Standing up for the environment

(I realise that it won’t mean much to the average reader, but I feel compelled to record that this is my one hundredth blog and that it represents a very significant milestone to me, at least).

There is a noticeable change in the way that Dialogue by Design presents the results of the public consultation on HS2 in Chapter 6 of its report High Speed Rail: Investing in Britain’s Future Consultation Summary Report (here). The title of this chapter is Natural and cultural resources: protection and enhancement and the change that I refer to is that we are only presented with numbers of those respondents that expressed concern about the impacts of HS2. This does not mean that none of the respondents spoke up for HS2, but we are just told that “a small number of respondents” expressed a particular view, or some other similar phrase is used. This approach appears to indicate that the majority that expressed concern in this category was fairly overwhelming.

The figures that we are given are:

  • 3,170 respondents “are of the opinion that the proposed high speed rail scheme would have an overall negative impact on the environment”.
  • 1,212 respondents “do not think that a national high speed rail network would be able to ‘protect natural and cultural resources and enhance the environment’”.
  • There are 2,864 comments “about the potential impact of the proposed high speed railway network on diversity and wildlife”; it is not stated, but I think that we may assume that these are adverse comments.
  • 406 respondents “raise concerns about the potential impact of the proposed high speed rail network on various Sites of Special Scientific Interest (SSSIs) along the route”.
  • There are 2,022 comments from respondents “who think the proposed high speed rail network will be detrimental to the countryside and natural landscape”. Specific comments “about the environmental impacts of construction works” are made by 710 respondents.
  • 1,269 voiced concerns about “the impact … on the Chilterns AONB”.
  • There are 725 comments from respondents “about the potential impact of the route on woodlands” and these “largely relate specifically to ancient woodlands”.
  • There are 1,020 comments about “the potential impact of the proposed scheme on waterways and aquifers”. A further 551 respondents “comment on the construction of the scheme across floodplains and the potential to increase flood risk”.
  • There are 871 “general comments from respondents about the potential impact of the proposed scheme on cultural heritage, with specific comments about listed buildings, archaeological sites and conservation areas”.

That’s quite a list and represents a substantial body of opinion that has not been totally convinced by the downplayed assessment of the impacts of HS2 in Chapter 2 of Volume 1 of the Appraisal of Sustainability (here) or by the attempts by HS2 Ltd to assure us that its mitigation plans will effectively heal any scars.

So HS2 Ltd has had another attempt at reassurance in Chapter 6 on pages 19 to 25 of Review of HS2 London to West Midlands Appraisal of Sustainability (here). This latest statement from HS2 Ltd begins with recognition that “many of the issues raised by consultees are relevant to the project” coupled with an assurance that these issues will be “appropriately addressed through the usual EIA process” (paragraph 6.1.1).

We are told that the EIA (environmental impact assessment) process will include “ongoing dialogue and engagement with relevant stakeholders” (paragraph 6.2.2). The main mechanism for this “dialogue and engagement” will be “relevant forums to continue dialogue and engage locally in relation to mitigation and developing opportunities” (paragraph 6.3.2). This process has already begun, and I will describe how it works and give some initial reactions, based upon my own involvement in it, in my next couple of blogs.

HS2 Ltd rightly claims that it has already “sought to address specific issues raised during consultation through recommended changes to the route” (paragraph 6.1.2). These changes it must be said have concentrated on the “high profile” issues, leaving many areas of concern unresolved, and the worry is that HS2 Ltd may have largely used up its mitigation budget before the real EIA work has started.

HS2 Ltd also claims, in paragraph 6.5.2, that its approach “has included lowering viaducts and embankments”. Whilst this would have been true if it had been written in September 2010, it is much less true following the “spoil reduction” exercise that I reported in my blog The ups and downs of route engineering (posted 9 Feb 2012).

HS2 Ltd makes attempts to sweeten the pill. In paragraph 6.2.1 we are told that “railway lands are also recognised as being able to provide important, varied and secure environments for wildlife habitats”. In paragraph 6.2.4 we are promised “enhancement opportunities”, that the railway will be a “green corridor” and that there will be “extensive planting” of trees. In paragraph 6.2.3 the possibility that HS2 will provide “important contributions” to Biodiversity Action Plans and associated Opportunity Area targets is mentioned. In my blog The view from Victoria Street (posted 5 Aug 2011) I expressed scepticism about these benefits, and remain sceptical.

In section 6.4 we are promised that the EIA will assess wildlife habitats and the impacts of HS2 on protected species. A whole load of site designations, regulations, guidelines and acts of Parliament are referenced and we are told that these will be complied with.

Most of section 6.5 concerns a justification for despoiling the Chilterns AONB. The defence offered by HS2 Ltd is basically that HS2 is in the national interest, cannot practically be routed elsewhere and that the option chosen is the least damaging. As I reported in my blog “Not some Constable country” (posted 19 Apr 2010), the Chilterns Conservation Board is not convinced by these arguments. I have to say that, even after considering the latest statement from HS2 Ltd, I am not convinced either, particularly as HS2 Ltd has totally ignored the perfectly viable option of upgrading the existing routes, which will have no effect whatsoever on the Chilterns AONB.

Overall, I think that the attitude of HS2 Ltd to the reservations that have been expressed about the impacts of HS2 on natural and cultural resources is best summed up by the first sentence of paragraph 6.3.3:

“Given our approach outlined above, and the future measures we would follow in light of consultation responses, we conclude that our approach to considering natural and cultural resources and their protection and enhancement in the AoS is appropriate for a project at this stage of development.”

Only to be expected, I suppose.

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