HS2

1. Effects of Road Transport to HS2 during construction

· 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 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, which have different postcodes..

· We welcome HS2s assurance to provide a permanent roundabout at this dangerous junction, or other measures to improve road safety such as better visibility splays.

· Similarly access to Ingestre Pavilion beyond Upper Hanyards Farm must be maintained 24/7, including for large Timber HGVs and Farm tractors and trailers.

· We are concerned at the proposed use of Tixall road from Hoo Mill crossroads to Blackheath Lane for transfer of materials for HS2. The proposed temporary, additional passing places and road widening between Hoo Mill crossroads and Tixall Village do nothing to solve the problems between Tixall obelisk and the junction with Blackheath Lane. HS2 Drawing 2PT02-ARP-PT-DSK-000-100105 shows an additional 52 HGVs travelling along this Tixall Road in both directions.

· This disruption could be partly compensated for by HS2 funding the provision of a wheelchair friendly towpath from Holdiford Road to the Sow Aqueduct on the Staffs & Worcs.Canal, and by improving the land drainage at the lower end of Tixall Churchyard, which periodically floods the path from the Lychgate to the Church.

· Major adverse effects at The Blackheath Lane/Baswich Lane/Tixall Rd traffic signals. In particular the predicted 98% increase in traffic exiting Hanyards Lane by 2023 (HS2 Drawing 2PT02-ARP-PT-DSK-000-100105) with many of these ending up stuck across Tixall Rd and in the path of traffic turning left from Blackheath Lane when the lights change and who are not expecting another junction 22.4m away.

· An additional solution would be to replace the deep cuttings on either side of Upper Hanyards Farm with a cut and cover tunnel to reduce the amount of spoil to be transported away from the site.

2. Noise Effects (E19 Vol.2 Map Book)

· Increase in airborne noise from new train services both daytime and night-time in Ingestre and Tixall, probably 12/hr in both directions. Residents of Ingestre and Tixall have paid higher house prices to be able to live in a quiet and peaceful location. This will no longer be the case.

· 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.

· 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.

· 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.

· Construction traffic is likely to cause adverse noise effects on occupants of residential dwellings adjacent to Tixall Road, and Hanyards Lane, between the Proposed Scheme and Tixall Road

· The HS2 line will require ongoing maintenance at night which will result in more disturbance for local residents, both from noise and lighting.

· Ingestre Church is now a significant venue for concerts and weddings and any increase in noise levels will impact on this. The number of bookings for weddings has already significantly decreased with consequent loss of income. See below for suitable compensation to Church.

· Solutions to this would be to provide significant mitigation packages to the most severely affected homes and to provide a cut and cover tunnel in place of the deep cuttings on either side of Upper Hanyards Farm

· A further solution is to provide adequate sound barriers on the viaduct and embankments.

3. Vibration

· Effects of vibration, during construction. Numerous listed buildings are within a few hundred metres of the route, e.g. Grade I listed church of St Mary the Virgin, Ingestre, 400m from the area of the works; Ingestre Hall (Grade II*) is closer, at 350m and Ingestre Pavilion (Grade II) closer still at 150m. All in proximity to the substantial Hanyards Cuttings, nearly 20m deep, in hard sandstone. Until geological surveys have been conducted, there is a possibility that blasting might be required if particularly tough ground conditions are encountered.

There is particular concern on the effects of any vibration on the above Listed Buildings which have no substantial foundations.

4. Visual Effects

· The Viaduct with noise barrier and Brancote/Hanyards North Cutting will be an unacceptable visual intrusion on this historic landscape, especially the Staffs & Worcs. Canal Conservation Area and Tixall Conservation Area and Listed Buildings. 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.

The visual impact of the viaduct and its noise barriers can be reduced by using transparent noise barriers as in Holland and by having a sandstone effect over the concrete structure. The National Trust is particularly concerned at the visual impact from Hadrians Arch at Shugborough.

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

· A millennium avenue of Horse chestnut trees was planted on either side of Hoo Mill Lane with protective fencing and bronze plaques recording the dedications in 2000. The trees nearest the crossroads will be removed by HS2, in addition some of the Horse chestnuts have become diseased and need replacing. Could additional Oak trees be planted further along the lane and the missing plaques reused.

· The EIA notes a medium adverse impact and moderate adverse significant effect for the Ingestre Conservation Area. Trent N embankment and 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 at least 3 years, and will be visible from the eastern boundary of the Ingestre Conservation Area. 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.

· The remnant Golf Course directly in front of Ingestre Hall, will become wasteland, unless the Golf Club is retained at Ingestre.

· 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:- hot-air ballooning and other enterprises offering: gliding, hang-gliding and micro-light opportunities for the enthusiast and public alike. 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.

· A cut and cover tunnel instead of the Hanyards cuttings could reduce the amount of spoil to be removed along our local roads and improve the visual and noise effects from both Ingestre and Tixall.

5. Impacts on the communities of Ingestre and Tixall and lack of any benefit to our residents

· 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.

· HS2 has not included Ingestre Stables equestrian training and examination centre (which is a Riding for the Disabled registered and has a cafe) or Ingestre Community Open Space by Home Farm Court, in their list of Community Facilities in Ingestre. In addition we now have Ingestre Orangery and both the Orangery and the Riding Stables are likely to have reduced patronage and consequent financial loss due to problems accessing them across the HS2 constructions at Hoo Mill crossroads.

· Failure to acknowledge all businesses in Ingestre & Tixall including: 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; Tixall Heath Joinery; Tixall Heath Land Rover Garage; Tixall Heath Caravan Store & Repairs, and several arts and crafts businesses.

· We strongly object to the exclusion of the very real issue of impacts on the community of generalised property blight and reduction in property values. 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, especially due to the reduction in value of their properties.

· Potential Loss of Ingestre Park Golf Club and it's social facilities due to the 6 month period when the course will not be available for play and members may join other local clubs. The resulting financial loss would encourage the club to move to an alternative site. The Golf Club also provides employment opportunities for local residents.

· Adverse effect on local businesses/community facilities: Most vulnerable are Ingestre Hall, St Mary's church and Ingestre Orangery all 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. The number of weddings at Ingestre Church has already significantly decreased due to uncertainty about the effects of HS2, especially on access to the Church and the noise effects.

· It is suggested that a contribution from HS2 towards the £80,000 replacement of the current faulty organ could help to ameliorate this. The church has recently suffered a significant loss of lead from the roof and will have to find funds for this as well.

· Similarly a contribution towards the repair of the Apple Store at the Orangery would enable it to serve as a heritage centre.

· The workers camp would impact on Community Services at Gt Haywood such as Doctor's Surgery, Shops, etc. which are shared by residents of Ingestre and Tixall where there are none of these facilities.

· Many of the houses already purchased by HS2 have remained empty. This has had a significant negative effect on the local community.

· Currently the mobile phone coverage is variable throughout Ingestre and Tixall, and similarly access to superfast broadband. Some compensation for the impact of HS2 would be to improve these communications.

6. Failure to act on previous requests by Parish Council - no 2-way communications

· We are very concerned to find that most information provided to HS2 Ltd in previous communications has been ignored. This is partly because consultations responses are combined in a report which just summarises the main points raised, losing much of the specific details.

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. Brancote S cutting is actually N of Brancote. This will lead to considerable confusion for local contractors, and in the rare event of a major rail accident, e.g. terrorist activity, in the cutting would hinder the prompt arrival of emergency vehicles.

More recently a utility compound has been name as Hanyards Compound, although it is nowhere near Hanyards.

· 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. Primarily because HS2 Ltd have refused to carry out an Appropriate Assessment to show that there would be no significant effect on the Pasturefields SAC. This would involve new borehole evidence, etc. and was very different from the Habitat Regulations Assessment (HRA) already carried out by HS2 with regard to the SAC. The BGS (January 2014) said: "The review of the information that has been presented leads us to conclude that each phase of investigation of the PSMSAC has built upon the previous phase. As a consequence alternative conceptual ground models have not been presented or tested. Furthermore, there has been little resolution in issues regarding the alleged deterioration in the quality of the PSMSAC, e.g. whether or not leakage from the canal is diluting the emerging groundwater, the impacts of flooding of the River Trent and the source of nutrients that impact on biodiversity. Without this baseline data it is hard for anyone to predict the potential impact of the proposed HS2 construction along any of the proposed alignments."

· We are concerned that provisions to mitigate community effects during construction have not worked well for Phase 1. It is important that there is an efficient procedure for us to report back problems which arise, especially if they arise from issues which we had previously identified to HS2. Some of the changes to the local hydrology may take a long time to become apparent.

7. Failure to fully understand local hydrology

· Route C has 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). HS2 has not carried out sufficient investigations to understand the complex hydrology in this area.

The salt marsh part of the site is non-designated yet is potentially of national importance.

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.

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..

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 previously sent to HS2 by Mr M.Woodhouse, which suggests the presence of springs near Congreves Plantation, Ingestre Village, Flushing Covert and at Salt spring 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.

· an Appropriate Assessment of the effect on Pasturefields SAC is essential to determine if there would be any risk of an adverse impact arising from Route B.

· 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.

We note that the solution to all the above problems would be for HS2 to adopt the less expensive and less environmentally intrusive route up the Trent Valley, which was originally favoured by HS2 technical advisors. The only reason we have been given for not using this route is that it required an appropriate assessment to ensure that it would not have a detrimental effect on Pasturefields SAC.

The British Geological Survey have pointed out none of the routes proposed by HS2 can be guaranteed not to have an effect on the SAC.

However, planning permission for a marina at Pasturefields has been passed, and there have been industrial development nearby, none of which appear to have had any effect on the SAC.

Ingestre Park Golf Club (No. AP2–25) 79. In our Second Special Report we directed HS2 to “come to a solution that allows the golf club to continue as a community asset.”

This was supported by Ingestre and Tixall Parish Council who petitioned on AP2 and told us that they were concerned that the loss of golf playing facilities (the temporary reduction of holes) could result in the financial collapse of the golf club as members may choose to play golf elsewhere.

There are two types of construction compounds, main construction compounds which act as strategic hubs for core project staff, and satellite compounds, which will generally be smaller and will be used as the base to manage specific works along a section of the route (Environmental Statement, p. 28).

24 Third Special Report of Session 2017–19 80. When hearing the original petition we heard challenges from both parties regarding the other’s estimates of costs. Ingestre Park Golf Club returned to petition against the proposal contained in AP2 (to purchase land adjacent to the existing golf course as a replacement for the land being taken by the Scheme and thus build a new course adjacent to the existing golf club).

Ingestre Golf Club petitioned, once again, for a replacement course, clubhouse and carpark and demonstrated that they had found an alternative site in Tixall which would be suitable.

The Parish Council was not in favour of the proposal from the Golf Club as the Golf Club’s proposed new site would impact on other residents within the Parish who were not supportive of this change. The Golf Club’s proposal raised a level of risk as it would depend upon the Club obtaining the land and obtaining planning permission. Ingestre with Tixall Parish Council were content with the proposal contained in AP2.

HS2 told us that the proposal contained in AP2 would cost £4.9m.51 The Golf Club said that HS2’s proposals in AP2 would cost £13m52 but that their option was cheaper.

Ingestre Golf Club argued that it would cost £10.9million for their option but the net cost would be “£7.8 million on the new proposed course because the £3 million compensation would have to be deducted” from the overall compensation figure which they would receive. The figures provided by HS2 and Ingestre were not comparing like with like. Having evaluated the costings and taking into account the view of the Parish Council we agree that the proposals set out in AP2 will ensure that the golf course can continue as a community asset.

We understand that there will be a reduced number of holes for golfers to play for a 6 month period and we are also aware that the Golf Club is a source of local employment. Employees of the golf club, those working both full and part-time, must not be disadvantaged by the proposals contained in AP2. We therefore emphasise that the golf club is entitled to apply for compensation as part of the existing compensation packages, which would enable the golf club to continue to employ or pay compensation to all staff who are employed at present.

The Club could operate with nine holes for six months and with 18 holes before and after this period53 and perhaps offer attractive subsidised and reduced fees to golfers whilst the new course is created.

The club was concerned that the realignment would reduce the visibility at the first Tee. Security cameras for this area could also form part of the Golf Club’s claim for compensation.

HS2 told us that the Secretary of State would be happy to support this way forward. We expect Ingestre Golf Club to work with HS2 to ensure that the proposals set out in AP2 are delivered for the local community and that the Golf Club maintain current levels of employment for all their staff.

The Promoter welcomes the decision of the Select Committee and will work with Ingestre Park Golf Club to take forward the proposals in Additional Provision 2 to the Bill (AP2). The proposals in AP2 were promoted with the aim of providing an opportunity for the Golf Club to continue as a local business and employer. The Promoter confirms that the Golf Club will be able to apply under the compensation code for losses arising from the implementation of the proposals set out in the Bill as amended by AP2 and those losses can include staff costs.

Residents of Ingestre will see an increase in construction traffic during the building of the railway as construction compounds will be sited at Trent North, Hanyards Lane and Ingestre Park.

The Parish Council petitioned, on the grounds of road safety, for a new footpath alongside Ingestre Road so that pedestrians, those with pushchairs and wheelchair users would be safe travelling along this section of road.

HS2 has given an assurance that a footpath will be provided and in Committee, gave a further assurance that the footpath could be extended westwards.

The Parish Council expressed concern about the proposal for the new site found by the Golf Club and as we have stated above we support the view of the Parish Council.

The full assurance to which the Select Committee refers has been included in the latest draft of the Phase 2A Register of Undertakings and Assurances.

“We heard from petitioners that there were opportunities to carry out the necessary infrastructure works whilst excavations were taking place on their land. We would like to see a joined-up approach to the Government’s commitments. At detailed design stage, planners should incorporate the necessary infrastructure to support super-fast broadband in rural areas. We do not expect HS2 to provide super-fast broadband but we do expect the Government not to miss this opportunity to install the necessary infrastructure to rural areas where such opportunities arise. This could be HS2’s 21st Century contribution to improved communications.”

76 The Promoter recognises the need for a joined-up approach to realise wider Government commitments and the benefits of cross-Government working. The Promoter will engage with the Department of Digital, Culture, Media and Sport and infrastructure providers regarding current plans for super-fast broadband and to understand how the construction programme for Phase 2a may provide any opportunities.

“We regret that on many occasions we heard from the Parish Councils that the County and Borough Councils had not engaged sufficiently with the local Parish Councils to seek their views. We hope that as the legislation progresses and the preparation work for the railway continues this will be remedied locally. HS2 when sending correspondence to the primary authorities should copy the correspondence to the relevant subsidiary authorities.”

90 During the delivery of Phase 2a, HS2 Ltd will ensure all key stakeholders are kept informed, involved and responded to, in accordance with the HS2 Community Engagement Strategy, including, where relevant and appropriate, copying correspondence with primary authorities to the relevant subsidiary authorities. As part of this engagement activity, HS2 Ltd will seek to ensure primary authorities and subsidiary authorities are engaged within the same, broad timescales. A recent example of HS2 Ltd’s engagement with parish councils is an invitation to visit ground investigation sites along the line of route, which has been taken up by six parish councils to date.

91 When HS2 Ltd engages or consults primary authorities as part of their statutory, technical function, such as those related to planning, highways or heritage, it would be for the primary authority to decide how they involve subsidiary authorities and other local representative groups or bodies.

“In our Second Special Report we recommended that the Secretary of State made provision for the construction of a 5-metre high noise and visual barrier at the Great Haywood Marina in order to protect narrow boat owners living there. The Government told us that this would not be possible as HS2 had already given assurances to the National Trust about the viaduct in that the Area of Outstanding Natural Beauty of Cannock Chase. The Government’s response says “while HS2 Ltd gave an indication of the engineering complexity of delivering higher barriers here, this did not cover the trade-off between barrier heights and their visual impacts” and that the 5-metre high noise barriers would impact on the view. We ask why this was not raised by Counsel for HS2 in Committee at the time of petitioning. In order for the process to work well for both petitioners and HS2 the Committee requires such evidence so that an informed and fair decision can be made. We expect the Trent and Sow Parklands and Cannock Chase Area of Outstanding Natural Beauty Group, (of which the Canal and River Trust is a member) to work with HS2 to find a suitable solution which will allay the concerns of the Inland Waterways Association about noise.”

107 The Promoter agrees with the Select Committee’s view that the Trent, Sow Parklands and Cannock Chase AONB Group, of which the Inland Waterways Association is also a member, has a key role locally. The Promoter will ask the Group to consider this aspect as part of their consideration of the design principles for this structure which will inform the detailed design.

“Colwich Parish Council petitioned the Committee on 1 May 2019 arguing for an upgrade of the towpath of the Trent and Mersey Canal and work to expose the footpath within the highway verge of the A51 for the benefit of walkers. HS2 are now in discussions about using the Community Fund to upgrade the towpath and we were told that HS2 would be agreeing with the Parish Council an assurance on the upgrade of this footpath.”

114 The Promoter has given an assurance to Colwich Parish Council that the nominated undertaker will be required to clear the vegetation obstructing the footpath alongside the A51 between Great Hayward and Hixon, and to repair the existing asphalt paving on the pathway that is currently paved with asphalt during the compound establishment period.

115 The Promoter is continuing to engage with Colwich Parish Council, working with the Canal and River Trust and Sustrans to help facilitate an alternative route for cyclists wishing to avoid construction traffic on the Great Haywood Road, including working with them to make a bid for HS2 Community and Environment Fund (CEF), Business and Local Economy Fund (BLEF) or Sustrans funding.

1. Residents of Ingestre will be subjected to significantly increased traffic because of the additional Utility Compounds at:

The name Hanyards Lane Compound is confusing. The bottom of Hanyards Lane is 4½ miles away by road and a further 1½ miles to the top of the lane. In addition, Hanyards is in Tixall while Ingestre is in Tixall.

2. Ingestre Park Golf Club. We are concerned that loss of playing facilities for 15 months will result in the financial collapse of the golf club.

As a result Ingestre and Tixall will then lose this important Community Asset, which provides the only licensed community space in the two parishes.

The community is also greatly concerned about the future of the remnant of the golf course directly in front of the Grade II* Ingestre Hall. We worry about its potential use when it is no longer part of the golf course.

There are very few passing places, and at certain times in the farming calendar there is very heavy farm traffic, e.g. during silaging and harvesting.

1a We would like to see a permanent improvement in road safety at these crossroads, e.g. a permanent roundabout or improved visibility splay.

1b There is a problem along Ingestre Park Road/BOAT 1 as there is nowhere for pedestrians, especially with pushchairs, etc. to be safe from the traffic.

We would like to have a footway installed from the entrance to Ingestre Manor Farm to Home Farm corner - taking off a sliver of land from that proposed for the extension of the Golf Club.

Property Consultation

Informal meeting between HS2 representatives and Parish Councillors 5.11.18

Present: Malcolm SIndrey (Chairman), Nicholas Bostock and Anne Andrews representing Tixall .

Sue Haenelt, Nicola Woodhouse and Rob Hall representing Ingestre

Omar Deedat and Charles Leprince from HS2

We had the benefit of projecting from Charles's Laptop onto the Village Hall wall using our new VGA-HDMI adaptor.

Charles started by showing us a map with existing and predicted HGV traffic flows. These included:

The A51 Currently 1260 HGV/day with HS2 additions of 6 and 5 (busy period in months and peak months)

Tixall road " 81 HGV/day " 3 and 2

Hanyards Lane " 87 HGV/day " 4 and 1.

More information is available at: https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/715722/Section_P_-_Traffic_Arrangements_-_Part_1.pdf (a very large file)

There will be satellite HS2 compounds at the top of Hanyards Lane and by Hoo Mill, these should be restored to agricultural use when HS2 construction has been completed. The main compound, with workers accommodation will be just north of Haywood Marina, at Farley corner adjacent to the A51. There will be a new, temporary road to this compound from the Hoo Mill compound with a temporary bridge over the West Coast main line.

Construction of the HS2 viaduct over the river Trent will involve pile driving. 8am to 6pm Mondays to Fridays and 8am to 12noon on Saturdays.

Hanyards Lane will be used by traffic setting up the Hanyards Satellite Compound and haul road adjacent to the line of the HS2 track.

No work can be started until the Bill has been approved by parliament, i.e. Royal Assent. Advanced work will then start in 2019 with detailed designs being prepared, and initial fencing, etc. installed along the line of the track. Compulsory purchase can only start after the Bill has received Royal Assent.

The second Additional Provision (AP2) Bill to clarify details such as the accommodation of utility services along the line of HS2 is scheduled to be presented early next year in January or February 2019. A further round of petitioning by those directly affected by these additional provisions would then take place in March & April 2019. This includes changes to Ingestre Golf Course, and other changes shown on the current draft plans.

The main construction work is expected to start in 2020/2021.

The works will be scheduled to minimise impact on the farming programme wherever possible.

The suggested AP2 changes include:

· Temporary compounds for the Utility Contractors, e.g. by Hoo Mill Lane while the gas pipeline is moved. These will be restored to agricultural use with the stored topsoil returned.;

· More land around the temporary roundabout near Hoo Mill crossroads. It was suggested that we should petition for this to be retained after the construction of HS2, which would require constructing the roundabout to a higher specification but would be partial compensation to the disruption caused by HS2 to the local community;

· Using Mr A.Collier's land on the far side of Ingestre road between Ingestre Manor Farm and Trent Drive for the Golf Course in compensation for the Golf Course land taken by HS2. The Parish Council is strongly in favour of retaining the Golf Club at Ingestre as this retains the Clubhouse for community house and safeguards the part of the course directly in front of Ingestre Hall.

· Ingestre Access Bridge under HS2 to the Golf Clubhouse;

· A further Utility Contractor compound NW of Lion Lodge Covert;

· BT and electric diversions down Hanyards Lane.

All these suggested changes will be subject to further consultation and then the petitioning process as before.

If there were any further major changes, Omar was happy to come back and meet with the Parish Council with relevant HS2 colleagues

Details on the draft maps are continually changing and it is unusual for them to be shown to the public at this stage. They also give a worst case scenario with maximum potential land take.

Mr Bostock asked for details of the fencing along the track boundary. It was suggested that we should petition for this to include hedges, but the future maintenance of these would have to be agreed between HS2 and the adjacent landowner.

Applications for the Community & Environment Fund could only be made after Royal Assent had been given, but we were given details so that applications could be prepared, e.g. for a footpath alongside Ingestre Road from Ingestre Village to Home Farm corner.

Mr Sindrey then thanked everyone for attending and the meeting closed at 8.05pm.

HS2 Phase 2a HISTORIC ENVIRONMENT RESEARCH & DELIVERY STRATEGY (HERDS)

Consultation Workshop 31.10.2018

Anne Andrews was one of 12 people attending this workshop at HS2 in Snow hill, Birmingham.

Other attendees were:

Chris Jordan HS2 Heritage Advisor;

Jessica McIver, Andrea, and Charles all ERM Cultural Heritage Consultants;

Shane and Debbie - Staffs CC Archaeologists;

Alan Tayor - Stafford BC Conservation Officer and Historic Parks representative;

A representative from Keele University;

Neil Davis from Manchester Industrial Archaeology;

Stephanie a Ceramics expert from Barbican Consultants.

It was noted that Phase 2a is scheduled to open in 2027, assuming the Hybrid Bill, equivalent to outline planning permission, is passed. This is scheduled to be completed by Christmas 2019 and enables compulsory purchase by HS2.

An Environmental Impact Assessment Report, EIAR, has already been completed.

So far work by ERM has involved:

· Desk based work and studying maps. They have no permission to access private land.

· Remote sensing using aerial photos and LIDAR,

· and Field walking and Magnetometry where access was allowed, although results from this have been largely negative.

