text: CHILTERN DISTRICT COUNCIL – Response to High Speed Rail: "Investing" in Britain"s Future Q1. This question is about the strategy and wider context (Chapter 1 of the main consultation document): Do you agree that there is a strong case for enhancing the capacity and performance of Britain"s inter-city rail network to support economic growth over the coming decades? 1.1 This Council agrees with the 51m position that there is likely to be a need for some increased capacity on the inter-city rail system in the next few years but it does not believe in any way that the solution to the provision of this additional capacity is HS2. 1.2 This Council agrees with the 51m position that there is likely to be a need for some increased capacity on the inter-city rail system in the next few years. We agree that there is not by some margin the level of need set out in the business case; capacity enhancements should not be provided in a massively expensive and high risk project and that the opportunity costs are far too high – there are better and quicker ways to get the national and regional economies moving. 1.3 The Government needs to think more fully about the regeneration case – Local Authorities based in the North and Midlands instinctively will ask for their share of the cake in public investment decisions, believing that they have not had their share in the past. However, Government must:- (i) Be clear on the value for money issues. (ii) Be clear that HS2 will not create unintended consequences, eg reinforce the dominance of London, and its labour catchment area, and will not result in the desired high tech, manufacturing or head office investment in the North and Midlands (developed in the response to Question 3). (iii) The Government"s own National Infrastructure Plan, published in October 2010 states: 4.2 In addition, the Government has identified a new hierarchy for infrastructure investment that builds on the approach to capital investment in the Spending Review to inform investment decisions. Maintenance and smarter use of assets. The priority is to make the best use of the extensive assets that are already in place through maintenance and demand management. There needs to be a much stronger emphasis on use of innovative demand management without stifling growth. For example, the managed motorways programme is using technology to maximise the available capacity, varying speed limits and enabling use of the hard shoulder at busy times. Targeted action to tackle network stress points and develop networks. Where maintenance and demand management investment needs to be supplemented, the focus of new capital investment should be on pinch points to enhance resilience and capacity of the network overall and where new networks need to be developed. Small investments can often be much more cost effective in tackling issues like congestion. Transformational large scale capital projects. Significant investment in new or replacement infrastructure should only be -1- CHILTERN DISTRICT COUNCIL – Response to High Speed Rail: "Investing" in Britain"s Future considered where it is a part of a clear long term strategy, is affordable and where maintenance or small scale investment will not meet future need. There is no such strategy to underpin HS2 and there are alternatives, such as the development of Rail Package 2, which have not been fully considered. HS2 does not make better use of existing assets and does not address stress points or the railway network as a whole. (iv) The Government is not following the advice of its own and immediate predecessor reports: "…because the UK is already well connected, the key economic challenge is therefore to improve the performance of the existing network… There are very high returns from making best use of existing networks [with…] large projects with speculative benefits and relying on untested technology, are unlikely to generate attractive returns" (Eddington 2007). "…there should be a move away from "predict and provide" to "predict, manage and provide", with much better use of existing system capacity" (McNulty 2011). The Department of Transport"s predict and provide approach to motorway building had been discredited by the 1980s. (v) The project has been discredited by many commenters, most recently by the respected economic think tank: the Institute of Economic Affairs: "High Speed 2 is another political vanity project – like Concorde and the Millennium Dome – being ploughed ahead with complete disregard for properly thought-through commercial prospects or the mounting opposition to it. Its environmental credentials are questionable, its projected passenger figures suspect, and its proposed regenerative effects highly dubious. Proceeding with HS2 plans is a recipe for disaster and, as always, it will be the forever-embattled British taxpayer who will end up footing the bill for this latest white elephant."1 Q2. This question is about the case for high speed rail (Chapter 2 of the main consultation document): Do you agree that a national high speed rail network from London to Birmingham, Leeds and Manchester (the Y network) would provide the best value for money solution (best balance of costs and benefits) for enhancing rail capacity and performance? 1 Dr Richard Wellings: High Speed 2: the next government project disaster? -2- CHILTERN DISTRICT COUNCIL – Response to High Speed Rail: "Investing" in Britain"s Future 2.1 No. 2.2 We agree with the 51m stance that:- The UK is not comparable with Europe in terms of HSR as distances are much shorter and we already have a modern 125mph railway (WCML) compared with slow European classic networks and thus journey time savings will be far less than has been experienced in Europe. Demand growth predicted by the DfT on the classic network can be provided for by increasing capacity on the WCML as and when required, predominately by lengthening and reconfiguring trains with limited infrastructure. This argument is strengthened even further when the Chiltern Evergreen 3 project, being delivered this year, is taken into account. The Government should be looking to provide low risk solutions with public funds. The ability to run 18 trains per hour is not supported by the evidence and this has a significant negative impact on the HS2 business case. Use of a realistic "do minimum" case would significantly reduce the comparative benefits of HS2. If HS2 and alternatives were compared against the same base, the case for HS2 would be weaker. There are serious concerns about the demand forecasts produced by the DfT which leads to the conclusion that the lessons of previous optimistic forecasts have not been learnt. Sensitivity tests and more severe downside assumption should be factored into the evaluation, which would have a major impact on the business case. There are serious flaws in the assumptions upon which the benefits analysis is based and even if you make a conservative adjustment for these failings, the overall business case would be seriously undermined. There is a great deal of work to do on the economic case before a decision can be made for HS2 to proceed. 2.3 We make the following additional points of emphasis. (1) We consider insufficient attention has been paid to the need for inter-city connectivity. Links to London, even by international comparisons, are already good. Looking at inter-city links, HS2 does nothing for the extremely poor services between Manchester and Sheffield, the slow (but frequent) Leeds-Manchester services. Newcastle, Teeside, Bristol, Exeter, Cardiff, Liverpool and Hull remain out on a limb. This accounts for the low level of diversion from the private car – only 7%. Consequently, the Government should be investing in improving the network as a whole rather than creating premium services with public subsidy for a narrower range of destinations. -3- CHILTERN DISTRICT COUNCIL – Response to High Speed Rail: "Investing" in Britain"s Future A very good example of this approach to improving the networks is Chiltern Railways Evergreen 3, with increased speed and capacity on the Marylebone-Birmingham link. The existing service is well regarded locally for its reliability, frequency and competitive walk on fares. Its connectivity with other services is also being improved – the only disadvantage is the Moor Street/Snow Hill destination is less useful than New Street. HS2 will of course create another, even less convenient, terminal in Birmingham; 10 minutes walk from New Street with any improved linkages an addition to the costs in the business case. A particular attraction with Chiltern Railways is the good "door to door" times because of accessibility of stations on foot or by cycle plus good parking. This enhances convenient travel opportunities and provides the real prospect of car journeys diverted from the M40. (2) Given the context of transport capital funding being reduced by 11% in the 2010 spending review, cost effective improvements to the network become even more important. Rail is a particularly inefficient industry – efficiency savings of 20-30% are required (McNulty). This means a £16bn annual cost reduction by 2018. (3) We have grave doubts over the calculation of transport user benefits. "Research also shows that the level of productivity that can be achieved on a train is very similar to that which can be achieved at a normal workplace. For instance, the Mott MacDonald IWT Consortium study in 2008 found that the average productivity factor – or the amount of working time needed if work were done at the normal workplace relative to that on a train – is between 96% and 98%, depending on the duration of the train journey. However, this is at odds with earlier studies, which have suggested that around 10-20% of rail travel time may be productive. There are three potential effects of including productive use of travel time in the appraisal:- it would reduce the benefits attributed to the reduction in travel time because the value placed on these time savings is dependent on how much the time spent travelling costs the employer, which would then be negligible/significantly lower; it would increase the benefits for passengers remaining on conventional services, who would experience less crowded conditions (currently, the only benefit from reducing crowding is reduced discomfort); it would increase the benefits when passengers switch from other modes if they can work more productively on HS2 than on their previous mode of travel.2 We trust the Secretary of State"s decision will be informed by this independent research commissioned by the Transport Select Committee. (4) The Government needs to be in tune with what the public say to it on transport policy. "The prime wishes of the public as regards transport are a reduction in the number of potholes and lower charges for fuel; lower rail fares come way down the agenda, let along the building of High Speed Rail. The public, let along industry, are not really 2 Review of the Government"s Case for High Speed Rail Programme. Report for the Transport Select Committee, prepared by Oxera, 20 June 2011 -4- CHILTERN DISTRICT COUNCIL – Response to High Speed Rail: "Investing" in Britain"s Future engaged in the case for it." These concerns certainly echoed by local residents in Chiltern.3 Q3. This question is about how to deliver the Government's proposed network (Chapter 3 of the main consultation document): Do you agree with the Government"s proposals for the phased roll-out of a national high speed rail network, and for links to Heathrow Airport and the High Speed 1 line to the Channel Tunnel? 