CONSULTATION RESPONSE
HS2 Phase 2b: Crewe – Manchester Environmental Statement Consultation March 2022
Mike Slater (Chairman MCAHS2)
Lea Head
Nantwich Road
Stanthorne
Cheshire
CW10 0LJ
Date: 30th March 2022
This submission is made on behalf of Mid Cheshire Against HS2.
Mid Cheshire Against HS2 (MCAHS2) is an action group formed in January 2013 to disseminate, inform, and educate local and national opinion on the proposed HS2 Project.
MCAHS2, its members and supporters fundamentally disagree with the principle of High-Speed Rail as a tool for producing increased interconnectivity, jobs, and growth. Railways were a functional part of the industrial revolution, which had a requirement to move materials and goods around the UK. The decline of traditional industries, the rise, convenience and greater connectivity of road transport, the move toward a service economy, the proliferation and use of the internet in business and everyday life, and the post pandemic ‘working from home’ culture mean that it is ‘local shared office space’ and ultra-highspeed broadband that will lead to wider connectivity, growth, and greater prosperity.
We continue to have grave concerns about the timeframe for consultations of such complexity. The abundance of paperwork and documents that require detailed examination and cross-referencing in the limited time frame of 8 weeks produces a flawed engagement process. Critical information made available for the consultation appears to be out of date, plans include cross-sectional maps marked as ‘Interim Preliminary Design’, dated 2018. The lack of up-to-date information on construction traffic movements, environmental issues, and noise from construction limits our ability to make a comprehensive assessment of the impacts and mitigations required. The lack of this data and consequent mitigation is a flagrant omission on a critical matter which will blight the lives of residents, adjacent to the route, over the long period of construction.
MCAHS2 continue to seek the views of the public and our members by holding open meetings at organised events such as The Royal Cheshire Show.
Prior to the pandemic we regularly attended meetings with representatives of HS2 Ltd and raised concerns on issues of engagement, engineering, and the environment and we also lobbied and informed local MPs and county councillors. Post pandemic the ability to interact with HS2 Ltd has deteriorated to a point of no meaningful contact.
The HS2 Minister, Andrew Stephenson stated in his latest 6 monthly progress update to Parliament:
“I expect affected communities to be at the heart of our plans for this project. I am therefore pleased that HS2 Ltd.’s refreshed community engagement strategy (‘Respecting People, Respecting Places’) has this vision at its core and sets out HS2 Ltd.’s renewed commitments to the communities impacted by the programme”.
HS2 Ltd. and their associates must therefore ensure they are proactive in public engagement, have consulted, assessed, and considered, in the design and implementation of the project, all the information submitted and communicated by the public and others via HS2 consultations, public information events and other means.
HS2 state that the environment has been central to selecting the route and developing the design, MCAHS2 continue to believe that the route of the Proposed Scheme through the salt fields of mid-Cheshire is flawed and potentially dangerous.
The route north of Crewe passes over the mid-Cheshire salt field an extensive area of geologically unstable and challenging ground which continues to be prone to subsidence. The track tolerance for movement on the HS2 line is extremely small (5 mm); infrastructure on the WCML is constructed with inbuilt jacks to compensate for natural and continuous movement, a solution which would be a disaster for HS2. MCAHS2 commissioned TerraConsult Ltd to produce an independent geotechnical report on the proposed (2016) change of route, they concluded that there would be an increase of 11% in the route length over wet rockhead. HS2’s lead ground engineer called the ground conditions in the Cheshire salt area “spicy” when referring to the engineering challenges of building a high-speed railway through that area; Wardell Armstrong HS2’s own consultant recognises the risks of building HS2 through mid-Cheshire stating HS2 will be at “high risk” of ground collapse and “large structures may be particularly susceptible to unwanted movement, and it is important to understand the local geology, faulting and collapse mechanisms”. None of which has been done.
HS2 Ltd acknowledge the potential for subsidence, “The study area is located in a brine compensation area which indicates there is the potential for subsidence resulting from the historical pumping of brine”, but there is no analysis of whether HS2 rail operations will be impacted by subsidence or whether construction will be causative of subsidence in future.
Early geotechnical investigation work to obtain more advanced survey information was cursory and the results of these ground investigation works have not been made public. HS2 Ltd admit that there is more work to be done to further assess the geological risks, they have announced a £350 million contract to appoint a lead ground investigation team, supported by up to ten specialist ground investigation contractors; this work will inform on the choice and cost of route and should have been carried out prior to the deposition of the Hybrid Bill.
It should be noted that the extreme weather events we are experiencing will affect the water table and present even greater challenges through the unstable salt district geology. HS2 Ltd state that the Proposed Scheme has been developed with “the need for critical infrastructure and environments to be resilient to future climate change impacts and risks” and that HS2 has been designed with “events such as high winds, intense rainfall and major storms, in mind”. What HS2 fail to mention is the increase in water table levels over time and the associated risks to the Proposed Scheme.