· Constructing a Geoarchaeological model of the Trent Valley, e.g. showing Turnpike Roads, Canals and Railways;

· Historic landscape characterisation.

All of this information is available on the Government website (not HS2) although it is difficult to locate specific areas as the indexing is poor. It is hoped that some direct links can be sent out for our area.

The Historic Environment research will cover all historic assets within 500m of the route and all scheduled structures, e.g. Listed Buildings and Ancient Monuments, within 2km.

HERDS will have a commitment to Parliament to carry out this research and report it, and it will be delivered by a supply chain of subcontractors. The aim is to create the maximum amount of knowledge cost effectively for the tax payer, using a research led approach underpinned by technical knowledge.

There was some discussion on the best ways to deliver the information generated by the work, noting that it will be a limited life project. Methods of how to measure success need to be set out.

It was suggested that possible methods of public engagement and dissemination of the findings could be:

· A large monograph containing all the information;

· Several smaller, more user friendly documents;

· Creating a virtual museum;

· Digital games;

· School visits as part of the Science, Technology, Engineering and Maths syllabus;

· Engagement with Community Groups

Part of the public engagement was to to learn new skills, etc.

Works reports would be available within a relatively short time frame, e.g. 8 weeks, with monographs taking much longer.

Lessons were being learnt on disseminating information from HS1, Cross Rail and the Staffordshire Hoard.

The Post medieval period, which was the main focus of this workshop, was taken as 1540 to the present, although they were happy to accept discussion on earlier features.

ERM were suggesting the following major topic:

Landscape Issues:

Geographically the area consisted of the Upper Trent Valley; the Stoke & Stone uplands; and the Cheshire Plain.

The area crossed the E-W watershed which had had a direct effect on human culture of all periods, including with respect to resources and transport.

When had enclosure occurred, e.g. relatively early in Ingestre and Tixall.

A characteristic landscape around the late 18C Listed Moreton House whose Haha would be touched by HS2. This landscape had been built on the profits of coal mining on Cannock Chase.

Water meadows in the Trent Valley.

Rural industries including Glass making and Iron working.

Turnpike roads and milestones - many of these had been broken or displaced, and some would need to be relocated after HS2 road diversions.

The following broad themes for research were suggested:

1. Enclosure and colonisation.

2. Rural settlement/Built heritage.

3. Landscaped Estates.

4. Transport & Industry.

5. Conflict in the landscape, e.g. WWI and WW2 remains.

In addition, the following research topics were suggested;

1. Development & diversity of local industries including the role of ceramics, e.g. Hoo Mill Flint Mill.

2. Rural settlement patterns and vernacular building traditions.

3. Landscapes of display and power - e.g. Historic Parks.

4. Transport corridors - the Trent, Canals and Railways.

5. Interaction between the growing towns of Stafford, Lichfield and Crewe, and the rural hinterland of the study area.

We then discussed a variety of topics and I was pleasantly surprised at how aware ERM was of Ingestre Hall and parkland; Ingestre Church; the Hoo Mill tramway; St Erasmus Chapel and the earlier church at Ingestre; the salt working by Lion Lodge, and the ancient history of Upper Hanyards.

Other topics covered were:

· The Cistercian monastery at Yarlet and the original site of the Hall in an oval woodland. The school is on the site of a rebuilt Manor House.

· Ceramic related sites showing the growth of the Pottery Industry.

· The interaction between Industrial activities and the Agricultural revolution.

· How communities evolved.

· The movement of labour.

· How changes in the Poor Law impacted on the supply of apprentices for industry from the workhouses.

· Possible sites of temporary camps for railway navies.

· Small coal mines.

· Local heritage such as the Abbots Bromley Horn Dance.

I have sold them a copy of my book on Tixall Farms, and they have requested a further copy. I am also sending them a copy of "The Short History of Ingestre", and relevant editions of the Staffordshire Industrial Archaeology Society, e.g. on Brickworks and quarries.

Report of informal meeting between members of the Parish Council and HS2 representatives held on October 17th 2018.

Present: Mr Malcolm Sindrey (Chairman), Dr Anne Andrews, and Mr Nicholas Bostock - Tixall Parish Councillors.

Mrs Susan Haenelt, Mrs Nicola Woodhouse and Mr Robert Hall - Ingestre Parish Councillors.

Representing HS2: Omar Deedat, Petition Advisor; Joe Wilson, HS2 Stakeholder; Beth Chamberlin, Environment Consultant and Charles Leprince, Civil and Structural Engineer.

Apologies had been received from Mrs Penny Brookes, a Tixall Councillor.

Omar explained that following the completion of the last round of consultations and petitions, the latest HS2 Hybrid Bill passed through Parliament. Matters covered in this Bill including the actual route of HS2 could not be changed. Since then HS2 has developed the design, particularly in respect of highways and utilities and needs to make some changes to the Bill to reflect these. They have already sought to make changes to the Hybrid Bill through additional Provision submitted in March 2018. They are now seeking to make further changes through a second Additional Provision (AP2) to clarify details such as the accommodation of utility services along the line of HS2. This was scheduled to be presented early next year in January or February 2019. A further round of petitioning by those directly affected by these additional provisions would then take place in March & April 2019.

Proposed changes include a series of amendments to utilities works including:

· Revised designs for gas and electricity diversions and altered connections for water supplies, sewers and telecommunication cables.

· Provision of a number of local placement sites for excavated material that would otherwise be exported by road;

· Provision of maintenance access to a number of elements of permanent railway infrastructure including the under bridge at Ingestre;

· Additional land required temporarily for construction and utility and railway system compounds;

· And changes brought forward at the request of local agricultural businesses and other stakeholders, as well as at the direction of the committee of MPS considering the Bill. These include changes to accommodate Ingestre Park Golf Club by extending it across Ingestre Road onto Mr Andrew Collier's land.

· Additional land temporarily required alongside the track to provide haul routes.

HS2 was taking the unusual step of consulting with interested parties before the final detailed plans were published. This meant that the plans currently being discussed were only drafts and provisional.

There were considerable difficulties viewing the plans on a small laptop which could not be connected to the Village Hall projector. It is hoped to resolve this in the future.

Hard copies of these draft maps for our section of the route will be available at Stafford Gatehouse on Monday October 29th from 2 to 8pm., but they cannot be taken away.

A separate meeting will be held with landowners directly involved in early November.

Red "bubbles" showed the changes from the original plans. These include:

· The exclusion zone alongside the diverted gas main near the viaduct has been widened at their request, and a temporary site compound for the diversion works has been added.

· The temporary roundabout near Hoo Mill crossroads has been widened. This will ensure that Ingestre Road will never close.

Various other matters were raised:

1. Some landowners including Mr Bostock, Tixall Heath Farm and Halfway Cottage had received lengthy forms asking them to confirm their ownership of the land and any additional constraints on this, without explaining why this information was required. This had led to great concern. HS2 responded that these letters had been sent out by a Manchester sub-contractor.

Mr Sindrey noted that he had not been approached at all by HS2 despite having told them on many occasions that he owned the sporting rights on land required by HS2 and land opposite Tixall Church required for road widening in the Hybrid Bill.

2. It was noted that the present works on the Hoo Mill side of the canal and Haywood Marina was nothing to do with HS2, but was purely to divert and underground the oil pipeline from going over the adjacent canal bridge where it was very vulnerable.

3. Concern was expressed as to how golfers would cross Ingestre road, and what would happen to the small area of golf course to the SW which would be isolated by HS2.

It was noted that Mr A.Collier's recent hedge clearance work was necessary in order to sort out the drain from Ingestre across these fields, which currently had no outflow.

4. Mr Martin Harrison, co-owner of Ingestre Wood had been assured that large timber waggons would be able to pass over the new over bridge.

5. Currently drilling was being undertaken to investigate the geology, etc. of Hanyards/Brancote South Cutting at the edge of the large field below the track to Ingestre Wood from Upper Hanyards, adjacent to the belt of trees (Churchfield Belt) separating this field from Ingestre Golf Course.

6. Excavated material would either be placed in temporary soil tips, where it could later be used for nearby embankments, or if excess to requirements, made into permanent local placement sites. These would be low mounds, up to 3m high, with their contours landscaped to merge in to existing land contours. They would be covered with topsoil and then grassed over.

7. HS2 was asked about ongoing maintenance of compensatory tree planting, e.g. at Hoo Mill crossroads. They had replied that ongoing maintenance would be agreed with Natural England, and funded by HS2 for up to 10 years. After this the future of the woodland would be agreed,

following case by case discussions with the landowners.

8. It was noted that HS2 Phase 1 was already 2 -3 years behind schedule, and thus the various temporary works could be in place for some time. HS2 replied that they were currently on target, but could not predict what would happen in the future.The main construction work on Phase 2 was scheduled to start in 2021 with the railway operating from 2027.

9. It was noted that it had been agreed that Colwich and Ingestre with Tixall Parish Councils and Shugborough would have input into the final design of the viaduct by Haywood Marina. Apparently this was being organised by Cannock Chase AONB. The AONB boundary runs along the S bank of the Staffs & Worc. Canal to Haywood and then along the boundary of Shugborough Park.

10. Dr Andrews hoped to attend a Post-medieval and Built Heritage workshop being led by the Staffordshire County Archaeologist, Shane Kelleher, on October 31st from 11am to 3pm at HS2 offices nr Snowhill Station, Birmingham. She had been confused to receive a further invitation to a similar Communities, HERDS workshop on November 8th, which she could not attend.

When HS2 is up and running current service plans are for one train an hour between Stafford and London taking 53 minutes, a saving of 22 minutes. Much needed increased railway capacity would occur. Staffordshire and Cheshire would be served by three stations: Stafford, Stoke on Trent and Crewe. Construction of HS2 would support thousands of new jobs including 2,000 apprenticeships.

There being no further business, Mr Sindrey thanked all those who had attended and the meeting closed at 8.55pm

Report of meeting between Parish Council and representatives of HS2 24.6.19

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

Mrs S.Haenelt, Mrs N.Woodhouse and Mr R.Hall representing Ingestre

Omar Deedat, HS2 Petition Advisor and Joe Wilson, HS2 Community Engagement Officer

1. House of Lords Petitioning Process:

Omar said that the 3rd reading of the Bill had been expected in June, but now was more likely at the beginning of July, and this would trigger the House of Lords Petitioning Process. This would have a similar format to the Commons petitioning, but can cover all issues. However, it was very unlikely that it would promote any additional provisions which would require further consultation and petitioning. There would be a 30 day petitioning period.

The Lords petitioning would then start around September with initial briefings on the route, etc. by HS2. So it was likely that petitions would be heard around October, and would be relatively quick.

Omar explained that the petitions could include some blue sky thinking, e.g. The impact of HS2 on the local community could be used to press for money for the village hall, as at Hopton, or for better sound barriers. The refusal of a tunnel at Hopton could be used to support more community benefit for Hopton. It would be important to check with Omar which proposals would require Additional Provisions, and were therefore less likely to succeed.

It would be helpful to repeat the key points of our previous petition, and to contact Lord Shrewsbury and Jeremy Lefroy to support us.

It was suggested that Ingestre Church could petition for a new Organ as it was a concert venue and there would be a fall in visitor s during HS2 construction with the increased traffic and this would result in a loss of income.

2. Update on Ground Investigations site visit offered by Joe Wilson on April 15th:

Mr Sindrey and Mr Bostock were interested in attending this, but had received no further information.

Joe Wilson explained that Balfour Beatty had the contract for these groundworks, which they had sub-contracted to Soctec. Their preliminary investigations of our area were almost complete, and he hoped to arrange a planned visit during the 2nd phase of investigations later this year.

Dr Andrews noted that there had been considerable activity at the top of Hanyards Lane with a series of bore holes along the proposed line of HS2, on either side of the track leading to Ingestre Wood, and one borehole in the field to the left, at the far end of the Black Drive.

3. Membership of Trent Sow Parklands HS2 Group:

Omar said that this was in the process of being set up with terms of reference and an independent chairman appointed, and the Project Manager would be contacting Parish Councils in due course. Currently the County Council, National Trust, etc. were involved.

Dr Andrews noted that on June 5th on June 5th she came a across a carload of people parked at Hoo Mill crossroads and carrying OS Maps. They said they were from the National Trust at Shugborough and were identifying the proposed route of HS2.

4. Timetable for Community Grant Applications:

After the Bill had finally been given Royal Assent at the end of 2019 or early 2020, Community Funds, CEF, would be available for local projects, e.g. Road Safety, but these would require more rigorous applications with tender, etc.

Applications would be assessed and monitored by Groundworks, who were independent of HS2. Offers of volunteer labour input or part funding from elsewhere would be helpful.

Colwich had suggested funding for improving the Trent & Mersey Canal Towpath. Applications would be considered on merit rather than on the size of the area applying.

5. AOB:

Dr Andrews asked if the Parish Council needed to do anything further regarding the roundabout at Hoo Mill crossroads and the new footway along Ingestre Road. Omar said no, this was now in the system.

Mr Hall asked how much the traffic along Ingestre Road would increase during construction. It was noted that in addition to Utility Compounds accessed via Ingestre Gold Club, there was a further Pipeline Utility and Satellite Compound by Hoo Mill crossroads, accessed off Ingestre Road.

Omar said the Pipeline or Trent North Utility would only be active for about 6 months, and the Satellite Compound was not the main works site. He agreed to send updated figures for traffic along Ingestre and Tixall Roads.

Mrs Parrott noted that the plans provided by Ingestre Golf Club for their proposed site at Holdiford Road were still inaccurate, e.g. no agreement had been reached to access the site from Holdiford Road.

HIGH SPEED RAIL (WEST MIDLANDS - CREWE) BILL - ADDITIONAL PROVISION 2- HOUSE OF COMMONS SELECT COMMITTEE:

PETITION HS2-AP2-021 - INGESTRE WITH TIXALL PARISH COUNCIL 7 May 2019

I am writing to you in my capacity as the Director of Hybrid Bill Delivery at HS2 Ltd, which is acting on behalf of the Promoter of the High Speed Rail (West Midlands-Crewe) Bill (the Bill') currently before Parliament I understand that Ingestre With Tixall Parish Council has a number of concerns about the impact of the proposals in Additional Provision 2 (AP2) to the Bill in the House of Commons and has submitted a petition on that basis.

Following conversations with my colleague Omar Deedat, I am writing to you, on behalf of the Secretary of State for Transport, to offer the Parish Council the following assurances:

In these assurances:

"the Footway" means a pedestrian footway to be provided along the part of Ingestre Park Road shown edged black on the plan attached to this assurance; "the Proposed Scheme" means Phase 2a of HS2;

Visibility Splays

1. If the relevant highway authority does not retain the Temporary Roundabout permanently, the Secretary of State will require the nominated undertaker to engage with Staffordshire County Council during the detailed design of the Proposed Scheme in relation to the improvement of the visibility splays at the junction.

2. Subject to any proposals meeting the proposals in paragraph 3 below, the Secretary of State will require the nominated undertaker to implement any reasonable proposals put forward from the engagement with Staffordshire County Council to improve the visibility splays at the junction.

3. The conditions referred to in paragrph 2 above are:

a. that the proposals can be implemented within the powers or limits of the Bill.

b. the proposals do not give rise to any new or different environmental effects to those assessed in the Environmentall Statement or effect compliance with the Environmental Minimum Requirements: and

c. the proposals can be implemented within the construction programme for the Proposed Scheme and do not prejudice the safe, timely and economic delivery of the Proposed Scheme.

BOAT 1/Ingestre Park Road Footway

1. Subject to the conditions in paragraph 2 below being satisfied, the Secretary of State will require the nominated undertaker to provide the Footway as part of the Proposed Scheme prior to the use of Ingestre Park Road by HS2 construction traffic.

2. The conditions referred to in paragraph 1 are:

a. that the provisions contained in Additional Provision 2 relating to Ingestre Park Golf Course (AP2-002-010) receive Royal Assent and are implemented as part of the Proposed Scheme;

b. that the Footway can be constructed and retained within the powers and limits of the Bill

c. that Staffordshire County Council agree to the Footway being provided and agree to adopt the Footway;

d. that the Footway does not give rise to any new or different environmental effects to those assessed in the Environmental Statement or effect compliance with the Environmental Minimum Requirements; and

e. that the Footway can be constructed within the construction programme for the Proposed Scheme and does not prejudice the safe, timely and economic delivery of the Proposed Scheme.

If accepted, these assurances will be included in the Register of Undertakings and Assurances, which is held by the Department for Transport. Drafts of the Register will be published regularly during the passage of the Bill and it will be finalised after Royal Assent. A nominated undertaker will be contractually obliged to comply with all relevant undertakings and assurances set out in the Register. The assurance process is set out in Annex A.

Additionally, I wrote to you on 29 March offering the following assurances:

1. Use of Hanyards Lane

1.1 During the construction of the Proposed Scheme the Secretary of State will require the nominated undertaker in so far as reasonably practicable, after taking account of the relevant factors referred to in paragraph 1.2 below, to seek to utilise any Relevant Site Haul Roads as a construction route for Large Goods Vehicles between the public road network and the Compound for the purposes of mitigating the nominated undertakers expected frequency and/or period of use of Hanyards Lane as a construction route for Large Goods Vehiclles and Construction Vehicles between the public road network and the Compound.

1.2 The relevant factors referred t in paragraph 1.2 above are:-

1.2.1 compliance with all relevant approvals, permissions, undertakings and assurances regarding the operation and use of any Relevant Site Haul Roads; and

1.2.2 the safe, timely and economic delivery of the Proposed Scheme

2. Hoo Mill roundabout

2.1 Recognising that lngestre and Tixall Parish Council would like the temporary roundabout proposed in the Bill at Hoo Mill Lane and shown on Map Number CT-05-212 in the CA2 Colwich to Yarlet Mapbook, in Volume 2 of the Environmental Statement ("the Temporary Roundabout") to be made permanent, the Promoter will require the nominated undertaker to design and construct the works to provide the Temporary Roundabout in a manner that does not preclude this subject to the satisfaction of the conditions in paragraph 2.2.

2.2 The conditions in paragraph 2.1 are:

i. the nominated undertaker being satisfied that the permanent retention of the Temporary Roundabout can be delivered without the need for any additional land to that included within the limits of land to be acquired or used in the Bill; and

ii. Staffordshire County Council securing the necessary consents and approvals to enable the permanent retention and adoption of the Temporary Roundabout under relevant legislation prior to the Temporary Roundabout being removed by the nominated undertaker.

Yours sincerely

Oliver Bayne Director, Hybrid Bill Delivery High Speed Two (HS2) Limited

PETITION SUBMITTED 22.2.2018

Group of organisations’ details

Names of organisations

1. Ingestre with Tixall Parish Council

2. St Mary's Ingestre Parochial Church Council

3. Friends of Ingestre Orangery

Details of individuals in organisations

First name(s)

Anne

Last name

Andrews (Parish Clerk)

Address line 1

2, The Hanyards

Address line 2

Tixall, Stafford

Post Code

ST18 0XY

Phone

01785 246101

Who should be contacted about this petition?

Individual above x

Terms and conditions

Personal information

A copy of this petition and information provided in the online form will be:

· kept in the Private Bill Office and as a record in the Parliamentary Archives.

· sent to the Department for Transport and High Speed Two (HS2) Limited after the petition has been received by the Private Bill Office.

We will publish your petition on UK Parliament’s website. This will include your name and address.

The personal information you have provided may be kept in a database by both Private Bill Offices.

Communications

Private Bill Office staff may call or email any of the people named in the petition to verify the information provided.

Communications may be stored in databases to keep track of information you have given or received. This information may be shared between the Private Bill Offices.

Consent and confirmation

The information you have provided in the petition and online form is accurate.

If you have completed the form on behalf of an individual, a group of individuals, an organisation, or a group of organisations, you have been authorised to do so.

x☐ Check this box if you agree to the terms and conditions

Hybrid Bill Petition

House of Commons

Session 2017-19

High Speed Rail (West Midlands – Crewe) Bill

Do not include any images or graphics in your petition. There will be an opportunity to present these later if you give evidence to the committee.

Your bill petition does not need to be signed.

Expand the size of the text boxes as you need.

1. Petitioner information

In the box below, give the name and address of each individual, business or organisation(s) submitting the petition.

1. Ingestre with Tixall Parish Council

c/o Dr Andrews, 2, The Hanyards, Tixall, Stafford ST18 0XY

2. St Mary's Ingestre Parochial Church Council

c/o Mrs Susan Haenelt, The Lindens, Ingestre ST18 0RE

3. Friends of Ingestre Orangery

c/o Mrs Gill Broadbent, Maple Cottage, 8,Home Farm Court, Ingestre ST18 0PZ

In the box below, give a description of the petitioners. For example, “we are the owners/tenants of the addresses above”; “my company has offices at the address above”; “our organisation represents the interests of…”; “we are the parish council of…”.

1. We are the Parish Council of Ingestre with Tixall both of which are directly affected by HS2 Phase 2a.

2. Ingestre Church will be directly affected by HS2 Phase 2a

3. Ingestre Orangery will be directly affected by HS2 Phase 2a

2. Objections to the Bill

In the box below, write your objections to the Bill and why your property or other interests are specially and directly affected. Please number each paragraph.

Only objections outlined in this petition can be presented when giving evidence to the committee. You will not be entitled to be heard on new matters.

1. Effects of Road Transport to HS2 during construction

· 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.

· Alternative emergency access could be obtained by repairing the surface of Trent Drive and the River Bridge, although there is some local opposition to this.

· Similarly access to Ingestre Pavilion beyond Upper Hanyards Farm must be maintained 24/7, including for large Timber HGVs and Farm tractors and trailers.

· Major adverse effects at The Blackheath Lane/Baswich Lane/Tixall Rd signals. 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 Blackheath Lane when the lights change and they are not expecting another junction 22.4m away.

· An alternative solution has been suggested by an Ingestre resident to have a temporary haul route from the A51 at Pasturefields , across a couple of Bailey Bridges over the fields direct to HS2. This would remove the need to use Tixall Rd except, initially Hanyards Lane to Blackheath Lane.

· An additional solution would be to replace the deep cuttings on either side of Upper Hanyards Farm with a cut and cover tunnel to reduce the amount of spoil to be transported away from the site.

2. Noise Effects (E19 Vol.2 Map Book)

· Increase in airborne noise from new train services both daytime and night-time in Ingestre and Tixall, probably 12/hr in both directions. Residents of Ingestre have paid higher house prices to be able to live in a quiet and peaceful location. This will no longer be the case.

· 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.

· Construction traffic is likely to cause adverse noise effects on occupants of residential dwellings adjacent to Tixall Road, and Hanyards Lane, between the Proposed Scheme and Tixall Road

· The HS2 line will require ongoing maintenance at night which will result in more disturbance for local residents, both from noise and lighting. Further evidence will be required to support this.

· Ingestre Church is now a significant venue for concerts and any increase in noise levels would impact on this.

· A further solution is to provide adequate sound barriers on the viaduct and embankments.

3. Vibration

· Effects of vibration, during construction. Numerous listed buildings are within a few hundred metres of the route, e.g. Grade I listed church of St Mary the Virgin, Ingestre, 400m from the area of the works; Ingestre Hall (Grade II*) is closer, at 350m and Ingestre Pavilion (Grade II) closer still at 150m. All in proximity to the substantial Hanyards Cuttings, nearly 20m deep, in hard sandstone. 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.

There is particular concern on the effects of any vibration on the above Listed Buildings which have no substantial foundations.

4. Visual Effects

· The Viaduct with noise barrier and Brancote/Hanyards North Cutting will be an unacceptable visual intrusion on this historic landscape, especially the Staffs & Worc Canal Conservation Area and Tixall Conservation Area and Listed Buildings. 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.

· 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.

· The EIA notes a medium adverse impact and moderate adverse significant effect for the Ingestre Conservation Area. Trent N embankment and 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. 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.