3.1 No. 3.2 We agree with 51m"s conclusion that there is no economic case for providing links to Heathrow and HS1. This is compounded by there being no train paths for these services. 3.3 It is clear that the operation of through services will require significant unjustifiable subsidies which will worsen even further the benefit cost ratio for HS2. The link will increase capital costs, reduce capacity into Euston and reduce overall reliability. 3.4 A supporting argument often used for the HS2 connections to both Heathrow and HS1 is that it will reduce domestic air travel and thus have significant carbon emission benefits; however it is clear that the aviation industry has a different viewpoint. Nigel Milton, Director of Policy for BAA at Heathrow, stated in March 2011: "No sensible, well-informed person still seriously pretends HS2 is a green alternative to a third runway. The question now is given no third runway, how we can maximise the effectiveness of our limited capacity at Heathrow. That means more long-haul flights…every time BMI or British Airways have cancelled a domestic route in the past they"ve replaced it with a more profitable medium- or long- haul route. That"s exactly what will happen when HS2 comes and more domestic routes get cut." 3.5 The response to this questions links back to Q1 and the need for a clear national policy on infrastructure and transport, including airports. Q4. This question is about the specification for the line between London and the West Midlands (Chapter 4 of the main consultation document): Do you agree with the principles and specification used by HS2 Ltd to underpin its proposals for new high speed rail lines and the route selection process HS2 Ltd undertook? 4.1 No. 4.2 The DfT has failed to properly consider alternatives, and using a "cart before the horse" approach has reached a view on the principles of HS2 before it being necessary or desirable. 4.3 We agree with the 51m response. 3 HS2 and National Policies, Modern Railways, July 2011 Prof Stephen Glaister -5- CHILTERN DISTRICT COUNCIL – Response to High Speed Rail: "Investing" in Britain"s Future 4.4 We would add that commuter, business and leisure traveller have different needs and ways of using trains. Thus the value of IT facilities and luggage varies. Japanese Shinkansen trains are so confined for space anything more than an overnight bag has to be conveyed separately by van leading to adverse carbon impact. The current generation UK trains are far more luggage friendly and better designed for the leisure traveller. The current proposal seems to be to create a high speed commuter route. 4.5 Business travellers value frequency and reliability – the walk on facility so popular on Chiltern Railways. The ECML diesel sets are still popular because of their reliability on travel times. Current thinking seems to be to make trains more like planes – terminal to terminal with no stops which is a retrograde step and diminishes the value of the network as a whole. Q5. This question is about the route for the line between London and the West Midlands (Chapter 5 and Annex B of the main consultation document): Do you agree that the Government"s proposed route, including the approach proposed for mitigating its impacts, is the best option for a new high speed rail line between London the West Midlands? 5.1 There are so many problems with the consideration of the environmental impacts, and therefore route selection, that it is not possible to make informed comments on optimum routes or mitigation. We consider this further with our response to Q6. Q6. This question is about the Appraisal of Sustainability (Chapter 5 of the main consultation document): Do you wish to comment on the Appraisal of Sustainability of the Government"s proposed route between London and the West Midlands that has been published to inform this consultation? 6.1 These comments relate to Q5 and Q6 – we consider that the Appraisal of Sustainability is inadequate and flawed. 6.2 We agree with 51m"s comments on the Appraisal on Sustainability (AoS) and approach to mitigation. We do have particular concerns because of the unique character of our area which comprises Area of Outstanding Natural Beauty and Green Belt. 6.3 72% of the area of Chiltern District is designated as an Area of Outstanding Natural Beauty and 88% lies within the Metropolitan Green Belt. Located just 25 miles north west of London and just outside the M25, the capital can be reached in about 30 minutes by rail (Chiltern Railways Aylesbury and Birmingham lines) and the LUL Metropolitan line. Chiltern"s overall population is 90,900 and growing – the level of development and outward pressure from London were the reasons why the area was designated as Green Belt. That development commenced in the early part of the 20th century when "Metroland" was created: rail investment was followed by residential development, characterised by John -6- CHILTERN DISTRICT COUNCIL – Response to High Speed Rail: "Investing" in Britain"s Future Betjeman, who also referred to an earlier grandiose scheme for linking the north with Paris and Europe.4 6.4 We are now faced with another grandiose scheme, and the experience of our community illustrates the impact of rail investment on property values – but not the commercial and industrial official values and activity so important in the regeneration of the midlands and north of England economy, but residential property and the outward spread of communities. Birmingham will have comparable travel times to the capital to the original Metropolitan line journey from Baker Street to Amersham. The labour catchment area – daily and weekly commuters – will be extended as a consequence. This centralising tendency is the reverse of what the Government apparently intends. HS2 will make it quicker to get to London from a small range of locations, and the commuting/travelling distance will extend to those locations. 6.5 We have divided our assessment of the sustainability impacts into the economic and distributive impacts, green belt and AONB; the Government"s commitment to overhaul planning policy; localism and local environmental impacts. (1) Economic and Distributive Impacts 6.6 We are concerned that the Government has not thought through the economic and distributive impacts of HS2. These themes were picked up in the Oxera report. HS2 Ltd stresses the need for high-speed rail to be fully integrated into local and regional economic and spatial strategies in order that maximum economic benefits are obtained. This is likely to be an important enabling factor in the Government"s desire to see the high speed network changing the economic geography of the country: The Government believes that high speed rail can play an important role in promoting valuable strategic change in the economic geography of Britain, supporting sustainable long-term growth and reducing regional disparities. In practice, there are likely to be higher benefits in the vicinity of high speed rail hubs, so the "regeneration" benefits to those areas are likely to be understated. However, these may be offset by economic losses in other areas, including locations not served by the high speed line – the "tunnel effect". Thus, the London and Birmingham economies might benefit partly at the expense of areas not served by the new scheme. The precise impacts will depend on the reallocation of conventional services on the WCML and elsewhere. The AoS does note that there could be inter- and intra-regional redistributive impacts, and that people may be attracted to locate around HS2 stations in London or Birmingham, at the expense of other parts of those cities or other cities in the UK. In its April 2011 document, HS2 Ltd forecasts the monetised impacts of transport benefits and WEIs by region, calculating that 34% of benefits (by origin of trip) will 4 BBC TV 1973 Metroland (reissued on DVD) -7- CHILTERN DISTRICT COUNCIL – Response to High Speed Rail: "Investing" in Britain"s Future go to those from London. It also notes that the longer-distance rail users who will be the principal beneficiaries of high speed rail are likely to be from London, Birmingham, Manchester and their surrounding areas. However, a number of impacts of the proposed scheme have been assessed at the route level only. This prevents a clear indication of whether the benefits or costs are concentrated in certain regions. Some of these factors include: the change in carbon emissions as a result of modal shift and change in total emissions (the carbon emissions from construction have been assessed by route section); planned regional growth (major