 Ltd have made mistakes of fact or rejected, in environmental terms, a better though more expensive option this should also be pointed out.

Key Points You Should Include In Your ES Response

Although local impacts will vary, HS2AA believe there are some key issues everyone should include in their response to this consultation.

These are:

1. HS2 is not part of our low carbon future

  • The latest business plan for HS2, forecasts only 1% of HS2’s passengers will transfer from air and 4% from the car.  Most trips on HS2 will either be transferring from existing rail (which emits less carbon) or wholly new trips.
Previous mode Classic rail New Trips Air Car
2010 Economic case 57% 27% 8% 8%
2011 Economic case 65% 22% 6% 7%
2012 Economic case 65% 24% 3% 8%
2013 Economic case 69% 26% 1% 4%

2. Environmental Mitigation Is Not Being Prioritised

  • The plans set out in the Environmental Statement indicate a consistent pattern across Phase 1 where what can be afforded is being prioritised over minimising environmental impacts.
  • The environment has a value and this should be factored in fully and properly in deciding appropriate mitigation -including deciding between tunnels versus surface routes.
  • The costs being used by HS2 Ltd in their sums must be made public and subject to independent review given the level of environmental damage which current plans for HS2 will cause.
  • Many environmental impacts arising from construction are being described as “temporary” in the Environmental Statement although they are actually planned to last for up to 9 years, the period required to construct HS2. It’s not reasonable to expect people to suffer building works for such a long period, which is also as long as the average person stays in their home in normal circumstances.

3. Ancient Woodland Must Be Protected

  • Twenty one ancient woods face destruction on this phase, with twelve more at risk of secondary effects such as disturbance, noise and pollution. Analysis shows that the route will directly affect 33 ancient woods. And depending on the final route, track specifications (the width of which varies between 25m and 60m) and location of stations there could be an additional negative impact on further ancient woods.
  • Ancient woodland is irreplaceable. Nothing can mitigate for the loss of some our most important biodiversity and cultural habitats. Ancient woodland is an important national resource. Any loss or damage should be recognised as a significant national loss.
  • If it  has to be lost then the Woodland Trust, the charity which looks out for woodland,  should be asked to say what to do for each one (including advising on how loss can be minimised) and how mitigation should work eg where new trees should be planted – types, age, etc.

4. The Environmental Statement Doesn’t Provide A Proper Analysis of Alternatives to HS2

  • The alternative to HS2 put forward by the group of local authorities opposed to HS2 known as 51M has been assessed by the Department for Transport’s own experts as having a far better cost-benefit ratio than HS2. It suggests a solution of lengthening trains and platforms on the West Coast Main Line, as well as substituting first class carriage for standard class accommodation.
  • These proposals would provide enough additional capacity for even the most aggressive forecasts for future passenger demand put forward by the Department for Transport.
  • In the recent legal proceedings in the Supreme Court, the lawyer for the Government confirmed that it was accepted by the Department for Transport that improvements to existing lines would have a far reduced environmental impact when compared to HS2.

5. Environmental Impacts Will Take Be Significant

  • The Environmental Statement makes clear that there will be highly adverse environmental consequences for the tens of thousands of people who live near the proposed route of Phase 1 of HS2. These impacts are listed as including disruption to drinking water supply, road closures, demolition of existing buildings, disruption to existing businesses (with the potential for permanent job losses) and the destruction of prime agricultural farm land.
  • There will be significant impacts on human health from light pollution/noise; problems with access to health services from cutting communities off, depression, air quality issues from dust, dirt, spoil etc.
  • These impacts are not acceptable given the limited benefits which will arise from HS2.

6. Lack of Time To Consider The Documents

It’s worth pointing out the amount of information published in the Environmental Statement (around 50,000 pages) combined with the decision to provide a very short consultation period (this period straddled the Christmas period where many people take more than the three days which are Bank Holidays off). By comparison the Environmental Statement for Crossrail was deposited on 22 February 2005 with a deadline for comments of 17 May 2005. This was a much longer period for a document which was far shorter and far less ambitious in scope.

7.  Community Blight Must Be Addressed

The Environmental Statement makes clear that constructing and operating HS2 will devastate communities located near the proposed line-urban, suburban and rural. Mitigation measures which might minimise such negative impacts have been downgraded-its cheapskate mitigation wherever you look.

The Environmental Statement avoids dealing with blight, yet this is a significant environmental effect. Blight causes empty buildings and change of farming land use and puts of jobs and investment in impacted areas-these effects have all been ignored in the Environmental Statement.

 8. Construction Process Must Be Properly Managed

The Environmental Statement says that HS2 Ltd will be subject to a “Construction Code” when building the new line. However, the code doesn’t provide any real safeguards and entitles HS2 Ltd to effectively do what they want during construction.  There’s no way for local authorities or communities to enforce the obligations in the Code, meaning HS2 Ltd won’t be subject to any oversight on construction matters.

HS2AA believe local authorities should be empowered to monitor and enforce minimum standards and provided with funds for enforcement. HS2 Ltd should also be required to appoint an independent panel to oversee its impacts in communities where construction is scheduled to take place.

9. Noise 

The noise maps produced appear to have very little detail. HS2 Ltd has not published details of the model it used to predict noise impacts, so its impossible to know how accurate its assumptions in this area are.  No noise maps for construction works  have been provided either.  Much more information on noise should be published to enable informed decisions to be made on mitigation.

1o. If It All Goes Very Wrong

Much of HS2’s plans are based on forecasts. Matters like noise impacts, vibration in properties located above tunnels, light pollution and damage to wildlife could turn out very differently (and far worse) than predicted in the Environmental Statement.

Communities therefore need some guarantees that if the actual impacts are not as they say now then they will get matters rectified/compensated.

Further Information

Woodland Trust on HS2

Wildlife Trusts on HS2

Commission to Protect Rural England Maps of HS2 Impact