· The remnant Golf Course directly in front of Ingestre Hall, will become wasteland possibly ripe for development as a brownfield site.

· A cut and cover tunnel instead of the Hanyards cuttings could reduce the amount of spoil to be removed along our local roads and improve the visual and noise effects from both Ingestre and Tixall.

5. Impacts on the communities of Ingestre and Tixall and lack of any benefit to our residents

· Failure to acknowledge the following businesses: 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.

· We strongly object to the exclusion of the very real issue of impacts on the community of generalised property blight. 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.

· Potential Loss of Ingestre Park Golf Club and it's social facilities

· Adverse effect on local businesses/community facilities: 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.

· Many of the houses purchased by HS2 which are being let have remained empty. This has a significant negative effect on the local community.

6. Failure to act on previous requests by Parish Council - no 2-way communications

· 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. Primarily because they have refused to carry out an Appropriate Assessment to show that there would be no significant effect on the Pasturefields SAC. This would involve new borehole evidence, etc. and was very different from the Habitat Regulations Assessment (HRA) already carried out by HS2 with regard to the SAC. The BGS (January 2014) said: "The review of the information that has been presented leads us to conclude that each phase of investigation of the PSMSAC has built upon the previous phase. As a consequence alternative conceptual ground models have not been presented or tested. Furthermore, there has been little resolution in issues regarding the alleged deterioration in the quality of the PSMSAC, e.g. whether or not leakage from the canal is diluting the emerging groundwater, the impacts of flooding of the River Trent and the source of nutrients that impact on biodiversity. Without this baseline data it is hard for anyone to predict the potential impact of the proposed HS2 construction along any of the proposed alignments."

7. Failure to fully understand local hydrology

The salt marsh part of the site is non-designated yet is potentially of national importance.

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).

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, 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.

· an Appropriate Assessment of the effect on Pasturefields SAC is essential to determine if there would be any risk of an adverse impact arising from Route B.

· 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.

The British Geological Survey have pointed out none of the routes proposed by HS2 can be guaranteed not to have an effect on the SAC.

However, planning permission for a marina at Pasturefields has recently been passed, and there has been industrial development nearby, none of which appear to have had any effect on the SAC.

Meeting with HS2 Representatives January 23rd 2018

Present:

Representing the Parish Council: Malcolm Sindrey (Chairman), Dr Anne Andrews (Parish Clerk & Cllr),

Nicholas Bostock (Cllr.), Sue Haenelt (Vice Chairman), Nicola Woodhouse (Cllr.)

Representing Ingestre Church and Friends of Ingestre Orangery: Gill Broadbent

Representing HS2: Adrian Osborne (HS2 responsible for delivering the Hybrid Bill with regard to the

Environment), Omar Deedat (HS2 Petition Management), Joe Wilson (HS2 Stakeholder

Advisor),Jason Fairbairn (HS2 Hydrogeologist), Simon Dale-Lace (HS2 Hydrogeologist)

Apologies: Penny Brookes and David Cooke

The Petitioning Process

This was described by Omar Deedat with the help of 2 handouts. The Hybrid Bill Delivery Directorate is composed of Oliver Bayne, Delivery Director; Simon Knight, Head of Management & Technical teams; and then two Senior Petition Managers: Martin Wells for Complex Agreements, e.g. Staffs CC; and Laura Wise for Individuals and Communities, e.g. PCs.

The Hybrid Bill Process has now progressed through the 1st Reading, which is a procedural step authorising the printing of the bill, but with no debate; A public Consultation on the Environmental Statement; to the 2nd reading.

The 2nd reading is scheduled for the end of January, and will establish the principles of the Bill with debate in Parliament. It will also set the length of the petitioning period and assure the principle of the scheme.

This will be followed by a Petitioning Period; Petitions being heard by a Select Committee; a Public Bill Committee with further consideration and possible amendments by MPs; and then the 3rd reading when the House considers the bill again with any possible amendments by MPs.

The Bill then goes through a similar process in the House of Lords, before returning to the Commons for further debate and approval of any Lords amendments; and then finally Royal Assent.

Full petitioning guidance and template are available from:

www.parliament.uk/business/committees/committees-a-z/commons-select/high-speed-rail-west-midlands-crewe-bill-select-committee-commons/news-/

During this process the Bill can be amended but not stopped. The design is evolving during this process. Following the Phase 1 petitions it has been suggested that generic objections should be heard together.

The formal decision of the Select Committees for Phase 1 is a useful guide and is available at:

www.parliament.uk/business/committees/committees-a-z/commons-select/high-speed-rail-london-west-midlands-bill-select-committee-commons/news-parliament-20151/hs2-london-west-midlands-bill-report-published-15-16/

and: www.parliament.uk/business/committees/committees-a-z/lords-select/high-speed-rail-london-west-midlands-bill-select-committee-lords/news-parliament-2015/hs2-bill-committee-publishes-report/

Some changes to the design will occur as more information becomes available, e.g. from further surveys. Any additional information that changes the reported effects of the scheme by HS2 can be reported in Supplementary Environmental Statement, (SES) but some human errors are inevitable. There were 3 Supplementary Environmental Statements for Phase 1.

During the course of Select Committee process, changes to the Proposed Scheme maybe identified as a result of discussions with stakeholders, continued project development, and in response to the Select Committee’s decisions.

In some cases these revisions involved the acquisition or use of land outside of the current limits of the Bill, additional access rights or other extensions of the powers conferred by the Bill, making it necessary to submit an Additional Provision. There were 5 Additional Provisions for Phase 1.

In addition Ground Investigations, or GIs, such as boreholes, will be carried out if the land can be accessed and these will feed into the engineering design.

We questioned the continuing factual errors in HS2 documents, eg. Brancote cf Hanyards Cutting and calling the Tixall Rd to Hoo Mill crossroads, Gt Haywood Rd. We were told that these names were consistent with their initial guidelines, and it seems cannot be changed.

We then continued to consider the various items we had outlined to HS2 in advance of the meeting

1. Why has ARUP/ERM not referred to the BGS report, only Envireau ? It was explained that Envireau included consideration of the BGS report.

2. Why is the line of the ARUP/ERM section not shown in Figs 2 & 3 ?

Because a different section line is used by ARUP/ERM to that used by Envireau, it is difficult to compare the two sections and the ARUP/ERM section excludes Lion Lodge Covert and the adjacent saltmarsh which is known to have Common Saltmarsh Grass growing on it, and the saline pool, possibly St Erasmus Well in the wood.

HS2 said that as they were primarily concerned to show that there would be no effect on the Pasturefields SAC they had chosen a different line.

3. Why is HS2's knowledge of surface water and drainage in this area so poor ?

Known land drains and watercourses were not included in the map previously supplied by your Hydrogeology expert following our last meeting, despite HS2 having previously been given a map by Mr M.Woodhouse 7.11.2016.

Similarly, during a recent visit by HS2 to Lion Lodge Covert, with the owner's son, Mr Field, HS2 were surprised to be shown the saline pool in the wood.

We expressed concern that lack of knowledge of local drainage could result in problems similar to those resulting from recent work by Amys in laying a new sewer nr St Thomas Priory, with field drains being destroyed and having to be relaid at considerable expense.

4. Barker’s map of groundwater salinity distribution, shown in Figure 6 in his report, refers specifically to his interpretation of groundwater salinity within the uppermost bedrock alone (and excludes salinity within the overlying superficial geology, within which Pasturefields SAC is situated).

Therefore why is the salinity shown in HS2 Fig.2 of the superficial geology ?

We did not get a satisfactory answer to this question although HS2 had spoken to Barker who has now retired.

5. In ARUP/ERM 3.2.9 you note that Barker also acknowledges that his conclusions regarding the general role of the Tixall Fault in this regard are inconclusive.

Coincidentally, however, it is at the intersection of the route of the Proposed Scheme with the Tixall Fault where Barker’s interpretation concerning the distribution of saline groundwater is much more clearly aligned with (and constrained by) the subcrop of the Tixall fault (note that the Tixall Fault pre-dates deposition of the superficial geology and therefore does not extend into the drift geology itself).

At this location saline groundwater within the bedrock does not appear, according to Barker, to extend westwards beyond the Tixall Fault. This suggests that there is no pathway, at this location, for westward migration of saline groundwater towards Pasturefields SAC.

But Pasturefields SAC is N of this intersection, not W - see HS2 Fig 3.

We did not really get a satisfactory answer to this question. We were refered to Envireau Fig 3, which shows the possible saline groundwater flowing from NE of Pasturefields SAC down to Lion Lodge Covert and Barkers area of saline groundwater.

HS2 pointed out that the Environment Agency in consultation with Natural England, were satisfied that the current route would not affect Pasturefields SAC.

If there was a potential effect on the SAC, HS2 would take appropriate mitigation measures and these would have to be passed by the Environment Agency in conjunction with Natural England.

6. It is not clear from ARUP/ERMs report how the saline groundwater gets to Lion lodge LWS and the pool in the wood ? This is directly in the path of the proposed HS2 Route.

Envireau Fig.3 shows saline groundwater flow in a NE & SW direction towards the R.Trent beyond Pasturefields SAC, but also in a SW and SE direction towards the area of saline groundwater shown on ARUP/ERMs figures.

Again if there was found to be a potential effect on the SAC, HS2 would take appropriate mitigation measures and these would have to be passed by the Environment Agency in conjunction with Natural England.

7. What precautions will be taken to stop any long term chemical effect of the viaduct pile concrete polluting the local groundwater ?

The hydrochemistry of the piles would be designed for a 120yr life. Different concrete mixes would be used for different parts of the scheme depending on local conditions. It was noted that the saline ground water could have a direct effect on piling.

8. ARUP/ERM states that the Hanyards cutting will extend to a maximum depth of 17m bgl in the Mercia Mudstone and a maximum depth of 13.3m bgl within the Sherwood Sandstone in the worst case.

Do these figures include the depth of sub-base, ballast and track as suggested by Envireau in their figure of 19m ?.

We were shown a picture of the proposed Colne Viaduct in Buckinghamshire. Viaducts would be to a standard design, which could then be modified after consultation with the local community, e.g. Noise barriers up to a certain height and a sandstone finish on the concrete.

The Hanyards cutting would be an average of 9.6m deep, with an average of 10.5 through the mudstone and 11.5 through the sandstone. Soundproofing barriers would be at the trackside, i.e. in the cutting. Due to the changing depth of the cutting, trains would be visible in some parts.

We then raised other areas of concern:

1. Road Access to the construction sites. Tixall Rd is unsuitable for any additional HGV traffic, it has many blind bends and blind changes in elevation. There are many lengths of the road where overtaking is impossible. The proposed widening by Tixall Church and Tixall Manor Farm, and 2 additional passing places will not solve these problems. These problems had also been raised by Staffs CC.

Instead we suggested a direct, temporary haul route from the A51 at Pasturefields to HS2 with 2 Bailey Bridges over the canal and river. HS2 agreed to investigate this further.

We also raised the problem of HGVs emerging from or entering Hanyards Lane 25m from the traffic lights at the bottom of Blackheath Lane.

HS2 said that designated construction routes were still subject to approval, and would be subject to maximum dust, noise, and visual impacts. Haul routes, eg. from Hanyards to the Weston Rd would run alongside the track without any additional landtake.

We also noted again the need to have 24/7 access to Ingestre for emergency vehicles and local residents. HS2 said this had been noted.

2. Possible blasting to make the deep cuttings. We expressed concern at the lack of knowledge of the exact nature of the underlying sandstone and the possible effect on buildings such as Ingestre Church is blasting was necessary. HS2 said that there were now various ways of making the cutting, and the general design would set maximum limits , or the worst case for the impact of vibration and noise.

3. We noted that HS2s Noise baseline for Ingestre was significantly higher than the actual level. People had moved to Ingestre, and paid premium prices for their houses, because of this peace and quiet. The increase in noise level to HS2s baseline is significant, let alone any additional noise from the construction and operation of HS2.

Ingestre Church is an important national and international concert venue, like St Marys Church, Wendover, and Ingestre Hall Residential Arts Centre has a strong music department.

It was noted that there was considerable discussion on the methods of noise assessment during the Phase 1 petitioning. This was reported in the subsequent Phase 1 petitioning reports. In addition, Historic England is also currently assessing the effect of noise on heritage assets.

4. We suggested that a cut and cover tunnel in place of the cuttings would significantly reduce the noise and visual impact of HS2, and reduce the amount of material to be transported away from the site. It would also do away with the need for the green bridge and access bridge to the Pavilion.

Mr Bostock said that the views from this area, which was part of the historic park landscapes of Ingestre and Tixall, to the Wrekin and over Staffordshire, were incredible and should be preserved.

HS2 noted that to construct a cut and cover tunnel would take longer and have to go deeper, and there could be problems aligning it with the level of viaduct. It would also need additional land take at the entrance and entrance to provide emergency evacuation facilities.

HS2 also noted that the greenbridge was a unique , skewed design to link the two parklands as well as the local wildlife.

5. In conclusion we remained concerned that most information provided to HS2 Ltd in previous communications has been ignored. This is partly because consultations responses are combined in a report which just summarises the main points raised, losing much of the specific details, 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. Brancote S cutting is actually N of Brancote. This is already leading to confusion amongst local residents and no doubt with contractors in the future.

The chairman then thanked everyone for attending and for their contributions and the meeting closed at 8.47m.

Review of Habitats Regulations Assessment (HRA) screening assessment for Pasturefields Salt Marsh Special Area of Conservation (SAC)

Contents
1 Introduction 1
2 Context 3
3 Review and findings 4
3.1 Introduction 4
3.2 Envireau suggested hydrogeological mechanism 4
3.3 HS2 Ltd response to Envireau Suggested Mechanism 8
3.4 Individual concerns raised 9
4 Conclusions 14
5 References 15
6 Figures 16

1 Introduction
1.1.1 A Habitats Regulations Assessment (HRA) screening report1 was undertaken for the Pasturefields Salt Marsh Special Area of Conservation (hereafter referred to as Pasturefields Salt Marsh SAC) as part of the HS2 Phase 2 Appraisal of Sustainability2.
The HRA screening report considered the potential construction and operational effects from the proposed route alignment on the Pasturefields Salt Marsh SAC due to hydrological processes. It concluded that the chosen route alignment option would have no likely significant effect, and this conclusion has been agreed with Natural England and the Environment Agency.
1.1.2 This report has now been prepared in response to additional information that has subsequently been made available to HS2 Ltd as a result of a representation by Mr Jeremy Lefroy, MP for Stafford Constituency. This comprised an interpretative report by Envireau Limited (hereafter referred to as the Envireau report)3 founded upon a geophysics report by Barker (1979)4. At the time that the HRA screening report and subsequent Environmental Statement5 were produced, Barker’s geophysics report
was not in the public domain as it was a private report commissioned by the then Severn Trent Water Authority (STWA).
1.1.3 Barker’s objective was to characterise the distribution of saline groundwater in the bedrock surrounding STWA’s public water supply (PWS) borehole at Essex Bridge, approximately 1.25km south of the proposed Great Haywood viaduct, as shown in Figure 1, and from which water was derived for public supply.
1.1.4 Based on information contained within the Barker report, the Envireau report raises concern that a potential mechanism for the Proposed Scheme to impact Pasturefields Salt Marsh SAC had not been adequately considered in the HRA screening report. The concerns raised within the Envireau report are now considered in this report and whether they change the conclusions of the HRA screening report for Pasturefields Salt Marsh SAC.
1.1.5 HS2 Ltd has consulted with Natural England and the Environment Agency regarding the Envireau report and agreed to review the additional information provided and reported therein. Natural England has requested that the implications of this additional information for Pasturefields Salt Marsh SAC and/or the Proposed Scheme are reviewed and reported.
1.1.6 Whilst there are no changes to the route alignment option of the Proposed Scheme, additional design details and refinements are now available for the Proposed Scheme, 1 Introduction
1.1.1 A Habitats Regulations Assessment (HRA) screening report1 was undertaken for the Pasturefields Salt Marsh Special Area of Conservation (hereafter referred to as Pasturefields Salt Marsh SAC) as part of the HS2 Phase 2 Appraisal of Sustainability2.
The HRA screening report considered the potential construction and operational effects from the proposed route alignment on the Pasturefields Salt Marsh SAC due to hydrological processes. It concluded that the chosen route alignment option would have no likely significant effect, and this conclusion has been agreed with Natural England and the Environment Agency.
1.1.2 This report has now been prepared in response to additional information that has subsequently been made available to HS2 Ltd as a result of a representation by Mr Jeremy Lefroy, MP for Stafford Constituency. This comprised an interpretative report by Envireau Limited (hereafter referred to as the Envireau report)3 founded upon a geophysics report by Barker (1979)4. At the time that the HRA screening report and subsequent Environmental Statement5 were produced, Barker’s geophysics report
was not in the public domain as it was a private report commissioned by the then Severn Trent Water Authority (STWA).
1.1.3 Barker’s objective was to characterise the distribution of saline groundwater in the bedrock surrounding STWA’s public water supply (PWS) borehole at Essex Bridge, approximately 1.25km south of the proposed Great Haywood viaduct, as shown in Figure 1, and from which water was derived for public supply.
1.1.4 Based on information contained within the Barker report, the Envireau report raises concern that a potential mechanism for the Proposed Scheme to impact Pasturefields Salt Marsh SAC had not been adequately considered in the HRA screening report. The concerns raised within the Envireau report are now considered in this report and whether they change the conclusions of the HRA screening report for Pasturefields Salt Marsh SAC.
1.1.5 HS2 Ltd has consulted with Natural England and the Environment Agency regarding the Envireau report and agreed to review the additional information provided and reported therein. Natural England has requested that the implications of this additional information for Pasturefields Salt Marsh SAC and/or the Proposed Scheme are reviewed and reported.
1.1.6 Whilst there are no changes to the route alignment option of the Proposed Scheme, additional design details and refinements are now available for the Proposed Scheme, as well as an alternative opinion reported by Envireau regarding potential water borne pathways supporting Pasturefields Salt Marsh SAC. These have all now been reviewed in combination and potential concerns assessed.
1 High Speed 2 Ltd, (2012), Screening Report for Pasturefields Salt Marsh Special Area of Conservation.
2 High Speed 2 Ltd , (2013), High Speed Rail: Consultation on the route from the West Midlands to Manchester, Leeds and beyond, Sustainability
Statement, Volume 1: Appendix E4 Biodiversity
3 Envireau Water, (June 2017), Hydrogeological Conceptualisation of Pasturefields Salt Marsh SAC & Ingestre/Tixall Salt Marsh SBI Great Haywood,
Staffordshire.
4 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
5 HS2 Ltd (2017), High Speed Rail (West Midlands – Crewe) Environmental Statement, Volume 2: Community Area report, CA2: Colwich to Yarlet.
Available online at: https://www.gov.uk/government/publications/hs2-phase-2a-environmental-statement.

2 Context 2.1.1 Pasturefields Salt Marsh SAC is located approximately 7km to the east of the centre of Stafford, in between the Trent & Mersey Canal (also known as the Grand Trunk Canal) and the River Trent in the West Midlands. It is the only significant remaining example in the UK of a natural saline spring with inland saltmarsh vegetation. The primary reason for the designation of the SAC is the presence of inland salt meadows, a priority habitat which is listed on Annex I of the Habitats Directive6. Figure 1 shows the site location.
2.1.2 The HRA screening report considered route alignment options to the north and south of Pasturefields Salt Marsh SAC. As part of the HS2 Phase 2 Appraisal of Sustainability the potential hydrological effects associated with these route alignment options on Pasturefields Salt Marsh SAC were further considered. It was concluded that the chosen route alignment option to the south would have no likely significant effect on the SAC as it does not intersect with the surface water or groundwater catchment of the SAC. It was therefore concluded that an appropriate assessment under the
Habitats Regulations was not required. Route alignment options to the north were, however, assessed by HS2 Ltd as being unlikely to satisfy the requirements of the Habitats Regulations.
2.1.3 The overall horizontal and vertical route alignment of the Proposed Scheme has therefore not subsequently changed. Note that an Addendum to the HRA Screening Report7 considered the potential for air quality effects due to the need to use the A51 Lichfield Road as a construction route for the Proposed Scheme. This report also
concluded that there were no likely significant air quality effects on the Pasturefields Salt Marsh SAC during construction of the Proposed Scheme.
2.1.4 Due to the additional information presented within the Barker report, as identified and further interpreted within the Envireau report, and the concerns raised as a result, this report now provides a review of the original HRA screening conclusions in relation to surface water and groundwater.
6 Council Directive 92/43/EEC of 21 May 1992 on the conservation of natural habitats and of wild fauna and flora. Strasbourg, European Parliament
and European Council, http://jncc.defra.gov.uk/Publications/JNCC312/UK_habitat_list.asp
7 HS2 Ltd (2017), High Speed Rail (West Midlands – Crewe) Environmental Statement, Volume 5: Ecology and biodiversity technical appendices:
Habitats Regulation Assessment screening report – Pasturefields Salt Marsh Special Area of Conservation addendum. Available online at:
https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/627065/E55_EC-017-004_WEB.pdf

