INGESTRE & TIXALL
PARISH COUNCIL
HS2 Information

Ingestre with Tixall PC response to Environmental Impact Report Sept.2017




Report of informal meeeting with HS2 representatives


Environmental Impact Report


Ministerial Reply 4.7.17


Letter to Minister and Hydrogeological Assessment

HS2: Notes on costs and benefits from seeking a route change


Environmental Impact Assessment Report


Equality Impact Assessment Report


Property Consultation


HS2 Phase 2a: West Midlands to Crewe

Environmental Statement

Response by Ingestre with Tixall Parish Council 29.9.2017


Introduction:

Tixall and Ingestre are rural parishes, set in tranquil estate parkland, located approximately 5km east of the town of Stafford.  We have a combined resident population of approximately 400.

 

The parishes are directly affected by the proposals for HS2 Phase 2a (West Midlands to Crewe), which is the subject of this consultation.

 

The Parish Council is opposed to the current preferred route of HS2 but wants to make sure that, should it proceed, the impacts of construction and operation of HS2 are minimised and that residents who are adversely affected are properly and fairly compensated. 

 

The comments that follow relate to the draft Environmental Impact Assessment Report (EIA) for Phase 2a (West Midland to Crewe) published on 17th July 2017.

 

The parishes of Ingestre and Tixall are located within Community Area 2 (CA2): Colwich to Yarlet. The substantive body of comments below is specific to CA2. 

 

We are only commenting on sections of the EIA where we feel we are able to offer an informed opinion. The absence of a comment on any particular part of the document should not be taken as an indication of agreement with the contents, in whole or in part. 

 

It has been agreed that the road between Mill Lane at Hoo Mill crossroads and Tixall Village should be called Tixall Rd and not Gt Haywood Rd. Tixall Rd then continues to Blackheath Lane             See pp84 and 88 in E113 Landscape and visual assessment and photomontages (LV-001-002) ES 3.5.2.2.11  and E12 Vol.4  Map Book . Off-route effects ES 3.4.2 (A3)  Drawing CT-28-105 Environmental Baseline including Heritage Assets.

 

   All references to Great Haywood Road have been changed to Tixall Road and all references to Brancote cutting changed to Hanyards, see below.

 

General:

a)  Ingestre with Tixall Parish Council has responded in detail to numerous previous consultations.  We are very concerned to find that most information provided to HS2 Ltd in previous communications has been overlooked or misrepresented in the subsequent documents including the current EIA, e.g. We have consistently said that the deep cutting should be called Hanyards Cutting and not Brancote Cutting. This error is no doubt due to HS2 using an incorrect Google Map which wrongly showed Brancote Farm at Upper Hanyards. Continuing to use Brancote Cutting will only lead to confusion if and when construction starts. 

b) HS2 Ltd has pursued a route alignment in our area that is more expensive to build, more environmentally damaging and which has greater impact on communities than available alternative alignments.  More favourable alignments have been set aside to the detriment of the tax-paying public and the country in general.  Comments below that are specific to the proposed route do not signify acceptance of the proposed route.  Our position remains that, should the project proceed, it should do so on the basis of a different alignment, generally following route HSM03 (south of Weston option) as described in the March 2012 HS2 Phase 2 Route Options Report.

c)  As per our response to the Phase 2 Route Consultation, should the alternative alignment per b) above, be rejected, then the negative impacts on our communities should be minimised, beyond that set out in the current proposals, by providing a twin-bored tunnel between Ingestre Park Golf Club and Hopton Lane. 

d)  Shortage of time precludes a detailed response to all points across all documents associated with this consultation (and those of the other consultation that is being run concurrently).  There are many areas of overlap, with the same issues being raised multiple times in different places.  Please take our responses to below as the definitive set and, where appropriate, ensure that these are rolled out for inclusion in the other associated documents.

e) We remain concerned that not all owner-occupiers have been contacted by HS2 and regularly updated.

f) Notwithstanding e), we have taken the following actions to inform our parishioners of the consultations and obtain their views:

  • Provided details in the monthly parish newsletter (delivered to all properties in Ingestre and Tixall) and displayed on the relevant parish notice boards;
  • Posted details on the parish website and invited on-line comments/feedback
  • Obtained additional copies of the CA2 report and map books, lodged these in the parish churches of Ingestre and Tixall and invited feedback of comments to the parish council.
  • Ensured that hard copies of the consultation documents were available for inspection during community events at the Village Hall in Tixall (a shared facility with Ingestre), as well as having councillors on hand for guidance and to receive comments.
  •  One-to-one discussions.

 

Question 1: Please let us know your comments on the Non-technical Summary (NTS).

p18 We welcome the inclusion of Green bridges in order to maintain habitat connectivity, and to enable the safe movement of animals, although a cut and cover tunnel would be even better.

 

p23  Road, public right of way, utility and watercourse diversions

We are concerned that "Where new roads, bridges and public rights of way are required to cross the route, they will, where reasonably practicable, be constructed in advance and offline to allow the existing route to continue in use until its replacement is ready to be brought into public use." It is essential that access to Ingestre via Hoo Mill crossroads is maintained 24/7 as it is the only public road access to the community. In the last 12 months there were 53 emergency calls to the ambulance service to Ingestre ST18 0RE, and this does not include Home Farm Court, 36 electors and Little Ingestre Barns, 19 electors, and not all residents are registered to vote.

   Site Haul routes

    "Where reasonably practicable, movement of construction material, construction machinery and/or construction workers between the construction compounds and worksites will be on designated temporary roads within the area of land required for construction (known as site haul routes), along the line of the route of the Proposed Scheme, or running parallel to it.

    Using site haul routes will reduce the need for construction vehicles to use the existing public highway network, thereby reducing traffic related impacts on the road network and local communities."

    We are concerned at the proposed use of Tixall road from Hoo Mill crossroads to Blackheath Lane for transfer of materials for HS2. Despite the proposed passing places and road widening between Hoo Mill crossroads and Tixall Village, this road is unsuitable for increased use by HGVs. In addition to the bus service, school buses and farm traffic, it is increasingly used by cyclists, especially by groups at weekends. Many sections of the road do not allow any overtaking due to bends and blind summits. This will lead to increased delays to HS2 and other traffic.

 

p 27 4.2 Construction management

    It is essential that HS2 Ltd and the nominated contractors engage with the Parish Council so that local residents, businesses and community facilities are kept fully informed in advance of any road or public right of way realignments, diversions or closures.

           

p30 It is noted that Core working hours will be from 08:00-18:00 on weekdays (excluding bank holidays) and from 08:00-13:00 on Saturdays.

 

p31 "Certain activities, such as earthworks, are season and weather dependent. Contractors may seek to extend the core working hours and/or days for such operations to take advantage of daylight hours and weather conditions, subject to the approval of the relevant local authority.

Certain other specific construction activities will require extended working hours for reasons of engineering practicability. Abnormal loads, or those requiring a police escort, may be delivered outside core working hours subject to the requirements and approval of the relevant authorities.

Guidance on site-specific variations to core working hours and/or additional hours likely to be required will be included within the local environmental management plans following consultation with the relevant local authority.

   To maximise productivity within the core working hours, the contractors will require a period of up to one hour before and up to one hour after core working hours for start-up and closedown of activities. Activities within these periods will include (but not be limited to) deliveries, movement to place of work, unloading, maintenance and general preparation works."

   It is essential that HS2 Ltd and the nominated contractors engage with the Parish Council so that local residents, businesses and community facilities are warned of any temporary changes to the working hours.

 

Other points mentioned in the Non-Technical Summary, eg. Transport and Noise, will be considered in the relevant sections below.

 

Question 2: Please let us know your comments on the documents that form Volume 1 Introduction and Methodology

pix Figure 1: Structure of the HS2 Phase 2a ES is a useful guide to the documentation, and p6, Figure 3 is helpful on the Hybrid Bill process, although no suggested dates are given.

 

p19 2.3 Releasing capacity and improving performance and reliability on the WCML. and p38 Section 4.3 Services and operating characteristics. It is still not clear how rail services from Stafford will alter when HS2 is operational. It has been suggested that there will be considerably fewer trains to London with marginally shorter journey times than at present. 

 

p25 3 Stakeholder engagement and consultation. We disagree that "Stakeholder engagement has been an integral and ongoing part of the process of designing and assessing the Proposed Scheme from its inception. It has enabled the general public, local authorities, statutory bodies and technical and specialist stakeholders to respond to, and inform." As we have already said, HS2 has consistently disregarded any responses from this Parish Council, and the consultations appear to have been a largely one way process.

 

p47 Permanent features of the proposed scheme will be considered in relation to our area in Volume 2 CA2. The outline descriptions of the permanent features of the Proposed Scheme (Section 5) and the overview of the way that construction will proceed (Section 6) is a useful and helpful introduction.

 

p69 6.3.15 - 17 Community Relations. It is essential that the nominated and its contractor are in regular contact with our Parish Council, so that we can keep our local electors informed of what is going on, any potential problems and give advance notice of any works. This can be done via our website and via our monthly Newsheet delivered to all local households.

 

p71 6.3.30 Management of construction traffic will be considered in relation to our area in Volume 2.

 

p89 6.13 Highways (roads) and public rights of way. It is essential that Access to Ingestre and Ingestre Pavilion is maintained 24/7. In the last 12 months there were 53 emergency calls to the ambulance service to Ingestre ST18 0RE, and this does not include Home Farm Court, 36 electors and Little Ingestre Barns, 19 electors, and not all residents are registered to vote.

 

p105 6.23 Site restoration and landscape treatment. We welcome the early installation of landscape mitigation, e.g. for the viaduct and Trent north embankment.

 

p107 6.26 Train control and telecommunications. We would like early notice of the siting of any radio masts so that the best locations can be chosen.

 

7 Environmental Impact Assessment and 8 Scope and methodology summary for environmental topics will be considered in relation to our area in Volume 2 CA2.

 

p163 9.6 Community

 9.6.2. We welcome the provisions to mitigate community effects during construction, including:

  • appointment of community relations personnel;
  • a community helpline to handle enquiries from the public;
  • sensitive layout of construction sites to reduce nuisance; and
  • maintenance of public roads, cycleways and PRoW around construction sites, where reasonably practicable, to avoid their deterioration due to construction traffic.

However, we understand that these provisions have not worked well in the past, eg for Phase 1.

 

p184 10.4 Route-wide alternatives It is very difficult to assess these in the absence of maps showing the proposed routes, e.g. the high cost alternative of new high speed alignment to Baldwins Gate and the low cost new conventional speed alignment.

 

p187 10.4.16. We note that: "..more recent work by HS2 Ltd with the Environment Agency and Natural England showed that effects on the Pasturefields SAC and SSSI could not be ruled out due to complex hydrological issues. This is because research suggested that there was a possibility that the salt marsh could be fed by brine flows located to the north of the site. There was therefore a risk that construction works associated with proposed routes to the north of Pasturefields SAC and SSSI could have interfered with groundwater flows that feed the salt marsh, which could have caused adverse effects on the site. This led HS2 Ltd to reject potential routes to the north of Pasturefields SAC and SSSI in advice to Government because of the high risk associated with ensuring compliance with the Habitats Directive214. HS2 Ltd, the Environment Agency and Natural England are in agreement with this approach."

   We believe that this assumption that the brine flows are located to the north of the site is incorrect, as shown in our Envireau Consultants Report of 2017 which was forwarded to HS2.

   From the moment that the Initial Preferred Route (IPR) for Phase 2 was announced in January 2013 it appeared to us that HS2 Ltd had made a fundamental misjudgement in deciding to divert the route alignment away from the lowest cost, lowest impact route up the Trent Valley (route HSM03, south of Weston option, per the March 2012 Route Options Report) to a more southerly alignment. 

   Commencing in June 2013 and on multiple occasions thereafter, information has been provided to HS2 Ltd presenting evidence-based arguments why the decision to divert the route was a bad one.  Our comprehensive response to the Phase 2 Route Consultation (21 pages and 6 appendices), in January 2014, contains a consolidated presentation of the arguments. 

   It is with great concern and frustration to find that this information has been ignored, that contra-indicated arguments have been fed into the route review process and, consequently, that the Secretary of State for Transport appears to have been misled into approving a section of the Phase 2a route without full benefit of the known evidence. 

   We believe that this is unacceptable – to an extent that it could be argued that HS2 Ltd has been professionally negligent.

 

   The decision to proceed with Route C was taken, regardless that, at the time, Route C had been shown to cost £154m more to construct than Route B and would have greater sustainability impacts.  No appraisal of the cost and sustainability benefits of Route B was made against the need for an Appropriate Assessment.

   Subsequent events, including a review of the HRA Screening report by the British Geological Survey (BGS), undermined HS2 Ltd's original presumptions by showing:

a) that the HRA Screening Report was too narrowly focused;

b) that there was insufficient base-line data to predict the potential impact of the proposed HS2 construction along any of the proposed routes;

c) that an alternative conceptual model for the hydrology of Pasturefields should be considered;

d) that Route C had been routed so that it passed directly through the middle of a previously unrecognised historical inland salt marsh whose brine springs remain active today (and could well be linked with those at Pasturefields); see 2.3 of Q3 below, for more details.

e) that, unrecognised by HS2 Ltd, Route C had been routed so that it passes through a region, near Marston, that is at risk of subsidence as a result of the historical pumping of brine near Stafford (see   10.3.41 of Q3 Part A, below, for more details).

NB 1: c) follows directly from a). This is because the HRA Screening Report considered only a near-surface brine feed to Pasturefields SAC, from the north-east, whereas BGS believe it was just as likely (if not more so) that the brine had a deep ground origin, brought to the surface locally by Artesian pressure from the underlying Sherwood sandstone aquifer.  The BGS suggested some additional work to evidence the likely source. None has been carried out.

NB 2: BGS noted that if the deep ground source for the brine was correct then depletion of the Sherwood sandstone aquifer could affect the brine flow at Pasturefields (also at Ingestre). 

   The case was put to HS2 Ltd that there was compelling evidence that the decision to use Route C was unsound and that an Appropriate Assessment of Pasturefields SAC was essential to determine if there would be any risk of an adverse impact arising from Route B.  It is to be noted that the HRA Screening Report states that Route B would be acceptable to Natural England as long as the necessary ground investigations were carried out and mitigation by design used, if required, to ensure that no significant risk to the SAC would occur.  HS2 Ltd has persistently declined to undertake this work even though, as we pointed out, this information was essential to inform the route selection process.

   Not only have the necessary ground investigations not been carried out but the contra-indicating facts outlined above have been ignored by HS2 Ltd in all on-going work.

The result is that the Proposed Scheme is:

i) more expensive and more damaging to communities and the environment than it should be;

ii) facing major engineering challenges as a result of being routed through a rare inland salt marsh about which HS2 Ltd has been forewarned but ignored;

iii) facing similar engineering challenges as a consequence of being routed through an area vulnerable to subsidence caused by historic brine pumping, about which HS2 Ltd has also been forewarned but ignored;

iv) has every probability of adversely affecting Pasturefields SAC, contrary to the stated objective behind the selection of Route C; i.e. we contend that the Proposed Scheme fails the HRA requirement that: “no reasonable scientific doubt remains as to the absence of [any significant adverse] effects” and therefore the conclusion of the HRA Screening Report is invalid. 

p190 Section 11 Local Alternatives. We note that alternatives between Gt Haywood and Yarlet were not adopted because none of the options delivered sufficient sustainability benefits to outweigh the additional anticipated costs.

 

Question 3: Please let us know your comments on Vol. 2: Community Area (CA) reports

   We will confine our response to our area, Volume 2: Community Area Report CA2: Colwich to Yarlet

 

   We continue to correct the use of Brancote for the deep Hanyards cutting, despite telling HS2 about this error on numerous occasions. We believe the error arose because HS2 used a Google Map which incorrectly showed Brancote Farm at Upper Hanyards, rather than the Ordnance Survey Map.

    The road between Mill Lane at Hoo Mill crossroads and Tixall Village should be called Tixall Rd and not Gt Haywood Rd. Tixall Rd then continues to Blackheath Lane           

 

Q3 Response: Part A: Volume 2: Community Area Report CA2: Colwich to Yarlet

p8   Notable community facilities

p9  2.1.14 Community Facilities in Ingestre lists: Ingestre Church and Hall, Little Ingestre Care Home, The Orangery, Ingestre Park Golf Club.

   We are pleased to see that Little Ingestre Care Home, Ingestre Orangery and Ingestre Park Golf Club  have been added as we suggested in our response to the draft EIA. However, as we previously suggested Ingestre Stables equestrian training and examination centre (which is a Riding for the Disabled registered and has a cafe) should also be added.

 

       Recreation, leisure and open space

p9  2.1.20  Mentions Ingestre Hall Residential Arts Centre and Ingestre Golf Club, but not Ingestre (Home Farm ) Community Open Space.

p11 (Committed development): We note that developments with planning permission or sites allocated in adopted development plans are not included in this draft EIA.  However, we believe that this should mean that completed developments are included. Housing developments known to us in the neighbouring community but not appearing on any of the maps of the Proposed Scheme are: 76 houses at Millers Croft, Main Rd Great Haywood; 9 houses at The Shires, Main Road, Great Haywood (adjacent to land required for construction) and 45 houses at Devereux Grange, Little Tixall Lane, Great Haywood (approximately 500m distant – 100m if taken from an altered road). There have also been large developments, 620 houses, on the Stafford side of the Tixall Road beyond the junction with Blackheath Lane which will contribute to significantly to traffic flows, e.g. on Blackheath Lane. Between them, they account for 6330 homes.

 

p11 Section 2.1.33 Changes to design since working draft EIA Report:

  We welcome the following changes to design since the working draft EIA Report:-

1.   Reduction in height of Gt Haywood viaduct from 16.5m to 15.4m above existing ground level in central section

2.   Introduction of Ingestre Green Overbridge to facilitate ecological connectivity between fragmented habitats. We urge HS2 to reconsider a cut & cover Tunnel which would be a much better solution with many additional benefits for local residents.

3.   Change to diversion route of high pressure gas pipeline north of Gt Haywood Viaduct

4.   Diversion of 10" diameter fuel pipeline east of Ingestre Underbridge

5.   Diversion of high pressure gas pipeline across route of proposed scheme, south of Brancote South Cutting and west of Ingestre Underbridge

 

2.2 Description of the Proposed Scheme 

See CT-06-213, CT-06-214 and CT-06-214L1  Vol 2 CA2 Map Book

p13 2.2.6  We do not understand how some sections of Brancote Hanyards North Cutting can be up to 3m above existing ground level, when the cutting is 4m deep.

p19      Refers to Trent North Embankment over the A51 ? should be South Embankment

   We note that the Noise Fence Barriers on the Gt Haywood viaduct are 3 and 4 m high in addition to the 15.4m height of the viaduct which is 16.5m long. We understand that the noise barriers in Holland are transparent, please can the use of similar barriers be investigated for HS2 as they would have a much better visual impact for both rail passengers and local residents.

See: www.boscoitalia.it/prodotti-infrastrutture/barriere-antirumore-stradali/barriere-fonoisolanti-con-pannelli-in-vetro/

 Example of
                        transparent sound barrier

p20  Section 2.2.19 This suggests that in addition to the North Trent Satellite compound by Hoo Mill Lane, there will be a further satellite compound at the Mill Lane auto-transformer station by Hoo Mill crossroads. This is not shown on the maps as a satellite station, CT-05-212. This needs clarification as two adjacent satellite compounds seems excessive.

 

p20    Mill Lane auto-transformer (ie Hoo Mill crossroads) to Hanyards Culvert

(Beyond Upper Hanyards Farm)

p20 -22 2.2.22 Key features of this 2.7km section:-

   We note that there will be a Noise Fence Barrier up to 4m high and ask that the use of a transparent barrier as in Holland be investigated.

p21  There will be a landscape bund 375m south of Ingestre Hall up to 3m high to provide visual screening for Ingestre residents. We wonder if this will be sufficiently high to hide the railway and note that a cut and cover tunnel would be a much better solution with many added benefits.

   We ask that the Diversion of HP Gas pipeline Route be clarified as it appears to go through corner of 4 Hoo Mill Lane, although the owner has not been contacted about this or when it will be done.

   Ingestre Green Overbridge at existing ground level and 14m above railway to provide ecological connectivity. This would not be required if a cut and cover tunnel was used.

   We welcome the Woodland HC south of the Overbridge, on either side of Trent North Embankment Map, and at Hoo Mill crossroads, CT-06-213; and the two ecological mitigation ponds as replacement habitat for reptiles and amphibians.

   We welcome the realignment of Tixall Bridleway by Upper Hanyards over the new Overbridge, and the diversion of Tixall Footpath to join the diverted Bridleway and Overbridge. This footpath is a dead end to Ingestre Wood Gateway but is also the only access to Ingestre Pavilion, Ingestre Wood and the mobile phone base station.

  Brancote Hanyards North Cutting 4m deep and 34m wide for a 60m section, would be better replaced by a cut and cover tunnel.

