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Our Response to the HS2 Environmental Statement

A GARGANTUAN TASK The HS2 Environmental Statement published late in November 2013, ran to more than 30,000 pages. Despite this, the period allowed by the government for responses to this mass of detailed proposals within a ‘public consultation’ was a mere eight weeks. As a representative of Bucks County Council told the Guardian newspaper, to tackle this within the time limit would mean reading, understanding and composing a reponse at a rate of more than 500 pages per day!

Fortunately not all 30,000 pages applied to the historic environment in Buckinghamshire, whiuch was our concern.

Nonetheless, the Environmental Statement was a critical document because it set out those elements of the environment that were recognised by HS2 Limited as of value, set a value on them – high or low, and estimated the impact that HS2 and its construction would have. Its engineering plans indicated how these assets would be affected by the line's construction.

Responding to this was therefore also critical, otherwise errors and misjudgments would go uncorrected and become fixed in the HS2 engineering plans.

This task faced the society's HS2 project team at the start of 2014.

• A draft had been issued in Spring 2013 – see the society's
  Response to the HS2 Draft Environment Impact Assessment.

SERIOUS OMISSIONS AND NO SPECIFIC COMMITMENTS

As well as the potentially disastrous mismatch in the HS2 Environmental Statement between the company's archaeological report on Doddershall deserted medieval village site and its engineering plans (see HS2 ploughs on: Now Doddershall deserted village faces destruction), the society's Response identified other serious omissions:

• The lack of aerial photographs.
• The failure to hold any public consultation events. Indeed the HS2 Community Forums had been suspended before the Environmental Statement (ES) was published, leaving ‘no opportunity for public engagement with HS2’.
• The limited archaeological survey work done in relation to the wide extent of ground disturbance by construction sites, road diversions and so on.
• The failure to use data from the Bucks Historic Environment Record, all supplied to HS2 by Bucks County Council.
• The omission of Pleistocene deposits (prehistoric animal and human remains) from the survey, though these are known at several places along the planned rail line.

Click here to read the full text of the Society's Response.

The 400,000-word Statement (ES) was published by HS2 Limited before Christmas 2013. The deadline for responses was 27 February.

Fortunately not all 400,000 words were on heritage issues. The ES also covered effects on wildlife and the natural environment, noise and visual intrusion, and other issues. But, with heritage information spread across 28 volumes with 35 appendices and various Map Books, just tracking down the predicted effects of HS2 on individual sites, buildings and monuments was a gargantuan task.

Hopefully these contributions will persuade HS2 Limited of the need to minimise the impact of construction `on historic assets along the line. In some cases rescue excavation will be the ‘best’ option before destruction. Grim's Ditch and Stoke Mandeville church ruins are two examples.

NEEDED: PUBLIC ACCESS TO EXCAVATIONS, FINDS AND RESULTS

So far HS2 have made no provision for the storage and curation of archaeological finds that will be recovered during construction. This was a significant omission with HS1, the high-speed line across Kent to the Channel Tunnel. The society is pressing hard for well-defined HS2 budgeted provision for:

• Organised local community involvement during archaeological investigations,
• A coherent strategy of both popular and academic publication of results,
• New museum provision for storage, curation and public display of the huge quantity of finds,
• In conjunction with the local community, a Stoke Mandeville Legacy Garden for the estimated 2,600 burials that will have to be moved from the ruined St Mary's churchyard.

The society's response has also been widely circulated, including to all Bucks Members of Parliament, County Council members and officers.

To see present and future activities
by the society's members in relation to HS2, click HS2: What we're doing now.

To see the results of work already done
– surveys, reports, letters, consultations and responses – click on any of the links at the top of the page.