The salt fields of mid Cheshire are especially susceptible to ground movement caused by salt dissolution. The predicted rise in sea level of 150 centimetres over the lifetime of the Proposed Scheme with consequential rises in water tables and groundwater flooding will lead to increased dissolution and landslip putting the rail line at severe risk. Boreholes, man-made caverns, or underground mines may enable unsaturated water to flow through or against salt deposits allowing development of small to large dissolution cavities. If the dissolution cavity is shallow and large enough roof failures can cause land subsidence or catastrophic collapse. Because salt dissolution proceeds rapidly karst features can develop quickly and with dramatically adverse impacts.
MCAHS2 are at a loss to understand why any responsible body would deliberately expose the public to such severe risk.
The cost of overcoming the geological challenges in building a high-speed railway through Cheshire is still an unknown and paramount to that is an in-depth understanding of the geological challenges. HS2 Ltd have stated that geotechnical investigation will not commence until late 2022 and cannot therefore forecast the costs with any degree of accuracy. HS2 has singularly failed to fully comprehend and understand the Phase 2b route geology.
The current solution to the problem of subsidence is to raise the route through mid-Cheshire on embankments and viaducts which presents a highly visible and noisy intrusion into the landscape. A scar running the full length of and splitting mid-Cheshire. The only way to effectively mitigate HS2 through mid-Cheshire is by tunnelling from Crewe to Manchester.
It is the opinion of MCAHS2 that HS2 Phase 2b cannot be built safely and at the same time offer value for money.
In January 2018, the Government’s 25-year Environment Plan set out the goals for improving the environment within a generation and leaving it in a better state than it is at present. The construction of HS2 is not in line with the Government’s commitment to sustainable development over a 120-year period never mind a 25-year period.
HS2 claims that it will be carbon neutral in its lifetime of 120 years; the latest IPCC report Feb 2022 stated, “we only have a narrow window to prevent the worst of climate impacts this decade”. HS2’s planned reduction of carbon in its construction over the next decade and it’s claimed carbon neutral objective by 2040 is too little too late.
The HS2 Minister, Andrew Stephenson stated in his latest 6 monthly progress update to Parliament:
“In January, HS2 Ltd published its ‘Environmental Sustainability Vision’ which reaffirmed its commitment to provide low carbon rail travel for a cleaner, greener future. I was delighted to confirm, as part of that vision, that HS2 trains will use zero carbon energy from day one of operation. This will support HS2 Ltd.’s target to achieve net zero in construction and operation from 2035. The commitment is a key part of the new HS2 ‘Net Zero Carbon Plan’ “ ambitious new targets to reduce the carbon footprint of the programme”.
A laudable claim however it ignores the embedded carbon during 20 years of construction, the land take, and the loss of mature trees, all of which restrict the ability of HS2 to become carbon neutral in its lifetime. Post COP26 the understanding is that the current decade will be critical in our attempts to limit temperature increases to 1.5 °C. The Proposed Scheme is incompatible with Paris 2015 and COP26 commitments.
In June 2021 the Government announced an aim for the Proposed Scheme to deliver net gains in biodiversity. The plans being developed by HS2 within the Phase 2b section of the route to support this key policy area fall far short of net gains. The site of the RSD north of Crewe decimates this quiet rural area of Wimboldsley. The small amount of tree planting in this area is a facile attempt at mitigation for the wholesale damage caused by the siting of the RSD in a greenfield location.
HS2 Phase 2b will not serve nor be of benefit to most of the population of the mid-Cheshire region. During construction the rural villages will be surrounded by construction compounds for up to 10 years. There is no reference data about the expected noise or planned mitigation throughout this long construction phase which will be even more disruptive, intrusive, and troublesome to residents than the eventual operation of the railway. The peace and tranquillity of the area will be severely and negatively compromised by the construction of HS2 Phase 2b.
The communities of mid-Cheshire would be better served with rail improvements along existing corridors and improved and integrated rural bus services for Cheshire, South Manchester, and the North West in general.
HS2 will not level up the North. Investment in existing rail infrastructure in the North would be of a far greater benefit in levelling up the regions and cities, and improving productivity and connectivity rather than building a single high-speed route with few stations going to the South East. HS2 is London centric and the benefits of capacity release on the existing classic network diminish as you move farther away from London. The North needs enhanced commuter and short haul rail options. It is a matter of concern that the journey from Manchester to London will be 1hr 11 mins whereas Northwich to Manchester a journey of some 24 miles will, after the colossal spend on HS2, still take more than an hour.
HS2 does not represent value for money. There are better options which would bring better and faster returns. The destruction of prime agricultural land and the need to overcome numerous complex geological issues throughout the salt district of Cheshire increases costs and compromises the return on investment.