 

p22 2.2.23 we do not understand what the 4 Emergency Access Points: 2 east of Ingestre Underbridge and 2 east of Tixall Bridleway Overbridge entail. Do they have gates to the railtrack and approach tracks ?

 

p32 2.3  Construction of the Proposed Scheme

     The proposed route and all associated features between approximately Ch 206+000 and Ch 207+000 are constructed on the site of an historic salt marsh, see Fig 1, that is still being fed by active brine springs.  Substantial surface and underground workings exist in this area that have been built over the last 250 years in an attempt to make previously unproductive marshland suitable for agricultural use.  Natural salt dissolution under this area is not only producing an up-welling of saturated brine but also a volumetric loss of underlying ground amounting to many cubic metres per year. 

 

Current and historical
                  extent of saltmarsh

Fig 1: Current & Historical Extent of Ingestre/Tixall Salt Marsh

 

    It is difficult to locate potential springs, from E116 Water resources assessment (WR-002-002) which only shows springs at: G6, east of Tixall Farm; Potential spring, G5, Home Farm; Potential spring, F7,  Blackheath Covert. The map kindly forwarded by Mr Simon Dale-Lace - HS2 Hydrogeologist confirms that HS2 is not aware of any springs in the area around Lion Lodge Covert, despite this parish council  having  sent HS2,  the map above previously.

 

p33 2.3.5 During the construction phase, public roads and rights of way will remain open for public use wherever possible. Alternative routes will be constructed before any closure of existing, may require temporary alternatives.

    It is essential that access to Ingestre via Hoo Mill crossroads is maintained at all times, both for the health and welfare of local residents, e.g. access by emergency vehicles, and for local businesses in Ingestre.

 

p34 2.3.11 Advance Works:-

     We note that it is intended to carry out further detailed site investigations and surveys.  It is essential that additional investigations are carried out to show the exact nature of the salt spring drainage in the Lion Lodge Covert Area, both to ensure there is no detrimental effect on Pasturefields SAC and that there is no subsidence due to salt dissolution in the future.

 

p36 2.3.25 Construction traffic routes, site haul routes and transfer nodes. Wherever possible designated haul routes within the site, eg along HS2 route or parallel to it, will be used.

    The CT-06 series of maps (construction phase) marks the roads designated as construction traffic routes but do not show the proposed haul roads.  This is of particular interest to us because we wish to see construction traffic movements on Tixall Road minimised, while noting that Great Haywood Viaduct to the south and the deep Brancote Hanyards Cutting to the north pose particular challenges in respect of the routeing of any haul road along the line of the route.  We previously requested that HS2 Ltd engage with us regarding the details of their haul road proposals in our area and make sure that the haul roads are added to the construction maps of the formal EIA, but this has not happened. 

    We note that there will be no sand or gravel extraction in our area, and assume the material from Hanyards deep cuttings will be used for Trent North and South embankments, but would like to know what transport routes will be used.

    We are especially concerned at the proposed use of Tixall Road from Hoo Mill crossroads and the Trent North Satellite Compound, to Blackheath Lane.

   Despite the proposed passing places and road widening between Hoo Mill crossroads and Tixall Village described in E12 Vol 4 ES 3.4.2, this road is unsuitable for increased use by HGVs. In addition to the bus service and school buses.

    It is essential that the pavement between the entrance to Dairy Bridge and Tixall Mews, to opposite the Church Lychgate is retained. Many people park at the Village Hall and then walk across to Church.

   The road widening by Malcolm & Sheila Sindrey’s wood is shown as a temporary modification. Will any trees be lost and if so will they be replanted ? The Parish Council has also planted daffodills along the edge of the wood which will need replanting.

 

   Many sections of the road, especially between Tixall Obelisk and Tixall Heath Farm entrance,  do not allow any overtaking due to bends and blind summits. This will lead to increased delays to HS2 and other traffic.

  This road is completely unsuitable for HGVs.

 

p41 2.3.40 Temporary roundabout at Hoo Mill crossroads. A number of lane restrictions, overnight and weekend closures are proposed during construction.

    Overnight and weekend closures are unacceptable. With an increasingly aging population in Ingestre, 24/7 ambulance access is essential, as well as for other emergency vehicles and local residents and businesses. In the last 12 months there were 53 emergency calls to the ambulance service to Ingestre ST18 0RE, and this does not include Home Farm Court, 36 electors and Little Ingestre Barns, 19 electors, and not all residents are registered to vote.

 

     We are pleased to see that Hoo Mill Lane will remain open during construction of a permanent diversion, although this will take 6 months and will require lane closures and traffic management on Ingestre Rd.

 

p46 2.3.59 Brancote Hanyards S Cutting Satellite Compound

    This is scheduled to operate for 4 yrs 3 months, starting in 2021 with 25-35 civil engineering workers/day and 4 temporary material stock piles to S and N of compound.

     This will initially be accessed via Hanyards Lane then via a site haul route to the A518 Weston Rd. Hanyards Lane is very narrow with few passing places, but our greatest concern is the potential for accidents with HGVs turning out onto the Tixall Road to go up Blackheath Lane. Hanyards Lane is only 22.4m (kerb to kerb) from the junction with Blackheath Lane. Cars turning left from Blackheath Lane when the lights change do not expect to find a HGV across the road.

     E110 Health Assessment matrix (HE-001-002) ES 3.5.2.2.9 States "Increased risk of road traffic accidents associated with increased traffic flows. Risk is considered low as there are no locations where elevated baseline accident rates coincide with changes of greater than 30% in average daily traffic flows".

 However, in E14 Community Area Report Vol.2  CA2: Colwich to Yarlet (A3) ES 3.2.1.2 p311 Accidents and safety there is no mention of Hanyards Lane/Tixall Rd junction.

HS2: Significant effects relating to accidents and safety are identified if there is a cluster of nine (or more accidents) in a three year period. Accident data was provided by Staffordshire County Council. Although there is a greater than 30% increase in average daily traffic flows this does not trigger a significant effect, as there is no accident cluster identified for Hanyards Lane/Tixall Road junction.

     Unfortunately this is the usual situation of people having to be killed before any action is taken instead of avoiding the dangerous situation.

     We note that the Code of Construction Practice (CoCP) requires HS2 to develop a route-wide traffic management plan, which includes the requirement for the main works contractors to develop a local traffic management plan. The LTMP will provide detailed information on temporary traffic management measures and construction routes.

     We have suggested that a roundabout or filter lane could be introduced at this problem crossroads using the Dept. of Transport Bypass Fund.

 

P46 2.3.61 Demolish Upper Hanyards farm. It is important that a full archaeological survey is carried out of Hanyards Farm as we have records going back to 1305 and it was probably the location of the smaller manor at Tixall in Doomsday. There were strong links between the Manor of Hanyards and the Early Chapel at Ingestre, which was nearer to the Hanyards than the present church at Ingestre. In 1305, Hugh de Hanenyate acknowledged the manor of Haveneyate to be the right of Roger Toly, Chaplain of Ingestre. In 1323 Ralph de Haveneyate ie. Hanyards, Chaplain , is suing Richard de Coppenhale and Isabella his wife  for land at Hopton. Further court cases occur in 1479 and 1481, when Thomas Counter, Chaplain of Ingestre is occupying 1/3 part of the manor of  Hanyat.

 

p 46 2.3.64  Temporary diversion of Bridleway for 3 years. 1st round farm demolition and 2nd to connect with Footpath.

It is essential that vehicle access to Ingestre Pavilion for Landmark Trust visitors and maintenance, and to Ingestre Wood for commercial forestry operations, and the mobile phone base station is maintained.

 

p57-58 (No page numbers for table) Figure 6 Shows Construction Programme and approx time chart which is helpful.

 

p60 2.4 Operation of Proposed Scheme

2.4.2  We note that it is proposed to run up to 6 trains/hour in both directions increasing to 12 from 2033 when Phase 2 is operational. Mon to Sat 5am to 24mn; Sun 8am to 24mn using 200m single or 2 x 200m coupled trains travelling at 225mph.

   The West Coast mainline is used for freight all night, will HS2 be used for freight like HS1 and the West Coast mainline ?

   This will generate significant noise when people are trying to sleep, although no houses in Ingestre or Tixall qualify for sound mitigation, despite E19 Vol.2 Map Book SV-02-106: showing a possible major adverse affect at  Lion Lodges (2), Hoo Mill Lane & Hoo Mill(5) and Tixall Manor Farmhouse (1). And a possible moderate adverse affect at  Tixall Farmhouse,(3) and Tixall Court (12) and Lower Hanyards (2) SV-02-107.

 

p64 2.5.14 Route alignment at Ingestre Golf Club

   Four options were considered all south of Ingestre, changing the depth and width of the deep  cutting. and including a cut and cover tunnel.

  This option would allow the landscape to be reinstated above the tunnel and thereby reduce the setting impacts on the historic landscape and Ingestre Conservation Area, compared with Option 5.3, the chosen option. Noise impacts would be significantly reduced at Ingestre. The tunnel would largely pass beneath Ingestre Park Golf Club, reducing the land permanently required and the loss of land within the golf

Course. Impacts on agricultural land and holdings would therefore be reduced. We urge HS2 to reconsider this option.

  However, our position remains that, should the project proceed, it should do so on the basis of a different alignment, generally following route HSM03 as described in the March 2012 Route Options Report – then referenced as “Route B” in 4.3 of the Alternatives Report.

 

 3 Stakeholder engagement and consultation

p77 3.2.1 Summary of Engagement. Contrary to the claim in Table 7 no direct engagement with us took place until 17 October 2016.  This is more than one month after the draft proposals were published.  Further, as noted under point a) of “General” above, we are very concerned to find that much of the information provided to HS2 Ltd in previous consultation responses, and other communications, has been ignored or misrepresented in the EIA.  

3.2.9  Relevant themes and issues identified from the draft EIA Report:-

§  Ecological impacts incl. Pasturefields SAC and SSSI

§  Noise and visual impacts related to height of scheme, especially viaduct

§  Impacts on communities of Ingestre and Tixall

§  Use of local road network for construction traffic

§  Impacts on Ingestre Golf Club

   None of the identified themes and issues have been resolved in the current EIA.

 

3.3 Engagement and Consultation with Stakeholder Groups

      As already noted above, no direct engagement with us took place between the Phase 2a route announcement in November 2015 and the publication of the draft EIA in September 2016.  This and the fact that previous consultation responses appear to have been ignored means that the Proposed Scheme shows little evidence of having been “informed” by any input from us. 

     The draft consultation response in November 2016 was the first opportunity to contribute to the main themes for the Colwich to Yarlet area.

 

p80 3.3.5  We were pleased to see that Table summarising engagement with technical and specialist groups included the included Landmark Trust who run Ingestre Pavilion and Tixall Gatehouse.

 

p83 3.2.13 Communities

    We were pleased to see that Table 9 includes meetings with our Parish Council, Residents of Ingestre and representatives of Ingestre Residential Arts Centre and St Mary's Church.

 

P83 3.3.14 Directly affected individuals, landowners and businesses.

    We are concerned that no engagement appears to have been made with Little Ingestre Care Home, or the owners of Ingestre Wood and Lion Lodge Covert who live outside the area but run the woods as commercial forests. Similarly you have not acknowledged Ingestre Lodges, New Stables, Four Units of self-catering accommodation, or Acorn Services, Birch Hall Farm, Ingestre, Vintage tractor parts; Car and Motorbike repair business on Trent Drive.

 

p 85  4 Agriculture , Forestry and Soils

p86 4.3.2 (Geology and soil parent materials): An incomplete summary has been given. 

   While mention is made of the Stafford Halite to the north of Yarlet, no mention is made of the halite deposits of the western edge of the Needwood basin to the south.  These are the presumed source of the active brine springs that still emanate in the areas of Shirleywich, Pasturefields and the Lion Lodge Covert area of Ingestre/Tixall. Here, the salt of the Needwood basin has dissolved near outcrop and, consequently, the salt sequence is most likely represented by brecciated strata caused by the collapse and foundering of the sequence caused by the removal of the salt by dissolution. 

   There is no mention of the local faults.

 

p87 4.3.6 (Topography and drainage):  Again, an incomplete summary is given.  The complex drainage of the land to the south of Little Ingestre, including Lion Lodge covert and its surrounds needs special mention.  This is the site of an historic salt marsh.  See Fig 1 above.

p90 4.3.27 Land Use

4.3.28 Notes the woodland predominantly around Ingestre, including Lion Lodge Covert 16.9ha of deciduous woodland and Lamberts Coppice ~14.1 ha, but there is no mention of Ingestre Wood, 13.73ha (excluding 0.52ha view and the Pavilion grounds).

 

4.3.33 Number, type and size of holdings Table 10 pages 92 - 95

includes Tixall Lodge Estate; CA2/15* Land south of Hoo Mill Lane; CA/2/19 Hoo Mill Lane Farm; Ingestre Manor Farm;            CA/21 Land at Tixall Lane used for horse grazing; CA/22 Land S of Lion Lodge used for horse grazing; CA/23 Tixall Manor Farm; Lion Lodge Covert; Upper Hanyards Farm with 2 wind turbines and farm shoot - again no Ingestre Wood.

 

p95 4.4 Effects arising during construction

p96 4.4.1 We welcome the realignment of Tixall Bridleway Bridge to minimise use of agricultural land

 

p96 4.4.3 Location of some of the mitigation planting , eg. at Hoo Mill crossroads. 

   We are strongly opposed to joining Ingestre Wood to Lamberts Coppice as we wish to maintain the historic view across the deerpark, at this site known locally as Hell’s Gate.

 

p105 4.4.26   Permanent effects of construction

    It is not just land take that is involved but the usability of land that remains (whether untouched by construction or used temporarily and then restored).  While severance is addressed, there is no mention of, for example, the effects on ground moisture conditions arising from permanent alteration of the water table and/or surface drainage characteristics arising from the principal engineering works.  In particular, the creation of deep cuttings through sandstone aquifers, as in the vicinity of Upper Hanyards, has the potential to lower the water table to the detriment of the adjoining farmland and woodland. 

 

p106 4.4.30 Mentions Lion Lodge Covert but again not Ingestre Wood

 

4.5 Effects arising from operation

p112 4.5.2       Noise from moving trains  - dealt with elsewhere.

            We welcome the future control of Noxious weeds on operational land

 

5 Air Quality

p115 Environmental Baseline

p116 5.3.7 We are pleased to see that this now mentions Little Ingestre Care Home

5.3.8 Lists the Statutory designated sites including Pasturefields SAC and SSSI, and the Non designated sensitive sites including Lion Lodge Covert Local Wildlife site and Ingestre wood.

 

p119 5.4.12 Assessment of impacts and effects – Temporary effects: To the list of roads expected to see an increase in traffic flows during construction should be added Blackheath Lane. This is the means by which construction traffic will, access Tixall Road from the A518, Weston Road.  See also p302 14.3.6 below.

Missing from this section is assessment of emissions from fixed plant and vehicles on construction sites.

 

6     Community

      We wish to repeat our Formal Objection given previously in our response to the draft EI Consultation: Before addressing the specific points contained in the CA2 report we wish to formally object to the exclusion from the assessment, without reason or explanation, the very real issue of impacts on the community of generalised property blight.  The statement in our May 2016 consultation response to the draft EIA SMR was as follows:

“We note that community impacts are being assessed on predicted physical effects.  While important, the biggest single impact is that arising from generalised property blight caused by the proposals.  The degradation of assets that are not required for the construction or operation of the railway is not part of the assessment.  Furthermore, the magnitude, temporal and spatial extent of blight is driven by market perception rather than cold analysis of physical effects. The character of the community is threatened in a complex way depending on the nature of the blight, the Government's property compensation proposals and the personal circumstances of the individuals and families involved.  It is difficult to see how a meaningful assessment of impacts on community can be carried out without taking this economic dimension into account. “

The Government's response, given at paragraph 4.9.2 of the EIA SMR Consultation Summary Report, published on 13 Sept 2016 says:

" Consultees requested that the impact of the Proposed Scheme on property or asset values or implications of property blight be considered.

    Response:

Section 9.1 of the draft EIA SMR states that property will be considered as part of the assessment. This includes, for example a loss of housing stock or associated land (for example gardens) as a result of the Proposed Scheme. The community assessment excludes financial considerations, such as loss of property value arising from blight [emphasis added]."No changes have been made in the current EIA, to reflect this theme.

    The widespread impoverishment of communities (except, perhaps, those within roughly 5 miles – 8km – of an HS2 station) and the resultant change in character of the communities arising from the replacement of long-term residents by short term tenants living in properties purchased under the Government's discretionary compensation schemes is of much greater impact than that arising from the whole or partial loss of properties that are required for the construction and operation of the scheme.

    It is unacceptable to make a pretence of assessing community impacts while deliberately excluding the single most important contributing factor to the effect on communities.

 

p122 6.1.2 Refers to engagement with users and operators of community facilities incl. Ingestre Golf Club, Ingestre Hall and Ingestre Orangery, but does not mention Ingestre or Tixall Church, or the Village Hall at Tixall which serves both communities, or Select Healthcare Group in respect of Little Ingestre House residential care home for the disabled.

 

6.3 Environmental Baseline

    There are 8 business properties, 106 residences and 1 church within 1 km of the proposed route. All will encounter intrusion/disturbance as a result of the construction and operation of the proposed scheme however only Ingestre Park Golf Club is directly affected.

 

p123 6.3.6 Villages of Ingestre and Little Ingestre include ~76 residential properties and share a single route of entry along Ingestre Rd. Also in village:

·         St Mary's Church with services twice a month and regular congregation of ~40, but there is no mention of the weddings, e.g. 7 in 2017, and regular concerts, eg. The world renowned Catrin Finch, harpist. These are an important for church outreach.

·         Riding School and B & B at Stables, no mention of hosting Riding for the Disabled.

 

p124 6.3.4 Recreational Facilities

    Ingestre Park Golf Club with ~650 members, an 18 hole course par 70/72 for men and women, club house including bar, restaurant and Pro Shop is used for social and recreational events. Losing this will be a major loss to the local community.

    No mention of Ingestre (Home Farm ) Community Open Space, a recently completed Open Space and orchard for use by the local community.

 

6.4 Effects during construction

P126 6.4.1 Includes Planting and landscape works on Trent N Embankment and Brancote Hanyards S Cutting to limit visual impacts on residential properties and community resources in Ingestre, Little Ingestre and Tixall. We consider that a cut and cover tunnel would be a much better option.

 

P127 6.4.3       Minor utility and highway works – Temporary effects

There are 7 residential properties in Ingestre that are within 250m of the works.  What is of greater significance is that this will result in a major adverse isolation effect for the residents, which will be significant. This is not confined to the 7 residential properties immediately adjacent to the works but to the whole of Ingestre (74 residences).  This is because the only access  to Ingestre is via Ingestre Park Road.  This originates at Hoo Mill Lane crossroads, which lies at the centre of construction works at the northern end of the Great Haywood viaduct.

 

p129  Community Facilities – We are concerned that there is no mention of Ingestre or Tixall.

As noted previously all the facilities listed in 3.3.5 and 3.3.14 above except Tixall Gatehouse, will also suffer major adverse isolation effects. Separately, proper consideration is required in respect of isolation (and other) effects on Hanyards Lane, Tixall.

 

p130  Recreational Facilities - We are concerned that there is no mention of Ingestre or Tixall

                       

Permanent Effects

p132        Community Facilities - We are concerned that there is no mention of Ingestre or Tixall

 

p132 6.4.28  We are pleased to note the inclusion of the loss or isolation of 24.5 ha or 47% of golf course. Which will be a significant major adverse effect if club closes.

 

6.5    Effects arising from Operation

p135 6.5.1 Avoidance and mitigation measures  A noise fence barrier along the embankment, cutting and viaduct. We would repeat our request for a transparent barrier.

 

p136 6.5.4 Assessment of impact and effects  Hoo Mill Lane and Lion Lodges. There will be significant noise and views of running trains resulting in a significant major adverse effect. There is no mention of  Meadow Cottage, Ingestre Village  which looks straight out across the Golf Course

       Similarly there is no mention of Tixall Manor Farm, Tixall Farm or Tixall Court shown on SV-050106 E19 ES3.2.2.2

 

p140    7 Cultural Heritage

p143 7.3.3  Designated assets: It is noted that the following will be directly affected: Trent & Mersey Conservation Area COY037 and Ingestre Conservation Area COY049, and

7.3.4 Within 2km of area: St Thomas Priory COY083; Grade I Tixall Gatehouse and Ingestre Church; Grade 2* Ingestre Hall; and Grade II buildings in Ingestre and Tixall, and Staffs & Worc Canal Conservation Area.

