Things can only get better

Environmental aspects of the 51m consultation response, part 6

“The published AoS resembles an initial statement of the high level sustainability performance of HS2. It would normally be expected that a further stage would be completed to demonstrate how the negative impacts can or will be reduced, before any decision to proceed with the project would be made. Instead the AoS is a free standing document that commits HS2 Ltd to no mitigation at the design stage. This undermines the purpose of asking for people’s opinion on the outcome of the AoS.”

These words of Ian Thynne in Appendix 13 of the response to the HS2 public consultation by the 51m alliance (available here) summarise the point that our discussion on the sustainability performance of HS2 had reached at the conclusion of my previous blog (What next? posted 30 Sep). The “further stage” that Ian refers to is a clear identification of mitigation measures to be employed to offset the negative impacts of HS2.

Now assuming that stubbornness prevails over common sense and the project is given the go-ahead, then mitigation has a potentially large contribution to make. I can illustrate this with an example from just south of where I live in Cubbington, Warwickshire. About seven kilometres further down the proposed route from us towards London, Long Itchington and Ufton Woods crown the summit of a hill. This is a Site of Special Scientific Interest (SSSI) and so rates as a “national asset”; accordingly the impact of HS2 of this site has been considered for the work that has gone into the current version of the AoS. The result is that, right from the first published version of Route 3, a tunnel bored under the Woods has been proposed.

Now there is a dispute with the locals here about the length of the tunnel, but I think we can conclude that, subject to a survey of the local hydrology, this proposal will protect the Woods from harm and is, therefore, a good example of how mitigation can improve the project’s sustainability ratings.

The problem is, of course, that such measures are expensive and there will be a limit as to how far HS2 Ltd is prepared to go in providing mitigation. There is also a real fear that there will be a temptation to “cut corners”; take for example my worry that noise barriers will be undersize (refer to A little bit of magic, posted 17 May).

The other problem is that details of the mitigation proposals for “lesser” assets have not been included in the AoS. As Ian Thynne puts it:

“Instead of committed mitigation and detailed policies for the design stages, HS2 Ltd has instead relied on unsubstantiated sums of money to provide comfort that compensation and mitigation can be delivered. This amounts to £939 million and £215 million respectively as set out in Table 7 of the Consultation document dated February 2011, the ‘Economic Case for HS2’. These sums are provided without doing any high level work as to what the mitigation may look like, its actual cost, or where it may be located. In addition there are no policy commitments to ensure design stages will take into account the sustainability objectives set by HS2 Ltd.”

Ian also cautions:

“These mitigation measures are far too generic to have any practical weight at future decision making stages. The mitigation details provide no accountability or comfort that suitable measures will be put in place in the design stage. The consultation documentation is highly non-committal regarding mitigation which undermines the point of a sustainability appraisal. Basically, the AoS for HS2 scores the project as unsustainable but there are no suggestions to seek to improve that position.

“It would be expected that further mitigation policies would be presented at this stage to demonstrate how the project could be supportive of the sustainability goals set by HS2 Ltd as opposed to the unsupportive project it currently is.”

Ian’s conclusion indicates real pessimism regarding the future of the HS2 project:

“It is 51m’s view that there is a significant disconnect between the high level AoS and the design stages. There is no commitment to policies on specific mitigation which in turn means that there is no commitment from HS2 Ltd to find solutions to the myriad of negative environmental and social impacts they have found.”

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