3 Review and findings
3.1 Introduction
3.1.1 The Envireau report considers the potential geological and hydrogeological systems which may contribute to the saline water input that sustains Pasturefields Salt Marsh SAC. On the basis of these considerations, the Envireau report suggests that the Great Haywood viaduct, the Trent North embankment, and the Brancote South cutting could all affect the saltmarsh habitat within the Pasturefields Salt Marsh SAC. The potential effect raised by the Envireau report in association with these design
elements is considered in this section.
3.1.2 Figure 2 shows the British Geological Survey (BGS) mapped superficial geology in the area. Figure 3 shows the BGS bedrock geology in the area including mapped geological faults. Figure 4 shows a geological cross-section along the route of the Proposed Scheme from the River Trent viaduct to the Brancote South cutting.
Figure 5 shows a schematic geological cross-section between the route of the Proposed Scheme at the Brancote South cutting and Pasturefields Salt Marsh SAC including annotation regarding the proposed water supply pathways proposed within the Envireau report. Maps showing the key construction (Map Series CT-05) and operation (Map Series CT-06) features of the Proposed Scheme can be found in the
Phase 2a Environmental Statement Volume 2 Map Book CA2: Colwich to Yarlet 8.
3.2 Envireau suggested hydrogeological mechanism
3.2.1 As explained in Section 1, the Envireau report raises concern that a potential mechanism for the Proposed Scheme to impact Pasturefields Salt Marsh SAC has not been adequately considered. In this regard Envireau’s proposed hydrogeological mechanism is founded upon the Barker report4. The mechanism suggested in the Envireau report, about the possible existence of a sub-surface water flowpath
between the Proposed Scheme and Pasturefields Salt Marsh SAC, is first outlined below. Details of both the Barker and Envireau reports in relation to this proposed potential hydrogeological mechanism are thereafter also summarised below, in order to provide insight into the development of the suggested mechanism.
3.2.2 The components of the hydrogeological mechanism suggested in the Envireau report are illustrated in Figure 5 and include:
1. recharge from rainfall at outcrop into the Sherwood Sandstone Group;
2. downwards flow of recharge through the topographically higher and more permeable strata of the Sherwood Sandstone Group (compared to the Mercia Mudstone Group);
3. upward flow of groundwater due the suggested increase in permeability surrounding the Tixall Fault, resulting in a vertical hydraulic gradient from the
confined Sherwood Sandstone Group up the Tixall Fault and through the Mercia Mudstone Group;
4. groundwater flowpath through the saliferous beds within the Mercia Mudstone Group resulting in saline groundwater; and
5. emergence of saline springs through the superficial deposits.
Barker’s Geophysical Data and Salinity Results
3.2.3 As discussed in Paragraph 1.1.3, Barker’s objective was to characterise the distribution of saline groundwater in bedrock surrounding the STWA Essex Bridge groundwater supply borehole, 2km to the south of Pasturefields Salt Marsh SAC (immediately south of the confluence of the River Sow and River Trent), the locations of which are shown in Figure 1. In this regard, although Barker’s report presents information that is new to HS2 Ltd, the report itself is for the most part factual and therefore of a
descriptive nature based upon interpretation of geophysical measurements aligned with salinity distribution. Whilst passing reference is made to saline springs in the area, Barker did not specifically investigate these, nor any aspect of Pasturefields Salt Marsh SAC. Regarding the role of any hydrogeological mechanism influencing the distribution of saline groundwater Barker is cautious, alluding to a potential partial role that the Tixall Fault may play in limiting this distribution (rather than being a conduit for saline groundwater flow in itself). At the end of Section 4.1 Barker’s report states:
3.2.4 “The area of strongly saline groundwater is approximately defined by the 25 ohm-m contour and is seen to cover the whole region between Tixall Farm and Essex Bridge and to extend northwards along the valley of the River Trent. It is presumably this zone of saline water that has been the source for saline springs which have been observed in the Tixall Farm area in the past and which have favoured the growth of halophytic plants”.
3.2.5 Furthermore, in the report’s conclusions, the following inference is made:
3.2.6 “The position of the saline groundwater plume appears to be controlled partly by the Tixall Fault in the north-west and possibly by other faults to the south of Essex Bridge”.
3.2.7 Barker therefore makes no comment on whether or not the Tixall Fault itself is material to the supply of saline groundwater to the general area, nor to Pasturefields Salt Marsh SAC in particular, merely that a zone of saline groundwater exists in the general area.
3.2.8 Although geophysical measurements within the overlying superficial geology, shown in Figure 2, are recorded by Barker, he acknowledges that these are uncertain due to a lack of adequate control (calibration) data and that the focus of his work is the underlying bedrock shown in Figure 3. This is because the Essex Bridge borehole abstracts groundwater from the underlying bedrock of the Sherwood Sandstone Group. The saliferous beds, from which high concentrations of salinity in the local
groundwater are derived, are located within the Mercia Mudstone Group, which occur locally to the north and east of the Essex Bridge groundwater supply borehole, as shown in Figure 3. Note that Barker’s map of groundwater salinity distribution, shown in Figure 6 in his report, refers specifically to his interpretation of groundwater salinity within the uppermost bedrock alone (and excludes salinity within the overlying
superficial geology, within which Pasturefields Salt Marsh SAC is situated).
3.2.9 Whilst the Barker report offers some insights into the potential role of the local geology around Shugborough and the River Trent to help account for the distribution of saline groundwater in the area, the report also acknowledges that its conclusions regarding the general role of the Tixall Fault in this regard are inconclusive.
Coincidentally, however, it is at the intersection of the route of the Proposed Scheme with the Tixall Fault where Barker’s interpretation concerning the distribution of saline groundwater is much more clearly aligned with (and constrained by) the subcrop of the Tixall fault (note that the Tixall Fault pre-dates deposition of the superficial geology and therefore does not extend into the drift geology itself). At this location saline groundwater within the bedrock does not appear, according to Barker, to extend westwards beyond the Tixall Fault. This suggests that there is no pathway, at this location, for westward migration of saline groundwater towards Pasturefields Salt Marsh SAC.
3.2.10 To the north and south of the Tixall Fault, Barker’s delineation of saline groundwater in the area diverges from the alignment of the fault subcrop, as shown in Figure 3, and this clearly demonstrates that the fault is not the sole factor in determining the distribution of saline groundwater in the bedrock within the wider area.
3.2.11 In many instances Barker’s narrative is from his primary focus around the Essex Bridge groundwater supply borehole, and then northwards towards the Mercia Mudstone Group, wherein lie the saliferous beds and thereby the predominant source of high salinity within local groundwater. At no point does Barker interpret this to be the direction of groundwater flow either within the bedrock or the drift deposits.
3.2.12 Similarly Barker alludes to the potential for the Tixall Fault to continue in a northeasterly
direction from that which has been mapped by the BGS towards Pasturefields Salt Marsh SAC, as shown in Figure 3. At no point does Barker interpret this to be the direction of groundwater flow within the fault zone.
3.2.13 In summary:
• Barker’s scope did not extend to investigating saline springs in the area, nor the role of the Tixall Fault in supplying saline groundwater to Pasturefields Salt Marsh SAC;
• Barker acknowledges that he lacks control data (calibration data) for groundwater salinity within the drift deposits (upon which Pasturefields Salt Marsh SAC is sited) and therefore does not extend his interpretation into the drift deposits;
• Barker’s objective was to map the distribution (and not the supply) of saline groundwater in the uppermost layers of the bedrock (sub-drift) surrounding the STWA Essex Bridge groundwater supply borehole, 2km to the south of Pasturefields Salt Marsh SAC. He makes only passing reference to saline
springs in the area and acknowledges that information regarding the Tixall Fault is incomplete and would be enhanced by gravity survey; and Barker’s mapping of salinity distribution in the uppermost bedrock is mostly at variance with the subcrop of the Tixall Fault, except in the vicinity of the route of the Proposed Scheme where the presence of saline groundwater is limited to the east of the fault, in contrast to Pasturefields SAC which is located to the west of the fault. This clearly demonstrates that the fault is not
the sole factor in determining the distribution of saline groundwater in the bedrock within the wider area. It also strongly suggests that there is no pathway, at this location, for westward migration of saline groundwater towards Pasturefields Salt Marsh SAC via the Tixall Fault.
Envireau’s hydrogeological interpretation based on salinity results
3.2.14 The Envireau report discusses the presence of saline groundwater inferred within the shallow drift deposits, as illustrated in Figure 2, and the bedrock, as illustrated in Figure 3, based upon geophysical data presented within the Barker report and located between the Tixall fault and the River Trent. The Envireau report describes this as a ‘pocket’ of saline groundwater apparently identified by Barker as being approximately 10 to 30m below ground level (bgl). This is not directly reported by Barker but is an
inference made in the Envireau report based on Barker’s work. The apparent depth interval arises from limitations in the survey method employed by Barker to clearly distinguish between saline groundwater and bedrock at greater depths, and because of the overlying drift above 10 m bgl, which was not the focus of Barker’s work (and is poorly constrained due to a lack of reliable control data). The saline water body
referred to in the Envireau report may therefore not be a discrete ‘pocket’ of saline groundwater between these depths.
3.2.15 Agreed Mechanism (Mechanism #1): Whilst not directly discussed within the Envireau report, the report’s Figure 3 clearly shows that at least a component of brine flow originates from the mapped salt subsidence area to the north, being brought to Pasturefields Salt Marsh SAC via the groundwater within the River Terrace Deposits.
This is consistent with what is reported in the HRA Screening Assessment, which was supported by Natural England and the Environment Agency. Paragraph 5.4.1 of the HRA Screening Assessment states:
This conclusion was discussed with the Environment Agency on 16th May 2012 and with Natural England on 20th May 2012, with agreement reached that the groundwater flows feeding the Pasturefields site originate to the north-east of the Pasturefields Salt Marsh SAC, with no flow from the south or west.
3.2.16 Suggested Additional Mechanism (Mechanism #2): in addition to Mechanism #1, the Envireau report proposes that the origin of brine springs in the area are potentially facilitated by deep geological faults providing flowpaths and inter-connections between saliferous deposits in the Mercia Mudstone Group and groundwater in the underlying Sherwood Sandstone Group at depth, as shown in Figure 5. Envireau therefore suggest that there may be a connection between Pasturefields Salt Marsh SAC and Lionlodge Covert Local Wildlife Site (hereafter referred to Lionlodge Covert LWS), the latter being intersected by the route of the Proposed Scheme.
3.2.17 In summary:
• Barker’s focus on groundwater salinity between 10 and 30 m bgl is on account of limitations in the geophysical survey techniques deployed, not on account of any hydrogeological processes. It is misleading for the Envireau report to suggest this particular horizon is more important or influential than any other
or that it exists as a discrete ‘pocket’ of groundwater salinity;
• the Envireau report acknowledges the Mechanism #1 pathway supplying saline groundwater to Pasturefields from the north-east; and
• the additional pathway (Mechanism #2) that the Envireau report suggests ay potentially be supplying saline groundwater from the west of the Tixall Fault is speculative.
3.3 HS2 Ltd response to Envireau suggested mechanism
3.3.1 For an impact, or potential impact, upon the saline springs and salt marshes at Pasturefields Salt Marsh SAC to be associated with the Proposed Scheme, there must be a waterborne pathway connecting the Proposed Scheme with the processes sustaining the springs and salt marshes at Pasturefields Salt Marsh SAC. This section considers the potential for such effects, bearing in mind that it is not necessary to
understand the precise details of such pathways, so long as the Proposed Scheme can be shown to avoid any such potential pathways or to have no likely significant effect upon them if indeed they are active in the first place.
3.3.2 Note that a connection between the Proposed Scheme, and Pasturefields Salt Marsh SAC and Lionlodge Covert LWS, would need to occur at depth, i.e. flow component No. 4 as shown in Figure 5, in order to entrain saline groundwater from the deeper underlying geology, and is therefore not considered by HS2 Ltd to be a feature of any shallow surface pathway.
3.3.3 As discussed in Paragraph 3.2.3, the Barker report interprets the Tixall Fault to be a controlling mechanism on the distribution of brine within the vicinity of the route of the Proposed Scheme. The fault apparently limits the brine to the area directly to the east of the fault, coincidentally at the point at which the route of the Proposed Scheme crosses the subcrop of the fault on the Great Hayward viaduct. If Barker’s interpretation is correct, then there is no component of groundwater flow in a westerly direction at this location and therefore no groundwater flowpath at this location towards Lionlodge Covert, directly to the west of the fault. However, westerly components of groundwater flow may exist north of the route of the Proposed Scheme, closer to Pasturefields Salt Marsh SAC, where the groundwater salinity distribution was interpreted to diverge from the projected subcrop of the Tixall Fault. Nevertheless in both cases, shallow groundwater flow around the intersection of the route of the Proposed Scheme and the subcrop of the Tixall Fault will be influenced by the local topography and therefore likely to be in an easterly
direction towards the River Trent (as shown in Figure 2).
3.3.4 In summary:
• it is not necessary to understand the hydrogeological processes surrounding Pasturefields Salt Marsh SAC and the Tixall Fault if there is no likely significant impact arising from the Proposed Scheme upon the processes that may potentially sustain the SAC; and
• if the hydrogeological mechanism suggested in the Envireau report is important in sustaining Pasturefields Salt Marsh SAC, the saline groundwater must originate from depth and upwell directly beneath the SAC. Any shallow emergence of saline groundwater around the intersection of the route of the
Proposed Scheme and the Tixall Fault will flow in an easterly direction towards the River Trent as illustrated in Figure 2 and not northwards towards Pasturefields Salt Marsh SAC. Furthermore, the SAC is located west of the Tixall Fault as shown in Figure 3, whereas shallow groundwater flow surrounding the intersection of the route of the Proposed Scheme with the subcrop of the Tixall Fault flows eastwards, towards the River Trent, as illustrated in Figure 2. On both counts there is no pathway for shallow
groundwater surrounding the Proposed Scheme to make its way towards the SAC.
3.3.5 The intersection of the route of the Proposed Scheme with the subcrop of the Tixall Fault occurs at the surface. The potential impacts of which can, if deemed necessary as a precautionary measure, be readily mitigated (as explained below) and are unrelated to any deeper processes that may or may not be relevant to the maintenance of saline groundwater flow towards Pasturefields Salt Marsh SAC.
Within this context each individual design element identified within the Envireau report to be of concern to them is considered below.
3.4 Individual concerns raised
Great Haywood viaduct
3.4.1 The Envireau report suggests that piling associated with the Great Haywood viaduct may intersect fault planes and high permeability zones serving as flowpaths for saline groundwater supplying Pasturefields Salt Marsh SAC and salt marsh habitat at Lionlodge Covert LWS.
3.4.2 It is important to note that the viaduct itself, and therefore the associated piles, will not extend as far west as the Tixall fault, as shown on Figure 3. At the location of the Tixall fault the Proposed Scheme will be in the form of an embankment (Trent North embankment) and there will be no requirement for deep piling at this location. No other faults have been identified within the area crossed by the viaduct.
3.4.3 The Envireau report describes the geological structures and associated hydrogeological conceptualisation potentially functioning over depths of several hundred metres below ground level, as shown in Figure 5. The fault planes discussed are identified as three dimensional structures, not only extending to several hundred metres in depth but also extending many kilometres in length and at varying angles, whilst the subject strata extend over many square kilometres in plan area, as shown in Figure 3. In contrast the piles required for the Great Haywood viaduct are singular ‘pillars’ penetrating relatively shallow depth, spatially separated by natural ground and installed in accordance with best practice and mitigation measures as set out in the Proposed Scheme’s draft Construction Code of Practice (CoCP)9.
3.4.4 In summary therefore:
• the Great Haywood viaduct will not intersect the Tixall Fault; and
• the intermittent nature and small scale of the piles will be insignificant when compared with the continuous and large scale structures, continuing over several hundred metres, associated with the underlying geology and any potential hydrogeological pathways.
3.4.5 Taking all of these factors into consideration, the piles for the Great Haywood viaduct will have no likely significant effect upon Pasturefields Salt Marsh SAC.
Trent North embankment (at Tixall)
3.4.6 At the time the HRA screening report was undertaken the foundation design for the Trent North embankment had still to be developed, and some options required piling. The Envireau report therefore identifies similar concerns regarding the use of piled foundations to stabilise the Trent North embankment as for the Great Haywood viaduct.
3.4.7 The design for the embankment has now been further developed and there is no longer any requirement for deep piled foundations. The foundations will be shallow, around 1m in depth, and so would not interfere with faulting in the bedrock.
3.4.8 If it is concluded at the detailed design stage (i.e. following further ground investigation), that the embankment will prevent brine discharge at the Lionlodge Covert LWS, precautionary drainage measures (such as a granular drainage blanket) or other appropriate mitigation measures, would be included within the embankment foundations to enable shallow groundwater to pass beneath the structure. Note that
shallow groundwater in the vicinity of Lionlodge Covert LWS will generally be in an easterly direction, towards the River Trent, as shown in Figure 2, and therefore will not have any bearing on the supply of saline water to Pasturefields Salt Marsh SAC.
3.4.9 In summary therefore:
• the Trent North embankment will not require deep piled foundations, so these will not interfere with any shallow groundwater pathways conveying brine, nor deeper pathways associated with faulting; and
• although considered unlikely to be needed, standard construction measures to more closely preserve the general pattern of shallow groundwater flow beneath the embankment are available.
3.4.10 Taking all of the above factors into account, there will be no likely significant effect from the North Trent embankment upon Pasturefields Salt Marsh SAC.
Brancote South cutting
3.4.11 The North Trent embankment described above will transition into the Brancote South cutting to the west of Lionlodge Covert LWS and approximately 1km south-west of Pasturefields Salt Marsh SAC, as shown in Figure 3. The cutting will be approximately 1.5km in length. Travelling from east to west, the cutting will be in low permeability Mercia Mudstone Group for 795m and only penetrate the Sherwood Sandstone Group in the latter half of its extent, as shown in Figure 4. Approximately 50m of the
Sherwood Sandstone Group will be further exposed as the cutting will remove a small portion of the overlying Mercia Mudstone Group as it passes west into the Sherwood Sandstone Group, as shown in Figure 4.
3.4.12 The cutting will extend to a maximum depth of 17m bgl in the Mercia Mudstone Group and a maximum depth of 13.3m bgl within the Sherwood Sandstone Group. Whilst these depths are approximate, they are based upon likely maxima and are therefore precautionary in their nature. More accurate depths will be confirmed in future during preliminary ground investigation, during detailed design and in consultation with the Environment Agency.
3.4.13 The Envireau report raises concern that the cutting will drain groundwater in this area, lower the water table and thereby reduce the groundwater elevation that potentially drives flow downwards through deeper deposits and then upwards through saliferous (saline) deposits towards the ground beneath Pasturefields Salt Marsh SAC. These potential groundwater and surface water flowpaths to the east and west of Pasturefields are shown in a schematic cross-section and inset at Figure 5 (note that the vertical scale is exaggerated for clarity).
3.4.14 The potential impact on groundwater immediately surrounding the Brancote South cutting, as illustrated in Figure 5 and associated inset, is considered in the Phase 2a, Community Area 2, Volume 5, Technical Appendix WR-002-00210. In this instance a reasonable worst case numerical analysis of the likely extent of groundwater impact due to the cutting within the Sherwood Sandstone Group has been undertaken. The assessment concludes that the maximum likely drawdown of groundwater level
within the Sherwood Sandstone Group at the Brancote South cutting would be 3.3m and that this would gradually diminish over a distance of approximately 25m, as shown in Inset 1 on Figure 5; whilst the exposed Sherwood Sandstone Group is located at an approximate minimum distance of 1.8km south of Pasturefields Salt Marsh SAC.
This analysis is based upon a precautionary, reasonable worst case scenario. The precise impacts to local groundwater levels are subject to detailed design, including a focussed ground investigation. Potential impacts to local groundwater may therefore be less than reported due to the precautionary nature of this assessment.
3.4.15 Based on the above analysis it is clear that the likely reduction in groundwater elevation at the cutting is very small and in the worst case only 3.3m in relation to the several hundred metres depth of sandstone over which the groundwater flowpath required to activate this pathway would be required. Based on topography alone, the cutting will be at an elevation of 102 to 120m above ordnance datum (AOD) within the sandstone, whereas Pasturefields Salt Marsh SAC is at an elevation of around 70m
AOD. Therefore, the difference in elevation alone that may contribute to driving flow along any such potential pathway is around 30 to 50m and therefore significantly larger than the maximum drawdown of 3.3m, as illustrated in Figure 5. In addition, the areal extent of the drawdown in groundwater levels around the cutting is small (approximately 25ha), in relation to the overall outcrop area of the Sherwood
Sandstone Group, therefore the recharge area over which groundwater in the sandstone is replenished will be mostly unaffected.
3.4.16 In general terms, and for all cuttings, HS2 Ltd has proposed a range of potential mitigation measures designed to protect the water environment. No specific measures are currently envisaged as being necessary to protect Pasturefields Salt Marsh SAC. However, if, following the preliminary ground investigation described in Paragraph 3.4.12, for the avoidance of any doubt and as a precautionary measure, it is concluded that additional mitigation should be incorporated at the Brancote South
cutting, then these measures can be incorporated during the detailed design stages of the Proposed Scheme. The measures could be put in place as advanced works, before any potential harm could arise. The design of these measures may require further ground investigation to support and build on the findings of the preliminary ground investigation.
3.4.17 The Phase 2a Environmental Statement, Volume 2, Community Area Report CA2: Colwich to Yarlet5, states in paragraphs 15.4.12 and 15.4.13 that: Measures will be introduced, as required, to mitigate the temporary and permanent effects on groundwater flows and water quality during excavation and construction of foundations and cuttings as far as is reasonably practicable. The types of measures likely
to be adopted could include (paragraph 15.4.12):
• installation of cut-off structures around excavations [this measure would maintain runoff from adjacent land flowing over natural ground];
• ensuring cut-off structures are driven to sufficient depths to meet an underlying strata or zone of lower permeability [this measure would prevent the excavation dewatering adjacent permeable strata, as if it were a drain. An example could be the sealing (tanking) of a cutting];
• promoting groundwater recharge, such as discharging pumped water to recharge trenches around excavations to maintain baseline groundwater and surface water conditions [this measure would help to preserve local groundwater table elevations and thereby local groundwater flowpaths and the volume of
groundwater available locally]; and • incorporation of passive bypasses within the design, which could comprise a ‘blanket’ of permeable material, such as gravel, placed around temporary structures, allowing groundwater to bypass the below-ground works, without a rise in groundwater levels on the upstream side [this measure would help to maintain the natural distribution of groundwater levels and flowpaths].
The exact requirements will be refined and method of mitigation will be designed following ground investigation at cutting locations. (paragraph 15.4.13)
3.4.18 In summary, therefore:
• potential impacts to groundwater levels around the Brancote South cutting have been assessed on a precautionary basis and assessed to be very small and localised in relation to the significant groundwater recharge areas and the thickness of sandstone; reasonable worst case numerical analysis indicates a maximum radius of impact perpendicular to the cutting of 25m, 1.8km away from Pasturefields Salt Marsh SAC;
• the maximum drawdown of groundwater level within this 25m distance is 3.3m, compared to a groundwater level difference between the cutting and Pasturefields Salt Marsh SAC (i.e. driving head) of significantly more and at least 30m. In addition, a sandstone pathway of several hundred metres in
thickness would also need to be active; and
• although not currently considered necessary to protect Pasturefields Salt Marsh SAC, a range of standard construction mitigation measures exist which could fully mitigate these localised impacts, if further investigation identifies their requirement to prevent impacts on Pasturefields Salt Marsh SAC.
3.4.19 Taking all of the above into account there will be no likely significant impact on account of the Brancote South cutting upon Pasturefields Salt Marsh SAC.

4 Conclusions
4.1.1 The HRA screening assessment undertaken as part of the HS2 Phase 2 Appraisal of Sustainability concluded that there are no likely significant effects on Pasturefields Salt Marsh SAC due to the Proposed Scheme. This conclusion has been questioned by the Envireau report.
4.1.2 The Envireau report’s suggested conceptualisation of the hydrogeology around Pasturefields Salt Marsh SAC, and the potential pathways discussed therein, has been considered in light of three key design elements within the area.
4.1.3 After detailed consideration of the points raised in the Envireau report and consideration of the available mitigation measures, it remains HS2 Ltd’s view that no potential impacts on Pasturefields Salt Marsh SAC have been identified, and therefore the original conclusion that there are no likely significant effects on the SAC due to the Proposed Scheme remains.
4.1.4 All parties (HS2 Ltd, Natural England, Environment Agency and Envireau Ltd) agree that the available evidence indicates that there is a supply of saline groundwater towards Pasturefields Salt Marsh SAC from the north-east.
4.1.5 Route alignment options to the north of Pasturefields do have the potential to cause a likely significant effect on the SAC, and would therefore require an appropriate assessment under the Habitat Regulations. HS2 Ltd considers that, based on current information, including the availability of the Proposed Scheme’s route alignment as an alternative, such an assessment is unlikely to satisfy these regulations.
4.1.6 By contrast, the Proposed Scheme’s southerly alignment avoids the flowpaths from the north east and any potential interference of the route with other hydrogeological mechanisms that could impact Pasturefields Salt Marsh SAC can be effectively avoided or mitigated. This means that there is no risk of the Proposed Scheme having a significant effect on the SAC and therefore no requirement for an appropriate
assessment under the Habitat Regulations.

