2011 Consultation Response

Response from the Rt Hon. David Lidington MP

Member of Parliament for Aylesbury

 

Introduction

I represent the villages of Wendover and Stoke Mandeville, the town of Aylesbury and the parish of Fairford Leys, all of which will suffer serious harm if route three goes ahead, and the villages of Hughenden, Bryants Bottom, North Dean, Speen and Lacey Green, which would be affected by route 2.5.  Up to the 2010 General Election, I also represented the villages of Great Missenden, South Heath and Ballinger and the parish of Ellesborough, all affected by route three.

Since Lord Adonis’s announcement in March 2010, HS2 has dominated my constituency postbag, mailbox and even informal conversations in the constituency.  As of 25 July 2011, I have received letters and emails regarding HS2 from 797 constituents. Five of these representations supported HS2; the remainder expressed opposition to the scheme.  I have attended five packed public meetings, during 2010 in Wendover, Speen and Great Missenden, and during 2011 in Wendover and Stoke Mandeville.   The Speen meeting had to be held outside because no local venue was big enough to hold all those who attended.  At the other meetings, people had to stand outside the hall and try to listen through open windows because the village hall was full. Others had to be turned away.  There have been further public meetings which I was not able to attend in Aylesbury and Fairford Leys and I have received a petition from residents in Walton Court and the surrounding neighbourhood which the organisers are sending in to the consultation.

I have attended the HS2 Ltd roadshows at Stoke Mandeville and Wendover. I have had separate meetings regarding HS2 with local council members and officers and at various times with representatives of Wendover HS2, the Speen Area HS2 Action Group, the Stoke Mandeville Action Group, HS2 Action Alliance, the Chilterns Conservation Board, the Chiltern Society, the Chiltern Countryside Group, the Berkshire, Buckinghamshire & Oxfordshire Wildlife Trust, and the National Trust.

This issue has aroused more passionate feeling locally than any other constituency issue in my nearly 20 years’ service in the House of Commons.

While my constituents first took a detailed interest in HS2 because it affects their communities directly, it is also clear to me from countless communications and correspondence that they would be willing (with reluctance) to accept this scheme if they were persuaded that it is genuinely in the national interest.  In fact, as people have studied the case put forward by HS2 Ltd and the Department for Transport, they have become more and more convinced that the economic and environmental case being put forward in favour of the proposal is seriously flawed. 

I do not believe that the questions around which the consultation is structured address properly the environmental or the economic arguments around HS2. Having made that point, I shall nevertheless make my comments within the framework of those unsatisfactory questions and try to summarise the key arguments made by my constituents.

Q1.  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?

While there is clearly a need to improve our national transport infrastructure to encourage economic growth and, in particular, to address the lack of capacity on the southern stretches of the West Coast Main Line, it is very far from clear that HS2 as currently proposed is the right answer to those challenges.  The central point made to me by constituent after constituent is that there are other and better ways to meet these challenges which have the advantage of being less expensive and less environmentally destructive than HS2, and which would benefit a much greater number of people than the minority who could afford the premium fares that HS2 would need to charge.

Few of my constituents would argue that building an inter-city high speed rail network would have absolutely no positive effect on economic growth, but they are clear that such a proviso alone is not enough to justify any capital project at any price.  Rather, the return on investment must be significant enough to justify the financial and environmental cost, and the evidence indicates that HS2 would not create enough economic growth to make it justifiable. (I try to address this issue in more detail under question two).

The majority of representations made to me regarding HS2 express concern and even disbelief at the Government’s proposal to commit £17.1bn of taxpayers’ money at a time when the country is facing major spending cut-backs.  Of course the bulk of the spending would not be required until after the current Parliament, by which time it is anticipated that the structural deficit will have been eradicated.  Nevertheless, my constituents feel that the level of public spending associated with HS2 is entirely at odds with the Government’s message of fiscal restraint.  They feel that lessons should be learned from the level of debt that Britain managed to accumulate in recent years, and that public spending commitments of this magnitude should only be undertaken if absolutely necessary. 

Many of my constituents have argued that the link between improved inter-city transport and economic growth will be weakened in the future, as advances in technology will lead to lower demand for inter-city travel for business purposes.  This is because businessmen and women will be able to communicate through improved broadband connections and greater use of video-conferencing rather than face-to-face meetings.  Even if this trend were not to lead to a fall in real terms in the future demand for rail travel, it may still mean that current estimates for future growth in demand are over-optimistic.  Given the major shifts in the way people have communicated over the last two decades, it does not seem unreasonable to expect that further advances will have taken place by 2026, when the Birmingham leg of the proposed network is supposed to open.

