HS2 Environmental Case

Environmental Impact Assessment

More information on how HS2 will conduct this is given on our mitigation page here

 

EU Challenge

HS2AA fully support the letter of complaint to the EU commission over the UK’s decision on High Speed Rail, that the wildlife trust (BBOWT) are sending today.  For press release from Berks, Bucks, and Oxon Wildlife Trust (BBOWT) see here   Hilary Wharf, Director of HS2AA says “The UK has a bad record in applying EU environmental legislation – and if the UK courts are not going to remedy this for High Speed 2 then we are confident that the EU Commission will”. 

Noise

If HS2 is built, once the dust generated by its construction has settled the main ongoing impact on thousands of people living near the line will be noise nuisance. Unfortunately this subject has been largely ignored by politicians – there is only a single sentence on noise in the Transport Select Committee report – and downplayed by HS2 Ltd. Noise is deemed a difficult technical subject, beyond the comprehension of the man in the street. However we all have noise detectors, known as ears, and we will all be capable of being affected by HS2 noise.

A summary is given below of why the way that HS2 Ltd has treated noise nuisance so far is unsatisfactory, particularly in its presentation of information in support of the recent public consultation.  Links are provided to blogs on the HS2 and the environment and Stop HS2 websites, which provide more detail on each particular topic. You can download this summary here as a pdf document.

The information that has been provided is inadequate:

The information that has been provided is misleading:

  • Despite designing HS2 to support speeds up to 400 kph, the calculation of noise levels assumes a maximum operating speed of 360kph. This assumption allows lower noise nuisance figures to be produced. Its adoption has been justified on the basis of very loosely specified undertakings not to increase operational speeds above 360 kph, if to do will increase noise impacts
    ( http://hs2andtheenvironment.wordpress.com/2011/11/13/a-promising-future ).
  • HS2 Ltd in its noise nuisance calculations has assumed that future technical improvements in locomotive and rolling stock design will reduce noise levels, but has failed to provide any assessment of the technical risk involved in this assumption
    (http://hs2andtheenvironment.wordpress.com/2011/11/25/perhaps-you-were-right-all-along).
  • HS2 Ltd has assumed in its noise nuisance calculations that the track will be maintained to “reference” quality, rather than making an allowance for the increased noise from train bogies that will be inevitable as track quality degrades during normal use
    (http://hs2andtheenvironment.wordpress.com/2011/10/24/it-could-be-a-bumpy-ride).
  • HS2 Ltd is relying on a single parameter, the equivalent continuous noise level over an eighteen-hour day (LAeq, 18hr), to assess the noise nuisance impact. The WHO advises that where “there are distinct events to the noise such as with aircraft or railway noise” measures of those individual events should also be used. The failure of HS2 Ltd to follow WHO advice means that the noise impacts have been underestimated
    (http://hs2andtheenvironment.wordpress.com/2011/06/22/taking-a-longer-term-view).
  • HS2 Ltd has not employed the day-evening-night equivalent continuous noise level parameter(Lden), which is preferred by Article 5 of the EU Environmental Noise Directive. This parameter is favoured because it takes account of the increased impact of noise during the evening and night periods. HS2 Ltd has provided no rationale for ignoring this parameter, which is being employed, in the same or similar form, for other high speed rail projects (e.g. California).
  • HS2 Ltd has applied “A-weighted” correction to noise power levels in order to reflect the sensitivity characteristic of the human ear. Whilst the use of this particular characteristic is widespread, some authorities, including the WHO, have questioned its suitability for use with loud noise sources with an appreciable low-frequency component, such as high speed trains; these reservations have not been addressed by HS2 Ltd
    (http://hs2andtheenvironment.wordpress.com/2011/06/26/a-weighty-matter).
  • HS2 Ltd has employed the Calculation of Railway Noise 1995 (CRN) modelling methodology to predict the levels of noise nuisance, whilst admitting that this model “would need to be adapted” for very high speed rail. The way in which this model has been utilised has restricted the representation of the noise source to a single height of one metre above the track, whereas it is generally considered that multiple source heights are required to adequately model noise from very high speed trains. HS2 Ltd has, apparently, failed to recognise that the use of the CRN in this way carries a significant risk that noise impacts have been underestimated. The decision to use the CRN has been made despite more suitable models having been developed elsewhere, e.g. in Germany.
    (http://hs2andtheenvironment.wordpress.com/2011/12/15/doing-things-by-the-book)
  • Whilst HS2 Ltd admits that the additional impact that HS2 noise will have on previously tranquil areas requires special consideration, no indication has been given of how this will be addressed and this factor has not been taken into account in any meaningful way in the assessment of the number of dwellings that will be adversely affected
    (http://hs2andtheenvironment.wordpress.com/2011/10/12/it-used-to-be-really-quiet-round-here ).
  • The estimations of the number of dwellings that fall into the three noise categories (red, yellow and grey) can be shown to be very sensitive to small changes in the assumptions made about noise levels. Any understatement of noise levels, such as would result from some of the issues that have been identified herein, will lead to a significant underestimation of the number of dwellings affected
    (http://hs2andtheenvironment.wordpress.com/2011/10/12/it-used-to-be-really-quiet-round-here).
  • The evidence from the noise simulations presented at the roadshows last summer is that HS2 Ltd is assuming that noise mitigation, using trackside noise-absorbent barriers or equivalent, will produce a very significant reduction in noise, of up to four times loudness as heard by the ear. No justification of this optimism has been provided
    (http://hs2andtheenvironment.wordpress.com/2011/07/12/have-you-heard and http://hs2andtheenvironment.wordpress.com/2011/11/09/going-over-the-top).

