The draft EIA Scoping and Methodology report for the London to West Midlands route to which the following responds may be found here.
NEAHS2 Response to HS2 Ltd's draft Environmental Impact Assessment (EIA) Scoping and Methodology Report
This response has been prepared by North Ealing Against HS2 (‘NEAHS2’). NEAHS2 is an affiliation of residents living in the northern wards of the London Borough of Ealing (‘Ealing LBC’) who are outraged by the lack of mitigation for the northern wards of Ealing LBC proposed should HS2 be built along the route preferred by the current government in accordance with current plans.
However, NEAHS2 also strongly opposes the proposed HS2 network on the grounds that it is not convinced of the arguments for the claimed national benefits and because of the significant adverse environmental impacts that HS2 would cause. Those adverse impacts have not been adequately incorporated in the HS2 business plan or design.
NEAHS2’s response only comments on sections of the draft document where NEAHS2 feels it is able to offer an informed opinion. NEAHS2 not commenting upon any particular part of the document should not be taken as an indication of agreement with the document in whole or in part.
NEAHS2 believes that the EIA will not be sufficiently broad ranging or rigorous for a scheme of the scale and potential adverse impact of HS2. Insufficient information has been presented as this stage, no project description has been provided, the measures of impact lack clarity and the proposed methodologies are insufficiently well described. NEAHS2 is particularly concerned that insufficient time has been made available and it is not conceivable that the EIA and subsequent Environmental Statement (‘ES’) can be prepared to the necessary standard in the time provided.
The scoping report unacceptably does not include any project description and instead it assumes that readers have a full knowledge of previously published documents. This is a flawed assumption and it is compounded by including wholly inadequate large scale maps. For this exercise detailed descriptions and maps are required including, for example, the location of work camps and associated infrastructure, design details of bridges and even basic information such as the area of land take and storage areas.
Nothing in this response indicates or should be taken to indicate NEAHS2’s agreement with or support for either phase of the proposed HS2 network, or the proposed route of either phase of the proposed network.
NEAHS2 is highly concerned at the level of dependency upon professional judgement and notes that the review of the AoS was not undertaken independently and that HS2 Ltd awarded itself a clean bill of health. On this basis NEAHS2 submits that the EIA must be undertaken by an independent arm’s length organisation that is not legally connected to HS2 or the Department for Transport and has no financial or other stakehold in HS2 being constructed or not constructed. Not being legally connected also includes the directors or partners of the organisation undertaking the EIA not having any shareholdings in HS2 Ltd or any of the organsations it intends to contract with to construct HS2.
NEAHS2 notes that to date there has been a notable lack of confidence in the public consultation process most recently exemplified by the conclusions and justification for taking the project to the next stage which were contrary to the significant majority of views expressed by the general public in the public consultation on HS2 conducted in 2011. NEAHS2 suggests that this indicates that the Government intends to proceed as it wishes and will only use the results of the EIA to confirm its preferred way of proceeding.
NEAHS2 suggests that it might be difficult for Department for Transport policy-makers who consider local opposition groups to be ‘NIMBY’s to empathise with the local concerns and the complete and utter frustration and disempowerment of communities along the proposed HS2 route. NEAHS2 suggests that a remedy for this might be for such policy-makers to imagine being reborn, growing up and acquiring a long term stakehold in one of the communities along the proposed HS2 route facing adverse impacts.
NEAHS2 responds to particular chapters and paragraphs of the EIA:
Chapter 1 – Introduction
Paragraph 1.4- it is vital that HS2 gives full weight to public opinion on what it considers to be “likely significant effects”. To date HS2 Ltd and the Department for Transport have under-played what the public considers to be significant effects, such as noise.
Paragraph 1.5.3 is misleading and should be rewritten so as not to exclude the possibility of tunneling as a solution between North Acton and South Ruislip (under Northolt, Greenford and Perivale)
In particular, the statement:
‘the route would enter a further tunnel in the Northolt area for 4km to reduce impacts on people living near the railway’
implies that the adverse impact of HS2 on people living near the railway in the area of Northolt will be reduced by virtue of a tunnel under Northolt, whereas in fact the current proposal is for no tunnel under Northolt, Greenford or Perivale, which are all very quiet and peaceful residential areas in the Northolt Corridor.
NEAHS2 considers that references to avoiding major disruption to the Chiltern Railways line and the West London Waste Authority transfer station are invidious as they imply that the human and adverse environmental impact of HS2 on people living, working and attending school near the railway line is a lesser consideration than minor land take to a waste transfer station and/ or the temporary disruption to the Chiltern Railways Line if HS2 were run over ground through South Ruislip as previously proposed.
NEAHS2 further maintains that the HS2 route should be in tunnel the entire distance between North Acton and South Ruislip to reduce adverse impacts not only on people living near the railway but indeed on ancient Woodland (Perivale Wood Nature Reserve), recreational areas, Perivale and Greenford Scouts, businesses leisure facilities and schools in the area including:
- Northolt High School
- Willow Tree Primary School
- Selborne Primary School
- Vicar’s Green Primary School
- St John Fisher Primary School
- The Busy Bees Nursery School
NEAHS2 maintains that these adverse impacts are extremely severe but have not been properly considered by HS2 Ltd. The adverse impacts would include the following:
- The temporary disruption of construction work – diversions and traffic tailbacks that may be caused when bridges are demolished, replaced, retaining structures built and embankments reinforced
- The necessity of privately owned or leased permanent land reclaim including people's homes including but not limited to Ealing Park Lodge on Horsenden Lane South in Perivale and properties in Willesmere Drive in Northolt as well as the gardens of other properties.