We agree with Lord Berkeley that an ‘Integrated Rail Plan’ should deliver better more integrated regional services by concentrating on smaller regional projects and better local services with the emphasis on electrification and capacity that levels up the regions and delivers more benefits more quickly than HS2.
HS2 and the IRP do not deliver the levelling up, capacity release and enhancement of rail freight capacity that is required to benefit the North and the Midlands; HS2 is London centric, it delivers the most benefit from capacity release and connectivity to London.
HS2 Ltd state that they are “committed to developing an exemplar project through seeking environmental enhancements and benefits whilst limiting negative impacts through design, construction and operation of the railway”.
Throughout mid-Cheshire the route is highly visible on embankments and viaducts which will produce adverse effects even with the proposed mitigation measures. We note that the term ‘significant adverse’ used throughout the ES enables effects to be downgraded to ‘adverse’ with mitigation. An adverse effect is still of considerable concern for all receptors.
The ES states “Ground stability and the potential for managing subsidence as a result of mine workings, for example for the extraction of salt, brine, coal and limestone has been considered in the development of the design”. HS2 are therefore aware that ground stability and subsidence are potential hazards, and they have responded to this problem by raising the track onto embankments. They have not carried out detailed geotechnical investigation work which leaves them ignorant of the impact that construction and operation will have on the underlying geology.
The ES also states that the route of the Proposed Scheme “will intercept mining and mineral resources, including salt extraction” and where these resources will be impacted by the Proposed Scheme “they have been dealt with in the context of their value as an asset”. In other words, the ES does not address salt mining as a hazard that may cause subsidence to the HS2 track or viaducts, it focuses instead on the impact HS2 may have on commercial operations.
HS2 say of the Middlewich to Pickmere route through salt mining areas. “The route would avoid direct interfaces with brining and gas storage infrastructure and would be raised to allow for management of drainage and geological risk. There would also be more flexibility for ground stability mitigation options”.
The reference to ‘infrastructure’ is an obfuscation. The proposed route narrowly avoids brine well-heads and surface installations, but in the absence of a comprehensive study of underground caverns, watercourses and brine runs, the impact of HS2 on those geological features is completely unknown. Raising the track on embankments and the driving of piles for viaducts will alter and/or create new underground watercourses/brine runs, with an unknown impact on salt dissolution leading to subsidence. HS2’s reference to “flexibility for ground stability mitigation options” is a coded admission that HS2 Ltd are stepping into the dark and seeking Parliamentary consent to proceed without having completed their geological homework.
The ES makes no risk assessment for the driving of piles to support viaducts in these locations. It has been suggested that piles to depths of 100 or 120 metres will be required. This is an area where sunken glacial till overlies salt levels that have collapsed following brine extraction. The subsided landscape is sprinkled with bodies of water known as meres or flashes. HS2 have not produced any assessment of how the driving of such piles will disrupt the migration of water and accelerate salt dissolution.
- Community Areas.
Wimboldsley to Lostock Gralam area (MA02)
Pickmere to Agden and Hulseheath area (MA03)
- Socio-economics.
The temporary and permanent adverse effect on the socio-economics of the area are of concern. HS2 Ltd are very positive about the employment opportunities of the Proposed Scheme but these come at a price for local communities and businesses along the route.
The Proposed Scheme requires the demolition of 34 residential properties, 11 commercial properties and six other structures.
There will be permanent closure, realignment, or diversion of 20 roads, 13 public rights of way and seven watercourses will be permanently diverted or realigned. The Proposed Scheme will require excavation of engineering material from four large borrow pits in this area.
Construction of the Proposed Scheme will result in significant residual effects with respect to sterilisation of the salt resources associated with the Springbank Farm extension to Holford Brine field. The Springbank farm extension to Holford Brine field has planning permission for 12 salt caverns. The Proposed Scheme will impact on the viability of five of these caverns, resulting in the loss of these resources.
During construction the Proposed Scheme will require land currently used for staff car parking at the Gadbrook Distribution Centre in Northwich. The operations of the businesses at this location will be affected by this loss.
The Verdin Arms public house in Walley’s Green will experience isolation effects as it will cease to have access to the main road (the A530 Nantwich Road) and will experience less exposure to and trade from passing travellers.
During construction, Holford Hall Estate Wedding Venue east of Lostock Gralam will experience significant noise effects which may discourage customers from using the venue, resulting in a significant adverse effect on the business.
Construction of the Proposed Scheme will require temporary use of 25ha of land at the Cheshire Showground, of which 5ha will be required permanently. This is likely to mean that the showground will not be able to continue to operate. Whilst avoidance and mitigation measures have been considered during the development of the design with provision to maintain vehicular and pedestrian access to the Cheshire Showground during construction this may not be sufficient to offset the disruption during construction and enable the showground to continue to function and hold events.
The Proposed Scheme will require the permanent acquisition of land from Mere Court Hotel and Cheshire Showground, potentially affecting the viability of and resulting in a significant effect on both businesses.
