Comparisons are odious

This is a guest post by Peter Delow, who writes the blog HS2 and the Environment.

As already announced on this website, HS2 Ltd has issued the document HS2 London to West Midlands EIA Scope and Methodology Report (at in draft for consultation. This is an important publication as it will, as it says in its title, set the scope of the environmental impact assessment (EIA) work and the methodology to be employed.

I have been looking at Chapter 3 of this document, which describes how HS2 Ltd proposes to report on the alternatives to the current HS2 proposal in the Environmental Statement (ES); the ES is the document that will be produced summarising the findings of the EIA to inform Parliament when it considers the hybrid bill. The reason that this chapter has been included in HS2 London to West Midlands EIA Scope and Methodology Report at all is because it is a requirement of a European Union Directive. The piece of European legislation that applies is Council Directive 85/337/EEC, as amended by Council Directive 97/11/EC (at This EU legislation applies to “the assessment of the environmental effects of those public and private projects which are likely to have significant effects on the environment”.

Article 5 of the amended directive requires an environmental impact assessment to be carried out and for the results of this assessment to be supplied “in an appropriate form”; in the United Kingdom this “appropriate form” is the ES. Paragraph 5 of Article 5  requires the ES to include:

“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.”

I regard the last six words of this phrase as essential to the purpose of this requirement.

What is necessary is that the reader of the ES is given sufficient information to allow him or her to compare the environmental impact of the developer’s preferred solution to alternative means to the same, or similar, end that will have different, possibly lesser, environmental impact.

For example, two alternative solutions for providing increased rail capacity between London and the West Midlands are to upgrade the existing West Coast Main Line and to build a new railway, still at high speed but not for 400 kph, using one of the existing transport corridors such as the M1 or M40. I strongly suspect that both of these alternatives will have a lower environmental impact that the current HS2 proposal. However, the search for alternatives need not necessarily be restricted to rail solutions; the approach for catering for a perceived increased demand to travel to and from the Capital and the West Midlands might be to expand other travel modes, or to depress demand (e.g. by using price as a mechanism), or to develop alternatives to travel (e.g. broadband).

The ES will not be a complete analysis without taking this broader view and considering the environmental implications.

Unfortunately, my impression from reading Chapter 3 of HS2 London to West Midlands EIA Scope and Methodology Report is that the intention is to ignore the requirement to report in the ES on the environmental effects of the real alternatives to HS2.

That this is a fair interpretation is surely clear from paragraphs 3.1.1 to 3.1.4 of HS2 London to West Midlands EIA Scope and Methodology Report, which I would paraphrase as:

More inter-city travel capacity will be needed over the next twenty to thirty years and the Government has decreed that this should only be provided by increased rail capacity, and moreover that there is a clear case for this capacity to be provided by high speed rail. Upgrading the existing network will not satisfy demand, they say, and will mean unacceptable disruption. Also, high speed rail will bring additional benefits. Since a new railway is necessary, the only choice is whether this should use conventional or high speed rail technology. Opting for conventional speeds will not significantly reduce cost or environmental impacts and would reduce the value of benefits. HS2 Ltd has spent two years looking at alternative configurations for a new high speed line and, except for changes by way of mitigation, this chapter is considered closed.

Any doubt about the intention of HS2 Ltd to ignore a consideration of the environmental impacts of the alternatives is removed by paragraph 3.1.5:

“The Environmental Statement (ES) will provide an outline of the main alternatives studied by HS2 Ltd and the Department for Transport (DfT) and the reasons for their rejection.”

Loosely translated, I think this amounts to “we will repeat all the stuff that we have already published”.

Leaving aside the matter that many of the assertions in this HS2 Ltd summary are contentious, it completely ignores the inconvenient consideration that the quest for truly sustainably development may mean that you have to settle for something less than you think you want in order not to impoverish future generations unduly.

The intention of HS2 Ltd appears to be to avoid having to admit that solutions other than HS2 are likely to have much lower environmental impacts. We have already seen this tactic employed in the AoS. I commented in my blog There’s more than one way to skin a rabbit (at that despite claims by HS2 Ltd that the AoS was intended to be compliant with the Strategic Environmental Assessment Directive, it had clearly failed to meet the SEA requirement to compare the environmental impacts of the reasonable alternatives.

Clearly, as far as HS2 Ltd is concerned, “comparisons are odious”.

One comment to “Comparisons are odious”
  1. It is very worthwhile each organisation producing comments to the scope and methodology EIA draft on the HS2 web site. The methodology requires to address specific projects within the route 3 proposed scheme and and compllete scheme with suggestions for changes/alternatives and other Routes such as Route 4. The EIA needs to be more than a support for hybrid bills. In many nations the EIA is coupled with Environmental Management Protection plans and stategies. Without a robust response to HS2 on this superficial document on the web of 223 pages there will not be the robustness needed for the judicial reviews and for the protection of areas currently disregarded. The AOS documents are not suitable baselines for the proposed scheme and they lack local inputs and rigour. The forums are conversation opportunities and not decision making and changing venues. More structured approaches are needed to the draft EIA than appears to be emerging and perhaps it is because there are not the links to more local specialists in each of the areas. There are some noticable omissions from the topic scope of the EIA which need addressing.

    It is understood many environmental impact and protection people are out of work and it may be possible to engage with specialists such as Peter to have documentary inputs to the parish councils and to the district councils and the county councils and to the HS2 people before noon on the 30th May 2012. The impacts are stil emerging as land take and facilities and work site locations are unknown. Local people can address those issues concerns and problems within the responses and then no one can say HS2 did not realise.

    The more inputs to this draft consultation the more on specifics and doubts the more the EIA for hybrid bill support will become questioned against the more pressing issues of real local impacts. Again HS2 is not providing the detail to judge the Environmental Impacts fully but is trading on vague text and grandiose notions. The EIA will not reveal the concerns people have because of the routing of HS2 unless the people who can read the sections as Peter has done to select those impacting their business, their daily school journies, or their level of dust inhalation and who submit comments to hS2 before the deadline.

    Otherwise it will be another situation of asking the public and the public not reacting to the extent of the environmental impacts. Remember there was one inadequate instruction ot comment on the AOS in February 2011 and the AOS was a volume of images and text not easily digested or addressed. This EIA draft is again 200 page of structured text with little contribution to the design and construction processes. Please do not waste the opportunity to make you concern heard by HS2 and submit meeaningful reasons of concerns, issues and requirements. Thank you.

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