LETTERS
NEAHS2 RESPONSE TO THE COMPESNATION CONSULTATION:
Dear Mr Patrick McLoughlin, Secretary of State for Transport and Simon Burns, Minister of State for Transport
HS2:(London-West Midlands) Property & Compensation Consultation Response
We write in respect of the people of North Ealing. A large many will have already submitted their own individual responses to this compensation consultation but we write here on behalf of all affected people in North Ealing.
We are all already in 2013 suffering from blight now as a result of HS2. Not only those within 60m of the line but those further away whose lives will be made a nightmare by bridge reconstruction on principal north south access routes through the borough, including Hanger Lane and the A406, Horsenden Lane South, Greenford Road and Mandeville Road.
Perivale is largely a quiet London suburb with a village-like character and community. Perivale and Greenford lie in a valley and HS2 and bridge replacement works will be seen and heard for about 500m either side of the route. For those that can hear the Central Line now HS2 will at least double the train frequency with louder trains. A surface HS2 route would divide up the community – it would be 100 nails in the coffin for Perivale.
Compensation would be entirely UNECESSARY and could be AVOIDED if HS2 were tunneled under the Northolt Corridor. The environmental impact of a surface route not only on homes, businesses, schools and traffic flow but the character of the whole area on our community buildings and natural heritage including Perivale Wood would be entirely resolved.
We write here in defence of our community and area but communities and areas all the way from London to Staffordshire are suffering blight because of HS2. This blight is severely disrupting people’s lives, including some of the most vulnerable members of these communities.
Urgent action is required for the Government to honour its previous promises that no individual should suffer significant financial loss as a result of their proximity to HS2.
In short we believe that the current compensation proposals are inadequate, unjust and unsustainable.
The Government is pushing ahead blindly with a project that risks overwhelming central London with people.
We are sympathetic with the concerns of people who wish to see growth in the North of the country and suggest that if high speed rail is to be constructed at all it should interconnect northern cities first. South East England is extremely densely populated and the impact of building a high speed line here should not be underestimated.
Our response to the specific questions of the compensation consultation is as follows:
We support the ‘polluter pays’ principle: if HS2 causes a loss in property values then the HS2 project should pay for it, not the private individual. Just a small part of the blight being suffered is being compensated (All Questions).
• All people whose house prices are affected by HS2 should notbe prevented from moving or re-mortgaging as they otherwise would have done in the next 15 yrs (All Questions).
• Eligibility should depend on a property’s ‘loss in market value’, and not distance from the line or other ways to define proximity to HS2. All blighted areas should qualify – rural and urban. (Question 2 and 4).
• Without prejudice to the last answer – as eligibility for compensation should depend on a property’s loss in market value rather than distance from the line, the current compensation scheme proposal fails to meet the Government promise to compensate all significant losses, as blight extends far beyond the 120m boundary in rural areas and 60 metres elsewhere (Question 2).
• The hardship rules relate to personal circumstances, and not the degree of blight being suffered. They should be dropped from the long-term scheme. They are inappropriate given the long timescales involved (Question 4).
• There should be an independent appeal panel – to make sure decisions are fair (Question 5)
• The needs of council and social housing tenants and landlords must be properly considered. There appears to be little help for the most vulnerable members of communities, the elderly and disabled. (Question 4, and 7)
• The real cost to the community and people’s lives must be addressed. There is no compensation for the distress and disruption caused by the planning, construction and then operation of HS2. (All Questions) There is a need to modernise compensation arrangements. A better solution would be to replace the current proposals with a Property Bond which can help reduce the blight itself. This is the approach which is endorsed by the professionals such as the Council of Mortgage Lenders, the British Bankers Association and the National Association of Estate Agents. It was also acknowledged by a Government report after HS1 as coming closer than any other to dealing with the problem of blight.
This is our formal response to the seven consultation questions. But we also wish to stress again the point that compensation in respect of the proposed HS2 route through North Ealing would be entirely unnecessary if HS2 were tunneled through this section.
Yours sincerely
Alex Nieora (LLB)
Chairman – North Ealing Against HS2
For and on behalf of the people of North Ealing
Copies of correspondence between the Department for Transport and NEAHS2 are available on request.