Customers of Heyrose Golf Club are susceptible to change in the local environment and setting and may be discouraged from using Heyrose Golf Club due to highways changes and a combination noise and visual effects associated with construction and operation of the Proposed Scheme. This may impair the business’s ability to attract and retain customers.
It is stated that “The Government recognises that the Proposed Scheme will have significant effects on those who live close to the route and upon the local environment through which it will pass. HS2 Ltd.’s aim is “to ensure that the significant adverse effects of constructing and operating the Proposed Scheme are avoided, reduced, or mitigated, as far as reasonably practicable”.
However, mitigation from the effects of construction noise is sadly missing from the ES and communities along the route of the Proposed Scheme will be subjected to high levels of noise throughout the long period of construction. This will lead to stress and high levels of dissatisfaction.
There are many properties along the route and close to construction compounds which are affected by construction and operational noise. Affected properties should be afforded sound insulation at the commencement of enabling works and prior to construction activities to mitigate for nuisance effects as early as possible.
Acoustic fence barriers for communities of along the route should be high enough to contain the noise from catenary and not just the rail track.
It is surprising that the HS2 list “Notable community facilities within the village of Pickmere” include the Pickmere and Wincham Methodist Church and the Red Lion public house but fail to mention the Village Hall or Grade 2 listed buildings. There is also a reference to the Cheshire Showground but no mention of Pickmere Lake which is an important local wildlife site that attracts thousands of visitors annually.
No alternative provision has been made for the permanent ‘live aboard’ boating community at Park Farm, Stanthorne. These permanent moorings will be lost during construction of the canal rail bridges. Alternative moorings need to be identified by HS2 Ltd so that this permanent boating community can continue to reside in the local area for family connectivity and work.
During the construction of the Proposed Scheme access to the Winnington and Peas woodland from the A559 Manchester Road will be prevented on a permanent basis, which will mean that most of the walking track and woodland will be inaccessible. We note that HS2 Ltd propose to re-instate the permissive path through Winnington and Peas Wood Local Wildlife Site once the Proposed Scheme is operational.
In the environmental statement there is no recognition of the disastrous disruption of wildlife habitat from the removal of Store Room Wood and the blocking of fox and badger runs. It is very clear to any wildlife specialist that although most of the fox earths and badger sets are to the west of the proposed line, the territory they need to survive and feed in extends to the east. No tunnels for crossing points have been indicated on current maps and no acknowledgement that wildlife can only survive where there are effective corridors, movement here is blocked to the west by the river Weaver. The Proposed Scheme is a disaster for the environment and wildlife from potential flooding issues to trapping wildlife in an unacceptably small area.
The operation of the proposed development ‘Middlewich Eastern Bypass’, expected from 2021 onwards together with the operation of the Proposed Scheme, expected from 2038, is anticipated to result in an adverse negative impact on barn owl in these locations because of collision risk. The consecutive nature of these impacts is likely to result in an increase in mortality of barn owl over time, leading to an overall reduction in breeding success for these pairs and will therefore result in a significant adverse effect on barn owl at Wimboldsley and north-west of Middlewich.
We know from Phase 1 that living close to construction works for the Proposed Scheme causes extreme anxiety. Construction News dated 9th March said, “Contractors working on the £100 billion High Speed 2 (HS2) project have been told to clamp down on excessive noise amid a rise in complaints”.
The HS2 independent construction commissioner said there was evidence of a “growing impact on suburban and rural communities” from sound associated with the megaproject. Mark Worthington’s 13th report since taking on the key arbitration role three years ago revealed that 368 complaints were made to HS2 Ltd in the final quarter of 2021, up from 358 in the previous quarter. He said: “There are growing impacts on suburban and rural communities, which contractors need to be mindful of” and “I feel that I must mention again the frustrations of many local people at the impact of noise. It continues to register very strongly in the complaints. With spring and summer approaching, contractors need to be very aware of the impact of their works.”
Worthington said road use by HS2 contractors generated “by far the largest number of complaints”. He called for construction companies to work harder to mitigate the impact of road closures on local communities.
The combination of traffic noise, construction noise, a non-local workforce, and visual impacts will change the character of neighbourhoods resulting in a massive impact on health, mental health, and the wellbeing of residents living amidst such major works over an extended period. They will experience this as changing the quality of their neighbourhood and regard that change as adverse, in diminishing the amenity of their area and reducing the sense of its rural character. Residents will be subjected to high levels of dissatisfaction with their living environment, their use of outside space, the visual impact and the noise, light and air pollution over the construction period. Life in Lostock Green village has already been eroded with HS2 Ltd owning at least 12 houses in the village that are either empty or rented out, which has a detrimental effect on the local community.
It should be noted that there is no mention of respiratory disease or mental health within the ES.
Viewpoints will be significantly affected both during construction and operation. Plantings will not provide adequate screening during the autumn, winter and spring months and it is debatable as to whether the screening will be adequate in the summer months.