5 References
Council Directive 92/43/EEC of 21 May 1992 on the conservation of natural habitats and of wild fauna and flora. Strasbourg, European Parliament and European Council. Available online at: http://jncc.defra.gov.uk/Publications/JNCC312/UK_habitat_list.asp
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.
Conservation objectives of Pasturefields Salt Marsh SAC. Available online at:
http://publications.naturalengland.org.uk/file/5376597540470784
Envireau Water, (2017), Hydrogeological Conceptualisation of Pasturefields Salt Marsh SAC & Ingestre/Tixall Salt Marsh SBI Great Haywood, Staffordshire
HS2 Ltd, (2012), HRA Screening Report for Pasturefields Salt Marsh SAC
HS2 Ltd, (2013), High Speed Rail: Consultation on the route from the West Midlands to Manchester, Leeds and beyond, Sustainability Statement, Volume 1: Appendix E4 Biodiversity
HS2 Ltd, (2017), Phase 2a Environmental Statement Habitats Regulations Assessment
screening report for Pasturefields Salt Marsh Special Area of Conservation, Volume 5:
Appendix EC-017-003. Available online at: https://www.gov.uk/government/publications/hs2-
phase-2a-environmental-statement.
HS2 Ltd, (2017), High Speed Rail (West Midlands – Crewe) Environmental Statement, Volume
2: Map Book, CA2: Colwich to Yarlet. Available online at:
https://www.gov.uk/government/publications/hs2-phase-2a-environmental-statement.
HS2 Ltd, (2017), High Speed Rail (West Midlands – Crewe) Environmental Statement, Volume
2: Community Area report, CA2: Colwich to Yarlet. Available online at:
https://www.gov.uk/government/publications/hs2-phase-2a-environmental-statement.
HS2 Ltd, (2017), High Speed Rail (West Midlands – Crewe) Environmental Statement, Volume
5: Technical appendices, CA2: Colwich to Yarlet, Water resources assessment (WR-002-002).
Available online at: https://www.gov.uk/government/publications/hs2-phase-2aenvironmental-
statement.
HS2 Ltd, (2017), High Speed Rail (West Midlands – Crewe) Environmental Statement, Volume
5: Technical appendices, Draft Code of Construction Practice (CT-003-000). Available online
at: https://www.gov.uk/government/publications/hs2-phase-2a-environmental-statement.

Figures available on request

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.

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:

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.

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.

"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.

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.

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

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:

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.

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

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.

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.

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

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

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.

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/

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.

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 ?

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.

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.

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.

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.

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.

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.

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.

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.

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.

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.

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.

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.

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).

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.

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.

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.

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.

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.

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.

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.

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.

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.

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

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.

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

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.

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.

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 18^th 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 17^th century description of gardens and grounds by Celia Fiennes.

In the early 18^th 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 19^th 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 20^th century Georgian Tixall Hall was demolished although the Tudor Gatehouse, Bottle Lodge and 19^th 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.

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.

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.

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.

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.

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 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."

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;

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

· 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.

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 ?

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.

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:

· 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

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

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.

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.

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 visible” It is the “including trains” part 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.

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:

"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."

"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."

"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."

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."

"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.

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.

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

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.

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.

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.

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.

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.

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.

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."

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:

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.

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 Haywood~~Tixall 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.

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 15.4.2 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.

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.

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.

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.

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."

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."

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.

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."

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.

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.

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.

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."

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.

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.

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

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

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.

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.

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:-

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.

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.

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.

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

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.

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.

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 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.

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.

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.

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.

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

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.

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

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.

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.

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.

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.

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.)

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.

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, 29^th 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.

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.

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 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.)

“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.

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.

If the technical basis is robust, the law will be on our side and failure will only result if inadequate funds are available to pursue the case – including the cost of any appeals or referrals to higher courts if required.

However, even with robust technical evidence in our favour and adequate funds to pursue legal enforcement in the courts, there is provision in the Habitats Regulations for the Government to invoke IROPI: “Imperative Reasons of Overriding Public Interest”, which is a clause that can be used to force through the Promoter's wishes, provided there are no alternative solutions and appropriate compensatory measures are taken. The compensatory measures have to be agreed at European level and may involve a heavy fine being imposed on the UK Government.

This means that either through lack of funds to enforce the law or through enactment of IROPI we could still end up with Phase 2a being built on the current alignment. All monies spent in attempts to achieve a route change will be forfeited.

The Parish Council exposure to this is limited by the S137 cap. This means no more than around £2,600 in any one financial year. As far as I'm aware, there is no mechanism for carry-over of S137 allowances so money not spent in one FY will simply add to reserves. It is not possible to accumulate funds to cover particularly large expenditure in any one year.

During FY 2017/18 there is currently £1,950 of the S137 allowance committed (balance due to Envireau Water), assuming zero contribution from any other source. This leaves £650 to spend on all other non-core activities.

An important observation is that it is not in the best interests of the Parish Council to allow any outside contribution to the costs to cross its accounts. Say, for example, Hopton PC offer £500 towards the costs, if they pay it to the PC, the PC still pay Envireau Water £1,950 and end up with £650 of 2017/18 S137 monies to spend on other things. If on the other hand Hopton paid their £500 direct to Envireau, the balance due to IwT PC would be £1,450 and the PC would have £1,150 of S137 monies to spend on other things. If Colwich also contribute, it is similarly most efficient if their contribution is paid directly to Envireau and not to IwT PC. If pledges of assistance from all sources equal or exceed £1,950 (and a sum equal to £1,950 is paid directly to Envireau) then IwT PC would owe nothing further and it would retain its full S137 allowance for 2017/18. This also means that, if the attempt to get the route moved subsequently fails, the full S137 allowance remains available for spending on other HS2-related matters: e.g. seeking better mitigation of the present route.

A second approach is to use any donor contributions to make good a shortfall in the cost of the initial challenge. As mentioned in my e-mail of 28 March, James Dodds has indicated that the sum of £4,450 covers only one presentation (presumed to be to HS2 Ltd in London) and with only him attending to present both technical and legal arguments. He has strongly recommended that Emma Tattersdill of Freeths should also be present to put/defend the legal arguments. Furthermore, we have been advised that we have a much greater chance of succeeding with the initial challenge if the presentation can be repeated to senior members of the DfT. We do not have a firm quote for two people to attend two presentations but James has indicated that an additional sum of the order of £1,500 should suffice. If the PC can agree that we should maximise our chances with the initial challenge (and hence minimise the chance of there being a follow-up legal phase), then the existing arrangement of IwT PC with Envireau Water should stand and the additional cost of having both James and Emma attend two separate meetings picked up by potential donors in agreed proportions – but, as above, with the donors making their contribution direct to Envireau Water. Because, as James pointed out, there are many variables associated with the costs of making the presentations, the precise figure might not be known until after the event. In this case we would need to agree a percentage split of the extra sum so that the appropriate invoice values could be raised.

A further alternative approach is a variation on the second but, in this case, all contributing parties, including IwT PC, agree in advance to fund the additional costs and to split the resulting balance due in an agreed percentage way. This has the advantage of more evenly distributing the pain and has the potential of reducing IwT PC’s contribution and thus retaining a bigger part of the 2017/18 S137 allowance for spending on other HS2-related issues. This is my preferred approach.

Here is an example, assuming that agreement is reached to fund both James and Emma to be present at two separately arranged meetings, one with HS2 Ltd and one with DfT:

The assumption is that the total cost for the initial challenge (with the extras added) is £6,000 and that donors are Hopton and Colwich PCs plus the Ingestre & Tixall HS2 Action Group (AG). IwT PC has already paid £2,500 leaving a balance to find of £3,500. My further assumption is that we agree a split of this balance of costs in the proportions 1 to the AG and 2 each to IwT, Hopton and Colwich – i.e. 7 portions. One portion is worth £3,500/7 = £500 meaning that the AG would contribute £500 and the three Parish Councils £1,000 each.

This is just an example but it serves to illustrate the principle. IwT PC’s total contribution is then £3,500 or roughly £1,000 below its agreed ceiling and is left with £1,600 of its 2017/18 S137 allowance still intact.

If, as a result of the challenge, the route is moved away from the area, future Parish Council spend on HS2-related matters will become minor.

If the route stays as currently proposed, there will be an intense period of negotiation and engagement with HS2 Ltd, SCC, SBC and other local communities up to the granting of Royal Assent at the end of 2019. This will involve full appraisal of the Bill proposals and accompanying EIA and the preparation and presentation of petitions to the House of Commons and House of Lords Select Committees (with technical/legal support if needed).

Assuming Royal Assent by the end of 2019, from 2020 to completion by the end of 2027 there will be continuous responding to all matters related to detailed design and construction, together with help and assistance to all local residents seeking compensation for land and property. There is also likely to be involvement in and supervision of local community projects funded by HS2 Ltd. Two funds will be open for application to support suitable community projects:

a. Community and Environment Fund (CEF). Objective: To add benefit over and above committed mitigation and statutory compensation to communities along the route that are demonstrably disrupted by the construction of HS2. £75k max local, £1m max strategic.

b. Business and Local Economy Fund (BLEF). Objective: To add benefit over and above committed mitigation and statutory compensation to support local economies that are demonstrably disrupted by the construction of HS2. Capital/Revenue grants: £10k to £1m.

1. As currently proposed, all the residential properties and hence the whole population of Ingestre and Tixall are located within HS2 Ltd's 3km zone of potential impact.

2. Approximately half the residential properties and half the population are within the most severely affected 1km from the centreline of the currently proposed route.

3. Since the announcement of the route in 2013, there has been approximately £8 million loss in property values in the two parishes.

4. The loss in property value will increase during the seven years of construction.

5. By 2042 (15 years after commercial operation is scheduled to start), property values, excluding inflation, will still be reduced by a predicted £2 million.

6. Between 2020 and 2027, the residents of both parishes will be exposed to severe disruption due to construction. Those closest will be the greatest affected but all will experience frustration and delays from the movement of heavy construction plant. Upper Hanyards Farm and Ingestre Park Golf Club will be destroyed (relocated?).

7. After 2027, operational effects kick in: noise, dust and visual intrusion arising from the passage of up to 24 trains per hour at 360kph (225mph).

8. The financial and other disruptive effects described above will have a significant and widespread adverse effect on the social, emotional and health/wellbeing of everyone affected.

9. All the above negative impacts are a consequence of the decision by HS2 Ltd to divert the alignment of Phase 2a over a 20km-long section to avoid having to carry out an Appropriate Assessment of Pasturefields Salt Marsh SAC.

10. Evidence exists that suggests that the basis for the decision to divert the route is flawed and that a formal challenge to HS2 Ltd is in order.

11. The Parish Council has agreed a spend of £4,450 for a focused expert appraisal of the technical evidence and an assessment of the legal implications arising from it.

12. If the challenge is successful, HS2 Ltd would be forced into conducting an Appropriate Assessment for Pasturefields SAC whichever route is taken. The northern route is then favoured because Hixon, Weston and Salt would suffer cumulatively less than Ingestre,Tixall, Great Haywood, Hopton, Marston and Yarlet. Plus, there is a £154m saving in project costs.

13. The sum spent to secure a challenge is trivial compared with the potential benefits. Financial help is potentially available and this could be used either to defray existing costs or to improve the chances of success. The latter is recommended.

14. Even if a technical case is proven, HS2 Ltd might resist a change to the route. This would invite a legal challenge.

15. It is recognised and accepted that IwT PC does not have the resources or powers to pursue a legal case against HS2 Ltd/DfT. This would be dependent on separate arrangements to which the PC may wish to subscribe or not as it sees fit.

16. If the route is not moved, Ingestre and Tixall will suffer as outlined above and the PC will be faced with a decade of other HS2-related pressures.

17. It is self-evident that the PC should do everything in its powers to seek a change of route for as long as the opportunity for doing so exists.

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 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 13 September 2016.

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 draft 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.

Section numbers and principal headings mirror those of the referenced Draft EIA documents.

d) Shortage of time precludes a detailed response to all points across all documents associated with this consultation (and those of the two other consultations that are 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 Q2 and Q3 below as the definitive set and, where appropriate, ensure that these are rolled out for inclusion in the other associated documents.

e) At the launch of the current consultation, HS2 Ltd announced that it would be writing to all owners/occupiers of properties located within 1km of the proposed route. It soon became obvious that many residents of Ingestre and Tixall, who live within 1 km of the route, had not received notification letters. A comprehensive list of addresses has been prepared and provided to HS2 Ltd. We hope and expect that HS2 Ltd use this information to amend their mailing list to ensure that all owners/occupiers most directly affected by HS2 are, in future, kept properly informed.

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

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

We have not reviewed the non-technical summary but are aware that it has been useful for those parishioners seeking a simplified overview of the Proposed Scheme.

Question 2: Please let us know your comments on the documents that form Volume 1 of the working draft EIA.

Our response to Q2 is in three parts: A, B & C, corresponding to the three tick-boxes of the printed consultation response form.

We welcome the background information that this part of Volume 1 provides. Our views on the EIA methodology have already been given in our response to the draft EIA SMR earlier this year, while our detailed responses to the individual assessment topics are given in our responses to Q3 and Q4 below.

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.

We look forward to discussing with HS2 Ltd the details as they apply to our part of CA2.

We disagree, at multiple levels, with the rationale for the HS2 project as set out in Part I of the Alternatives Report but accept that the Secretary of State for Transport remains committed to the project and is seeking feedback on the assessment of impacts of the Proposed Scheme.

Part II of the Alternatives Report describes the various route alternatives that have been examined. The comments that follow relate to those alternatives that directly affect Ingestre and Tixall (CA2). The relevant sections are:

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.

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

It is not appropriate, here, to elaborate in detail all the issues involved but the essence of our case is that the arguments at 4.3 of the Alternatives Report are essentially spurious and that, even though HS2 Ltd has been provided, in a timely and formal way, with information that challenged the original presumptions, it has failed to act professionally on this information, contrary to the proper interests of the British tax-payer.

The IPR for Phase 2 in our area used the “Hybrid South of Pasturefields” corridor (Route C on Fig 10 of the Alternatives Report). The competing alignment is Route B: Alternatives Report, Fig 10, “North of Pasturefields” – formerly HSM03 (south of Weston). While accepting that Alternatives Report Route A (“South of Pasturefields”) was an early consideration, this was rejected at a very early sift stage. Further discussion, below, relates only to the comparison of Route B with Route C.

At the time that the HS2 Project Board met to consider between the two route options (in Q2 2012), the overriding consideration was avoiding the need to carry out an Appropriate Assessment of Pasturefields Salt Marsh SAC.

Central to the decision was acceptance by Natural England that the HRA Screening Report for Pasturefields SAC had concluded that routes to the south of Pasturefields would not need an Appropriate Assessment whereas those to the north would. This dictated the selection of Route C.

The decision to proceed with Route C was therefore 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:

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;

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). At 10.3.17 of the response to Q3 Part A below, it is noted that dewatering of the aquifer could occur as a result of the creation of the Hanyards Cutting (currently named Brancote Cutting).

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.

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;

With the above background summary in mind, we respond to the content of section 4.3 of of the Alternatives Report as follows:

4.3.5 Corridor B (the discarded route) is stated as being within 300m of Yarlet School. Not mentioned here or in any subsequent paragraph is that Route C (the chosen route) passes much closer to the school (<100m) and is therefore more harmful.

4.3.7 Reference to direct habitat loss from Pasturefields SAC is misleading as none of the proposed routes has any direct impact on the site. Corridor B is closest. It passes 300m to the north of Pasturefields SAC, on an embankment, and is separated from the SAC by both the A51 trunk road and the Trent & Mersey canal. As mentioned above, the possibility of interference with surface water catchment dynamics is just that: “a possibility” – something easily determined by appropriate ground measurements. Even if ground measurements identified a potential impact, Natural England had already indicated that Corridor B was acceptable subject to mitigation by design. Potential design mitigation measures are set out in Appendix 4 to the HRA Screening Report.

4.3.8 As recorded above, HS2 Ltd was subsequently alerted to the many deficiencies in the described process and to the false reasoning that arose from it. Nothing has been done to correct this. We dispute and challenge HS2 Ltd's stated claim that carrying out the necessary investigation work could potentially take “a number of Years”. Guidance from the Planning Inspectorate (who are normally responsible for overseeing the approval of Nationally Significant Infrastructure Projects) is that developers should allow 13 months for HRA assessment. Separately, a proposed development has come forward (already notified to HS2 Ltd) that is much more threatening to Pasturefields SAC (a 196 berth narrow-boat marina at Shirleywich). The proposed marina is immediately adjacent to Pasturefields SAC and requires deep excavation with considerably greater prospect of disturbing the surface-water catchment dynamics than does HS2 Route B. The marina application has been referred to Natural England who have indicated that a 12 month period of monitoring of boreholes is sufficient to identify any potential threats to the SAC (Stafford Borough Council Planning Application ref: 15/22518/FUL refers). There is no reason to suspect that a railway line on an embankment, over 300m away, would require any more. It is to be noted that more than three years has elapsed since since HS2 Ltd's attention was drawn to the deficiencies in their reasoning – comfortably more than that needed for the necessary investigations to have been carried out. No action has been taken.

4.3.9 A misleading and distorted depiction is presented that, at best, can be described as “Red Herrings”. MOD Stafford and Norton Bridge Junction are only relevant for Route A. Route A was rejected at a very early sift yet MOD Stafford and Norton Bridge Junction have remained cited by HS2 Ltd in multiple examples of subsequent correspondence which related only to Route B and C. Sandon Park (a grade II listed Registered Park) is a privately owned estate with no public access. Route B has no direct impact on Sandon Park and comes no closer than 1km. The chosen route (Route C) moves out to about 2.5km from Sandon Park but, conversely, brings the route much closer to the more sensitive, publicly accessible, sites of Grade I listed Shugborough Park and Cannock Chase AONB. For Shugborough, Route B is 2.5km distant but reduces to 900m with Route C. For Cannock Chase AONB, Route B is also 2.5km distant but falls to 600m with Route C. On this criterion, Route B is the clear favourite. Hopton Registered Battlefield site, while important, is of low significance historically and the site context is already substantially degraded by the presence of multiple buildings owned by the MOD (see Fig 1). Route B, which passes at 300m to the north in a 15m deep cutting, is to be compared with Route C which passes at approx 650m to the south but in a cutting of less than half average depth.

As far as we can tell, Route B is superior in virtually all measurable respects to Route C.

There should never have been any question that Route B should have been taken forward as the preferred route, even though an Appropriate Assessment for Pasturefields SAC was required.

HS2 Ltd must act immediately to formally bring Route B back into existence as an up-to-date, fully refined and optimised derivative of the original HSM03 (south of Weston) option so that, on confirmation of its superior status, there is time for it to be consulted on in advance of finalisation of the Phase 2a Hybrid Bill.

An Appropriate Assessment of Pasturefields SAC is an inevitable consequence and this must be commenced without delay. NB: We believe there is no real prospect that an Appropriate Assessment will identify any requirement for mitigation that would cost more than the saving in route cost nor, if started promptly, result in any delay to the planned completion date for Phase 2a.

5.3 Local alternatives considered before November 2015 – Great Haywood to Yarlet:

The work described is almost certainly wasted effort. This is because all the information provided by us at the Phase 2 Route Consultation was ignored and only minor adjustments to the IPR (Route C per section 4.3 above) were considered. Every route option examined therefore was more expensive, more environmentally damaging than Route B as well as being compromised through the failure to pick up on the prior notification that all routes would pass directly through the inland salt marsh at Ingestre/Tixall (with its probable linkage with Pasturefields SAC) and through the area around Marston that BGS identifies as prone to subsidence – both of which are avoided by Route B.

6.3 Local alternatives considered since November 2015 – CA2: Colwich to Yarlet:

As with 5.3 this is also mostly wasted effort. There is, however, an inkling of flexibility in thinking in that, amongst the route options studied, three of them (B5-7-3a, B5-7-3b and B5-7-4b) indicate some willingness to consider more radical realignments from the IPR than hitherto has been the case. All three are variations on a theme based on a 21 km section between Colton and Pirehill (the same section of track over which Route C deviates from Route B).

Regrettably, the one exercise that could and should have been carried out at this time was to evaluate a fully up-dated, optimised and refined version of Route B over the same 21km length. This was not done.

The failure to act on Route B is brought into sharp focus by comparison with B5-7-3a, which is one of the options that was studied. We have chosen B5-7-3a because, of the three variants mentioned above – which are all very similar – this is the one most closely related to Route B as it involves a surface crossing of Hopton Heath Battlefield site (the other two variants are tunnelled options)

B5-7-3a is an alignment intermediate to Route B and Route C. It lies to the east of the safeguarded corridor of Route C but to the west of Route B. It follows a not dissimilar alignment to Route B but with a more southerly crossing of the river Trent. This brings the route to the west side of the river Trent, near to Little Ingestre, allowing it to pass to the south of Pasturefields SAC (but significantly closer to it than Route C).

From information obtained under FOI 16-1586, compared with the baseline Route C, B5-7-3a is £36m cheaper to construct, results in a major reduction in demolitions required (from 49 to 19), removes impact on Ingestre Conservation Area and Ingestre Golf Course; has beneficial effects for Hopton (especially for noise and vibration); improved visual effects to Moreton House, Lion Lodge Covert and Great Haywood Marina; improved water course diversions and less impact on surface water bodies. The downside is that it would have major physical and setting impacts on Hopton Heath Battlefield site and has a greater probability of adversely affecting Pasturefields SAC.

Given the overwhelming benefits accruing to B5-7-3a, we question the value judgement of HS2 Ltd in rejecting this option simply on account of its negative effect on Hopton Heath battlefield site and the greater potential for it to affect the groundwater regime of Pasturefields SAC (something that we believe all routes have the capacity to do anyway).

Of more significance, Route B (had it been studied) would, we believe, have conferred very similar benefits while, at the same time avoided impact on Hopton Heath battlefield site as well as providing far easier construction access.

As has already been noted, it appears that it is only the reluctance of HS2 Ltd to undertake an Appropriate Assessment of Pasturefields SAC that is preventing option B from being taken forward.

We therefore restate our position that the Appropriate Assessment process must be started and that:

Our response is guided by the footnote on Page 6 of the printed consultation response form which states that: “For consistency of approach across the HS2 scheme, the measures set out in the Draft CoCP for Phase 2a are likely to be amended from those on Phase 1 only where there are particular geographical reasons why they should do so.”

We take, at face value, that the Nominated Undertaker will adhere to the CoCP in all respects and that we will be kept informed and consulted on, as appropriate, throughout the construction phase.

Detailed comments on each of the environmental topics are given in our response to Q3 below.

One geographically-related issue raised locally with us is concern regarding the vulnerability to damage by vibration, during construction, of the numerous listed buildings that 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 Hanyards Cutting (currently known as Brancote Cutting – see Q3 Part B “Nomenclature”, below). This is a substantial cutting, nearly 20m deep, in hard sandstone.

At paragraph 6.8.1 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.

In the CoCP, at paragraph 13.2.24, detailed guidance is given with respect to the protection of buildings from damage due to vibration. The key observation is that referenced standards are specific to “Vibration sources other than blasting”

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

Such situations are not addressed and, while the CoCP makes it clear that the Nominated Undertaker is responsible for assessing any situation arising and complying with the advice on maximum vibration levels, we still believe there is scope for some statement that covers blast-type events.

Question 3: Please let us know your comments on Volume 2: Community Area (CA) reports : We welcome any information you may have on how the scheme may impact the local environment and community in your area and any opportunities you feel there may be to reduce these impacts.

Our response is in two parts: Part A on the report itself and Part B on the associated map book.

2.1.12 (Notable community facilities): In relation to Ingestre, please add: Little Ingestre House residential care home for the disabled, Ingestre Stables equestrian training and examination centre (which is Riding for the Disabled registered), Ingestre Park Golf club and Ingestre Orangery (currently undergoing HLF-funded restoration as a community facility).

2.1.19 (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. Two housing developments known to us in the neighbouring community but not appearing on any of the maps of the Proposed Scheme are: The Shires, Main Road, Great Haywood (adjacent to land required for construction) and Devereux Grange, Little Tixall Lane, Great Haywood (approximately 500m distant – 100m if taken from an altered road). Between them, they account for 80 to 90 homes.

2.2 (Description of the Proposed Scheme): Please see our response Q3 Part B, below, for detailed comments on the proposed scheme.

2.3 (Construction of the Proposed Scheme): Our detailed responses to construction and construction compounds are dealt with elsewhere but some key issues are mentioned here because of their potential impact on the current proposals:

· 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 2, 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 many cubic metres per year. See 10.3.8 below for more details.