Many constituents have also questioned the relationship between improving inter-city transport and achieving increased productivity.  This may not be improved by shorter rail journeys: many have pointed out that as the route to Birmingham terminates at Curzon Street in the city’s Eastside regeneration area, much of the 35 minute time-saving in the journey from London would be lost in the onwards journey into the New Street area.  Many constituents have pointed out that time spent on a train is productive anyway due to the use of laptops and blackberries, and a small number even claim that time on a train is among their most productive as they are isolated from the normal distractions of the office.  Although it is true that such productivity cannot be achieved if trains are so overcrowded that one cannot find a vacant seat, this counter-argument assumes that HS2 is the only way of improving railway capacity, which of course is not the case.

My constituents are far from convinced that there is sufficient evidence that improving Britain’s inter-city rail network would improve the ‘North-South divide’.  Little data has been produced to support this assertion; nor has the term ‘North-South divide’ in this context been defined.  It can be argued that a high-speed rail network would worsen any economic disparities between the North and South of England by enabling human capital resources to be more easily diverted away from the Northern cities and to London.  Given that 70 per cent of passengers are predicted to be using HS2 for leisure, it seems likely that many of these will be Midlands and Northern residents travelling to London for sightseeing purposes (more so than vice-versa).  Some constituents have reminded me that 70 per cent of the jobs created by HS2 would be in London, as opposed to the Midlands or the North. 

Q2. 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?

I have received several highly detailed critiques of the benefit-to-cost ratio (BCR) for HS2 from constituents.  One common complaint has been that the demand forecasts for future inter-city rail travel are unrealistic.  Demand for Eurostar’s London to Paris line in 2009 was just 37 per cent of the predicted 2006 level.[1]  The detailed analysis carried out by HS2 Action Alliance showed that more than 90 per cent of rail projects have been subject to overestimated demand, by an average factor of over two.[2]  Although passenger growth has increased since 1995 from under 40 to over 60 billion passenger kilometres, it should be noted that growth between 1952 and 1995 was stagnant despite large increases in GDP per capita.[3]  Much of the post-1995 growth can be attributed to more sophisticated pricing mechanisms and a more enjoyable onboard experience.  My constituents are concerned that this rate of growth will not continue for as long as the Department for Transport expects (ie: until 2043).       

My constituents are also particularly concerned that a project of such expense may go ahead when it has a BCR of as little as 1.6 (for the first phase).  Even the previous estimate of 2.4, published in March 2010, was considered a low return for such a large outlay.  The fact that the BCR for the entire ‘Y’ network was cut by almost half, from 4 in March 2010 to 2.2 in February 2011, has caused many of my constituents to question the reliability of the measurement at all.  Some have drawn my attention to work by HS2 Action Alliance, which claims that the revised BCR remains overinflated because it compares the benefits of HS2 to a scenario which underestimates the improvements to capacity which could be achieved by upgrading the West Coast Main Line (WCML).  The BCR assumes that up to 18 trains will run per hour, which some constituents are unconvinced will be possible.  I have also been told that it ignores improvements to the current network which may occur over the next 30 years, including some which are already being planned by railway operators. 

My constituents are concerned about the fare levels that the business case for HS2 relies on.  The main consultation document of February 2011 contains surprisingly little information regarding pricing strategies for HS2, and yet it seems that these would be likely to have a strong effect on the level of demand and therefore the BCR, particularly if premium fares were introduced.  Some constituents have also expressed concern that premium fares would price most travellers out of the market and allow only the wealthy to benefit from HS2.  This fear is underlined by the fact that those in the top household income quintile already make as many as 47 per cent of long distance rail journeys every year.[4]  Many fear that they will be expected to pay through their taxes for a railway that they will not be able to afford to use.     