- The permanent long term noise, echoes and potential vibrations to thousands of properties and businesses along the line caused by HS2 trains.
- The ineffectiveness of so termed ‘noise barriers’. As NEAHS2 and other organisations have demonstrated to the Department for Transport in previous consultations and correspondence ‘noise barriers’ would be wholly ineffective against aerodynamic noise and Rayleigh waves and would only reduce a very negligible amount of noise. They would also only be 2m high and would not be effective against much higher double decker trains. They would be additionally visually unsightly and would not cross over bridges.
- The permanent safety implications of running high speed trains on an embankment at 250kph, given that the proposed route would be elevated through Greenford and Perivale and the catastrophe that would ensue in the case of a derailment in these residential urban areas.
- The removal of tunnel spoil would only be temporary whereas 250kph trains and continue to impact people living near the railway but indeed on habitats and visitors to ancient woodland (Perivale Wood Nature Reserve), recreational areas, businesses and schools for decades if not centuries (although NEAHS2 questions the long term sustainability of HS2).
- An overground HS2 route would add more misery for the thousands of commuters using the London Underground daily (Central Line, West Ruislip branch) alighting or boarding at North Acton, Hanger Lane, Perivale, Greenford and Northolt, or those travelling out towards Ruislip.
- HS2 will directly cause reduced investment in Perivale, Greenford and Northolt over the next decade, and has already lead to property market stagnation. If HS2 is built as proposed the area will become undesirable and properties will significantly lose their value and become unsaleable.
- HS2 would permanently prevent the currently extremely minimally used freight line on which HS2 trains are intended to run between North Acton and South Ruislip being used as a suburban passenger line in the future to alleviate overcapacity on this stretch of the Central Line West Ruislip branch during peak travel times.
These impacts are wide ranging in scope and would extend community wide in Perivale, Greenford and Northolt. NEAHS2 maintains that tunneling beneath Northolt, Greenford and Perivale, which would at once avoid all negative impacts of an overground HS2 route through Perivale, Greenford and Northolt listed above, would provide the only effective mitigation for these areas.
When the Channel Tunnel Rail Link (‘CTRL’) was constructed 20 years ago it was tunneled through 16 miles under East London. NEAHS2 submit that similarly the entire route of HS2 through west London should be tunneled if HS2 is constructed along the proposed route, including the entire section through the London Borough of Ealing. This is in accordance with the Appraisal of Sustainability (AoS) priorities of:
- maintaining sustainable communities (in Perivale, Greenford and Northolt); and
- protecting natural and cultural resources such as Perivale Wood Nature Reserve – the second oldest protected ancient woodland in England.
NEAHS2 therefore maintains that the scope of the EIA and the Environmental Statement (‘ES’) report must fully and properly incorporate an assessment and report of:
a) all the above listed adverse impacts; and
b) tunneling this stretch of the proposed HS2 route between North Acton and South Ruislip beneath the Central Line South Ruislip branch as a solution to these adverse impacts.
NEAHS2 maintains that assessing these adverse impacts and tunneling between North Acton and South Ruislip is fully within the scope of this consultation and further points out that these adverse impacts and tunneling as a solution are not unique to this locality but would be relevant to other proposed overground sections of the proposed HS2 route in other urban areas.
Paragraph 1.6.3 states: “The AoS considered and compared various route options for Phase 1 of HS2 …” NEAHS2 can find no evidence that this exercise was undertaken. It was neither published nor subject to public scrutiny or consultation. The AoS that was published was specifically about the single chosen route only.
Paragraph 1.6.4 makes no reference to the scale and number of criticisms of the AoS once again undermining confidence in the analysis undertaken by DfT/HS2 Ltd and the related failure to acknowledge the scale of public opposition to this scheme.
Paragraph 1.8.1 states: ‘during the EIA process the potential significant effects identified in the AoS will be monitored and the ES will report on how the predicted effects may have changed as a result of scheme development. To facilitate the reduction of such effects HS2 Ltd is preparing Environmental Design Aims (EDAs) to guide the project development teams.’
The AoS reported that the scheme would have significant adverse impacts on the majority of features and characteristics included. NEAHS2 contends that simply monitoring impacts on those is insufficient and it should be a stated aim that the scheme design will reduce significantly the number and scale of adverse impacts.
There is a failure to provide any clarity over what the EDAs are, their content, how they are prepared and by whom.NEAHS2 queries whether these EDAs will take into consideration flaws in the AoS including, for example, the fact that noise sources at various heights – shown in countless international studies at speeds in excess of 200kmh – were modelled at the lowest possible height of zero metres, when this was contrary to advice given by advisors to the European Commission (in the IMAGINE project) and contrary to guidelines set out in ISO:3095-2001. Internationally recognised noise experts are well aware of the various heights of train noise sources, such as bogies, windscreens, cooling fans, traction & electric motor noises, turbulent boundary layer noise, roof, and pantographs. However, these separate and distinct noise sources have been ignored with assessments concentrating on rolling noise only. By taking this step, HS2 Ltd have downplayed the significance of noises higher than track level, and thereby exaggerated the effectiveness of ‘noise barriers’.
Paragraph 1.8.2 refers to Environmental Plans with virtually no detail as to what they are and how they will be prepared and implemented. Will stakeholders and local communities be invited to contribute to them?