· No access is possible to Mill Lane Satellite construction compound from the A51 end of Hoo Mill Lane as inferred from 2.3.32. All construction traffic must use Tixall Road. See 14.3.6 below for more details

· Only one main utility diversion is mentioned. No mention is made of other main utilities in the area that have been advised previously. See Q3 Part B for more details.

· Incorrect/inappropriate naming has been used for roads and other features in the area. See see Q3 “Nomenclature”, below for more details.

2.5 (Route section alternatives): See Q2 Part B for our detailed response. However, as noted at point b) of “General” above, 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 – referenced as “Route B” in 4.3 of the Alternatives Report.

3.4 (Engagement – Local Authorities and Parish Councils): Contrary to the claim at 3.4.2 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 overlooked or misrepresented in the Draft EIA.

3.5 (Engagement – Communities): It is with considerable concern to read that, in preparing the draft scheme proposals, HS2 Ltd has apparently failed to engage with the following:

These are key community facilities that will encounter intrusion/disturbance as a result of the construction and operation of the proposed scheme.

3.8 (Engagement – Informing the Proposed Scheme): As already noted at 3.4 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. This consultation response is therefore the first opportunity to contribute to the main themes for the Colwich to Yarlet area, set out in 3.8.2, which apparently emerged from the claimed stakeholder engagement process.

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. Further information is given in section 10, Land Quality, where the local geography is addressed more fully.

4.3.5 (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 2.3 and Fig 2 above.

4.4.15 (Permanent effects of construction – Impacts on agricultural and forestry land): 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 the water table to the detriment of the adjoining farmland and woodland. See also Water resources and flood risk (15) below.

5.3.6 (Receptors): To the list of “other receptors” should be added: Little Ingestre House Care Home.

5.4.9 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 (we presume) construction traffic will, access Tixall Road from the A518, Weston Road. See also 14.3.6 below

Missing from this section is assessment of emissions from fixed plant and vehicles on construction sites, see section 3 of our response to Q4 below.

Formal Objection: 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:

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.

· 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 revised EIA SMR to reflect this theme.

The widespread impoverishment of communities (except, perhaps, those within roughly 5 miles – 8km – of a 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.

6.1.2 (Introduction): As per 3.5 above, it is with considerable concern to read that, in preparing the draft proposals, there is no mention of HS2 Ltd having engaged with any of the following:

These are key community facilities that will encounter intrusion/disturbance as a result of the construction and operation of the proposed scheme.

6.3 (Environmental baseline): As already noted, we are extremely concerned at the failure to recognise (and presumably take into account in the preparation of the Proposed Scheme) important features of our community. At 6.3.2 of the CA2 report, a summary of residences at Hopton, Marston and Yarlet are given but nothing is said about Ingestre/Tixall. At 6.3.3 a comprehensive summary is given of Ingestre Park Golf Club but this is the only community facility mentioned. As mentioned at point g) of General, above, we have found it necessary to prepare a comprehensive list of properties within the parishes of Ingestre and Tixall. This has already been provided to HS2 Ltd in order that they may update their mailing list for the area. The essential part of that list, relevant to the environmental baseline for Community, is as follows:

The affected business properties are listed below, together with associated website addresses from which details can be obtained.

NB: Tixall Gatehouse is just outside the 1 km limit but shares ownership with Ingestre Pavilion.

In addition, a community-led, HLF- supported, project is underway to restore Ingestre Orangery. The aim, apart from restoring this Grade II listed building, is to establishing it as a viable centre for community activities. Visit Friends of Ingestre Orangery: http://www.foio.btck.co.uk/

6.4.5 (Assessment of Impacts and effects – Temporary effects – Residential properties): No breakdown is given of the 11 residential properties stated as being adjacent to the cited works. We cannot comment on the number of adjacent properties at the Great Haywood end of the viaduct but there are 7 residential properties in Ingestre that are within 250m of the works. What is of greater significance is that the conclusion that: “This would result in a major adverse isolation effect for the residents, which would be significant.” 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 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.

6.4.10 and 6.4.12 (Temporary effects on Community and recreational facilities): For the same reason as stated in 6.4.5 all the facilities tabulated as business properties in 6.3 above, except Ingestre Pavilion and Tixall Gatehouse, will also suffer major adverse isolation effects. Separately, proper consideration is required in respect of isolation (and other) effects affecting Hanyards Lane, Tixall (see point 11 of CT-05-214 in Q3 Part B below for more details).

6.4.14 (Permanent effects): These are noted but we draw attention to Q3 “Nomenclature”, below so that correct references are used in the final EIA.

General: We acknowledge footnotes #38 on p73 and #40 on p75 to the effect that the draft assessment of cultural heritage has taken into account the revised Ingestre Conservation Area boundary even though the accompanying CT-10 series map shows the old Conservation Area boundary.

7.3.7 & 7.3.8 (Non-designated Assets): An impressive list is given. We would welcome feedback on the results of all studies and investigations relating to features found within the parish boundaries of Ingestre and Tixall.

1. 7.3.7, 6^th bullet: As noted at 2.3 above, it is an established fact (not just a possibility) that a 1.5ha area of salt marsh 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, see Q3 Part A Fig 2 above. See also point 5 below. 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, see 8.3.9 below.

2. 7.3.8, 7^th & 8^th bullets: The referenced 19^th century saw-mill and accompanying office block has recently been developed. These buildings now comprise 10 residential units: Nos 1 – 10, Little Ingestre Barns.

3. Not mentioned but should be added: 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 19^th c, which, themselves, incorporated an ancient triumphal arch that was relocated from the pleasure grounds of Ingestre Hall.

4. Not mentioned but should be added: remains of 19^th c (or earlier) tramway linking Hoo Mill with the Trent and Mersey Canal (within 500m of the land required). The tramway follows what is shown on present day maps as Hoo Mill lane on that part between Hoo Mill and the canal which is no longer open.

5. 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).

6. 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 17^th 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.

7. Known to exist from historical records dating to the 14^th c but for which there are no known surviving above-ground remains is the deserted medieval township of Hanyate. This 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 (due to be demolished under the present proposals) is a candidate site

7.3.9 (Cultural Heritage overview): The possible existence of ancient stone tools in the Trent valley river deposits is more than hypothetical. Two polished stone axe-heads have already been found locally – in the field between Hoo Mill Lane and Little Ingestre.

7.3.17 (Cultural Heritage overview): We propose two minor additions to the summary for Ingestre: In the opening sentence: “.... Ingestre Hall was built in around 1613, on the site of an earlier medieval manor house, ….” In the concluding sentence: “... while the 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.”

7.4.9 (Cultural heritage – Assessment of Impacts and effects – temporary effects): 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 avoided if a tunnel is used.

7.4.12 et seq (Cultural heritage – Permanent effects): 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), and our recommendations on the alternative naming of features of the scheme as set out in Q3 “Nomenclature”, below.

In respect of the observation at 7.4.25 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.

In respect of 7.4.28 (summary of likely residual significant effects), the summary must pick up on the negative socio-economic effects on heritage assets as discussed in 12 below.

7.5 (Effects arising from operation): This needs to be reassessed to take account of the observations above and our detailed comments on the Proposed Scheme as set out in our response to Q3 part B, below.

8.3.5 Environmental baseline – Existing baseline – Pasturefields SAC): This is an incorrect statement and is not valid as an existing baseline. The words used in the CA2 report mirror those of the site condition when it was first registered as a SSSI in June 1986, prior to becoming a SAC. Since then the condition of the site has deteriorated. Several species of saltmarsh vegetation have been lost and there has been no record, that we can establish, of any of the mentioned waders (snipe, redshank and lapwing) having bred there in the past 10 years. 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.

8.3.9 Environmental Baseline – Existing baseline – Lionlodge Covert LWS): The CA2 report gives an incorrect and misleading representation of the facts. The referenced LWS corresponds with Staffordshire Ecological Record for site 92/84/70. The site was 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:

8.3.15 (Environmental Baseline – Existing baseline – Ponds): Mention is made of 17 ponds within CA2, that are wholly or partly within the land required for construction. We flag (again!) 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 2 as part of 2.3 above) and trust that this is included as one of the 17.

8.3.18/Table 4 (Environmental Baseline – Existing baseline – Relevant species): It is with considerable concern (and frustration) to find such a trivial assessment presented in the CA2 report. The report may be a draft document but there is no excuse for it to have failed to take into account detailed information already provided to HS2 Ltd as part of our January 2014 Phase 2 Route Consultation response. This response contained (at Appendix 5) a 23 page wildlife report for Ingestre & Tixall. There is no evidence that any of the content of this report has been used.

8.4.1 (Effects during construction – Avoidance and mitigation measures): Please see our response at Q3 Part B below for detailed comments. Here, we flag the apparent absence in the proposals for any “green bridge” provision at either Ingestre Underbridge or at the overbridge at the top of Hanyards Lane (currently referred to as Tixall Bridleway 0.1628 Accommodation Overbridge but which should be renamed as set out in Q3 “Nomenclature”, below). Provision of appropriate measures to mitigate the effects of severance of wildlife access is something we believe is essential.

8.4.3 et seq (Effects during construction – Assessment of impacts and effects): This needs to be reassessed to take account of the observations in the preceding paragraphs of this section and our detailed comments on the Proposed Scheme as set out in our response to Q3 part B, below.

We single out 8.4.4 (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 grounds that the HRA for Pasturefields SAC was deficient on numerous counts and that HS2 Ltd has failed in its duty to the taxpayer in refusing to properly examine an alternative route alignment that is lower cost and has reduced environmental and community impact than the current proposal. Please refer to Q2 Part B above for more detail.

In respect of 8.4.24 & 8.2.25 (Other mitigation measures) we request that HS2 Ltd fully engage with us, before the EIA is finalised, to ensure that we can give proper consideration to any proposals that might be brought forward.

8.4.26 (Likely significant residual effects): 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. This includes:

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.

9.3 (Environmental baseline): 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.

9.4.24 (Assessment of impacts and effects – Ingestre Park Golf Club): The assessment that, in the face of the loss of function of the Golf Club: “no adverse effects on community health and wellbeing are predicted”, is almost certainly wrong. 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.

NB: We note that, with regard to Ingestre Park Golf Club, the assessment is for the scheme “as currently designed” and that, from 6.4.27, HS2 is continuing to work with the Golf Club. We are aware that one option under consideration is relocation of the Golf Club to an alternative site. Should this happen there are many implications. We request that HS2 engage with us before any final decision on the relocation of the Golf Club is made.

9.4.35 (assessment of Impacts and effects – access to emergency services): We note the very general statement about seeking to reduce effects on emergency response times as far as reasonably practical. This is too weak. Ingestre requires special attention because:

Yet again we find it necessary to register our concern that important information about the area, already provided to HS2 Ltd in previous consultation responses and other correspondence, has been ignored. As a consequence, the current scheme proposals have (apparently) been developed without taking this information into account. This has led to mistakes having been made.

10.3.11 through 10.3.14 (Environmental baseline – Bedrock Geology): As as already been noted at Q2 Part A section 4, 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.

10.3.17 through 10.3.22 (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 Hanyards Cutting (currently named Brancote Cutting – see Q3 “Nomenclature”, below) 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.

10.3.28 (Environmental baseline – Current and historical land use – Landfill sites): Five historical landfill sites are mentioned, however later, at Table 8, the list does not include the landfill site near Hoo Mill crossroads, at approximately OS grid ref: SJ991236. This lies within 250m of the proposed works. It is possible that this site has already been screened and eliminated as a potential source of contamination but we mention it in case it has been omitted in error.

10.3.34 together with 10.4.20 (Environmental baseline – Mining/mineral resources): We are concerned to see the possibility of mineral extraction (sand & gravel) taking place in the region between the western edge of Lion Lodge Covert and Hoo Mill. We request that we are kept fully informed of any developing plans to exploit these resources.

10.3.38, 10.3.39 together with 10.4.21 (Environmental baseline – Mining/mineral resources – Halite deposits): 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. The route of the Proposed Scheme (Route C) passes through the area identified by the BGS where further subsidence may occur (see Fig 3). On the other hand, this area is avoided by the March 2012 route HSM03 (Route B).

Historical exploitation of the “broader solution zone … parallel to the line of the Hopton fault” – which we presume means to the east of the fault, corresponding to the western edge of the Needwood basin halite deposit that is responsible for the brine springs in the Trent valley – was never on a scale comparable with that in Stafford. The two largest extraction sites (Shirleywich and Weston) both ceased operation at the start of the 20^th century. NB: 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 2 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.

Note ref Fig 3: This is based on Fig 1 of the BGS report that formed Appendix 6 of our response to the Phase 2 Route Consultation. At the time, the BGS Karst database did not include the Ingestre/Tixall saltmarsh mentioned at 2.3/Fig 2 of Q3 Part A above, so it does not appear.

11.1.3 (Principal landscape and visual issues in the area): Permanent landscape and visual effects are summarised at the 2^nd bullet. We contend that the deep Hanyards cutting (currently named Brancote cutting, see Q3 “Nomenclature”, below) warrants mention as a significant issue.

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 construction, the ZTV will also include the additional temporary effects of construction plant, temporary buildings and temporary stockpiles of construction materials (including temporary storage of spoil from earthworks) etc. 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 visible” It is the “including trains” part that requires further elaboration.

11.3.7 & 11.3.8 (Environmental baseline – Ingestre Riparian Alluvial Lowlands and Ingestre Park Sandstone Estatelands): We note that these Landscape Character Areas also include Tixall. The area covered is extensive and, as noted, is principally historic parkland. Although modified, we contend that the wider parklands remain essentially intact, together with the multiple historic buildings they contain (there are 13 listed buildings within 1km of the Proposed Scheme). We claim there is more than “remnant” historic features and do not support the assessment that the presence of polytunnels at the Canalside farm shop, grandstands at the county showground, an overhead power line and an 18-hole golf course as a sufficient detraction to warrant only a “medium to high” landscape value rating. It should be reassigned “High”

11.3.16 (Visual baseline – general): Detailed comments concerning viewpoints and proposed mitigation measures are given in our response to Q3, Part B below.

11.4.12 (Visual assessment construction) and 11.5.9 (Visual assessment operation): Both only include appraisal of “views south from Ingestre Park” (Paragraphs 11.4.16 and 11.5.16 respectively). Both conclude that there will be major adverse (significant) effects. In the case of operation, it is assessed (at paragraph 11.5.6) that, by year 15, landscape effects will only be slightly reduced through the establishment of landscape planting and would still be significant.

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 at all (but alluded to at paragraph 12.4.12) 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 businesses/community facilities set out at 6.3 above will, to some degree or other, be adversely affected. 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.

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 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.

Our detailed comments on the proposed mitigation measures are given in our answer to Q3 Part B below. However, we have reason to believe that not all factors relevant to the selection of proposed mitigation measures have been taken into account.

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.

14.2.2 (Scope, assumptions and limitations): Ingestre needs to be added to the list of affected settlements.

14.3.4 (Environmental Baseline – Existing baseline – Roads crossed by route): Mill Lane and Tixall Road (currently marked on some maps as Haywood Road – see Q3 “Nomenclature”, below) 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).

14.3.6 (Environmental Baseline – Existing baseline – Local roads used for construction): 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 occur at peak times.

14.3.8 (Environmental Baseline – Existing baseline – Bus routes crossed): Important to the analysis but apparently missing from the list are 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.

14.4.13 (Effects arising during construction – Assessment of impacts and effects – Access routes): No mention is made of the Hanyards Lane (Tixall Bridleway) satellite construction compound nor, as noted at 14.3.6 above, of the impacts on Blackheath Lane of having to route construction traffic for both Hanyards Lane (Tixall Bridleway) and Mill Lane satellite construction compounds along it.

14.4.14 (Effects arising during construction – Assessment of impacts and effects – Increased traffic flows): Tixall Road and Blackheath Lane need to be added to the list.

14.4.13 (Effects arising during construction – Assessment of impacts and effects – Temporary diversion of PRoW): Attention is drawn to our detailed comments in our answer to Q3 Part B regarding Tixall Bridleway 0.1628.

15.2.6 (Scope, assumptions and limitations – Study information): Once again we find ourselves having to express our deep concern 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.

15.3.5 (Environmental baseline – WFD baseline – Water-course crossings): Missing from table 12 is the Hanyards drop inlet culvert.

15.3.8 to 15.3.14 (Environmental baseline – Geology): Please refer to section 10 above and our comments against 10.3.11 and 10.3.13 in particular.

With regard to table 13, if our understanding is correct, the Staffordshire Trent Valley sandstone comes to outcrop to the west of the area, not east as stated – indeed it is this outcrop that is cut into by the Hanyards (Brancote) cutting. See point 10.3.17 above.

15.3.18 and 15.3.19 (Environmental baseline – springs, GWTEs and Pasturefields): As has been reported to HS2 Ltd on many occasions, over nearly four years, the Proposed Scheme has been aligned right through the middle of an extant inland salt marsh that has a high probability of being linked with that of Pasturefields SAC. See section 8.3.9 (Ecology and biodiversity) above, as well as 2.3, Fig 2. There is indeed at least one groundwater-dependent terrestrial ecosystem (GWDTE) in the study area, adjacent to Lion Lodge Covert. In addition, at least some of the features identified as “springs” are probably saline in nature and furthermore, are not natural springs but simply discharge points for culverts that are part of the extensive drainage system for the salt marsh.

15.4 (Effects arising during construction – Avoidance and mitigation measures): As already noted, the Proposed Scheme does not avoid sensitive areas. Instead, the proposed alignment passes right through the middle of a 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 has been restated many times since. Regrettably, this information has been ignored.

15.4.5 (Effects arising during construction – Avoidance and mitigation measures – Culverting): We note that there is no mention of Hanyards drop inlet culvert. More important, though, is the failure to understand the hydrology of the area of the ancient inland salt marsh in the Lion Lodge area of Ingestre/Tixall. This means that the proposed Lion Lodge Culvert and associated surface water drainage diversions will need a detailed review – but only after a comprehensive survey has been carried out to determine the exact nature of the extensive surface and underground drainage networks in the area. Alternatively, the proposed route is abandoned in favour of the cheaper lower impact route as discussed in Q2 Part B.

15.4 (Effects arising during construction – Avoidance and mitigation measures – Mitigation of ground water effects): The measures described seem more relevant to the management of the intrusion of water into excavation works rather than the preservation of existing ground water conditions. The fact that, at paragraphs 15.4.14 through 15.4.16, impacts are identified on nearby abstraction wells indicates that some draw-down in water table is expected. This implies that it is not envisaged that any form of cut-off structure will be used in association with Hanyards (Brancote) cutting. In view of the potential impact on Pasturefields SAC, this needs proper reassessment.

15.4.23 (Assessment of impacts and effects – Pasturefields SAC): The assessment is almost certainly invalid for reasons that have been provided to HS2 Ltd on many occasions. The key one being that the referenced HRA Screening report, dating from 2012, was prepared in ignorance of the existence of the salt marsh and associated brine springs, in Ingestre/Tixall, and the over-interpretation of limited available evidence that 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. See Q2 Part B.

15.4.25 et seq (Assessment of impacts and effects – Flood risk and land drainage): 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.

Community Area 2 (CA2) extends from Colwich to Yarlet. The responses below are selective and cover only that subset of CA2 that encompasses the parishes of Ingestre and Tixall plus relevant parts of neighbouring parishes. The area corresponds, roughly, to the 5km section of the Proposed Scheme from Ch 205+000 at Great Haywood to Ch 210+000 at Staffordshire County Showground.

As noted at paragraph b) of “General”, at the beginning of this consultation response, our comments on the Proposed Scheme do not signify acceptance of this scheme. As set out elsewhere (see Q2 Part B above) we believe 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 HS2 Phase 2 Route Options Report and referred to as “Route B” in section 4.3 of the Alternatives appendix.

As noted at the 4^th bullet of 2.3 in Part A of our response to Q3, incorrect/inappropriate naming has been used by HS2 Ltd for roads and other features in the area. We propose and strongly recommend that HS2 change place and feature designations on the maps and at the relevant points in the text of the CA2 report, in line with the following:

2. At map square H1 (spilling into H2 and I1), add “Little Ingestre”. NB: The Wellington-boot shaped part of the complex that sits at OS grid Ref: SJ 98952445 is Little Ingestre House Residential Care Home. This should be added as a spot reference, marked “Care Home”

5. At approximately the meeting point of grid squares G4, G5, H4 & H5, add “Lion Lodge Covert”

11. Lion Lodge Culvert is marked on CT-06-213 but is missing from CT-05-213. Neither map shows any access road to this culvert. An access road appears to have been provided for other similar situations.

12. We note proposed mitigation planting and mitigation ponds but request further detailed engagement about these before the scheme is finalised. It is not clear whether there is any form of “mitigation” that would off-set the loss of the remnant inland salt marsh – including the loss of Saltspring Pool (see 7.12 of our Phase 2 Route Consultation response and point 4 against map WR-01-203 below).

13. There is no indication on the maps of any utility diversion (or special provision for the protection thereof) in respect of either the BPA Thames-Mersey high pressure aviation fuel pipeline, or the Stafford Reinforcement high pressure gas pipeline that are crossed by the Proposed Scheme in this area and which we flagged in our Phase 2 Route Consultation response.

14. Further discussion about proposed scheme features is included as part the discussion, below, on the SV-01 series of noise maps.

· Integration of any utility services (if present) that otherwise would be severed

· HS2 maintenance access requirements in respect of Hanyards Drop Inlet Culvert

We strongly recommend that this overbridge is designed as a green bridge to facilitate wildlife movements between the predominantly open fields to the south and the predominantly wooded area to the north.

Having provided an overbridge that meets the above needs, its adoption as the path for Tixall Bridleway 0.1628 becomes a formality.

9. We note that Hanyards Drop Inlet Culvert is labelled on CT-06-214 but not on CT-05-214 (although the access road to it is shown).

10. We note the proposal to have a satellite construction compound at the top of Hanyards Lane. If this is retained in the final scheme we recommend that, in line with the reasons given at Point 8, it is renamed “Hanyards Lane Satellite Compound”

11. We have very serious doubts about the wisdom/practicality of locating a construction compound at the top of Hanyards Lane and using the existing lane as the means of access. The existing lane is a narrow, single track lane which is completely unsuitable for HGV movements, except on a one-at-a-time basis. Furthermore, the entry point for the lane, off Tixall Road, is extremely close to the busy, traffic-light-controlled intersection of Tixall Road with Blackheath Lane. Traffic turning into and out of Hanyards Lane is already problematic at times and this will only be made worse by the introduction of any significant additional traffic using the lane. We accept and note, at paragraph 2.3.22 of the CA2 report, that designated haul roads, along the line of the route will be used where practical. However, the report does not indicate, on a compound-by-compound basis, what proportion of comings and goings this will be. With an average attendant workforce of 25 at this compound (40 at peak) but, as yet, no indication of associated traffic movements, it difficult to assess the real impact. We request detailed engagement on this matter prior to finalisation of the Proposed Scheme.

2. We note that Berryhill (South) Culvert is labelled on CT-06-215 but not on CT-05-215. No access road is shown on either.

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 3m above railhead are proposed (limited to 2m on the viaduct). The resulting 3.3km long, 15-20m 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.

A suggestion, for consideration, that we believe may go part way to addressing this, is for HS2 Ltd, as part of the scheme, to acquire land/permission to plant an avenue of tall-growing trees along the full length of footpath Tixall1/Colwich 28 which runs from the Bottle Lodge, on Tixall Road (by Tixall Court) to the White Lodge on Mill Lane, Great Haywood. Once established, we believe this would provide a good measure of shielding from the west that would benefit Tixall, Shugborough Park, Cannock Chase AONB and the leisure users of the Staffs & Worcester canal (including, in particular, the very popular section known as Tixall Wide).