Text of NEAHS2 letter to the Minister of State for Transport (26 October 2012)
Dear Mr Burns
North Ealing and HS2
Thank you for your letter of 11 October 2012
While we understand that the government should be concerned with present and future capacity on the railways we sincerely do not believe, for reasons that were set out in my letter of 27 September 2012, including current and projected capacity and ONS demographic figures, lessons from HS1 and the negligibility of benefits accruing from high speed per se that a third railway line to Birmingham is warranted.
Let me set out some further points that were not included in my previous letter. I have already set out the appalling economic case for HS2. We do not agree with the 2.5 benefit-cost ratio laid out in the Department for Transport’s economic case for HS2, which is based largely upon assumptions. I could state further that while only 3% of journeys and 7% of passenger miles are by national rail, the Government spends half its transport budget on rail. This is before HS2 – the largest and most expensive government transport infrastructure construction project – is even taken into account. While some people opt to travel by rail the idea that there will be a significant modal shift from road to rail is preposterous. Indeed the government’s entire rail strategy must be seriously questioned and it must be questioned now.
In central London and in the peak hour there are sufficient surface rail passengers to occupy only one seventh of the capacity that would be available if the network were paved and those passengers were all seated in 75-seat express coaches. The passengers number some 250,000. There are at least 25 inbound surface tracks into London. Hence passengers per track average 10,000. All these passengers would all find seats in 150 75-seat coaches. Those coaches would occupy one seventh of the capacity of one lane of a motor road the same width as required by a train.
By way of example, there is a contra-flow bus lane in New York that is 4 miles long including 1.5 in tunnel. It carries nearly 700 45-seat coaches in the peak hour offering circa 30,000 seats. At its narrowest the width is 10.9 feet. In comparison 30,000 crushed passengers arrive at Victoria main line in trains that require four inbound tracks.
90% of rail journeys in the UK are less than 80 miles long. For nearly all of those the express coach operating in uncongested conditions would match the train for speed, particularly after taking account of a service frequency four to twelve times as great as the train. Furthermore fares would be between one quarter and on half those suffered by train.
The government wishes to build a high speed rail network to alleviate capacity on other sections of the network including capacity for freight. But we know local services will lose out to HS2 and cuts will be made. It should be pointed out that it costs the Government (i.e. the taxpayer) six times as much to move a passenger or tonne of freight by rail as it does via the motorway and trunk road network.
As I set out in my previous letter, HS2 is not green – despite what its proponents claim. Rail returns the equivalent of 110 passenger miles per gallon, little better than an efficient diesel car containing the national average of 1.6 people. Given rail rights of way lorries and express coaches would discharge the function of rail using less fuel and emitting less carbon than does rail.
HS2 is clearly not the panacea the government would like it to be.
North Ealing
We welcome that HS2 Ltd have agreed to undertake a comparative tunnelling study in respect of North Ealing and are furthermore pleased that this has been welcomed by you. We are also pleased that you have been quoted as saying: ‘I am determined to do everything I can to minimise the effect on those closest to the line.’
Ealing London Borough Council has confirmed that it will review the outcome of this study, including the costing of tunnelling under Ealing.
However, we are outraged by your comments quoted in yesterday’s London Evening Standard: “In more urban areas, a voluntary purchase zone would encompass homes a number of streets away from the line where the impact is likely to be negligible.” This is simply not true and indeed it is discriminatory and invidious that rural areas should be provided for differently from urban areas – where in fact more people live and more would be impacted by HS2. The safeguarded zone should in fact be just as wide in urban London as it is in the countryside to reflect this. Many areas of north west London, like North Ealing are quiet suburban residential neighbourhoods where the impact of HS2 would be felt and heard very acutely. Indeed a large part of Perivale, where I live, near to the proposed HS2 route has a quasi rural character, which takes in, inter alia, Perivale Wood Ancient Wood and Nature Reserve – the second oldest nature reserve in the country, Perivale Wood borders the proposed HS2 route and its character will be utterly destroyed by a surface HS2 route. Through significant sections of the HS2 route through North Ealing a surface route would be elevated on an embankment, meaning that noise and construction will be more visible and audible.
It is further discriminatory and individious that urban areas should be treated differently from rural areas. There should be no such distinction made and we will be making our views on this very clearly heard in our response to the compensation consultation.