Chapter 2 – EIA methodology
Paragraph 2.1 - the draft Report states that the EIA will be ‘carried out in accordance with applicable legal requirement and current best practice’ – specific references need to be included here to lend credibility, in particular with regard to the intended sources of best practice guidance. One guidance document that should clearly be reference and followed here is the EU guidance on EIA scoping from June 2011 which includes a simple checklist of the details that should be provided. The approach set out in this chapter fails to make explicit statements of principle with regard to avoidance/ mitigation/ compensation and enhancement, or to set out standards for assessment which will ensure minimal environmental harm. Such statements are essential. The report should for example make clear that, avoidance of adverse environmental effects is considered to be the most acceptable approach, followed by minimising of impacts (rather than minimising of features, as proposed in paragraph 2.3.2).
Paragraph 2.1.3 states that the scoping report will ‘identify the potentially significant environmental effects and establish the scope and methodology of environmental studies to be carried out ….’ . The chapters that follow substantially fail do this, leaving too many crucial decisions about methodology and scope to the ‘professional judgement’ of unidentified individuals, whose qualifications are not specified, working to unknown timetables, often to unidentified standards making decisions outside of the public scrutiny of this consultation. This is not conducive to public confidence that the assessment has been carried out in an appropriately independent, rigorous and objective manner. NEAHS2 restates that the EIA should be carried out by an independent and legally unconnected organisation operating at arm’s length to the Department for Transport and HS2 Ltd.
Paragraph 2.1.3 also states that there will be ‘engagement and consultation with formal and informal stakeholders throughout the assessment and EIA design process.’ It is not clear what is meant by ‘formal’ and ‘informal’ stakeholders, and more importantly the track-record on this so far is poor, with for example no community forum meetings planned during the course of the draft Report consultation period. The specific proposals for this engagement and consultation as well as their timetable need to be clarified.
Paragraph 2.2.5talks about taking account of ‘longer term considerations after opening of Phase 1, such as progressive growth in background road traffic or the maturing of mitigation’ but does not include examples such as the expansion of broadband or other technological changes. The draft Report should specifically indicate the main ‘predicted or anticipated change factors’ which it would expect to address.
Paragraph 2.27 - the approach to geographic scope should be directed by the nature and the sensitivity of the environmental receptors/ features and their setting, rather than by an arbitrary ‘distance from proposed scheme’ approach.
Paragraph 2.2.11 – NEAHS2 contends that the list of environmental topics to be addressed should be expanded to include the following:
- Recreation, access and amenity
- Health and well-being
- Cumulative effects and inter-relationships between topics
Paragraph 2.3.3refers to mitigation measures being considered at Design Workshops, but omits to state who will be involved, at what stage in the process and what opportunities there will be for input into these workshops. NEAHS2 would expect to be involved.
This paragraph also states that ‘where practicable design modifications will be considered to avoid or reduce significant effects’, but does not state what will be the response where this is not considered practicable, what the criteria are for what is considered ‘practicable’ and whether this relates to financial costs.
Paragraph 2.3.5 states that: ‘the proposed mitigation measures will be described in the ES, together with the significant effects remaining after mitigation (termed the residual effects). Where the Proposed Scheme is likely to improve environmental conditions (over and above the baseline), these effects will be identified as enhancements.’
NEAHS2 is concerned by the lack of definition of the word ‘baseline’ in this context and contends that the HS2 network would not enhance the northern wards of Ealing LBC in any conceivable way.
Too often the draft EIA Scoping and Methodology Report suggests that a current legal standard will be used. These are regarded as minimum standards often based on past experience and standards have fallen below what is expected. This project must be future proofed based on the best and highest standards available now adapted and evolved to reflect what will be considered best practice long into the future.
Paragraph 2.3.6 discusses implementation of the mitigation and compensatory measures. There is no reference to provision for long-term monitoring and management of such measures. It is crucial that these are included.
Paragraph 2.5.2 defines ‘minor impact’ as ‘slight, very short or highly localised impact without a significant consequence’. This is expanded on at Paragraph 2.5.5
NEAHS2 takes issue with this categorization of minor impact and maintains that impacts should not be considered to be minor simply because they are localised – a local impact may have a major impact on that locality.
More broadly the EIA should be based on a clear and detailed description of a project. It must be accompanied by sufficient information to demonstrate what is identified as a likely significant impact. The approach to assessment of significance is not adequate, it lacks clarity and consistency, with each topic area using different terminology. It is crucial that the report adopts a clear, comprehensible approach which removes ambiguity and is based on a clear statement of what is meant by a ‘significant effect’ and the criteria by which ‘significance’ is to be defined. Where this is a marginal decision on significance the EIA should also demonstrate why other impacts are not thought likely to be significant. This must be complemented by clear definitions of how the impacts will be measured and the methodologies to be used. In the draft EIA Scoping and Methodology Report there is considerable inconsistency between chapters with a variety of proposed descriptions of impact significance. Only when consistency has been provided can the consultee understand what is being proposed and the likely level of impact.
Chapter 3 – Reporting of alternatives in the ES
European Union Council Directive 85/337/EEC, as amended by Council Directive 97/11/EC, requires that the report of the findings of the EIA in the ES includes:
'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.'
The last six words of this requirement are important. It is essential that the reader of the ES is given sufficient information to allow him or her to compare the adverse environmental impact of the developer’s preferred solution to alternative means to the same, or similar, end that will have different, possibly lesser, adverse environmental impact. Only if this information is available can the environmental impacts of the preferred scheme be properly assessed and evaluated.
