Please submit your comments by 11 July
RESPONSE TO PHASE 1 DRAFT ENVIRONMENTAL STATEMENT CONSULTATION
I wish to make the following comments, to be included in the DES Consultation.
General
Despite the huge volume of material presented, the assessment remains superficial and incomplete. The worst of the environmental effects of HS2 are obscured; it underplays the likely noise and visual effects; omits HS2’s carbon impacts and dismisses without proper explanation many local mitigation proposals.
The DES confirms that HS2 as currently designed will have a highly negative impact on our environment. It will require a significant landtake, severely damage irreplaceable ecosystems, sentence people and communities to years of construction disruption and cause permanent damage when built.
The DES does not provide convincing evidence of the need for HS2. It fails to state why the need cannot be met or moderated in some other way.
Community Forum Area Report 8: The Chalfonts and Amersham
Economic impact: no account has been taken of the economic impact of construction and operation of HS2 on the local tourism economy. Amersham station is a key entry point for walkers in the Chilterns and Amersham Old Town also benefits from staying visitors. Visitor numbers will be seriously affected by noise, traffic and visual impact during the construction of the Amersham ventilation shaft, the tunnel entrance at nearby Mantles Wood and hugely intrusive work in the neighbouring Central Chilterns - Area 9. Destruction of the Chiltern landscape, and noise, will continue to deter visitors once HS2 is in operation.
Traffic: the DES shows that construction of the Amersham vent shaft will generate in the region of 200 lorry trips per day, disrupting traffic flow to South Buckinghamshire Hospital and Amersham Old Town, the A413, A355 and other approach routes to Amersham. It is stated that the CoCP would seek to minimise lorry trips “as far as reasonably practicable” and would “include HGV management and control measures”. Without further detail, these supposed assurances are meaningless.
Noise and vibration relating to tunnel boring, shaft construction and operation: throughout the DES, the level of “assumptions” made on these key issues is wholly unacceptable. For example:
The DES states that tunnel boring machines will generate “short-term” ground borne noise and vibration to be suffered by residents “within a close distance of the centre line of the tunnels” – a totally inadequate guideline. It is “assumed” that the drives (for the twin tunnels) “would be staggered in time so there would be no combined effects from them.” If this is so, it will double the period of noise and vibration suffered in all affected locations. This is not acknowledged in the DES.
During the operation of HS2, potential “minor ground borne noise and vibration” has been forecast at a small number of properties “very close to the tunnels”. Details should have been provided to clarify this statement. In particular, it is noted that the hospital in Whielden Street potentially has a high sensitivity to vibration, being just 122 metres from the tunnel. However, at this stage it is only “considered unlikely” that the hospital will suffer any adverse effects.
It is also only “assumed” that “significant noise ..from tunnel vent shafts … would be avoided through the design and specification of shafts and fixed plant and equipment.”
It is stated that vibration from tunnel boring machines, and the operation of HS2, will “present no risk of any building damage”. Problems of subsidence or building damage experienced by HS1 do not appear to be acknowledged or addressed. This is a serious omission.
Dust: the CoCP makes no mention of site-specific dust assessment. The National Planning Policy Framework makes it clear that a dust assessment study should be undertaken by a competent person/organisation with acknowledged experience of undertaking this type of work.
Visual Intrusion: “Appropriate measures to reduce landscape, visual and other environmental impacts associated with temporary site offices and compounds” is so vague as to be meaningless. “Relevant local authorities…..will be consulted, as appropriate” does not provide for agreement with the local authorities to screen the compound of the Amersham vent from public view.
Draft Code of Construction Practice
Throughout the DES great weight is attached to the draft CoCP – yet this is seriously flawed.
Under the proposed Code of Construction Practice, contractors would be largely self-regulating. There are no independent safeguards to ensure that the working practices set out in the code are met. No redress is identified if assurances given to petitioners and Parliament are not met - as happened with HS1. There is, therefore, nothing to protect the interests of local communities during the prolonged and hugely intrusive construction process. As all evidence shows that contractors cannot be relied upon to ‘police’ themselves, the code as it stands is worthless.
For the CoCP to be fit for purpose, the following measures must be put in place:
- Local authorities must be empowered to approve local construction agreements and monitor their progress. It is not enough for local authorities to be ‘consulted’ on local construction practice: experience of HS1 has shown that their views would simply be ignored.
- Crucially, local authorities must have the powers to suspend work where agreed working practice is breached.
- The government must earmark funds to enable local authorities to recruit dedicated Environmental Health Officers who are properly qualified to carry out these functions on behalf of local communities.
- It is noted that the Local Environment Plan site controls are to be provided after the Bill submission has been made in support of the Hybrid Bill. Comments from local authorities and communities will have to wait until then. Commenting at that stage will be an expensive and difficult task and may well be too late.