HS2: Phase Two Route Consultation Submission by HS2 Action Alliance

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1 HS2: Phase Two Route Consultation Submission by HS2 Action Alliance 31 January 2014

2 Contents Page 1. Introduction 3 2. Overview Executive Summary 4 3. Capacity Issues 6 4. Business Case Compensation Responses to Consultation Questions Question i: The selection of route to Manchester Question ii: The choice of station locations for Manchester Question iii: Requirements for additional stations western leg Question iv: The selection of route to Leeds Question v: The choice of station locations eastern leg Question vi: Requirements for additional stations eastern leg Question vii: Appraisal of Sustainability comments Question viii: Use of freed up capacity Question ix: Other Utilities The Way Forward Appendices Appendix A: Example commuter journeys References January

3 1. Introduction HS2 Action Alliance is a not for profit group that aims to put decision making on High Speed 2 on an evidenced based footing. We have over 100 affiliate organisations mainly local action groups that support our work through feedback, endorsement of our reports and promotion of our findings. More generally through our website we have thousands of individual supporters many of whom have contributed comments, requests, raised questions, and provided feedback on our consultation responses. Our focus on all issues is to take an evidenced-based approach, concentrating on whether HS2 is in the national interest. Regarding the case for HS2 in general, we have studied the materials published by HS2 Ltd and the Department for Transport (DfT), reviewed papers produced by academics and other professionals specialising on the specific issues and those produced by or for high speed rail supporters. We have sought clarification on a range of issues, met with experts and with HS2 Ltd and DfT on several occasions, making requests for information in correspondence and under Freedom of Information legislation. Since April 2010, HS2AA have issued numerous draft reports for comments by affiliate organisations and independent experts, and developed our position in the light of feedback. These have covered: The business case for HS2 Alternatives Compensation options, current schemes and consultation proposals We have drawn the attention of HS2 Ltd and DfT to areas where we feel that their position and that of four successive Government Ministers has been inaccurate, misleading, or prejudicial to a fair consultation, with a view to this being corrected. On compensation we have developed and promoted a Property Bond approach as a way of addressing the underlying issue of property blight. In our view the evidence drives any reasonable assessment of HS2 to conclude that it is not in the national interest, and HS2AA remain opposed to the HS2 proposal. HS2 Action Alliance 31 January

4 2. Overview A consultation for the HS2 Phase One route was undertaken in It contained three questions related to the principal of HS2. This consultation was not promoted along the Phase Two route, which had not been announced at that time. The consultation for HS2 Phase Two contains no questions about the principal of HS2. It could have done and should have done. The second reading of the Hybrid Bill will not take place until Spring 2014 and it would have been perfectly possible for the results of this consultation to be provided to Members of Parliament before any vote on this legislation. HS2AA therefore believe the Department for Transport/HS2 Ltd have not provided the opportunity for those affected by the HS2 route to comment on the principle of whether or not it should be built. Whilst HS2AA has chosen to include its own views on this subject in the first part of this response, this omission has disenfranchised thousands of people in communities which are blighted by HS2. That cannot be right Executive Summary HS2AA considers the following conclusions relevant to the subject matter of this consultation: The trains running on the West Coast and East Coast Mainlines are the least overcrowded trains serving London and other major cities (measured by standing passengers). HS2 will provide almost no benefit to rail commuters into major cities for whom additional capacity is most needed-in particular HS2 will make little difference for commuters in Birmingham, Leeds or Manchester. By contrast, the Northern Hub will bring major benefits to northern rail travellers, and could be expanded further if additional funding was freed up from the cancellation of HS2. There are significantly fewer users of the West Coast Mainline the further north you go, making capacity arguments even more specious for Phase Two. HS2 will result in a poorer service for a number of journeys on existing classic rail. Classic compatible trains, which are planned to run on high speed lines from London to the West Midlands and then on existing tracks to destinations further north, will have less seating capacity than the trains they replace in most cases. There will be a bottleneck between London and Birmingham on the HS2 line which will have no ability to accommodate more trains after 2032/3. Euston, the site of the proposed London terminus for HS2, will have difficulty handling growing passenger numbers with 30% fewer classic train platforms. Its Underground lines will need the addition of Crossrail 2 to handle more than double the number of passengers, but this is not included in the HS2 budget. The benefit cost ratio for HS2 falls to less than 0.5 when realistically calculated, which is unacceptable. The costs of servicing the debt resulting 31 January

5 from construction and the on-going subsidy required have not been included in the Business Case. Independent academics agree that if there is any regional regeneration impacts from HS2, then the beneficiary will be London, not the North or Midlands. Hundreds of thousands of homeowners are affected by property blight. Yet the Government is likely to compensate no more than 2% of them. Those that are able to sell their homes will be tens or hundreds of thousands of pounds out of pocket. The remainder will be trapped in their homes. This issue is particularly worrying for Phase 2 communities, where there will be years between a route being announced and the line opening. There are numerous adverse environmental impacts which are being ignored. A better way to spend the proposed 50 billion would be to divide the sum into much smaller amounts and address numerous existing capacity bottlenecks on the classic rail network. 31 January

