HS2 Hybrid Bill Petitioning
Summary of SMBC Asks – 23/09/13
Background
The Council has a developed a significant number of ‘asks’ and ‘propositions’ for
consideration by HS2 Ltd and Government throughout further development of the HS2
scheme.
The ‘asks’ set out by this note reflect those submitted by the Council in response to the recent
HS2 Ltd consultations on its Draft HS2 Environmental Statement and Design Refinements.
These ‘asks’ (set out in no particular order) are of the high-level, strategic nature relevant for
consideration as part of the Hybrid Bill petitioning process.
1)
Socio-economic Benefits – UK Central, Skills and Employment
To ensure the success of HS2 it is vital that the socio-economic benefits that may be
generated both directly and indirectly by HS2 are identified and realised.
UK Central has been launched recently by the Council and it sets a direction for
managed growth across a wider geographical area than the HS2 Interchange station.
Plans for HS2, should therefore be aligned with emerging plans for UK Central
(http://www.uk-c.com/ (formerly referred to as the ‘M42 Economic Gateway’ in
Solihull)) so that the economic growth potential associated with HS2 is captured for the
benefit of Solihull and the wider region, including the Greater Birmingham and Solihull
Local Enterprise Partnership area.
There is a need for intervention to ensure that procurement and employment
opportunities (and the accessibility of those opportunities) arising from the construction
and operational phases of HS2 do not bypass the local economy. This should be
implemented via a strategic partnership approach between HS2 Ltd, the Council and
its partners including a statement of intent in the Construction Code of Practice,
development of a Skills and Employment Strategy and inclusion of Targeted
Recruitment and Training clauses in contracts and supply chain engagement and
development activities.
2)
Balsall Common Tunnel
The Draft ES does not propose a deep bore tunnel in the Berkswell / Balsall Common
area.
It does however consider 3 different tunnel options as ‘scheme alternatives’. Whilst
each of the tunnel options would have some form of impact, the Draft ES does
acknowledge that (relative to the proposed scheme) the implementation of a deep
bore tunnel would give rise to environmental and community benefits. However, it
concludes that the magnitude of the benefits that would be generated would not be
“substantial enough to justify the increased cost and construction programme”. The
Draft ES does not provide evidence of the analysis carried out to support such a
conclusion.
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The Council considers that the implementation of a tunnel in the Balsall Common area
will avoid the problems associated with crossing the West Coast Mainline and mitigate
the enormous environmental impact on the local area. Serious reconsideration should
therefore be given to running HS2 in a deep bore tunnel at this location. Furthermore,
more detailed ‘Cost-Benefit Analysis’ information is required, and has already been
formally requested, in order for the Council to better understand the HS2 Ltd decision
making processes carried out to date.
3)
Hampton in Arden Realignment / Tunnelling
The Draft ES does not propose realignment and / or tunnelling for the section of HS2
that runs to the east of Hampton in Arden.
In its meeting with the Secretary of State, the Council requested consideration of the
realignment of HS2, and / or tunnelling where possible, to minimise impacts on
Hampton in Arden.
The Draft ES does not refer to options having been considered for realignment or
tunnelling adjacent to Hampton in Arden. Clarification on this matter is therefore
required.
4)
Heath Park, Chelmsley Wood
In the vicinity of Chelmsley Wood, the alignment of HS2 has been shifted to the east,
relative to that announced in January 2012. The impact of HS2 on the Bluebell
Recreation Ground and the Chelmsley Wood area is therefore reduced. However,
there remains an impact on Heath Park, over which HS2 is proposed to pass on a
viaduct – there will be both a temporary and permanent loss of greenspace and
significant visual and noise impacts on local residents.
Clarification is required on how the noise and visual impact of the viaduct over Heath
Park will be mitigated, as well as the provision of like-for-like facilities to cater for the
loss of greenspace; simply compensating financially is considered unacceptable.
Options for mitigation should be developed through consultation with the Council and
local communities.
5)
Wider Landscape Enhancement – Extent of Assessment Corridor
The Draft ES sets out a range of mitigation (and, potentially, enhancement) measures
within a finite corridor extending along the route of HS2. There appears to have been
little consideration given towards providing mitigation measures and enhancements in
more remote locations away from the railway.
Opportunities should be explored to provide improvements of, and enhancement to,
the wider area surrounding HS2. Landscape, ecological, heritage and green
infrastructure enhancements could go some way towards offsetting the localised
impacts of the railway (for communities and eco-systems etc.) as well as enhancing
views from HS2 for its users. Early investment in these measures is important to
ensure that the associated benefits are realised and established in advance of the
opening of HS2.
6) Community
Fund
In its response to the Government / HS2 Ltd consultation on Property Compensation,
the Council raised its concern regarding the impacts of both the construction and
operation of HS2. The response suggested the establishment of a ‘Community Fund’
to provide a form of mitigation of / compensation for the effects of HS2 on local
communities.
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It is understood that a 'Countryside Initiative' was set up in association with HS1 to
provide enhancement of landscape, biodiversity and heritage in areas affected by the
railway through the provision of grants, advice, support and advocacy. A similar
initiative should be set up in association with HS2, perhaps within the context of
delivering enhancements to the wider landscape surrounding the railway.
Any Community Fund arrangement that is set up should be done so on a local area
basis. Funding should be apportioned to each area to enable local improvements to
be delivered in those areas. Establishment of a ‘single pot fund’, to which all local
areas could bid and compete for funds, would be considered inappropriate. HS2 Ltd
should engage with the Council throughout the development and administration of any
form of Community Fund scheme.
