This week we submitted our response to the High Speed Two Phase 2A Environmental Impact Assessment (EIA) and Scope and Methodology Report (SMR).
The report sets out the proposed method for working out the likely environmental impacts of Phase 2A of the project which is due to run from Birmingham to Crewe passing close to special places in our care in Staffordshire including Shugborough Hall, Great Haywood Banks and Downs Banks.
This report is important because the way HS2 Ltd assesses impacts of the scheme will inform what, where and who they consider to be impacted by the railway and so what mitigation will ultimately be provided such as changing the alignment of the railway or providing screening and noise barriers.
We are pleased to note that as a result of comments we and many others made to the EIA methodology for HS2 Phase 1 back in 2012, improvements have been made to the way HS2 Ltd assess environmental impacts. However, there are a number of areas where additional information is required, or where we believe the methodology is incomplete or incorrect:
Cultural heritage – We are very concerned that the proposed 500m study corridor for cultural heritage is too narrow, visual impact analysis needs to be modified to consider broader parameters of view and viewer. We also strongly believe that all listed buildings and registered parks and gardens have national significance and thus we consider that they should be shown as having high significance.
Ecology – The proposed habitat surveys have some significant omissions, such as the consideration of veteran trees, Brown Hare and deer. Habitat connectivity mapping and modelling, using the method recommended by the HS2 Ecology Technical Group, should be incorporated into the EIA and we would like to see a programme of proactive monitoring of the significant residual impacts of the scheme.
Future of Shugborough – Planned works on the park at Shugborough may render the baseline surveys already undertaken to be unreliable, similarly the works are likely to change the recreational value of Shugborough Park. We would welcome further discussion with HS2 about the impact of planned changes in the management of Shugborough on its socio-economic values.
Noise and traffic – We are concerned that the potential impacts of traffic disruption due to construction are not fully considered and that the noise assessment methodology does not take account of the impact on Shugborough due to its distance from HS2.
We hope that HS2 Ltd take our comments on board for the full environmental impact assessment for Phase 2A. In the interim we will continue to engage with HS2 Ltd, and government, in order to deliver the best possible mitigation and design for the impacts of both the train line and its associated construction in the vicinity of our places.