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HS2 phase 1 ES response

This is the letter sent to the Dept. of Transport in response to the publication of the draft Environmental Statement.

HS2, Phase 1 – Formal ES Response by CPRE Staffordshire

Staffordshire Branch of CPRE is an independent charity covering the geographical county of Staffordshire.  Its purpose is defined by its title.  We subscribe to the general thrust of National CPRE’s response to HS2 but only insofar as they are taken in their entirety – including the caveats.  We have basic reservations regarding the local benefits, disbenefits and justifications as the project affects Staffordshire.  These reservations can, and do, amount to a rejection of the whole HS2 concept as it is apparent that its fundamental premises are incapable of being overcome, or adequately mitigated by the detailed mitigation measures being propounded by the “consultations” so far undertaken.


Our opposition in principle to HS2 is as follows as it seems unlikely, or even impossible that they can be mitigated by detailed environmental measures.

a) Cost

Financial and fiscal statements issued by the government forecast a perilous and deteriorating national economic situation into the future that CPRE or any other institutions cannot responsibly ignore.  The National Debt is increasing at around £120 billion per year with estimates that it will total 5 times Gross Domestic Product by 2040, with debt interest alone equalling half of all the revenues.

In the resultant climate of austerity the expenditure of £40 billion – possibly reaching £100 billion on a single contentious project ranks as perverse.  The economic case for HS2 has been seriously questioned with its cost/benefit ratio being widely challenged by dispassionate observers.  Even the benefits claimed to accrue to northern regions have been derided by no less political authority than Vince Cable who has stated that any flow of wealth would be towards the capital rather than the reverse.

For Staffordshire the adverse case is yet more extreme, and this has resulted in an almost total opposition from all elected bodies, County Council, District and Parish Councils, and MPs along its route – this is a true measure of its perceived effect environmentally on the County community.  From a wider perspective it is noted that in a “satisfaction” survey of rail users British train services came second highest in Europe, only beaten by Finland with a minor track mileage.  These do not seem to bear out the claims for need of HS2 scale expansion.

b) Speed

Economic benefits are claimed to be derived from shorter journey times with high speed travel.  These arguments must be refuted as the decrease in supposedly “unproductive” travel times is proved to be inaccurate when journey time is effectively working time in an age of electronic communications.

Time savings too are illusory, as these relate only to station - to - station timing.  However these are only a modest proportion of overall door to door journey times.  Of greater economic benefit to travellers would be the advantages derived from expenditure on integrated local transport

Journey speeds are proposed to be increased by reducing or eliminating intermediate stops between terminals of HS2.  In this process Staffordshire population of near 2 million people derives no benefits, needing to drive or ride north or south beyond the County boundary to gain access entailing increased car usage – an unsustainable outcome.

In environmental terms CPRE condemns the negative proposal of siting inter-change stations in countryside locations that, south of Birmingham would invalidate decades of Green Belt protection of the “Meriden Gap”, a key feature of erstwhile Regional Planning.  The alternative solution of siting rail termini, or intermodal transfer in city centres is to be deplored also; the high public costs of highway works transferring such passenger numbers being incalculable, and rendering even less viable the financial case for HS2.

c) Sustainability

In an anticipated future scenario of climate change, world shortage of basic resources and increased economic competition, sustainability has become a key objective of governmental planning.

Transport is responsible for broadly one third of CO2 emissions, and the first sustainability principle in this field is to reduce the need to travel – HS2 breaches this first principle.  CPRE supports an increased percentage of travel by rail, but only where this has convenience advantages i.e. regional travel.  Beyond these distances rail becomes unsupportively expensive, and for shorter distances increasingly inconvenient for users (hence the historic decline in railways in favour of unsustainable road transport).

HS2, with a planned speed of 225 MPH incurs a disproportionate penalty in power consumption, contrary to sustainability aims.  The construction of the project would itself generate huge CO2 emissions, both directly and indirectly in the mining and manufacture and transport of construction materials.

e) Comparability

CPRE sees arguments advanced advocating HS2 for the UK “because other countries have it”.  Comparisons with other countries should take into account differences of terrain and landscape, population density, methods of finance, especially degree of subsidy not only of development costs but also of rail fares.