One theme that has become increasingly common in my constituency inbox in the recent months has been Rail Package Two (RP2).  Many constituents argue that this upgrade package could offer several of the benefits of HS2 at a fraction of the cost, and in a sample of cases they have engaged in depth with the data provided by both the Department for Transport and HS2 Action Alliance to demonstrate this.  Some claim that RP2 could deliver a capacity increase of 151 per cent.  A paper published by DfT itself in March 2011 gives RP2 a BCR of 1.9 (compared to the 1.6 figure for HS2), and at a gross capital cost of just £4bn (compared to £17.8bn for HS2).[5]  RP2 could also be completed much sooner than 2026, and would not be as crowded as HS2 (HS2 Action Alliance claims that RP2 has a load factor of 51 per cent, compared with 58 per cent for HS2).[6]       

Finally, I would challenge the assumption of this consultation question: that it is possible to make a well-informed decision on the BCR for the entire ‘Y’ network, when detailed data (including a route) exists only for the first phase up to Birmingham.      

Q3. 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?

The Consultation Document assumes that trains will leave and arrive at Euston station every few minutes. This would mean many thousands of additional passengers having to be absorbed both by Euston Station and by London’s transport system getting people to and from their HS2 journey. I question whether the infrastructure of the London tube and bus network would be able to cope.

Q4. 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?

Some constituents have written to me to challenge the principle that trains must travel as fast as 225mph to achieve the status ‘high speed’.  They have argued that a top speed of less than this figure would still constitute ‘high speed rail’, and would allow more flexibility with the route, as it would not need to be so straight.  They argue that this would afford more scope for lessening the impact on the Chilterns AONB, and that the speed lost would not be missed because inter-city distances within the United Kingdom are relatively short when compared with rail networks in continental Europe, Asia or North America.   One key local stakeholder has informed me that Decision No 1692/96/EC of the European Parliament and of the Council of 23 July 1996 states that high speed rail can be defined as speeds of 250km/h (155mph) on purpose-built lines, or 200 km/h (124 mph) on upgraded lines.[7]  

I should also reflect the intense anger of my constituents at the way in which route three has been described by the promoters of HS2 as running along an existing transport corridor comparable to the route taken for the HS1 Channel Tunnel link. The A413 between Amersham and Wendover is (with the exception of about a mile of dual carriageway just west of Amersham) a single carriageway rural road. The existing Chiltern Line branch from Aylesbury to Amersham runs alongside, carrying a two or three carriage train half-hourly for much of the day. Rather than running alongside existing routes, HS2 route three would cut across the existing road and rail lines at right angles at Stoke Mandeville, while there is no existing transport corridor at all around the western perimeter of Aylesbury and Fairford Leys where route three is planned to run. To describe route three as running along an existing transport corridor might just about make sense if the comparison were with route 2.5, which cuts through virgin countryside and very narrow lanes, but to compare it with the HS1 corridor is wrong.

Q5. 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?

The single most common theme in all of the representations made to me by constituents and key local stakeholders is the serious concern at the proposal to route HS2 through the Chilterns.  The Chilterns is one of only two Areas of Outstanding Natural Beauty (AONB) to have a statutory conservation board, and is the only one between London and Birmingham.  It would be difficult to understate the anger felt by my constituents at a willingness to alter irreversibly this environmentally important and protected landscape.  The landscape damage would be significant. Twenty-four woods would be damaged, of which 12 hectares are ancient, and 13,700 metres of hedgerow would be destroyed.[8]  This would be a loss not just for my constituents, but for the nation as a whole, since the Chilterns has been designated by successive governments as an Area of Outstanding Beauty whose landscape is of national importance and for that reason deserving of special protection. There are more than 55 million visits to the Chilterns AONB each year, many for walking or cycling purposes.[9]  Ten sites of special scientific interest would be affected by HS2.[10]  The proposals would have a serious impact on local habitats and wildlife populations.  The security fence that would be erected alongside the railway line would inevitably split habitats in two, contradicting the approach to conservation and the natural environment set out in the Government’s White Paper, ‘The Natural Choice: Securing the Value of Nature’, published in June 2011. 

National planning guidance in the form of Planning Policy Statement Seven gives equal protection to National Parks and Areas of Outstanding Natural Beauty. In the case of either, there is a presumption against any inappropriate development unless such development can be shown both to be in the overriding public interest and impossible to carry out by any means which avoid intruding upon those specially protected areas of landscape.  I have not found anyone in my constituency, nor any reputable conservation group, that is prepared to argue that these conditions, set out in national planning guidance, have been met in the case of HS2.

A small number of constituents have raised more detailed concerns regarding archaeological sites which may be damaged by HS2.  These include prehistoric, Iron Age, and Roman finds at Hartwell, and the possible site of the Battle of Edgecote just outside the village of Chipping Warden.