6 3. Capacity Issues 3.1 Capacity Issues National Capacity has become the main argument for justifying HS2 on the basis that the proposed new line will provide additional intercity seats and release capacity to allow more local trains to be run on existing lines. Before looking at the issues related to the Phase Two section of the HS2 route between the West Midlands and Manchester and Leeds we need to review the national situation. Measured by standing passengers during the morning three hour peak in autumn 2012, London clearly has the most significant train overcrowding problem [1]. The main cities affected were as follows: Birmingham 2,751 Bristol 502 Cardiff 839 Leeds 2,961 Liverpool 915 London 112,246 Manchester 3,366 Sheffield 440 This is not a major surprise as the number of rail passenger journeys in London and the South East has increased by almost 400 million compared to 10 years ago [2]. The increase in number of long distance journeys over the same period has been very much smaller. Million Passenger Journeys London and South East Operators Regional Operators Longdistance Operators Q3 to Q Q3 to Q Increase The busiest London stations have as many as 31,000 standing passengers on their trains in the morning three hour peak and there are five mainline stations which have more than 8,000 standing passengers on their trains during this period. The West Coast Mainline (WCML) terminus is at Euston, where there were 2,821 standing 31 January

7 passengers during the morning three hour peak. The vast majority of those that were standing on Euston bound trains were on London Overground and London Midland trains [1]. The following table shows the percentage of standing passengers arriving during the morning three hour peak split by train operator: Percent Train operator standing London Overground 48 South West Trains 28 Southern 25 c2c 25 Southeastern 19 First Great Western 15 Greater Anglia 14 First Capital Connect 12 London Midland 12 Chiltern Railways 11 East Midlands 7 Virgin Trains 1 East Coast 0 Measured by standing passengers, the West Coast Mainline (WCML) and East Coast Mainline (ECML) intercity services were the least crowded trains serving London. The percentage of standing passengers on Virgin Trains and East Coast services at other stations was at most 1% and often 0%. It is evident that the most severe train overcrowding issues are in London. Providing more capacity into Euston would indirectly address approximately 2.5% of the current rail overcrowding issue for London [3]. In other words HS2 would not benefit 97.5% of the passengers who currently have to stand during their morning commute to London. West Coast Mainline is nearing the limit of trains that it can accommodate per hour, but so are many other lines into London. However it is possible to add some additional trains to the timetable. Project 110, which is due for introduction in May 2014, will provide three additional trains in the morning peak and five additional trains in the evening peak for WCML commuter services [4]. A series of enhancements to the WCML in the Stafford area are underway although one is still awaiting approval [5]. If all the enhancements are introduced, then it is intended four extra trains per hour will be run in each direction. The 51M group has proposed two other changes which would allow more trains to be run on the WCML. 31 January

8 3.2 Capacity Issues Phase Two The usage of the West Coast Mainline is greatest close to London. Further away from the capital, the usage diminishes [6]. Million journeys/year both Section directions London Euston to Watford Junction Watford Junction to Tring Tring to Wolverton Wolverton to Rugby Rugby to Rugeley Rugeley to Manchester 5-10 Rugeley to Acton Bridge 5-10 Acton Bridge northwards Less than 5 In terms of passenger usage there is half the passenger demand or less on the Phase Two equivalent part of the route compared to the Phase One section. Looking at specific journeys there were nine times more journeys made from Milton Keynes to London than there are from Manchester to Birmingham in 2009/10. The latter journey was the most popular on the WCML not involving London. Passenger journey data was not found between Leeds and Birmingham, as most Rail Utilisation Strategy (RUS) documents tend to focus on routes to/from London. The most overcrowded trains in the North and Midlands tend to be commuter trains reflecting the situation experienced in London. Using Manchester as an example to show the percentage of passengers standing during the three hour morning peak in 2012 [1] : Percent passengers Train Operator standing First TransPennine Express 23 East Midlands Trains 10 Northern Rail 8 Arriva Trains Wales 7 CrossCountry 3 Virgin Trains 0 We see a similar picture in Leeds during the three hour morning peak: 31 January

9 Train Operator Percent passengers standing First TransPennine Express 22 Northern Rail 12 CrossCountry 0 East Coast 0 The commuter trains in both cities are overcrowded while the intercity services either have either very little or no overcrowding, even on official figures. HS2 therefore will not address these commuter overcrowding issues. 3.3 Future Commuter Journeys Claims have been made that HS2 will release capacity on classic rail so enabling more commuter services to be run. Examination of the HS2 Business Case published in October 2013 reveals indicative schedules for both do nothing and with HS2 [7]. Seven typical commuter journeys were selected and the indicative schedules for these journeys with and without HS2 were compared. These seven journeys were as follows: Barnsley to Leeds Doncaster to Leeds York to Leeds Leeds to Manchester Liverpool to Manchester Stockport to Manchester Chesterfield to Sheffield In no case are there plans for a more frequent service. Fuller details are available in Appendix A. HS2AA therefore believes that claims HS2 will permit additional commuter services to be run as largely spurious. If the Government is serious about such services, it should publish indicative timetables for regional services it proposes to run once HS2 is built. 3.4 Classic Rail Service Cuts The October 2013 Economic Case appraisal spreadsheets show that 8.3 billion savings are planned to be made from cuts to classic rail services. The following cities will have fewer services to and from London. 31 January

