Time for a pause

A promising local playwright and poet once wrote that “summer’s lease hath all too short a date” and that certainly seems to me to be the case this year (see footnote 1). The events that count down the progress of a British summer are rattling through – as I post Wimbledon is reaching the climax of its second week and the First Night of the Proms takes place this very evening – and I am only too aware that, in my own life calendar, summer has passed and I am well into autumn – I “celebrated” my sixty-ninth birthday this week.

For more than six years now (see footnote 2) I have managed, with very few exceptions, to stick to my self-imposed discipline of posting a new blog every four days, and once or twice have stepped up this posting rate when the urgency of the situation dictated. The automatic count of blogs on my WordPress administration page shows that I am within a handful of clicking over the six hundred mark, which must be somewhere in the region of half-a-million words.

Whilst I have never aimed at a mass audience I have a steady, if numerically unspectacular, readership and have, on a number of occasions, been surprised to learn that some notable environmentalists and politicians have read some of my output, or are at least aware of my efforts. And, it appears, my “fame” knows no geographical boundaries: the world map that WordPress provides to blog administrators tells me that I have a worldwide readership, although why someone on the other side of the world would be interested in the UK Government’s attempts to play catch-up with a technology that is already past its sell-by date is beyond me – perhaps these people are UK exiles or, more likely, are just cybersurfers who land on my site by pure serendipity.

The satisfaction that I have derived from all this graft has, however, nothing to do with crude numbers: it arises from my genuine belief that I have exposed, by rigorous and objective examination of the evidence that has been available to me, that the case that has been made for building HS2 is based upon suspect claims and exaggerated benefits. Most of all, I am proud to have highlighted the disregard that the Department for Transport and its liegeman HS2 Ltd have shown for the value of our natural environment, and the environmental law and government policies that are meant to protect that environment, and of the inadequacy of the proposals that have been made for new habitat creation in place of what will be destroyed. Most recent examples that have come under the objective lens of my microscope are the alleged failure to satisfy the requirements of the relevant EU Council directive, as interpreted by the European Court of Justice, in respect of affording protection to the Pasturefields Salt Marsh SAC (see footnote 3) and the failure to adopt the replacement ratios for ancient woodland that have been proposed by Natural England (see footnote 4).

Sifting through the evidence in an attempt to arrive at the truth has often not been easy. The sheer volume of documentation that has been published in connection with the project, much of it overstuffed with words, has meant that I have had to devote many hours of reading to distil the essential elements to present them to you, and each posting is a considerable labour of love. Paradoxically though, it is probably within some of the documents that have not been published, despite the best efforts of a group of campaigners to employ freedom of information legislation to tease them out of the Government’s firm grasp (see footnote 5), that the really juicy stuff might be found, and there are significant gaps in the evidence that is available, for example in the figures that support the passenger demand predictions that lie at the heart of the business case.

But there is one particular statistic that has become, above all others, foremost in my mind in recent months. This is the realisation that my own expectancy of years of active life is unlikely to be many more than I have fingers and, if I am unlucky, could be fewer than I can count on my digits. I really don’t want to spend a significant proportion of those precious years chained to a computer screen and keyboard.

I feel that now is the right time to reflect on this and begin to loose the bonds. After all our dear friends at Westminster are preparing in this coming week to return to their constituencies for the summer recess, and the HS2 project is effectively settling into a between-phases period. It is, of course, true that we have been promised that the Rubicon for Phase 1 will be crossed in the next week or two with the signing of the main design and build contracts, but the die has already been cast for this to be an inevitable rather than a significant event. Also, we cannot expect much action on Phase 2a until the hybrid Bill has been deposited in Parliament, which we are unlikely to see before the end of this year, if not later than that.

If I take the opportunity of a break that this hiatus appears to offer, perhaps I will be able to enjoy what is left of the summer and give some much needed attention to my wilderness of a garden, the desolation of which bears testament to the demands that the HS2 project has made on my time. I am sure that the current state of my plot is probably very beneficial to the environment, but an excursion into it makes me feel like the Knight in Burne-Jones’s set of paintings The Legend of the Briar Rose.

I have decided, therefore, that this will be the last regular blog that I will post on the four-day cycle, and that I will, hereafter, post irregularly and far less frequently, depending on when I feel the need.

Although shedding this burden is a relief, I do feel a little like Prospero seeking to quit his enchanted isle, but feeling the need to beg the “indulgence” of his audience to “set [him] free” (see footnote 6). I hope that you, my loyal readers, will feel similarly kindly disposed towards me in my desire to be released to resume my previous life.

Footnotes:

  1. See William Shakespeare’s Sonnet 18, Shall I compare thee to a summer’s day?.
  2. My first blog, Why am I doing this?, was posted on 10thMarch 2011.
  3. See my blog A stab in the dark, part 4 (posted 6 Jul 2017).
  4. See my blog Cutting out the old wood, part 4 (posted 22 Dec 2016).
  5. For a case in point see my blog Peering into the laundry basket (posted 19 May 2017).
  6. See the Epilogue to The Tempest, William Shakespeare.
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A stab in the dark, part 5

(… continued from A stab in the dark, part 4, posted on 6 Jul 2017).

In this concluding part of the blog series I will consider, by way of a coda, the impacts that the Initial Preferred Route (IPR) for HS2 Phase 2a, or Route C as I have identified it, will have on Lionlodge Covert Site of Biological Importance (SBI) and the remnant of inland salt marsh that lies within the SBI.

Lionlodge Covert was first surveyed for the Staffordshire Ecological Record in 2014 (see footnote 1). It is a broadleaved, mixed and yew, plantation woodland that is growing on drained saltmarsh. The woodland is 15.4 ha in extent and is privately-owned. Consistent with its name, it is used for the raising of gamebirds.

Lionlodge Covert – drainage ditch

In 2015 a further ecological survey was carried out, and the “woodland boundary was extended” to include the area of inland saltmarsh that lies to the south of Lionlodge Covert, and which I have referred to in this blog series as the Ingestre/Tixall Salt Marsh. The current extent of this marsh is 1.5 ha and it is described in the Ecological Site Report as poor semi-improved grassland.

Ingestre/Tixall Salt Marsh

Following the second survey the site was designated as a Site of Biological Importance (SBI) and recognised as comprising two sub-sites: woodland, and inland saltmarsh (see footnote 2).