housing and other developments have been assessed by route section); the impact of the scheme on reducing health inequalities. When the AoS does assess benefits and costs by route section, it is not clear whether certain regions benefit at the expense of others. Furthermore, the only regions that are assessed in detail in terms of economic impacts are the catchment areas surrounding key stations on the line. ……… There is evidence that those cities where the service sector (including tourism) counts for a large proportion of the economy, are the most likely to benefit from access to high speed lines. London is thus very likely to benefit, possibly at the expense of less service-oriented cities on the line. In fact, a large proportion of the quantified benefits (34%) in the Economic Case are to long-distance passengers from London, so the regeneration effects (if they exist) would be large in London. The AoS does not assess many distributional implications between regions along the route, although it states that one of the aims of HS2 is to reduce disparities between London and the rest of the UK. For this reason, it would be of interest to assess all of the benefits of the scheme by route section. While some benefits of the scheme are assessed in this way in the AoS, many of the significant effects – such as benefits for commuters/consumers, agglomeration, maintaining/improving access to public transport – are assessed at the route level, and therefore it is not clear if there are disparities in benefits/costs between different parts of the route. (2) Green Belt and AONB 6.7 The metropolitan Green Belt and later Area of Outstanding Natural Beauty designations were introduced to prevent further development – "urban sprawl", and enhance the natural environment. The purpose of the Green Belt is:- To check the unrestricted sprawl of large built –up areas To prevent neighbouring towns from merging into one another To assist in safeguarding the countryside from encroachment To preserve the setting and character of historic towns -8- CHILTERN DISTRICT COUNCIL – Response to High Speed Rail: "Investing" in Britain"s Future To assist in urban regeneration, by encouraging the recycling of derelict and other urban land. 6.8 The most relevant are highlighted in bold above (PPG 2 Green Belt, 2001). Para 1.7 says that "the purposes of including land in green belts are of paramount importance to their continued protection, and should take precedence over the land use objectives" – in other words, the quality of landscape within the green belts is not relevant to the inclusion of land within them. But the purposes are paramount. Para 3.1: The general policies controlling development in the countryside apply with equal force in green belts but there is, in addition, a general presumption against inappropriate development within them. Such development should not be approved, except in very special circumstances. …….. 3.2: Inappropriate development is, by definition, harmful to the green belt. It is for the applicant to show why permission should be granted. Very special circumstances to justify inappropriate development will not exist unless the harm by reason of inappropriateness, and any other harm, is clearly outweighed by other considerations. In view of the presumption against inappropriate development, the Secretary of State will attach substantial weight to the harm to the green belt when considering any planning application or appeal concerning such development. 6.9 Since a railway is not amongst the "appropriate" uses, it is by definition harmful to the green belt and it would be for the applicant to demonstrate very special circumstances why it should be allowed. It is clear from the evidence submitted to the Transport Select Committee and as part of the consultation response that the proposal manifestly fails the green belt test because of its flawed business case. 6.10 Further (para 3.12) the statutory definition of development includes engineering and other operations, and the making of any material change in the use of land. The carrying out of such operations and the making of material changes in the use of land are inappropriate development unless they maintain openness and do not conflict with the purposes of including land in the green belt. 6.11 Clearly a railway, even if defined as "operations", would conflict with the purposes as set out in bold above, and we are back to the justification of "inappropriate development". 6.12 In para 3.13, when any large-scale development or redevelopment of land occurs in the green belt (including mineral extraction, the tipping of waste, and road and other infrastructure developments or improvements,) it should, so far as possible contribute to the achievements of the objectives for the use of land in green belts. This approach applies to large-scale developments irrespective of whether they are appropriate development or inappropriate development which is justified by very special circumstances. It must be stressed that this is about the principle of development, not landscape quality. 6.13 So if HS2 were, exceptionally, allowed, it should be contributing to the following objectives as set out in para 1.6 of PPG2: -9- CHILTERN DISTRICT COUNCIL – Response to High Speed Rail: "Investing" in Britain"s Future To provide opportunities for access to the open countryside for the urban population To provide opportunities for outdoor sport and outdoor recreation near urban areas To retain attractive landscapes, and enhance landscapes, near to where people live To improve damaged and derelict land around towns To secure nature conservation interest and To retain land in agricultural forestry and related uses. 6.14 The Government in its HS2 proposals have manifestly failed to consider these objectives or set out how HS2 will contribute to them. 6.15 Looking at other large transport schemes, PPG2 specifically says that park and ride may be acceptable in green belt but non-green belt alternatives must be investigated first and there are some criteria for minimising impact. However, advice on Motorway Service Areas (MSA) from 1994 makes it clear that MSAs are inappropriate development and should only be approved in very special circumstances. The intention with this and other development is that other sites should be explored first, and such a proposal should be clearly flagged in Local Plan (and thus open to Examination in Public or inquiry) (PPG17, 1991). 6.16 The Chiltern Hills have been protected as an Area of Outstanding Natural Beauty (AONB) since 1965. The Chilterns AONB is a heavily wooded landscape, with the famous beechwoods the jewel in its crown. The area has been well wooded for hundreds of years and today is still one of the most wooded parts of England with over one fifth covered by woodland. Ash, cherry and oak is widespread as well as beech. The scenic countryside of the Chilterns and its proximity to London means that approximately 50 million visits a year take place to the Chilterns. 6.17 The statutory duty in respect of the Area of Outstanding Natural Beauty is contained in Section 85 of the Countryside and Rights of Way Act 2000 and is as follows: "In exercising or performing any functions in relation to, or so as to affect, land in an area of outstanding natural beauty, a relevant authority shall have regard to the purpose of conserving and enhancing the natural beauty of the area of outstanding natural beauty." 6.18 The definition of "relevant authority" includes "any Minister of the Crown" as well as public bodies, statutory undertakers and holders of public office. It is difficult, to say the least, to reconcile the current proposals with the Secretary of State for Transport"s duty. (1) We do not believe the Government has complied with this Section 85 duty. To do so we would have expected an explicit assessment of the proposal against this duty and an impact statement dealing with the AONB. - 10 - CHILTERN DISTRICT COUNCIL – Response to High Speed Rail: "Investing" in Britain"s Future (2) In the existing consultation there is inadequate information on the impact on the AONB on completion and during the construction phase. (3) The current proposals are a token gesture regarding mitigating the impact on the AONB. Thus the route to Amersham is in tunnel. We accept that this minimises the intrusion into the AONB and green belt for that section, though we have concerns about the access shafts, construction and associated impacts. This is not the case when the route leaves Amersham when it passes through the area of highest landscape quality in the heart of the AONB and green belt. To satisfy the AONB and green belt tests and minimise the environmental impact, the Secretary of State"s only option is to tunnel in the AONB and green belt. This would further weaken the already shaky business case. (3) Planning Reform 6.19 The Coalition Government has a radical agenda to overhaul planning policy. On 21 December, the Rt Hon Greg Clark, Minister for Decentralisation, announced a new framework for planning policy:- The new framework will: - hand power back to local communities to decide what is right for them – instead of imposing excessive rigid rules from the centre - be more user-friendly and accessible, so that it is easier for members of the public to have a meaningful say in planning decisions - make sure that planning is used as a mechanism for delivering Government objectives only where it is relevant, proportionate and effective to do so - establish a presumption in favour of sustainable development. 6.20 The 51m and this response clearly establish:- (i) The opposition of the local community. This will be further evidenced by the consultation responses. (ii) The misleading nature of the consultation itself. (iii) The proposal is completely outside the planning system, and if within, fails every business case and environmental test. (iv) Is not sustainable financially or environmentally. 