This is not a complete solution but it could be part of a more wider set of proposals.

As noted at section 13 of Q3 Part A, above, the local background LAeq is in the low 30s dB so even the outer edge of the pale yellow contour represents an increase in excess of 15dBA above background. The impact on quality of life will therefore extend much further from the track than implied from the mapped contours.

Furthermore, it is not obvious that the mitigation measures of the draft scheme have been developed with a proper understanding of the distribution of residents in the two parishes. We note that the Church, Hall and Stables of Ingestre have been considered to be the “core” of the community but, as noted at 7.4.12 of Q3 Part A, only 13 of the 74 residences in Ingestre are in this core area. The remainder are distributed as: 19 at Home Farm Court, 13 in Ingestre Village, 16 at Little Ingestre and the remaining 13 as outliers. While the “core” area and Home Farm Court appear to lie a reasonable distance outside the lowest contour, the margin for the remainder, which account for more than half the residents, is much less so. A further 17 residences on the Tixall side, located closest to the Trent North Embankment, are also going to be particularly affected.

At least on the Tixall side, there appears to be an obvious immediate mitigation measure. This is to install noise barriers on the southern side of the track and not just the north. We are concerned that this was not done from the outset. We are looking, therefore, for the immediate implementation of noise barriers on the southern side.

We are puzzled also about the way it is proposed that noise barriers are arranged on the Great Haywood viaduct. It would appear that barriers of up to 2m height are proposed on the viaduct, on both sides, but in a configuration in which those on the north side run only 2/3rds of the way across the viaduct from the western end while those on the southern side run only 2/3rds of the way across the viaduct from the eastern end. Visually, and acoustically, this must be very odd. We strongly believe that you should implement barriers across the full length of the viaduct, on both sides, with those on the southern side being further extended to somewhere around the Ch 207+500 mark.

Sensitivity studies should be performed to test the effects of different barrier heights. These should include the effect of going higher than 3m on the northern side of the Trent North Embankment to determine the benefits to residents in Ingestre village and Little Ingestre.

This is a complicated subject area and we formally request that HS2 Ltd engage with us on this matter as part of developing the final design.

1. The portion of the map defined by map squares F5, F6, G5, G6 needs detailed review, taking into account the information shown at Fig 2 in 2.3 of Q3 Part A.

2. At map square D6, Hanyards Lane Accommodation Overbridge (currently known as Tixall Bridleway 0.168 Accommodation Overbridge) is not labelled.

3. At paragraph 10.3.19 of the CA2 Report, it is recorded that there are six known groundwater abstraction points. Five of those listed are within the range covered by WR-01-203: Ingestre Park Golf Club, Staffordshire County Showground (two records), Upper Hanyards Farm and Lower Hanyards Farm. On the map, only two are shown: 03/28/01/0201 (which we presume is Ingestre Park Golf Club) and MD/028/0004/001 (which we presume is one of the two at the Staffordshire County Showground). The other three are missing.

4. We note the marking of ponds but do not see Saltspring Pool (on the southern edge of Lion Lodge Covert) as being marked. Saltspring pool does not appear on regular OS maps but has been advised to HS2 Ltd previously, as part of our Phase 2 Route consultation response. It is not large (only about 4.5m diameter) but is significant because of its depth (>2.5m) and saline nature (it is possibly an historical site of brine extraction). See Fig 2 at 2.3 in Q3 Part A.

Question 4: Please let us know your comments on Volume 3: Route-wide Effects: We welcome any information you may have on how the scheme may impact the environment at a route-wide level (i.e. on a geographical scale greater than the Community Areas) and any opportunities you feel there may be to reduce these impacts.

Paragraphs 2.2.1 through 2.2.4 address the total land take and the proportion of BMV agricultural land that is within this. We draw your attention to our response to Q2 Part B above and make the point that we believe that both total land take and, more importantly, the proportion of BMV agricultural land lost to the project would be reduced if Route B was used instead of Route C.

At paragraph 2.2.5, it is stated that: “It is estimated that there would not be any significant surplus of displaced agricultural soils arising from the Proposed Scheme.” This implies that at least some soils will need to be disposed to land fill or to remote regions of the HS2 project. No assessment is given of this quantity. Nor has any action been taken here, or in the revised EIA SMR, to address the point we raised at the earlier consultation on the draft EIA SMR that, when relocation of soils over considerable distances from their place of origin is involved, it is important that displaced soils are reallocated only to places which have soils of comparable structure and composition and that care is exercised not to introduce uncharacteristic (i.e. out-of-area) weeds, pathogens and pests. We would expect the final EIA to give some indication of route-wide movement of soils and the measures adopted to control what goes where (we note that the CoCP seems to deal only with local stripping, storage and reinstatement of soils).

Paragraph 3.2.3 addresses emissions from fixed plant and vehicles within construction sites. While we accept that, at a route-wide level, this contribution is likely to be small in comparison with existing emissions, this is not going to be true locally, especially for sites of construction in quiet rural areas away from existing highways. It is to be noted that this topic is not currently raised under the local (CA2) assessment on air quality which deals only with dust and the consequences of altered highway traffic flows.

HS2 is predicted, at best, to be carbon neutral after 60 years of operation (2087 for Phase 2a). This has to be set against the Government's own commitment to de-carbonise the UK economy by 80% by 2050.

No attempt has been made in the draft EIA to assess the contribution of HS2 to climate change nor of the magnitude of climate change that the design of the scheme must take into account to provide resilience. All this is deferred until the full EIA is produced.

In terms of the present draft EIA only the climate baseline conditions are set out. In this we have reason to doubt the figures given. We have not had the time to access the datasets that underpin the claimed climate statistics for Fradley to Crewe at paragraph 4.4.4 et seq. However, there is one statistic that just does not ring true and this then calls into question the validity of the other data. It is stated at paragraph 4.4.6, 3^rd bullet, that the region experiences approximately six frost days per year. Common experience dictates that this is a gross underestimate and a spot check of Met Office summary climate data for the UK Midlands confirms this. The average annual number of days of air frost for Keele, Staffordshire, over the period 1981 to 2010 is given as 46. This is more in line with experience.

Effects are principally local: see point 7 of Q3 Part A, above. However, cumulatively, they produce route-wide effects that are nothing short of a devastating loss to the cultural heritage of the country. Even though direct impacts on heritage assets has been minimised, a very large number will have their settings diminished. In this respect we draw your attention to our response to Q2 Part B above and make the point that we believe that there would be far less impact on the settings of heritage assets if Route B was used instead of Route C.

As already addressed at Q2 Part B and point 8 of Q3 Part B, above, we believe the ecological assessment of Pasturefields SAC and the undesignated LWS that is the remnant part of an historically larger inland salt marsh in Ingestre/Tixall, is fundamentally flawed.

Furthermore, while accepting that ecological surveys are on-going, we restate, from point 8 of Q3 Part B, that it is with considerable concern (and frustration) to find such a trivial assessment presented in the CA2 report. The EIA may still be in draft but there is no excuse for it to have failed to take into account detailed information already provided to HS2 Ltd as part of our January 2014 Phase 2 Route Consultation response. Our response contained (at Appendix 5) a 23 page wildlife report for Ingestre & Tixall. There is no evidence that any of the content of this report has been used either at the CA level or at the route-wide level.

As at point 9 of Q3 Part B above, 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.

It is hypocritical of HS2 Ltd on the one hand to link potential health benefits arising from the economic opportunities provided by local employment and the expenditure of earnings by construction workers in the area yet, on the other hand, to completely ignore the much more widespread and immediate negative economic effects caused by generalised property blight.

Considerable analysis is given in respect to the health impacts on those home-owners whose properties are required for the construction or operation of the railway. While their lives will undoubtedly be disrupted, with all the stress and emotional upset that this entails, they do at least receive full financial compensation. However, these are in the minority compared with those home-owners whose properties are not required yet have seen their property values reduced. Likewise, considerable effort has gone into describing the avoidance and mitigation measures that are proposed to limit adverse health impacts but the adequacy or otherwise of property compensation (probably the biggest single health mitigation measure available) is completely ignored.

The biased and unrepresentative analysis of health impacts therefore fails to properly represent the conditions on the ground. As noted at point 9 of Q3 Part B above, we believe that mapping of loss in property value due to HS2 should 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.

We refer you to point 10 of Q3 Part B above, with particular reference to the issue of the crossing of the salt marsh in the Ingestre/Tixall area and all that derives from it.

On a route wide basis, we presume that, on the operating railway, there will be an on-going need for vegetation control and that the use of chemical herbicides will be part of this. The persistent and regular use of herbicides (or, worse still, a spillage of concentrate) could result in contamination of nearby land and watercourses. While contamination from other sources (e.g. an oil leak from an auto-transformer or from the trains themselves) is mentioned, nothing is said about herbicide use.

While accepting that most landscape and visual effects are local, we would point out that the assessments are all made assuming a ground-based observer.

The section of the country through which the Proposed Phase 2a 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 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 in the final EIA.

NB: A more creative use of tunnels, instead of deep cuttings, would be an important mitigating measure, much as has been employed on Phase 1 in the Chilterns.

We believe that the assessment (and the revised EIA EMR on which it is based) remains seriously deficient in terms of the recognition and treatment of accidents arising from human error, vandalism, sabotage, or terrorism etc; which, collectively, we would suggest, constitute the greatest risk of leading to a major accident.

Apart from a few brief references (e.g. of HS2 Ltd's commitment to cyber security at paragraph 11.3.4, or to the fact that a derailment may have multiple causes, including; “malicious intent or human error” at paragraph 11.4.6), the whole topic is firmly rooted in “operational failure or natural disaster” as the cause of major accidents. This includes extreme weather (storm, flood, temperature) and ground-related incidents (subsidence, landslide, earthquake) etc.

Unless “operational failure” is interpreted in its widest sense; i.e. issues such as inadequate security measures in respect of public access to trains and other railway facilities, poor training or inadequate psychological screening/background-checks of HS2 employees etc., count as “operational failures” (as well as e.g. a broken rail or a signalling failure etc.) then the whole class of incidents that arise from inappropriate human action (with or without malicious intent) will be excluded. This seems to be a major omission from the EIA.

Paragraph 11.6.3 cites examples of hazards external to the proposed scheme that lie within the construction zone or are crossed by the scheme. To the list should be added “oil pipelines” (e.g. the Thames-Mersey high pressure fuel-oil pipeline mentioned above in Q3 Part B (point 5 under map CT-05/06-212). Possibly also “chemical pipelines” if piped hazardous products, other than oil and gas, might exist in proximity to the Proposed Scheme.

NB: Water would normally be considered non-hazardous but a breach to a major confined water course (whether e.g. a dam or major culvert that is part of the national water supply network or of a canal or embankment-contained river etc) with the potential to suddenly release very large quantities of water, would certainly place water in the hazardous category.

The appraisal that leads to the conclusion that the Proposed Scheme will have major beneficial effects seems unduly biased.

We are not in a position to provide any robust evidence for this but to conclude that, on a route-wide basis, the Proposed Scheme has the potential to create 1,010 full-time equivalent new jobs during construction and 415 direct and indirect jobs during operation while sacrificing only 10 (5 as direct losses and 5 as indirect losses) seems unduly optimistic.

As noted at point 12 of Q3 part A above, we believe that indirect effects in Ingestre/Tixall alone could be significant, the magnitude being critically dependent on the impacts on and degree of assistance available to local businesses. In Ingestre and Tixall alone there is the potential for more than 10 job losses, which is a significant portion of the very small number of local job opportunities for our residents.

We concur that this is essentially a local issue and that any route-wide effects would be picked up in the route-wide health impact assessment.

Local issues are addressed at point 14 of Q3 Part A but we would flag, in particular, the potential negative impacts, during construction, in the wider regional network, on emergency medical response times – especially journey times to Wolverhampton and Stoke-on-Trent.

There will be some local residents who commute to work or whose work involves travel in the wider area and who might be concerned about the route-wide impacts of construction. We do not have information on the numbers that may be affected.

When the Proposed Scheme is in operation, benefits will most likely be negative overall. Much will depend on whether the Handsacre link to the WCML is completed as part of Phase 1 or be cancelled, as has been much speculated since the announcement of Phase 2a. Even if it is not cancelled, an indicative service pattern, including the effects of released capacity on WCML, indicates that HS2 will provide only a single, hourly fast (non-stop) Classic Compatible service to London, from Stafford, saving 15-20 minutes, with most other local and regional rail services reduced in number and/or made slower stopping services. If the Handsacre link is abandoned and/or the present indicative once-per-hour stop at Stafford is dropped, then no benefits will accrue. We wait with interest the assessment that is promised in the formal EIA.

We note the extensive work reported and are pleased to see that HS2 Ltd expect to be able to reuse 99% of all materials arising from the works in the construction and landscaping of the scheme with only 1% going to landfill. The 1% nevertheless amounts (in round figures) to 270,000 Tonnes.

The balance of over 25 million Tonnes of generated material will nevertheless require processing, transporting, storing and eventually distributing and integrating into the works. This is an horrendous exercise. At paragraph 15.6.3 it is nevertheless said that “There is expected to be a net shortfall in excavated material” so, we presume, there will be additional excavated material imported to the region to make up the shortfall. The expected level of the shortfall is not disclosed.

What is required but appears will not be disclosed until the formal EIA is published, is just how and over what routes, the various movements of materials will take place. Until this is known we are not really in a position to express a view on it. We request, however, that HS2 Ltd seek to engage with us at the earliest opportunity, before finalisation of the EIA, to discuss in detail their ideas regarding the movement of men/women, machines and materials in our area of CA2.

On a route-wide basis, we can only emphasise the need for due diligence, especially with regard to the cumulative effects of all activities in the River Trent catchment area.

The low-lying areas of Ingestre and Tixall, though not having a history of flood inundation are nevertheless precariously located on the edge of the River Trent/River Sow flood-plains. We do not want to see any activity during the construction or operation of HS2 (taking into account the effects of climate change on the frequency and intensity of extreme weather events) that raises the risk of flooding by any amount above that which would have occurred naturally had the Proposed Scheme not been built. We wait with interest the assessment that is promised in the formal EIA.

HS2 Phase Two: West Midlands to Crewe, Property Consultation Response submitted 23.2.2016

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 Phase Two of HS2 (Birmingham to Manchester leg) and are located on the section of route, between Fradley and Crewe, now designated as Phase 2a, which is the subject of this consultation.

Question 1: We believe that the compensation and assistance schemes that are available for Phase One of HS2 are also suitable for those living along the Phase 2a (West Midlands to Crewe) section of HS2. Are there any circumstances which you think should be considered to make the proposed schemes more suitable for the Phase 2a section of HS2? Please provide as much detail as possible.

1.1 The Parish Council has previously responded to both the HS2 Property Consultation, 2013 and the HS2 Property Consultation, 2014.

1.2 We are deeply concerned that our views, along with those of the majority of other respondents, have been disregarded and that the Government has put in place on Phase 1, proposals that fail to provide adequate compensation for those adversely affected by HS2.

1.3 We are now advised that it is the Government's intention to impose the same inadequate compensation and assistance schemes on Phase 2a. Because the compensation and assistance schemes for Phase 1 are inadequate to start with, the basis of the current consultation is flawed. Changes to the proposals are required, with any changes arising from this consultation being applied not only to Phase 2a but also retrospectively to Phase 1. Our detailed comments on the current proposals are given in the following paragraphs:

1.4 The proposals for Express Purchase are considered acceptable and we welcome the decision to launch this component immediately; i.e. prior to consultation.

1.5 We welcome also the provision of Homeowner Protection. However, the exclusions set out at paragraph 5.2.9 of the consultation document are incompatible with the objective of the scheme as set out at paragraph 5.2.8. Clause 5.2.9 should be deleted.

1.6 The proposals for Rent Back appear broadly sensible. Annex B of the consultation document makes clear that, in order for the seller to rent back their property, the Government must first assess the property and bring it up to the minimum legal standards for renting. We ask that the Government arranges, where possible, for there to be continuity of occupancy during this process. To the families involved, the property will still be the family home, even if the legal title has changed. This transition needs to be handled with care and sensitivity and, wherever possible, be achieved without requiring participants to temporarily move out of their home with all or part of their possessions – only for the move to be reversed upon commencement of the rental agreement.

1.7 In previous consultation responses, we registered our concerns about the use of a Rural Support Zone (RSZ); favouring a Property Bond instead. We objected to the Government's proposal for a fixed limit for the RSZ of 120m because it is too small and ignores the real effects of topology and characteristics of the line on the distribution of blight. On the Alternative Cash Offer, we considered 10% of the property value to be too little to significantly reduce the number of property owners in the RSZ who apply for Voluntary Purchase. We restate these views and ask that the Government yet again reconsider their proposals for the RSZ, along the lines previously indicated.

1.8 As noted at paragraph 1.9.1 below, under current proposals, there are no properties in the Parishes that lie within the RSZ and only a very few are in the Homeowner Payment (HOP) Zones. As a result, nearly all the parishioners who are adversely affected by HS2 only have recourse to help via the Need to Sell Scheme (NTS).

1.9 We ask that both HOP and NTS schemes are reviewed and revised, taking into account the following observations based on the current proposals:

1.9.1 Within the parishes, there is one property in the safeguarded zone, none in the Rural Support Zone and just seven in the Homeowner Payment Zone. Of the latter, only three of these are owner-occupied (two in HOP Zone 2 and 1 in HOP Zone 3); the remainder are rented.

1.9.2 As a result, under the discretionary parts of the scheme, a paltry £37,500 in total will be paid out to just three households who happen to live within 300m of the line. Additionally, none of the payments are in the form of compensation but, instead, are what is cynically described as: “an early share in the benefits of the scheme”. To offer a few thousand pounds to a minority of the property owners who have seen the value of their properties fall by tens of thousands, in some cases by more than a hundred thousand pounds, is an insult. HOP should be abandoned or substantially upgraded.

1.9.3 There are over 100 properties, representing over half the population of the two parishes, within 1km of the route that are seriously affected by blight as a result of HS2. The only recourse, if any of these owners wish to move without incurring a significant financial loss, is currently the Exceptional Hardship Scheme (EHS) – which is to be replaced in late Spring 2016 by the Need to Sell scheme (NTS) following analysis of the responses to the present consultation.

1.9.4 As evidence of the impact of HS2, we submit, at Annex 1, a commentary on the experience of some of the home-owners from within the two parishes who have attempted to market their properties since the announcement of the Phase 2 Initial Preferred Route (IPR) in January 2013.

1.9.5 Generalised blight due to HS2 was immediate and severe from the moment that the IPR for Phase 2 was announced three years ago. Even with the proposed acceleration by six years of Phase 2a, commercial operation will not commence until the end of 2027, with eligibility for compensation under Part 1 of the Land Compensation Act commencing one year later, at the end of 2028. If the Government is correct that generalised blight is temporary and will evaporate once the railway is in operation, this still means that residents close to Phase 2a will have had to endure 16 years of blight and, for approximately half that time, the additional disruption arising from the construction of the railway, during which the blight will intensify.

1.9.6 Residents living close to the remaining parts of Phase 2, which are not scheduled to be completed until 2033, will experience blight for over 20 years.

1.9.7 In the UK, changing family needs and/or work-related factors results in the median interval between families moving home being 8 years[1]. Hence, compared with the 16/20 year period of blight caused by HS2, many families affected by HS2 will find that they are unable to move, at the normal time of their choosing, without incurring a substantial financial penalty. In this respect, we consider that the Government is being disingenuous in describing the blight caused by HS2 as “temporary”, when “temporary” extends up to 20 years (a whole generation!) and is two or more times the median residency time. Under present proposals, the Government will only intervene in exceptional circumstances to help those trapped. This is further discussed below.

1.9.8 The Parish Council, along with the majority of respondents to previous property consultations, strongly supported a Property Bond scheme as a means to ease the problems highlighted at 1.9.7. The Government rejected this and, instead, made only minor adjustments to EHS, re-branding it as NTS, and introducing Homeowner Payments. None of the changes have provided any meaningful relief to the problem of blight: the Homeowner payments being too small, too tightly confined and having no relationship to the blight experienced, while evidence from the initial operation of NTS on Phase 1[2] shows that its complex, intrusive and adversarial procedures have resulted in little uptake and caused considerable frustration, annoyance and distress.

1.9.9 Consequent on 1.9.8, it is imperative that the Government takes action to address the shortcomings of the present proposals. In this respect, and in the light of the observation at paragraph 1.8 above, this means changing the NTS scheme. As has been stated in previous consultations (and referred to at 1.9.8 above), the preferred solution is abandonment of NTS in favour of a Property Bond scheme. If the Government is resolute in not pursuing this option, in spite of the widespread support for it and the low cost to Government, then it is the NTS operating criteria that need revision.

1.9.10 With regard to NTS, we commend and support the observations and recommendations of the Phase 1 Hybrid Bill Select Committee as set out in their report². With reference to that report, we make the following specific points as being of particular relevance to our joint Parish:

▪ Whilst the Government's view is that NTS is performing well[3], paragraph 4 of ref [2] points out the abysmally low take-up rate, citing that: “many people who should probably be applying still find the scheme off-putting by its sheer complexity.” We note that there have been only 116 applications over 10 months out of a potential of 43,000 properties that lie within 500m of the Phase 1 route. The extent of blight is known to extend much further (ref [3] indicates that 20% of successful NTS applications lie further out than 800m) but, even so, out of 43,000 properties within 500m, ref [1] would suggest that roughly 10% (4,300) would have been expected to change hands during the 10 month period. The figure of 116 applications (of which 45 have been accepted) represents just 0.27% of the property sales that would be expected in a normally operating housing market. Hence, it is clear that NTS is not helping most of the people that are adversely affected by HS2. We therefore urge the Government to simplify the NTS scheme and revise the acceptance criteria to better achieve: “the availability and fairness of the means of redress for reductions in property value” that is required (clause 4.1.2 of the consultation document refers).

▪ Many of our parishioners who are trapped in their homes are elderly. We fully support the view, at paragraph 8 of ref [2], that “Age and Stage” should suffice as a compelling reason to sell, and concur with the statement: “Neither a couple nor a person alone should be required to stay on in a large home when previously resident children have become non-resident adults. It will often be right for homeowners in such positions to be able to sell without having to go to any length to demonstrate their inability to sustain home running costs. Applicants should not have to show that they will be penniless in order to demonstrate an “unreasonable burden”. Retirement is as acceptable a reason to move as is a new job.”

▪ We are concerned about and share the view of the Committee expressed in ref [2] that: “financial scrutiny is excessively intrusive” (paragraph 16) and that there has been: “an over-zealous approach to seeking medical evidence” (paragraph 17).

▪ At paragraph 18 of ref [2], we especially welcome the observation that: “where local estate agents have a policy of insisting on up-front fees for marketing because of HS2, that should normally be assumed to be a sufficient indication of blight to meet the criterion on failure to market successfully.” Requesting up-front fees is a practice that local residents have encountered and we therefore endorse the view of the Committee that the NTS guidelines be amended to make clear that the charging by estate agents of up-front fees is sufficient evidence that a property is blighted and would not sell if marketed at the unblighted open market price.

▪ A significant number of the residential properties in the two parishes, which are affected by HS2, are rented and not owner-occupied. We are seriously concerned that the proposed property compensation schemes are restricted to owner-occupiers. Under the current schemes the only concession to the rental sector is to accept the category of “reluctant landlords”, where previous owner-occupiers have been compelled to move away but been unable to sell and have had to resort to renting the property in order: “to avoid a situation of unreasonable burden.” This has left the bulk of the rental sector out in the cold. Yet, for many landlords, these properties are key sources of income and/or represent capital set aside to support future needs. They, too, are negatively affected by HS2 because of potentially reduced rental income and/or loss of capital value of the property. We note the observation, by the Select Committee, at paragraph 24 of ref [2], that although the effect of HS2 on rental property may be different from that on freehold property, there is still an impact. We therefore welcome and support the statement by the Committee that: “we would like the Department to look at whether exceptions or provisions should be made to the overall approach on rented properties”. We urge the Government to take this request on board.