The Ecological Survey Report notes that the SBI designation has been afforded to Lionlodge Covert because of its “species-rich woodland ground flora which supports several ancient woodland indicator species” (see footnote 3). Examples of such species are noted in the report as “frequent Bluebell, Dog’s Mercury, Wood Speedwell and occasional Enchanter’s Nightshade where the ground was wetter” (see footnote 4). A good selection of other woodland plants are listed in the report as having been recorded, including four species of fern.

The report describes the Ingestre/Tixall Salt Marsh as “an area of rank, wet grassland”: the photograph reproduced above confirms that it is not much to look at, but this image problem belies its ecological importance as an example of natural inland salt marsh (see footnote 5). Although, due to drainage schemes being employed, it is now only a remnant of its historical extent, which records indicate was something in excess of 35ha (see footnote 6), what remains of the Ingestre/Tixall Salt Marsh is, like its more-illustrious cousin at Pasturefields, a rare example of a habitat type that is listed as a priority habitat in Annex 1 to Directive 92/43/EEC of the EU Council.

The Ecological Site Report records that the Ingestre/Tixall Salt Marsh “supports extensive areas of Saltmarsh Rush” which is “currently only recorded on two other sites in Staffordshire”, one of which is Pasturefields. However, the report also credits the Ingestre/Tixall Salt Marsh with an accolade that cannot be claimed by Pasturefields:

“The site also is host to Stiff Saltmarsh-grass which has not been recorded in the county since 1923 and is a significant record for the country. The species is nationally scarce and normally confined to coastal locations. At present there is only one other inland site in Britain (in Cheshire) where the species has been recorded in modern flora accounts.”

The report also notes records of breeding Northern Lapwing and of Eurasian Curlew “displaying breeding behaviour” – more recent information indicates that Eurasian Curlew is now an established breeder on the site (see footnote 7). Both of these birds are “red listed” as birds of the highest conservation concern in the UK; the Eurasian Curlew is of particular concern as it has moved from amber to red (see footnote  8), and has been authoritatively described as “[the UK’s] highest priority species from a global perspective” (see footnote 9).

The map reproduced below indicates that the HS2 IPR Route C will be bad news for Lionlodge Covert and the Ingestre/Tixall Salt Marsh (see footnote 10).

Source: HS2Ltd

HS2 Ltd advises that the construction of the Trent North embankment, shown on the map, “would result in the permanent loss of approximately 5ha (approximately 30%) of Lionlodge Covert LWS” (see footnote 11). According to the Ingestre with Tixall Parish Council, this breaks down to a loss of approximately 25% of the woodland sub-site and the whole of the saltmarsh sub-site (see footnote 12).

It is a condemnation of the way that environmental protection operates in the UK that there are two similar inland saltmarsh sites within a mile of each other, with one being strictly protected under the EC Habitats Directive and the other having nothing more than the ineffectual protection offered by Local Wildlife Site (LWS) status. Inland salt marsh is an irreplaceable habit, and the Ingestre/Tixall Salt Marsh is, surely, potentially of national importance.

Sadly, as the treatment of ancient woodland on Phase 1 of the HS2 project has demonstrated only too clearly, HS2 Ltd pays no regard to the irreplaceability of habitat and appears to treat LWS status as an open invitation to trash with impunity.

The Ingestre with Tixall Parish Council has also learnt a lesson that many respondents to the public consultations on Phase 1 would recognise; that HS2 Ltd pays little regard to intelligence fed to it by local communities. The Council notes that it has passed a “considerable quantity of information” to HS2 Ltd, but that “but none has been acted on”, and that “almost all previously supplied information had been ignored or misrepresented” in the draft Environmental Impact Assessment that was published in September 2016 (see footnote 13).

There is however one matter that HS2 Ltd would be well-advised to pay some attention to. The Ingestre with Tixall Parish Council has warned HS2 Ltd that the “brine springs that feed [the Ingestre/Tixall Salt Marsh] remain active” and that “local measurements of brine concentration and flow rate at just one of the outflow points from the drainage network of the marsh gives a daily loss of 1.34 Tonnes (0.5m3) of salt” and that this salt derives from “natural dissolution of halite that underlies the salt marsh”. The Council adds that it regards this figure as “a minimum as there are several outflow points and not all were measured” (see footnote 14).

The Council concludes that (see footnote 15):

“Apart from the corrosive nature of brine, it appears that HS2 Ltd has created for itself significant engineering challenges in maintaining track stability in the face of the loss of supporting ground amounting to several hundred cubic metres per annum.”

That this may be a much wider problem in the area is, perhaps, indicated by the following map, which shows where salt dissolution subsidence can occur (see footnote 16).

Source: British Geological Survey

This map is evidence of the “geological instability” that I referred to in part 1 of this blog series, which is a legacy of both the history of commercial salt extraction and the natural processes that have created the two inland salt marshes. Historic ground subsidence is a matter of record and Dr Anthony Cooper, at the time a geologist with the British Geological Survey, warns in a paper reviewing the “geohazards” associated with the erosion of rock salt deposits, that “further subsidence may occur” as “only about 10% of the volume of salt removed … has been accounted for by recorded subsidence” (see footnote 17).

The IPR for HS2 Phase 2a (Route C), coloured dark green, cuts across the north-eastern corner of the large area that is marked as being “prone to some salt dissolution subsidence” on the BGS map that I have reproduced above. This potentially problematic traverse is in contrast with the much safer original first choice route, Route B (coloured light green), which avoids the subsidence-prone area altogether: it is extremely unlikely that this increased risk factor, and the consequential engineering expenses of overcoming the subsidence risk, was taken into account when the additional £154million cost of Route C was calculated by HS2 Ltd.