6.21 The statement adds "The Government will continue to maintain Green Belt protection, Areas of Outstanding Natural Beauty, Natural Parks, Sites of Special Scientific Interest and other environmental designations which protect the character of our country"s landscape, stop sustainable urban sprawl and preserve wildlife". 6.22 The HS2 proposal does none of these. Do Government departments discuss these proposals together? Is there any evidence of joined up thinking? 6.23 The Secretary of State should review the proposals in the light of this and the July consultation on planning reform in the Draft National Planning Policy Framework Consultation. - 11 - CHILTERN DISTRICT COUNCIL – Response to High Speed Rail: "Investing" in Britain"s Future 6.24 The Report opens by stating "The purpose of the Planning System is to contribute to the achievement of sustainable development." This is defined by: planning for prosperity, which includes infrastructure planning for people (a social role) planning for places (an environmental role) 6.25 We have already established how HS2 conflicts with these principles because of its uncertain impact on regeneration and significant economic opportunity costs, has generated widespread opposition and, as is developed in this section, is extremely environmentally damaging. 6.26 Stripped away of decades of accretion, the planning framework is very clear on the key principles – and one of those is to protect the essential characteristics of Green Belts and "the openness and permanence". The five principles are restated exactly as existing policy (para 6.7 above). 6.27 In considering exceptions, these include "local transport infrastructure which can demonstrate a requirement for a Green Belt location". 6.28 There can be no doubt that the Secretary of State for Transport"s proposals for HS2 not only conflicts with the Government"s own existing Green Belt policy but also its vision for how it sees that policy for the future. Because so much is being stripped away, Green Belt policy has even greater prominence. There is no way that HS2 can be described as local transport infrastructure, serving a local need in exceptional circumstances and contributing to the prosperity, community or environment of the local area of the Chilterns. (4) Localism 6.29 The Coalition Government has a real commitment to localism – as illustrated in Greg Clark"s statement above. Government makes the distinction between this and major infrastructure planning reforms. 6.30 The public are entitled to rely on the information in the consultation though there does not seem to have been any real engagement with the public, as opposed to stakeholder consultation, beyond Birmingham. You will receive many comments on the flaws in the consultation and we wrote to put our concerns on 10 June (copy attached – Appendix 1). 6.31 The executive decision making process focuses on what view the Secretary of State for Transport will take in the autumn, which will then be followed by a hybrid bill to promote the route (most likely the first section to Birmingham). The choice of this method is in itself of concern as it combines both public and private interests. Our advice is that it will be almost impossible to get a hearing of our wider strategic and economic points once the proposal reaches that stage. But is this really the right mechanism to hear all the arguments? Wasn"t the Infrastructure Planning Commission and its successor supposed to fulfil that role? - 12 - CHILTERN DISTRICT COUNCIL – Response to High Speed Rail: "Investing" in Britain"s Future 6.32 The real concern is that the Government"s charge of Nimbyism is an inevitable consequence of the decision making method they have chosen. Where was the national debate on the strategic issues? What is the future direction of transport policy? What is the most effective way of getting our economy moving and regenerating the north and midlands? Are there monetised costs and benefits of an Area of Outstanding Natural Beauty or listed buildings? Is this the optimum route? Indeed the proposal seems to be completely opposed to the current national infrastructure plan (see Q1 response). 6.33 Rather than the hybrid Bill process, it would have been more transparent and consistent with the Coalition Government"s approach to introduce the proposal through the Planning Act 2008 (which contemplates a procedure for national infrastructure projects preceded by a national policy statement (NPS) with strategic environmental assessment, consultation and a vote in Parliament (Localism Bill), then a decision of Secretary of State to designate and then a planning application to the Infrastructure Planning Commission. We understand the Department of Transport is in any event planning a consultation on "national networks" NPS later this year: and to put HS2 first is, as noted above, to put the "cart before the horse". 6.34 Until we have a better process for reconciling national and local interests, the current system will inevitably face accusations of a lack of transparency and game playing, and the Coalition Government commitment to "localism" will sound very hollow to local people.5 (5) Local Environmental Impacts 6.35 The proposed scheme will have significant adverse local environmental impacts. Appraisal of Sustainability 6.36 Since the proposals have not been subject to either a Strategic Environmental Assessment (SEA) or Environmental Impact Assessment (EIA) the results do not adequately address the relative environmental impacts of the various options (including, but not limited to, the impact on biodiversity, local SSSIs, ancient woodlands and contextual landscape). 6.37 Whilst we accept there will be consultation on the Environmental Impact Assessment, it is our view that the assessment is a key factor in determining the best choice of route. 6.38 The validity of the consultation is therefore significantly flawed as it is not possible for informed comments to be submitted as the full environmental impacts are unknown. That stage is only reached when the hybrid bill is laid before Parliament. As part of the business case, and in line with Government 5 See also Alan Goodrum and Martin Tett: Can localism survive national infrastructure projects? Municipal Journal, 14 July 2011 - 13 - CHILTERN DISTRICT COUNCIL – Response to High Speed Rail: "Investing" in Britain"s Future thinking, the economic benefits should already have been robustly weighed up against the environmental damage. 6.39 The Appraisal of Sustainability is therefore not sufficient and also omits information as well as containing factual inaccuracies. The appraisal also fails adequately to address local environmental impacts. For example, there will be potentially irreparable damage to the Chiltern aquifer which supplies water to millions of homes in London and the South East. 6.40 HS2 Ltd have provided little detail on the environmental costs, benefits and mitigation (apart from saying there will be some and allocating unspecified funding). This is the only opportunity for the benefits and drawbacks to be understood and considered, before the principle is fixed. The lack of information makes any valid consultation or assessment impossible and completely undermines the Appraisal of Sustainability. 6.41 The Appraisal of Sustainability also demonstrates that HS2 will not be a sustainable project. The Government has set out aspirations of a sustainable transport sector in its White Paper: Creating Growth, Cutting Carbon as well as within the Department for Transport (DfT) 5 year Business Plan. The Government has long since pledged that sustainable growth is at the heart of all new development projects. However, the AoS provides a negative assessment of all environmental and social factors related to HS2. Considering the operational and embedded carbon impacts HS2 is hugely carbon negative and would lead to an increase in UK greenhouse gas emissions (51m) 6.42 The sustainability merits of the project are therefore at best dubious. Of the 66 identified impacts associated with the construction and subsequent running of HS2, only 9 comply with sustainability objectives as set by the Government, whilst more than 50% conflict greatly with an ongoing commitment to embed "green" principles throughout all aspects of UK society. This is not a sound basis on which to proceed with the proposed new high speed rail line. The construction period and its aftermath will have a significant, detrimental and permanent impact on the leisure and tourism industry along the entire route, and specifically the green belt and AONB. 6.43 The mitigation measures are far too generic to have any practical weight at future decision making stages, which undermines the point of a sustainability appraisal. Further detailed mitigation methods or policies should be presented as part of the AOS to demonstrate how the project could be supportive of the sustainability objectives. 6.44 HS2 Ltd has assessed the proposed route as having considerable negative impacts. This makes it even more important to provide an understanding of why the proposed route is being promoted. It is apparent that the AoS has only assessed regional and national impacts with no real consideration of the local impacts. When these are added to the vast range of negative regional and national impacts, the AoS would further expose HS2 as being highly unsustainable. - 14 - CHILTERN DISTRICT COUNCIL – Response to High Speed Rail: "Investing" in Britain"s Future 6.45 HS2 should not proceed to the design stages until it has been proven that there is a commitment to specific and detailed mitigation policy requirements, which are clear and transparent in addressing the negative impacts and that further work is undertaken to clarify the unknown issues. Landscape, Countryside and Built Form 6.46 HS2 will cut through some of the most valuable and cherished countryside in the UK. We estimate that along the proposed HS2 route, up to 7000 historic / heritage assets will be affected between London and Birmingham. 