We would also point out that the cost to the government through payment of compensation as proposed under the compensation scheme under consultation – along with the cost to the people of North Ealing through replacement of bridges, compulsory purchases and demolitions, and general noise and disruption to inter alia homes, businesses schools, commuters using the Central Line (West Ruislip branch) and Perivale Wood Nature Reserve – could be best avoided if HS2 were put underground through North Ealing.
It is very clear that the government is proposing to route a high speed trans-European mainline that would eventually potentially run from Lyon or Milan through to Manchester, Leeds and Glasgow on an embankment on a surface route through built up quiet residential suburbs. There is absolutely no guarantee that at some point in the future a four track route might be proposed for the section through North Ealing, along with utilities conveyance infrastructure to run alongside the route, such as a large water pipe, which was mooted earlier this year.
North Ealing Against HS2 stands steadfastly united with our local authority against these considerations. Our primary local concern as an action group with the HS2 proposals and our primary local consideration is to protect the area of North Ealing, where we worked hard to acquire our own homes and chose to live absent any knowledge of high speed rail. A surface HS2 route is simply unacceptable to local residents. A stretch of Perivale, where I live, was blighted once in the 1970s by the widening of the A40. We will not be blighted again by HS2.
As I stated in my previous letter, any employment, regeneration and retail opportunities potentially exploited around the Old Oak Common area resultant from HS2 (even if the trickle down effect is in fact realised) are highly unlikely to extend west of Hangar Lane to Perivale, Greenford and Northolt, even within a wider Old Oak Common development masterplan.
Again, as I stated in my previous letter to you, the potential development of improved rail connections to North Ealing would be best served by an overground commuter line to run alongside the Central Line, West Ruislip branch on the currently infrequently used freight line (the New North Main Line or 'NNML') to potentially connect up to a hub at Old Oak Common. This would ease capacity constraints and rush hour congestion on this branch of the Central Line in the same way that Crossrail will ease congestion on the Central Line, Ealing Broadway branch. Of course, were a surface HS2 route to be pursued along the current route of the NNML, as is presently proposed by HS2 Ltd, rather than a tunnel, this is yet another way in which North Ealing will see no benefit from HS2.
In response to the point you make in your letter we have made HS2 Ltd very clear about where we stand, and we are also relating our position to you as the minister responsible for HS2. I have also included some of the petitions that were sent in as an Annex to my letter of 7 April 2012 to Patrick McLoughlin’s predecessor, Justine Greening.
Community Fora with HS2 Ltd
You have advised me to engage with HS2 Ltd at Community Forums in order to feed our thoughts into the HS2 design process.
I must stress that the feedback presented by HS2 Ltd regarding the level of success of the Community Forum 'community engagement' exercise being undertaken in respect of HS2 Ltd is entirely misleading. Contrary to the rosy picture painted by HS2 Ltd the Forums are failing to engage effectively and are in fact causing a great deal of upset and anger among members of our and other affected communities and campaign groups, with whom we are in contact on a daily and sometimes hourly basis.
Clearly with an infrastructure project of this scale, any engagement exercise will draw some criticism from opponents of the scheme, particularly those likely to be most affected. Therefore a community engagement exercise needs to fully understand local concerns and discuss any potential solutions identified by community members to alleviate them. This must include HS2 Ltd making available ample time at the Forums to hear objections and counter-proposals from Forum members and then acting to resolve these objections and take on board these counter-proposals. At present this is not happening. Instead what we are experiencing from HS2 Ltd is a persistent mixture of deception, inaccurate information, misleading reporting, and contempt for genuine and evidenced local concerns. Information from HS2 Ltd is drip fed to the forums and members are forced to remain in a state of uncertainty and anxiety between each Forum.
These are strong words indeed, but unfortunately supported by ample evidence and witness accounts. This behaviour is not helped by the unprofessional attitude of many of the officers in attendance – several of whom appear to be on a training exercise.
