Today we’ve responded formally to the HS2 Phase 2b Working Draft Environmental Statement (WDES) consultation. The consultation marked a key stage for those impacted by Phase 2b, as it was the first time HS2 Ltd published detailed plans for the construction and operation of the railway. The consultation also included some details of HS2’s impact assessments on topics such as landscape, transport and agriculture though at this stage there is still a lot of data missing. Here’s more on our response from the HS2 Project Team.
At 161 pages it’s our longest ever response to a consultation. After scrutinising the proposals in detail we continue to be very concerned about the impact of HS2 on special places, including those which we look after on behalf of the nation. We believe that there is more which HS2 Ltd need to do to address the impacts of the scheme and to deliver improvements for people, places and nature.
There are four National Trust places which we expected to be negatively affected by Phase 2b: Hardwick (Derbyshire), Nostell (near Wakefield), Dunham Massey and Tatton Park (both on the Cheshire border at south-west Manchester). A summary of our response to the consultation can be found below.
Whilst the National Trust welcomes HS2 Ltd’s Environmental Policy, Landscape Design Approach and the Green Corridor Strategy we are seriously concerned that the commitments made in these policies have not adequately followed through to the proposals in the WDES.
The Trust maintains that there may be opportunities for HS2 to go beyond direct mitigation and provide enhancements for heritage assets or improved public access. We also believe that HS2 should adopt a policy of biodiversity net gain.
It is a major limitation of this consultation that details of vertical alignment and visualisations have not been made available in order for the public to properly understand the impact of HS2.
Hardwick is one of England’s most instantly recognisable country houses. The setting for Hardwick includes the greater landscape flowing away from it, through which local people see the house and visitors get their first glimpse of the property. National Trust’s work at Hardwick starts, as it does everywhere, with our founding cause; to look after our Nation’s most precious places forever, for everyone.
The National Trust is therefore deeply concerned and disappointed by the proposals in the WDES for Hardwick. They in no way reflect the serious concerns that we have expressed to HS2 Ltd over a number of years nor the mitigation proposals we have developed and sent to HS2 Ltd.
The National Trust objects to several specific design features including:
- The Hardstoft North Cutting
- The realignment of Hawking Lane and the closure of Mill Lane
- The location of the Great Pond Autotransformer Station and the design of the balancing pond northwest of the Astwith cutting
- Significant loss of connectivity between the Park and its historic villages
Our mitigation proposals address these issues in detail. For example, our proposals include earth bunds and tree planting between HS2 and the M1 to mitigate noise and visual impacts of HS2; an underbridge for Hawking Lane below HS2 to maintain one-way visitor traffic flow and maintain local access; and a green bridge over both HS2 and the M1 as an alternative to diverting Mill Lane which would also improve connectivity for people and wildlife.
We consider that the historic environment assessment in the WDES grossly underplays the impact of HS2 on Hardwick Hall, Old Hall and Registered Historic Park and Garden. We also believe that there will be long term major landscape and visual impacts in and around Hardwick.
There will be major disruption for visitors to Hardwick and for the local community due to the major works to M1 J29 and to local roads.
Nostell was created to impress and delight and continues to provide an oasis of rural retreat for its surrounding populations. Nostell’s popularity is growing and it is an important amenity for local communities. We are concerned about how HS2 will impact Nostell.
We have developed mitigation proposals to address the impacts of HS2 on Nostell however these are not yet fully reflected in the WDES design. Our proposals seek to enhance landscape quality and ecological value of the area between Nostell and New Crofton. Our proposals also include new areas of community accessible countryside and a green buffer between the railway and communities.
We have serious concerns about the visual impacts of HS2 on Nostell and are disappointed that no viewpoints appear to have been assessed within Nostell.
There is no recognition that Nostell is a major regional visitor attraction and an important recreational space. The construction impacts of the proposed scheme have the potential to significantly disrupt visitor access and worsen visitor experience.
Currently no noise mitigation is proposed for the Nostell Viaduct. We consider measures will be necessary to reduce the impact of noise on staff, volunteers and visitors to Nostell.
We cannot agree with HS2’s conclusion that none of the listed buildings within Nostell would be affected by the construction of HS2.
We are concerned that the WDES has not reflected the full context and significance of the Dunham Massey Estate. Dunham Massey is more than just the Mansion and the Registered Park and Gardens. It is a large historic estate which includes 14 working farms, a network of paths the River Bollin and the Bridgewater Canal. Dunham Massey plays a central role as one of Greater Manchester’s principal cultural heritage assets, and provides areas of recreational space and ecological habitat.
We consider that the landscape and visual impacts of HS2 on Dunham Massey have worsened due to the significant increase in height of HS2 in this area. The National Trust wishes to work with HS2 Ltd to explore opportunities to mitigate these impacts.
A farm within the south west of the estate will suffer major significant effects. The farm will be seriously disrupted by the closure and diversion of local roads and the residential properties associated with this farm will be totally exposed to HS2. We do not consider these impacts to be mitigated in the WDES.
Woodland habitat creation is proposed on National Trust land between the Bridgewater Canal and A56. We would like to discuss this proposal with HS2 Ltd further including species type and maintenance arrangements.
There will be notable impact for those accessing the Dunham Massey estate and its surrounding communities due to the severance and/or diversion of local roads including A56 Lymm Road.
Whilst we welcome that some noise mitigation measures have been proposed in the area it is our position that further measures are required with particular attention to the areas of Woolstencroft Farm, the Bridgewater Canal / Cheshire Ring Walk and Trans Pennine Trail.
The River Bollin, which is crossed by HS2 just outside the Estate, is part of the National Trust and Environment Agency’s Riverlands Programme. It is our hope therefore that HS2 could make a positive contribution to this programme and in doing so offset some of the considerable environmental harm of the scheme.
Tatton Park is one of the most complete historic estates open to visitors and one of the most popular attractions in the North West. Today Tatton Park is financed and managed on the Trust’s behalf by Cheshire East Council.
HS2 will contribute to the fragmentation of Tatton Park and Dunham Massey from each other. These two places together provide a substantial area of recreation space for Greater Manchester and we wish to work with HS2 Ltd to enhance their other linkage and accessibility.
The National Trust and Cheshire East Council believe that the construction phase of HS2 will have serious implications on Tatton Park’s ability to host special major events throughout the year. These events provide vital income to maintain the care and conservation of Tatton. Proposals such as the closure of Ashley Road and the use of Cherry Tree Lane as a construction route will directly impact the ability for people to access Tatton and could have major impacts on the wider transport network.
We request substantiation of the conclusion that there will be no significant visual effects on the Park. We are concerned that the Ashley Embankment may be visible.
The National Trust is committed to playing our part to ensure that HS2 leaves a positive environmental legacy. As designs develop over the course of 2019, we will continue to engage with HS2 Ltd in a challenging but solution focused manner. We will continue to work collaboratively with other stakeholders impacted by Phase 2b including other charities, local authorities and those who live in, work and visit our places. Where possible we will seek to build consensus with others about mitigation proposals and encourage HS2 to incorporate these into designs in advance of the formal Environmental Statement.