7)
Noise Impact and Design Speed
The Draft ES includes a series of noise contour maps, which provide an indication of
the noise levels generated by HS2 through the borough.
Whilst useful, the mapping is difficult for residents and communities to interpret as it
does not demonstrate the increase in noise levels that they will be subject to relative to
those currently experienced. This is due to baseline noise assessment remaining on-
going.
Furthermore, the noise mapping released refers only to ‘average’ noise levels; it does
not provide an indication of the ‘peak’ levels of noise that will be generated by HS2.
The impact of peak noise is considered especially important for members of the local
community as it is likely that the peak level of noise generated by HS2 will be most
intrusive form of noise, for example in disrupting sleep.
In order to fully understand the impact of noise generated by HS2, the Formal ES
should include an assessment of the impact of peak noise and should demonstrate the
increase in average noise levels that will be experienced throughout areas affected by
HS2.
The Formal ES should also consider the environmental benefits that may be brought
about through a reduction in design speed of the railway in the Solihull area – it is
likely that the impact of noise will be decreased in association with a reduction in
design speed. Furthermore, a lower design speed will enable tighter turning radii to be
achieved, which could enable the railway to be realigned such that it passes further
away from local communities, thereby further reducing impacts on those communities.
8)
Construction – Haul Routes, Enforcement, Engagement, Management and
Funding.
The Draft ES highlights roads that will be used as haul routes to serve HS2
construction sites, and provides an indication as to the potential usage of these roads.
The Council’s view is that, where possible, construction sites should be accessed
directly from ‘A’ roads to minimise impacts on communities and ensure that roads of a
suitable construction standard and width are used.
A number of the roads identified by HS2 Ltd as being used to serve construction
compounds are considered unsuitable; for example Truggist Lane and Lavender Hall
Lane in Balsall Common; Diddington Lane, Hampton in Arden; Water Orton Road,
Castle Bromwich and Middle Bickenhill Lane, Bickenhill.
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Clarification is required in more detail as to the intended use of these roads, and
whether alternative options for construction site access are available (for, example
through the construction of new, temporary roads and / or through use of the land
upon which HS2 will be built).
The Council is aware that the HS2 Hybrid Bill may not affect the general permitted
development and works privileges afforded to Statutory Undertakers. It is important
that works undertaken by Statutory Undertakers are well coordinated with those
associated with the construction of HS2 such that disruption to the operation of the
local highway network is minimised; clarity is required as to how this will be achieved.
Clarity is required on the role of the Council in enforcing all construction activities (not
just limited to haul routes) that do not comply with the requirements of the CoCP and /
or any other agreements that may be established. Appropriate funding should be
provided for Council resources in association with enforcing upon HS2-construction
related activities.
It is also important that engagement with local communities is continued throughout
the construction process to enable a two-way flow of information and discussion with
those directly affected by construction activities. The Draft CoCP makes reference to
the development of a Stakeholder Engagement Framework; clarity is therefore
required as to how HS2 Ltd and its construction contractors intend to engage with local
communities throughout the construction of HS2.
Communities should have a clear and effective link to HS2 to ensure any concerns are
dealt with effectively and quickly.
9)
Viaduct Design
The Draft ES includes photomontages of proposed viaducts. The photomontages
illustrate that a relatively bland and imposing concrete structure will form the basis of
the proposed viaducts.
It is understood that the photomontages are, at this stage, purely indicative of the type
of material that will be used in viaduct construction. It is therefore vital that HS2 Ltd
works with the Council, and local communities, to develop viaduct design proposals
that are iconic, attractive and complement and showcase the character of the area in
which they are proposed.
Similar principles should be applied to the design and development of the proposed
‘people mover’ link between the Interchange Station and the NEC, Birmingham
International Station and Birmingham Airport.
10) Kenilworth
Greenway
The Draft ES indicates that a section of the Kenilworth Greenway will be used as a
haul route during the construction of HS2, and that a temporary diversion route will be
provided to cater for this loss.
Part of the temporary footpath is proposed to run through a flood plain, which is known
to flood from time to time. It is important that the temporary measures are provided to
an equivalent standard to that of the Greenway and that appropriate measures are put
in place to prevent and / or mitigate any flooding issues that may arise.
Following construction of HS2, the Draft ES suggests that the Greenway will be
reinstated to its current standard. Given the impact on the Greenway (and the
surrounding area) associated with the operation of HS2, the Council considers that
opportunities to enhance the Greenway substantially should be captured in association
with its reinstatement.
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Furthermore, the opportunity should be explored to deliver, in association with HS2, an
effective link between the northern end of the Greenway and Balsall Common village
centre.
11)
Lack of background information, evidence and analysis
The Draft ES has been released to show the current thinking of HS2 Ltd and to gauge
opinion on some of the mitigation measures that are currently proposed. It therefore
includes statements on the significance of HS2-generated effects for a number of
potential impacts, e.g. the effects of noise on people, the effect of road closures, the
effect on cultural heritage assets etc.
However, due to a number of assessments remaining on-going, there is a lack of
evidence supplied in support of those statements. It is therefore difficult to form an
informed decision as to whether or not the statements put forward by Draft ES are
valid.
Furthermore, not all potential environmental impacts appear to have been addressed
by the Draft ES. For example, no information appears to have been provided in
relation to either the potential electromagnetic interference or the potential for light
pollution that may be generated by the scheme.
In order for the Council to fully understand the impacts of HS2, it is important that the
Formal ES includes all the analysis and evidence relied upon in drawing its
conclusions. The analysis should be provided in relation to all effects generated by
HS2, not solely those identified as being ‘significant’.
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