The Middlewich box structure, 164m in length and up to 13m in height, carrying the route of the Proposed Scheme and Crewe Northern Connection over the southbound HS2 reception track cannot be mitigated resulting in a far reaching severe visual impact.
The presence of construction traffic is likely to give rise to concerns about road safety, which may contribute to perceptions of reduced neighbourhood quality.
Construction of the Proposed Scheme will result in significant demolitions of properties in the village of Wimboldsley, representing a large proportion of the local community. The erosion of social networks resulting from these demolitions will decimate the community reducing levels of social contact and support and the health benefits they generate. It is expected that most of the population at Wimboldsley will experience impacts on two or more environmental or social factors that influence health during the construction of the Proposed Scheme, and this will result in a cumulative effect on health.
Operation noise and visual impacts from passing trains will result in permanent operational impacts on neighbourhood quality in the communities near the Proposed Scheme. The anticipated service of up to 9 trains per hour each way produces a continuous noise impact between 05:00 and midnight from Monday to Saturday and between 08:00 and midnight on Sundays.
HS2 Ltd acknowledge most of the impacts of the construction of the Proposed Scheme but fail to provide suitable mitigation measures.
Temporary closure, diversion, or realignment of public rights of way will increase travel distances for users of public rights of way. This will affect the leisure and day to day activities of many people who live in and around the affected areas.
Severance of the public footpaths will isolate Lostock Green from local essential services and amenities, robbing residents of the freedom to choose to walk; not all residents have access to cars. Closing footpaths or massively elongating them impairs residents’ ability to walk to the local chemist, local shops at Rudheath and Lostock Triangle, the two primary schools in Lostock and Rudheath and to access the only public transport at Lostock Gralam Station.
Notice has been served on many footpaths throughout mid-Cheshire. HS2 Ltd should ensure that such notice is required, to do otherwise is to restrict freedoms without just cause. As an example, notice has been served on footpaths 15/1 (Plumley), 15/2 (Plumley) and 8/2 (Lostock Gralam) as shown on Drawing No. 2DE01-MWJ-HY-PLN-M000-000037 Rev HB01. These footpaths are used daily by many walkers, they provide a link between communities and a link to numerous other footpaths in the area. These footpaths are unaffected by any of the proposed works as specified.
The notices are not “reasonable” and should be revoked, this must apply in all instances where notice has been served on footpaths which are not directly interfering with the Proposed Scheme.
- Sound, Noise, and Vibration.
Noise and vibration effects from construction will result in significant effects on the acoustic character of residential communities closest to the construction works and construction traffic, and will cause significant noise effects on adjacent residential properties.
Operation of the railway will result in noise effects on occupants of residential properties, due to potential noise increases above recognised thresholds, and hence change the existing acoustic character around those properties closest to the Proposed Scheme.
HS2 Ltd will offer noise insulation and/or temporary rehousing to dwellings which satisfy the applicable qualifying criteria. It is essential that noise insulation of properties is the preferred method of mitigation and that it is carried out at the start of enabling works and prior to the start of construction.
HS2 Ltd state that by year 30 of operation extremely severe noise and visual impacts should have been mitigated. That is 50 years from now; the Proposed Scheme has a multi-generational impact.
- Construction Compounds.
There will be three main compounds and 37 satellite construction compounds required in this area. Ten of these compounds will continue to be used as satellite compounds for railway systems following the completion of civil engineering works at those compounds. There will be one further satellite compound used for railway systems works only and four borrow pits for the extraction of acceptable engineering material for construction.
Four of the compounds in this area will provide temporary accommodation for up 90, 125,100 and 155 workers respectively.
The number of construction compounds has increased from a total of 20 (2018) to 27, as shown on current plans for the Wimboldsley to Lostock Gralam and Plumley section of the route. This exacerbates the potential to disrupt traffic, cause noise, air and light pollution and impact on residential properties adjacent to the compounds.
The location of the Smoker Brook South Satellite Compound is on a non-designated heritage asset. When reinstated at the end of the construction period it will be irreversibly changed which will impact on the heritage status.
There are many instances when the core working hours of construction compounds can be extended and the protection afforded to residents adjacent to construction compounds compromised. Project time pressures can lead to misuse with subsequent increases in noise, air, and light pollution.
Saturday working hours of 8am-1pm are totally unacceptable. The proposed working week provides only 1.5 days of respite for residents each week, assuming of course that these core working hours are not extended. These conditions will have a severe detrimental effect on the health and wellbeing of residents.
Limits on construction working hours must be adhered to, there is far too much room for increases in the core working hours.
- Traffic and transport.
The ES states that “Construction will lead to increased vehicular traffic and has the potential to cause increased congestion and journey times at several locations”. “The most intensive periods of construction of the Proposed Scheme will cause changes in traffic that will result in additional congestion and/or delays for road users”.