Aarhus Convention
These failures demonstrate the Community Forums are little more than window dressing, designed to give the impression of compliance with the United Nations Economic Commission for Europe (UNECE) Convention on Access to Information, Public Participation in Decision-Making and Access to Justice in Environmental Matters adopted by the European Commission on 25 June 1998 (the ‘Aarhus Convention’). As you know Aarhus has been not only ratified by the UK but incorporated into UK law through, not necessarily exclusively, the implementation of Directive 2003/4/EC on Public Access to Environmental Information by virtue of the Environmental Impact Regulations (2004) (the ‘EIR’) and of Directive 2003/35/EC.
However, even if and where one of the three pillars of Aarhus has not been fully implemented in UK law, under the European Court of Justice case of ‘Étang de Berre’ case C-239/03 – more specifically, Commission of the European Communities v French Republic of 7 October 2004 mere EC (now EU) membership would per se introduce the Aarhus obligations into the Community legal order as part of the acquis communautaire thus making them binding both on Member States and EU institutions. Needless to say under s2 of the European Communities Act 1972 the UK is bound by all European Court of Justice decisions.
As you are aware under the EIR the Department for Transport is required to:
'progressively make information relating to the environment measures (including administrative measures), such as policies, legislation, plans, programmes, environmental agreements, and activities - i.e. HS2 - affecting or likely to affect the environment'. [Emphasis my own].
This is because Reg. 4(1) of the EIR states that:
'subject to paragraph (3), a public authority shall in respect of environmental information that it holds (a) progressively make the information available to the public by electronic means which are easily accessible; and (b) take reasonable steps to organize the information relevant to its functions with a view to the active and systematic dissemination to the public of the information'
and 'public authority' for the purposes of the EIRs is define at Reg.2 (para.(a)) of the EIRs as 'government departments' – i.e. the Department for Transport – or – at para. (d) 'any other body or other person, that is under the control of' a government department - i.e. HS2 Ltd. [Emphasis my own]
The information also includes 'cost-benefit and other economic analyses and assumptions used within the framework of the measures and activities referred to in (c) under para. (e) of Reg. 4(1). [Emphasis my own]
Under Reg. 5(1) 'subject to paragraph (3) and in accordance with paragraphs (2), (4), (5) and (6) and the remaining provisions of this Part and Part 3 of these Regulations, a public authority that holds environmental information shall make it available on request.'. Moreover, at para. (6) ‘Any enactment or rule of law that would prevent the disclosure of information in accordance with these Regulations shall not apply’. [Emphasis my own]
HS2 Ltd therefore is and indeed acknowledges on its website that it is legally bound to Aarhus by virtue of implemented (although HS2 Ltd attempted to deny at our first Northolt Corridor Community Forum that the Community Fora had been established pursuant to any legal requirement or international convention) but it is in fact violating its principles and spirit.
The Aarhus Convention provides for:
- Pillar I – the right of everyone to receive environmental information that is held by public authorities ("access to environmental information"). This can include information on the state of the environment, but also on the effect of policies or measures taken - such as the development of a new railway line - on the state of human health and safety where this can be affected by the state of the environment. Applicants are entitled to obtain this information within one month of the request and without having to say why they require it. In addition, public authorities are obliged, under the Convention, to actively disseminate environmental information in their possession.
- Pillar II – the right to participate in environmental decision-making. Arrangements are to be made by public authorities to enable the public affected and environmental non-governmental organisations to comment on, for example, proposals for projects affecting the environment, or plans and programmes relating to the environment, these comments to be taken into due account in decision-making, and information to be provided on the final decisions and the reasons for it ("public participation in environmental decision-making");
- Pillar 3 – the right to review procedures to challenge public decisions that have been made without respecting the two aforementioned rights or environmental law in general ("access to justice").
In prima facie contravention of pillar one of the Aarhus Convention and the EIR Freedom of Information requests from the Department for Transport relating to HS2 Ltd have often been refused or responded to with opacity. In prima facie contravention of pillar two of the Convention, Community Forums have been structured by HS2 Ltd so as to limit comment and decision making participation by affected communities and information held by HS2 Ltd, far from being actively disseminated by HS2 Ltd has been actively withheld. HS2 Ltd are setting the agenda for the Forums resulting in a vast proportion of time at Forums being spent on maters which are not most important to the communities affected.
We demand that going forward control of the Forums is given to the community and to the Forum chairperson. Only this way can what is a growing a potentially toxic frustration with this process be potentially avoided.