6.47 HS2 travels through more than 25 km of Green Belt in Buckinghamshire. Within 1 km of the HS2 route in the Chiltern District, there are: 331 Listed Buildings 47 Ancient Woodland Sites A site of Special Scientific Interest 12 County Wildlife Sites 5 Scheduled Ancient Monuments 3 Historic Parks and Gardens 8 Conservations Areas 34 Archaeological Notification Sites 305 Rights Of Way 117 Protected Sites 104 records of Protected Species 1115 Historical Environment Records 8 Local Wildlife sites 17 Biological Notification sites 359ha of previously designated ancient woodland, with an average wood size of 7.34ha (along Buckinghamshire stretch of HS2) 6.48 The Appraisal of Sustainability (AoS) appears only to identify impacts on designated heritage assets. As such 90% of all assets may be overlooked, many of which are within the Chiltern District. Heritage assets, features and landscape also significantly contribute to the character of the Chiltern Area of Outstanding Natural Beauty (AONB), protected by Planning Policy Statement 7 (PPS7 - Sustainable Development in Rural Areas). It is clear that the project will be extremely damaging to the District. The proposed HS2 route will impact directly and indirectly on many aspects of life in the AONB, including its landscapes, wildlife, historic and cultural heritage, communities and local economy, recreation and access. 6.49 We also refer the Secretary of State to the submission of the Chilterns Conservation Board and its assessment of the impact on the AONB: 149 mature trees (outside woodland areas) will be destroyed within the construction corridor of HS2 through the Chilterns, and many smaller ones. 24 areas of woodland will be affected by HS2, including 9 ancient woodland sites. The latter are sites which have been continuously wooded for at least - 15 - CHILTERN DISTRICT COUNCIL – Response to High Speed Rail: "Investing" in Britain"s Future 400 years. Once lost they can never be replaced and their loss can not be mitigated by planting new trees. The total area of woodland destroyed will be around 17.75ha. 13,700m of hedgerow will be destroyed. 6.50 Historic, environment, community and heritage assets will be impacted by the route from: Physical destruction or harm during construction Harmful noise and visual intrusion on the setting of assets Loss of historic character by severing landscape patterns and linear features Indirect harm from vibration and alteration of water table 6.51 There is insufficient information included within the AoS to determine properly the impacts. Although the revisions to the fine detail (changes such as the addition of a green bridge) of the route illustrate HS2 is at least cogniscent of the issues, in the Chiltern District alone the proposed route will still be detrimental to, for example: Grims Ditch, The Lee: HS2 destroys 90m of Grims Ditch, a scheduled prehistoric boundary feature. East of Great Missenden: HS2 passes in a cutting through the Chilterns AONB, severing field patterns, ancient woodland, lanes and harming the setting of monuments and listed buildings. At Bury Farm, for instance, the line will pass at surface level within 300 metres of a major Grade II listed farm group on a moated site, and continue in only a shallow cutting close to two further listed farmsteads and the care home at Grade II listed Woodlands Park." (as well as slicing through Grim"s Ditch). Hyde End: HS2 cuts through Grade II listed Hyde Farm and barns - barns destroyed by cutting and farmhouse left within 25m of cutting edge. It is highly likely that the Grade II listed farmhouse, which contains early 16th century timber framing, will cease to be viable as a dwelling so close to the line, with major threat to its future preservation. Shardeloes Park: The line will cut across and appear to truncate the Grade II* historic landscape extended by Repton, with major detriment to views from the Grade I mansion out across the ornamental lake, and to the setting of the walled kitchen garden. The amended plans for a narrow land bridge at the centre of the park would be woefully inadequate to counteract this damage. Old Amersham: Cutting and tunnel entrance 300m north of town affects the setting of conservation area. Historic buildings with often limited foundations will be subject to vibration while the noise impact in this locality will be substantial. St John the Baptist, Little Missenden: Its history spans almost two thousand years with remains of local Roman structures having been recycled - 16 - CHILTERN DISTRICT COUNCIL – Response to High Speed Rail: "Investing" in Britain"s Future by the Saxons. Roman bricks, Norman arches, Saxon windows, Crusader Crosses, Medieval floor tiles and 800 year old wall paintings are evident. 6.52 The AoS states it will maintain Rights of Way "in the long term where feasible". It must be noted that even if access is maintained, the ability to enjoy a tranquil walk through open countryside will be lost. A major underestimate of the number of affected footpaths (based on assessments) means the business case does not reflect the true costs. Assessments show major disruption to a number of existing routes (road, rail, cyclist and pedestrian; man-made and natural) intercepted by HS2. Not all will be suitable for mitigation. Where routes can be diverted around, over, under or moved without permanent closure, the right solution would need to be sensitive to the environment and appropriate to the site. Such solutions are costly and are not shown in the business case. When the route emerges from the tunnel (close to Old Amersham, a conservation area with listed buildings and not far from a primary school) it cuts through the Chilterns AONB, on a range of tunnels, cuttings, viaducts and embankments. 6.53 Claims by the Secretary of State that the A413 is a major transport corridor shows the lack of local research and investigation undertaken and a lack of understanding of the impact. Integrating a high speed railway into any landscape can mean looking well beyond the rail corridor depending on visibility, landscape sensitivity and key receptors, to create the right landscape. 6.54 HS2 Ltd show road and rail crossings but fail to give details about vertical realignments that will impact on the landscape and setting. The environmental impacts should be correctly assessed before attempting to determine the appropriate route or mitigation. With a high quality environment such as the Chilterns the mitigation so far proposed appears wholly inadequate. 6.55 HS2 will have a major and devastating effect on the landscape. A landscape character assessment has been carried out across the three southern districts within Buckinghamshire (Buckinghamshire County Council). As part of this study the consultants were asked to undertake sensitivity testing of the proposed HS2 route and its impact on the landscape. Within Chiltern the route cuts through 4 distinct landscape character areas. In an early draft of the assessment, the consultants have concluded that although part of the route is in a tunnel the development of the HS2 route would have a detrimental impact on the character of the landscape. With the exception of the Chalfont St Peter area where the HS2 route is totally in a tunnel, each of the other landscape areas crossed by the route are ranked between moderate and high in terms of their sensitivity to the proposed rail route. It should also be noted that the consultants are to do additional work on the tunnel air shafts which may alter their assessment of the tunnelled sections. Carbon 6.56 HS2 Ltd claim that the multi billion pound HS2 will be broadly carbon neutral. A review of the appraisal of the HS2 Greenhouse Gas Report shows that the assumptions of HS2 Ltd are wildly inaccurate and misleading. Due to the lack of data available, it is not possible to critically appraise the cost of carbon. - 17 - CHILTERN DISTRICT COUNCIL – Response to High Speed Rail: "Investing" in Britain"s Future Nevertheless, HS2 Ltd has attributed the cost of carbon at somewhere between +£1.37billion and -£4.6billion (Appraisal of sustainability – Appendix 2). It is however the latter figure that is much more probable, especially if the aspirations of the aviation industry are realised, and freed domestic flight slots are switched to long haul flights (Scenario B - table 7). Although the predicted carbon cost will be dependant upon exactly where in the world the additional international flights fly to, this area of carbon valuation has not received adequate consideration and in terms of the overall potential carbon costs of HS2 would be immense. 6.57 HS2 will also run on electricity, a high proportion of which still come from fossil fuelled powered power stations. Therefore during the operational stage it will only be as carbon neutral as the energy source. This also contributes to the flawed argument. Construction 6.58 The impacts from the construction will be enormous. Significant dust, additional vehicle movements, temporary road diversions and closures and night time working are inevitable and will be extensive. It is not appropriate to postpone consideration of these impacts (potentially lasting years) until after the Bill. 6.59 The HS2 proposal will generate unprecedented quantities of spoil – estimates are 8.7 million cubic metres of solid material net for phase 1. HS2"s official estimates were 680,000 cubic metres though this has been amended two weeks before the consultation closedown. Even allowing for use within the scheme, 6.44 million cubic metres will be created. Some 74% is in the Chilterns because of tunnelling and deep cuttings. - Amersham Tunnel (9.6km), 1.42 million cubic metres - Little Missenden Tunnel (1.26km), 0.19 million cubic metres - Chiltern Deep Cuttings (9.2km) 4.83 million cubic metres 6 6.60 The consultation does not deal adequately with:- (i) The calculations themselves. (ii) The method of disposal – land fill. (iii) The location of the disposal. (iv) Transport (v) The energy/carbon impact of the construction. (vi) Whether the assumed costs are realistic. 6.61 The HS2 project represents one of the largest peace time projects ever undertaken in the UK. It will require significant labour and support during construction. No evidence is provided in the consultation on the impact of large construction compounds and populations. 