There is insufficient information about the impacts of construction traffic and HGVs on the local road networks and construction traffic routing plans, the number of HGV movements, the impact on existing traffic volumes, the anticipated delays of adding slow moving large vehicles to the road network exacerbating existing congested roads and junctions, and the potential for additional mud and debris being brought onto the local road network by construction traffic exiting from construction areas. A robust plan to minimise construction traffic impacts and an assessment of the noise and air quality issues are omitted from the ES.
The volume of traffic on the A556 continues to increase with added pressures from new homes and expansion of industry in mid-Cheshire. The construction of the Proposed Scheme will significantly increase the volume and character of traffic and impact primary and local roads.
Mitigation measures for the increased vehicular movement especially control of HGVs entering and exiting from the construction compounds will inevitably cause disruption to existing users of the main road networks.
We continue to have serious concern about disruption and safety during the realignment of the A556 and increased danger where the new realignment of Birches Lane joins the new A556, slow moving traffic will be joining fast moving traffic after a blind summit on the A556. This potentially dangerous vehicular access is unacceptable. There are other major road realignments to Chester Road, Pickmere Lane, Flittogate Lane and School Lane, all of which will cause significant diversions, inconvenience, and re-routing of traffic on unsuitable roads.
There will be a significant impact from the presence of construction workers living on site and increasing traffic on local highways, particularly Gadbrook Viaduct North satellite compound accessed via King Street roundabout which as reported by CWAC is already over capacity.
Local people and businesses will be greatly inconvenienced by the unnecessary stopping up of local roads and significantly long and time-consuming diversions along unsuitable country lanes which are to be shared with heavy plant and construction traffic. The rural tranquillity and open green aspects of areas throughout mid-Cheshire will be irreversibly damaged.
Necessary ‘improvements,’ widening of our rural network of country lanes most of which have a 7.5t weight limit, to accommodate HGVs and construction vehicles will permanently blight the rural character of areas along the line of the Proposed Scheme.
The unsuitability of Wimboldsley as a location for the Crewe North RSD is exacerbated by the knowledge that parking for 450 vehicles will be created. The character of this quiet rural area will be dramatically changed. How does this fit in with sustainable transport and net zero aspirations?
- Landscape and visual.
During construction temporary residual effects will arise from the presence of construction works including night-time lighting and changes to the existing landform and vegetation patterns that will affect the character of the local landscape at several locations along the route. The loss of vegetation, noise from construction equipment, construction compounds and changes in landforms will impact the tranquillity of the agricultural landscape. Early planting to reduce the visibility of the Proposed Scheme must be managed to ensure that it thrives and provides the required mitigation.
Construction of the Proposed Scheme will result in significant visual effects at 90 representative viewpoint locations within the area, residents at 22 representative residential viewpoint locations will also experience adverse night-time visual effects due to additional lighting associated with construction compounds, the proximity of lighting associated with realigned roads, and elements of the Proposed Scheme. It is of concern that no mitigation measures are proposed to offset the impact of night-time light pollution. These effects must be mitigated.
Whilst HS2 state that during operation “the significant effects of the Proposed Scheme on the character and appearance of the local landscape will substantially reduce over time” they also state that the “effects may remain significant”. This is unacceptable, mitigation measures must integrate the Proposed Scheme into the landscape such that there is no visual intrusion.
- Historic environment.
The Proposed Scheme will have a significant detrimental effect on 36 historic buildings and sites along the route including the tranquillity of the Trent and Mersey Conservation Area as the introduction of modern infrastructure will change the historic and rural character of the settings.
The mitigation of modern infrastructure in an historic setting is impossible and the character change will be permanent.
- Land quality.
The primary school at Wimboldsley is the only community asset in this village where 40% of the land area will be taken and is rated ‘Outstanding’ by Ofsted, the school accommodates 150 children half of whom have special educational needs. The key assets of the school along with the teaching staff are that it is a ‘village school’ providing sanctuary and a peaceful environment for learning. If the school had to be moved, the current environment would be lost and the proposed plans especially with the monstrous Crewe North RSD being so close would jeopardise the learning for many pupils especially those with special educational needs. The proposed borrow pits and heavy lorry movements should be kept away from the school to ensure that it continues to provide sanctuary for the children. The school will need a buffer zone to minimise noise and light pollution. Within the environmental statement there is no recognition of these needs and the damage the Proposed Scheme will have on this vital resource.
On maps outlining the location of the Crewe North RSD which is proposed to be built on the Wimboldsley plain in the parish of Stanthorne & Wimboldsley, a wastewater treatment plant is shown but there is no indication of what will then happen to this water and whether the drainage from the whole site will be captured and processed. The surrounding land drains to the river Weaver and there is therefore a serious environmental risk of pollution if all water landing on the Crewe North RSD is not treated before leaving the site. There is no indication of planned drainage beyond the proposed depot whereas other more suitable potential sites especially the Basford sidings south of Crewe have the advantage of already being linked to mains sewage systems.