10 City Current Service (to/from London) Service post HS2 Phase One 1 train/hour with an additional Stoke-on-Trent 2 trains/hour train/hour during peak Wilmslow 1 train/hour No service Stockport 3 trains/hour 1 train/hour with an additional train/hour during peak City Current Service (to/from London) Leicester 4 trains/hour 3 trains/hour Nottingham 2 trains/hour 1 train/hour Chesterfield 2 trains/hour 1 train/hour Sheffield 2 trains/hour 1 train/hour Wakefield 2 trains/hour 1 train/hour Service post HS2 Phase Two The existing classic service between Liverpool and London will be discontinued so such journeys will have to be made by HS2 in future. Given experience of other high speed rail lines, it is to be expected that HS2 will be premium priced, which will produce a financial disincentive to travel. It is noted that Ashford to London HS1 services carry a 20% premium on their ticket price compared to classic rail services. In Europe the typical ticket price premium for high speed rail is 70%. The Department for Transport don t appear to have studied the impact of ticket pricing on future passenger demand for HS2. Several services will become slower post HS2, as some classic trains will stop at more stations. Currently there are two Virgin trains per hour on the section between Preston and Carstairs (Scotland) where the routes to Glasgow and Edinburgh separate. For HS2 Phase One there are expected to be three trains per hour (HS2 and Virgin trains combined) on this section. For HS2 Phase Two this will rise to four trains per hour. As this section of track has only one track in each direction this is likely to have an adverse effect on other existing services including rail freight traffic between England and Scotland. HS2AA believe it is important the Government sets out how it proposes to overcome these issues given their potential impact on the existing rail network. 3.5 Classic Compatible Trains 31 January

11 Trains running on classic rail for part of their journeys will be 200 metres long. The majority of Virgin Pendolino trains have 11 carriages with 589 seats [8]. Currently East Coast has a mixture of Standard trains (10 carriages and 608 seats) and Mallard trains (9 carriages and 530 seats) [9]. From 2018, East Coast will be using IEP trains (new rolling stock for East Coast Mainline) that will have 627 seats in their 9 carriages) [10]. So although passenger demand is forecast by DfT to increase, each classic compatible HS2 train will have less capacity (39 seats) than the 11 carriage Pendolino train it will be replacing. Similarly, each classic compatible HS2 train will have less capacity (77 seats) than the IEP train that it will be replacing. This seat reduction applies on routes to Manchester (phase one), Liverpool (phases one and two), Preston (phases one and two), Glasgow (phases one and two), Edinburgh (phase two), York (phase two) and Newcastle (phase two). This comment also applies to 16 other stations as well. There is little logic in providing a train that has less capacity than the one it replaces, when rolling stock needs to be used for twenty to thirty years before replacement. 3.6 London Birmingham Bottleneck There is an issue which affects Phase Two passengers travelling south of Birmingham. The International Union of Railways has advised that it is not safe to run more than 16 trains per hour at speeds of 350 kph [11]. The DfT is proposing to run 18 trains per hour on the main section between London and Birmingham at up to 360 kph once phase two becomes operational in 2032/3. The indicative schedule does not include any trains to connect with Europe on this section of the route [12]. Therefore there is no expansion capability for additional train paths seven years after HS2 becomes operational. This has been confirmed within the Environmental Statement document that shows that any direct services from Birmingham (or further north) to Europe would be at the expense of currently planned services using the Birmingham - London section of HS2. This major constriction appears to be a very significant oversight for a line with a 50 billion price tag. The Victorians built lines which could accommodate growth for more than 150 years. Atkins, a contractor for HS2, pointed out this potential bottleneck in 2008 [13]. So HS2 will create the very problem its supporters use to criticise the West Coast Main Line within seven years of opening. It is conceivable that one partial solution to this problem may be to start/finish all HS2 services to Europe at Old Oak Common. So anyone choosing to travel from say Manchester to Paris will have to change trains/platforms at Old Oak Common and go through customs and immigration procedures there. If that is the solution chosen, it rather undermines the case for the link from Old Oak Common to join with the HS1 route north of St Pancras. It will be an expensive few miles of track involving tunnelling. It will also restrict the expansion of London Overground services on the North London Line and interfere with freight services on this section too [14]. Those passengers could alternatively travel to Euston and then travel one stop on the Northern or Victoria lines to reach St Pancras. 31 January

