Comparisons are odious

This is the final blog, at least for the time being, that I intend to devote to HS2 London to West Midlands EIA Scope and Methodology Report (here).

I have been looking at Chapter 3 of this document, which describes how HS2 Ltd proposes to report on the alternatives to the current HS2 proposal in the Environmental Statement (ES); the ES is the document that will be produced summarising the findings of the EIA to inform Parliament when it considers the hybrid bill. The reason that this chapter has been included in HS2 London to West Midlands EIA Scope and Methodology Report at all is because it is a requirement of a European Union Directive. The piece of European legislation that applies is Council Directive 85/337/EEC, as amended by Council Directive 97/11/EC (here). This EU legislation applies to “the assessment of the environmental effects of those public and private projects which are likely to have significant effects on the environment”.

Article 5 of the amended directive requires an environmental impact assessment to be carried out and for the results of this assessment to be supplied “in an appropriate form”; in the United Kingdom this “appropriate form” is the ES. Paragraph 5 of Article 5 requires the ES to include:

“An outline of the main alternatives studied by the developer and an indication of the main reasons for his choice, taking into account the environmental effects.”

I regard the last six words of this phrase as essential to the purpose of this requirement. What is necessary is that the reader of the ES is given sufficient information to allow him or her to compare the environmental impact of the developer’s preferred solution to alternative means to the same, or similar, end that will have different, possibly lesser, environmental impact.

For example, two alternative solutions for providing increased rail capacity between London and the West Midlands are to upgrade the existing West Coast Main Line and to build a new railway, still at high speed but not for 400 kph, using one of the existing transport corridors such as the M1 or M40. I strongly suspect that both of these alternatives will have a lower environmental impact that the current HS2 proposal. However, the search for alternatives need not necessarily be restricted to rail solutions; the approach for catering for a perceived increased demand to travel to and from the Capital and the West Midlands might be to expand other travel modes, or to depress demand (e.g. by using price as a mechanism), or to develop alternatives to travel (e.g. broadband).

The ES will not be a complete analysis without taking this broader view and considering the environmental implications.

Unfortunately, my impression from reading Chapter 3 of HS2 London to West Midlands EIA Scope and Methodology Report is that the intention is to ignore the requirement to report in the ES on the environmental effects of the real alternatives to HS2.

That this is a fair interpretation is surely clear from paragraphs 3.1.1 to 3.1.4 of HS2 London to West Midlands EIA Scope and Methodology Report, which I would paraphrase as:

More inter-city travel capacity will be needed over the next twenty to thirty years and the Government has decreed that this should only be provided by increased rail capacity, and moreover that there is a clear case for this capacity to be provided by high speed rail. Upgrading the existing network will not satisfy demand and will mean unacceptable disruption. Also, high speed rail will bring additional benefits. Since a new railway is necessary, the only choice is whether this should use conventional or high speed rail technology. Opting for conventional speeds will not significantly reduce cost or environmental impacts and would reduce the value of benefits. HS2 Ltd has spent two years looking at alternative configurations for a new high speed line and, except for changes by way of mitigation, this chapter is considered closed.

Any doubt about the intention of HS2 Ltd to ignore a consideration of the environmental impacts of the alternatives is removed by paragraph 3.1.5:

“The Environmental Statement (ES) will provide an outline of the main alternatives studied by HS2 Ltd and the Department for Transport (DfT) and the reasons for their rejection.”

Loosely translated, I think this amounts to “we will repeat all the stuff that we have already published”.

Leaving aside the matter that many of the assertions in this HS2 Ltd summary are contentious, it completely ignores the inconvenient consideration that the quest for truly sustainably development may mean that you have to settle for something less than you think you want in order not to impoverish future generations unduly.

The intention of HS2 Ltd appears to be to avoid having to admit that solutions other than HS2 are likely to have much lower environmental impacts. We have already seen this tactic employed in the AoS. I commented in my blog There’s more than one way to skin a rabbit (posted 29 Apr 2012) that despite claims by HS2 Ltd that the AoS was intended to be compliant with the Strategic Environmental Assessment Directive, it had clearly failed to meet the SEA requirement to compare the environmental impacts of the reasonable alternatives.

Clearly, as far as HS2 Ltd is concerned, “comparisons are odious”.


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