6 Dr Marilyn Fletcher: SSE PhD, HS2 Spoil in the Chiltern Area of Outstanding Natural Beauty - 18 - CHILTERN DISTRICT COUNCIL – Response to High Speed Rail: "Investing" in Britain"s Future Biodiversity 6.62 No comprehensive ecological surveys have been undertaken to assess the impact on habitats and animal and plant species. Even without the essential detailed assessment, it is already known that HS2 threatens 160 wildlife sites, 21 ancient woods, 4 Wildlife Trust reserves and 10 Sites of Special Scientific Interest along its proposed path. 6.63 The Government"s Lawton Report, (2010), proposes a principle of biodiversity offsetting, recognising and using habitat value and assignment costs to identify the scale of compensation. The report also states that if compensation and /or mitigation is undeliverable within the existing footprint, compensatory offsetting should be provided on a 1:1 ratio at minimum. Land purchase, habitat establishment and land management (in perpetuity) are not factored into HS2 Ltd's costs. The 2010 Report also stressed the need for wildlife corridors, demonstrating that to rebuild ecological networks, better connections between adjoining sites via physical corridors or stepping stones was needed. As a result the Government announced plans to protect wildlife with an aim of halving the loss of habitats. It appears, however, that the HS2 proposals contradict such good intentions. Severing hundreds of wildlife corridors will have serious consequences for many species; not assessed in the AoS. 6.64 The AoS provides too little information about biodiversity and habitat impacts, and does not properly consider protected species. It fails to determine how cumulative impacts may be mitigated and key species protected. We believe this is a major omission. 6.65 HS2 will affect important species along the route; many internationally, nationally and locally protected species have been identified. Such effects must be fully investigated and reported in the EIA. By taking such a broad brush approach and not considering local impacts now, nationally and internationally important species and habitats are effectively ignored. 6.66 Destruction of habitat will threaten rare species and result in significant tree loss. It will cut through 23km of high grade farmland. It will also have a huge visual impact – the track is 75m wide including a 25m non-vegetation zone on each side. There will also be enormous viaducts over flood plains. Green Spaces 6.67 Buckinghamshire County Council environment team have undertaken an audit of all green spaces affected by the HS2 route. They have surveyed a 1km corridor along the route and also audited green spaces directly crossed by the route. In the case of Chiltern the route directly affects the equivalent of 9 football pitches of natural and semi-natural7 green spaces. Water 7 1) Natural and semi natural Greenspace – (with public access) woodland and scrub, nature reserves, grassland, wetlands, open access land, communal greenspaces, village greens - 19 - CHILTERN DISTRICT COUNCIL – Response to High Speed Rail: "Investing" in Britain"s Future 6.68 The AoS admits that HS2 will affect groundwater, thus failing to meet DfT sustainability objectives. The Chiltern area is one of complex hydrology typical of chalk geology. Chalk streams have a tendency to appear and disappear in an unpredictable fashion with dry valleys suddenly becoming filled with springs and streams. The River Misbourne is well named because of this characteristic. The impact of the complex pattern of tunnels and cuttings has not been adequately considered. In addition, some of the rare chalk streams in the Chilterns have sections which only flow in winter. 6.69 Damage to groundwater could affect water supplies that cannot be solved with expensive solutions. HS2 will pass in tunnel under the River Misbourne at two points: Bury End and Misbourne Farm. At both points, the twin tunnels would be less than 30m underground, passing through the saturated zone of rock beneath the river. Construction within these sensitive areas may lead to increased loss of water from the river and/or a change in groundwater flow in the saturated zone affecting flows further downstream. The AoS recognises this risk but fails to prove that they can be managed. 6.70 Construction of the route is likely to involve closure of some groundwater supply sources (Amersham and Chalfont St. Giles included) by water companies, who will need to compensate for supply loss by bringing in water from outside the affected area. If HS2 impacts public supplies, then any loss would need to be met from long distance imports of water, most likely from supplies within the Chess and Colne catchments. Both river catchments are listed as 'over- abstracted' by the Environment Agency and therefore this will increase the stress on these rivers and their associated wildlife, the increased costs and carbon associated with pumping longer distances and additional pressure on groundwater supplies overall. This impact also does not appear to have been considered in relation to the planned housing growth in the South East which will continue to put strain on supplies. Operational Noise 6.71 One of the drivers for sustainable development is creating sustainable communities. This is acknowledged within the AoS (Main report Volume 1 6.3.1). An important factor when appraising community sustainability is the extent to which the noise and vibration will be created. 6.72 According to Table 6 of the AoS Volume 1, the likely noise impact of HS2 is highly unsupportive of the noise objective and unsupportive of the vibration objective. The AoS makes a number of fundamental omissions, namely that of the impact from ground-borne noise and vibration from trains running in tunnels (Appendix 5 9.1.1) and along the proposed alignment (Appendix 5 9.3.5); night- time train noise impacts upon dwellings and noise impacts upon non-residential dwellings. 6.73 It also fails to adequately take account of the impact from other noise and vibration sources. The assumptions and prediction presented within the - 20 - CHILTERN DISTRICT COUNCIL – Response to High Speed Rail: "Investing" in Britain"s Future submission are also questionable. These issues are expanded upon in Appendix 2. AOS Conclusions 6.74 It is difficult to understand how an infrastructure project of this significance and size with so many detrimental effects has been subject to so little environmental impact assessment or scrutiny. 6.75 Due to the inadequacy of the AoS, it is also impossible for any person to make an informed response. This again calls into question the legitimacy of the whole consultation process. 6.76 Because the true environmental impacts (and costs associated with mitigating, offsetting etc) are not known, this also results in distortion to the overall economic case 6.77 Technically, the consultation documents show HS2 does not meet the DfT"s sustainability objectives and there is serious concern that the Government is applying double standards; requiring less scrutiny for its own scheme compared to those promoted elsewhere. Other infrastructure projects would be expected to look at all impacts at the earliest stage and to have provided a more robust and defensible business case. 6.78 Since this is the only opportunity for the benefits, drawbacks and mitigation measures/principles to be understood and considered before the principle of HS2 is fixed, the lack of relevant information makes any consultation or assessment impossible and worthless. The choice of the decision-making process, the hybrid bill, as already commented upon, is manifestly unfair. 6.79 The AoS has only assessed regional and national impacts and not local impacts. When local impacts are added to the vast range of negative regional and national impacts, the AoS would further portray HS2 as being highly unsustainable. The assessment of source noise, mitigation and impacts has inadequately described the true impact of this proposal on the affected communities and therefore may have significantly underestimated their true monetary cost. 6.80 HS2 will create major environmental damage that cannot be mitigated. Arguing the project is in the "national interest" cannot justify ignorance or non- quantification of that damage. As presented, HS2 is an unsustainable and indefensible infrastructure project that admits huge environmental risks, but fails to show these can be mitigated, even at a strategic level, with no costs included in the business case. Q7. This question is about blight and compensation (Annex A of the main consultation document): Do you agree with the options set out to assist those whose properties lose a significant amount of value as a result of any new high speed line? 7.1 This Council is extremely concerned about the blighting effects of the proposal – blight that will last a further 14 years at least. The terms of this question are - 21 - CHILTERN DISTRICT COUNCIL – Response to High Speed Rail: "Investing" in Britain"s Future unclear – particularly whether there are other options to be considered. Because our area is affected, we would certainly wish to be consulted on any future schemes or refinements. 7.2 We support the 51m position that the starting point for deciding on what discretionary scheme to adopt, and its terms, must be the principles upon which such scheme is based. In 51m"s view those principles should be: a. That any scheme is based on the principle of fairness to all those who are affected regardless of the business/investment sector of the claimant, rateable value of the property or if the owner is not in occupation. b. That such principles must be applied to both residential and business premises and to owners of agricultural land. c. A fundamental feature of any scheme is that those affected should not have to wait for compensation/purchase for a prolonged period. This is particularly the case given the very extensive period of blight that arises with HS2; d. Any scheme should address the real effects of blight and not be limited by artificial distance (or noise) criteria. e. Any scheme should aim to ensure that so far as possible the property market continues to operate normally in the affected areas. This should cover not merely people who wish to move property, but also those who wish to re-mortgage their property. f. Any scheme should have the support of relevant financial institutions, and they should make commitments that they would honour the principles of such a scheme. g. The effect of wider blight on communities. 