As Greening ordered to explain growing HS2 consultation errors in court, HS2 chief says methodology was inadequate

Published 30th July 2012

An article by Joe Rukin

With the date of the five Judicial Reviews into HS2 now set to start on 3rd December, Transport Secretary Justine Greening has been ordered to explain errors in the consultation, which continue to grow. The official consultation omitted responses from three of the four parties bringing cases; HS2 Action Alliance, Cherwell District Council (a member of 51m), and Heathrow Hub, which Greening will be asked to explain in court.

Last week HS2 Ltd issued a report addendum to the consultation, which aimed to cover the 413 responses which went missing, but since then the errors have continued to mount, with action groups representing Hints in Staffordshire and Little Missenden in Buckinghamshire still finding their submissions to be ‘missing in action’. In addition, the response from Staffordshire MP Chris Pincher has been ‘miscategorised’.

Scoring a rather big own goal in a desperate attempt to divert attention from continual failures of her organisation, HS2 Ltd Chief executive Alison Munro telling the Financial Times:

“If you’re talking about a little roundabout scheme you can get very high benefit/cost ratio ... The methodology isn’t really designed for the big, transformative projects.”

This is despite the fact that one of the first uses of cost benefit analysis (CBA) was the evaluation of a “big, transformative project” — London’s Victoria Line — against alternatives. It should also be noted that whilst HS2 is meant to ‘heal the north south divide’ according to proponents, since the arrival of the Victoria line, the number of jobs in Haringey has dropped, in favour of central London.

Stop HS2 Campaign Coordinator Joe Rukin, who was one of the 413 consultation respondents to have been missed in the initial analysis said:

“After having read the so-called analysis of the missing 413 consultation responses, I quickly realised that I have been ignored twice. First because my response was ignored originally and now because they clearly didn’t analyse my response. HS2 Ltd produced a table of different comments people made. I first spotted that they say no-one mentioned reopening old lines in question two when I had done, but it then got a lot worse. In my very first paragraph I said: " it is evident that ‘more local trains due to the capacity released via HS2’ must mean a cut in current inter-city services to cities such as; Coventry, Leicester, Loughborough, Sandwell and Dudley, Wolverhampton, Nottingham, Derby, Sheffield, Shrewsbury, Wrexham, Stoke on Trent, Chesterfield, Peterborough, Wellingborough, Kettering, Corby, Market Harborough, Doncaster and Wakefield." This meant that all of those 'locations' should have been logged in the analysis, but the only ones which were were Coventry & Stoke on Trent. I very much doubt that I was the only one who they didn’t analyse as the City Councils for Nottingham, Doncaster and Leeds (and their chamber of commerce) were also in the 413 missing responses and the analysis suggests that not one of them mentioned the name of their city in their response at all, which I find very difficult to believe.”

“The comments from Alison Munro are absolutely unbelievable. When HS2 started out, she was one of the people extolling the business case which was propped up by flawed methodology. Now the business case has completely fallen apart, she is more or less admitting they have had it wrong from the start. At least on that point we can agree. The other things she is totally missing with the benefit analysis is that since the announcement of electrification of the Midland Mainline, which will benefit Nottingham, Sheffield and Derby much more than HS2, the case has got worse and will have to be recalculated, as the baseline has moved.”

Penny Gaines, chair of Stop HS2 said: "For the last two years, we've been saying that relying on a benefit cost ratio which ignores modern working practises is the wrong way of evaluating the HS2 proposal. Alison Munro, the head of HS2 Ltd, appears to have suddenly decided to agreeing with us by saying in the Financial Times, a respected national newspaper, that the benefit cost ratio is the wrong methodology to use when looking at a project like this.

If she'd got away from a methodology which relies for half the claimed benefits of HS2 on relatively small time savings two years ago, then many of the negative effects of HS2 on the environment could have been avoided. The need for speed that the methodology that HS2 Ltd have been using means that the tracks have to plough through environmentally sensitive areas like ancient woodland and SSSIs, rather than going round them. It also means that HS2 Ltd prematurely rejected stations between London and Birmingham, whereas they had the chance to design in an interchange station on the east-west route between Oxford and Bedford."


a. Inadequate consultation

i. There has been a failure to consult with people north of Birmingham who therefore do not know if they will be impacted by the HS2 route;

ii. There has been a failure to consult on the Optimised Alternative which was offered to the Government by 51m;

iii. There has been a failure to consult on the changes to the route which were announced for the first time on 10 January 2012. For many people, the announcement in January was the first time they became aware that they would be affected.

b. The impact of building and operating the HS2 rail link on the Underground capacity at Euston has not been fully considered.

c. The decision to proceed with the HS2 rail link was made with inadequate environmental information. The Strategic Environment Assessment which the Government is required to carry out before reaching a decision has not been undertaken. The decision is also in breach of the Habitats Directive which is one of the EU's two directives in relation to wildlife and nature conservation, and aims to protect some 220 habitats and approximately 1,000 species listed in the directive's Annexes.

d. The Hybrid Bill process is not compatible with the Environmental Impact Assessment Directive which states that the public should be given the opportunity to participate in the environmental decision-making process before a decision on development is made. This has not happened.


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