Footnotes:

  1. The site reference in the Staffordshire Ecological Record is 92/84/70. The Ecological Site Report is not currently available on the internet.
  2. Site of Biological Importance is a non-statutory designation used locally by the Greater Manchester, Cheshire and Staffordshire County Councils to protect locally valued sites of biological diversity, which are described generally as Local Wildlife Sites by the UK Government.
  3. Although Lionlodge Covert is not, of course, ancient woodland.
  4. The report notes that the “native Bluebell is at risk from being displaced” by the Hybrid Bluebell that occurs along the main access tracks “if it continues to spread”.
  5. For an explanation of the importance of this habitat type see part 1 of this blog series.
  6. See bullet point 1 under Section 7 (Cultural Heritage) 7.3.7 and 7.3.8 (Non-designated Assets) in the response to Question 3 in HS2 Phase 2a: West Midlands to Crewe Environmental Impact Assessment Report Response by Ingestre with Tixall Parish Council 7.11.2016 on the Council’s HS2 webpage.
  7. Breeding of Eurasian Curlew at the Ingestre/Tixall Salt Marsh is confirmed in a private email circular, dated 12thApril 2017, transmitted by the Deputy Chairman of the West Midland Bird Club.
  8. There was an overall UK decline in Eurasian Curlew population of 42 per cent between 1995 and 2008 and the UK is host to as much as 27 per cent of the world’s breeding curlews.
  9. According to Dan Brown, Conservation Adviser with RSPB Scotland – see the web article Curlew should be UK’s top conservation concern says RSPB Scotland, Royal Society for the Protection of Birds, 3rdDecember 2015.
  10. The map is a section of drawing LV-11-109 in the publication High Speed Two Phase 2a: West Midlands to Crewe Working Draft Environmental Impact Assessment Report Volume 2: Map book CA2: Colwich to Yarlet, HS2 Ltd, September 2016. I have rotated the axis of the map to comply with the north upwards presentation of all the other maps that have been used to illustrate this blog series.
  11. See paragraph 8.4.6 in the publication High Speed Two Phase 2a: West Midlands to Crewe Working Draft Environmental Impact Assessment Report Volume 2: Community Area report CA2: Colwich to Yarlet, HS2 Ltd, September 2016.
  12. See under 8.3.9 (Environmental Baseline – Existing baseline – Lionlodge Covert LWS) in the response to Question 3 in the response to the HS2 Phase 2a EIA by Ingestre with Tixall Parish Council.
  13. See Section 1 (Introduction) in HS2: Notes on costs and benefits from seeking a route change on the HS2 webpage of the Ingestre with Tixall Parish Council.
  14. See bullet point 1 under Section 7 (Cultural Heritage) 7.3.7 and 7.3.8 (Non-designated Assets) and 10.3.38, 10.3.39 together with 10.4.21 (Environmental baseline – Mining/mineral resources – Halite deposits) under Section 10 (Land quality) in the response to the HS2 Phase 2a EIA by Ingestre with Tixall Parish Council.
  15. See 10.3.38, 10.3.39 together with 10.4.21 (Environmental baseline – Mining/mineral resources – Halite deposits) under Section 10 (Land quality) in the response to the HS2 Phase 2a EIA by Ingestre with Tixall Parish Council.
  16. This map was provided in private correspondence dated 29thJanuary 2014 between the BGS (Dr Vanessa Banks) and Ingestre with Tixall Parish Council (Cllr Michael Woodhouse).
  17. The paper is Cooper A H, Halite karst geohazards (natural and man-made) in the United Kingdom, Environmental Geology Volume 42, Issue 5, pp505-512, August 2002.

Acknowledgements:

I am very grateful to Cllr Michael Woodhouse of Ingestre with Tixall Parish Council for hosting and guiding my fact-finding visit to Ingestre, providing background information and copies of unpublished documents, checking the factual content of this blog, and for his helpful suggestions for improvements.

The Ordinance Survey mapping upon which the HS2 Ltd route design and subsidence areas have been overlaid has been reproduced in accordance with the principles of fair dealing as set out in the Copyright, Designs and Patents Act 1988.  On this basis, this mapping is:

Reproduced by permission of Ordnance Survey on behalf of HMSO.

© Crown Copyright. All rights reserved.

A stab in the dark, part 4

(… continued from A stab in the dark, part 3, posted on 2 Jul 2017).

I concluded the previous posting with the accusation that the HRA Screening Report for Pasturefields Salt Marsh has not attained the standard of proof required by the Waddenzee judgment, specifically that “no reasonable scientific doubt remains” that constructing HS2 on a southern route past the Pasturefields Salt Marsh SAC will have no adverse effects on the SAC. In this part I will explain my reasons for holding this view.

In the first place the authors of the HRA Screening Report were either unaware, or chose to ignore, potentially significant evidence that may indicate that the catchment area for the saline water that feeds the Pasturefields Salt Marsh extends further southwards than is envisaged in that report. This evidence is the existence of the Ingestre/Tixall Salt Marsh (also known as Lionlodge Covert), which is located just under one kilometre south of Pasturefields, as shown on the map reproduced below.

Source: Ingestre with Tixall Parish Council

The present extent of the saltmarsh, part of the Lionlodge Covert Site of Biological Importance (SBI) designated by Staffordshire County Council (see footnote 1), is indicated by the red hatching. The red star just above that is the still-active salt spring that feeds the saltmarsh, which is known as Salt Spring Pool. The yellow area is the extent of the saltmarsh before it was drained by the open ditches and culverts (known and suspected) shown by blue lines (broken lines for culverts). The near-horizontal black line that cuts through the saltmarsh is HS2 Route C. The orange area with a blue duck on it, is the Pasturefields SAC.

I don’t think that you need to be a hydrogeologist to spot that there may be a connection between the saline sources that are feeding the Ingestre/Tixall Salt Marsh and the Pasturefields Salt Marsh, and that the proposed construction of an embankment to carry HS2 across the former might just affect the health of both. Whether or not this proves to be the case, it is surely negligent to present a screening report that fails to take account of the possibility.

Fortunately, we don’t have to rely on our own instincts, because expert opinion is near to hand. The Ingestre with Tixall Parish Council has recently commissioned Envireau Water, a specialist hydrogeological consultancy, to review the hydrogeology of Pasturefields Salt Marsh SAC and Ingestre/Tixall Salt Marsh SBI.

The lead author of the Envireau Water report, James Dodds (see footnote 2), whilst noting that there “remains significant uncertainty relating to groundwater flow paths in the area due to a lack of groundwater level data” (see footnote 3) is clearly not convinced by the assertion in the HRA Screening Report for Pasturefields Salt Marsh that “there are not predicted to be any saline groundwater flows from the west or south of the site to the Pasturefields Salt Marsh SAC” (see footnote 4).

The Envireau Water report postulates a totally different mechanism for the source of the saline water that gives rise to the two salt marshes. It identifies a “fractured zone associated with the Tixall Fault” (see footnote 5) and considers it “likely that the saline groundwater seepages/springs at both Pasturefields Salt Marsh SAC and Ingestre/Tixall Salt Marsh SBI have a common source and groundwater catchment, associated with the Tixall Fault”. The report adds that “any impact to the groundwater along the trajectory of the Tixall Fault has the potential to impact groundwater seepages/springs at both Pasturefields Salt Marsh SAC and Ingestre/Tixall Salt Marsh SBI” (see footnote 6).