7.3 We are not in a position to make detailed or final comments on the three options proposed, given the lack of information provided in Annex A and the large number of questions that arise in relation to the operation of any of the schemes proposed. Therefore the comments that are made below should be viewed as being provisional, until full information is provided. 7.4 We offer the following additional comments based on views expressed by our local residents. 7.5 Three scheme options are offered for consultation, together with five criteria for determining the proposed approach to compensation. The DfT say one of the options will be developed further: Hardship based scheme (like EHS and HS1 had): that helps just those who must sell Property bond (like BAA and Central Railway had): focusing on those who wish to sell Compensation bond (similar to the statutory scheme): for those that stay until it is built. - 22 - CHILTERN DISTRICT COUNCIL – Response to High Speed Rail: "Investing" in Britain"s Future 7.6 These types of schemes were all reviewed during the 2010 public consultation on the EHS by HS2 Action Alliance (HS2AA). Their view and recommendations were widely distributed and commended: 83% of respondents (including two thirds of councils and third party organisations) supported their proposed alternative scheme (based on a Property Bond approach). 7.7 Despite widespread recognition of the problems that blight causes, how it manifests itself and the nature of the injustice, there are few examples of successful schemes and none to date in the public sector. Key ingredients to success are that the scheme must be perceived as fair (increasingly viewed by the public on the model the "polluter pays") and able to generate sufficient confidence for the property market to function normally. A fair scheme also benefits the promoter through less local hostility to the project that otherwise is intense. 7.8 The HS2AA review finds that experience and the specific circumstances of HS2 – the time horizons involved during which most people will move or seek to remortgage, the potential impacts on properties, and the resistance to settling the route now and as it extends north – suggest that: A Hardship scheme is likely to be unsustainable (morally and potentially in law) as most individuals who will suffer losses will never qualify for compensation. It also does not meet Government commitments that the next scheme would represent an improvement. A Property bond is likely to be the best option to address blight as it provides a mechanism to enable the property market to continue functioning at or near to unblighted prices. It does this by providing a safety net (or purchase arrangements) that financial bodies can support. This option is more expensive to the promoter, can include those who stay, and involves Government in property purchase (that they now wish to avoid). Despite this they have previously commended the approach "as coming closer than any other to addressing blight concerns" and have approved such schemes for the private sector. A Compensation bond is unlikely to provide the necessary confidence to the property market to prevent prices and activity from still being depressed, as typically current owners will still have to accept blighted prices to achieve sales, construction impacts are ignored, and there is no role for financial bodies to help. It hence fails the test of fairness. It relies on the promise of compensation to the eventual owner (in 2027/2033) to persuade prospective purchasers to still pay at or near unblighted prices. It is the DfT"s preferred option as it avoids both property purchase and any payments until project completion (2027 at earliest). It is similar to the existing statutory arrangements and a previous draft scheme developed (but not implemented) following the last review of blight issues by Government (in 1997 after HS1). 7.9 The five criteria proposed by DfT cannot be completely achieved for selecting any scheme option. Priority must be given to those criteria that enable a fair compensation scheme to be developed to protect people from suffering losses, and - 23 - CHILTERN DISTRICT COUNCIL – Response to High Speed Rail: "Investing" in Britain"s Future hence what is needed to achieve that. Revisions to the DfT criteria are suggested, to: Make explicit reference to the support of mortgage lenders, so that property markets can function normally – with valuations at/near unblighted prices for lending and remortgaging. That Government "avoiding property purchase" is essentially an administrative issue that can be managed. Only one of the three options avoids all property purchase. Remove the restriction to those who suffer "significant" loss, as this is likely to be felt "unfair" by those affected, given the circumstances and past interpretations (greater than 15% loss). To explicitly include those who move home (as well as those who stay). 7.10 Only the Property Bond approach would have the support of the Council of Mortgage Lenders (CML) and the British Banking Association (BBA) – the other options would not give lenders the assurances they require. 7.11 This approach has been more fully developed in a further paper by Wharf Weston which is commended to Department for Transport.8 8 Wharf Weston: Compensation for Property Blight from HS2, 24 June (updated 23 July 2011) - 24 -


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2625 Kessler Blvd North D Street View
US Army Reserve Center 2625 Kessler Blvd North D, Indianapolis Indiana 46222 (IN)
US Army Reserve Center in Indianapolis
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All pieces are solid wood, I got these custom made while I lived in China.
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Aluminium centred boat trailer self centering roller with polyurethane ends in 6".
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Length O/A 155mm
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3 x 6" Red polyurethane cotton reel/keel rollers made locally in our factory in Sandgate. Photo is of 41/2", 6" & 8" rollers all available direct from the factory. Please contact us for all other types & sizes. Thank you.
Set of 2 Rear Polyurethane Coil Spring Spacers for Hilux Surf 50mm.
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50mm (2") Universal body lift blocks with crush tubes suits Toyota Hilux and Landcruiser/4Runner/Surf plus vehicles with existing blocks of the same diameter and hole size:
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2 x 6" Red polyurethane self centering rollers made locally in our Sandgate factory. Many more sizes & types of rollers available. Please contact us directly at our factory. Thank you.
Aluminium Centred Boat Trailer Cotton Reel (Keel) Roller with Polyurethane Ends 6".
To be used with aluminium boats only - no more breaking as with regular rollers.
These aluminium outer casings have been core filled with polyurethane for added durability and to minimise damage to the keel of the ...boat when retrieving and towing.
Length O/A 150mm
Centre Dia 50mm
End Dia 70mm
To suit pin size 5/8" (16mm)
Larger pin size hole can be cast on request only.
We make these in 41/2", 6", 8" and ...
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Sets of 4 polyurethane coil spacers 50mm to suit Landcruser 80/100 & some 105 models manufactured in our Sandgate factory. To suit springs rear ID134mm OD178mm, front ONLY ID120mm OD155mm as some front springs are different. Front or rear sets & 15mm & 30mm sets are also available. For coil spacers ...for other makes & models please contact us. Thank you.
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50mm (2") body lift blocks suitable as add-ons for Hilux & Landcruiser. 60mm dia with 10mm hole without crush tubes.
Manufactured locally at our factory in Sandgate in high grade polyurethane. 30mm (approx 1") & 75mm (3") also available plus replacement blocks for Landcruiser with spigots as shown ...in photo.
Bolts not supplied. The price is for ONE block only.
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Nissan Patrol GU/GQ front & rear suspensions arm & castor correction bush kit for 2" lift. Also suits Y60/Y61 & GR series with coil springs only.
1989-2010 models Except from 1/2000 on wagons only the panhard bush changes.
Set includes: front panhard rod bushes, front offset castor radius rod to d...iff mount bushes for 2" lift, front radius rod to chassis bushes, rear trailing arm upper, lower front & rear bushes, rear panhard rod bushes.
Standard kits & 3 " lifts, front or rear kits only also ...
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Body lift blocks to suit Nissan Patrol GQ 50mm (2") High x 70mm Dia with 12mm hole in crush tube. Manufactured from high grade polyurethane with crush tubes in black. 75mm (3") also available.
Universal body lift blocks 60mm dia with crush tubes in 2" and 3" and 60mm dia aluminium blocks are also m...anufactured locally at our factory in Sandgate. Bolts not supplied..
The price is for ONE body lift block only.
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Set of 4 polyurethane castor bushes manufactured locally in our workshop. To suit Landcruiser models FJ80 FZJ81 HZJ80 HDJ80 HDJ81 HZJ105 HZJ78 HZJ79. Does NOT suit models ending in "R".
100 series solid (live) front axle only not I.F.S.
Suits vehicles with 70mm - 100mm lift (3 - 4") 1989-2011
2 D...egree & Nissan Patrol also available. Please contact us or call in at our factory.
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Red 4" wobble roller.
Length O/A 85mm
Dia 105mm
To suit pin size 20mm (3/4").