This is a particularly important requirement for the EIA as, despite claims by HS2 Ltd that the AoS was intended to be compliant with the requirements for a strategic environmental assessment (SEA), and that Directive 2001/42/EC requires that a SEA also considers the adverse environmental impact of alternatives, the AoS for HS2 did not consider the adverse environmental impacts of any alternatives that did not require the building of a new high speed line capable of 400 kph which would include trains traveling at 250kph overground and on embankment through urban areas.
This omission is particularly significant as the assessment of the sustainability of the preferred solution presented in the AoS demonstrably shows it to be an unsustainable proposal, and so it is important for any more sustainable alternatives to be identified and fully considered.
The draft Report itself does not present any alternatives and so it is not clear why Chapter 3, entitled ‘reporting on alternatives’ has been included. Chapter 3 indeed simply lists the reasons why Government wishes to proceed with this project, which will not involve any assessment of environmental impacts.
NEAHS2 cannot see therefore how the requirement of Directive 85/337/EEC, as amended by 97/11/EC, to outline alternatives in the ES “taking into account the environmental effects” can be satisfied by the present version of Chapter 3.
Paragraphs 3.1.1 to 3.1.4appear to be an attempt to exclude alternatives from the environmental assessment on the grounds that they have been ruled out for other reasons. Certain contentious statements are presented as baseline premises, namely:
- That “a clear case exists for … a new high speed rail network”
Yet even the Government’s own consultants have shown that significant capacity enhancements to the existing network and services are both realistic and have a better Benefit Cost Ratio (‘BCR’) than HS2.
- That long-term rail capacity needs will not be satisfied by “yet more rounds of incremental enhancements to existing lines” according to Network Rail.
Yet Network Rail’s own Rail Utilisation Report at (page 55), for example shows that in the busiest hour during the morning peak (when fares are at their highest), long distance services in to Euston are at just 64% of capacity, with the figure dropping to 60% for the whole three hours of peak morning demand. With the exception of the non-commuter Heathrow Express (30%), the only other services in to London which are quieter are domestic HS1 services at St Pancreas, which net just 44% and 41% occupancy.
- That the adverse impact of new conventional rail lines on the environment and communities would not be “significantly less than those of new high speed lines”.
Yet in 2007, the government commissioned Rod Eddington report found that building and operating a new north-south rail network in England would generate more CO2 than taking the same route by air over a 60-year period. “There is no potential carbon benefit in building a new line on the London to Manchester route over the 60-year appraisal period. In essence, the additional carbon emitted by building and operating a new rail route is larger than the entire quantity of carbon emitted by the air services,” said the report. The Eddington Report stated “Given that domestic aviation accounts for 1.2 per cent of the UK’s carbon emissions, it is unlikely that building a high-cost, energy-intensive very high-speed train network is going to be a sensible way to reduce UK emissions.” HS2’s power requirement varies as the square of the running speed so at 225 mph (360kph) it would requires 3 1/4 times the power of a train running at 125 mph (200kph). For HS2 trains running at the track’s design speed of 250 mph (400kph) power required increases to 4 times. More power requires more energy. HS2 Ltd state that a journey time saving of 3.5 minutes consumes 23% more energy (300kph to 360kph).
Paragraph 3.1.2- works necessary to improve the WCML to provide adequate capacity for the future would be in fact relatively minor compared to the recent WCML upgrade, and would not involve the massive disruption to Euston and those services which use it, that are part of the HS2 proposal. The draft Report largely overlooks this aspect. Indeed there is no mention of the massive disruption that the building of HS2 will cause along its length and no attempt to identify let alone quantify it.
Paragraph 3.1.3– the draft Report here erroneously puts forward the argument that the alternative is either a new conventional speed or high speed line. This false comparison, which is invidiously made to the exclusion of other alternatives, is not put forward by those challenging HS2 and should be present in the draft Report.
Paragraph 3.1.5 implies that any consideration of alternatives in the ES will be fairly superficial and will largely be a restatement of already published material. There is no stated requirement to carry out any environmental assessment of alternatives, which there should be. This would form part of the SEA approach which NEAHS2 and many others advocate, but is rejected by Government.
A more mature and open minded assessment would include reducing the need to travel by use of IT facilities. It is now known that loading of peak hour services from Euston to Birmingham, Manchester and Liverpool typically averages 56%. With a more sophisticated approach to managing services and demand, it is feasible to enhance existing networks and services to more than adequately accommodate both realistic forecasts of passenger traffic and even those inflated forecasts of HS2.
The Major Projects Authority recently assessed HS2 as Amber/Red. This highlights the high risk associated with the proposal, and its unsound demand forecasts and economic case. This assessment, the scepticism of the Pubic Accounts Committee, the criticism of the Transport Select Committee, the inaccuracy of the forecasts of demand for HS1 and the overwhelmingly negative response of the general public all suggest that this scheme is deeply flawed and its basic assumptions need, not only to be re-assessed but tested against alternatives and subject to public consultation. Any degree of sensitivity analysis shows that HS2 is so high risk it should not go ahead.
Paragraph 3.1.10refers to considerations of reduced line speeds on sections of the route, which were investigated and published following the public consultation. However, no attempt was made in this investigation to evaluate the environmental benefits arising from a significant decrease in line design speed in urban residential areas where the route is proposed to go overground and on embankment such as in Perivale and Greenford, and where therefore the human environmental impact is significant and adverse. This rationale is explained in the document thus:
“Given the sizeable loss of benefits from lower speeds, and the scope to mitigate
environmental effects, we remain of the view therefore that the current design speed is appropriate. However we recognise that there could be places where, selectively, a lower design speed is more appropriate. We have therefore considered speed reductions in individual sections of the route.”
