There must be a better way

Environmental aspects of the 51m consultation response, part 2

(It’s hardly of earth-shattering significance, but I think that it is appropriate to record that this is my fiftieth blog. Who knows maybe I’ll carry on to my century, maybe not. At the moment I am finding no shortage of topics to comment on.)

“The AoS has only been carried out for one rail option, rather than as a comparative assessment of different options. The process by which the proposed route has been defined has not been carried out in an open and transparent way. By not undertaking a comparative high level assessment of the alternatives to HS2 and the proposed route, it is not possible to determine whether the scheme is the most sustainable way to meet the purported ‘need’. The assessment highlights a range of negatives with the proposed routes and it is therefore essential to carry out a more rigorous assessment to determine whether alternatives are more sustainable.”

There are the words of Ian Thynne in Appendix 13 to the response to the public consultation on HS2 submitted by the 51m alliance. Now I’m pleased to say that I latched on to this shortcoming when I blogged about the Appraisal of Sustainability in March (Does it actually mean anything? posted 18 Mar). I said then:

“If sustainability appraisal is truly to be a tool designed to move our economy towards sustainable development, it must be placed at the very heart of the decision making process and be used from the very inception of a project. It should be employed to evaluate the environmental effects of alternatives to a ‘preferred’ option on an equal footing, not just to compare one solution with a ‘do nothing’ scenario. Selecting a single option for evaluation implies a prejudgement of the outcome.

“Alternatives must be genuinely and radically different ways of achieving the desired economic aims, even if the economic advantages of alternatives are judged to be less. Solutions that are just tinkering with the details of a single option are no substitute for genuine alternatives. It should be part of the sustainability appraisal to weigh the different economic, social and environmental pros and cons of each alternative.

“Sustainability appraisal must be capable of ruling out a preferred option on environmental grounds, if the environmental impacts are judged to be too great. Any process that merely serves to enforce a prejudged choice is misleading and totally pointless.”

In its response to Question 6 of the public consultation, the 51m alliance says:

“The AoS has not been properly carried out or consulted upon with regard to the other alternatives, such as improving the capacity of existing rail services. This is fundamental to any proper sustainability assessment. It is therefore not possible for the public to have an understanding of the sustainability performance of the alternative options. HS2 Ltd has assessed the proposed route as having considerable negative impacts. This makes it even more important to provide an understanding of why the proposed route is being promoted ahead of the other options.”

It is shameful, particularly in light of the recommendation of the McNulty report that “there needs to be a renewed focus on making better use of existing capacity”, that the Government has not put forward a serious proposal for an alternative to HS2 based upon making best use of the existing rail infrastructure. The work of the 51m alliance has shown, in its “optimised alternative” proposal, that such an alternative solution is not hard to find.

This alternative should certainly have been considered in the AoS, where it would surely have been shown to have far less environmental and social impact than HS2. If this had proved to have the case then it should have been sponsored by the Government as an alternative to HS2 in the documentation produced to support the public consultation.

It is time that the Government swallowed its pride, admitted that it was wrong not to have done this and took steps to redress this misjudgement.

Footnote: The McNulty Report, published in May 2011, was the outcome of an independent study chaired by Sir Roy McNulty and commissioned by the Secretary of State for Transport. It was tasked “to examine the opportunities and barriers to improve the value for money of GB rail for taxpayers, passengers and freight customers.” It may be downloaded, in full or summary versions, here.


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