There’s more than one way to skin a rabbit

This is the final blog that I propose to devote to the analysis by Dialogue by Design of the responses to Question 6 of the public consultation on HS2, which asked respondents whether they wanted to comment on the Appraisal of Sustainability (AoS).

In a paragraphs 6.3.60 to 6.3.62 on pages 130 and 131 of High Speed Rail: Investing in Britain’s Future Consultation Summary Report (here) we are advised that “a number of respondents outline their opinions about the possible alternatives to a high speed rail network in their comments about the AoS”.

More specifically we are told:

“There are 1,297 respondents who believe that the proposed high speed rail network is not the most sustainable option, while 934 respondents express the opinion that alternatives have not been given adequate consideration.”

And the Department for Transport need not feel short of advice about what these alternatives might be:

“Some respondents go on to indicate which other approaches or schemes they think would be more sustainable than the proposed national high speed rail network. The most frequent suggestion is to invest in the existing rail infrastructure; respondents think this would be a more sustainable means of creating additional capacity than building new infrastructure. Others recommend investing in IT capabilities and focusing on reducing the need to travel by encouraging more people to live and work locally. There are 597 comments mentioning electric vehicles and green technology, in some cases suggesting that some or all of the money proposed for a high speed rail network should be used to develop and roll out these technologies.”

HS2 Ltd doesn’t address these issues directly in its document Review of HS2 London to West Midlands Appraisal of Sustainability (here). The only relevant comment that HS2 Ltd makes appears in paragraph 3.1.2 on page 10, where the requirements of the Strategic Environmental Assessment Directive (SEA) are referred to. In this paragraph HS2 Ltd makes the claim that “the AoS was intended to be compliant with the principles of SEA”. It also offers the view that “as part of [the SEA] assessment, consideration must be given to reasonable alternatives that are available”.

Having specifically made this last point, it is strange that HS2 Ltd does not realise the obvious contradiction in its position. An important purpose of the SEA, as described in A Practical Guide to the Strategic Environmental Assessment Directive (here) is to compare the environmental impacts of the reasonable alternatives. Since there are clearly reasonable alternatives that the AoS has not considered, such as “to invest in the existing rail infrastructure” as suggested by respondents to the consultation, it appears that the AoS fails to be compliant with SEA in at least this one important aspect.

This did not escape the respondents to the public consultation, as Dialogue by Design reports in paragraph 6.3.62 on page 131 of High Speed Rail: Investing in Britain’s Future Consultation Summary Report:

“There are comments from organisations as well as members of the public suggesting the AoS should set out how the sustainability of the proposal compares to alternatives such as not investing in high speed rail or upgrading the wider transport network, or establishing specific improvements.”

One of the organisations that commented on this issue was the 51m alliance of local authorities. It sets out its complaint very clearly in paragraph 13.15 on page 13-5 of Appendix 13 to its consultation response document (here), as follows:

“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.”

However, HS2 Ltd will have nothing to do with this and the other complaints about the methodology used for and contents of the AoS. It sets out its overall response to the consultation responses to Question 6 in chapter 10 on page 32 of Review of HS2 London to West Midlands Appraisal of Sustainability. Whilst conceding that “a number of areas would need to be addressed further in the next stage, when an EIA would be undertaken”, its conclusion about the suitability of the AoS is predictable:

“For the current stage of the project, we conclude that our approach to examining the impacts on the environment and sustainability through the AoS is appropriate.”

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2 responses to this post.

  1. Dear Peter
    Yet another great piece that perfectly illustrates the blinkered idiocy of this whole project. When will logic enter the argument from the DfT and HS2 Ltd? The Consultation we are told was not a referendum, but when looking at the figures in it then surely scrapping the whole project should at least be seen as the most popular option.

    Reply

    • Thank you for those few kind words “drilldevil1”.
      My suspicion, and I stress that it can only be a suspicion since it is almost impossible to prove such things, is that the decision to go ahead with HS2 is a purely political one and has nothing to do with the logic or force of the arguments.
      The current shenanigans at the Department for Culture, Media and Sport surely provide two lessons. Firstly, that politics is a dirty business and we can’t take anything that we are told by politicans at face value. Secondly, that there is always a danger that the real power in this land is the the hands of the lobbyists and the powerful who have the politicans in thrall.
      Those of us who have taken the time and trouble to research the HS2 proposal know that many of the things that we have heard from politicans on the subject are at best misrepresentations and at worst downright lies. Many of us also suspect that the powerful construction and transport lobby is pulling the strings of the puppets that are supposed to be representing us in the House of Commons.
      Oh dear, I suppose that, in saying this, I have given “hs2isright” to opportunity to get back on his soapbox and rail at me again.

      Reply

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