We are further told that:
“The 186mph route has a journey time that is four and a half minutes longer than the consultation route between London and Birmingham, at 53 and a half minutes as opposed to 49 minutes.”
This illustrates perfectly why it is essential for the ES to include a proper consideration of the environmental impacts of alternatives, because this vital decision about design speed has been made, apparently, overwhelmingly on economic grounds and provides an example of sustainability obligations being overlooked. Surely, if the concept of sustainability is to mean anything it must require developers to understand the environmental consequences of their decisions, and to be prepared to compromise on requirements to reduce the impact on future generations.
Chapter 7 – Community
Neither this chapter nor the chapter on socio-economics deals adequately with local economic impacts, particularly those that are negative and this should be addressed. A fall in house prices is likely to be felt across the entirety of the northern wards of Ealing LBC through which HS2 is proposed to pass and levels of home-ownership and long term stakeholders in the area are both likely to be significantly reduced.
As stated previously, NEAHS2 considers that the impact of an over ground HS2 route through the northern wards of Ealing LBC would impact on the wider population of the wards, not only those living near the line. In particular and inter alia:
- Disruption during construction work – unlikely to be very temporary, given that HS2 will by the draft Report’s own estimates take almost years to construct. This will cause havoc for local traffic when bridges are replaced, particularly, for example the East Bridge at Hanger Lane but also bridges over key transport routes such as Horsenden Lane South.
- Audible and visual pollution from 250kph potentially double decker trains for the thousands of commuters using the London Underground daily (Central Line, West Ruislip branch) alighting or boarding at North Acton, Hanger Lane, Perivale, Greenford and Northolt, or those travelling out towards Ruislip.
- Reduced investment in Perivale, Greenford and Northolt over the next decade, including property market stagnation.
- Prevention of the currently extremely minimally used freight line on which HS2 trains are intended to run between North Acton and South Ruislip being used as a suburban passenger line in the future to alleviate overcapacity on this stretch of the Central Line West Ruislip branch during peak travel times.
Similarly, no mention is made of the reputational damage and damage to community cohesion that would be caused to an area, including adverse impacts on community building organizations such as the Scouts. Perivale 3rd Scouts and Greenford 1st Scouts are both located right next to the proposed HS2 route. Few people are likely to want to visit Perivale Wood Nature Reserve after construction of HS2.
As stated previously NEAHS2 contends that this damage could be avoided if HS2, if constructed, were put in tunnel right the way through Ealing LBC.
Paragraph 7.1.3 deals with the effects associated with residential property, but does not address the adverse impact of noise, vibrations and echoes. This should clearly be considered here. Visual impacts should also be addressed here.
Paragraph 7.5 - Table 3 details various resources, receptors and the spatial scope of the assessment. Under residential property NEAHS2 contends that the receptors are too narrow and should at least include other property and visitors. For the spatial scope this is limited to ‘any properties needed as part of the direct impacts on land’. Based on HS2’s information this would limit the number of properties severely and the spatial scope should be extended to include all land and property affected by the scheme.
Under spatial scope in Table 3 the following text is repeated on numerous occasions: ‘to be determined based on relevant communities, settlements and infrastructure and their geographic boundaries’. It is not clear what is meant by this, though it infers that the Community Forums will take some part in determining what might be defined. However, the timing and length of the public consultation on the EIA Scoping Report does not allow any input via the Community Forums. The Forums do not therefore have a voice in connection with this issue. With lack of direct input NEAHS2 wonders who will decide what the spatial scope will be.
Paragraph 7.6.1 - the end of paragraph 7.6.1 refers once again to a reliance on ‘professional judgment’ amongst other methods. There is no indication of who will be doing what, what relevant experience the practitioners have and who the competent authority will be. These issues need to be addressed and clarified.
Chapter 9 – Ecology
Paragraphs 9.2.7, 9.5 lists specialist surveys which may be included as part of the assessment. However, there is no indication of where, when or by whom such surveys will be carried out. It is not clear who will be responsible for making the decision as to whether or not such surveys are required in particular locations, nor who will be consulted on this. NEAHS2 suggests adding Ancient Woodland including Perivale Wood Nature Reserve to the list of specialist surveys.
Chapter 12 – Landscape, townscape and visual assessment
Paragraph 12.1.4 and Figure 3. In identifying the zone of theoretical visibility (‘ZTV’) all construction, operational, mitigation and potential offsetting measures need to be assessed. The ZTV must include structure and infrastructure and also the loss of or change to individual landscape and townscape components currently present (railway embankment foliage, residential properties, and the visual impact of potential double decker trains, new bridges and noise barriers, if the proposed over ground HS2 route is constructed through the northern wards of Ealing LBC.
Paragraph 12.2.11 – the definition of the meaning of the word ‘tranquillity’ must be agreed and the impact of HS2 on the tranquility of ancient woodland such as Perivale Wood Nature Reserve and its habitats must be assessed.
Paragraphs 12.4.1 and 12.4.2 - The assessment of construction works must include:
- all temporary fencing,
- removal of existing vegetation along the line (including any advanced works and the period of time before reinstatement),
- temporary signage,
- spoil movements, machinery and personnel working within the route corridor; and
- construction traffic on public roads.
Infrastructure and utility diversions must include assessment of the wider impacts of road and rail closures and diversions and their impacts on local people. Features should also include cut and cover, bridges (road and footpath), road diversion /’upgrading’, lighting, pantographs and signage.