The farmland currently comprising the Wimboldsley plain drains to the river Weaver along with properties on the A530 main road, two culverts are proposed for surface water after construction of the Proposed Scheme however the process of digging the ‘borrow pits’ will sever current drainage systems resulting in the flooding of Lea Head and any other properties with cellars, there is no indication of plans to avoid damaging these adjacent properties.
The current plans to use clay from the Wimboldsley plain will destroy the current drainage network, damaging neighbouring properties. It is essential that mitigation is in place before the proposed construction.
On the indicative maps post construction there are balance ponds shown to manage the drainage and egress of water. It should be noted that where subsidence has occurred due to salt extraction and the route of brine streams the subsidence fills with water and forms long term ponds from which water does not drain away. The replacement of land drains will be required to ensure water egress occurs and will reach the proposed culverts. It should be noted that imported fill material will take many years to settle before effective drainage can be installed. It should also be noted that to effectively grow trees, shrubs and grass the bulk density of the soil must be no more than 1.6 kg/l.
Lostock Green has seen an increase in the land take of 156% more compared to the 2018 map books, a huge increase on temporary and permanent land acquisition.
The area of High Legh is significantly affected by the Proposed Scheme having existing, proposed HS2 and future NPR rail routes crossing the area. This has the effect of creating isolated partitions of land on prime agricultural land, blocking nature corridors for wildlife habitat endangering biodiversity at the very time we need to be doing the opposite.
- Agriculture, Forestry and Soils.
There is a significant loss of 452ha of land which will be permanently required by the Proposed Scheme, 178ha of which is high quality agricultural land, and 32 holdings will be permanently significantly affected due to the proportion of land required, severance or demolition of buildings. A large proportion of this, 65ha, is attributable to the Crewe North RSD at Wimboldsley which has a dramatic effect on this hither to rural area.
The ES says “HS2 Ltd has designed the Proposed Scheme to avoid or reduce adverse impacts on habitats, species and other features of ecological value”.
Less than 2.4% of the UK is covered in ancient woodland, bringing vast benefits to people, wildlife, and the environment. The UK’s ancient woodlands and veteran trees are incredibly diverse and valuable habitats that provide a home for many rare and threatened species, such as dormice, lesser-spotted woodpeckers, and Bechstein’s bats.
The loss and devastation of woodland and hedgerows throughout the mid-Cheshire area is of particular concern. It destroys habitat for birds, animals and insects destroying ecosystems which will not recover for many years. It significantly increases the amount of embedded carbon in the Proposed Scheme and affects the wellbeing of residents.
HS2 Ltd must learn from Phase 1, where many ancient woodlands were lost due to poor mapping and lack of assessment of suitable alternatives.
The construction of the Proposed Scheme will result in the temporary use of 1.2ha land at Winnington and Peas Wood Local Wildlife Site, 10% of the total area. It is stated that 0.4ha will be required permanently however this is a misnomer. All woodland will take a minimum of 50 to 100 years to recover to a mature condition. Winnington wood is an ancient woodland and as HS2 state “Ancient woodland is irreplaceable, and its loss will result in a significant permanent adverse residual effect”. It is more accurate to say that the permanent loss of ancient woodland is 1.2ha, or whatever is the total amount taken for construction of the Proposed Scheme.
Construction of the Proposed Scheme will lead to a total loss of 1.6ha of ancient woodland from Stanthorne Hall Farm, Bull’s Wood, Winnington Wood, and Leonard’s Wood, Smoker Wood, Daisybank Wood and Belt Wood resulting in a permanent significant adverse effect upon ancient woodland at each location where this habitat is lost.
HS2 admit ancient woodland is irreplaceable and therefore it cannot be partly compensated through any mitigation measures, including planting of native broadleaved woodland, the translocation of ancient woodland soil with its associated seed bank or planting native trees and shrubs.
HS2 state that “where reasonably practicable, measures will be taken to protect veteran trees that are assumed to be lost”. HS2 then go on to assume that “within the land required for construction all but one veteran tree will be lost” and “the assumed loss of at least two veteran trees from Leonard’s and Smoker Wood Local Wildlife Site and Arley and Waterless Brook Corridor Local Wildlife Site which will result in a permanent adverse residual effect”.
There will also be a net loss of 103.7km (64.5 miles) of hedgerow, which will result in a permanent adverse residual effect.
Construction on the Proposed Scheme will result in the loss of orchard habitat from Bostock Road Orchards Local Wildlife Site and Pear Tree Farm.
The impact of the construction of the Proposed Scheme on woodland is difficult to visualise, figures provided by HS2 show hectares impacted which does not give a good indication of the width of corridor required through a woodland for both construction and operation. However, given that the finished width, fence to fence, is stated to be 22 metres it is a fair assumption that a larger land clearance will be required for the construction, say 32 metres. This will fragment and significantly impact woodlands within the Parish of Plumley that are affected, Winnington Wood, Peas Wood, Smoker Wood, and Leonard’s Wood. All are traversed by the Smoker Brook Viaduct and will be permanently impacted. The extension of the Lostock Gralam North Embankment has increased the land take at the end of Long Wood adjacent to the A556.