The proposals to mitigate the noise problem are inadequate:

  • No external constraints apply to require HS2 Ltd to limit noise nuisance levels. This means that any measures taken to reduce noise levels will be solely at the discretion of HS2 Ltd and that it is likely that many dwellings will be subjected to unmitigated noise
    (http://stophs2.org/news/3543-shinkansen-sound).
  • It is doubtful whether the three metre high trackside barriers (two metres on viaducts) will sufficiently screen the noise sources from a train travelling at 300 kph plus speeds. HS2 Ltd admits that barriers “are not likely to be as effective or feasible, due to the required increase in barrier height, to provide shielding for the entire train”, and is relying on “advanced rolling stock design” to solve this problem; however HS2 Ltd has made no assessment of the technical risk associated with this assumption
    (http://hs2andtheenvironment.wordpress.com/2011/11/09/going-over-the-top).

It is clearly unsatisfactory that HS2 Ltd, which has a vested interest in understating the HS2 noise nuisance, should be able to develop its own guidelines for estimating noise impacts. The HS2 noise and vibration working group set up by HS2 to peer review methodology clearly lacks the independence required to discharge such a role effectively. There is an urgent need for an independently produced and reviewed UK standard for assessing the impacts of noise from very high speed trains, to which HS2 Ltd should be required to adhere
(http://hs2andtheenvironment.wordpress.com/2011/12/15/doing-things-by-the-book).

HS2 Ltd has promised on a number of occasions to host a technical seminar on noise for action group members and other interested parties; this would at least allow the issues to be raised and HS2 Ltd to defend its position. However, despite the promises, the event has yet to be organised. In view of the controversy surrounding the noise methodology employed for the Appraisal of Sustainability, it is essential that a noise technical seminar is hosted by HS2 Ltd early in the New Year.

For those wishing to get to grips with some of the basic technical concepts involved in these discussions about noise, a series of tutorial blogs has been posted. Subjects covered are:

Logarithms
The decibel
The dBA unit
Measuring a train pass-by
Calculating sound exposure level
Calculating the equivalent continuous noise level

 

This article on noise was written by Peter Delow, BSc(Eng), ACGI, CEng, MIET.

For more blogs on the environmental impact of HS2 go to hs2andthe envirnoment.wordpress.com

________________________________________________________

Earlier information about noise

How much noise will HS2 make? As yet DfT has not published the information. But according to "The High Speed Revolution" (click here for link) - a paper published by DfT on its web site - quite a lot!  Terry Gourvish (the author) states:

"............Current thinking is that the noise from high-speed trains is acceptable at speeds of up
to 300kph, especially where there is a separation from the infrastructure of at least 150 metres,
but that higher speeds produce more intrusive noise levels as a result of aerodynamic effects.115
As environmental concerns have grown, construction costs have risen to mitigate environmental
damage, via noise barriers, cuttings and tunnelling."

HS2 is planned to operate at 400kph.

The information that HS2 has released on 28 May, in response to a FOI request concerning the basis of the 'Non Technical Summary of the Appraisal of Sustainability', concerns noise generated by trains travelling at 350kph. It states that the pass-by noise at 25m from the centreline is 95dB Laeq. The average daytime noise level is 81 dB(A), allowing for the silences in between trains. No information is provided for 400kph. See useful links page.