 

                        Non designated assets

P144 7.3.6 High Value:  Crop marks at Hoo Mill and Ingestre; Crop marks south of Lion Lodge Covert

7.3.7 Moderate Value:   Crop marks east of Little Ingestre and Upper Hanyards Farm dating from 1775. But Robert de Hanyate, Chaplain, has land at the end of the vill of Hanyate 8 July 1311 Staffordshire Record Office D938/605 St Thomas Priory deeds, and there are wills for farmers at Hanyards in the 17th century The deserted medieval township of Hanyate was on land belonging to Robert de Hanyate, described as being on the highway leading from Ingestre to Stafford – present day Hanyards Lane.  The location is unknown but present-day Upper Hanyards Farm is a candidate site

 

p145 7.3.8 Low Value: Hoo Mill renovated in the 19th century on site of mill to 1086 with previous tramway to canal; Cropmarks and earthworks on Gold Course; Golf Club avenue planted for the 21st birthday of the 21st Earl of Shrewsbury; Ingestre Park with boundary earthwork features; Hoo Mill crossroads finger post; Historic extent of Tixall Park; Crop marks in former Tixall Park and Quarry at Upper Hanyards, and p146 Earthworks in field east of Upper Hanyards Farm.

 

    There is no mention of the following non-designated assets, reported in our previous response to the draft EI consultation in 2016:

    The 1.5ha area of salt marsh which exists at the southern edge of Lion Lodge Covert.  This is a remnant of a much more extensive salt marsh which, from historical records, extended, we believe, to something in excess of 35ha but which has subsequently been drained. The brine springs that feed this area of marshland remain active, the emerging brine being intercepted and carried away by the extensive surface and sub-surface drainage NB: The remnant salt marsh is host to rare plant species, including one not recorded in Staffordshire for nearly 100 years and to breeding lapwings and curlews.

  

   Little Ingestre which was the Estate Offices including a sawmill, in the 19th century and previously in the 18th century was the site of Ingestre Home Farm. These buildings now comprise 10 residential units: Nos 1 – 10, Little Ingestre Barns, and 4 cottages: North, South, West Barns and Yew Tree Cottage.

 

    Lion Lodges (within 500m of the land required). The present lodges date from the 1930's when they were rebuilt on the site of earlier lodges, dating from the early 19th c, which, themselves, incorporated an ancient triumphal arch that was relocated from the pleasure grounds of Ingestre Hall.

 

    Known to exist from historical records but for which there are no known surviving above-ground remains is the Holy Well and Chapel of St Erasmus.  This was a significant place of pilgrimage until the late middle ages.  Following the Reformation, pilgrimage stopped, the chapel was demolished and the well (a naturally occurring mineral water spring containing salt and elements that gave it a sulphurous quality) was eventually lost to history.  The location is unknown but is described in Robert Plot's History of Staffordshire (1686) as being close to Ingestre Marsh (see point 1 above).

 

     Known to exist from historical records but for which there are no known surviving above-ground remains is the original 13c church of St Mary the Virgin, Ingestre (and possible accompanying burials).  The church was described as being small and incommodious, and was, by the mid 17th c, in a state of ruinous repair.  It was taken down and parts reused, when the new church (commissioned by Walter Chetwynd and reputedly designed by Christopher Wren) was built on a new foundation to replace it. The new church opened in 1676.  The location of the original church is unknown but is believed to have been to the west of Ingestre Hall, possibly somewhere in what is, today, Church Field.

 

p149 7.3.13 Cultural Heritage Overview

   We note the inclusion of the Neolithic Axes found nr Little Ingestre; and value the list of other important sites given in &.7.3.14,18 and 19.

 

p151 7.3.19  The Elizabethan Tixall Hall was demolished in the 18th century and Georgian country house built to the east, probably using the site of the eastern wing of the earlier house as the new west wing.

Consent for Staffs & Worc Canal included the requirement for the construction of Tixall Wide and  Capability Brown remodelled the landscape at that time

 

p151 7.3.20 The Jacobean Grade II* Ingestre Hall was built c1613 on the site of an earlier medieval manor house with the Grade I Ingestre Church built in 1676 to a Wren design. There is a Late 17th century description of gardens and grounds by Celia Fiennes.

    In the early 18th century a walled wilderness was laid out north west of Hall with a number of classical buildings. Only the Pavilion survives.  Capability Brown landscaped the area to the north of the Hall.

In the 19th century the Parkland south of the Hall was landscaped after the road in front of the Hall to Stafford via Hanyards Lane was closed in 1802.

 

p152 7.3.25 In the 20th century Georgian Tixall Hall was demolished although the Tudor Gatehouse, Bottle Lodge and 19th century stables survive.

 

   The designed landscapes of Tixall and Ingestre Halls were converted to agricultural or recreational use.

Ingestre stables and other farm buildings have been subdivided and converted to residential use and the establishment of an internationally renowned equestrian training and examination centre.

 

7.3  Effects during Construction

Avoidance and mitigation measures

P153 7.4.2 “Construction of Ingestre green overbridge at the historic boundary of Ingestre and Tixall parks/parishes, on a precautionary basis for reasons of ecological connectivity, will also maintain a key feature of the historic landscape and therefore reduce the effect on the Tixall and Ingestre Parklands HLCA.” However, a cut and cover tunnel would be a much better option.

 

Assessment of impacts and effects   Temporary Effects

p154 7.4.10 and p155 7.4.13 The EIA notes a medium adverse impact and moderate adverse significant effect for the Ingestre Conservation Area. Trent N embankment and Brancote Hanyards S cutting will introduce noise into this quiet rural setting. Outward and inward views from Ingestre Park’s historic perimeter and buildings and its historic relationship with Tixall Park to the south Construction activity will last about 3 years, and will be visible from the eastern boundary of the Ingestre Conservation Area.

   There is more than an historical relationship between Ingestre and Tixall. Over centuries the neighbouring parkland estates have evolved  jointly and in harmony. They share landscape, heritage, social and cultural assets as well as being administered jointly.  The Proposed Scheme intrudes on and completely splits apart the two communities; there being an enormous viaduct and high embankment, at the south, that transitions, rapidly, to a deep cutting in the north. The cutting will create a scar in the ancient parklands in excess of 100m wide – but this would all be avoided if a cut and cover tunnel is used.

    Between them, Ingestre and Tixall host 13 listed buildings that lie within 1km of the proposed works.  In addition to the noise, dust and visual intrusion during construction, there is the potential for disruption to the one and only means of access to Ingestre. The in-combination socio-economic impacts on the hall and church arising from all this disturbance will be profound (see 12.4 below).

   With all the adverse factors mentioned, it is inconceivable that the effects and impacts on the area can only be considered to be “moderate”. We believe the temporary effects on cultural heritage will be “severe”.  Please review.

 

p156                                                     Permanent Effects

    We note the number of adverse effects 7.4.19 - 29

p159 7.4.48 “Ingestre Conservation Area, an asset of moderate value, will be subject to a permanent change in its setting. The Conservation Area has relatively few significant outward or inward views, with the core of the estate being largely masked by trees. The most important relationships in terms of heritage significance tend to be those between the various key elements of the estate: the buildings, landscape features and gardens.

  The south-western end of Lionlodge Covert will be removed by the Trent North embankment. This will pass immediately south of the tree-lined carriageway that leads from Ingestre House Hall to the Lion Lodges, which lie within the Conservation Area.

  The route of the Proposed Scheme, together with overhead line equipment, noise barriers, security fencing and mitigation planting will be in full view from the asset at these locations. The Tixall Bridleway 0.1628 accommodation overbridge will also be visible.

  The route will run between the historic parklands of Ingestre and Tixall that were formerly set out partially in relation to one another, albeit both parks were substantially degraded during the 20th       century. However, the core area around Ingestre Hall, St Mary’s Church and the stables will remain largely unaffected, as only limited, distant views of the Proposed Scheme will be apparent and change in noise will be insignificant.

  Taken together, these changes will constitute a medium adverse impact and a moderate adverse significant effect.”

  We strongly disagree that Ingestre Conservation Area is only an asset of moderate value, and are concerned at the significant adverse impact and effect HS2 will have on it.

   Please review and amend, taking into account all the points previously raised under Cultural Heritage (including the complete loss of the  referenced remnant salt marsh, with its rare flora and fauna),

 

p157  7.4.25 In respect of the observation that: The core area around Ingestre Hall, Church and Stables, however, would remain largely unaffected. we would point out that while this might be true in terms of heritage assets, only 13 of the 74 residences in Ingestre are in this “core area”. 

The remaining residences are divided, in roughly equal numbers, between Home Farm Court, Ingestre Village and Little Ingestre, with a few outliers.  In the wider sense, the Hall, Church and Stables is not the core of the community and, while the assessment of largely unaffected may apply to the Hall, Church and Stables in the longer term this is certainly not the case during construction.

 

p161 7.4.53 (summary of likely residual significant effects), the summary must pick up on the negative socio-economic effects on heritage assets and the local communities of Ingestre and Tixall as discussed in 12 below.

 

P161 7.5 Effects arising from operation

p162 7.5.1 Avoidance and mitigation measures  Noise Fences on Trent N embankment and Brancote S cutting to reduce noise effects in Ingestre Conservation Area. We would again request that the use of transparent noise barriers is investigated.

 

p163 7.5.8 Assessment of impacts and effects  Ingestre Conservation Area - only moderate adverse significant . We strongly disagree with this and believe that HS2  has underestimated the impacts and effects during both construction and operation. 

 

P165 8 Ecology and Biodiversity

P166 8.3 Environmental Baseline

P168 8.3.3 Pasturefields SAC  The official site designation in 2005 was “unfavourable, recovering”, a situation that had not changed when next reviewed in 2012. The current assessment is that the site is stable but in an unfavourable condition. The next formal review is not due until 2018. 

 

p169 8.3.5 Tixall Broadwater – Local Wildlife Site or LWS and Lion Lodge Covert LWS

   Lion Lodge Covert LWS corresponds with Staffordshire Ecological Record for site 92/84/70, surveyed in 2014 and the ecological report submitted to HS2 Ltd, in draft form, in Dec 2014, as part of our Phase 2 Route Safeguarding consultation response.  A copy of the final report was sent to HS2 Ltd in June 2015 following formal ratification of the site as a local Site of Biological Importance (SBI).

    SBI 92/84/70 has two distinct parts (not recognised in the CA2 report or on the accompanying CT-10 series map):

Part A: Broadleaved, mixed and yew woodland (Lion Lodge Covert) and,

Part B: Inland Saltmarsh (open wet grassland immediately south of Lion Lodge Covert).  The salt marsh is 1.5ha in extent and is described as Poor, Semi-improved.

    The salt marsh is entirely within the land required for the proposed scheme and will be destroyed if the project proceeds as proposed. 4ha of the broadleaved woodland portion of the SBI (approximately 25%) will also be lost.

    The salt marsh part of the site is non-designated yet is potentially of national importance. The following three paragraphs are taken from the site report:

“The site also is host to Stiff Saltmarsh-grass which has not been recorded in the county since 1923 and is a significant record for the country. This species is nationally scarce and normally confined to coastal locations. At present there is only one other inland site in Britain (in Cheshire) where the species has been recorded in modern flora accounts.

Breeding Northern Lapwing have been recorded on the grassland in 2013 and 2014. Eurasian Curlew were also recorded in 2013 and 2014 and were also displaying breeding behaviour, although breeding has not been confirmed on the site. Lapwing and Curlew are UK Species of Principal Importance (SPI) which have been identified for priority conservation action.

Due to the potential importance of the saltmarsh area as a remnant Annex 1 habitat type (a habitat type which is listed on the European Union’s Habitats Directive and is considered to be a European priority for conservation), a detailed, appropriate geo-hydrological survey of the site is recommended to ascertain the nature and extent of the current edaphic conditions the site supports.”

 

p174 8.3.23 Water Bodies - no list of the location of the 40 ponds directly affected by the scheme in CA2. We flag Saltspring Pool, on the southern edge of Lion Lodge Covert (details provided to HS2 Ltd, initially in August 2013, repeated in our Phase 2 Route Consultation response in January 2014 and as marked on Fig 1 as part of 2.3 above) and trust that this is included as one of the 40.

 

p174 8.3.25 "Inland salt meadow, covering an area of approximately 1.5ha, also occurs at Lion Lodge Covert LWS. The salt meadow comprises marshy grassland and is characteristic of NVC community MG10b Holco-Juncetum effusi rush pasture Juncus inflexus subcommunity. The salt meadow is dominated by creeping bent with occasional soft-rush and several patches of saltmarsh rush Stiff saltmarsh-grass (which is nationally scarce) was recorded within the salt meadow by the Staffordshire Wildlife Trust during June 2014. The salt meadow is located within the land required for the Proposed Scheme. As a consequence of agricultural management the salt meadow is of county value."

   We disagree and believe it is potentially of National importance.

 

p175 8.3.29  Table 16 Summary of protected and/or notable species: Bats south of Hoo Mill Up to Regional Value; Bats at Golf Club Up to Regional Value; Bats at Upper Hanyards Up to Regional Value; Bats south of Hoo Mill County value; Great Crested Newt - 12 ponds at Golf Club County value; Curlew at Tixall (Manor) Farm south of Lon Lodge Covert County value; Golden Plover R.Trent floodplain between Ingestre and Rawbones Meadow Local/Parish value; Lapwing Meadow SE of Tixall Local/Parish value; Breeding birds at Upper Hanyards - Low densities; Wintering birds at Upper Hanyards - Low densities; Otter at Hoo Mill.

      It is with considerable concern (and frustration) to find that Table 16 fails  to take into account much of the detailed information already provided to HS2 Ltd as Appendix 5 (a 23 page wildlife report for Ingestre & Tixall) of our January 2014 Phase 2 Route Consultation response. 

    A pair of Curlew regularly nest on the grassland to the south of Lionlodge Covert as confirmed by the survey and desk study records and the nest site is located within the land required for the Proposed Scheme.

   There is no mention of the Barn Owls that apparently breed somewhere between Tixall Farm House and Tixall Village seen in the area over a period of some years. There are also Barn Owls nesting in a box adjacent to the bridge over the Trent at Trent Walk. These are not mentioned even though their presence has been well known for several years.

 

p183 We single out 8.4.7 (Pasturefields SAC) for special mention because, as is already known to HS2 Ltd, since shortly after the announcement of the IPR for Phase 2 in January 2013, we have disputed the claims made by HS2 Ltd on the environmental and community impact of the current proposal. 

   Please refer our previous response to  the  HS2 Phase 2a: West Midlands to Crewe Working Draft Environmental Impact Assessment Report on 7.11.2016. Q2 Response: Part B: Appendix: Alternatives Report:

 

p184-186   8.4.15, 8.4.17, 8.4.18, 8.4.21, 8.4.22, and 8.4.31     We are concerned at the loss of:

·      27% of Lionlodge Covert LWS, designated for its lowland mixed deciduous woodland and inland salt meadow;

·      17% of ancient woodland at Flushing Covert, which is to be added to the AWI;

·      34% of ancient woodland at Town Field Plantation, which is to be added to the AWI;    

·      19% of woodland habitat within Lionlodge Covert LWS;

·      33% of the woodland belt on the west side of Ingestre Park Golf Club;

·      100% of inland salt meadow (within the Lionlodge Covert LWS); and                             

·      a veteran Lime and a veteran Horse Chestnut on the SE side of the Golf Course

 

p187    8.4.36  There is no mention of the very significant assemblage of 200+ pipistrelle bats at Home Farm Court as witnessed during the week of July 22nd 2017 and in previous years. There are also bats at Ingestre Church and Ingestre New Stables as well as other sites around Ingestre.

 

p189 8.4.46  Birds: “Construction of the Trent North embankment will result in the permanent loss of curlew breeding and foraging habitat on the grassland south of Lionlodge Covert at Tixall (Manor) Farm. This loss represents a permanent adverse effect on the curlew population at Tixall (Manor) Farm, which will be significant at the county level."

  The report states that the creation of a 5ha wetland habitat on the River Trent flood plain between Great Haywood and Hoo Mill will reduce this adverse effect to a level that is not significant.

  How will that be measured and who determines the significance ?

 

p191 Para 8.4.59 How will the new grassland areas by the Mill Lane Auto Transformer Station and at the edge of Ingestre Golf Club (CT-06-213) for newts and Barn Owls  be monitored to ensure that they are effective ?

 

Summary of likely residual significant effects

p195 8.4.78     "There will be a residual effect due to the loss of 1.5ha of inland saltmarsh habitat at Lionlodge Covert LWS that is significant at the county level."

    We believe that there will be no effect on breeding waders at Pasturefields SAC as there is no evidence that any waders breed there. Redshank have not attempted to breed in the area since 2004. Snipe winter there along with the occasional Jacksnipe (winter visitor to the UK). The site is therefore important as a winter refuge but no longer attracts breeding birds. Lapwings are very rarely seen at Pasturefields at any time of the year.

    In that respect the field adjacent to Lionlodge Covert is more important as it attracts Curlew, Lapwing and Skylarks.

 

   The only effects listed relate to areas of habitat that are permanently lost to the railway.  No mention is made, whatsoever, to effects on nearby habitats whose characters are permanently changed as a result of the building the railway.  These include:

·         Changed surface and groundwater conditions, including dewatering of the Hanyards aquifer by the construction of a deep cutting through it.

·         With reference to Great Haywood viaduct, the impact on adjacent flood-plain meadows and wetlands of shading by the viaduct and/or change in soil and surface-water ph as a result of the leaching of alkaline components from the concrete used in its construction.

 

9  Health

Formal Objection: As for section 6 (Community) above, before addressing the specific points contained in the CA2 report we wish to formally object to the exclusion from the assessment, without reason or explanation, the very real issue of impacts on health caused by generalised property blight.   

   The degradation of asset values, changes in community cohesion and a feeling of entrapment for those who have lost the freedom to move away to escape the impacts of construction and operation of the scheme, without incurring substantial financial loss, has already created severe mental stress.  This will only get worse once construction starts.

    As with Community, it is unacceptable to make a pretence of assessing health impacts while deliberately excluding the single most important contributing factor to anxiety/mental ill-health.

 

p201 9.2.4 In line with this objection, we propose that mapping of loss in property value due to HS2 be used as a proxy “health determinant” to be considered alongside data from the Office of National Statistics and the Association of Public Health Observatories both during construction and during operation.

 

p206 9.4.2 No specific mention of maintaining access to Ingestre during construction which is essential.

 

p207 9.4.10 No mention of construction effects on Ingestre which will be significant with worries about journey times and access.

 

p211 9.4.25 The report notes that construction traffic will use Mill Lane east of Haywood, Hanyards Lane and Blackheath Lane, but there is no mention of Tixall Rd through Tixall.

 

p212    9.4.35 " In the event that construction of the Proposed Scheme leads to the loss of Ingestre Park Golf Club clubhouse as a facility available for use for local community meetings, clubs and societies, the loss of that facility may lead to a reduction in social capital. In that event, and in the event that no suitable alternative facility is made available, the consequence may be an adverse effect on wellbeing in the local community."

    We note that there definitely will be an adverse effect on the wellbeing of the local community. While it is true that the golf course is not open to the public as place providing an accessible green space, the whole community will lose the social amenity provided by the clubhouse restaurant, bar and meeting-room facilities which are used regularly for community events.  This is especially significant as there is no other convenient place for the local community to socialise.  Also, the Golf Club is an important place for local employment and, while the numbers are not high, they are significant in terms of local employment opportunities.  The loss of the Golf Club as a community resource and place of employment will definitely have a negative impact on health and wellbeing in the area.

 

p213    9.4.39 HS2 Ltd will continue to engage with local stakeholders to ensure that, in the event that Ingestre Park Golf Club club-house cannot continue to function in its present state, appropriate mitigation is put in place.

   We would like to ensure that this will include an alternative site for a social amenity in Ingestre, and request that HS2 engage with us before any final decision on the relocation of the Golf Club is made.

 

p214 9.5.3 (Assessment of impacts and effects on Neighbourhood Quality) There is no mention of Ingestre in relation to negative feelings re quality of life and local environment.

 

p215 9.5.11 (Access to services, health and social care)  There is no mention of the effects on emergency response times to Ingestre which requires special attention because:

·         There is only one route of access to Ingestre – Ingestre Road.

·         Elderly residents with complicated medical conditions are represented disproportionally.

·         A riding school, several working farms and a residential care home for the disabled are accessed from this road and need constant, 24-hour access to medical emergency services.     

·         Ingestre Road is vulnerable to significant disruption during construction of the railway due to the nature and scale of the works currently planned in the vicinity of Hoo Mill crossroads.

·         The debacle over the failings of the Mid Staffordshire NHS Trust has led to reduced emergency services at what is now Stafford County Hospital.  Urgent and out-of-hours emergency treatment has to be obtained either from Wolverhampton or from Stoke on Trent, both a considerable distance away.

·         None of these hospitals can be accessed, except via roads that have been nominated by HS2 as construction traffic routes

 

10    Land Quality

p220-221 10.3.12 through 10.3.14 (Environmental baseline – Bedrock Geology):  As has already been noted regarding p86 4.3.2 above, an incomplete summary has been given.  While mention is made of the Stafford Halite to the north of Yarlet, no mention is made of the halite deposits of the western edge of the Needwood basin to the south. These are the presumed source of active brine springs that still emanate in the areas of Shirleywich, Pasturefields and the Lion Lodge Covert area of Ingestre/Tixall.  Here, the salt of the Needwood basin has dissolved near outcrop and, consequently, the salt sequence is most likely represented by brecciated strata caused by the collapse and foundering of the sequence caused by the removal of the salt by dissolution.