The report identifies two aspects of Route C that could cause such an effect: that piling associated with the HS2 railway embankment to be built across the Ingestre/Tixall Salt Marsh will “intersect high permeability fracture zones associated with the Tixall fault; and, that the proposed Brancote South cutting will have a severe adverse impact on the local water table, thus reducing the artesian pressure head which almost certainly drives the brine springs (see footnote 7).

This intervention alone should be enough to convince any independent observer that the HRA Screening Report for Pasturefields Salt Marsh does not achieve the degree of certainty that is required by the Waddenzee judgment, but the Ingestre with Tixall Parish Council has also received advice from the British Geological Survey (BGS). The Parish Council asked the BGS to review the HRA Screening Report for Pasturefields Salt Marsh. The BGS notes the lack of “baseline data” available to the authors of that report and comments that “it is hard for anyone to predict the potential impact of the proposed HS2 construction along any of the proposed alignments” and suggests that “an alternative conceptual ground model should be considered looking at the wider area from which brine has been derived” (see footnote 8).

Armed with this formidable evidence that the HRA Screening Report for Pasturefields Salt Marsh is deficient, the Ingestre with Tixall Parish Council has sought, through correspondence and meetings with HS2 Ltd to seek a recasting of the document, but have encountered a stonewall. Statute limits what a local council can spend in the furtherance of such disputes (see footnote 9), but the Council’s webpage indicates the intention to launch an independent fund-raising campaign to allow the matter to be pursued through the courts, if necessary (see footnote 10).

In this respect, it should be noted that Article 9 of the Aarhus Convention requires that “members of the public have access to administrative or judicial procedures to challenge acts and omissions by private persons and public authorities which contravene provisions of its national law relating to the environment” and that the employment of such procedures should be “not prohibitively expensive” (see footnote 11), although the Aarhus Convention Compliance Committee has recently determined that the European Union, and some of its member states (including the United Kingdom), fail to comply with their Article 9 obligations (see footnote 12).

(To be concluded …)

Footnotes:

  1. Site of Biological Importance is a non-statutory designation used locally by the Greater Manchester, Cheshire and Staffordshire County Councils to protect locally valued sites of biological diversity, which are described generally as Local Wildlife Sites by the UK Government. The designation for the Ingestre site covers two sub-sites: the woodland area of Lionlodge Covert, and the inland saltmarsh area referred to above as the Ingestre/Tixall Salt Marsh.
  2. James Dodds MSc CGeol FGS is Managing Director of Envireau Water and is a Chartered Geologist with some thirty years’ experience of hydrogeological consulting.
  3. See Section 7 in the report Hydrogeological Conceptualisation of Pasturefields Salt Marsh SAC & Ingestre/Tixall Salt Marsh SBI Great Haywood Staffordshire, Envireau Water for Ingestre with Tixall Parish Council, June 2017. The text of this report is reproduced on the Ingestre with Tixall Parish Council website under the heading Hydrogeological Assessment by Envireau Water (but the original pagination has not been retained).
  4. See paragraph 3.6.2 in the unpublished HS2 Phase 2 HRA Screening Report for Pasturefields Salt Marsh.
  5. According to the Envireau Water report, the Tixall fault runs “alongside Ingestre/Tixall Salt Marsh” and “may extend a further 2km to the northeast beyond the village of Hixon … and therefore also runs alongside Pasturefields Salt Marsh SAC”. See Section 3 on page 4 of the report Hydrogeological Conceptualisation of Pasturefields Salt Marsh SAC & Ingestre/Tixall Salt Marsh SBI Great Haywood Staffordshire.
  6. See Section 3 on page 5 of the report Hydrogeological Conceptualisation of Pasturefields Salt Marsh SAC & Ingestre/Tixall Salt Marsh SBI Great Haywood Staffordshire.
  7. See Sections 4.1 and 4.2 on pages 5 and 6 of the report Hydrogeological Conceptualisation of Pasturefields Salt Marsh SAC & Ingestre/Tixall Salt Marsh SBI Great Haywood Staffordshire.
  8. The quotes are taken from the Conclusions section of private correspondence dated 29th January 2014 between the BGS (Dr Vanessa Banks) and Ingestre with Tixall Parish Council (Cllr Michael Woodhouse).
  9. Section 137 of the Local Government Act 1972 allows a local council to “incur expenditure which in their opinion is in the interests of, and will bring direct benefit to, their area or any part of it or all or some of its inhabitants” for purposes for which they do not have specific statutory powers. The total sum that may be spent under Section 137 in the year 2017-18 is limited to £7.57 per head of population of the administrative area of the council.
  10. See the section 4 What if HS2 Ltd resist? On the HS2 webpage of the Ingestre with Tixall Parish Council.
  11. See paragraphs 3 and 4 of Article 9 of the document Convention on access to information, public participation in decision-making and access to justice in environmental matters, United Nations Economic Commission for Europe, Aarhus Denmark, 25thJune 1998.
  12. See the document Findings and recommendations of the Compliance Committee with regard to communication ACCC/C/2008/32 (Part II) concerning compliance by the European Union, Aarhus Convention Compliance Committee. 17thMarch 2017.

Acknowledgements:

I am very grateful to Cllr Michael Woodhouse of Ingestre with Tixall Parish Council for hosting and guiding my fact-finding visit to Ingestre, providing background information and copies of unpublished documents, checking the factual content of this blog, and for his helpful suggestions for improvements.

The Ordinance Survey mapping upon which the HS2 Ltd route design and details of the saltmarsh have been overlaid has been reproduced in accordance with the principles of fair dealing as set out in the Copyright, Designs and Patents Act 1988.  On this basis, this mapping is:

Reproduced by permission of Ordnance Survey on behalf of HMSO.

© Crown Copyright. All rights reserved.

A stab in the dark, part 3

(… continued from A stab in the dark, part 2, posted on 28 Jun 2017).