Attitudes towards public versus private ownership and land acquisition are important, as is the degree to which other countries accept a strict public order and policing regime.  We fear that the UK’s relaxed attitude towards personal freedoms and stringent policing will expose high-speed rail travel to an unacceptably high security risk, from terrorist groups, of sabotage and loss of life.  This form of travel has no security safeguards comparable to air travel and the location of rail track for hundreds of miles in countryside remote from any practicable surveillance is, in our view, culpable in the extreme.


Environment in this context concerns itself with the physical setting and quality of people’s lives.  This CPRE response refers to Phase 1 of HS2 lying within the county of Staffordshire from a southern boundary at Drayton Bassett to a point at Handsacre, north of Lichfield where a junction is proposed with the West Coast Mail Line (WCML) railway.

The proposed route traverses predominantly rural open countryside.  The perception of the County as a grimy industrial face of the 19th century Industrial Revolution is misleading and untrue.  Outside the close confines of the Black Country and Potteries conurbations Staffordshire is a leading agricultural county with countryside of great beauty climaxing scenically in the Peak District National Park and Cannock Chase Area of Outstanding Natural Beauty.

Staffordshire is the county with the greatest range of geology and therefore scenery, both upland and lowland.  Its varying topography and character gives rise to wide vistas as far as the Welsh Hills and the Derbyshire Peak and enshrines many small scale local scenic qualities within its folds.  Attributes which CPRE sets out to protect and which HS2 threatens to mar or destroy include:-

  • Its pastoral beauty – the changing pattern of crop fields and hedgerows, woodland and water in changing seasons and changing light.
  • Beauty also of its historic heritage of historic buildings and their landscape setting; of humbler grouped to form compositions of great beauty, our hamlets and villages.  (The number of Conservation Areas exceeds 100).
  • We value the dominance of nature, its flora and fauna, and treasure its peace, tranquillity and seclusion; opportunities for town and country dwellers to escape and retreat from metropolitan life along its comprehensive footpaths and bridleway network.

These latter facilities are selected out for special mention.  In threading HS2 clear of obstacles in its path such as built up areas and statutory – protected reservations the HS2 line has taken the line of least resistance – open countryside.  CPRE has independently mapped the county identifying degrees of quiet and seclusion – “tranquil areas” – and it is upon these areas of high tranquil value that the HS2 line largely trespasses.  Noise and disturbance must be the very antithesis of the tranquillity sought by recreational users of rural areas, a body of increasing importance to the tourist economy of the County.

CPRE therefore defines the qualities that personify the Staffordshire countryside, and the threat to these values which must be resisted.  The plans display a lack of concern for its inhabitants both in the environmental disturbance and the direct effect on our properties and livelihood by severance and demolition.

The past half century has seen a wide dispersal of housing from town to country, affecting villages and hamlets greatly valued by their owners for the very qualities we outline.  CPRE protests strongly at the injustice of a railway lines destructive impact on so many people’s lives and environment for a miniscule and debatable time saving percentage of travellers.  Such an imposition cannot be justified except on grounds of a national emergency.  HS2 cannot plead such a status especially when its disbenefits can be discerned so clearly.

The published route of HS2 is overwhelmingly within open countryside whose main attributes are its scenic beauty, and its tranquillity and quiet restfulness.  Within such an area violent movement is alien, distracting the eye from appreciation of the landscape, and noise an abomination.

Unfortunately the alignment and operation of such a high speed rail track invariably creates the greatest possible damage to this highly valued environment, and “mitigation” of its effects must perforce extend over large areas recreating landscape, in its literally widest sense, if it is to counterbalance its destructive impact.

Sadly, illustrations of the proposed landscape assimilation for HS2 uses examples adopted from HS1 through Kent.  These are wholly inadequate when dealing with Staffordshire’s more extreme topography and choice of routing across higher ground.  The physical consequences have lead to brutal earthworks, cuttings and embankments, and exposure of the running track to open view over substantial lengths.

These effects are demonstrated dramatically in the Stage 1 proposals upon which we wish to comment.

Entering the County at Drayton Bassett the line should be capable of shielding earthworks and planting where it runs at or near land surface levels, but cuttings, although preferable in some degree to embankments, show crude engineering profiles at their entrances and exits needing the earth shaping and woodland introduced and modelling to soften their transition.

EXAMPLE A  Chainage 176,800/178,000 – Hints Village and Blackbrook Valley

Hints village is a charming even exquisite and unspoilt hamlet, lovingly maintained by is owners with care for its character.  We do not hesitate to describe it as an environmental jewel.  Its setting on the slopes of the steep Blackbrook Valley with the winding lane crossing a ford and then rising up sloping fields to the crowning woodland opposite makes a perfect composition.  It was earlier given the accolade by the District Council of “Special Landscape Area” until government decreed for administrative reasons the withdrawal of such categories other than for designated areas.