HS2 will have a very long construction period that will entail activity on both sections of the route and the route as a whole. There will be facilities set up that will be in use for long periods of time. Construction camps, equipment storage and maintenance, spoil storage and handling, haul routes, site haul roads and so on. Consequently such areas should not be considered as having short term impacts but should be recognized from the outset as having long term impact and their potential effect should be assessed on that basis. It has to be a matter of judgment as to what constitutes a long term construction impact but it is suggested that any facility or use that is in place for more than six months should be considered as an operational source and assessed accordingly.
Chapter 13 – Sound and vibration
The draft Report seeks to set out the topics and methodologies to be addressed in the EIA. In this regard there are areas in this chapter where such methodologies are not sufficiently detailed or explained. There is a danger that certain areas of examination will not receive sufficient study in depth. Previous processes of the public and professional consideration of HS2 on sound and vibration such as the AoS have been hampered by insufficient information. This scope must ensure that such information is now available.
The parameter LpAeq,T is used extensively within Chapter 13 to specify noise level thresholds, with different values of T covering both day and night periods. European Union Directive 2002/49/EC aims to define a common approach to the assessment of nuisance from environmental noise, including the “use of harmonised indicators and evaluation methods”. To this end this Directive, whilst allowing the use of “existing national noise indicators”in the interim, specifies two “selected common indicators” to be employed for the desired target of a common assessment method. One of these common indicators is the night-time noise indicator, Lnight, which is consistent with LpAeq,8hr, as used in Chapter 13 of the draft Report. The second common indicator is the day-evening-night level, Lden ; this is not employed for any of the limits specified in Chapter 13 of the draft Report.
NEAHS2 suggests that, in support of the aims of Directive 2002/49/EC, the parameter Lden should be used in Chapter 13 wherever this is consistent with the noise nuisance level being assessed. This seems particularly apposite in view of the long lead time of the HS2 project and the expectation that EU requirements will have been strengthened by the time that noise from HS2 activities affects UK citizens.
Paragraph 13.3.10 identifies the following issues associated with potential nuisance caused by airborne sound that were raised by responses to the consultation, but that are not addressed in Chapter 13:
- A request to present contour maps;
- The need to consider pantograph sound particularly in respect of the height of the source above ground compared to the height of noise barriers;
- That the assumed 3 dB reduction in train sound emission levels (compared to current high speed trains) may not be reasonable; and
- The need to assess sound levels in terms of the long term expected usage of the proposed scheme.
Paragraph 13.3.13 provides insufficient detail of how the mitigation of noise will be specified and its benefits assessed. HS2 Ltd has conceded, for example, that the impact of aerodynamic noise sources high up on the train “does need to be considered” and that the effects of this noise mechanism “will be reviewed at the time of the EIA”.
On the more general aspects of noise mitigation, in the AoS we are told:
“the way in which noise would eventually be mitigated would depend on various
considerations, such as engineering feasibility and effectiveness, and may use any of the techniques set out in Section 2, either independently or in combination, and these would be developed further as part of the EIA should the scheme be progressed.”
More specifically we have been told that:
“An Environmental Impact Assessment of the scheme would be undertaken at the next stage if the scheme progresses. This would confirm the heights of noise barrier required at each location along the route and would help develop the design principles by which taller noise barriers could be provided without causing significant adverse effects in other environmental areas e.g. landscape and visual.”
Since many types of barrier design are available, it is suggested that the EIA work should include an evaluation of noise barrier efficiency and whether other mitigation options such as tunneling are more appropriate from an environmental and human impact perspective locally.
On the topic of “performance specification of the rolling stock” HS2 Ltd has undertaken that “the train noise level will be revisited and checked for suitability as the input to the more detailed EIA”.
As well as reviewing the technical risk associated with the 3 dB(A) assumed reduction in source noise permitted by EU Decision 2008/232/CE, this work should also investigate whether it is also appropriate to make an adjustment to the assumed noise source level to account for track quality degradation during normal operations.
Paragraph 13.3.15 cites 50 dB LpAeq,16hr as a daytime threshold. It is suggested that the use of this parameter should be reviewed in the light of the suggestion made above (under “General note”) that “in support of the aims of Directive 2002/49/EC, the parameter Lden should be used in Chapter 13 wherever this is consistent with the noise nuisance level being assessed” (see also the comments made against paragraph 13.3.25 below).
Paragraph 13.3.16 employs the parameter LpAeq,T for quantifying the baseline sound level. It is suggested that the use of this parameter should be reviewed in the light of the suggestion made that “in support of the aims of Directive 2002/49/EC, the parameter Lden should be used in Chapter 13 wherever this is consistent with the noise nuisance level being assessed” (see also comments made against
paragraph 13.3.25 below).
Paragraph 13.3.19 advises, in respect of the proposed methodology for calculating airborne sound levels, that “The method has been further refined for HS2 to allow for aerodynamic sound sources at speeds over 300 kph”. We were told in the AoS that “the research basis for this change in calculation methodology is not currently available” An explanation of the way in which this previously advised limitation has been overcome should be provided.
Paragraph 13.3.21 advises that the “number and location of properties estimated to qualify under the Noise Insulation (Railway and Other Guided Transport Systems) Regulations (1996) will be reported”. It is suggested that the way in which this information will be presented should also be specified.
Paragraph 13.3.24 employs the parameter LpAeq,16hr for identifying the change in
daytime equivalent continuous sound level. It is suggested that the use of this
parameter should be reviewed, that “in support of the aims of Directive 2002/49/EC, the parameter Lden should be used in Chapter 13 wherever this is consistent with the noise nuisance level being assessed”.