I should add here that my constituents are angry and frustrated at the refusal so far of either the Department for Transport or HS2 Ltd to provide information about their preliminary thinking about access roads to construction sites, depots for building materials, camps for construction workers or arrangements for dealing with spoil. It is impossible to make a fully informed judgement about the environmental impact of what is proposed or the compliance of the scheme with PPS 7 without such information.

A large number of my constituents believe that even to discuss mitigation would be to concede the principle that they believe the scheme to be deeply and irredeemably flawed on both economic and environmental grounds. My comments on mitigation need to be understood in that context.

If route three is built, then my constituents in the ancient market village of Wendover will strongly wish for the line to pass through the area in a 2.8km bored tunnel of the type described in a report by HS2 Ltd of November 2010, as opposed to a 300m ‘cut and cover’ tunnel (the Government’s current preferred option).[11]  The former alternative would dramatically reduce the visual and noise impact of HS2 on the local community.  Some constituents in Wendover are not convinced by HS2 Ltd’s estimate that a bored tunnel would cost £300m more than a ‘cut and cover’ one.  They argue that a bored tunnel would lead to significantly fewer claims for compensation due to loss of value of property, and would remove the need for the permanent Ellesborough Road diversion (mentioned as a possibility in map nine); both of which would offset much of the increased cost of the tunnel.

Constituents in the outskirts of Aylesbury and Fairford Leys have expressed concern that route three has been moved 75-100m closer to them, in order to help mitigate the impact of the route on Hartwell House.  They fear that the noise impact on their community would be worsened as a result of this proposal. I believe that the National Trust now supports the idea of a bored tunnel to protect the inalienable National Trust land and Grade One listed Jacobean Manor at Hartwell. My understanding from the National Trust is that for a bored tunnel to protect Hartwell House, it would have to start somewhere between Wendover and Stoke Mandeville and resurface somewhere north of Stone. While this would mean a considerable additional cost, the expense would be a fraction of what it is proposed to spend building even just the first phase of HS2, and would spare my constituents in Stoke Mandeville and Aylesbury (particularly residents of the Hawkslade and Walton Court estates) from the prospect of a high speed rail route running on an embankment or viaduct close to their homes.

Whether or not a tunnel is built, I believe that some better way needs to be found at Stoke Mandeville than the current plan to run the A4010 on a bridge over the top of HS2 which itself would be on a viaduct. The consequence would be massive visual intrusion and noise nuisance for my constituents in the village.

Mitigation should not only include measures to reduce the noise impact and visual intrusion of any development but also adequate provision for the restoration of all rural lanes, public rights of way and landscapes that would inevitably be damaged during construction. When members of Buckinghamshire County Council and Aylesbury Vale District Council visited Kent to gauge the long-term impact of HS1, they were dismayed at the evidence that restoration work had not been done. Lanes that had been widened to allow for construction traffic had not been restored to their original state. Footpaths and bridle paths remained severed. In a designated AONB there should be no quibbling over making much better provision for restoration and the responsibility for that should be accepted by the DfT.

Q6. 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?

My constituents should have had sight of a full Environmental Impact Assessment (EIA) of HS2 before or at least alongside the current public consultation.  This is because the Government is consulting on, amongst other things, the very principle of high speed rail in the UK, and I believe that a full assessment of the environmental costs of such a scheme should play an integral part in that decision-making process.  I am not convinced that the Appraisal of Sustainability (AoS) contains adequate detail for people to make an informed decision regarding HS2.  For instance, the Berkshire, Buckinghamshire, and OxfordshireWildlife Trust has informed me that known wildlife habitat sites along the route have not been mentioned in the AoS.

Given the obligation of the Government to cut carbon emissions by eighty per cent of their 1990 levels by 2050, my constituents are concerned that a £32bn major infrastructure project is being considered when it is only carbon neutral.  

My constituents are particularly concerned about the level of noise that HS2 will cause.  An EIA would presumably have included noise maps with isochrones which would have given them a considerably better understanding of how their communities would be affected by noise.  My constituents were alarmed to hear confirmation that the AoS was the result purely of desktop studies, as opposed to any field work.  Some have expressed disbelief that the DfT can say with confidence that only ten houses will suffer high noise levels as a result of HS2 (greater than 73dBLAeq18hr), without having conducted site visits to assess the contours and lay of the land in question.[12]  Appendix 5.4 of the AoS, where noise is discussed in most detail, skirts over some issues which are important to my constituents.  For instance, section 8.2 on ‘night noise’ contains fewer than 100 words.  One constituent has pointed out that although the noise created by HS2 will be less than that generated by a main road near his house, such will not be the case if trains run at night.