In September 2016 HS2 Ltd published the draft Environmental Impact Assessment (EIA) for HS2 Phase 2a (West Midlands to Crewe). This document identifies three routes past Pasturefields Salt Marsh SAC as having been considered, and these were depicted in a figure in an appendix to the EIA, from which the following map has been extracted (see footnote 1):

Source: HS2 Ltd

The three routes discussed in the draft EIA, reading from north to south, are:

  1. Route B, passing to the north of the Pasturefields Salt Marsh SAC and depicted in red on the map, which the HS2 Ltd HRA Screening Report has assessed and has concluded requires an appropriate assessment to be carried out.
  2. Route HSM1, now referred to as Route A, passing south of the Pasturefields SAC and coloured blue on the map, which the HRA Screening Report has assessed and has concluded does not require an appropriate assessment to be carried out.
  3. A route that was not assessed in the HRA Screening Report, identified in the draft EIA as Route C and coloured brown on the map. Although not specifically assessed by the HRA Screening Report, the inference of that report is that no appropriate assessment will be required for this route, since it passes south of the Pasturefields SAC at a greater distance than Route A (see footnote 2).

By this stage the other route that had been assessed in the HRA Screening Report, HSM2, had been dropped from the alternatives under discussion.

Despite three route options being discussed in the draft EIA, it is clear that HS2 Ltd had, for some time, been settled on one of them, as Route C had been selected for the Initial Preferred Route (IPR) that was announced in January 2013, and subjected to public consultation between July 2013 and January 2014. It is clear from the discussion in the draft EIA that a key factor driving this choice was the HRA Screening Report conclusion that an appropriate assessment would not be required for this route (see footnote 3).

The appropriate assessment procedure is described in the HRA Screening Report as “a very stringent process with often demanding requirements to be met” (see footnote 4) and in the draft EIA as “involving considerable ground investigation work potentially over a number of years to investigate and assess potential impacts on the integrity of the internationally important SAC” (see footnote 3).

Route C was chosen despite being considerably more expensive, to the tune of at least £154million, than the putative “best performing route” (Route B). In his submission to the HS2 Phase Two Route Consultation the local Member of Parliament Jeremy Lefroy comments that it is “not known why HS2 wishes to avoid an Appropriate Assessment although it is speculated that the time taken [to carry out the assessment] is a consideration”. Mr Lefroy opines that “it is extraordinary both to incur so much additional cost to the taxpayer and to cause such a devastating impact on the village communities [of Ingestre, Hopton and Marston, that lie in the path of Route C] simply to avoid an Appropriate Assessment” (see footnote 5).

Mr Lefroy also raises the question of whether switching to Route C legitimately avoids the need for an appropriate assessment. In considering this point, it helpful to recognise the Waddenzee judgment made by the European Court of Justice (see footnote 6). This judgement has implications for the standard of proof that HRA screening must achieve, and these have been conveniently summarised in a government publication, which makes clear that a competent authority must be “certain” that there will be no adverse effects on the conservation site. In this respect, the publication explains that certainty requires that “no reasonable scientific doubt remains as to the absence of such effects” and requires that competent authorities must be “convinced” that there will be no adverse effects (see footnote 7).

There are substantive grounds for holding the view that the HRA Screening Report for Pasturefields Salt Marsh has not attained the standard of proof required by the Waddenzee judgment, and I will investigate these grounds in my next posting.

(To be continued …)

Footnotes:

  1. The map that has been reproduced is an inset of Figure 10 on page 69 of the publication High Speed Two Phase 2a: West Midlands to Crewe Working Draft Environmental Impact Assessment Report Volume 1 appendix: Alternatives report, HS2 Ltd, September 2016.
  2. See paragraph 9.1.1 in the unpublished HS2 Phase 2 HRA Screening Report for Pasturefields Salt Marsh, Environmental Resources Management (ERM) for HS2 Ltd, September 2012, which concludes that “other route options were they to follow a similar southern alignment past Pasturefields Salt Marsh SAC at a similar or greater distance from the SAC” do not require an appropriate assessment.
  3. See paragraph 4.3.8 in the draft EIA alternatives report.
  4. See paragraph 1.1.3 in the unpublished HS2 Phase 2 HRA Screening Report for Pasturefields Salt Marsh.
  5. The quotes that I have attributed to Mr Lefroy may be found on page 9 of the document High Speed Rail 2 (Phase Two) Response to the Phase Two Route Consultation, Jeremy Lefroy MP, January 2014.
  6. See the judgement in Case C-127/02, Landelijke Vereniging tot Behoud van de Waddenzee and Nederlandse Vereniging tot Bescherming van Vogels v Staatssecretaris van Landbouw, Natuurbeheer en Visserij, European Court of Justice in Grand Chamber, 7th September 2004.
  7. See paragraph 21 in the document Government Circular: Biodiversity and geological conservation – Statutory obligations and their impact within the planning system, Office of the Deputy Prime Minister/ Department for Environment, Food and Rural Affairs, ODPM Circular 06/2005 and Defra Circular 01/2005, 16thAugust 2005.

Acknowledgements:

I am very grateful to Cllr Michael Woodhouse of Ingestre with Tixall Parish Council for hosting and guiding my fact-finding visit to Ingestre, providing background information and copies of unpublished documents, checking the factual content of this blog, and for his helpful suggestions for improvements.

The Ordinance Survey mapping upon which the HS2 Ltd routes are overlaid has been reproduced in accordance with the principles of fair dealing as set out in the Copyright, Designs and Patents Act 1988.  On this basis, this mapping is:

Reproduced by permission of Ordnance Survey on behalf of HMSO.

© Crown Copyright. All rights reserved.

 

 

A stab in the dark, part 2

(… continued from A stab in the dark, part 1, posted on 24 June 2017).

In an uncharacteristic manifestation of candour, HS2 Ltd has admitted that “the hydrological processes that support the salt meadows [of the Pasturefields Nature Reserve] are imperfectly understood” (see footnote 1). The same passage in the source document gives an indication of why this should be the case:

“The salt water is derived from natural deposits within the underlying rock and is carried to the site by groundwater. It is currently understood that the local topography and orientation of below ground geology cause the salt water to rise to the ground surface to form the springs at Pasturefields Salt Marsh SAC.”

The passage concludes by expressing the expectation that further work to improve the understanding of this complex hydrogeology “could involve some advance groundwater investigation if feasible and required”.

The Government has published guidance for planning authorities faced with applications for developments that may have the potential to impact upon internationally designated biodiversity and geological conservation sites. Under the terms of the legislation, any such authority is deemed a “competent authority” for the purposes of making a determination regarding the application. In the case of projects of national significance, such as HS2, the same rules apply but the competent authority will be the relevant Secretary of State, who is required to consult the appropriate statutory nature conservation body (SNCB). For HS2 this SNCB is Natural England (see footnote 2).