Yours sincerely
Text of NEAHS2 letter to the Secretary of State for Transport (11 June 2012)
Dear Ms Greening
I write in response to Jonathan Mitchell’s letter dated 11 May 2012. I am copying this letter to my MP, the London Assembly Member for Ealing and Hillingdon North Ealing councilors and residents and organizations, who were also copied into my letter dated 7 April 2012
Mr Mitchell’s implication that I have not read or am unfamiliar with the Department for Transport’s published material addressing the issues he lists and which I covered in great detail in my letter dated 7 April 2012 is disingenuous to say the least. Much of Mr. Mitchell’s three page response to my 51 page letter ignores the vast majority of the points I raised and strongly suggests that at best he - skim read my letter You will appreciate this is dismissive and invidious towards not only of me but also the residents, businesses, schools, representatives and other community organisations in North Ealing who will be adversely impacted by current HS2 proposals.
I requested that this letter be addressed by you but understand that in your position you may be unable to respond directly. Mr. Mitchell’s letter, however exemplifies the high handed approach the government officials appear to be taking in implementing policy on the introduction of HS2 and in effect further alienates voters who may in general be supportive of government policy.
The following refers to those points raised in my letter which were selectively and subjectively addressed by Mr. Mithchell in his response.
Current and future rail demand
Let me re-clarify my own points explained in detail in my letter to you dated 7 April 2012 more succinctly and supported by yet more evidence that has come to light since my last letter, including the government’s own information, further undermining the government’s case for high speed rail as it stands.
Mr Mitchell asserts in his letter that ‘Information on the capacity issues is produced by Network Rail’ and states that ‘data indicates that the [West Coast Main] line will face serious capacity issues earlier than was originally predicted’.
Mr Mitchell refers to Network Rail’s Rail Utilisation Strategy dated July 2011 ‘RUS’. Despite the fact that theDepartment for Transport have consistently refused to release passenger loading data on the West Coast Main Line,the RUS shows that that long distance services in to and from Euston are at just 60% of capacity for the three hours of peak morning demand, and just 64% in its busiest hour. This makes trains to and from Euston the least busy long distance service with a terminus in London. Furthermore, Euston utilisation will fall as new carriages are added this year. By contrast trains from Paddington and Waterloo (which both account for a high proportion of local greater London urban railway journeys) both show over 100% capacity usage at peak hours.
By 2031, after the first stage (but before the second stage Y network) of HS2 is due to be built, Network Rail assume in their RUS report that long-distance services into Euston will have become the most under-capacity part of the London network, as the projected forecast of 6,500 passengers in the peak hour at Euston will be just 47% of the projected 13,796 capacity.
Clearly there will be no capacity crunch on the West Coast Mainline for many decades, if at all and the 51m group alternative in fact delivers more capacity than the Department for Transport forecast for HS2, has a benefit cost ratio of 5 rather than the current HS2 plan BCR of 1.2* and would provide the new infrastructure identified in the Rod Eddington report.
*using the latest Passenger Demand Forecast Handbook (v5.0) the BCR is cut by a further 0.4, using the correct figure for business passengers’ earnings cuts it by a further 0.3 and assuming time is not wasted on trains cuts the figure further still so the true figure is likely to be under 0.3, i.e. 30p of benefit for every £1 invested.
In fact nearly half the population uses a train less than once a year and, more particularly, long distance travel accounts for barely 10% of total rail journeys – as indicated in the table I reproduced in my letter from p17 of the 2010 National Rail Transport Survey. Across the country railways (discounting intra urban and metropolitan networks such as London Underground) carry 3% of passenger journeys and 7.7% of passenger miles, yet take up over half of the Government’s expenditure on transport! Moreover, those from the top quintile of household income travel four times as much by rail as do those from either of the bottom two quintiles. Railway journeys therefore disproportionately subsidise the most wealthy in the country and so too will HS2 – as is apparent from the fact that the £20.1 billion figure for alleged time saving benefits accruing from HS2 is calculated by assigning a value of £37 an hour to that time per passenger – implying that the average HS2 passenger earns almost £70,000 a year at current earnings. These disparities will increase even further with HS2.