12 Even if all HS2 services for Europe start and stop at Old Oak Common, there is no opportunity to add further HS2 services between London and Birmingham post Phase Two opening. 3.7 Side effects of Bottleneck Eight of the eighteen trains using the Birmingham London section in the peak hour will have started their journeys on classic rail. They will have had to travel on classic rail for up to 200 miles before joining HS2 rails. The overhead line equipment on the West Coast and East Coast Mainlines is some of the least reliable in the United Kingdom as evidenced by the lower Public Performance Measure granted to the train operating companies on these routes until 2019 by the Office of Rail Regulation [15]. Trains operating on the Birmingham London section of HS2 will be spaced every 3 minutes 20 seconds on average with an extremely small window of running early or late. It seems unlikely that all the HS2 trains will run to the required timetable requirements when joining the HS2 network. Consequently some may run out of sequence with knock on effects to the overall timetable. It is evident that this Birmingham London section will be intensively used. However it is only two track, i.e. one track in each direction. Consequently any breakdown by one train is going to quickly affect many others. There are three maintenance loops between Birmingham and London but they are so infrequent that they are unlikely to be of much help in most cases, even if the loop happens to be empty. Where 1100 seat trains are in use, more people will be affected than would happen on classic rail. Much of the WCML and ECML is four track, so there are ways of avoiding a broken down train. In addition, reroutes are possible using alternative classic lines which would not necessarily be suitable in the case of dedicated HS2 trains. 3.8 Problems in London If HS2 is built these issues will affect travellers from north of Birmingham who use the WCML or HS2 to reach Euston. Soon after construction starts at Euston, the number of platforms for classic rail services will be reduced from 18 to 13 and the number of lines on the approach will be reduced from 6 to 4 for classic trains [16]. These changes will be permanent. While an indicative schedule has not been produced for the construction period, indicative schedules have been provided for London Midland services post HS2. Supposedly the only services that will be adversely affected (on a temporary basis) will be those serving Watford [17]. This is most surprising when the total number of platforms and number of approach lines have both been reduced by approximately 30%. The DfT estimates the number of passengers arriving by classic rail at Euston during the morning three hour peak will increase from 24,682 (2012) to 36,100 by 2041, an increase of 46% [18]. Coupled with the reduction in the number of platforms detailed in the previous paragraph, the average number of passengers using each platform will double. Another capacity issue created by HS2 will be the handling of additional passengers on the Underground system at Euston. It has been estimated by the DfT/HS2 Ltd that the number of passengers wishing to use the Underground during the morning three 31 January

13 hour peak hour is likely to more than double from 24,682 to 56,420 by No agreement has been made to build Crossrail 2 and the HS2 budget does not contain any allowance for increasing Underground capacity. 31 January

14 4. Business Case 4.1 Benefit Cost Ratio The main benefit cost ratio figure publicised for the Y Network in October 2013 was 2.3. Web tag advises that such ratios should exclude Wider Economic Impacts (WEI), partly because they are less reliable [19]. The benefit cost ratio falls to 1.8 without the WEI. The benefit cost analysis still assumes that rail passengers do not work on trains. The time savings provided by shorter journey times are calculated to provide 45bn or 79% of the claimed benefits. It is widely recognised that passengers do work on trains. Recalculating the benefit cost ratio on a realistic basis produces a result of less than 0.5, i.e. there would be a net return of less than 50p for every 1 spent [20]. In other words, HS2 is not a sound investment. 4.2 Anticipated Cost The October 2013 Business Case shows that the total cost of HS2 (Y Network) is estimated to be 50.1bn made up of 42.6bn construction costs and 7.5bn rolling stock. It has been reported unofficially that the Treasury expects the total cost to be 73bn [21]. The Institute of Economic Affairs has estimated the full cost of HS2 at 80bn [22]. Some HS2 engineers speaking off the record have suggested the cost is likely to reach 100bn. The Business Case omits the cost of building Crossrail 2 which will be needed to accommodate the additional passengers at Euston if HS2 goes ahead. 4.3 Debt and Subsidy The Government is going to be saddled with the debt resulting from the construction costs of HS2 for many years just as it has been (on a much smaller scale) for HS1. In France the accumulated debt from TGV line construction costs had reached 38 billion euros by 2011 (SNCF and RFF combined) [23]. Total rail debt in Spain in 2012 was 16 billion euros (Renfe and Adif combined) [24]. Japan has had major issues with the debt incurred in building its high speed lines which had reached $300 bn [25]. China s high speed rail debt is close to $300 billion and has been described by a professor as more serious than the US subprime crisis [26]. The debt incurred from HS2 will be in addition to that of Network Rail which currently has a debt of just over 30 billion. This debt is expected to reach 50bn by 2020 without HS2 [27]. Interest payments on the HS2 debt could reach 2.3bn per year based on current low rates of interest. It is understood that Spain spends nearly $3 billion on high speed rail subsidies annually and Germany more than $1 billion per year [28]. Japan is another country which appears to subsidise its high speed rail despite it having the highest rate of rail use in the developed world [29]. In July 2010 a World Bank report cautioned that governments planning high-speed rail systems... should also contemplate the near-certainty of copious and continuing budget support for the debt [30]. An on-going subsidy of 1 billion or more per year for the next 50 plus years is an unnecessary and unwanted millstone for taxpayers. A subsidy will be required 31 January