Also in this paragraph, the maximum sound level, expressed by the parameter LpAF,max, is introduced as a noise metric to determine an operational sound impact. Whilst maximum sound levels did not form a part of the estimation of impacts upon receptors in the AoS, we welcome this introduction into the EIA procedures. This appears to be an overdue recognition, in line with World Health Organisation (‘WHO’) advice, that the use of equivalent continuous sound level alone does not give a full picture of the likely annoyance and health impacts of operational airborne noise from HS2 train movements. We have previously been advised by HS2 Ltdthat the maximum sound level of a train pass-by is approximately 14 dB(A) higher than the equivalent continuous noise level over eighteen hours. The anticipated train movement data presented in the AoS23 allows a calculation to be made that shows that the peak to equivalent continuous ratio is even more marked at night, at around 19 dB(A). These are very large margins indeed, and underline how imperative it is that a maximum sound level parameter is adopted as a criterion for assessing noise impacts for the EIA.
NEAHS2 also contends that 85 dB LpAF,max is much too high a level to be employed as an indicator of annoyance or health impacts. Compare this with practice on the Shinkansen Super Express Railway in Japan; the Ministry of the Environment of the Government of Japan has chosen a peak sound measure to set absolute noise limits for this railway. The parameter employed is identical to that now being specified for the EIA, except that a slow time constant sound meter setting is stipulated in Japan in place of the fast time constant used for the EIA. At 70 dB(A) in residential areas and 75 dB(A) in commercial and industrial areas, the Japanese maximum levels are well below what is being proposed in the current draft Report as a threshold level.
In order to put this in a UK context, reference may be made to Planning
Policy Guidance 24: Planning and Noise. Leaving aside the question of whether or not PPG24 is applicable to the construction of new railways, it can serve as a useful yardstick for this current purpose. A table is provided in PPG24 that defines four noise exposure categories (NEC) to be used in the assessment of a planning application25. A note to this table introduces a night-time level of 82 dB LAmax free field (equivalent to 85 dB LAmax façade), occurring “several times in any hour”, as a trigger to treat the receptor site as the second highest noise exposure category “C”. NEC C is categorised as loud enough to require that “planning permission should not normally granted”. So even in the UK’s noise tolerant regime, a peak level that achieves 85 dB LAmax is considered as fairly disruptive to life.
In the light of the above, it is suggested that the 85 dB LpAF,max threshold should be reduced considerably to a level which HS2 Ltd is able to demonstrate is applicable as a threshold which will “protect the majority of people from being moderately annoyed during the daytime”.
NEAHS2 also suggests that two values of peak noise should be specified; one for daytime and another, lower, level for night. The night threshold should be specified at a level that is consistent with the LAmax,inside threshold levels for effects reported by the WHO,
Paragraph 13.3.25 specifies a threshold for the equivalent continuous sound level over a 16 hour period, LpAeq,16hr of 50 dB(A). Whilst we appreciate that this is fully in accordance with WHO guidelines, we note that these predate European Union Directive 2002/49/EC by several years. It is suggested that the use of the 16 hour parameter should be reviewed in order to seek compliance with the EU aspiration of the “use of harmonised indicators and evaluation methods”.
This aspiration could be achieved in this case by the substitution of Lden for LpAeq, 16hr,whilst still retaining the threshold value of 50 dB(A). However, the WHO has also indicated that using a threshold of 50 dB(A) for new developments may not be appropriate:
“… most countries in Europe have adopted 40 dB LAeq as the maximum allowable level for new developments (Gottlob 1995). Indeed, the lower value should be considered the maximum allowable sound pressure level for all new developments whenever
The UK’s own Transport Analysis Guidance (WebTAG) states that a level of 45dB LAeq,18hr should be used “as the cut-off for both annoyance and valuation calculations”.
In view of these further WHO and WebTAG recommendations, it is suggested that the choice of 50 dB(A) for the daytime threshold is reviewed to determine whether it should be lowered. As night noise impacts were not quantitatively assessed in the AoS, the introduction in the EIA procedures of the night threshold of 40 dB LpAeq,8hr is a welcome addition. This threshold is the same as the WHO night noise guidance (NNG) of 40 dB Lnight,outside and is fully compatible with the “selected common indicators” of European Union Directive2002/49/EC.
Although the two thresholds that have been specified in paragraph 13.3.25 comply with WHO guidelines, the precedence that the application of these thresholds has over the change of 3 dB(A) in the equivalent continuous sound level may be problematic at previously tranquil sites.
The AoS also promises that “impacts on tranquillity and quiet areas would be considered in more detail as part of the EIA, should the scheme be progressed further” In accordance with WebTAG guidance, the draft Report requires that tranquillity impacts are assessed within “Landscape, townscape and visual assessment” and the matter is discussed in Chapter 12. However, this topic also impacts on the methodology to operate thresholds to determine the occurrence of sound impacts in previously tranquil residential locations and, accordingly, merits discussion under this current paragraph.
Paragraph 13.3.26 fails to specify how the impact calculations will be presented in the ES. It is suggested that noise contour maps, or possibly noise difference contour plots, should be specified.
Chapter 14 – Socio-economics
Though this Chapter is supposed to relate to both social and economic impacts, NEAHS2 considers that it relates primarily to business impacts. It does not appear that societal impacts are addressed in any detail at all. Instead it appears that the preparation of this chapter has been rushed resulting in a vagueness that does not help engagement.
