Never mind the details

Environmental aspects of the 51m consultation response, part 1

The response to the public consultation on HS2 by the 51m alliance of local authorities includes a critique of the Appraisal of Sustainability (AOS), in Appendix 13, and a response to Question 6, which invited comments on the AoS. This AoS is a mammoth document prepared for HS2 Ltd by consultants Booz & Co and Temple Group. It has been some time since I discussed the AoS in my blogs, back in March as a matter of fact. I was, if you will excuse the pun, fairly “green” in those days and so I was keen to find out how my naïve and amateur views matched up to the professional opinion expressed in the 51m document.

I say “professional” with some justification. Appendix 13 was authored by Ian Thynne who is Principal Sustainability Officer for the London Borough of Hillingdon. Ian is a qualified planner with fifteen years experience within the environmental sector.

One of the chief criticisms that the 51m response levels at the AoS is that the assessment of the environmental impact has not been detailed enough. This was a point that Cllr. Martin Tett mentioned in his speech at Aylesbury that I have quoted from in my blogs of 2 Sep and 6 Sep.

“And the Department for Transport has reneged on a firm commitment that they made to us at a meeting to produce what is called a ‘full environmental impact assessment’ prior to the public consultation. They promised us that because it would expose all of the environmental impacts. Instead they produced what is called an ‘Appraisal of Sustainability’. Do not be fooled; that is not an environmental impact assessment. It is a much, much lower grade of assessment. It actually is a desk study. It has involved no field work and it mainly focuses on development along the route rather than the impact upon the environment.”

Even Hs2 Ltd appears to concede this point; paragraph 4.7.1 on page 34 of Volume 1 of the AoS (available here) says:

“The AoS is a high level appraisal devised in large part to support the development of scheme options. Any impacts identified by it and reported here should be viewed as provisional at this stage. Further more detailed design work would be carried out in due course on the proposed scheme and on any changes to it that are secured through consultation during 2011.”

Using the AoS for its prime purpose to “support the development of scheme options” is not being questioned. What is in dispute is whether this document was suitable to inform the public consultation.

Ian Thynne makes a further charge in this respect in Appendix 13 to the 51m consultation response.

“The AoS was not developed in consultation with local authorities who are public authorities with key environmental, social and economic responsibilities. The project has therefore been progressed without their input. Partly as a consequence, the AoS has only considered regional and national impacts and virtually no local impacts have been considered. This means that the impacts on local features such as nature reserves, landscapes and settings, employment areas and waste sites are all ignored. The AoS is therefore not an accurate (or informative) portrayal of all the sustainability impacts and thus HS2 is likely to have much more of negative impact than that already acknowledged.”

Now I have to confess that in my aforementioned state of ignorance I did not latch on to this omission when I discussed the AoS in March. I should have done; it is a fairly significant failing, but Ian Thynne goes further:

“Even in respect of regional and national assets, the AoS does not adequately set out the specific areas that have been considered in the appraisal. It does not provide a list of all the sites that have been designated as regional or national assets. As a consequence it is not possible to fully appraise the HS2 assessment even at this very high level.”

Ian Thynne makes the charge that the AoS is “not an accurate (or informative) portrayal of all the sustainability impacts and thus HS2 is likely to have much more of negative impact than that already acknowledged.” So the AoS is a document that purports to appraise the environmental, social and economic impacts of HS2, but clearly fails to do this adequately or accurately as it hasn’t considered all of the “evidence”.

Ian Thynne also complains of “the difficulties in scrutinising the AoS, which in turn makes the Consultation process quite meaningless.”

I think that we all have the right to feel that we have been “short changed” in the public consultation on HS2 to the extent that the full environmental, social and economic impacts of the proposal have not been adequately assessed. Thanks a bundle Mr Hammond!

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