15 because passenger revenues will fail to match projections for at least two reasons. A study of more than 250 infrastructure projects showed that there is a tendency to overestimate passenger forecasts by more than 100% on rail projects [31]. Also the DfT forecasts for HS2 assume that there will be no premium on ticket prices. The Public Accounts Committee has challenged that assumption [32]. HS1 ticket prices from Ashford to London are 20% more expensive than those on classic rail. In Europe the average premium for high speed rail tickets is 70% more than classic rail. Passengers are price sensitive and many will choose a cheaper alternative where it exists. The cost of servicing this debt and the on-going subsidy required have not been included within the Business case. HS2AA believes it is important that any revised versions of the Business Case for HS2 properly reflect the costs of building and operating the new line. 4.4 Regional Regeneration Several politicians as well as HS2 literature have indicated that this line is expected to help rebalance the country, i.e. move some businesses to the North and Midlands. However no credible independent evidence has been produced to support this view. A group of leading transport economists wrote an open letter to the Secretary of State for Transport which was published in the Financial Times in January 2013 [33]. Their view was that the link between improved transport infrastructure and economic growth and more jobs can no longer be relied upon for the UK, which, as Eddington pointed out in 2006, is already well connected. Professor John Tomaney has studied the effects of high speed rail on regional regeneration in several countries. He provided written evidence on this subject to the Transport Select Committee in 2011 and also appeared to provide oral evidence. His conclusion was that if there are any regional benefits then they are most likely to accrue to the capital [34]. So if there is to be any regional beneficiary then it is likely to be London. 31 January

16 5. Compensation 5.1 Compensation HS2AA has conducted several surveys to assess the amount of property blight created by HS2 including two for the Phase Two part of the route during The conclusions reached concerning the effects of blight were as follows: Summary from Phase 2 for EHS consultation (and reconfirmed 9 months on) The consensus was HS2 had a substantial impact. Typical impacts by distance Up to 100m. Unsaleable m Unsaleable or 25 50% reduction M 15 20%, and more if big country house 30% hit on auction prices Unsaleable on some properties up to 300m Unsaleable if topography allows view of the line Examples of 16% to 30% loss Around 500m Unsaleable if property over 1m (in normally less expensive areas). Blight extended out to 1-2 miles for more expensive homes Whole villages are written off in buyers minds (or look for very large discounts) Tranquil settings and distant views are most vulnerable areas There are properties within 1km and 299,000 properties within 1 mile of the Phase two HS2 route. The corresponding figures for the whole route are 486,110 and 540,000 properties. From the evidence submitted by HS2AA for the Property Compensation Consultation in October 2013 it appears likely that HS2 Ltd will not be willing to buy more than 2% of properties affected by HS2 blight. The Exceptional Hardship Scheme run by HS2 Ltd had accepted applications from157 homeowners (Phases One and Two combined) as at 1 st January The Phase One part of the scheme has been operating for over three years. So the vast majority of homeowners who want to move or need to move will either be trapped in their existing homes or face losses measured in tens or hundreds of thousands of pounds if they are fortunate enough to be able to sell their properties. This is neither fair nor does it reflect statements made by Government ministers. HS2AA has proposed a Property Bond on four occasions in the last three years as a much fairer means of recompensing property owners affected by blight. We have created a cost model and shown that a credible Property Bond Scheme (PBS) outcome would reduce the Benefit Cost Ratio by 0.02 (with an outlay of 0.5-1bn). A PBS is essentially self-financing as the purchase outlay is reimbursed when the properties are re-sold and Government say the long term effect of HS2 will not reduce prices. HS2AA has assessed various scenarios including the maximum outlay assuming everyone sold to Government, which is unlikely. The Government has not yet seen fit to adopt this PBS proposal. The wide-ranging compulsory purchase orders contained within the Hybrid Bill, if enacted, could create additional property blight near to the sites of new HS2 stations such as Old Oak Common, Birmingham Interchange, Toton, etc. [35]. 31 January

17 It is unacceptable that the Government proposes that homeowners near the route of HS2 should collectively subsidise this line by several billion pounds. 31 January

