While everyone familiar with the progress from HS2 Ltd is used to delays, with there still being no sign of the Stage 2 route or the consultations which were promised in ‘spring’, one thing has come ahead of schedule is the publication of the revised Scope and Methodology document for the HS2 Environmental Impact Assessment.
Those in the know were not expecting to see this published until September 17th, but for some reason HS2 Ltd chose to publish their report on 4th September, just a couple of hours after a change in Secretaries of State at the DfT when all the focus was on the implications associated with the reshuffle, the perfect day to bury bad news. The publication on the 4th had definitely been too early for the HS2 Ltd staff team attending the Stoneleigh, Kenilworth and Burton Green community forum the day after on 5th September, as every question relating to it –even when staff were told by people who had read the relevant sections what it contained- was “We’ll take that one away.”
Earlier this year there had been a consultation into the scope and methodology of future (and ongoing) environmental assessments. In simple terms, that consultation was about what HS2 Ltd should measure and how they should measure it when looking at the likely environmental impacts of HS2. The subsequent report has set the goalpost, and while a detailed analysis of the 231-page document is ongoing, at first glance it seems the goalposts have been taken from a Subbuteo pitch.
The first and most obvious headline is the noise assessments. Ever since campaigners first found out the plan over two years ago, they have been incensed by the idea that noise assessments will be made on the basis of average noise. So if you have a train going past every four minutes, you make up a noise figure (see below) for the, say 30 seconds, of the train going past then add on the three and a half minutes of silence and average the whole thing out to get the noise levels. This completely ignores the way the human (and other species) brain works, in that a constant noise is far easier to deal with in terms of mental health and sleep than a sudden noise from nowhere. While HS2 Ltd have said they will measure peak noise, they intend to stick with the outdated legislation in terms of where noise barriers have to go.
Also on noise they were questioned in the consultation about their insistence that due to technology which has not yet been invented, HS2 trains will be 3 decibels quieter than current high speed trains. Bullishly, they insist “High Speed Technical Specification for Interoperability and has been demonstrated to be reasonable in the AoS.[Appraisal of Sustainability]”, despite those on this side of the fence being of the opinion that nothing was adequately demonstrated in the farcically weak document which was the AoS.
With the usual high-handedness that we have come to expect, many issues have been ignored and side-stepped. The idea that assessments should take place over a number of years has been translated to them taking place over a number of seasons and of course as we might expect HS2 Ltd have completely ignored the Aarhus Convention and part of the basis of one of the legal challenges which will be heard in December; Aarhus demands that a full Environmental Impact Analysis should take place not only on the chosen route, but also the strategic alternatives to allow a proper comparison of schemes. HS2 Ltd have stated they have no intention to do this whatsoever.
We are certain there will be more shocks and disappointments which come out of the revised Scope and Methodology document for the HS2 Environmental Impact Assessment, but besides reshuffle day being a good day to bury bad news, a 231 page document was an excellent place to bury it too.