 

p221 10.3.18 (Environmental baseline – Groundwater): Not mentioned is the Sherwood sandstone outcrop between Ingestre/Tixall and Stafford. This is a probable groundwater recharge point for the aquifer that is believed to provide the artesian pressure that drives the brine springs referenced in the preceding paragraph.   Abstraction from this aquifer and/or a reduction in artesian head resulting from dewatering in response to the creation of Brancote Hanyards Cutting could adversely affect brine flow rates.  This would be important for all ecological sites that depend on the sustained flow of brine, including the European protected site of  Pasturefields SAC.

 

p223 10.3.29 Table 19 Landfill sites does not include the Landfill site at Lodge Covert, Tixall, or the various infilled Marl Pits.

 


p226 10.3.41 (Environmental baseline – Mining/mineral resources):  We agree that commercial exploitation of the halite deposits in the area is unlikely in the foreseeable future. Nevertheless, there remains a legacy issue from previous exploitation, particularly in the northern part of the CA2 area, where brine pumping in the Stafford area continued until the early 1970s. The BGS estimate that only about 10% of the volume of salt removed by brine extraction from the Stafford Halite deposit has been accounted for by recorded subsidence.                       BGS map of areas prone
                        to subsidence

Fig 2: BGS Map of Areas Prone to Subsidence(see note below)

   Note ref Fig 2: This is based on Fig 1 of the BGS report that formed Appendix 6 of our response to the Phase 2 Route Consultation.  At that time, the BGS Karst database did not include the Ingestre/Tixall saltmarsh shown in Fig.1 above, so it does not appear. 

   The route of the Proposed Scheme (Route C) passes through the area identified by the BGS where further subsidence may occur (see Fig 2 above). On the other hand, this area is avoided by the March 2012 route HSM03 (Route B).

 

      The two largest extraction sites (Shirleywich and Weston) both ceased operation at the start of the 20th century. The Weston saltworks was fed with brine that was extracted from the ground in Ingestre, from a well located at approximately OS ref: SJ977260. 

   Of more relevance, is the natural dissolution of halite that underlies the salt marsh at Ingestre/Tixall, over which it is proposed to build the route (see 2.3 Fig 1 above).  Local measurements of brine concentration and flow rate at just one of the outflow points from the drainage network of the marsh gives a daily loss of 1.34 Tonnes (0.5m3) of salt.  This is a minimum as there are several outflow points and not all were measured. 

    Apart from the corrosive nature of brine, it appears that HS2 Ltd has created for itself significant engineering challenges in maintaining track stability in the face of the loss of supporting ground amounting

to several hundred cubic metres per annum.

 

p240   11 Landscape and visual

p241 11.2.2   Winter surveys for landscape and visual assessment were carried out from Jan to March 2016 and in February 2017. Summer surveys including photographic studies of landscape character areas and assessment of viewpoints were carried out July - Sept 2016. Some areas were inaccessible.

   We are surprised to note that some areas were inaccessible, we assume this is mainly because HS2 did not know who to contact. Putting up notices by the land in question was a very ineffective way of finding out, when by contacting the Parish Council directly, this information could have been supplied.

 

11. 3 Environmental Baseline

p241 11.2.2 (Scope, assumptions and limitations – ZTVs): The concept of a zone of theoretical visibility (ZTV) is understood but its application to construction and operation less so.  In both cases it appears that the fixed structures of the railway will be included (except, it would seem, the overhead line equipment).  For operation, the EIA SMR, paragraph 15.5.3, simply says: “the area over which the components of the Proposed Scheme (including trains) would be visibleIt is the including trainspart that requires further elaboration.

    At the simplest level, a train could be represented as solid object extending (say) 4m above the rail head and this, perhaps, is all that is needed to define a ZTV.  What is not explained in either the CA2 report or in the EIA SMR is how the dynamics of a moving train in the environment affects its intrusion.  The visual impacts of the static components of the railway will be (and need to be) assessed completely differently from the dynamic components – i.e. the trains. 

    On Phase 2a, the proposed service operation sees, in our area, the passage of 24 trains per hour (one every 2min 30s on average), each train being up to 400m in length and travelling at up to 360kph. Unlike the fixed features, for which mitigation is proposed to help blend them into the landscape, the trains will most likely be bright, shiny and decked-out in the eye-catching livery of the chosen train operating company.  The rapid motion across the landscape of a visually conspicuous object creates an environmentally intrusive feature of completely different character to that of the static infrastructure.  We see no indication as to how this critically important aspect of visual intrusion is being addressed.

     Trent South Embankment, Great Haywood Viaduct and Trent North Embankment combine to form a continuous elevated section of route of 3.3km in length.  The average rail height above grade over this distance is around 12m with a maximum of 17m.  In addition, noise barriers of up to 4m above railhead are proposed.  The resulting 3.3km long, 15-21m high linear visual barrier will be a major intrusion on the landscape.  Because of the proposed location at the confluence of the River Trent and River Sow valleys, in an area of relatively open landscape, this elevated section will have a major impact over a wide area, including views from the sensitive areas of Shugborough Park and Cannock Chase AONB.

  There does not appear to be any attempt, in the Proposed Scheme to offer mitigation against the wider effects in the landscape of this intrusion. 

   The use of transparent sound barriers would lessen this impact in combination with additional landscaping away from the direct line of HS2.

 

p241 11.2.4 We note that tall construction plant (for example cranes and piling rigs) and Overhead line equipment are excluded from the ZTV although Overhead line equipment is described and taken into account in the assessment of effects on LCAs and visual receptors.

   For construction it is not clear whether temporary stockpiles of construction materials (including temporary storage of spoil from earthworks) etc. will be taken into account.

 

p246    Table 27  Construction Phase significant landscape effects

   We are very concerned that despite Ingestre Park Sandstone Estatelands having High susceptibility and sensitivity, the Proposed Scheme will sever the landscape and visual relationship between the historic designed landscapes within the LCA.

    "Direct impacts will result from the introduction of large scale earthworks associated with Trent North embankment and Brancote Hanyards South and North cuttings. Changes to the landscape pattern will result from the demolition of buildings at Upper Hanyards Farm and Chase View, and removal of mature woodland and sections of the historic tree belt boundary of Tixall Park and the severance of the historic Hanyards Lane.

    In addition, rare landscape features such as the saltspring pool will be lost. The tranquil, rural landscape, accessed only by Hanyards Lane, will be temporarily disrupted by the presence of construction traffic routes, site haul routes, satellite compounds and the introduction of uncharacteristic features, such as material stockpiles, that will alter a substantial proportion of the character area. Construction of the Proposed Scheme will result in a high magnitude of change and major adverse effect, which is significant."

 

    Similarly Ingestre Riparian Alluvial Lowlands are also designated as having High susceptibility and sensitivity will also be badly effected.

   "The southern extent of the LCA will be directly affected by the concentration of large scale construction activities in this small scale, intimate and historic landscape. .......The use of Mill Lane as a construction traffic route and the noise, movement and scale of the works over a long duration will change the tranquillity and scale of the historic landscape which will be perceptible from a wider area within the LCA than will be directly affected by the construction works. In addition, perception of the LCA from outside its boundaries will change.

     Construction of the Proposed Scheme will result in a high magnitude of change and major adverse effect, which is significant."

 

p247 11.4.12 Table 28 Construction Phase significant visual effects. We are again very concerned at the visual effects of HS2 in this beautiful rural location, including:

Views north from Great Haywood Tixall Road (VP 009-02-015)

  "Residents of Tixall Manor Farm will have close to medium-range views dominated by the construction of Great Haywood viaduct and associated embankments, introducing construction equipment, vehicle movements and structures into the open valley floor landscape. The woodland removal at Lionlodge Covert will be a large scale activity in proximity to residential receptors, however, the retained woodland will provide the same backdrop to views until temporary material stockpiles are in place. The stockpiles, construction vehicle movements and large scale earthworks will be in proximity to the residential receptors, dominating and foreshortening the views.

    Construction activity will result in a high magnitude of visual change and major adverse effect, which is significant."

 

Views north from the Staffordshire and Worcestershire Canal and Tixall Gatehouse (VPs 009-03-010 and 009-03-019)

"Long distance views from Tixall Gatehouse will be partially screened and filtered by vegetation depending on the time of year, however construction activity will be discernible and will introduce incongruous elements to the rural landscape. Visitors and guests to this property will have their attention focused on the rural landscape setting and the panoramic views from the roof terrace, which are a feature of the Gatehouse. Walkers using The Way for the Millennium long distance footpath along the Staffordshire and Worcestershire Canal will have long-range views to large scale construction works for Trent North embankment.

    Due to the distance of construction works from the receptors, changes to the skyline from the removal of mature woodland and the nature of the works being incongruous with existing views across the historic designed parkland and the historic character of the canal, there will be a medium magnitude of visual change and moderate adverse effect, which is significant."

 

 

Views south from Ingestre Park Road (VPs 009-02-016 and 009-02-022)

    "Residents will have direct, close-range views from upper and lower storeys at Lion Lodges to the construction of Trent North embankment. Construction will introduce large scale vehicle movements, equipment and earthworks including the use of Great Haywood Tixall Road for a construction traffic route.

     Residents at Little Ingestre will have longer-range views to the removal of mature woodland for construction of Trent South embankment that will change the character of the view and open up views to the construction works. Construction of Great Haywood viaduct will be discernible also. Construction within Ingestre Park Golf Club and south of Lionlodge Covert will be screened by retained trees and woodland. A large scale material stockpile to the east of the golf club house will however be visible.

  Construction activity will result in a high magnitude of visual change and major adverse effect, which is significant."

 

View from Tixall Park (VP 010-03-005)

   "Users of the bridleway through Tixall Park will have close-range views towards the construction works, dominated by the large scale earthworks for Brancote South cutting and Tixall Bridleway 0.1628 accommodation overbridge. There will be also views of a satellite compound and temporary material stockpiles. These will introduce structures, construction activity and large scale earthworks into the views of the rural, parkland landscape. The demolition of Upper Hanyards Farm and the removal of surrounding woodland will be an additional change to the historic character of the view and of the skyline.

    Construction activity will result in a high magnitude of visual change and major adverse effect, which is significant."

 

Views from Hanyards Lane (VP 010-04-007)

   The view for road users along Hanyards Lane (010-04-007) will change within the mid-ground, particularly with the demolition of Upper Hanyards Farm. The use of Hanyards Lane as a construction traffic route will dominate the view at all ranges.

    Road users on Hanyards Lane will experience a high magnitude of visual change and a moderate adverse effect, which is significant."

 

Views from Tixall Park (VPs 010-03-009 and 011-03-002)

   "Users of the bridleways will have medium-range views towards the construction of Brancote Hanyards North and South cuttings. In views to the west from around the Staffordshire County Showground (010-03-009 and 011-03-002), the majority of Brancote Hanyards South cutting will be just below or at ground level with less change to existing topography and partial screening by intervening topography. Changes to the views will result from temporary material stockpiles which will shorten and change the character of views. In addition, construction equipment and vehicle movements will introduce a further discordant element to the rural views.

    Users of the bridleways will experience a medium magnitude of visual change and a moderate adverse effect, which is significant."

 

    While we have no reason to dispute the analysis, we contend that the reference view-points chosen (Tixall Bridleway 0.1628, either side of the Hanyards Lane Overbridge) is a poor one in terms of the frequency of experience of the referenced views.  Of far greater relevance to the visual importance of the landscape is views further south, where the Great Haywood viaduct and Trent North embankment intrude more prominently into the landscape and where the majority of both residents and visitors to the area will encounter the railway. 

    We note that there is no mention of the views from Meadow Cottage, Ingestre Village Road, the end of the terrace of 4 estate houses which overlooks the Golf Course with only a Haha on their boundary, and will therefore be in direct view of HS2 across the Golf Course.

 

p254 11.5.6     Table 29 Operational Phase significant landscape effects. We are again very concerned at the visual effects of HS2 during operation in this beautiful rural location. Many of our elderly local residents will not live to see the promised reductions in visual impacts after 15years, much less 60 years.

  We note with great concern:

Ingestre Park Sandstone EstatelandsHigh susceptibility and sensitivity

In year 1, the permanent severance of the historic landscapes at Ingestre and Tixall and loss of the historic line of Hanyards Lane and woodland will directly affect the landscape. We strongly oppose the mitigation woodland planting between Lambert’s Coppice and Ingestre Wood which will only add to the severance of the historic landscapes at Ingestre and Tixall . Mitigation planting across the Ingestre green overbridge will not be sufficiently established at year 1 to reduce effects and the introduction of structures and infrastructure will result in incongruous elements.

Operation of the Proposed Scheme at year 1 will result in a high magnitude of change and major adverse effects, which is significant.

Ingestre Riparian Alluvial LowlandsHigh susceptibility and sensitivity

In both summer and winter of year 1 of operation there will be limited direct effects on the landscape. However, the introduction of Trent South embankment will result in a substantial change to the open valley landscape and the Great Haywood viaduct will change the perception of the valley landscape from long distances. The intimate scale and character of the Trent and Mersey Canal Conservation Area will be degraded by the scale of the viaduct.

Operation of the Proposed Scheme at year 1 will result in a high magnitude of change and major adverse effects, which is significant.

 

p256 11.5.10 Visual assessment:  Table 30 Operational phase significant visual effects

From map CT-o6-213, the Auto-transformer station appears to be perched on a mound of soil (presumably so that it can be located at track height), the mound itself being balanced on the side of the Trent North Embankment.  Since the track at the chosen location is approximately 11m above grade this makes an already intrusive embankment even worse and, given the height involved, the access road must be incredibly steep !

 

     As we have said above many of our elderly local residents will not live to see the promised reductions in visual impacts after 15 years, much less 60 years.   We note with great concern:

Views north from the Staffordshire and Worcestershire Canal and Tixall Gatehouse (VPs 009-03-010 and and 009-03-019)

In Year 1 winter, recreational receptors at Tixall Gatehouse (009-02-019) will have long-range views to the Great Haywood viaduct and Trent North and Trent South embankments and will perceive the loss of existing mature vegetation. Walkers on The Way for the Millennium long distance path/canal towpath will experience changes to the skyline and the frequent train movements.

Operation of the Proposed Scheme at year 1 winter will result in a medium magnitude of visual change and moderate adverse effects, which is significant.

In year 1 summer the views will be predominantly screened by intervening existing vegetation, and operation of the Proposed Scheme will reduce to non-significant, as reported in Volume 5: Appendix LV-001-001

 

Views south from Ingestre Park Road, Little Ingestre (VP 009-02-016)

At year 1 winter, residents at Little Ingestre will experience partial views of Trent North embankment and train movements at distance.

Operation of the Proposed Scheme at year 1 winter will result in a medium magnitude of visual change and moderate adverse effects, which is significant.

At year 1 summer, intervening existing vegetation will provide partial screening of the Proposed Scheme, and operation of the Proposed Scheme will reduce to non-significant, as reported in Volume 5: Appendix LV-001-001.

 

Views south from Ingestre Park Road, Lion Lodges (VP 009-02-022)

At year 1 winter and summer, residential receptors at Lion Lodges will experience foreshortening of the view to the south due to the introduction of Trent North embankment at close-range.

Operation of the Proposed Scheme at year 1 winter will result in a high magnitude of visual change and major adverse effects, which is significant.

 

View from Tixall Park (VP 010-03-005)

In Year 1 winter and summer whilst much of the Proposed Scheme will be screened by intervening topography, changes to the view will result from the introduction of infrastructure elements including Tixall bridleway 0.1628 accommodation overbridge and mitigation planting.

There is limited intervening vegetation to provide additional screening of the Proposed Scheme.

Operation of the Proposed Scheme at year 1 winter and summer will result in a high magnitude of visual change and major adverse effects, which is significant.

 

View from Tixall Park (VP 010-03-009)

Year 1 winter and summer. Despite the distance from the Proposed Scheme and partial screening from intervening topography there will be views to  frequently passing trains between Brancote Hanyards North cutting and Hopton embankment, introducing incongruous elements to the view.

Operation of the Proposed Scheme at year 1 winter and summer will result in a medium magnitude of visual change and moderate adverse effects, which is significant.

 

  We are concerned that there are no photomontages from sites within Ingestre or Tixall.

 

  The section of the country through which the Proposed Scheme passes is essentially rural, with historic landscapes and an extensive number of heritage assets and estate parklands.  This, combined with the absence of controlled flight zones associated with any civil or military airports in the area, makes this part of the UK a hotspot for recreational air-borne activities.  There is a proliferation of light aircraft clubs, hot-air ballooning and other enterprises offering: gliding, hang-gliding and micro-light opportunities for the enthusiast and public alike.  There is absolutely no doubt that HS2, and the construction phase in particular, will create an enormous and unnatural linear scar in the landscape, visible for miles, that will seriously degrade the pleasure currently enjoyed by this group of people.

This degradation of the countryside from an aerial perspective will be substantial and will be on a route-wide basis.  We believe that it warrants proper assessment  and the more creative use of tunnels, instead of deep cuttings, e.g. in Ingestre/Tixall.

 

p268-277  12 Socio economics

   p273 12.4.12 The only direct impact on local employment is Ingestre Park Golf Club which will be unable to function in its current arrangement.  The probable loss of this facility will have a major impact on local employment.

 

   What is not addressed is the impact on businesses and community facilities that are not directly impacted but whose activities will be adversely affected as a result of the construction and operation of the railway.

   All the local businesses/community facilities mentioned previously will be adversely affected to some degree or other.  Most vulnerable are Ingestre Hall and St Mary's church both of which have to stand alone financially and for which the peace, tranquillity and historic setting of the area are central to their ability to raise funds.  If the church cannot be financially sustained, it risks closure and, likewise, if Ingestre Hall cannot be operated effectively as a stand-alone profit centre, its long-term survival as a residential arts centre, under the stewardship of Sandwell MBC, will be in doubt. 

   Ingestre Lodges, Ingestre Pavilion and Tixall Gatehouse are premium holiday lets that also have a heavy dependence on the peace, tranquillity and historic nature of their settings.  They face considerable harm through lack of take-up. 

   Ingestre Stables equestrian centre and Little Ingestre House residential care home have a lower sensitivity but nevertheless depend on an adequately high demand for their services to remain viable.

   These and other smaller local endeavours are critical to the socio-economic status of the area and all are under threat.

    It is absolutely essential that proper engagement takes place with the relevant authorities/owners to fully understand the potential impacts and concerns of these businesses/facilities and to agree mitigation and/or compensation as appropriate. It is essential that they are not driven to closure through no fault of their own.

 

13 Sound, noise and vibration [E19 Vol.2 Map Book . ES 3.2.2 (A3) SV-05-106 and SV-05-106 Operational Noise and Vibration Impacts and Likely Significant Effects and E77 Sound Noise and Vibration ES 3.5.1.10 SV-02-106 and SV-02-107]

    Ingestre is a quiet area that is prized by residents and visitors alike for its tranquillity. We have repeatedly objected to the basis for assessment of noise levels in which the lower cut-off for the equivalent continuous power level is 50dB for daytime LAeq.  The typical daytime LAeq is currently in the low 30's dB (as your measurements should confirm) so, even the lowest contour on your maps corresponds to a sound level in excess of 15dB  above current background.  HS2 Ltd consider that an increase of 10dB above background constitutes a major impact (EIA SMR Table 41).  Against this, an increase of over 15dB is very significant and will have a big impact on quality of life even though, at 50dB, direct adverse health impacts may be small.  It is regretted also that only LAeq contours are given.  For a proper appreciation of the effects there ought to be contour maps showing peak values of noise generated during the passage of an individual train.  This is what is heard, not some mathematically derived average.

    The plans show the difference between Day and Night noise, as the baseline at night is likely to be lower:

SV-02-106: More than 10dB  - Possible major adverse affect:  Lion Lodges (2), Hoo Mill Lane & Hoo Mill (5) Tixall Manor Farmhouse (1)

Night 40-55dB and Day 50 -65dB, 5 – 10dB – Possible moderate adverse affect  Tixall Farmhouse,(3) Tixall Court (12)

and SV-02-107:  5 – 10dB – Possible moderate adverse affect  Lower Hanyards (2)

 

    A notable shortfall in residential addresses that have received mail shots from HS2, at times when it has been claimed that all owner/occupiers within 1km have been written to, lead us to believe that HS2 may have underestimated the numbers of properties that lie within 1km of the route.

    As is noted at 6.3 above, we believe that in Ingestre and Tixall, there are 8 business properties, 106 residences and 1 church within 1 km of the proposed route. All will encounter noise as a result of the construction and operation of the proposed scheme. 

    Full details of all properties within 1km have been provided to HS2 Ltd via Joe Wilson, Stakeholder Adviser, Phase 2a.  We ask that you properly map these properties into the landscape so that the resultant impacts on each of these, as receptors, is properly taken into account in the analysis and selection of mitigation measures.

 

p283-4 13.4.16 Table 33 Direct adverse effects on residential communities and shared open areas that are considered to be significant on a community basis.

