HS2 Environmental Statement Summary – not fit for Purpose



The Independent Assessor’s High Speed Rail (London – West Midlands) Bill: Summary of Issues Raised by Comments on the Environmental Statement Report, prepared by Golder Associates, was published on 9 April 2014. It was submitted to The Examiners of Petitions for Private Bills, who in turn submitted it to the House of Commons, which had in fact ordered its publication on 7 (not 9) April.

It is this summary that MPs will be relying on to inform them about the responses to the Environmental Statement (ES) consultation but like the ES upon which it supposedly focuses, it is a woefully inadequate and unreliable document, despite its being produced by authority of the House of Commons.

The report condenses its deliberations on the 21,833 comments relating to the c. 50,000-page ES into 89 pages, which makes it of questionable value before any other consideration is taken into account. 32 of these pages are given over to Tables and Figures – representations of the responses in diagrammatic form: pie charts showing Response types (letter/email with/without standard text; letter/email with 2-5, 6-10, 11-50, over 50 pages; postcards/without standard text); block graphs ranking the Key Issues to emerge from the consultation, under the heading of Environmental Topics.

The top priority among these key issues, according to the report, was the provision of a tunnel under the Chilterns AONB, the Northolt tunnel extension and the tunnelling of the HS1 link across Camden.

Second was the adverse effect on local communities, followed by concerns about sound, noise and vibration; fourth, significantly, and not at all surprisingly, were complaints about the consultation process with regard to the ES, the time frame allowed for the consultation and the historical communication process between communities, individuals, organisations and HS2 Ltd.

All this seemingly objective presentation of data covers an overview of all the responses, analysis one by one of all 26 Community Forum Areas, plus analysis under headings such as Chilterns, London, Birmingham, and Other or Area Not Specified.

It doesn’t however do justice to the large number of responses submitted with careful, detailed critiques of the ES; the written summaries that accompany the pie charts and graphs are so abbreviated as to be of very little value, and they certainly go no way towards representing the views of the massive number of respondents, some of whom were acting on behalf of groups and organisations with very sizeable memberships.

Some individual CFA write-ups merit only a few lines; bottom of the league is CFA 5 which gets only one seven-and-a-half-line paragraph; the rest range from 2 to seven paragraphs, apart from CFA15 which tops the bill with 8 paras, albeit 2 of them with only 2 lines each. None runs to a full page, and all are an insult to the time and care taken by many to make an intelligent and informed response.

It isn’t made clear whether the 21,833 comments equates to that number of responses received, so that’s the first statistic over which there’s a question mark. If one were to take this report at face value, and leave the critique of its contents at that, there would be sufficient cause for concern that it’s a totally inadequate basis upon which to form any accurate impression of the volume and strength of opposition to this project.

Looking more closely, however, alarm bells should be ringing loudly at Westminster on 28 April, when the Commons debates the Second Reading of the Hybrid Bill.

There is something highly suspect about the data analysis, particularly with regard to the number of postcard responses that are claimed to have been received, that should be independently investigated and publicly corrected before this Bill proceeds any further.

Looking at the overall analysis of responses in the Types of Responses by Volume chart on p.4, a total of 12,521 postcards were apparently received, by far the largest category by type, of but there’s a huge discrepancy between this figure and the numbers claimed for each individual CFA on pp. 24 – 74.

Large numbers of postcards were distributed, for example in CFAs 8, 9 and 10; the report claims, however, that in CFA 8 only 2 were received, and in CFAs 9 and 10 only one was received in each.

This simply is not credible, when there is irrefutable confirmation from these CFAs that many more than that were posted. The situation becomes even more bizarre when the numbers for all the CFAs are examined.

Of the 26 CFAs the report shows that:

15 of them (inc. CFAs 9 & 10) submitted only 1 postcard each;

a further 2 CFAs (8 & 15) submitted 2 each;

CFA5 sent in 5;

CFA3 was next with 7;

CFA1 managed 19;

then improbably we jump up to:

CFA21 with 115;

CFA16 with 123;

CFA22 with 576;

CFA2 with 1677;

CFA6 with 2476;

CFA7 with 2479.

This adds up to only 7496, as opposed to the 12,521 quoted in the Types of Responses by Volume chart on p.4.

In addition, there are a further 37 postcard submissions attributed to Other and Area Not Specified, with 4 attributed in total to London, Birmingham and Off-Route Stations. Surprising, West Coast Mainline respondents, whoever they were, apparently submitted 562, postcards.

Even adding these 603 submissions to the 7496 CFA total, it comes nowhere near the 12,521 claimed.

To complicate the issue even further, on p.76 it is asserted that there were 8081 responses relating to the Chilterns area, 7513 of them on postcards! Evidently those living in the Chilterns AONB could only muster a handful of postcard responses about its decimation, while the respondents along the rest of the route were flooding Dialogue by Design with postcard protests about it.

So, what’s going on with the postcard count? Without this last Chilterns addition, only 8099 are accounted for (suspiciously close to 8081, the figure given for the total number of Chilterns responses); add in the Chilterns postcards and the figure is 15,621. Whichever way you try to rationalise the analysis, it doesn’t stack up.

Looking back at the CFA postcard submissions, there’s also something very suspicious about adjacent CFAs 6 and 7 having submitted 2476 and 2479 postcards respectively, when no other CFA comes remotely close to that number.

Either this is very shoddy and grossly misleading work, or the methodology of the analysis is not clearly explained, and we are missing a fundamental principle of analysis to which only the initiated are privy. It’s doubtful that MPs will have had the time or inclination over the Easter recess to discover which is the correct explanation, even if they’ve spotted the inconsistencies for themselves.

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