18 6. Response to consultation questions HS2AA wishes to make clear that it does not support the proposal for HS2 at all. Responses to the questions below do not indicate any form of tacit or implied support for HS Question i: The selection of the route to Manchester and onwards to the West Coast Mainline Qi. Do you agree or disagree with the Government s proposed route between the West Midlands and Manchester? This includes the proposed route alignment, the location of tunnels, ventilation shafts, cuttings, viaducts and depots as well as how the high speed line will connect to the West Coast Main Line. This section of route does not generally follow existing transport corridors except for a short section of M6 in Staffordshire, near Crewe and close to Manchester Airport. Consequently the route selected would pass through mostly open countryside much of it farmland. There are several places in Staffordshire and Cheshire where the route appears to run through a series of farmhouses. The route is likely to make several farms uneconomic to run once the remaining land has been divided into smaller parcels of land. HS2 will also divide a number of rural communities. HS2 will also have an adverse impact on some businesses where premises will have to be demolished as they are situated on the line of HS2. Jobs are likely to be lost as a consequence. Two examples of where this is very likely to occur are at Culcheth (western leg) and Killamarsh (eastern leg); there will be many other instances. The proposed route of HS2 crosses an area in Cheshire used for salt extraction. This is located between Northwich, Middlewich and Winsford. This activity makes the ground more liable to subsidence. It makes the route design and construction much more challenging in these areas. See further comment about Taiwan in section 6.4. The design of the HS2 route accentuates issues in some areas. The line will cross the Manchester Ship Canal on a very tall viaduct that is almost one mile long. This will spread the noise of the trains over a far wider area as well as being an unwelcome visual blight for this designated Green Belt area. The proposed route has highly negative impacts for the environment, ecology and biodiversity. Key issues which have been highlighted by the Wildlife Trusts include: Lancashire, Manchester & North Merseyside: The proposed link between HS2 and the West Coast Mainline in Wigan, runs within metres of Lightshaw Meadows nature reserve, and near to the Abram Flash SSSI that forms part of it. The proposed route runs along the Heybroook Corridor, in which that nature reserve lies; and it also crosses, and so further fragments, the historic Chat Moss area passing Little Wooden Moss nature reserve and particularly close to Holcroft Moss SSSI, and not far from Risley Moss SSSI. In fact the route would split the two SSSIs which would prevent plans to join them and form a larger protected area in the future. The Heybrook Corridor and the historic Chat Moss area form major components of the Great Manchester Wetland Living Landscape area. 31 January

19 The proposed route through the city of Manchester has the potential to impact on internationally and nationally vulnerable species; most notably roosting bats and, perhaps, breeding sites of the rare Black Redstart. Cheshire The indicative line passes through two Nature Improvement Areas (NIA) Government-identified areas for protection in the Meres & Mosses (already designated by Defra) and a proposed NIA, Greater Manchester Wetlands. Two Cheshire Wildlife Trust Living Landscape schemes (areas identified for improved connectivity of wildlife habitats) will be affected across the Dane and Gowy/Mersey river basins. The Saltscape zone recently earmarked by Cheshire West & Chester Council for a 1m natural and cultural heritage investment will also be affected. Holcroft Moss SSSI (the most intact lowland raised mire in the county) is a Cheshire WT reserve and part of Manchester Mosses Special Area of Conservation (a crossborder site with Greater Manchester). The route is expected to come well within the 100m direct impact zone, including construction of an overpass to the adjacent M62. Yellowhammers an IUCN Red List species in serious decline in the UK feed and nest on the site. A range of plants including cottongrass are restricted to the specialist conditions on raised mires. Several of the Local Wildlife Sites (LWS) in Cheshire which the route cuts through have components of ancient woodland (woodland at least 400 years old) such as Hancocks Bank and Leonards Wood LWS. Damage to and destruction of any woodland in the least wooded county in England (at just 6.4% woodland cover; source: Woodland Trust 2012) is a serious loss. The traditional English bluebell originates and thrives in ancient woodland and is already subject to a recovery project in the county. Eleven Acre common LWS is an unimproved grassland which would be bisected by the indicative route. The site is home to numerous butterfly species; a fact of concern given the recent year-on-year declines in species including speckled wood (a 65% decline in 2012: Butterfly Conservation Trust). Silver Lane Ponds LWS, also in the direct impact zone, is home to long-eared owls and barn owls the latter being an Amber List species in decline. 6.2 Question ii: The choice of station locations for Manchester Qii. Do you agree or disagree with the Government s proposals for: a. A Manchester station at Manchester Piccadilly? b. An additional station near Manchester Airport? a. The Manchester Piccadilly station is one of the very few stations for HS2 to be in a city centre and part of the existing station. b. The HS2 Manchester Airport station will be at least two kilometres from the airport terminals and the existing Manchester Airport rail station. Its means of connection to the airport has not yet been finalised. This is one of many examples where a new HS2 station is being proposed that is remote from its intended destination. This approach contrasts with that used at Paris (Charles de Gaulle), Lyon and Amsterdam 31 January