    We are concerned that there is no mention of Ingestre or Tixall.

 

p285 13.4.19 "Construction traffic is likely to cause adverse noise effects on occupants of  residential dwellings adjacent to Hanyards Lane, between the Proposed Scheme and Tixall Road. However, considering the small number of properties adjacent to this route, a likely significant construction traffic noise effect has not been identified."

    The noise effect for these properties will still be significant.

 

p287 13.4.30 No mention is made of the possible effects of vibration, during construction. The numerous listed buildings are within a few hundred metres of the route.  Of particular concern is the Grade I listed church of St Mary the Virgin, Ingestre.  This is 400m from the area of the works.  Ingestre Hall (Grade II*) is closer, at 350m and Ingestre Pavilion (Grade II) closer still at 150m.

  These important buildings are all in proximity to Brancote Hanyards Cutting a substantial cutting, nearly 20m deep, in hard sandstone.

   At paragraph 6.11.1 of Volume 1: Introduction and methodology, it is stated that: “Cuttings will be excavated using excavators, graders and scrapers”.  However, we understand that while not expected, until geological surveys have been conducted, there is a possibility that blasting might be required if particularly tough ground conditions are encountered.

    We understand that shock and vibration from explosive type events needs to be treated differently and that these may be encountered:

a) During certain demolitions

b) During excavation in hard rock conditions

c) During controlled detonation of unexploded wartime munitions.

All are geographically dependent.

p292 13.5.19  Measures to avoid or reduce effects of airborne noise during operation at Ingestre. We assume that these measures include the Landscaping and noise barriers. We note that a cut and cover tunnel would be even more effective for Ingestre residents.

 

p293 13.5.23 Table 34 Direct adverse effects on residential communities and shared open areas that are considered significant on a community basis. See Maps SV-05-106 Vol 2 CA2 Map Book

     There will be an increase in airborne noise from new train services both daytime and night-time in Ingestre and Tixall. Note the 5 properties on Hoo Mill Lane are in Ingestre not Gt Haywood.

     The plans show the difference between Day and Night noise, as the baseline at night is likely to be lower:

SV-02-106: More than 10dB  - Possible major adverse affect:  Lion Lodges (2), Hoo Mill Lane & Hoo Mill (5) Tixall Manor Farmhouse (1)

Night 40-55dB and Day 50 -65dB, 5 – 10dB – Possible moderate adverse affect  Tixall Farmhouse,(3) Tixall Court (12)

and SV-02-107:  5 – 10dB – Possible moderate adverse affect  Lower Hanyards (2)

     Despite this none of these properties will qualify for sound mitigation because HS2 has set the bar so high for this.

 

    Forecast increases in sound from the railway are likely to cause a major adverse effect on the acoustic character of a much wider area in Ingestre and the eastern side of Tixall.

   There are no shared open spaces identified as being affected in this community. However, Ingestre Park Road is widely used by walkers, runners, cyclists and riders because of it's tranquil landscape. This will no longer apply.

 

p300    14   Traffic and Transport

p302 14.3.6  (Environmental Baseline) No mention of Tixall road under main local roads. With Hoo Mill Lane having no through access and Mill lane restricted by a low bridge (3.5m) all HGV traffic from the main construction compound on the A51 at Great Haywood to the two satellite compounds at Hanyards Lane and Hoo Mill Lane will have to travel north on the A51 to Weston, west on the A518 towards Stafford, as far as Blackheath Lane island, south on Blackheath Lane and then east on Tixall Road.  Blackheath Lane is very busy, serving as a proxy eastern distributor road for Stafford, together with being the principal access to Weston Road Academy (1000 place secondary school), Staffordshire University (Centre of Excellence in Healthcare Education) and Stafford Crematorium.  Major delays already occur at peak times.

 

p302 14.3.8 Mill Lane and Tixall Road (currently marked on some maps as Haywood Road) should be added to the list of roads crossed by the route (NB: Mill Lane and Tixall road terminate under the route at Hoo Mill crossroads so, technically, they are not “crossed”.  Nevertheless they should be included for completeness as they will be affected to a similar, if not greater, degree).

 

p302 14.3.11 (Public Transport Network) This describes four bus corridors but there is no mention of the 841 and 841A services from Stafford to Uttoxeter and Stafford to Hixon respectively.  These services use Tixall Road and are hence “crossed” by the route at Hoo Mill crossroads as well as on the A51.

Additionally, Tixall Road is used by school buses and by coaches carrying students to and from Ingestre Hall Residential Arts Centre – the latter also having to enter/exit Ingestre Road at Hoo Mill crossroads.

 

p303 14.3.17 Tixall Road is extensively used by cyclists especially at weekends.

 

p307 14.4.11 Table 36 Typical vehicle trip generation for construction in the Colwich to Yarlet area includes:

Gt HaywoodTixall road Satellite Compound: Access to/from main road network via Gt Haywood Tixall road; Starting Jan 2021 for 3 years 9 months; 2 month busy period; 40-55 Cars/LGV and 98-122 HGV combined two way vehicle trips during busy period and within peak month of activity.

 

Trent North Embankment Satellite Compound: Access to/from main road network via Gt Haywood Tixall road to Blackheath Lane and A518 Weston Rd; Starting Oct 2024 for 1 year 3 months (Auto Transformer Station); 10 month busy period; 57-84 Cars/LGV and Up to 10 HGV combined two way vehicle trips during busy period and within peak month of activity.

 

Brancote Hanyards Satellite Compound: Access to/from main road network via Hanyards Lane foor site set-up and servicing, then site haul route to A518 Weston Rd; Starting Jan 2021 for 4 years 3 months); 3 month busy period; 40-55 Cars/LGV and 80-90 HGV combined two way vehicle trips during busy period and within peak month of activity.

 

P309 14.4.14  We repeat that any closure of Ingestre Park Road is unacceptable for the reasons stated previously.

 

P310 14.4.19 We note that HS2 accepts that there will be major adverse effects at The Blackheath Lane/Baswich Lane/Tixall Rd signals on delays for other road users during construction.

 

P311 14.4.21 Tixall Rd between Blackheath Lane and the proposed scheme and Hanyards Lane between proposed scheme and Tixall Rd, in both the increased heavy traffic will have a moderate adverse impact on non-motorised road users.

 

P311 14.4.23 (Accidents and safety) No mention is made of impact on the Hanyards Lane/Tixall Rd/Blackheath Lane junction of having up to 90 HGVs exiting Hanyards Lane to try and join the queue at the traffic lights. Many of these will end up stuck across Tixall Rd and in the path of traffic turning left from from Blackheath Lane when the lights change and they are not expecting another junction 22.4m away.

 

15  Water resources and flood risk

    We are deeply concerned at the failure by HS2 Ltd to take into account detailed information about the hydrology of the area that has been provided to HS2 Ltd over a period exceeding 3 years.  This includes, most recently, our consultation response to the draft EIA SMR and the EI Consultation, 7.11.2016.

    We note, that the proposed northern balancing pond  by Hoo Mill crossroads is positioned over a known culvert (roughly aligned from Lion Lodges to Nos 1&2 Hoo Mill Lane Cottages) that is part of the drainage system for the salt marsh, CT-06-213 (See Fig 1 above).

    We are also concerned that the intended inflow and outflow paths for the balancing ponds are not shown in any map, eg. in Vol.5 E79 Map Book of Water Resources and Flood risk. It is essential that these take into account the complex surface and buried drainage systems of the area. (See Fig 1 above). 

 

p325 15.3.19  Surface water/Groundwater interactions  Desk based assessment using OS maps identified 30 potential springs. Six of these have been confirmed by inspection. there is no mention of Ingestre or Tixall.

 

p326 15.3.21 Groundwater dependant habitats We are pleased to see that it is acknowledged that both Pasturefields Special Area of Conservation (SAC) and Site of Special Scientific Interest (SSSI), and Lionlodge Covert LWS which are high value receptors, are potentially groundwater dependent.

 

p330 15.4 Effects arising during construction

p330 15.4.2 Water resources and Water Framework Directive, WFD. We are extremely concerned that the proposed alignment passes right through the middle of a groundwater-dependent terrestrial ecosystem, GWDTE,  and then cuts deep into a primary aquifer that is almost certainly the source of the Artesian head that drives the brine springs at Pasturefields and Ingestre/Tixall.  What is so disturbing (and frustrating) is that HS2 Ltd's attention was first drawn to this as early as June 2013 and it has been restated many times since.  Regrettably, this information has been ignored.

 

p335 15.4.22 (Assessment of impacts and effects – Pasturefields SAC): We strongly disagree with this explanation for the source of salt water to Pasturefields SAC. The over-interpretation of limited available evidence has led, exclusively, to a shallow, near-surface, conceptual model of brine flow, whereas an artesian-driven deep ground-water origin is equally, if not more, likely. 

    Evidence, including a detailed report by the BGS has been presented to HS2 Ltd together with guidance on (and demands for) further work to better understand the hydrogeology.  This has all been ignored, no ground investigations have been undertaken and no attempt has been made to update the HRA screening report in the light of the new evidence provided.  Consequently, the Proposed Scheme has evolved and been assessed on a misleading and unreliable basis.  

    The Proposed Scheme should be paused while the rationale for diverting the lower cost, lower impact, March 2012 route HSM03, away from Pasturefields SAC is re-examined. 

 

p336 15.4.24 and p337 15.4.33 Flood risk and land drainage. We strongly disagree that Pasturefields SAC will not be affected by the proposed scheme.  For all the reasons previously stated, every aspect of the Proposed scheme, roughly between Ch 206+000 and Ch 207+000 needs to be re-evaluated. 

      More appropriate is to review the original decision to divert the route away from the March 2012 HSM03 route.

 

p338 15.4.37  We welcome further hydrogeological surveys of the area around the existing saltmarsh at the south-western end of Lionlodge Covert. However, this should also cover the source of supply to Pasturefields SAC which we believe will be seriously compromised by the proposed scheme.

 

Question 4: Please let us know your comments on Vol. 3: Route -wide effects

   Many of the topics in this volume have been covered already in our responses to question 3. However, we would like to make the following additional comments.

 

p42      7    Ecology and Diversity

7.2.4   "Pasturefields Salt Marsh SAC is located to the east of Ingestre, approximately 870m north of the route of the Proposed Scheme and approximately 60m west of a construction traffic route along the A51 Lichfield Road. The HRA screening report and addendum for this site concludes that there will be no likely significant effect due to the Proposed Scheme." We strongly contest this, using evidence from the British Geological Survey and Envireau Water, previously sent to HS2.

Current & Historical Extent of Ingestre/Tixall Salt Marsh

 

    It is difficult to locate potential springs, from E116 Water resources assessment (WR-002-002) which only shows springs at: G6, east of Tixall Farm; Potential spring, G5, Home Farm; Potential spring, F7,  Blackheath Covert . The map kindly forwarded by Mr Simon Dale-Lace - HS2 Hydrogeologist confirms that HS2 is not aware of any springs in the area around Lion Lodge Covert, contrary to the map above, previously sent to HS2 by Mr M.Woodhouse, below, which suggests the presence of springs near Congreves Plantation, Ingestre Village, Flushing Covert and at Saltspring Pool in Lion Lodge Covert:

      In addition to these springs, we believe that the presence of the Tixall Fault has a significant effect on drainage in this area, and in particular its effect on Pasturefields SAC.

 

p46 7.3.7  Lists the most notable habitat losses that will occur as a consequence of the construction of the Proposed Scheme, including the loss of approximately 1.5ha of inland saltmarsh.

   We believe that the historic saltmarsh by Lionlodge shows greater biodiversity than Pasturefields SAC.

 

    We note with concern the loss of bats during the construction and operation of HS2. p48 Section 7.4.3-5, and the adverse effect on Barn Owls, p51 Section 7.4.25.

              

Transport effects

     We are very concerned at the effects of "Traveller Stress" on the residents of Ingestre and Tixall during construction of HS2 over Hoo Mill crossroads and along the Tixall Road to Blackheath Lane.

p64 8.5.18 "Government guidance140 has identified 'traveller stress' as an outcome of transport delays and disruption, affecting both drivers and public transport users. This comprises feelings of discomfort, annoyance, frustration or fear, culminating in physical and emotional tension that detracts from the quality and safety of a journey. Factors influencing traveller stress include fear of potential accidents, journey time and route uncertainty."

 

p64  8.5.19  notes: "The Volume 2, community area 1–5 reports, Section 14, Traffic and transport, describe the impacts on the local road network during the construction of the Proposed Scheme. Delays will be caused by increased traffic flows, temporary road or lane closures and associated diversions, temporary signals and speed restrictions. This will lead to temporary increases in journey times on some routes, which may cause frustration for drivers. Additionally, temporary road closures and diversions will increase route uncertainty, and temporary large increases in the proportion of HGVs on some roads may increase fear of accidents. It is considered that the combination of these impacts will lead to temporary increases in the levels of stress experienced by drivers on the affected routes. Stress experienced during journeys is not expected to lead to an increase in levels of stress more generally. However, concerns about traveller stress may deter some people from travelling on the affected routes."

            There is no alternate route for residents of Ingestre.

 

Road safety

p64 8.5.20 Notes that: "Overall traffic flows affect the likelihood of accidents occurring, and the HGV content of traffic can affect road safety, particularly for pedestrians, cyclists and equestrians."

   Ingestre Riding Stables and the numerous other local horse owner/riders use the local roads, and Tixall Road is used extensively by cyclists, including cycle clubs, and runners training for various marathons. It is already too dangerous for regular use by walkers because of the blind bends and blind summits. We would urge HS2 to use an alternative haul route along the line of the track as soon as possible.

  We are pleased to see that " Contractors will be required to gain accreditation from the Fleet Operator Recognition Scheme 142, or equivalent, in order to demonstrate that all drivers have appropriate training in pedestrian, equestrian and cycle awareness and specific issues relating to driving on rural roads," but doubt that this will be sufficient to avoid serious accidents.

  We strongly disagree with the statement in 8.5.23 that "no specific locations have been identified as having a quantifiable increase in the risk of accidents."

 

p65    8.6 Effects during operation

p66 8.6.3. We are concerned at the potential Health burden of noise within the study area and refute the claim  that "By comparison to existing ambient sound levels, exposure to noise levels from the proposed scheme will be comparatively small." This is partly due to the use of the LpAeq which averages out short bursts of intense noise. This will have a particular health impact on sleep.

    This is especially so as no houses in Ingestre or Tixall qualify for sound mitigation, despite E19 Vol.2 Map Book SV-02-106: showing a possible major adverse affect at  Lion Lodges (2), Hoo Mill Lane & Hoo Mill(5) and Tixall Manor Farmhouse (1). And a possible moderate adverse affect at  Tixall Farmhouse,(3) and Tixall Court (12) and Lower Hanyards (2) SV-02-107.

 

p74      10 Landscape and visual

    The unique designed landscape heritage, associated landscape quality and prominent set piece/landmark buildings of Ingestre and Tixall will be significantly effected.

 

p77  10.2.11    The locally listed designed parkland of Tixall lies approximately 600m south of the Proposed Scheme and the registered park and garden at Shugborough Park lies approximately 800m south of the Proposed Scheme. Both parklands include prominent set piece buildings designed to be seen within the wider landscape and to take advantage of views out. These include Tixall Gatehouse and the Triumphal Arch, the Dark Lantern (a structure within the park which is also known as the ‘Lanthorn of Demosthenes’) and Shugborough Hall within Shugborough Park.

 

p77 10.2.12 Construction and operation of the Proposed Scheme (excavation and presence of the Brancote Hanyards South cutting) will impact on the setting of Tixall Park, as described within the Ingestre Park Sandstone Estatelands LCA (Volume 2: community area 2 report, Colwich to Yarlet, Section 11).

We disagree with 10.2.13: "However, as these effects are localised and would not materially impact on the quality          of the overall designed landscape heritage of the AONB or any of the prominent landmark buildings or set pieces within the designed landscapes, they have not been considered further in the route-wide effects assessment.

    In fact E19 Vol 2 Map Book for CA2 shows significantly affected viewpoints at: Hanyards Lane by Crab Covert (010-04-007 LV-03-212); on Tixall Road by Tixall Gatehouse (009-03-019), on the Tixall Bridleway  between Tixall Park Pool and Upper Hanyards (010-03-005) and at the entrance to Ingestre Manor Farm on Ingestre Road (009-02-16 LV-03-211). None of these viewpoints are covered by photomontages. In fact there are no photomontages from any location in Tixall or Ingestre.

                                                                                 

p78 10.2.18 The setting of the AONB is discussed in general terms within the landscape policy section of the AONB Management Plan. Reference is made to the conservation and enhancement of the AONB’s distinctive landscape character including ‘views into and out of the area’ and the ‘fixed point photography project’ to capture information from specific vantage points on landscape and visual change over time. This includes Viewpoint 009-03-019 by Tixall gatehouse on the edge of the AONB.

 

p78 10.2.19  notes that the Trent Valley and parklands, such as Ingestre and the wider Tixall Park, are located outside the AONB but reflect the characteristics and special qualities of the AONB, and therefore contribute to its setting. This appears to have been ignored by HS2.

 

p78 10.2.21 notes that:"Construction and operation of elements of the Proposed Scheme such as the Great Haywood viaduct, associated embankments and Brancote Hanyards South cutting will give rise to localised landscape impacts in relation to the AONB and its setting at Tixall and Ingestre." 

 

Question 5: Please let us know your comments on Vol. 4: Off-route effects

  We are concerned that the passenger service to and from Stafford will be less frequent than at present, and any time saving on the journey to London will be insignificant.

p11 Off-route railway stations does not consider Stafford, only Preston and Warrington Quay.  Apparently Stafford was considered in the Phase 1 Environmental Statement, p8 Section 2.2.10). We believe to should have been considered in the current consultation.

 

p29      5          Off-route highway modifications

   We note that three passing bays and localised widening will be carried out on the Tixall/Gt Haywood Rd, but no attempt has been made to overcome the problems of using the Tixall Road between Tixall Village and Blackheath Lane, which will give rise to significant traffic hold-ups and significantly reduced road safety with vehicles trying to pass at blind corners and blind summits (p30 Section 5.2.2 and p31 Sections 5.2.6 and p38 Section 5.3.53-56).

p38 5.3.58 notes that: "These highway modifications have the potential for significant cultural heritage, ecology and landscape and visual effects", which we deplore.

   This will also have a significant effect on the Cultural Heritage especially on the Tixall Conservation Area:

 

p39 5.3.59 notes that important elements of the area's historic significance including the interrelationships of different historic structures and landscape features, such as parkland, within it, as well as outward views, notably south-eastwards across the Sow Valley will be affected.

  Tixall Gatehouse (COY070), is a Grade I listed building and a heritage asset of high value. It is located approximately 100m north of Great Haywood Road, where minor widening is proposed. Significant aspects of its setting include its relationship with the former site of Tixall Hall and the surviving stables, and the south-easterly views across the Tixall Wide (a landscaped section of the Staffordshire and Worcestershire Canal (COY040)) and the Sow Valley; and Tixall Farm and Tixall Bottle Lodge, Grade II listed buildings (COY067). As previously noted, Viewpoint (009-03-19 LV-03-211) is just outside Tixall Gatehouse and is adversely affected this is endorsed in Section 5.3.66 p40.

 

p40 5.3.64  We note with concern that:"The widening of Great Haywood Road to the north of the Church of St John the Baptist (COY155) will involve the removal of approximately 0.1ha of mature woodland, which will change the historic context of the road and graveyard boundary, although there will be no direct impact on the graveyard itself. The road widening works will introduce additional activity and movement into the normally peaceful village core."

       Already one potential house sale in Tixall Village has fallen through due to concern about the impact of HS2 on traffic through the village. Section 5.3.65.

      It is not clear how the road modifications will be temporary with no permanent effects, Section 5.3.68, when it has already been noted above that 0.1ha of mature woodland will be removed.

 

Ecology      Assessment of impacts and effects

p41 Section 5.3.74 notes that: "Great Haywood Tixall Road has characteristics of a historic route, such as banked hedgerows and mature standard trees. This may indicate that the hedgerows meet both landscape and ecological criteria as ‘important’ as described in the Hedgerows Regulations 199728. In the absence of detailed survey information, it is assumed, on a precautionary basis, that the hedgerows do meet the criteria as ‘important’, and are species-rich. The permanent loss of approximately 450m in length of hedgerow will represent a permanent adverse effect of significance at district/borough level."

 

p42 5.3.75 "There will be a loss of mature trees along Great Haywood Tixall Road that are potentially veteran or ancient trees. Veteran or ancient trees are an irreplaceable resource, the loss of which will result in a permanent adverse effect of significance at district/borough level."

 

p42 5.3.76       "The removal of mature or veteran trees that have the potential to support roosting bats, as well as the removal of good quality woodland foraging habitats and commuting routes along hedgerows, has the potential to result in a permanent adverse effect on the local bat population. On a precautionary basis, in the absence of detailed survey information, it is assumed that bats are present within the mature trees on Great Haywood Tixall Road and that this will result in significant adverse effects at up to county level, depending on the types of bat roosts found to be present within the trees and historic buildings."