Paragraph 14.1.1 mentions that a socio-economic assessment is needed. NEAHS2 wonders why this has not already been produced and fed into the EIA process. Furthermore, the Scoping Report does not detail: what is actually going to be assessed, what criteria are to be used to assess impacts on businesses and economies for example and where such businesses and economies actually are.
Paragraph 14.1.2 states that community implications are covered in the Community Assessment. What is this and where can it be found?
Paragraph 14.2.3 claims that stakeholder views will inform how best to approach the more qualitative aspects of some work. How will those views be ascertained and what likelihood is there that they will ultimately influence the outcome?
Paragraph 14.2.5 talks about baseline information being presented against comparator statistics for benchmark areas – what does this mean?
Paragraph 14.3.1 states that key stakeholders (only business related ones are listed) were consulted through a reference group in preparation. Who were the stakeholders and when were they consulted? Social impacts and costs to society may not all be related to businesses, in fact many such impacts and costs will be felt by both residents and visitors as well as businesses.
Paragraph 14.3.2 claims that 7,487 responses stated that the proposed network will create jobs across the UK and then states that ‘a number’ of respondents expressed doubt about the forecasted economic benefits (undoubtedly significantly more than 7,487). Without including a specific number in relation to the negative aspects we cannot gauge what level of opposition there was. This is misleading and disingenuous and should be corrected. This section also talks about communities that ‘would not see any benefits’. The EIA should clearly show what all impacts are likely to be – whether positive, negative or neutral.
In the northern wards of Ealing LBC the noise impact on schools will be a negative social impact of HS2, for example.
Paragraph 14.3.4 refers to the Socio-Economic Assessment being carried out. What is and where is it? Aside from the fact that we don’t know what it is or where to find it, we consider that such studies should be available now because the EIA Scoping Report at present lacks detail and transparency. This section also states that local authorities within 1-2km of stations, interchanges, junctions and depots will be consulted – NEAHS2 contends that this consultation should extended to apply to the whole route. In addition, NEAHS2 contends that because social and economic impacts on local communities are not addressed in the Community Chapter they should be addressed here.
Table 27 fails to address the negative impacts of job losses, homeownership losses, reputational damage, and loss of asset value and fails to address social costs such as longer journeys to work during construction phases and to services and facilities for example.
Paragraph 14.7.1 states that it is assumed that there will be no major changes in technology and method of work that lead to changes in the skills mix etc. This is an absurd statement and appears to be contrary to the Government’s own policy in connection with the desire to reduce the need to travel and takes no account of the fact that there are continual advances in technology at a rapid rate which do lead to changes in the methods of work. The rollout of high speed broadband is one such example which is more than likely to lead to a significant reduction in the need to travel.
Chapter 15 – Traffic and transport
Despite the statements in Section 15.1.2, the Board considers that all transport modelling should already have been undertaken, particularly as there may be later changes to the proposed scope of the EIA.
Paragraph 15.1.3 does not appear to contain sufficient detail by which to judge likely significant impacts. For example, it should clearly consider the impacts arising from the construction and operation of the scheme: temporary closures of all routes (roads and public rights of way/footpaths) including key routes such as the Hanger Lane (‘gyratory’) junction in Ealing and the severance or stopping up of all routes with a full consideration of the impacts on CO2 emissions, as well as any impacts on journey times and distances and changes in amenity for all users, not just those listed in this paragraph.
Paragraph 15.6.1 mentions the Transport Assessment – what is this and where is it? The Transport Assessment should be informed by a much more detailed scheme description that that which has been provided so far and by a much more detailed scoping exercise than provided in the current Scoping Report.
Paragraph 15.7 – NEAHS2 considers that Paragraph15.7.3 should also scope in the likely impacts arising from changes in technology which will result in both changes to demand forecasts and trip generation. The greater use of broadband for example will mean a decreased propensity to travel which will be in accordance with Government policy.
Chapter 18 – Structure of the Environmental Statement
NEHS2 is greatly concerned that this Chapter lacks any real detail at all. It appears to have been drafted in a rush and without undertaking adequate research. From the text included NEAHS2 is not reassured that the ES will contain the required topics and the right level of detail.
Once complete the ES (including all of the associated studies and appendices) should be published in paper form, particularly for those people that request it and those that are not able to access electronic copies, and made widely available for a full period of public consultation which should last at least 12 weeks. Everyone that is involved in the process should feel confident that any engagement with it will be likely to influence the outcome.
Paragraph 18.1.2 is considered to inadequately reflect what will be required as part of the ES. Not only should the ES include detail about the main alternatives studied taking into account the environmental effects, it should also say why they have been rejected. The effects on the whole route should be addressed (not ‘a number of sections’ as described in the fourth bullet point) and this should cover the whole of the ‘Y’ route impacts as well. The main report should contain a detailed description of all the assessments that will have been done, not just some of them with others relegated to appendices. The main report should also include detailed descriptions of all mitigation that is to be proposed and the likely impacts arising from such mitigation. This paragraph should also have detailed the likely content of the ES and at present it does not.
Paragraph 18.1.3 lists a series of documents that will be produced to support the Environmental Statement. NEAHS2 considers that the following should also be available:
- assessments of mitigation measures,
- studies of mental health and well-being/psychological impacts (in addition to the Health Impact Assessment),
- community assessment (which has been mentioned in the Scoping Report without any background detail and is not detailed here either),
- noise contour maps, and
- GIS files for results and analysis at sufficiently detailed scale to allow interpretation at a local level
NEAHS2 – 30 May 2012