It is evident that the primary proposed mitigation measures of woodland habitat creation to replace ancient woodlands and provision of connectivity between habitats fall woefully below the measures that will be required to minimise the impact of the massive and extended construction impacts on the predominantly rural and tranquil mid- Cheshire countryside.
- Water resources and flood risk.
The ES says “the Proposed Scheme will cross watercourses either by viaduct, bridge, or culvert. These structures, together with cuttings and embankments, are being designed to consider the potential impact on surface waters and groundwater” and “the Proposed Scheme will be designed to avoid an increase in the risk of flooding from all sources in line with relevant guidance, considering the projected impact of climate change”.
We have commented earlier in this response on the extreme weather events we are experiencing that will affect the mid-Cheshire area with a predicted rise in sea level of 150 centimetres over the lifetime of the Proposed Scheme with consequential rises in water tables and groundwater flooding. Have HS2 Ltd considered this level of increase in the water table and the associated risks to the Proposed Scheme?
HS2 is being designed to cope with extreme weather events of one in a hundred years based on climate conditions over the last thirty years with an additional 40% flow. The increasingly frequent and extreme weather events we currently experience will challenge that design.
- Climate and Environment.
“The HS2 Environmental Policy seeks to minimise the carbon footprint (of the Proposed Scheme) and deliver low carbon, long-distance journeys that are supported by low-carbon energy”.
Despite HS2 claims to be a key agent for change to net zero carbon transport. It is beyond dispute that HS2 will have a disastrous impact on greenhouse gas emissions. The government’s own calculations for HS2 suggest its carbon emissions could exceed potential savings, even over the railway’s projected 120-year lifetime and HS2 Ltd.’s forecasts over the life of the Proposed Scheme show that overall construction and operation produce a net increase in carbon emissions of 1.49m tCO2e.
Evidently this will have a major negative impact at a time when biodiversity and reduction in carbon footprints are urgently needed. The Proposed Scheme fails to meet the UK’s commitments made under the Paris 2015 Agreement and COP26.
The Proposed Scheme, by connecting airports more effectively in London, Birmingham, and Manchester, will inevitably lead to an increase in flights which destroys any suggestion that HS2 is a key agent for change to net zero carbon transport. The case for a station at Manchester airport must be reassessed as it results in significant loss of ancient woodland and facilitates growth in carbon-intensive air travel for the lifetime of the Proposed scheme and beyond.
All planning when considering the next decades must have climate change and adaptation in its thinking. Post COP26 it is very clear that this decade is critical if we are to attempt to turn things around. HS2 will not provide any solutions this decade or within its lifetime.
- Route-wide effects.
The highly topical decline in passenger numbers since the Covid pandemic further damages the wafer-thin business case for a High-Speed service. It seems optimistic in the extreme for the route to reference a station at Manchester Airport without any guarantee whatsoever about ‘third party funding’ for the station and denying all allegations of promoting air travel by providing a link to the airport.
The construction of HS2 in the same area as the recently proposed Hydrogen gas network Hynet seems contradictory and it should be noted that the Proposed Scheme has a direct impact on strategic gas storage which compromises national energy resilience by reducing strategic reserves.
The ‘opportunity cost’ of HS2.with its £96bn price tag will lead to less investment in carbon-saving transport, such as electrifying existing railways, regional rail, and buses.
A hub station at Crewe with integrated connections on existing and improved travel corridors to Manchester and the existing West Coast Main Line would serve the North West far better.
The subject of subsidence is not adequately considered and no evidence of the “more work to be done to further assess geological risks and to provide suitable mitigations for them” promised by the Under Secretary of State for Transport in 2017. The “Land Quality” section deals primarily with contamination. stating “It should be noted that the Holford Brine field landfill site and Winsford Rock Salt Mine Waste Disposal Facility are of national importance, but as the facilities are located at depth and the Proposed Scheme is at surface level at these locations the impact on these ‘landfills’ is expected to be negligible.”
- Off-route effects.
We are concerned at the lack of detail made available at this stage of the design process, this inhibits our ability to enable a full and comprehensive assessment of the impacts and mitigation required that is crucial to a meaningful response.
The photo montages represent a fairy tale image of the railway that tests credibility.
The vast extent of the Proposed Scheme throughout mid-Cheshire is on embankments and viaducts which will have a major and widespread impact on land take, noise, visual impact, vibration, and the environment. This comes at a huge cost to the affected communities.
HS2 Ltd must provide mitigation measures that will successfully ensure integration of HS2 infrastructure within the landscape. This will require either bespoke designs of exceptional quality or tunnels.