The plastic centre can easily be drilled out if you require a bigger hole size.
We do not supply the pins and washers as we are a factory only.
They can be supplied in red, black and light blue.
We also supply the r...ibbed wobble rollers in red, grey and light blue.
Please contact our factory for more details. Thanks.
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Sets of 4 x 30mm polyurethane coil spacers to suit Nissan Patrol GU/GQ manufactured in our Sandgate factory. Front or rear also available plus 15mm & 50mm sets. To fit springs front ID120mm OD170mm, rear ID140mm OD180mm. Please contact us for coil spacers to suit other make and models. Thank you.
Looking for casual lawn mowing and garden maintenance jobs in the north brisbane area.
Am a teenager but have many years experience from helping neighbours,family & friends.
I enjoy it alot and have a createful eye
I am free in the arfternoons weekdays & all day weekends
Have equipment.
Can d...o majority of jobs
Please feel free to emal or text to arrange something!
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Victorian Blanket Chest
94 cm long x 45 high x
47 deep
Solid wood box with metal handles
Painted purple outside and white inside
Easy to strip/sand and repaint
Ducks - luscious free range duck eggs for sale
½ dozen for $6 or
1 dozen for $12
Chooks - luscious large free range chook eggs for sale
½ dozen for $5 or
1 dozen for $10
Available now! Hurry while stocks last, these luscious lovelies sell very quickly!!!
All this for just $5.00 WOW!!!
1 x Anzac biscuit tin
1 x Collectible car biscuit tin
2 x drink bottles with stoppers
3 x 230mm diameter Crofton quiche dishes
3 x 100mm diameter Crofton pie dishes with lids
Brand new still in its original packaging. Original Walterglass - Made in Germany. Centrepiece Swan Bowl. 435mm (bought for $180) for sale for only $20.
I have 3 games for sale:
1. TNA Impact (wrestling)
2. Red Dead Redemption
3. Assassin's Creed
Pick up only
Aluminium industrial single sided step ladder with tray
Excellent condition
Max load of 120kg
Basically brand new- bought for a job and only used once!!
Top brand at a great price. Bought brand new a couple of months ago, selling for great price
I am a 1st year midwifery student studying at Australian Catholic University, Banyo. I am paticipating in the Continuity of care experience (CCE) in order to pass my unit. Essentially, as a student, under supervision from your chosen care provider (Midwife, Obstetrician or GP) I am expected to engag...e with and provide support to women during pregnancy, labour and birth, and the postnatal period. The intention of this program is to allow students, like myself, to experience continuity with women ...
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Totally Bamboo 12 in. Spatula - 2 ToneItem # HN-TBA071
- Eco-friendly bamboo construction
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- Comfortable, shaped handle
- Anti-microbial bamboo for safe food prep
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Wannabe Policeman is Illegally Ripping Off London Comedy Show Posters
In joke-telling, there is 'The Rule of Three'.
Sometimes, this spills over into real life and overlaps with the saying 'It never rains but it pours'.
In my daily blog three days ago, I mentioned that comedian Martin Soan had broken a rib in a bicycle accident and that a comedian who double-booked himself for two simultaneous shows had caused problems for Martin's Pull The Other One comedy club in January.
In the last year, Pull The Other One has featured top comedy acts like Omid Djalili, Stewart Lee and Arthur Smith.
On Friday, as an end-of-year thankyou to locals, Pull The Other One staged a free comedy show in Nunhead, Peckham. As normal, Martin and Vivienne Soan publicised it widely locally - as they have done for over five years - with flyers and posters. Some of the posters were on bicycles which were ridden round the area.
The show was a success - despite what appear to be illegal actions by a local wanna policeman.
To save money on paying the police, England and Wales are now blessed with cheaper "Community Support Officers" to back-up the 'real' police. I suspect (with no evidence, m'lud) that these are often wanna policemen and wannabe policewomen with over-developed superiority complexes.
"It seems we now have a special constable," Martin Soan told me yesterday, "who has taken it upon himself to tear down our posters and most disturbingly rip them off our bikes... I'm not sure that's within his powers or even if it's legal."
I would have thought it was most definitely not legal. This guardian of 'The Law' appears to have decided to remove a piece of private property attached to a private vehicle without the owner's permission which I would think, in legal terms, must be pure vandalism and damaging private property - perhaps even theft.
"This bloke," says Martin, "rides around on a bike with a 'Comunity Warden' sticker on it.... Am I within my rights to rip that off?... Or deface a Sainsbury's lorry?... Or paint over shop signs?... He also told me that he would remove my bike if I put a poster on it again."
Martin's wife Vivienne, who co-runs Pull The Other One, says: "The community policeman has systematically taken down all our publicity, telling us that we are making money from free advertising at the council's expense. He says we are no longer allowed to put our poster on local notice boards and even took down a poster from British Rail property on which we have placed posters over the last five years!"
To my mind, this seems to be, again, a case of the 'Community' wannabe policeman damaging private property which stands on private land and removing property without the owner's permission.
An interesting mindset for a guardian of 'The Law'.
"Mind you," Vivienne told me yesterday, "it has saved Martin a job, as he usually takes down all the posters the day after the show. And Martin's rib is obviously greatly improved, as he wants to punch the guy in the face!"
Follow John Fleming on Twitter: www.twitter.com/thejohnfleming
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ALSA 1.0.16-rc1 Released
Published on 22 January 2008 11:18 PM EST
Written by
Michael Larabel
Comment On This Article
In the first development release for the new year and the ALSA 1.0.16 branch, version 1.0.16-rc1 of the Advanced Linux Sound Architecture (ALSA) is now available. This is the first new ALSA release in over three months, but it arrives with a lengthy change-log for this Linux kernel sound component. Among the many changes that had interested us with ALSA 1.0.16-rc1 were build fixes for the Linux 2.6.24 kernel, two dozen changes to the ALSA core, the rewritten C-Media CMI8788 Oxygen driver, emu10k1 clean-up, and just under 80 changes to the HDA Codec (and more changes to the HDA drivers). Of course, there are also many changes to other ALSA drivers, ALSA library, and other sound components.
Last month we had tested the new ALSA snd-oxygen driver with the CMI8788-based Razer Barracuda AC-1 and had experienced
positive results
. The HDA codec in ALSA 1.0.16-rc1 supports HDMI audio with the RV600 series (
Linux HDMI with ATI
article), VIA VT1708B support, Realtek ALC889/ALC267/ALC269 support, device ID support for the MacBook sound card, and a number of other HDA additions.
The ALSA emu10k1 driver, which is for the Creative Sound Blaster sound cards, has a general code clean-up and other minor changes. Unfortunately, the X-Fi series from Creative Labs has yet to be supported by ALSA (or any open-source sound driver) and it doesn't look like the support will arrive in time for ALSA 1.0.16. Creative Labs does provide an X-Fi Linux driver, but it's
is very late
only in beta
, and
only supports 64-bit Linux
The complete change-log for ALSA 1.0.16-rc1 is available from the
ALSA Project Wiki
. ALSA 1.0.16-rc2 is already planned for release next week.
Comment On This Article
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Going public on the New York Stock Exchange (NYSE) is a significant benchmark for any business. While it's the culmination of many successes, an IPO is followed by even more growth stories and achievements.
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The Floating Shadow Chair Looks Sketch, But Is Totally Safe
Lifestyle 25 Views
Take a hard long look because these chairs aren't actually floating. It took me a sec, but the shadow is in fact the supporting mechanism which provide the optical illusion behind the Shadow Chair. They cost about $1,250 a pop, but hey, they're the perfect compliment to the floating drip table.
[via Dornob]
Christen Costa
Grew up back East, got sick of the cold and headed West. Since I was small I have been pushing buttons - both electronic and human. With an insatiable need for tech I thought "why not start a blog focusing on technology, and use my dislikes and likes to post on gadgets."
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Homepage » Product Type » Lifestyle » The Floating Shadow Chair Looks Sketch, But Is Totally Safe


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