Where extra capacity – and greater reliability – is urgently needed on the railways is on local – particularly urban – passenger services and the GWR line from Paddington (which will be alleviated to a degree by Crossrail). This is not my opinion or my view, it is fact. In London this means increasing not decreasing Transport for London’s grant, yet the 50% of TfL’s funding that comes from central government is being cut. Even though TfL’s investment plan has been part funded by the government, which offsets some of the decrease in the general grant, overall funding is still being significantly cut. In fact the reduction translates to a 21% cut in real terms of the central government grant. Consequently the Mayor of London is being forced to reduce £7.6bn from TfL’s expenditure over the next 6 years.
I explained in my letter dated 7 April 2012 the need to support the stretched capacity of the Central Line West Ruislip branch at peak times by providing extra capacity on a section of the London Underground where capacity issues will not be alleviated in the future by Crossrail – as Crossrail does not pass anywhere near the northern wards of the London Borough of Ealing.
I explained how extra capacity on the Central Line West Ruislip branch could be achieved by converting the seldom used freight line running parallel to the Central Line West Ruislip branch by a suburban passenger line. I further explained that if HS2 were to be constructed over ground rather than in tunnel along the currently proposed route through the London Borough of Ealing, using this section of the seldom used freight line, converting this section of the freight line to a passenger line would be impossible.
I have not received a response to this point.
Mr Mitchell writes that ‘further rounds of upgrading the existing network would cause unacceptable disruption for passengers and fail to offer the benefits to the country that HS2 will bring’ ignoring the effect of HS2 construction on Euston commuters and the ability of London Midland to deliver consistently good services for commuters into Euston during that 7 year period, when the station is being practically rebuilt, the disruption of HS2 construction on West London, the homes that will be lost, the permanent disruption and lower quality of life for thousands of Londoners, and whether any or all of these are ‘acceptable’.
Demographic change
Mr Mitchell’s asserts that ‘as life expectancy increases so people tend to be more active, and take more rail journeys, in their later years’ without any evidence whatsoever to back up this statement. This was not the point that I was making to begin with in relation to demographic change in my letter dated 7th April. While life expectancy is projected to increase, an ageing population does not automatically translate as an increase in rail passenger demand! Indeed in my letter dated 7th April I provided evidence from the 2010 National Rail Transport Survey to show exactly the opposite: only 14% of total rail trips are made by the over 60 age group category.
Mr Mitchell’s response that the ‘Department for Transport is not best placed to comment’ on my suggestion that the government might do well to tighten immigration controls and disincentivise natural growth would seem to indicate that:
a) there is a dearth of central government cross department communication and
b) there is a dearth of cross departmental problem solving to issues of national importance, such as strategic transport planning.
Put simply demand for transport services, where it stems from population growth per se, is inimical to the long term business case and environmental sustainability implications inherent in government expenditure on transport.
Lack of Business Case
The accounting of productive work time spent during train journeys and improvements in telecommunications such as videoconferencing is the only subject within the gamut of the lack of a business case for HS2 that I covered extensively in my letter dated 7 April 2012 which Mr Mitchell chose to respond to in his letter. Therefore I will re-cover briefly the absence of a business case for HS2 in this letter.
However, since my last letter to you it has been revealed from a Freedom of Information request that the Department for Transport’s own 170 page Reference Work entitled: ‘Productive Use of Rail Travel Time and the Valuation of Travel Time Savings for Rail Business Travellers’ - Final Report June 2009 - states that:
‘a reduction in scheduled rail journey time for a business traveler by, for example 10 minutes, would increase the average amount
of time spent working by all business travelers by just 0.75 minute’
indicating that there is 'economic benefit' in just 7.5% of the time saved by business travelers. However, the HS2 business case also produced by your Department
claims economic benefit for 100% of the time saved by business travelers. This appears to be a huge difference and contradiction. I would be grateful if you would explain this?
I would also be grateful if you would provide an explanation as to why the recommendation in this same report, as quoted below, to reduce the value used for business
travelers by 50% from 7.5% to 3.7% of the time saved, was ignored and the values your own Department describe as 'unsupportable' have been used in the HS2 business case:
‘if these new values were carried through to forecast values using the current methodology these would reduce the estimated benefits of speeding up the current rail
system to this segment of business passengers by around 50%, changing from a figure of £0.74 per minute saved at 2008 prices as reported in WebTAG to £0.37 per minute saved, as a basis for
quantifying benefits1 at current values before allowing for income changes over the forecasting period. This difference arises from switching from a theoretical value for time savings (based on
premises which we have shown to be unsupportable) to an empirical value based on observation.’
