BCC SIC

1. Do you agree that there is a strong case for enhancing the capacity and performance of
Britain’s inter‐city rail network to support economic growth over the coming decades?

• Increased capacity and performance on Britain’s inter‐city rail network may well form an important part of a clear, transparent and well constructed national transport strategy that supports economic growth in coming years. But the evidence that there is a ‘strong case’ has not been provided during the consultation. Indeed, until there is a national transport strategy, consulted upon and agreed, with clear objectives and outcomes, it is not possible to agree any such ‘strong case’.
• The current High Speed rail consultation only proposes investment in a new north / south high speed railway linking London to the Midlands and Northern cities. From a review of 15 June 2011 – 51m
  the evidence prepared for the 51m alliance of local authorities, such a new high speed railway is likely to offer favour London over the North and not contribute to bridging the North South divide. Consequently it is likely to offer less for regional economies than other regional or sub‐regional transport schemes.
• Regardless of the strategy, HS2 is not the only way to enhance the inter‐city rail network, since it is an enormously expensive and environmentally damaging project requiring £17 billion of public subsidy, that has yet to be shown to be in the national interest.

2. Do you agree that a national high speed rail network from London to Birmingham, Leeds and
Manchester (the Y network) would provide the best value for money solution (best balance of
costs and benefits) for enhancing rail capacity and performance?

• No. There are better alternatives. Enhanced rail capacity and performance can be delivered in far simpler, greener and less expensive ways than the current HS2 proposals that links only London, Birmingham, Manchester and Leeds. Incremental improvements that deal with overcrowding on the existing network can be introduced much more quickly, and such a pragmatic approach means that if the proposed increase in demand forecast by HS2 does not happen there is no wasted investment.
• A limited high speed rail network does not offer benefits for large parts of Britain (including Wales and the South‐West) and some cities will endure worse rail services as a consequence (Coventry, Wolverhampton, Stoke‐on‐Trent, Leicester, Chesterfield, Peterborough and Doncaster and Newcastle).
• The 51m alliance is confident that an amended and optimised Rail Package 2 (not considered by DfT) offers better value for money and delivers the necessary passenger capacity more quickly than HS2.
• The valuation of journey time savings (that contribute more than 40% of assumed benefits), level of forecast demand and method of assessment all exaggerate the potential benefits of HS2. When a more balanced assessment is carried out, as for 51m, HS2 is far from good value.
• All the time long distance rail journeys are made by the most affluent (the top 20% income earners make 47% of journeys), the benefits are accrued by the highest earners but paid for from the general public purse. This is inequitable.

3. Do you agree with the Government’s proposals for the phased roll‐out of a national high
speed rail network, and for links to Heathrow Airport and to the High Speed 1 line to the
Channel Tunnel?

• No. Assuming that a national transport strategy indicates the importance of enhanced rail capacity and performance, and assuming that this can only be delivered through a high speed rail network, it is not believed that the current proposals or phasings are the best way for this to be delivered.
• There are serious technical concerns about the deliverability of the proposed services with the “Y” Network. The 18 trains per hour required at peak times on the “Y” network are not deliverable with existing technology.
• On HS2 Ltd’s own analysis (published in 2010) there are insufficient potential passengers to support a frequent service either for through trains to the continent or to Heathrow. Work done for 51m confirms that these links have a poor economic case, such services 15 June 2011 – 51m could only be achieved by reducing other services – all further diminishing the case for HS2.

4. Do you agree with the principles and specification used by HS2 Ltd to underpin its proposals
for new high speed rail lines and the route selection process HS2 Ltd undertook?

• Definitely not. There are many areas where the assumptions and principles need to be seriously scrutinised. For example, can HS2 deliver consistent, reliable service frequencies with 18 trains an hour across both a high speed and conventional rail network, when no other high speed rail route in the world operates more than 14 every hour, and the technology for what HS2 Ltd propose does not yet exist.
• The specification is based on a mistaken assumption that journey time savings are considerably more valuable than they actually are. This means the proposals strike entirely the wrong balance between the benefits of speed and its adverse impacts. As the Government now recognise, speed is less important han overcrowding which favours lower speed solutions that can be implemented more quickly.
• It is also not clear how the preferred route was selected, since the consultation documentation does not identify the selection criteria nor any transparent selection process. Importantly, since the proposals have not been subject to either a Strategic Environmental Assessment or Environmental Impact Assessment the results do not adequately address the relative environmental impacts of the various options (including impact on biodiversity, local SSSIs, ancient woodlands and contextual landscape) and
  therefore the rationale for the preferred route.