Q7. 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?

Not even the most ardent champions of HS2 argue that my constituents will benefit from the scheme. There is no plan for a station anywhere near them. They are asked, in the national interest, to bear perhaps a decade of property blight and the disruption to their lives and neighbourhood that a construction project of this magnitude will inevitably bring, with permanent harm to their area in terms of noise and visual intrusion. On top of that, they know that their taxes will be used to finance the scheme. It is a matter of basic justice that my constituents should be properly compensated if this scheme goes ahead.

The property markets in areas of my constituency close to route three were deeply unsettled by the announcement of March 2010.  A number of constituents have contacted me detailing the difficulties they have experienced in selling their home.  One in Wendover has reduced the asking price of his house from £675,000 to £500,000, and has still not received a single offer above £460,000.  Many have not met the requirements of the Exceptional Hardship Scheme; often because they have not been able to satisfy the panel that they have an urgent need to sell their house.  They have therefore been forced to either sell their property well below its value, appeal against the decision of the panel, or continue to live in a property which for whatever reason no longer suits them.  I have some constituents who now face the loss of their life savings or bankruptcy because of the refusal by the EHS panel to help them.

If the Government does decide, as a result of the current public consultation, to go ahead with HS2, then I feel it is important that a comprehensive and generous compensation scheme is set up quickly so that confidence can return to the affected property markets.  I believe that the downturn in the most affected areas has been exacerbated by a lack of clear understanding of both the statutory blight and compensation provisions that will come into force should HS2 go ahead, and the Government’s intentions for discretionary compensation.  The Government has stated its wish to consult on a new discretionary compensation scheme in 2012 (if it decides to go ahead with HS2).  I hope that it will publish its final plans soon after and advertise them comprehensively, as the sooner these matters are clarified the better.   The HS2 Action Alliance has now published a carefully researched proposal for compensation which draws on the best practice of both public and private sector schemes and I hope that that could be the basis for any comprehensive scheme that the Government brings forward.[13]

 

[1] ‘Submission to the Transport Select Committee consultation on High Speed Rail’, The TaxPayers’ Alliance, 12.05.11, p5.

[2] ‘Inaccuracies in Traffic Forecasting’, Flyvbjerg, B., Skamris Holm, M., Buhl, S., in Transport Review, Jan. 2006, cited in ‘High Speed 2: Review of the February 2011 consultation business case for HS2’, HS2 Action Alliance, version 1.12, June 2011, p8.

[3] ‘High Speed 2: Review of the February 2011 consultation business case for HS2’, HS2 Action Alliance, version 1.12, June 2011, p8.

[4] ‘Submission to the Transport Select Committee consultation on High Speed Rail’, The TaxPayers’ Alliance, 12.05.11, p3.

[5] ‘High Speed 2 Strategic Alternatives Study: London to West Midlands Rail Alternatives: Update of Economic Appraisal’, Atkins, March 2011, cited in ‘High Speed 2: Review of the February 2011 consultation business case for HS2’, HS2 Action Alliance, version 1.12, June 2011, p34-5.

[6] ‘RP2 not HS2: Better investing in Britain’s future’, HS2 Action Alliance, March 2011, p2.

[7] http://eur-lex.europa.eu/LexUriServ/site/en/consleg/1996/L/01996L0048-2…, Annex I, accessed 07.07.11.

[8] ‘Submission to the Transport Select Committee Inquiry to HS2’, The Chilterns Conservation Board, 16.05.11, p6.

[9] Ibid.

[10] Ibid.

[11]  ‘High Speed Rail: London to the West Midlands and Beyond: Line of Route Mitigation: Supplementary Report’, HS2 Ltd, 4.11.10, s.4.1-4.2.

[12] ‘HS2 London to the West Midlands: Appraisal of Sustainability, Appendix 5: AoS Technical Reports’, HS2 Ltd, February 2011, s.7.2.1.

[13] ‘Compensation for Property Blight from HS2’, HS2 Action Alliance, 20.07.11.