A set procedure is prescribed for the assessment of a project that may affect the integrity of a European site, known as “Habitat Regulations Assessment (HRA)”. This procedure has been conveniently described in a published flow chart, and comprises four stages. The initial stage is termed “screening” and is defined as (see footnote 3):

“The process to identify the likely impacts of a project upon a European site, either alone or in combination with other plans and projects, and consider whether the impacts are likely to be significant.”

It is the developer’s responsibility to undertake this screening process and to decide, for his proposal, whether there is “no potential likely significant effect on European sites, either alone or in combination with other plans or projects” or whether “an anticipated potential significant effect on European sites exists either alone or in combination with other plans or projects”. In either case, the developer will be required to furnish the competent authority with documentary evidence in support of his conclusions, in the form of a HRA screening report, in order that the competent authority may “in due course … be satisfied that it agrees with the developer’s conclusion” (see footnote 4).

If the HRA screening report concludes that there will be no potential likely significant effect, then the developer may append a “No significant effects report” to his HRA screening report and, subject to the competent authority concurring, “no further assessment is required”. If the HRA screening report concludes that an anticipated potential significant effect exists, then the HRA must proceed to Stage 2 “appropriate assessment” (see footnote 4). It should be noted that it is a key pillar of this decision process that the precautionary principle must apply in that “any project is to be subject to an appropriate assessment if it cannot be proven, beyond reasonable scientific doubt, that there is no significant effect on that site” (see footnote 5).

Considering its importance as environmental information concerning the protection of a conservation site within the Natura 2000 network, it is frankly beyond comprehension that HS2 ltd appears to have failed to make its HRA Screening Report for Pasturefields Salt Marsh publically available (see footnote 6). This failure to make environmental information freely available to the public is, at the very least, contrary to the spirit of the Aarhus Convention and is, arguably, also in contravention of the letter of that compact (see footnote 7).

The HRA Screening Report for Pasturefields Salt Marsh considers the anticipated potential significant effects that would result from three different route options as they pass its vicinity. These three route options, and their locations relative to the location of the salt marsh, indicated by a red star, are shown in the map that is reproduced below (see footnote 8).

Source: HS2 Ltd

The three routes that were screened by HS2 Ltd for the Stage 1 habitats regulation assessment are:

  1. The original first choice route, identified as HSM3 in the HS2 Ltd 2012 options report, but relabelled by me as “Route B” (see footnote 9). The section of this route that passes Pasturefields runs from south-east to the north-west of Pasturefields, and at its closest point is 300 metres to the north of the SAC.
  2. A more southerly alternative, identified as HSM1 in the HS2 Ltd 2012 options report. The section of this route corridor that passes Pasturefields runs from east to west to the south side of Pasturefields, and at its closest point is 650 metres to the south-west of the SAC.
  3. An option identified as HSM2 (or HSM02) in the HS2 Ltd 2012 options report. The section of this route corridor that passes Pasturefields runs from south-east to the north-west of Pasturefields, and at its closest point is 660 metres to the north of the SAC.

As it turned out, the route that was selected by HS2 Ltd for public consultation was none of the above, but used a fourth alignment running a little to the south of HSM1 (see footnote 10).

The conclusion drawn by the HRA Screening Report for Pasturefields Salt Marsh is that “it is not possible to conclude no likely significant effect in the basis of the information currently available for route options HSM02 and [Route B]” and, hence, “Appropriate Assessment would be required [if either of these routes were employed]”. The report adds that “due to the uncertainties which remain in relation to the underlying geology and route of the brine flow which feeds the Pasturefields Salt Marsh SAC, on-site intrusive investigations would be required to fully understand the groundwater and brine flows for either route” (see footnote 10).

If route HSM1 were to be employed, however, the report concludes that HS2 “would have no likely significant effect on the site as it is downstream of Pasturefields Salt Marsh SAC, outside of the surface water catchment of the River Trent at Pasturefields (and therefore the Pasturefields Salt Marsh SAC), and south of the SAC (downstream of the groundwater catchment of the SAC)”. The report determines that “Appropriate Assessment would therefore not be required for this route option as described”. A significant comment made in the report, for reasons that will become clear in part 3 of this blog series, is that the conclusion drawn by the report in regard to HSM1 applies equally to “other route options were they to follow a similar southern alignment past Pasturefields Salt Marsh SAC at a similar or greater distance from the SAC” (see footnote 12).

The report claims that “HS2 Ltd has undertaken regular consultations with NE [Natural England] and continues to do so”, with the implication that Natural England concur with the report’s conclusions. The report also advises that consultation “has also been undertaken with the Environment Agency (EA) in relation to hydrological matters” (see footnote 12).

Nevertheless, for reasons that I will explain in due course, I regard the report’s finding that HSM1, and similar southern routes, will have no significant effect on the Pasturefields Salt Marsh SAC as unsafe.

(To be continued …)

Footnotes:

  1. See Text Box 2 on page 48 of the report Options for phase two of the high speed rail network: A report to Government by HS2 Ltd, HS2 Ltd, 29thMarch 2012.
  2. See the sections Summary of this Advice Note on page 1 and the entry Secretary of State in the table Terms and abbreviations used in this advice note on pages 18 and 19 of the publication Advice note ten: Habitats Regulations Assessment relevant to nationally significant infrastructure projects, The Planning Inspectorate, Version 7thJanuary 2016.
  3. The flow chart is reproduced as Figure 1 on page 6 of Advice note 10 and the four stages are defined in Table 1 on page 3 of the same document. The definition of screening has been taken from Table 1.
  4. The quote phrases are all taken from the section Pre-application (no prescribed timeframe) on pages 12 and 13 of Advice note 10.
  5. See the section Background and legal context on page 2 of Advice note 10.
  6. A single paper copy of the HS2 Ltd HRA Screening Report was provided to a resident living close to Pasturefields in response to a freedom of information request, and I have been provided by that resident with a copy of that copy for the purposes of writing this blog series. The document citation is HS2 Phase 2 HRA Screening Report for Pasturefields Salt Marsh, Environmental Resources Management (ERM) for HS2 Ltd, September 2012.
  7. For example, see Article 7 of the document Convention on access to information, public participation in decision-making and access to justice in environmental matters, United Nations Economic Commission for Europe, Aarhus Denmark, 25th June 1998.
  8. The reproduced map is an enlarged section of the map on page 16 of the publication Options for Phase 2 of the high speed network Appraisal of Sustainability, Environmental Resources Management (ERM) for HS2 Ltd, March 2012. In the main text of my blog I have referred to this report as the “HS2 Ltd 2012 options report”.
  9. I have made this change to avoid the confusion that HS2 Ltd has caused by reusing the route designation HSM3 for the route eventually selected for public consultation, which runs further to the south of HSM1. This confusion is referred to by the local MP in the first paragraph on page 9 of the document High Speed Rail 2 (Phase Two) Response to the Phase Two Route Consultation, Jeremy Lefroy MP, January 2014.
  10. I will include a map showing the alignment of this consultation route in part 3 of this blog series.
  11. See paragraph 9.1.2 in the unpublished HS2 Phase 2 HRA Screening Report for Pasturefields Salt Marsh.
  12. See paragraph 9.1.1 in the unpublished HS2 Phase 2 HRA Screening Report for Pasturefields Salt Marsh.
  13. See paragraph 2.2.1 in the unpublished HS2 Phase 2 HRA Screening Report for Pasturefields Salt Marsh.