 

p42 5.3.77       "The mature trees on Great Haywood Tixall Road also have the potential to provide nesting opportunities for barn owl, and the adjacent agricultural landscape and river and canal corridor offer suitableforaging habitats for barn owl. On a precautionary basis, in the absence of detailed survey information, it is assumed that barn owl are present. The loss of barn owl nesting sites represents a permanent adverse effect of significance at up to county level."

 

p42 5.3.78       "The widening of Great Haywood Tixall Road to the north of the Church of St John the Baptist will result in localised loss of part of a small well-established woodland, approximately 0.7ha in total area. The unnamed semi-natural broadleaved woodland includes semi-mature and mature (potentially veteran) pedunculate oak, silver birch and ash. The loss of approximately 0.1ha of the well-established woodland will have a permanent adverse effect on the structure and function of the woodland and is significant at district/borough level."

 

p42 5.3.79       "The introduction of construction HGVs onto rural roads such as Great Haywood Tixall Road during the construction of the highway modifications has the potential to increase disturbance related impacts to bat populations roosting within mature trees and historic buildings adjacent to the road, and on barn owls hunting on road verges. This disturbance effect is assessed and reported in Volume 2,Community area 2, Colwich to Yarlet, Section 8 as it relates to construction of the Proposed Scheme as a whole in this community area."

  The rural qualities of the roadside landscape are important not only for local wildlife but also as an important factor in attracting visitors to the area. In addition to the two Landmark Trust Holiday Lets, there are a further 3 properties available for visiting tourists. The roadside landscape also contributes to the enjoyment and well being of day tourists, commuters and other local residents.

 

p42 5.3.80   It will take some time for newly planted replacement hedges to mature.

 

Landscape and visual    Environmental baseline

p43 5.3.86 "Great Haywood Tixall Road is within the Ingestre Park Sandstone Estatelands LCA, an area comprising the historic designed parkland of Ingestre and the designed landscape and deer park of Tixall Park, lying between the valley sides of the River Trent and the River Sow. Ingestre Park is the setting for the Jacobean Grade II* listed Ingestre Hall. Notable features of this parkland include boundary tree belts and coppices, the former Park Pool at Tixall and an early 20th century lime avenue at Ingestre."

 

p43 5.3.87       "Settlement comprises farmsteads and the historic villages of Little Ingestre and Tixall. Tixall is recognised as representing one of the special qualities of the Cannock Chase Area of Outstanding Natural Beauty (AONB), within which part of the Ingestre Park Sandstone Estatelands LCA falls.       

   There are numerous estate vernacular buildings including Tixall Mews. The Tudor Tixall Gatehouse is a distinctive local landmark. Overall, landscape value is judged to be high, as is landscape susceptibility and landscape sensitivity."

 

p43 5.3.88 "Great Haywood Tixall Road forms the approach to Tixall Gatehouse, which is within the AONB and the Ingestre Park Sandstone Estate lands LCA.[Landscape Character Area] It is a rural lane bounded to the north by historic woodland within the designed landscape of Tixall Park."

 

p59 5.3.89 "Visual receptor viewpoints in the vicinity include residents at Bottle Lodge and Tixall Court on the        Great Haywood Tixall Road near Tixall Gatehouse, a small number of residential properties on the eastern edge of Tixall village, and users of Tixall Bridleway 1, which intersects Great Haywood Tixall Road adjacent to Bottle Lodge, and Tixall Bridleway 0.1629, which crosses Tixall Park from north to south."   

[ Dairy Bridge to Upper Hanyards]

  It is therefore very surprising and unfortunate that there are no photomontages from viewpoints within either Tixall or Ingestre.

 

p45 5.3.97 "The loss of trees will be apparent due to the presence of new gaps in the views from residential receptors at Bottle Lodge and Tixall Court located on the Great Haywood Tixall Road near Tixall Gatehouse, as well as three residential properties on the eastern edge of Tixall village. The modification works will also be visible from several PRoW, notably Tixall Bridleway 1 and Tixall Bridleway 0.1629. However, due to the local and small scale nature of change in the general views, visual effects in operation year 1, 15 and 60 are assessed as either negligible or minor adverse (non-significant)."

    Without the benefit of photomontages in our opinion, views of the Trent Viaduct with sound barriers will be a serious intrusion on this rural landscape.

 

Summary of likely residual significant effects

p45 5.3.99 "The highway modifications will result in localised impacts on the Ingestre Park Sandstone Estatelands LCA during operation years 1, 15 and 60. This will not change the major adverse (significant) effect for years 1 and 15 and moderate adverse (significant) effect in year 60 reported in Volume 2. Visual effects during operation will be either negligible or minor adverse (non-significant)."

       Without the benefit of photomontages in our opinion, views of the Trent Viaduct with sound barriers will be a serious intrusion on this rural landscape.

 

 

Question 6: Please let us know your comments on Vol. 5: Technical Appendices CA2

  We have confined our observations to our own Area, CA2: Colwich to Yarlet, and these have been included where relevant in Question 3, our response to Vol.2 CA2 above.

 

 

 



NOTES ON THE MEETING OF INGESTRE WITH TIXALL PARISH COUNCIL & HS2 REPRESENTATIVES

held on August 22nd 2017

 

HS2 comments and amendments shown in italics

 

Present: Mr M.Sindrey, (Chairman), Mrs P.Brookes and Dr A.Andrews, representing Tixall

   Mrs S.Haenelt, and Mrs S.Lloyd representing Ingestre                                                                                                         

                      Mrs N.Woodhouse by invitation           

                                    Mr Richard.Johnson - Area Manager HS2 – West Midlands to Crewe  

                                    Mr Joe Wilson - HS2 Stakeholder Adviser – West Midlands to Crewe  

                                    Mr Simon Dale-Lace - HS2 Hydrogeologist

                                    Ms Laura Setright - HS2

                                    Mr Tim Buss - Hopton Parish Cllr

                                    Ms Sarah Mallen HS2 Project Manager for Staffordshire CC

 

      The chairman opened the meeting by acknowledging the huge role Michael Woodhouse had played in our HS2 deliberations over the last 4 years..

 

1. Introduction to the HS2 Timetable by Richard Johnson

            The HS2 Bill was deposited at Parliament on July 17th and papers for the formal consultation on the Environmental Statement and Equality Impact Assessment Report were sent out. These  consultations end on September 30th, and we are invited to submit our responses. The ES is a parliamentary consultation, while the EQIA is run by HS2.

            A separate firm, working for parliament will then report on these responses, taking about 4-5 weeks, i.e. probably to the end of October.

            The MPs will then review this report, probably to the end of November or later.

            There will then be a second reading and vote on the Bill, which will introduce a petitioning period of about 4 weeks, still to be confirmed by ministers, when we can register our wish to petition. [ Sarah Mallen will circulate advice on the petitioning process].

            The committee will then be formalised and will agree the order of petitions to be presented. This is likely to take till the end of 2018.

            Then in 2019, this whole process is repeated with the House of Lords, with the Bill eventually returning to the House of Commons around December 2019.

            HS2 works in the Phase 2a Bill require Royal Assent and can only be started after this.

            However Additional Provisions can be added as errors and anomalies will be being constantly updated, and changes made. eg. A tunnel was  extended in Phase 1 at this stage, and there were 4 other additional provisions for Phase 1.

            They hope to start construction in 2021 or earlier and complete by 2027.

            Environmental work including archaeology will commence after the Bill has been given Royal Assent, but some ground investigations such as boreholes and further surveys can be carried out earlier with access agreements from the relevant landowners. There will potentially be highways works and utilities works required in specific areas across the scheme.

 

            Soon after the last election, the new Transport Minister, Mr Paul Maynard, met with local MPs for the HS2 areas.  The Dept. of Transport Bypass Fund was identified as a key issue, which would enable relevant roadworks to be carried out in advance of HS2.

 

2. Inaccuracies and clarification of HS2 documentation which are likely to result in problems.

a)         Despite being repeatedly told by us the deep cutting is still called Brancote cf Hanyards in all the documentations. This no doubt arose because one version of Google Maps wrongly showed Brancote Farm at Upper Hanyards. We are concerned that lorries, etc. will try to go Brancote Farm which is some distance from the proposed cutting.

b)         Many of  the places in brackets from column “Description of Property” in Book of Reference are             misleading, eg. Under Tixall:-

                        15, 34, 46 & 85  Southwells  (Tixall Farm House) Should be Tixall Manor Farm

                        20, 28, 29, 41, 45 Bostocks  (Brancote Farm) Should be Kennels Farm

                        56  Madders (Tixall Heath) Should be Upper or Lower Hanyards Farm

c)  In    E101 Agriculture, forestry and soils data ES 3.5.2.2.1 4.1.2 Assessment of effects on holdings, and E14 ES 3.2.1.2 p106, there is no of Ingestre Wood. Both this and Lionlodge Covert are run commercially to provide income for the owners.

d) It was noted that the different greys in E4 Plans and Sections Volume 1: Plans  PLN 2.1  (A3 book) show different parcels of land.

e) P1, P2, P3 & P4 in Drawing C861-ARP-HY-DPL-000-120014 Sheet 1-28 refer to diversions ‘points’ of Public rights of Way.

f) It was agreed that the road between Mill Lane at Hoo Mill crossroads and Tixall Village should be called Tixall Rd and not Gt Haywood Rd. Tixall Rd then continues to Blackheath Lane        See pp84 and 88 in E113 Landscape and visual assessment and photomontages (LV-001-002) ES 3.5.2.2.11  and E12 Vol.4  Map Book . Off-route effects ES 3.4.2 (A3) Drawing CT-28-105 Environmental Baseline including Heritage Assets . These changes will be added to the Supplementary Environmental Statement, SES, list, but they will only be updated on the maps if there is an Additional Provision/SES change of the particular map.

g) E12 Vol.4  Map Book . Off-route effects ES 3.4.2 (A3)  Drawing CT-28-105 Environmental Baseline including Heritage Assets. The colours are confusing: Purple & Mauve  Non designated heritage assets and ?  Various greens Local Nature Reserve; Local Wildlife Site; Conservation Area and Woodland.

h) E78 ES 3.5.1.11Traffic and Transport TR-03-207 wrongly shows Hanyards Lane contnuing through Ingestre Wood. This should be the Black Drive.

i) Hoo Mill and 1-4 Hoo Mill Lane are all in Ingestre, not Gt Haywood

j) Tixall Church is adjacent to Tixall Rd not Hoo Mill Lane

k) It was noted that the Hoo Mill fingerpost would be removed and could then be relocated after consultation with the Parish Council

l) The trees in the Millennium Avenue of Horse Chestnuts along Hoo Mill Lane will need to be be replanted at a suitable location with their dedication plaques, after consultation with the Parish Council.

 

4. Importance of maintaining access to Ingestre and properties in Hoo Mill Lane 24/7, and to Ingestre Pavilion

            E7 Non-technical Summary ES 3 p55 Traffic and transport: Mitigation and monitoring says " Where new roads, public rights of way or bridges are required to cross the route, they will,       where reasonably practicable, be constructed in advance and offline so as to enable the         existing            route to continue in use until its replacement is ready to be brought into public use."

     It is essential that emergency vehicles can access Ingestre 24/7. Some concern was expressed as to what HS2 meant by reasonably practicable.

            It was suggested that HS2 might repair the River Bridge and resurface Trent Drive, as an alternative access to Ingestre, but this was strongly opposed by Mrs Haenelt, and no doubt some Ingestre residents.

             Richard Johnson said that alternative, temporary routes could be made if necessary.

     Access is also required to Ingestre Pavilion.

 

5. Transport Routes during Construction Phase (See E78 E3/5/1/11 CA2 Colwich to Yarlet )

The works along Great Haywood Road will be in place for the duration of construction to accommodate the safe passing of construction vehicles through Tixall and along the highway. Current swept path analysis has informed the design for localised widening and passing places to be introduced. Post construction highways will be returned to pre-construction layout and the highway boundary and hedges reinstates.

3 passing places provided either sides of bends to allow large construction vehicles to pull over to allow opposing vehicles to pass. These bays are 15m long with 2m tapers and 2m wide. Passing places are provided within the existing verge.

a)  Widening of Tixall Rd between Village and Tixall Farm.  E12      Environmental Statement.  Volume 4 Map Book. Off-route effects ES 3.4.2 (A3) Drawing CT-05-251 Construction Phase  INSET 4.  It is still not clear why the temporary modifications include the opening in Tixall Village to the Telephone Kiosk and the entrance to Kennels Farm and the Old Rectory.

Two passing places are shown on the wide verge, but the text says 3. They are at D4, E4 and I2

It is essential that the pavement between the entrance to Dairy Bridge and Tixall Mews, to opposite the Church Lychgate is retained. Many people park at the Village Hall and then walk across to Church.

Will the two Millennium Oaks by Tixall Gatehouse entrance be retained ?

This is covered in the Code of Construction Practice – Volume 4 describes that the CoCP sets out control measures to control effects on cultural heritage, ecology and landscape.

Where hedgerow / trees are lost it is proposed to plant replacements upon removal of the temporary works.

Also the CoCP requires the avoidance of unnecessary tree / vegetation removal and protection of existing trees where possible. The road widening by Malcolm & Sheila Sindrey’s wood is shown as a temporary modification. Will any trees be lost and if so will they be replanted. The Parish Council has also planted daffodills along the edge of the wood which will need replanting.

b) Tixall Village to Traffic Lights by Crematorium. E14         Community Area Report Vol.2  CA2: Colwich to Yarlet (A3) ES 3.2.1.2  Public Transport Network p302       14.3.11 There is no mention of Tixall and Haywood buses. There are also several regular school bus services.

The road is used by far traffic which at certain seasons is considerable.

Tixall Rd is used extensively by cyclists, especially at weekends. There are several sections of the road where it is not safe to pass cyclists due to blind bends or blind summits.

Sarah Mallen said that Staffordshire Highways have noted that there is a problem with the use of Tixall Rd by HS2 HGVs and are asking for haul routes to be used along the line of HS2 wherever possible.

HS2: When referencing four bus corridors, these include those corridors which cross the line of route. The Volume 5 Appendix: Transport Assessment outlines the bus routes that have been considered, which include buses serving Great Haywood, Little Haywood and Tixall. Where significant effects have been identified as a result of increased construction traffic (congestion and delay) bus services would also be impacted by the effect, along with all road users.

 

Hours of operation are outlined in the draft Code of Construction Practice (CoCP) they are 08:00 -18:00 weekdays and 08:00-13:00 on Saturdays. Limited construction traffic on weekends.  A moderate adverse effect has been identified as a result of traffic related severance for non-motorised users i.e pedestrians/cyclists (more difficult for NMUs to cross the road) on Great Haywood Road/Tixall Road as a result of an increase in HGV traffic. HS2 are in discussion with Staffs CC to discuss further mitigation measures and construction traffic routes.

c) HGVs turning in and out of Hanyards Lane onto Tixall Rd in path of vehicles turning left from Blackheath Lane when lights change.

HS2: A maximum of 86 average daily two-way HGV traffic has been assessed using Hanyards Lane for site set up and servicing until the site haul road is in place from the A518.

 

E110 Health Assessment matrix (HE-001-002) ES 3.5.2.2.9 States "Increased risk of road traffic accidents associated with increased traffic flows. Risk is considered low as there are no locations where elevated baseline accident rates coincide with changes of greater than 30% in average daily traffic flows".

 However, in E14        Community Area Report Vol.2  CA2: Colwich to Yarlet (A3) ES 3.2.1.2 p311 Accidents and safety there is no mention of Hanyards Lane/Tixall Rd junction.

HS2: Significant effects relating to accidents and safety are identified if there is a cluster of nine (or more accidents) in a three year period. Accident data was provided by Staffordshire County Council. Although there is a greater than 30% increase in average daily traffic flows this does not trigger a significant effect, as there is no accident cluster identified for Hanyards Lane/Tixall Road junction.

 

HS2 are in discussion with Staffs CC to discuss further mitigation measures and construction traffic routes.

 

The Code of Construction Practice (CoCP) requires HS2 to develop a route-wide traffic management plan, which includes the requirement for the main works contractors to develop a local traffic management plan. The LTMP will provide detailed information on temporary traffic management measures and construction routes.

 

It was suggested that a roundabout or filter lane could be introduced at this problem crossroads using the Dept. of Transport Bypass Fund.

d) It was noted that it will be essential that there is an integrated plan for any road closures, unlike in the recent past.

6. Sound impact on local residents

E7 Non-technical Summary ES 3 p46: Sound, noise and vibration: Mitigation and monitoring. "In some locations it has not been possible, notwithstanding the application of mitigation measures, to avoid an increase in community noise levels. Residual effects will occur at a number of residential areas and non-residential buildings that are located closest to the construction activities.

According to HS2 approximately 39 residential properties are predicted to be significantly affected by noise from the operation of the railway, however, it appears there are only 25 in Ingestre and Tixall. Residential properties which are predicted to experience significant observed adverse effects from noise from the operation of the railway will be offered a noise insulation and ventilation package. If this is accepted by the owner, this will avoid significant effects on those living within the property.

Operation of the railway has been predicted as likely to result in increases in external noise that are considered significant around a limited number of residential areas and non-residential buildings. These effects occur mainly within 300m of the route."

It was confirmed that the operational noise levels included the mitigation effects of sound barriers along the line, eg. over the viaduct across the Trent Valley.

E19 Vol.2 Map Book . ES 3.2.2 (A3) SV-05-106 and SV-05-106 Operational Noise and Vibration Impacts and Likely Significant Effects and E77 Sound Noise and Vibration ES 3.5.1.10 SV-02-106 and SV-02-107 are difficult to understand. It is not clear what the black box outlines with some red blobs represent,, eg. "where LpAF max exceeds 60 dB façade". The black box just outlines where the outside of a property exceeds 60dB, the coloured blobs (red, orange, yellow, white and green) relate to the airbourne sound impacts at the building as shown in panel B on the drawing (i.e. is the effect major adverse, negligible etc)

The plans also show the difference between Day and Night noise, as the baseline at night is likely to be lower:

SV-02-106: More than 10dB  - Possible major adverse affect:  Lion Lodges (2), Hoo Mill Lane & Hoo Mill(5) Tixall Manor Farmhouse (1)

Night 40-55dB and Day 50 -65dB, 5 – 10dB – Possible moderate adverse affect  Tixall Farmhouse,(3) Tixall Court (12)

and SV-02-107:           5 – 10dB – Possible moderate adverse affect  Lower Hanyards (2)

We asked whether all properties listed above will be eligible for the noise insulation package and what form will this take. Sarah Mallen said she would send us some information on this.

 

7. Historic Saltmarsh

            E116 Water resources assessment (WR-002-002) ES 3.5.2.2.14 p15  It is difficult to locate potential springs, e.g.: G6, east of Tixall Farm; Potential spring, G5, Home Farm; Potential spring, F7,  Blackheath Covert . Simon Dale-Lace - HS2 Hydrogeologist promised to send us more details of the springs.

p30  Pasturefields SSSI and SAC. Effect of Gt Haywood viaduct and Trent North             embankment. "Surface water drainage pathways, show that Pasturefields is up hydraulic gradient of the route of the Proposed Scheme." Simon said this referred to the groundwater in the River Terrace Deposits flowing to the river on top of the Mercia mudstones.

He caused confusion by referring to the 1979 paper about a geophysical investigation which indicates the continuity of the Tixall fault and an area of saline water rather than the 2017 Envireau Report (which utilises the 1979 investigation). When this had been cleared up, he went on to say that they were currently preparing a report on the logic and outcomes of the Envireau report, and did not believe it would effect HS2's previous conclusion that Pasturefields SAC would not be effected, and no "Appropriate Assessment" was required. This report would be vetted by Natural England and the Environment Agency and then forwarded to Parliament and Tixall and Ingestre Parish Councils. HS2 would need the approval of Natural England and the Environment Agency for any detailed proposals which could impact upon Pasturefields. The "Appropriate Assessment" under EU rules would only be required if there was a level of uncertainty.

p31 Lionlodge Covert LWS (Tixall Saltmarsh).

Mitigation could include diversion of the current salt springs (as yet unsurveyed due to land access constraints -This could be on Mr Southwell or William Fields land) to the north of the route of Proposed Scheme to recreate the saltmarsh in a different location as compensation.

p33 5.2.4 "Within the Sherwood Sandstone Group, where it outcrops, the recorded depth to groundwater is 10 mbgl or approximately 97.5m AOD. The maximum depth of the cutting in this section is 13.3m. There is no currently available information on groundwater elevations within the Mercia Mudstone Group. It has therefore been conservatively assumed that groundwater levels within the Mercia Mudstone Group are a ground level and therefore that groundwater flow within the Mercia Mudstone Group may be affected by the cutting. There may therefore be an effect to groundwater from dewatering of the cutting in both the Sherwood Sandstone Group and the Mercia Mudstone Group."