Mr Mitchell claims in his letter that ‘videoconferencing and improved communication technologies are taken into account in our demand forecasts, within our consideration of changing social behaviours’. However, in the same ‘Productive Use of Rail Travel Time and the Valuation of Travel Time Savings for Rail Business Travellers’ report the DfT admits it relies on the ‘unsupportable’ assumption that time spent on trains is unproductive and demands ‘major changes’ to the ‘1960s’ method, used to calculate the HS2 business case.
The report found that up to 82% of business travelers did some work on train journeys and almost half of all train travel time by businesspeople was spent working. It also found that most business travelers would not do any extra work off the train in the time that they had ‘saved’ through a faster journey, stating:
‘A reduction in journey time does not lead to much extra productive time overall… Sixty per cent [of business travelers] reported that they would do no work in the 'saved' time.’
Mr Mitchell also claims that the Government is ‘working on bringing superfast broadband to all parts of the UK and creating the best broadband network in Europe by 2015’. Yet the current government has reversed the previous Labour government’s plan to spend £1.1 billion from a 'Next Generation Fund' to deliver next-generation broadband to 90% of the country by 2017.
In relation to the ‘Productive Use of Rail Travel Time and the Valuation of Travel Time Savings for Rail Business Travellers’ it has also come to light that one senior official at the DfT explicitly told colleagues that this report could not be used or published because it would spoil the case for HS2. In this regard I would be most grateful if your Department would please stop covering things up!
Rail Freight
Mr Mitchell mentions rail freight: it costs the Government six times as much to move a tonne of freight by rail as it does to move the same by the Motorway and Trunk Road network. In this regard, should increasing capacity to enable rail freight growth at the expense of passenger services be a government priority?
Impact of HS2 on Ealing
Mr Mitchell has clearly IGNORED the points I have made consistently in regard to tunneling in Ealing if HS2 is constructed, namely but not limited to the fact that:
a) tunneling through Ealing is not and cannot be described as a ‘significant cost’ given the overall expenditure on HS2 and given the decision to tunnel through other areas, that
b) the environmental impact of constructing tunnels will be temporary as opposed to the permanent environmental impact – particularly in terms of lost homes, noise and visual impact – of not constructing a tunnel (although tunneling will also obviate the temporary environmental impact of bridge replacement), and that
c) ‘noise barriers’ are ineffective, as I explained by the evidence from numerous scientific reviews I presented in my letter of 7 April 2012, and therefore tunneling is the only effective form of noise mitigation against HS2 trains in Ealing.
I have been reliably informed that the government is still considering constructing a giant water pipe alongside the HS2 route (which cannot be tunneled) so would have to run next to the railway resulting in an upheaval and land take will be far greater than just HS2. Can you confirm whether this is the case? The water pipe would be a consequence of HS2 that would further increase the case for HS2 itself to be tunneled through Ealing.
On the impact of HS2 on Ealing I refer you further to North Ealing Against HS2’s 22 page response to the DfT’s consultation on the draft Environmental Impact Assessment Scoping and Methodology report.
Conclusion
I have addressed every comment that Mr Mitchell made although he ignored the majority of my points and the supporting evidence which I presented. It is simply not satisfactory to respond to detailed correspondence with in meaningless sound bites such as ‘[the Government has] a commitment to a modern transport network’.
On 3rd June 2012 the Prime Minister said that he leads a government that ‘doesn’t keep ploughing into a brick wall, it has the common sense to change its mind’. As Jerry Marshall, chair of Action Groups against HS2 stated ‘HS2 has reached a brick wall’.
At this juncture no administration with facing the reality of a spiraling National Debt and the results of profligate spending of our European partners, could or should possibly continue with the financial burden of HS2 – such a course would be against the national interest. Instead of retroactively trying to justify a proposal that was flawed in the first place we need to engage in prospective transparent analysis of the benefits of an alternative strategy to enhance the existing network with new local railway sections and modern services at a fraction of the cost of HS2.
Yours sincerely
....