Acknowledgements:

I am very grateful to Cllr Michael Woodhouse of Ingestre with Tixall Parish Council for hosting and guiding my fact-finding visit to Ingestre, providing background information and copies of unpublished documents, checking the factual content of this blog, and for his helpful suggestions for improvements.

The Ordinance Survey mapping upon which the HS2 Ltd routes are overlaid has been reproduced in accordance with the principles of fair dealing as set out in the Copyright, Designs and Patents Act 1988.  On this basis, this mapping is:

Reproduced by permission of Ordnance Survey on behalf of HMSO.

© Crown Copyright. All rights reserved.

 

A stab in the dark, part 1

One of the few benefits that I have gained from my own personal Don Quixote crusade against HS2 is that it has got me back into the learning process in a big way. Virtually every day, it seems, I have delved into some new facet of one of the disciplines touched by the project, and have boldly – or perhaps foolishly – sallied into intellectual territory new to me. Of course, it is so easy to do this today, with the internet holding a library of information of truly global proportions, and with that miracle of cyber technology, the search engine, affording instant access to even the most esoteric recesses of human intellectual endeavour.

But I’m afraid that, as I am prone to, I am digressing: the point I am meandering towards is that a new snippet of information that came my way recently in the course of my researches is that Staffordshire was once a centre of salt production. Whilst the salt extraction industry in Staffordshire never approached anything like the scale of its neighbour Cheshire’s level of production, it made, nevertheless, an important contribution to the County’s economy from its beginnings in the 17th century up to as recently as August 1970, when all industrial production of salt ceased.

The industry has left its mark in some of the place names of the County: there is even a village called Salt, and other names including the word can be found, such as Salt Brook, Saltwell, Salterford and Salter’s Bridge. As is the case in Cheshire, the termination “wich” can also indicate places associated with the salt industry.

In Staffordshire salt was obtained by the open-pan evaporation of brine taken from below ground, a process that is facilitated by naturally-occurring underground brine streams. These streams serve to erode the deposits of salt, leading to geological instability, and also break through to the surface in places as salt springs, leading to the formation of the rare inland salt marsh habitat. Unsurprisingly, this habitat supports salt-tolerant, or halophyte, plants, which form an exceptionally specialised group containing, perhaps, around 2 per cent of all plant species. In the United Kingdom the conditions that lead to the formation of inland salt marsh are confined to the salt-producing counties of Cheshire, Staffordshire and Worcestershire. Salt extraction and land reclamation have degraded and reduced the amount of this habitat over recent centuries, although the activities of the salt industry have also resulted in the creation of similar conditions around old brine pits and workings. The rarity of natural inland salt marsh has resulted in it being listed as a priority habitat in Annex 1 to Directive 92/43/EEC of the EU Council (see footnote 1).

According to the Joint Nature Conservation Council “Pasturefields Salt Marsh in the West Midlands is the only known remaining example in the UK of a natural salt spring with inland saltmarsh vegetation” (see footnote 2). For this reason this site, which lies about 5 miles north east of Stafford, has been granted Special Area of Conservation (SAC) status (see footnote 3).

Inconveniently for HS2 Ltd, Pasturefields occupies an area that is sandwiched between the River Trent and the Trent and Mersey Canal: it is inconvenient because, what HS2 Ltd clearly regards as the optimum route for its link up to Crewe, broadly following the valley of the River Trent as it passes to the east of Stafford, whilst not actually impinging directly upon the above-ground extent of the nature reserve, does pass close enough to ring alarm bells about possible, or even likely, impacts upon the hydrogeology. Any such changes in hydrogeology caused by HS2 may consequently directly impact upon the nature reserve by affecting the flow of brine.

Unlike other areas of important habitat along the route of HS2, the protection offered to Pasturefields by Directive 92/43/EEC and the UK’s commitments to the Natura 2000 network means that HS2 Ltd cannot blithely ignore any damage that its project may cause to the SAC. Indeed, the organisation’s response has been at the highest level of the mitigation hierarchy, opting to “avoid” the damage by realigning the route approximately one and three-quarter kilometres southwards, at considerable additional cost (see footnote 4).

You probably think that I should be overjoyed at this apparent victory for environmental protection legislation. Well I would be, but I’m not sure that the HS2 Ltd has demonstrated to any reasonable degree of doubt that this realignment really will avoid any impacts on the SAC, and am suspicious that project expediency has been the driver of the solution that has been proposed, rather than sound science.

In the remaining parts of this blog series I will explain why I think this.