Concern was raised by the Councilsthat lowering the water table due to the deep cutting could reduce the water available for trees in Ingestre Wood and other local crops. Simon Dale-Lace explained that there was no impact expected. More detailed ground investigation would be gathered in due course, and if required then any impacts could be fully mitigated by  either lining the walls of the cutting so that it was water tight, or reinject the water to the surrounding area. They aimed to minimise the effect beyond the width of the cutting.

 

8. Workers Temporary Accommodation by Haywood Marina

A local resident was concerned at the possible increase in local crime due to the presence of these workers. Sarah Mallen reported that as far as possible the workers would come from the local area, alongwith any companies and contractors, etc. in order to maximise the economic benefit to Staffordshire.

 

The chairman thanked everyone for attending and contributing to the discussion and the meeting ended at 8.30pm




Ministerial Reply

Reply from
                  Minister

Letter from Jeremy Lefroy MP
requesting meeting with Minister, 15th June 2017:

Letter from Jeremy Lefroy
                    p1
Letter from Jeremy Lefroy
                    p2

Hydrogeological Assessment by Envireau Water


1  INTRODUCTION

A proposed 20km-long section of HS2 - Phase 2a, referred to as Route C, in Staffordshire lies to the south of Pasturefields Salt Marsh SAC and has been justified based on an HRA Screening Report (ERM, 2012) which concluded that routes to the south would have no adverse effect on the SAC and could be screened out of requiring an Appropriate Assessment.

Ingestre with Tixall Parish Council (the Parish Council) believe that the decision not to undertake an Appropriate Assessment is based on a flawed conceptual hydrogeological model which fails to recognise alternative sources of salt water or wider controls on the local hydrogeology.

In addition, a key feature not recognised in the original Screening Report (ERM, 2012), is the existence to the south of Pasturefields Salt Marsh SAC of additional historic salt marshes in Ingestre and Tixall which may have important links to the SAC. The proposed diverted route of HS2 crosses the Ingestre/Tixall salt marsh. This historic salt marsh was formally documented in 2015 and is now designated as a Site of Biological Importance (SBI).

Envireau Water has been commissioned by Ingestre with Tixall Parish Council to review the hydrogeology of Pasturefields Salt Marsh SAC and Ingestre/Tixall Salt Marsh SBI to better understand the potential sources of high salinity groundwater feeding the marshes. In doing this a conceptual model has been developed; and using this conceptual model, how the proposed HS2 alignment could impact on Pasturefields SAC has been considered.

Envireau Water is a specialist hydrogeological consultancy established in 1998 with considerable experience in the preparation and presentation of hydrogeological impact assessments associated with large developments. The lead author of this report, James Dodds, has some 30 years of experience of hydrogeological consulting and the assessment of impacts from a wide range of developments. He is a Chartered Geologist and has provided expert evidence both within the planning and litigation arenas.


2 SITE DESCRIPTION

 

2.1 Pasturefields Salt Marsh

Pasturefields Salt Marsh was designated a Site of Special Scientific Interest (SSSI) in 1986 followed by a designation of Special Area of Conservation (SAC) in 2005 (SAC EU Code: UK0012789). According to the Joint Nature Conservation Committee (JNCC) it was the only known remaining example in the UK of a natural salt spring with inland saltmarsh vegetation.

The most recent condition assessment for Pasturefields Salt Marsh SAC, dated 09/03/2015, indicates that the site is in an unfavourable condition ‘…mainly because many of the saltmarsh axiophytes are at lower frequencies than they were at notification.’ The assessment indicates that the ‘…crucial underlying processes (including high saline conditions fed by ground-water) that support the saltmarsh might not be functioning properly.’ [https://designatedsites.naturalengland.org.uk/UnitDetail.aspx?UnitId=1014550&SiteCode=S1003939&SiteName=fields&countyCode=&responsiblePerson]

A study in 2004 by a hydrogeological consultancy stated that the ‘…reason for the emergence of the brines at this particular location is not clear from available data…’ (Chillingworth and Brown, 2004). Paragraph 6.1.2 of the HS2 Phase 2 HRA Screening report for Pasturefields Salt Marsh SAC produced by ERM (ERM, 2012) also refers to uncertainties in the hydrogeology of the site and states, ‘…the exact extent of the contributing groundwater catchment and saline geostrata are poorly understood and would, if necessary, require more detailed intrusive investigation to determine these more precisely.’

The HS2 Phase 2 HRA Screening report provides a hydrogeological conceptualisation, which is based on the previous work by Chillingworth and Brown (2004). A summary describing the source of the saline groundwater seepages taken from ERM, 2012 states:

“The brine springs emerge at the interface between the alluvium and the underlying River Terrace Deposits. The brine springs are fed by rain water recharge of groundwater reserves and that meteoric water filters into the ground to the northeast of the site (through River Terrace Deposits) and peat filled dissolution features near Amerton to recharge the underlying aquifer. Groundwater filters through the gravels and halite structures within the Mercia Mudstone, dissolving salts. Salinity is sensitive to groundwater residence time and dilution in the marsh and the central ditch, contributions to which are made from overspill from the Trent and Mersey Canal.”

The hydrogeological model presented by ERM (ERM, 2012) indicates a shallow groundwater source for the saline springs via rainfall falling on to nearby sands and gravels and reaching bedrock with halite before emerging at Pasturefields SAC. This contrasts with the findings of the British Geological Survey (BGS) (Banks, 2014) which indicate a much deeper (possibly 200m depth) source for the saline groundwater along fault zones rather than superficial sands and gravels.

 

2.2 Ingestre/Tixall Salt Marsh

Ingestre/Tixall Salt Marsh was designated as a Local Wildlife Site or Site of Biological Importance (SBI) in 2015 (Staffordshire Ecological Record designation reference no.: 92/84/70) and is located 1.5km northwest from the town of Great Haywood, Staffordshire, lying immediately south of a small wooded area called Lionlodge Covert. A saline spring, known as Salt Spring Pool is located at the southern edge of this wooded area.

Historical mapping suggests that the salt marsh once covered a larger area extending in to the woodlands to the north. However, installation of a field drainage system, pre-1900s, appears to have drained the area, reducing the size of the marsh. It is reported by the Parish Council that the water at the outflow of the drainage system has high salt content showing that the springs are still active.

The site has not been subject to any detailed hydrological or hydrogeological study or investigation thus, there is very little information available relating to the hydrology and hydrogeology of this site.

 

3 HYDROGEOLOGICAL SETTING

Based on local mapping by the British Geological Survey, BGS borehole log archives and literature sources, the hydrogeology of the area is characterised by the following key elements:

 

River Terrace Deposits, 1 – described as Quaternary sand and gravel, locally with lenses of silt, clay or peat. There are no data or information to determine this unit’s thickness or groundwater levels in this unit. It is likely that these deposits are around 5m thick; underlain by:-

 

Mercia Mudstone Group – described as dominantly red, less commonly green-grey, mudstones and subordinate

siltstones with thick halite (salt)-bearing units. The Mercia Mudstone Group in this area contains the thin beds of gypsum/anhydrite which are widespread; as well as thin sandstone units. There are no data or information to determine this unit’s thickness or groundwater levels in this unit at the SAC. It is likely that this unit is >40m thick and possibly up to 140m thick based on interpretation of limited geological data; underlain by:-

 

Bromsgrove Sandstone Formation – comprising red, brown and grey sandstones, commonly pebbly or conglomeratic at the bases of beds, interbedded with red and brown siltstones and mudstones. The overlying Mercia Mudstone Group grades in to the Bromsgrove Sandstone Formation and the boundary is taken as when sandstones dominate the layered sequence of mudstones and sandstones. A BGS cross section in this area indicates that this unit is likely to be around 30m thick; underlain by:-

 

Kidderminster Formation – described as pebble conglomerates and reddish brown sandstones. The sandstones

are cross-bedded and pebbly. The conglomerates have a reddish brown sandy matrix and consist mainly of pebbles

of brown or purple quartzite, with quartz conglomerate and vein quartz. A BGS cross section in this area indicates Ingestre/Tixall Salt Marsh and the surrounding area lie on the easterly dipping limb of a syncline. Strata are dipping around 10⁰ to the east.

 

Figure 1 is a map showing the geological information for the area, and Figure 2 is a geological cross section produced as part of this study and based on the readily available information and the geological map shown on Figure 1.

 
Geological information
                      for the area

 

Geological cross section of
                the area


The Bromsgrove Sandstone and Kidderminster form part of a major aquifer system often referred to as the Sherwood Sandstone Group aquifer. The overlying Mercia Mudstone Group has a generally lower permeability and forms a sealing (confining) layer above the Sherwood Sandstone Group aquifer. This can often lead to artesian conditions, where the water pressure (potentiometric surface) in the sandstone is close to or above ground level, resulting in the potential for upward flow, and if a flow path exists, the flow of groundwater out on to the surface via springs or wells. The low-lying areas of the River Trent valley are where the potentiometric surface is likely to be above ground level. Therefore, it is likely that water from upwards groundwater seepage occurs into the River Trent valley and associated superficial deposits in this area.

 

Figure 3 shows various data sets overlain on the geological base map. It has been postulated by others that faults may have an influential role in the location of the saline springs and controlling saline groundwater occurrence in this area (Barker, 1979 and Banks, 2014). Figure 3 shows the location of Ingestre/Tixall Salt Marsh on the extension of the Tixall Fault to the north. The postulated position of the Tixall Fault on the published BGS geological map does

not extend beyond the superficial cover. This is common, as the superficial cover hides the expression of the fault at surface, but it would be expected that the fault line would continue in the underlying bed rock geology. A Vertical Electrical Sounding (VES) geophysical survey in the area carried out in 1979 provides evidence that the Tixall Fault extends at least a further 1km to the northeast (Barker, 1979), thus running alongside Ingestre/Tixall Salt Marsh.


Geological base map with
                  additional data


The survey results have been plotted on Figure 3 which show saline water occurring in the area between the River Trent and the Tixall Fault, with the western extent of the saline groundwater being truncated by the fault. The northern extent of the saline groundwater is defined by the edge of the survey, rather than a geological feature.

This significant pocket of saline groundwater which occurs in bedrock at 10m to 30m below ground level and crosses the Mercia Mudstone Group, Bromsgrove Sandstone Formation and the Kidderminster Formation (Figure 3), is not fully understood. Particularly why this saline groundwater pocket occurs in the bedrock in this area, and why it should occur in the sandstone formations, given that halite beds are not present in the sandstone sequence.

This suggests that there is some other geological control other than direct seepage within the Mercia Mudstone Group beds or water moving along the top of the mudstone sequence. This wider saline groundwater occurrence is not described in any hydrogeological assessment presented by ERM on behalf of HS2 Ltd and its presence indicates that there are significant factors controlling saline groundwater flow in this area other than those described in ERM (2012).

Additional geophysical data (Bouguer anomaly contours) suggest that the Tixall Fault may extend a further 2km to the northeast beyond the village of Hixon (Barker, 1979) and therefore also runs alongside Pasturefields Salt Marsh SAC (See Figure 3).

 

The Barker (1979) work has not been referenced by HS2 in any of their assessments, and is an important element of the scientific data on which a conceptual model should be based.

It is known that where pathways exist, groundwater flows up from the Sherwood Sandstone Group aquifer and through the Mercia Mudstone Group, where it dissolves salt from the halite beds producing saline groundwater.

Regional borehole records (eg. the Trent Valley BH and BH140/256) provide evidence of Halite (NaCl) and Gypsum (CaSO4) (both readily dissolvable evaporite minerals) at depths as shallow as 45m. There is also strong evidence of collapse structures indicated by broken (brecciated) zones, which are caused by evaporite dissolution, which will increase the permeability of the mudstone and has the potential to create interconnecting pathways.

Based on the general hydrogeological setting and the location of the two salt water marshes, it is considered that a fractured zone associated with the Tixall Fault acts as a preferential groundwater flow route for groundwater from the confined Sherwood Sandstone Group aquifer at depth to circulate in the Mercia Mudstone Group mudstones, subordinate sandstone layers and evaporite beds. As groundwater flows through the fracture zone it encounters interbeds of halite which it dissolves resulting in saline groundwater. This saline groundwater continues upwards to the ground surface driven by the confined hydraulic groundwater head, and results in saline seepages at Pasturefields Salt Marsh SAC and Ingestre/Tixall Salt Marsh SBI (See Figure 3 and Figure 4), and more broadly flows into the River Trent gravels, as identified by Barker (1979). The presence of saline water in the Sherwood Sandstone Group, where it is not overlain by superficial deposits, provides evidence that the saline groundwater can not only move vertically up the fault, but also along the strike of the fault zone and out into the sandstone. Therefore, it is considered likely that the saline groundwater seepages/springs at both Pasturefields Salt Marsh SAC and Ingestre/Tixall Salt Marsh SBI have a common source and groundwater catchment, associated with the Tixall Fault.


Conceptual Hydrogeological
                    Model


Furthermore, it is considered that any impact to groundwater along the trajectory of the Tixall Fault has the potential to impact the groundwater seepages/springs at both Pasturefields Salt Marsh SAC and Ingestre/Tixall Salt Marsh SBI.

 

4 ASSOCIATION WITH HS2

There are two significant associations between Route C and the salt marshes. The first is the construction of an embankment across the Ingestre/Tixall Salt Marsh SBI together with the Great Haywood viaduct across the Trent flood plain both of which require significant piling, and the second is the construction of a cutting known as the Brancote South Cutting, which will intercept groundwater flow. These are discussed in the sections below.

4.1 Piling

The proposed HS2 Route C (preferred route) passes directly through Ingestre/Tixall Salt Marsh SBI and crosses the Tixall Fault. The Great Haywood Viaduct straddles the Tixall fault and aligns with the zone of maximum salinity as mapped by Barker (Barker, 1979), and the embankment to the west is located on the SBI. As a result, much of the SBI will be lost underneath the proposed railway embankment. Appendix 4 of the HS2 Phase 2 HRA Screening report (ERM, 2012) presents a technical note indicating various proposed designs for the construction of railway embankments in this area. Three of the four designs include a pile supported embankment using concrete piles driven in to the bedrock where salt dissolution features may be present or where there is significant brine flow.

The pile design is yet to be finalised and is dependent on ground conditions. However, it is reasonable to assume that the proposed piling operations will intersect high permeability fracture zones associated with the Tixall Fault.

The Great Haywood Viaduct will also be built on piled foundations, which will be constructed not only into the Tixall fault zone but also the high salinity groundwater mapped by Barker. Neither of these issues is discussed in the reporting which has reviewed.

 

Installation of concrete piles in to the Mercia Mudstone Group bedrock at Ingestre/Tixall Salt Marsh SBI and Tixall fault has the potential to:

· Create areas of zero groundwater flow in the fractured zones associated with the Tixall Fault thereby resulting in a derogation of groundwater flow through the fractured zones. This may manifest itself as a reduction or diversion in saline groundwater seepage flow to the Pasturefields Salt Marsh SAC and/or the Ingestre/Tixall Salt Marsh SBI. Such a derogation in groundwater flow has the potential to affect the hydrochemistry of the saline seepages/springs;

· Infill highly permeable subterranean salt dissolution features or cavities which may be present resulting in a derogation of groundwater flow. This may manifest itself as a reduction or diversion in groundwater seepage flow to the Pasturefields Salt Marsh SAC and/or Ingestre/Tixall Salt Marsh SBI. Such a derogation in groundwater flow has the potential to affect the hydrochemistry of the saline seepages/springs;

· Affect the hydrochemistry of the groundwater seepages to the Pasturefields Salt Marsh SAC and/or the Ingestre/Tixall Salt Marsh SBI in the short-term during construction, and in the long-term from railway operations/maintenance and potential leaching of materials used in the piles. It is not clear from the HS2 Phase 2 HRA Screening report what methods and materials are proposed to prevent sulphate and chloride attack of any pile supports and what, if any, potential impacts these may have on the groundwater hydrochemistry.

 

4.2 Brancote South Cutting

The embankment that crosses the Ingestre/Tixall Salt Marsh SBI and Tixall fault, as discussed above, transitions into a deep cutting (Brancote South) immediately to the west of the SBI. In the draft EIA (HS2, 2016) HS2 Ltd acknowledge that the cutting will have a severe adverse impact on the local water table. Taking account of the need for ballast and sub-base below the track, as well as the track height, the actual depth of cutting is estimated at some 19m at the deepest point. HS2’s own assessment shows that the cutting will drain groundwater. The effects of the drainage will propagate away from the cutting and reduce the groundwater pressure (head) within the Sherwood Sandstone Group aquifer. Given the importance of the pressure (head) in the sandstone with respect to driving the deep saline groundwater flow paths, small changes in head could have significant effects on the rate of flow from the saline springs.

 

Thus, the construction and drainage of Brancote South Cutting has the potential to:

· Directly impact on the water balance at the Ingestre/Tixall Salt Marsh SBI, and thus affect the salinity balance in the salt marsh.

· Directly impact on the groundwater pressure (head) in the Sherwood Sandstone Group aquifer and therefore on deep saline groundwater flows to Pasturefields SAC.

 

5 SUMMARY FINDINGS

The key findings from this assessment are:

  • The Pasturefields Salt Marsh SAC has been recently assessed by Natural England as being in an unfavourable condition.

  • Uncertainty remains on the exact controls of why saline spring seepages occur at Pasturefields Salt Marsh SAC and Ingestre/Tixall Salt Marsh SBI.

  • There is a significant pocket of saline groundwater which occurs in bedrock at 10m to 30m below ground level and crosses the Mercia Mudstone Group, Bromsgrove Sandstone Formation and the Kidderminster Formation (Barker, 1979). It is not fully understood why this saline groundwater pocket occurs in the bedrock in this area or why it should occur in the sandstone formations given that halite beds are not present in these sandstone formations. This suggests that there is some other geological control other than direct seepage from the Mercia Mudstone Group beds. This wider saline groundwater occurrence is not described in any hydrogeological assessment presented by ERM on behalf of HS2 Ltd. Its presence indicates that there are significant factors controlling saline groundwater flow in this area other than those described in ERM (2012). One explanation may be upwelling saline groundwater feeding the saline springs, with saline water being distributed by drainage through superficial deposits and surface drainage. These mechanisms have not been considered by HS2 Ltd.

  • The Tixall Fault appears to control the western extent of the pocket of saline groundwater (See Figure 3) (Barker, 1979).

  • Geophysical data (VES resistivity and Bouguer anomaly contours) indicates that the Tixall Fault extends much further northeast compared to the BGS map and therefore runs alongside both Ingestre/Tixall Salt Marsh SBI and Pasturefields Salt Marsh SAC.

  • The BGS state that ‘evidence from BGS records suggests that the springs are likely to be fed (at least in part) by artesian water focusing and rising on faults from the underlying Sherwood Sandstone Group and dissolving salt as it rises’ (Banks, 2014). The BGS’s conceptualisation is consistent with additional information obtained and interpreted as part of this report.

  • The hydrogeological conceptualisation of the controls of saline spring flow presented by ERM on behalf of HS2 Ltd. suggests a shallow groundwater source. This conceptualisation is not consistent with additional information obtained and interpreted as part of this report nor consistent with the findings of the BGS (Banks, 2014).

  • The construction of the Trent North Embankment and the Great Haywood Viaduct has the potential to significantly, directly impact on the Ingestre/Tixall Salt Marsh SBI and indirectly impact on the Pasturefields Salt Marsh SAC.

  • The construction and drainage of the Brancote South Cutting will affect the groundwater pressure (head) in the Sherwood Sandstone Group aquifer which controls the deep saline groundwater flow, and thus has the potential to significantly affect the Pasturefields Salt Marsh SAC.

  • It is considered necessary to undertake further geological investigation and interpretation of the hydrology and hydrogeology of both salt marsh sites given that:

  • despite previous studies there remains significant uncertainty relating to the hydrogeological controls of the saline groundwater seepage at Pasturefields Salt Marsh SAC;

  •  there is a significant lack of geological and hydrogeological information relating to the saline groundwater see page at Ingestre/Tixall Salt Marsh SBI;

  • the Pasturefields Salt Marsh SAC has recently been assessed by Natural England in 2015 as being in an unfavourable condition. Modifications to the hydrological and hydrogeological regimes in the area may have a deleterious effect on the already unfavourable condition of this site;

  • the limited hydrogeological information available, and interpreted as part of this report, suggests that it is entirely feasible that a hydraulic connection may exist between the source of saline groundwater seepages at Pasturefields Salt Marsh SAC and the saline groundwater seepages at Ingestre/Tixall Salt Marsh SBI. Any activities which may affect groundwater quality, levels or flow at one site has the potential to impact on the groundwater quality, levels or flow at the other site;

  • The Tixall Fault appears to exert some control over the occurrence of a pocket of saline groundwater to the south of Ingestre/Tixall Salt Marsh SBI. The Pasturefields Salt Marsh SAC is also associated with the Tixall Fault. The role of the faults in this area in either controlling or routing saline groundwater flow is not clear from information available and requires further investigation;

  • There is evidence that the extent of the faults mapped by the BGS in the area are not fully delineated. VES results presented by Barker (1979) and a Bouguer anomaly map of the area suggests the continuation of the Tixall Fault zone which is likely to run alongside both the Pasturefields Salt Marsh SAC and the Ingestre/Tixall Salt Marsh SBI. Given the likely influential role of faults in the area the delineation of faults is considered fundamental to forming a sound hydrogeological conceptualisation upon which a risk assessment may be based.