5. Do you agree that the Government’s proposed route, including the approach proposed for
mitigating its impacts, is the best option for a new high speed rail line between London and the
West Midland?

• No. Assuming that a national transport strategy indicates the importance of enhanced rail capacity and performance, it can be delivered in far simpler and less expensive ways than either the current HS2 proposals or a national high speed network that links only London, Birmingham, Manchester and Leeds. Incremental improvements that deal with overcrowding can be introduced much more quickly, and such a pragmatic approach means that if the proposed increase in demand forecast by HS2 does not happen there is no wasted investment.
• The route selection process is based on an exaggerated view of time savings. This means that trade‐offs between the benefits of faster journeys and the impacts of not following existing transport corridors, using more energy, creating significant ecological and landscape damage and noise pollution has not been correctly considered in the route selection process.
• The consultation materials are far from clear about what (if any) mitigation measures are proposed for the preferred route. Even after questions, the advice received has often been that these will be properly considered ‘at the next stage’. There is no information available about mitigation for those who will be affected by alterations / changes to existing transport networks to accommodate HS2.
• In respect of noise, HS2 Ltd have persisted in measuring impacts that do not adequately reflect tranquil environments or the proposed operating speeds (using average rather than peak noise impacts, and assuming noise emanates from near the track), it is unlikely that proposed mitigation will be adequate. 

6. Do you wish to comment on the Appraisal of Sustainability of the Government’s proposed
route between London and the West Midlands that has been published to inform this
consultation?

• Yes. As previously noted, since the proposals have not been subject to either a Strategic Environmental Assessment or Environmental Impact Assessment the results do not adequately address the relative environmental impacts of the various options (including, but not limited to, impact on biodiversity, local SSSIs, ancient woodlands and contextual landscape).
• HS2 Ltd admits that there will be no carbon or climate change benefits from the HS2 proposals. The Appraisal of Sustainability does not seem to have had sufficient regard to other options, such as improving capacity on existing services.
• Information provided on the plans is difficult to interpret. For example, maps on noise do not show individual properties and therefore they are of little practical use for residents wishing to know how they will be affected.

 7. Do you agree with the options set out to assist those whose properties lose a significant
amount of value as a result of any new high speed rail line?

• The blight has already started and will continue for many years until construction of HS2 starts. But apart from the very limited Exceptional Hardship Scheme, compensation will not be paid for some years.

There are other facts and information available to help you respond to the consultation. Check out the following websites for details:

Government websites
HS2 Limited
The HS2 public enquiry team
020 7944 4908
Email: HS2enquiries@HS2.gsi.gov.uk  
www.highspeedrail.dft.gov.uk

 
51m
The group of 13 local authorities who are united in a national campaign to actively challenge the scheme. www.51m.co.uk  Email: 51m@buckscc.gov.uk  
Follow 51m on Facebook – 51m_HS2project  
Join the 51m conversation on Twitter ‐ @51m_HS2project

Other organisations and action groups ‐ information and guidance on HS2:
Amersham HS2 group
www.hs2amersham.org.uk  
www.highspeedrailconsultation.org
 
Berkshire, Buckinghamshire, Oxfordshire Wildlife Trusts
http://www.bbowt.org.uk/content.asp?did=26551  

Chilterns Society
www.chilternsociety.org.uk  

Chiltern Conservation Board
www.chilternsaonb.org  

Chiltern Countryside Group
www.chilterncountrysidegroup.org
 
Greengauge 21
www.greengauge21.net  

HS2 Action Alliance
http://www.hs2actionalliance.org
 
Stop HS2 
http://stophs2.org

 
Where do I send my consultation response to?
You have two options:

Online
Visit http://highspeedrail.dft.gov.uk and complete the questions online.

By post
For consultation forms call 0300 321 1010 or visit http://highspeedrail.dft.gov.uk  
Return completed forms to:
Freepost RSLX‐UCGZ‐UKSS
High Speed Rail Consultation,
PO Box 59528,
London SE21 9AX

(all responses must include your name and organisation if applicable)