(To be continued …)

Footnotes:

  1. In Annex 1 the habitat type is identified as “Continental salt meadows”, with the Corine code 15.14, on page L 206/16 of Council Directive 92/43/EEC of 21 May 1992 on the conservation of natural habitats and of wild fauna and flora, Official Journal of the European Communities.
  2. See the webpage for this site on the Joint Nature Conservation Council website. There is, in fact, another remnant of spring-fed salt marsh just south of Pasturefields, but this has only been afforded Local Wildlife Site (LWS) status.
  3. A Special Area of Conservation (SAC) is an area of habitat of a type listed in Annex 1 to Directive 92/43/EEC that is proposed by an EU Member State as a component site of the European ecological network known as Natura 2000, as required by the provisions of Article 4 of that Directive. A SAC that is an area of priority habitat is afforded protection from damage from development, except in the very exceptional circumstances permitted by Article 6(4), which requires that:
    “Where the site concerned hosts a priority natural habitat type and/or a priority species, the only considerations which may be raised are those relating to human health or public safety, to beneficial consequences of primary importance for the environment or, further to an opinion from the Commission, to other imperative reasons of overriding public interest.”
  4. The additional cost of the more southerly route is quoted by Jeremy Lefroy, the local MP, at £154million on page 9 of the document High Speed Rail 2 (Phase Two) Response to the Phase Two Route Consultation, Jeremy Lefroy MP, January 2014. However, Appendix A to that document, which is a paper presented on behalf of Ingestre with Tixall Parish Council, describes this figure, on page 22, as “almost certainly an underestimate”.

 

Private fears in public places, part 3

(… continued from Private fears in public places, part 2, posted on 16 Jun 2017).

In his Modern Railways article HS2’s Conventional Compatible Conundrum the magazine’s Industry and Technology Editor, Roger Ford, quotes in full a response provided by Lord Ahmad of Wimbledon, Parliamentary Under-Secretary at the Department for Transport (DfT), to a written answer tabled by the “indefatigable” Lord Berkeley (see footnote 1). Although the response is rather long, I shall follow Mr Ford’s example in quoting it in full, and also include the original question for good measure.

Lord Berkeley (Labour): To ask Her Majesty’s Government, further to the Written Answer by Lord Ahmad of Wimbledon on 9 March (HL5562), what assessment they have made of advice from SNCF quoted in the March edition of Railway Gazette International that operating above 320 km/h incurs significantly higher track maintenance costs.

Lord Ahmad of Wimbledon: HS2 Ltd has collaborated with several high speed rail Infrastructure Managers, including SNCF, to ascertain the implications of running trains at 360km/h.

Using recommendations based on experiences of managing High Speed Lines in Europe, HS2 Ltd intends to incorporate specific components in the track design which will improve the system performance whilst utilising an Infrastructure Management System that determines asset performance and condition at all times.

The combination of these factors and the use of innovative maintenance activities, that go beyond current best practice, should reduce the maintenance implications of running at these speeds.

Mr Ford’s reactions to this apparent show of characteristic DfT hubris is to remark, with obvious irony, that “HS2 is going to show SNCF how high-speed infrastructure should be built and maintained”. He also picks up on the reference to “good old innovation”, which he describes as “the last refuge of a bullshitter”.

He also points out that the “the pre-qualification technical summary for the new fleet … notes that the anticipated maximum speed (360km/h) exceeds the technical scope of the relevant locomotives and passenger rolling stock (LOC&PAS) Technical Specification for Interoperability, which is 350km/h” (see footnote 2). This means, Mr Ford tells us that “TSI-compliant equipment will not meet the HS2 specification” and he foresees potential difficult contract negotiations resulting.

The reference to higher energy costs in the SNCF comment about the disadvantages of operating at the higher speed of 360km/h that I quoted in part 2 is also picked up by Mr Ford. He points out that “running at 360km/h rather than 300km/h increases power consumption of a 200m-long train by around 3 Mega-Watts, or 70%”. A fairer comparison, since the journey time is less at the higher speed, is provided by a table that compares the energy required to travel 100 km at different speeds (see footnote 3), but even this shows that 38 per cent more energy is required at 360km/h than at 300km/h.

Mr Ford accuses the DfT of avoiding this issue of increased energy costs in the written answer that I quoted at the head of this posting: that’s a bit unfair since Lord Berkeley asked about track maintenance, not energy, costs, but I would agree with Mr Ford that energy consumption is an issue that the DfT/HS2 Ltd has signally failed to address, in general.

Mr Ford describes the rigid adherence to 360km/h by DfT/HS2 ltd as “a shibboleth rather than a rational technical and commercial choice” (see footnote 4) and I feel that there is an element of that, particularly amongst senior technical personnel, who appear to want to hold on to the accolade of building the fastest railway in Europe. I also feel, however, that another written answer that he quotes in his article reveals perhaps the strongest motiving factor which is that any savings to be made from lowering the maximum linespeed “are more than offset by the significant loss in revenue and user benefits” (see footnote 5). It seems that even a modest loss in user benefits will be significant, since the business case is so highly geared to the value of passenger time savings.

One other issue that Mr Ford crams into his article is the requirement that HS2 conventional compatible very high speed trains (“CCVHSTs”) should fit within the classic UK loading gauge, rather than the larger GC gauge. He opines that “putting the traction power needed for 360km/h into the national network loading gauge is going to be a mite difficult” (see footnote 6).

I must say that after reading Mr Ford’s article it is clear to me that two simple steps could allow a whole cart-load of cash to be saved. Firstly, drop the linespeed to 320km/h, as he suggests, and secondly make the decision only to buy CCVHSTs for HS2 an all-time one. Since we are leaving the European Union anyway, why be shackled by European standards for our national infrastructure? Just think how much money could be saved by dropping the requirement for HS2 to be engineered to GC gauge.

Good eh? But then those clever chaps behind HSUK have already thought of both of those wheezes (see footnote 7).

All in all, I think that Mr Ford has produced a terrific article, and we are promised more of the same next month. I can’t wait – it might even be worth splashing out on a copy of the magazine.

Footnotes:

  1. See House of Lords Department for Transport written question HL6073, answered on 23rdMarch 2017.
  2. See Section 6.2 in document reference HS2-HS2-RR-SPE-00000006, Pre-Qualification Technical Summary, HS2 Ltd, 21stApril 2017.
  3. See Table 2 on page 10 of the report Carbon Impacts of HS2: Factors affecting carbon impacts of HSR, Systra for Greengauge21, 28thNovember 2011.
  4. A shibboleth is defined in the Oxford English Dictionary as “a custom, principle, or belief distinguishing a particular class or group of people, especially a long-standing one regarded as outmoded or no longer important”.
  5. See House of Lords Department for Transport written question HL5185, answered on 14thFebruary 2017.
  6. I reported another problem associated with CCVHST design, low-noise pantograph realisation, in my blog Checking the shopping list (posted 23 May 2017).
  7. At least I think that a reduced linespeed is proposed, but I haven’t been able to find confirmation of this in the HSUK promotional material.