6 LEGAL SETTING

Appendix A provides a legal comment from Freeths LLP, specialist environmental lawyers. The following section, provides a summary of the comments.

If there is a risk that the HS2 development will have a significant effect on the Pasturefields Salt Marsh SAC, the proposal must be subject to appropriate assessment of its implication for the SAC, in view of the SAC’s conservation objectives. Failure to carry out an appropriate assessment in such circumstances renders the HS2 development unlawful.

A plan or project which, by itself or in combination with other plans or projects, is likely to have a significant effect on a Special Area of Conservation (SAC), must be subject to “appropriate assessment” of its implications for the SAC, in view of the site’s conservation objectives. (Article 6(3) of the Habitats Directive, which is transposed into domestic law by Regulation 61 of the Conservation of Habitats and Species Regulations 2010).

The Court of Justice of the European Union has made it clear that the Habitats Directive sets a low threshold for likely significant effects (Case C-127/02) Waddenzee [2005] 2 CMLR 31).

Reiterating that the Habitats Directive has to be interpreted in accordance with the precautionary principle, which is one of the foundations of EU policy on the environment, the court concluded that a project is to be subject to appropriate assessment “if it cannot be excluded, on the basis of objective information, that it will have a significant effect on that site …"

Quoting the above analysis from Waddenzee and describing the significant effects test as “an informal threshold decision”, the Supreme Court in England has confirmed that, in cases where it is not obvious, the competent authority will consider whether the "trigger" for appropriate assessment is met and that there should be an appropriate assessment “where the authority has found there to be a risk of significant adverse effects to a protected site” (Lord Carnwath in R (on the application of Champion) v North Norfolk District Council & Anor [2015] UKSC 52 (22 July 2015)(emphasis added).

The appropriate assessment demands a high standard of investigation. The relevant authority must be certain, in the light of the best scientific knowledge in the field, that the project will not have lasting adverse effects on the integrity of the SAC and “that is so where no reasonable scientific doubt remains as to the absence of such effects”.

(Lord Carnwath in Champion [2015] quoting from EU case C-258/11 Sweetman v An Bord Pleanála (Galway County Council intervening) [2014] PTSR 1092.)

 

7 CONCLUSIONS

The conceptualisation presented by ERM on behalf of HS2 Ltd and on which the decision to select HS2 route C, is not consistent with additional information obtained and interpreted as part of this report nor consistent with the findings of the BGS (Banks, 2014). The conclusion of the original HRA Screening report for Pasturefields Salt Marsh SAC, that possible routes to the south of the SAC can be screened out of an Appropriate Assessment is therefore scientifically unsound.

There remains significant scientific uncertainty relating to groundwater flow paths in the area and as a result there remains significant scientific uncertainty relating to the groundwater catchment of the Pasturefields Salt Marsh SAC and the Ingestre/Tixall Salt Marsh SBI. It is entirely plausible, and likely, that a significant proportion of saline groundwater flow comes from a deep flow path through the halite beds within the Mercia Mudstone, driven by the groundwater pressure (head) in the Sherwood Sandstone Group aquifer. Construction of the Brancote South Cutting in particular, will change the groundwater heads in the sandstone and has the significant potential to affect the saline groundwater flows at Pasturefields Salt Marsh SAC.

There remains significant scientific uncertainty relating to groundwater flow paths in the area due to a lack of groundwater level data.

In the case of HS2 Phase 2a in Staffordshire, it clearly cannot be excluded, on the basis of objective information, that HS2 Route C (the preferred route) will have a significant effect on the Pasturefields Salt Marsh SAC. On the contrary, objective information presented in this assessment indicates that there is a material risk that the route may have a significant effect on the SAC, and on that basis an Appropriate Assessment should be undertaken.

 

James Dodds MSc CGeol FGS

Managing Director, Hydrogeologist

 

8 REFERENCES

Banks, V., 2014. Review of HS2 Reports Pasturefields, Staffordshire. Unpublished letter report prepared for Ingestre and Tixall Parrish Council by the British Geological Survey, BGS Ref.: IDA‐CED 215722, 29th January 2014.

 

Barker, R.D., 1979. Geophysical surveys around Shugborough Park Staffordshire. Report Georun 10. Unpublished report prepared for Severn Trent Water Authority by Applied Geophysics Research Unit, Department of Geological Sciences, University of Birmingham, October 1979.

 

Chillingworth, G. and Brown, L., 2004. An assessment of the hydrogeological conditions at Pasturefields Saltmarsh SSSI. Unpublished report prepared for the Environment Agency by ESI Ltd, Report. ref.: 6271XR1D2, October 2004.

 

ERM, 2012. HS2 Phase 2 HRA Screening Report for Pasturefields Salt Marsh SAC. Unpublished report prepared for HS2 Ltd. by ERM, September 2012.

 

HS2 , 2016. Working Draft EIA Report, Volume 2: CA2, Colwich to Yarlet, 2016.


APPENDIX A

Legal Comment by Freeths

 

PASTUREFIELDS SALT MARSH SPECIAL AREA OF CONSERVATION

THE LEGAL REQUIREMENT FOR “APPROPRIATE ASSESSMENT”

 

Ingestre with Tixall Parish Council is concerned about the potential impacts of the preferred route (route C) for HS2 phase 2a on the Pasturefields Salt Marsh Special Area of Conservation.

Where there is a risk that a development will have a significant effect on a SAC, the proposal must be subject to appropriate assessment of its implications for the SAC, in view of the SAC’s conservation objectives.

Envireau Water hydrogeological assessment identifies a clear risk that the preferred HS2 route will have a significant effect on the Pasturefields Salt Marsh SAC. Therefore, appropriate assessment is required. Failure to carry out an appropriate assessment in such circumstances renders the HS2 development unlawful.

 

The legal framework

Special Areas of Conservation (SACs) are protected under EU law. Designated under Council Directive 92/43/EEC on the Conservation of Natural Habitats and of Wild Fauna and Flora (“the Habitats Directive”), SACs form part of the EU-wide ecological network of protected areas, known as Natura 2000. The protection of Natura 2000 sites against potentially damaging development is central to EU environmental policy.

The Habitats Directive is transposed into domestic law by Regulation 61 of the Conservation of Habitats and Species Regulations 2010 (“the Habitats Regulations”). The legal protection afforded by the EU Habitats Directive and domestic Habitats Regulations is also, rightly, recognised throughout central and local government planning policy documents.

A plan or project which, by itself or in combination with other plans or projects, is likely to have a significant effect on a Special Area of Conservation (SAC),must be  subject to “appropriate assessment” of its implications for the SAC, in view of the site’s conservation objectives (Article 6(3) of the Habitats Directive; Regulation 61 of the Habitats Regulations).

The Court of Justice of the European Union has made it clear that the Habitats Directive sets a low threshold for likely significant effects (Case C-127/02) Waddenzee [2005] 2 CMLR 31). Reiterating that the Habitats Directive has to be interpreted in accordance with the precautionary principle, which is one of the foundations of EU policy on the environment, the court concluded that a project is to be subject to appropriate assessment if it cannot be excluded, on the basis of objective information, that it will have a significant effect on that site "

Quoting the above analysis from Waddenzee and describing the significant effects test as “an informal threshold decision”, the Supreme Court in England has confirmed that, in cases where it is not obvious, the competent authority will consider whether the "trigger" for appropriate assessment is met and that there should be an appropriate assessment where the authority has found there to be a risk of significant adverse effects to a protected site (Lord Carnwath in R (on the application of Champion) v North Norfolk District Council & Anor [2015] UKSC 52 (22 July 2015) (emphasis added).

 

The hydrogeological assessments

The hydrogeological assessment prepared by Envireau Water notes that assessments prepared for HS2 to date do not reference an important element of scientific data (Barker 1979). Envireau Water conclude significant factors controlling saline groundwater flow have not been described by the assessments carried out for HS2. Specifically, Envireau Water explain that the missed data (Barker 1979) indicates that the Tixall Fault runs alongside Pasturefields Salt Marsh SAC and conclude that any impact to groundwater along the trajectory of the Tixall Fault has the potential to impact the groundwater seepage/springs at Pasturefields Salt Marsh SAC.

Accordingly, ERM’s reports are not sufficient to exclude the likelihood of significant effects on the SAC. Taking into account the low threshold for likely significant effects, as established by caselaw, the requirements of the Habitats Directive clearly demand a reconsideration of the trigger for appropriate assessment in this case.

Envireau Water assessment identifies two significant associates with HS2 route C and the Pasturefields SAC: (i) construction of an embankment across the Ingestre/Tixall Salt Marsh SBI and (ii) construction of the Brancote South Cutting.

The assessment concludes that construction of the embankment has the potential to affect groundwater flow in the fractured zones associated with the Tixall Fault, to reduce or divert saline groundwater seepage to the SAC and to affect the hydrochemistry of the saline seepages/springs.

In relation to the Brancote South Cutting, the assessment notes that HS2s own assessment shows the cutting will drain groundwater. Envireau Water’s assessment demonstrates that the  construction and drainage of the cutting has the potential to directly impact on deep saline groundwater flows to the SAC.

Plainly, on the basis of objective information presented by Envireau Water, it cannot be excluded that HS2 Route C will have a significant effect on the Pasturefields Salt Marsh SAC. On the contrary, the information presented and analysed by Envireau Water indicates that there is a material risk the route will have a significant effect on the SAC.

Accordingly, appropriate assessment is required. Failure to carry out an appropriate assessment in such circumstances renders the HS2 development unlawful.

The appropriate assessment demands a high standard of investigation. The relevant authority must be certain, in the light of the best scientific knowledge in the field, that the project will not have lasting adverse effects on the integrity of the SAC and that is so where no reasonable scientific doubt remains as to the absence of such effects. (Lord Carnwath in Champion [2015] quoting from EU case C-258/11 Sweetman v An Bord Pleanála (Galway County Council intervening) [2014] PTSR 1092.)

Freeths LLP



HS2: Notes on costs and benefits from seeking a route change

 

1. Introduction

HS2 Ltd has diverted a 20km-long section of Phase 2a, southwards, in order to avoid  Pasturefields Salt Marsh Special Area of Conservation (SAC).  The diversion starts near Colton and ends near Pirehill.  In doing so, HS2 threatens Great Haywood, Ingestre, Tixall, Hopton, Marston and Yarlet (including Ingestre Golf Club and the County Showground).

 

The alternative route is further north, is shorter, straighter, £154m cheaper to build and, overall, has less sustainability impacts.  It avoids all the above communities but would pass nearer to (but still be some distance from) Hixon, Weston and Salt. 

 

The northern route would also pass within 300m of Pasturfields SAC (a European protected site).  Natural England (NE) and the Environment Agency (EA) have insisted that, if the northern route is used, HS2 Ltd would first have to conduct an Appropriate Assessment (AA), under the Habitats Regulations.  The AA is required to demonstrate that construction and operation of the railway will have no significant adverse effects on  Pasturefields SAC. 

 

HS2 Ltd has declined to carry out an AA and, instead, diverted the route to the south.

 

The diversion to the south is justified by HS2 Ltd on the basis that a Habitats Regulations Assessment (HRA) Screening Report on Pasturefields SAC, commissioned by them in 2012 and agreed with NE and EA, concluded that routes to the south of Pasturefields would have no significant negative effects and could be screened out of requiring an AA.

 

From the moment that the route was announced in Jan 2013, Ingestre with Tixall Parish Council believed the decision to divert the route was a mistake.  For four years, it has campaigned for the northern route to be re-examined.  Over this period, a considerable quantity of information has been gathered that supports the case.  This information has all been passed to HS2 Ltd but none has been acted on (including that contained in a report by the British Geological Survey (BGS) which was commissioned to review the evidence).

 

In September 2016, HS2 Ltd published its draft Environmental Impact Assessment (EIA) for Phase 2a, based on the diverted route.  In the EIA, almost all previously supplied information had been ignored or misrepresented.  A robust response to the consultation was submitted and, in parallel, an investigation was started to identify what professional help could be mustered to bolster the arguments for the route to be re-examined.

 

The investigation determined, provisionally, that grounds exist for a technical challenge to HS2 Ltd's decision to divert the route and that these grounds should be explored further. If compelling  technical evidence is found, the recommendation is that the case be presented with a strong emphasis on the potential legal implications should the evidence be ignored.

 

In practice, if HS2 Ltd ignores the evidence, the Parish Council does not have the financial resources to pursue any legal action.  Even gathering the evidence and presenting the case to HS2 Ltd, at around £4.5k, is a challenge and payment for this work has to be split over two financial years.  Any legal action would have to be separately funded.

 

The question has been raised as to whether even spending an initial £4.5k represents a direct benefit to the community.  This note attempts to address this point.

 

 

2. HS2 Impacts

To a first approximation, HS2 is 7 years in the planning, 7 years in construction and has an anticipated operational lifetime in excess of 120 years (60 years design life plus extension through upgrade/replacement as appropriate).

 

The impacts are different at each stage, being greatest during construction.  The working assumption of HS2 Ltd is that a new equilibrium will be established within 15 years of the commencement of operation, i.e. by 2042 for Phase 2a.  By this time it is assumed that the scars of construction will have healed, environmental impacts settled (including adequate maturation of mitigation plantings etc.) and the residents and social structures of impacted communities will have adapted to the new norm.

 

The zone of potential impact used by HS2 Ltd is 3km either side of the centreline of the route which, with the present alignment, encompasses the entirety of Ingestre and Tixall parishes.  The greatest impacts will lie within 1km of the route but will be unique for each situation.  This is because construction and operation will affect each location differently.  In extreme cases, on Phase 1, properties out to 20km from the route have been affected where they border designated construction traffic routes.

 

Under current proposals, the section of HS2 in Ingestre and Tixall Parishes is 4km long. This is approximately 7% of the total length of Phase 2a.  The land taken involves a strip approximately 120m wide for the construction of the railway plus approximately as much again in area for mitigation planting, road diversions and provision of ancillary services. The total permanent land take from the parishes is of the order of 100ha.  Most of this is agricultural land but a notable exception is the course of Ingestre Park Golf Club, which, it is understood, will be forced to relocate.  There is one demolition: Upper Hanyards Farm.

 

There are 106 residences (74 in Ingestre, 32 in Tixall), 8 business properties and 1 church (St Mary's, Ingestre) within 1 km of the route but only three of the residences are close enough to be eligible for minor “Home-owner Payments” (available to owner-occupiers living within 300m of the centreline of the route).

 

Property blight is extensive and severe.  Appendix 1 presents the results of surveys by HS2 Action Alliance on Phase 1, carried out after announcement of the route but before construction has started.  The oft-quoted simplification is that blight averages out at 20 % loss in value for properties within 1km.  However, this hides the fact that the depreciation in value is up to 40% for properties closest to the route (within 120m) and still detectable out to 3 miles (5km) depending on circumstances.  The geography of the land and the topology of the railway (eg whether on embankment or in a cutting etc) as well as proximity to construction camps and haulage routes are critical in determining the actual effect. 

 

A survey of residential property sales in Ingestre and Tixall carried out in Feb 2016 confirmed the findings from Phase 1.  The principal difference is that the average unblighted value of the 28 properties offered for sale in Ingestre/Tixall was £373k compared with an average of £775k (country south) and £455k (country north) on Phase 1 – see Appendix 1. The average loss in value recorded on the 20 completed property sales in Ingestre/Tixall since January 2013 was 20%.

 

Extending the figures across 106 residencies, the total unblighted value of properties within 1 km in Ingestre/Tixall is approximately £40 million.  HS2 has already caused a loss of £8m.  This figure will increase over the forthcoming years of construction.  On the other hand, the Government expects and predicts that once the railway is complete and the housing market settles down, prices for properties within 1km will, on average, recover to 95% of their initial unblighted value (applies to properties greater than 8km from a HS2 station, after adjusting for shifts in the national/regional value of similar properties that have not previously been blighted by HS2).  This corresponds to a permanent diminution in property values in Ingestre/Tixall of £2 million (on a 2016 base).

 

During the 7 years of construction of Phase 2a (currently scheduled from 2020 to 2027), there will be enormous disruption to local life.  Noise, dirt, dust and pollution (light pollution as well as emissions from construction plant etc) will be extensive.  However, the most widely experienced impact will be that arising from road closures/diversions and the intrusive effects of heavy construction traffic using the local roads.  Two satellite construction compounds are proposed in our area: one at the head of Hanyards Lane, Tixall and one off Hoo Mill Lane, Ingestre.  The designated construction route to the trace of the railway and to both construction compounds is Tixall road.

 

Until the full environmental impact assessment is published (expected summer 2017) the precise extent of predicted HS2 construction traffic movements is unknown.  However, the Ingestre/Tixall proportion of construction materials to be moved is 1.75 million tonnes (assuming a uniform distribution per unit length across the whole of Phase 2a).  Not all this will be moved by road but, nevertheless, we can expect tens of thousands of 20T truck movements to take place in the parishes over the 7-year construction period.

 

Severe disruption can be expected to the operational interests of Ingestre Hall, St Mary's Church, Ingestre Stables, Ingestre Park Golf Club, Little Ingestre residential care home, Ingestre Pavilion and Tixall Gatehouse as well as to other locally-based business activities.

 

The above-mentioned financial and other disruptive effects will adversely affect the social, emotional and health/wellbeing of all the residents of Ingestre/Tixall; half of them severely.

 

3. Benefits of Route Change

The benefits of success in getting the route changed so that HS2 does not pass through Ingestre or Tixall are so overwhelming that it is self-evident that every possible measure should be taken to maximise the chance of succeeding in this.

 

Even though our representations to date have been unsuccessful, there is a consensus among consulted technical experts that there is a case to be made that HS2 Ltd would be acting unlawfully if they proceed with the currently proposed route, without first carrying out an Appropriate Assessment of Pasturefields SAC.  The assembly of the evidence to support this view and to present it to HS2/DfT with the necessary authority to force HS2 Ltd to take notice is now in hand.

 

Even if there is a case to be made, there is no guarantee of success.  HS2 Ltd might accept that an AA is required, carry it out and still retain the present route (with the necessary safeguards put in place to protect Pasturefields SAC).  However, HS2 Ltd would additionally have to convince the Government/Parliament that this was the right thing to do because, once committed to an AA, whichever route is used, then it is clear that the route having the lower cost (by £154m in this case) and fewer overall sustainability impacts should prevail; namely the northern route.         

 

 4. What if HS2 Ltd resist?

This is possible, even likely:  As James Dodds of Envireau Water observed in his email of 14 February 2017 (circulated as part of “HS2 – Geological Consultant 3” on 20 Feb):

 

Be under no illusion that you have a significant uphill struggle. Both NE & the EA have bought into ERM’s* concepts and they will not be turned around easily. HS2 will carry considerable weight and your resources are very limited”.

 

*ERM is the subcontractor appointed by HS2 Ltd to prepare the HRA Screening Report for Pasturefields SAC.


James proceeds to say:

To argue the Appropriate Assessment case may require legal support.

This is the crunch issue as “legal support” immediately has the potential to become a financial black hole – but not to the Parish Council whose spend is limited by Section 137.

The Section 137 cap limits the Parish Council to an annual spend of approximately £2,600 on such issues, which must have a direct benefit to the area or to some or all of the inhabitants.

There is no possibility of the PC funding any form of legal case with resources as meagre as this. It is therefore inevitable that, should legal support be required, then it will have to be funded from other sources.

This will require an independent fund-raising campaign.

It is not, however, inevitable that HS2 will wish to make a fight of it.  This is because, in the first instance, they could gain benefit from a change of route in that, at least as at Q2 of 2012, the northern route was shown to cost £154m less to construct than the diverted route and have fewer impacts.  Secondly, protracted legal action only results in delay to the project, which HS2 is likely to want to avoid.  It is therefore possible that, if it is ruled that the current route cannot proceed without an AA first having been performed, we may find we are pushing at an open door and that will be the end of it.

Should this not be the case then what action is taken will depend on the legal advice as to the chances of success and the willingness or not of residents (and other benefactors) to contribute to a fighting fund.  In this sense, the PC is no different and can, at any time, vote on a properly set resolution to contribute to the fund.  What is clearly the case is that the PC will not be taking a leading role in any legal challenge.

There is a reasonably wide area over which to cast the net to raise funds.  In the first instance, residents of Great Haywood, Hopton, Marston and Yarlet may wish to contribute as these communities will also benefit from a change in the route, from the current to the northern one.

There is a network of local HS2 action groups that may wish to contribute, as well as the three main national action groups who have fighting funds already established but no longer a meaningful fight to conduct (Phase 1 having effectively been confirmed through the granting of Royal Assent).

Further out still are national campaigns promoted via the press, tv, radio and social media.

No-one should be under any illusions that this could be a difficult and challenging exercise but the potential rewards are great if it is successful – especially if a court rules against HS2 and awards costs to the plaintiff.