The first real demonstration of the noise was made at the Rally hosted by HS2AA in the Chilterns at Great Missenden on 7 November 2010.  Thousands attended and heard the sound, but it had to be turned down for health and safety reasons.  See report of the rally here 

 

Environmental landscape

The Natural Environment Team at Bucks County Council have done a Baseline Environmental Assessment of each of the 3 routes, using a 1km corridor either side of the route. 

 It shows 40 different types of asset from geological sites to ancient woodland. Click here to read about what they have done and have planned, and here to see the results for Route 3 (the preferred route); results for Route 2.5 (Hughendon Valley); and results for Route 4 (WCML).  Each set of results has a useful comparative table of the landscape features affected by the 3 different routes.  All this of course just covers Bucks. Other councils are being approached to see if they can do the same study. 

 

 

A Case For High Speed Rail No Longer Exists

DfT’s previous failure to notice the world has changed invalidates their entire case for High Speed 2, as speed is no longer king.  Their own small print concedes the principle without realising the catastrophic consequences for their case. 

 

Time on board trains isn’t wasted – it’s official

The Government has had to accept that people work on trains[1] and so their time is not wasted ie its used productively already (never mind by 2026). 

The case for HS2 depends on journey time savings – the high value of time savings is the corner stone of the business case that justifies a Government subsidy (representing about half the £44bn benefits). The argument runs that a 30 minute journey time saving means people get there 30 mins quicker and the business gains 30 mins extra productivity.  But this depends on the journey time being wasted now.  So if it’s not wasted that affects the sums.

 

Must make consequential changes

DfT have defended their position (of not re-doing their sums) by saying[2] this fact ‘cannot be taken in isolation’ and ‘may affect the approach to the valuation of other impacts’. 

They are right.  But then neglect to revisit the sums for high speed itself.

Government say they would need to re-value crowding and modal shift benefits and these would offset lower time saving benefits. Not only is the opposite true, but they must re-visit something much more fundamental – how fast to go.

 

First, crowding. 

It is true you can’t work productively on a very crowded train.  So what happens when you re-value crowding?  This depends on whether HS2 delivers more or less crowding than the alternative.  Given HS2 is more crowded than realistic alternatives, crowding doesn’t help the case for HS2.  There are 3 reasons why:

  • The industry would address crowding before HS2 starts in 2026 through incremental and short lead time options that prevent crowding becoming acute

  • Even DfT’s own alternative to HS2 (Rail Package 2 for WCML) has less crowding than HS2 ie a 51% loading factor compared to 58% for HS2

  • HS2 has no provision on the classic compatible part of the network for the extra passengers it induces – so these parts become more and not less crowded.

 

Second, modal shift. 

DfT say this accounts for 13% of HS2 passengers.  The 6% from air will soon be as productive as rail travellers as the same technologies are in the process of becoming available during flights.  This just leaves the 7% from cars.  But even this much modal shift depends on DfT’s inflated view of time savings.

 

Third, very high speed. 

DfT fail to re-examine this. The fundamental justification for very high speed and the route implications that flow from it (ie cannot follow existing transport corridors), depend on journey time savings outweighing other factors[3].  Government compare the costs and benefits of a new conventional railway with a high speed railway (where clearly crowding is not an issue). So DfT no longer have a basis for asserting that the journey time savings justify the extra capital, operating and environmental costs of a high speed railway.

 

By recognizing their view of time savings is now out of date DfT have taken the crucial first step in a process that inexorably unravels their case for HS2. 

 

[1]Economic case for HS2’ p 7.3.2 ‘  rail passengers are increasingly spending at least some of their time productively.’

[2]Op cit para 7.3.3   ‘.. such an observation may be true, but cannot be taken in isolation.  ‘ 

[3]Op cit para 6.1.6  for costs.   They also accept high speed rail has worse local impacts and carbon effects

 

 

Bucks HS2 Summit on Environment (15 October)

The film of the summit at which MPs Dominic Grieve and speaker, John Bercow, Sir Brian Briscoe (HS2 Ltd Chairman) and Phil Graham (Deputy Director HSR, DfT) attended, where we all witnessed the 'sounds of shifting goalposts' is now available on Bucks TV.  Also see Bucks County Council website for further information.


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