CPRE would have no hesitation in describing the village and Blackbrook Valley as the most idyllic – and tranquil – location in the County.  It would merit at least re-routing HS2 to run within the woodland in a roofed cutting, and/or re-routing to cross Blackbrook further west with a continuous tunnel as far as the re-routed A5.  (NB what headroom is required to cross a flood plain?)

EXAMPLE B  Chainage 179,400 – Flats Lane Diversion

Great publicity has attended the opposition of residents to this alignment, leading to suggestions for a “new village” to be created in the Green Belt for re-housing occupants.  CPRE would oppose this “solution” as breaching Green Belt policy to facilitate an unattractive intrusion by HS2.

We would rather advocate a “cut and fill” tunnel of minimum walled width to minimise property demolition, roofed to form a “village green” with the four crossing lanes routed informally across it.  This solution envisages joint working across the professional fields of engineering architecture, landscape architecture and site planning, which we believe should be normal practice.

EXAMPLE C  Chainage 181,600 to 182,400 – Whittington Heath Golf Course

CPRE has watched the transformation over many years of a bleak heathland site, to what now can seriously be described as an Arcadian woodland setting of unbelievable “natural” beauty.  It goes beyond belief that HS2 can now contemplate its destruction and presumably replacement elsewhere, starting again from scratch the 40 or 50-year process of wooded landscape creation.

This example along would condemn the HS2 project; re-routing or an extended tunnel would seem the only practicable landscape solution, which would link with the solution to Example B above.

EXAMPLE D  Chainage 183,000 to 185,100 – Darnford Lane to A38.

This length of HS2 presupposes a continuous 45ft to 50ft high embankment (plus power pylons) effectively “damming” the longitudinal visual sweep of the bally and cutting across the eastern arc of view of Lichfield and its cathedral spires.  The domination of the landscape by such a structure can be best judged looking northward from Darnford Lane at line level across the Streethay Farm on the A38 which the line oversails, and dominates on a 50ft high embankment.

We draw attention to the proximity of HS2 to the canals along this stretch, and others, and the transformation this effects on their tranquil setting.  Staffordshire’s canals are a major feature of its rural attractiveness and thus rural economics.  Detriment to these historic and environmental assets is to be deplored and avoided by whatever means.

CPRE fundamentally questions the choice of alignment for HS2 which results in such enormous and alien earthworks and raises real doubts whether any effective mitigation is feasible.  It has given rise to debate locally whether an alternative alignment west of Lichfield is worth attention even bearing in mind the disadvantages of such a routing.

Such public meetings as have been attended by CPRE when referring to environment mitigation and assimilation of the HS2 works into the landscape have had pointed out the HS1 works as exemplars of satisfactory practice.  For Staffordshire in particular its broken topography and choice of routing over higher ground has lead to need for earthworks of a much more forceful impact than experienced on the earlier HS1 – and a corresponding need for major mitigation works on perhaps a wider and more imaginative scale.

EXAMPLE E  Chainage 185,100 – 191,500 (Connection with WCML)

CPRE points out the elevated embankment prominent in the setting of any new residential development at Streethay, and the consequent need at least for substantial off-site tree planting here.  We raise no objections to the elevated embankment which, if tree planted would serve as a screen and separation of the industrial estate north of HS2.

Beyond approximately 187,300 the lines traverse between large woodland blocks could serve as an example of how to deal with the rail track at ground level in open country on a “whole landscape” basis.  (Please note our reservations above regarding the lines effect on the canals ambience and recreational/economic value).

At 190,400 the reminder is forcibly made that road diversions on embankments are part of the landscape scene and should be moulded into its whole 3-dimensional form.  Once again, also, we note the substantial embankment where HS2 joins WCML and its potential for constituting a new landscape feature if so modelled and planted for positive effect.

Hedgerow and tree planting

CPRE would seek a commitment in principle to replacement and augmentation of hedgerows and hedgerow trees – especially where these are close to onlookers viewpoints and therefore of maximum screening value.  We would offer the opinion however that these are not a replacement for full tree and woodland planting on a scenic scale with the objective of a full “landscape creation”.

P D J Goode, Technical Advisor


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