20 (Schipol) where the stations serving high speed rail are integrated with their airport terminals. The Department for Transport/HS2 Ltd have indicated that the HS2 Manchester Airport station will only be built if suitable (local) funding is provided. No indication has been provided of the amount of funding required, or the area from which this support will be sought despite Freedom of Information requests being made to the Department for Transport and Manchester City Council. People cannot make informed decisions on this subject in the absence of this key information. 6.3 Question iii: Requirement for additional stations on the western leg Qiii. Do you think that there should be any additional stations on the western leg between the West Midlands and Manchester? There will be additional stations on the western leg of HS2. They will be at Stafford, Crewe, Runcorn, Liverpool, Warrington, Wigan and certain other West Coast Mainline stations further north. These will be existing stations serving classic compatible HS2 trains. It is not considered that any further stations are needed. 6.4 Question iv: The selection of the route to Leeds and onwards to the East Coast Mainline Qiv. Do you agree or disagree with the Government s proposed route between the West Midlands and Leeds? This includes the proposed route alignment, the location of tunnels, ventilation shafts, cuttings, viaducts and depots as well as how the high speed line will connect to the East Coast Main Line. For most of the way between the West Midlands and Barnsley, the proposed HS2 route follows existing transport corridors such as the M42, A42 and M1. That is to be welcomed and highlights the scale of the problem for the remainder of the HS2 proposed route. Nonetheless HS2 will still have highly adverse environmental impacts north of Barnsley and in certain places further south as well. The proposed route of HS2 crosses the Leicestershire and South Derbyshire Coalfield and also the Nottinghamshire, Derbyshire and Yorkshire Coalfield. The previous mining activity makes the ground more liable to subsidence. This can be observed when travelling on parts of the A42 and M1. It makes the route design and construction more challenging in these areas. It should be noted that Taiwan s high speed rail system has been suffering from subsidence on some of its lines, which is reckoned to be between 5 and 7cm per year. To address the issue in Taiwan, it planned to spend US$18bn to seal off 1000 wells to reduce further subsidence [36]. The planning of this part of the HS2 route appears to have been the result of a deskbased exercise. For instance the planned maintenance depot at Staveley took no account of the recent restoration work completed by the Chesterfield Canal Trust. 31 January

21 The proposed route has highly negative impacts for the environment, ecology and biodiversity. Key issues which have been highlighted by the Wildlife Trusts include: Nottinghamshire: Sellers Wood SSSI, a Nottinghamshire Wildlife Trust reserve is within the corridor. Bulwell Wood SSSI is right on the edge of the centre line. Bogs Farm Quarry is a SSSI and a Nottinghamshire Wildlife Trust reserve directly impacted by the centre line. The site is a complex mix of wet and dry, acidic and calcareous habitats. Annesley Woodhouse Quarries SSSI is a Nottinghamshire Wildlife Trust reserve and is less than 100m from the proposed centre line. Nottinghamshire Wildlife Trust fought for 10 years to get this site designated as an amphibian SSSI and to protect it from landfill. The site is important for its calcareous grassland and for breeding and overwintering wetland birds. The adjacent land directly affected is an important site for birds. The proposed route runs straight through the magnesian limestone area of the County which already has the most seriously threatened and fragmented groups of calcareous grassland Local Wildlife Sites. Warwickshire The phase 2 proposals of HS2 require the creation of a new eastern section of high speed railway in Warwickshire, in addition to that already proposed across the county as part of phase 1. Initial assessment indicates that another 5 important wildlife sites are directly within the footprint with a further 7 at risk from indirect impacts. This raises the total number of wildlife sites in Warwickshire that could be directly or indirectly at risk from both phases of HS2 to 102. Yorkshire Three Wildlife Trust reserves may be affected: Woodhouse / Woodhouse Washlands, where the route goes along the eastern boundary and so direct impacts are expected, Water Haigh Woodland Park where the line goes straight through the middle, and Rothwell Country Park. 6.5 Question v: The choice of station locations for the eastern arm Qv. Do you agree or disagree with the Government s proposals for: a. A Leeds station at Leeds New Lane? b. A South Yorkshire station to be located at Sheffield Meadowhall? c. An East Midlands station to be located at Toton? a. The New Lane terminus station would be solely for HS2 and would be 250 metres from the existing rail station. A passenger bridge would connect the two stations. This lacks the integration planned for Manchester Piccadilly station. b. The Meadowhall station would be 5 kilometres from the centre of Sheffield. This would be inconvenient for passengers travelling to the city centre, adding to their journey times. Many passengers would need to connect to services to or from Sheffield Station to complete their journey. Having a station at Meadowhall is likely to make HS2 less attractive than existing rail services for many passengers. 31 January

22 c. Toton station would be approximately 13 kilometres from the centre of Nottingham and 18 kilometres from the centre of Derby. Although there are expected to be 12 HS2 trains stopping at Toton per hour, there would be just one train per hour to and from Derby [7]. Some passengers could experience significant delays to their journeys here through waiting, in addition to the time take to travel from Toton to Derby. No trains are planned to run from Toton to Nottingham centre. However if HS2 is approved, the tram network might be extended to Toton station. In which case the journey time to Nottingham centre would be approximately 20 minutes. If you include waiting time as well, then much of the HS2 journey timesavings would be lost. In this context, it is worth remembering that the classic rail service to London will be halved post HS2. The site of the proposed Toton station lies within a designated Green Belt area [37]. 6.6 Question vi: Requirement for additional stations on the eastern leg Qvi. Do you think that there should be any additional stations on the eastern leg between the West Midlands and Leeds? There are already additional stations on the eastern leg although they are north of Leeds. HS2 trains will serve York, Darlington, Durham and Newcastle upon Tyne. 6.7 Question vii: Appraisal of Sustainability comments Qvi. Please let us know your comments on the Appraisal of Sustainability (as reported in the Sustainability Statement) of the Government s proposed Phase Two route, including the alternatives to the proposed route Ancient Woodlands On Phase Two, twelve ancient woods face the threat of destruction with twenty two more close enough to be threatened by disturbance, noise and pollution. For the whole route, thirty three ancient woods are under threat with a further thirty four at risk within 200m of the line [38]. Planting trees will not recreate the habitats that have developed over hundreds of years Wildlife Sites The full HS2 route passes within 1km of 200 wildlife sites of which 65 would be directly at risk. The route of HS2 may impact 24 Sites of Special Scientific Interest (SSSIs) and 30 river corridors. At risk are a number of rare or declining species of bird, bat and butterfly. A number of wildlife sites will be bisected and HS2 would prevent the planned connection of some existing sites [39] Farmland 31 January