▪ We note the Committee's conclusion, at paragraph 29, that; “There remains some disparity between the aspirations for the scheme and the way it is actually working.” and urge the Government to address and rectify the points raised by the Committee. Particular attention should be paid to those points highlighted above.

The Government has responded to the Select Committee Report[4] and we note the intention to issue revised guidance for NTS later in Spring 2016. Please ensure the above issues are factored in.

1.10 Clause 4.2.3 of the consultation document states: “It is not the purpose of this consultation to invite comments on the Compensation Code or the statutory blight regime.” Nevertheless, we restate our view as first expressed in our response to the 2013 Property Consultation: “All parts of the present compensation proposals default to statutory compensation under Part 1 of the Land Compensation Act 1973, 12 months after the scheme becomes operational. This act is outdated and not fit for purpose in the 21^st century. The Government should thoroughly overhaul this act and include within its provisions the means for addressing general property blight due to all causes (not just physical effects such as noise, dust, vibration etc.).” It remains our view that this legislation needs to be fully revised and updated, and brought into force before Phase 1 of HS2 is completed.

1.11 It is now known to us that revision of legislation that surrounds the Compensation Code has been an aspiration of Government for at least 15 years but that successive administrations have failed to allocate Parliamentary time to it. That this is the case is brought to our attention by the evidence brought before the HS2 Phase 1 Hybrid Bill Select Committee by the Country Land and Business Association (CLA). Details were given as part of the presentation to the Committee by Mr Richard Honey, Counsel for petitioners (CLA), on Monday 17 November 2014. The full transcript can be found here. Paragraphs 22 through 36 provide a pertinent summary of the situation as it stood at that date. These paragraphs are reproduced at Annex 2. NB: Even though emphasis is placed on those parts of the Compensation Code of importance to members of the CLA, revision of the code is equally of importance to residential property owners.

1.12 We recognise that there are many complex issues that need to be addressed in any revision of compensation law. The current Compensation Code is a collective term describing principles that are derived from Acts of Parliament and case law that go back over centuries and this makes consolidating and updating the code difficult. Nevertheless it is a responsibility of Government to ensure that legislation is fit for purpose in the present era and it should not hold back from addressing difficult cases. HS2 has highlighted many problems with the present system. The Government must bite the bullet and act now to rework the Compensation Code as requested by us, the CLA and many others.

Question 2: What are your views on the proposed boundary of the Rural Support Zone (RSZ) at the south side of the A500? Please provide any alternative proposals and as much detail as possible.

2.1 We found this question opaque. Only after clarification had been obtained from HS2 Ltd, was it determined that the question referred to the proposal to make the A500 at Crewe the boundary between “urban” to the north and “rural” to the south.

3.1 The main compensation packages for properties outside the safeguarded zone are inadequate.

3.2 The geographical distribution of residents in the two parishes is such that over half the resident population lives within 1km of the route and is adversely affected by HS2. The only scheme available to most of these people is the NTS scheme, the provisions of which are overly restrictive.

3.3 We join with the Phase 1 Hybrid Bill Select Committee in calling for a radical overhaul of NTS.

3.4 Even though the present consultation does not seek views on aspects of statutory compensation, we restate our position that the Government must bring forward legislation to make statutory compensation law fit for the 21^st century.

The information below has been gathered from direct contact with local residents and on-line searches – principally from Zoopla and RightMove. Data was collected in early February 2016. It is as correct as it has been possible to ascertain and is presented in good faith as examples of local experience with property sales.

On-line searches were conducted by Post Code, all within ST18, using 0RE, 0PZ, 0ZF and 0RG for Ingestre and 0XJ, 0XN and 0XT for Tixall. Only properties from Ingestre and Tixall within 1 km of the confirmed route for Phase 2a of HS2 were considered.

The examples gathered have been assigned to one of the four following categories:

· Property sales completed since the announcement of the Phase 2 Initial Preferred Route (IPR) in January 2013.

· Properties which owners have attempted to sell but who have given up through lack of interest from potential buyers and withdrawn them from the market.

· Properties which have never been put on the market but whose owners have actively sought a professional valuation of their property.

No specific attempt has been made to determine homeowners who are, or have been, in contact with HS2 Ltd in respect of claims for assistance under the Exceptional Hardship Scheme (EHS). Where mention of EHS is made in the examples below, this is with the agreement of the owners involved.

The views of housing market specialists; estate agents, property surveyors, conveyancing agencies etc has not been sought – this is an entirely community-focused exercise.

Examples are presented in a standardised format, comprising: Property identifier, Category (as defined above), Distance from HS2 (approximate only – measured from the centreline of the route) and Commentary.

Property A (Old School House, Ingestre): Category 1; Distance from HS2: 470m.

Sold in July 2014, for an undisclosed sum, to HS2 Ltd under EHS. This property had been on the market since before the IPR for Phase 2 was announced. Reasons for acceptance under EHS were compelling and the owners were relieved (but emotionally drained) at the outcome. The property is now rented.

Property B (Kipscombe, Old Stables, Ingestre): Category 1; Distance from HS2: 440m.

Sold in June 2013 for £180k, through private offer, having been valued at £240k prior to going to auction (i.e property was sold at 25% below the pre-auction valuation). Purchaser knowingly used HS2 as leverage.

Property C (20, Home Farm Court [Home Farm House], Ingestre): Category 1; Distance from HS2: 630m.

Sold in March 2015 for £585k, in desperation, after having been continuously on the market (and empty for much of the time) since 2012. Property was originally acquired for £720k in Sept 2008 and, based on Halifax house price inflation indexing[5], using the regional average for the West Midlands between Q3/2008 and Q1/2015, would have been expected to be worth £762k at the time of sale. Effective loss in value is 23%. See notes at end of examples.

Property D (15, Home Farm Court, Ingestre): Category 1; Distance from HS2: 680m.

Originally placed on the market in 2012, prior to announcement of HS2, at £460k, with an expectation of sale at £425k - £430k based on real market value. Property was withdrawn from sale following the announcement of HS2. The following year (2013), it was re-advertised with a different agent, at the reduced asking price of £395k (i.e. roughly 10% below originally expected sale price). After little interest, even at this reduced value, the owner “walked away” in desperation, accepting an offer of £335k, in July 2014, in order to secure a sale. This was nearly £100k below the pre-HS2 realistic valuation, corresponding to an effective loss in value of 22%.

Property E (5, Home Farm Court, Ingestre): Category 1; Distance from HS2: 640m.

Sold in April 2015 for £500k. This is the same as the value paid by the owners when they bought in April 2005. Based on Halifax house price inflation indexing, using the regional average for the West Midlands between Q2/2005 and Q2/2015, this property would have been expected to be worth £561k at the time of sale. Effective loss in value is 11%. See notes at end of examples.

Property F (2, Home Farm Court, Ingestre): Category 1; Distance from HS2: 620m.

Sold in June 2015 for £290k after being competitively priced for a quick sale (see NB). This property was originally acquired for £272k in July 2002 and, based on Halifax house price inflation indexing, using the regional average for the West Midlands between Q3/2002 and Q2/2015, would have been expected to be worth £462k at the time of sale. Effective loss in value is 37%. See notes at end of examples. NB: The blighting effect of HS2 was exacerbated by other factors.

Property G (North Barn, Little Ingestre): Category 1; Distance from HS2: 630m.

Sold October 2015 for £342k. This property was originally acquired for £314k in March 2010 and, based on Halifax house price inflation indexing, using the regional average for the West Midlands between Q1/2010 and Q4/2015, would have been expected to be worth £351k at the time of sale. Effective loss in value is 3%. See notes at end of examples.

Property H (Little Ingestre Barns [Ingestre Sawmill Development]): Category 1/3; Distance from HS2: 670m (average value spread across 10 residential units).

This is a multiple-unit barn conversion development that commenced before the announcement of HS2. Eight out of ten terraced units have been sold as new build. Two (units 5 & 6) remain unsold and have been withdrawn from the market. Two units have been re-sold in the period since January 2013: Nos 8 & 9, both in October 2013; No 8 for £285k and No 9 for £222.5k. Within the time available for this study, it has not been able to pin down specifics related to these two sales, however the following observations can be made: i) the asking price for the unsold units, before withdrawal from sale, was “Offers in excess of £290k”; ii) average market value of the other units prior to HS2, worked out using the Halifax house price inflation index calculation tool, is £281k. This implies that No 8 was sold with no obvious impact of HS2 while No 9 appears to have been sold with a 20% reduction against the average. See notes at end of examples.

Property I (Khamsa, Old Stables, Ingestre): Category 2; Distance from HS2: 460m.

This property was initially put on the market in October 2014 with an asking price of £275k. It did not sell and, eventually, the property was withdrawn from the market. In November 2015, circumstances dictated that the property was re-advertised, this time at a reduced asking price of £260k. Some interest has been shown but, on more than one occasion, this interest has evaporated the moment the proximity to HS2 was discovered. Recently, a formal offer was made at the asking price but was subsequently withdrawn because of HS2. The property remains unsold. It is understood that the owner is now considering an EHS application. See notes at end of examples.

Property J (Garden House, Old Stables, Ingestre): Category 2; Distance from HS2: 470m.

This property was valued at £375k in August 2009 when the owners originally contemplated selling. Before it was sold, it was withdrawn from the market. In December 2015, the property was re-advertised but, because of HS2, was offered with a reduced asking price of £350k. Based on Halifax house price inflation indexing, using the regional average for the West Midlands between Q3/2009 and Q4/2015, the pre-HS2 (2009) value of £375k would have been expected to have grown to £434k. The current asking price is therefore 20% below the expected (unblighted) market value. See notes at end of examples.

Property K (11, Home Farm Court, Ingestre): Category 2; Distance from HS2: 700m.

This property was bought for £485k in November 2003 and, based on Halifax house price inflation indexing, using the regional average for the West Midlands between Q4/2003 and Q4/2015, would be expected to be worth £622k at the present time. The owner has been trying to sell since before 2013. It is currently advertised at £575k. Loss in value at asking price is 23%. See notes at end of examples.

Property L (Yew Tree Cottage, Little Ingestre): Category 2; Distance from HS2: 600m.

Recently (Jan 2016) put on the market with an asking price of £250k. At the time of writing, there is no further information on this property.

This property was put up for sale in February 2014 for £460k. After remaining unsold for more than 18 months, in October 2015, a prospective buyer came forward, prepared to pay the asking price. It turned out the the purchaser was unaware of HS2 until the day that contracts were to be exchanged. Having been informed of HS2 by their solicitor the purchaser withdrew. This was a devastating setback to the owner. The property was immediately put back on the market at a revised asking price of £450k. The property remains unsold. It is understood that the owner is now pursuing an EHS application.

Property N (Aston House, Tixall Mews, Tixall): Category 2; Distance from HS2: 930m.

This property was placed on the market in April 2015 with an asking price of £320k. It remains unsold. It was purchased by the owners in August 2001 for £206k. Using the Halifax house price inflation indexing tool, for a property in the West Midlands area, a value of £206k in Q3/2001 corresponds to £412k in Q4/2015. It would appear that this property is being offered for sale at roughly 22% below the expected open market price. See notes at end of examples.

Property O (Larkspur House, 11 Tixall Court, Tixall): Category 3; Distance from HS2: 660m.

On-line searches show that this property was advertised for sale with an asking price of £340k, effective from April 2014. It failed to sell and has subsequently been withdrawn from the market (date of withdrawal not found).

Property P (Church House, Old Stables Ingestre): Category 3; Distance from HS2: 450m.

Following the announcement of HS2, the owners wanted to move away and, in March 2014, put the property on the market with an asking price of £360k. There was little interest. In July 2014, at the recommendation of their estate agent, they lowered the asking price to £330k. This attracted a potential purchaser and a sale was agreed at an offer value of £320k. Regrettably, the purchaser was refused a loan by their mortgage provider, who cited the proximity of HS2 as the reason for the rejection of a loan. The sale collapsed. In frustration and annoyance, the owners withdrew the property from the market, moved away and placed the property in the hands of agents to rent it out. It is now successfully rented.

Property Q (14, Home Farm Court, Ingestre): Category 3; Distance from HS2: 690m.

On-line searches show that this property was placed on the market in December 2014, with an asking price of £395k. No sale was achieved and, in 2015 it was withdrawn from the market.

Property R (17, Home Farm Court, Ingestre): Category 3; Distance from HS2: 640m.

On-line searches show that his property was placed on the market in May 2011, with an asking price of £285k. No sale was achieved and, in 2015 it was withdrawn from the market.

Property S (9 Home Farm Court, Ingestre): Category 3; Distance from HS2: 680m.

This property was the subject of a failed attempt to engage with HS2 re EHS. It was put on the market in early 2015 for £350k as pre-qualification for EHS. In October 2015 a private buyer made an offer of £290k. In the interests of achieving a quick settlement this offer was accepted,– only for the sale to collapse due to complications, including HS2. Engagement with HS2 re EHS proved traumatic and insensitive which eventually resulted in withdrawal from the EHS process. The property remained unsold and is no longer on the market. NB: This property was originally acquired for £340k in November 2009 and, based on Halifax house price inflation indexing, using the regional average for the West Midlands between Q4/2009 and Q4/2015, would have been expected to be worth £393k at the time of the failed sale. Had the sale gone through at £290k the effective loss in value would have been 26%. See notes at end of examples.

The owner engaged two estate agents to each give two valuations for the property: one an open-market unblighted value and the other taking into account HS2. The unblighted value was £650k, while the blighted value was £525k. This corresponds to a reduction in value of 20% due to HS2.

The extract below is taken from the uncorrected transcript of the oral evidence to the Phase 1 Hybrid Bill Select Committee[6], presented by Mr Richard Honey, Counsel for petitioners, Country Land and Business Association (CLA), on Monday, 17 November 2014:

22. Now the issues, sir, that we raise, are not new, we have been looking at them for quite some time. The CLA and the NFU jointly produced a report in 1996 that dealt with the compulsory purchase and compensation system and many of the issues that we raise today were raised in that report as well. And we raise them again, because they’ve been unresolved, despite it being recognised that there are serious problems. And they include blight, accommodation works, dispute resolution, a way of dealing with complaints, the Crichel Down rules, to do with surplus land, advanced payments and interest. All of those are issues that we’ll be raising before the Committee. And we have many years of experience of dealing with those in practice; the statutory regime, how it works in practice reflected through our members, and projects up and down the country, and, of course, experience of the unfairness that results from the operation of the current statutory regime, frankly how it doesn’t operate properly in practice. So, that need for change we say, undoubtedly exists, and it has been recognised by Government repeatedly, over the last 15 years or so, but nothing has been done, due effectively to competing priorities, not because it wasn’t thought that something needed to happen.

23. So, that need for change, that’s been recognised over the last 15 years or so, remains and is now frankly more acute than ever, given the HS2 project and the impacts that it will have. And this is something that we have been stressing repeatedly in relation to HS2. We published a report in 2012, called Fair Play which set out what was required to make the compulsory purchase and compensation system fair, and indeed, we produced a manifesto for HS2 more recently which set out what we said needed to change in order to create fairness, so the issues that we raise today have been foreshadowed in those documents and they won’t be new to HS2.

24. There have been some discussions between the CLA and HS2 and other Government departments but frankly, there’s been less engagement than we would have hoped for, and as usual, from HS2, we’ve had some draft assurances provided at the last minute, as usual, again, they are caveated, qualified and general in their terms, and they go no way near meeting the concerns that we have, hence our need to present our case to the Committee today and tomorrow.

25. I want to address a particular point now, sir, if I may, which is why changes need to be made to the regime for compulsory purchase and compensation, in relation to HS2. It is a unique infrastructure project inasmuch as it will have undeniably major impacts in areas that will see no benefit at all, because they are so far removed from the stations. That’s not the case with CTRL – it may be that Mr Green will be able to tell you more about that later, but Kent had stations at Ashford and Ebbsfleet and therefore, although it took the brunt of the impact, also saw the benefit of it. That is simply not the case with HS2; on any analysis, the rural areas between London and Birmingham, will have to grapple with the very large effects of HS2, with no local benefits coming at all.

26. Early on in the process of developing HS2, The Secretary of State recognised that HS2 was a special case in relation to compulsory purchase and compensation. Going back as far as July 2012, Justine Greening, the Secretary of State, said in a written statement, that her intention, ‘Is to deliver a generous compensation package for those affected by the route which goes over and above the minimum required by law’. And she went on to say, ‘We’ve committed to going above and beyond the statutory requirements for property compensation’. And that’s something that’s been repeated since; Simon Burns, as Transport Minister, for example, in the preparation bill debate in July 2013, said, ‘The Government are committed to establishing a fair and general package of compensation for property owners affected by the scheme’, and he said that the Government wants to do as much as it can to minimise problems and to seek to help people, so the position is, sir, that the Government has accepted the principle that the current statutory regime is simply not good enough to deal properly with the effects of HS2, because it is such a unique project, and indeed, it remains common ground that changes to the statutory regime need to be made for HS2.

27. Most recently, Robert Goodwell said in the HS2 compensation debate in October, where, sir, I think you were present to hear it, and I’ll quote if I may, ‘Although the Government remain confident that reliance on the existing compensation code is appropriate for the majority of infrastructure schemes, we believe that the exceptional nature of the HS2 project justifies a different approach’. Now, the Government have long been committed to introducing measures for those directly affected by HS2 that go beyond what is required by law. So, the minister has said – recognised, that it is necessary to go beyond the current statutory regime for compulsory purchase and compensation, in order to ensure that it is fair, as far as HS2 is concerned. The question for the Committee to consider is whether the bill provisions, the information papers and the like achieve this. We say that it doesn’t, and that there is more for the promoters of this scheme to do, in order to achieve those objectives which minsters have set out repeatedly over recent years.

28. I will briefly sketch, if I may, the history of how law reform proposals in this area have panned out over the years. In the 1990s, the Government commissioned research on the operation of the compulsory purchase and compensation regime, and that fed into something that was called the Compulsory Purchase Policy Review Advisory Group, which was made up of industry experts, together with Government representatives, covering all areas of compulsory purchase and compensation. They produced a report which was published by DETR, as it then was in July 2000, called, ‘A Fundamental Review of the Laws and Procedures Relating to Compulsory Purchase and

Compensation’. There was also published at the same time, a separate research project into the Crichel Down rules. Following that, the then minister, who was Nick Raynsford, in July 2000, said that that research had confirmed the Government’s suspicions that the Crichel Down rules were not working well.

29. Following that, there were proposals by DTLR as they were at that time in 2001, for change. DTLR recognised, and I quote, ‘The current arrangements for the payment of compensation are convoluted, heavily dependent on case law and not always fair and consistent in their application’. And that, sir, is as true now, as it was then.

30. They said then, that there was a need for major changes, and the way that it was proposed to deal with that was through a Law Commission project. Now that stage, DTLR committed to giving effect to the Law Commission recommendations, and they said, in fact, that it would be brought before Parliament at the earliest opportunity, but sir, as I’ll explain in a second, that the Law Commission recommendations were shelved rather than being implemented, they were kicked, if I can put it this way, into the longest of long grass.

31. But notwithstanding that, things continued – at the time, in 2002, the Government published a policy statement which was linked to the planning green paper then, where ODPM, the next iteration of the relevant Government department at that time, accepted that compulsory purchase powers were not always fair to those people whose property was affected. One of the issues that they raised at the time, was capital gains tax, which I’ll mention just very briefly if I may, because this is an issue that the NFU are dealing with, primarily. At that stage ODPM recognised that all unavoidable additional taxes should be reimbursed in full. But that, in relation to capital gains tax remains unaddressed. It echoed what had been said by DTLR in 2001 as well, when the Government said compensation should include any additional taxation that arose as a result of compulsory purchase, including capital gains tax. Now we, sir, have put before the Committee our proposals for capital gains tax in relation to compulsory purchase payments, and they are, in a nutshell, first, that the relevant statutory provision should be extended to permit rollover relief for a new asset, not just land, but a new asset, because it may be impossible for a rural business to replace land in practice, given its limited nature, and they may therefore decide to invest in the business in other ways, and it should be possible, in our view, to get rollover relief for a new asset, not just replacement land.

32. The second point is to lengthen the rollover period, to be more reasonable. We are proposing that it should run, effectively from Royal Assent through to a period of five years after payment of compensation so that it is more closely aligned, in practice, to how long the search for replacement land would take, if a rural landowner is actually lucky enough to be able to find replacement land. So, those, sir, are our proposals in relation to capital gains tax, which are set out in our solution sort document.

33. So, as far as the course of normal reform continues, we then had the Law Commission project which reported in 2003 and they recommended fundamental changes to the law of compulsory purchase and compensation. It was frankly a complete overhaul that was recommended, and the way they put things, quoting from their report in 2003, was that, ‘The current law of compulsory purchase is a patchwork of diverse rules derived from a variety of statutes and cases, over more than 100 years, which are neither accessible to those affected, nor readily capable of interpretation, save by specialists. The case for reform has been recognised for many years. In July 2000, DETR reported that the law was an, “unwieldy and lumbering preacher”’, and that, sir, still remains the position today. Because, whilst there has been some law reform in this field, it has been piecemeal, giving effect a particular small parts of those Law Commission report. And in reality, very little has changed.

34. What we raise before the Committee in our submissions in evidence, are issues where it has been recognised, for many years, that change is needed, but where it is simply not happened, and this is the opportunity, particular where HS2 is going to have the effects that it will have, for this Committee to ensure that the Secretary of State here, does what has been proposed for many years.

35. Now, following the Law Commission report in December 2005, we had a ministerial response to that, and what was said in the written statement by the minister at the time, was that, ‘Finding legislative time for implementing the Law Commission’s proposals is not a practical proposition for the foreseeable future’. That’s the position. The only reason that was given by Government at the time for not implementing the Law Commission’s report was lack of Parliamentary time, and that has remained the position. For example, in 2009, January 2009, Hazel Blears, when she was the Secretary of State, said that she had recently responded to a letter from the Law Commission, which again, seeks primary legislation. All I can say is that there are clearly other priorities at the moment for primary legislation.

36. So, that, sir, is where the programme of reform left itself when we had the change of Government in 2010, but the commitment to reforming the law has lived on. We are still in a situation where the Government is committed to reforming the law. So, for example, in a written answer, Nick Boles, when he was the relevant minister, in April 2013, and we’ve got a copy of this that I can put up on screen for the Committee; if I can ask please for Exhibit A241 to be put up, and it’s the penultimate paragraph of A241, where the minister says, ‘We do recognise some of the problems highlighted by the report, such as advance payment and access to an easier form of dispute resolution, which we believe can be addressed through our current work on guidance and regulations’, and you’ll see there, sir, that he was responding to references to the CLA’s Fair Play Report, but also submissions made by the compulsory purchase association, who I will mention again later. And referring to it in positive terms, so the Government recognises still that these problems remain.

[1] ONS Social Trends: Housing – ST41

[2] High Speed Rail (London – West Midlands) Bill Select Committee, First Special Report of Session 2015-16, published 17 December 2015.

[3] DfT Report on the Performance of the Need to Sell Scheme – Early Trends, dated November 2015

[4] Promoter's Response to the Select Committee's First Special Report of Session 2015-16, February 2016.

[5] Part of suite of Lloyds Banking Group house price calculation tools, available here.

[6] Full title: House of Commons High Speed Rail Committee on the HIGH SPEED RAIL (LONDON – WEST MIDLANDS) BILL