23 The HS2 route would cut through much agricultural land particularly in Staffordshire and Cheshire. In some parts of these counties the route appears to have been drawn by connecting existing farmhouses. Where the route of HS2 bisects some farmland, it is likely that in some cases the remaining areas will be too small to be farmed economically Flood Risk The Sustainability Statement indicates that the proposed route of HS2 crosses several flood plains. Dan Rogerson, the Water Minister, recently indicated that the risk of flooding has not been fully assessed on the Phase One section of the route. At the same time he indicated that the Phase Two route had not been assessed at all for flood risk [40]. Such flood assessments must be made in relation to the future impacts of climate change as well as in relation to historical data Water Sources HS2 Ltd have acknowledged the risk to water supplies in the Colne Valley (Phase One) as a result of building HS2. Similarly the water abstraction borehole at Whitmore (Staffordshire) may be affected by the Phase Two route [41]. Contrast this with the recent recommendation by the Environment Agency and officers of Hertfordshire County Council that the council should refuse permission to a company that wants to extract sand and gravel in the Colne Valley close to the HS2 route because of the impact on the aquifer [42] Carbon Emissions The construction of HS2 will lead to a large generation of carbon emissions. DfT/HS2 Ltd estimate that as much as thirteen million tonnes of carbon dioxide equivalent may be generated during the building of phases one and two [43]. As a yearly average, the Phase One carbon footprint over the course of the construction period will represent approximately 1.9% of the UK s annual construction carbon footprint (based on the UK s annual construction emissions in 2026) [44]. The energy requirement of a vehicle increases with the square of its speed and its power requirement with the cube of its speed. So a train operating at 225 mph requires/uses over three times the energy of a train travelling at 125 mph and over five times the power [45]. So with ultra high speeds, these trains will be less green. In calculating the net carbon benefits considerable emphasis is placed on carbon emission reductions through modal shift. However the October 2013 Business Case anticipates that only 1% of HS2 passengers will have transferred from air travel and just 4% would have previously travelled by car. Set against this must be the 26% of HS2 passengers making trips they would not have previously made [46]. It is claimed that high speed rail is one of the most carbon-efficient means of transporting large numbers of people, measured in terms of emissions per passenger kilometre. However the Greengauge document The Carbon Impacts of High Speed 2 indicates that a load factor of 70% has been used in its calculations [47]. Noting that average load factor for East Coast and Virgin trains is between 32 and 39% [48] and that some of the HS2 trains will have 1100 seats rather than 550, it is highly probable that the emissions per passenger kilometre are very largely understated. This affects its carbon efficiency when compared to other modes of transport. 31 January

24 The carbon emissions created by electricity power stations used for HS2 will depend on their fuel source. There are national requirements to significantly reduce carbon emissions in the UK by We cannot say with any certainty that they will be achieved. If they are not achieved, then one of the contributing factors may be that the power stations are creating more carbon emissions than currently expected. HS2 Ltd does not expect the line to be carbon neutral within 60 years but expects that it is likely to be of carbon benefit after 120 years [49]. However there are so many uncertainties in such a projection that the claim is of questionable value. 6.8 Question viii: Use of freed up capacity Qviii. Please let us know your comments on how the capacity that would be freed up on the existing rail network by the introduction of the proposed Phase Two route could be used? The capacity that would be freed up should be used for commuter services as these are the ones that currently have standing passengers and will have even more of them by 2032/3. However it does not appear that commuters will gain from freed up classic rail capacity from examination of the 2013 Business Case or the plans for Phase 2 of HS Question ix: Other Utilities Qix. Please let us know your comments on the introduction of other utilities along the proposed Phase Two line of route? The width of land to be used for HS2 is likely to be kept to a minimum. Any utilities laid near to the line would need to be accessible for repair. This would only be possible at times of day when trains were not running e.g. early morning. If the hours of operation of HS2 trains were changed in the future this could further reduce the duration when access would be possible to these utilities cables or pipes. This proposed strategy introduces a high element of risk into the continued serviceability of the utilities installed. It would also mean further disruption and blight for communities located near the proposed route and underlines the need for fair compensation. 31 January

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