John Whitehouse

Retired County Councillor for Kenilworth Abbey Division Learn more

My response to the consultation on the HS2 draft environmental statement

by John Whitehouse on 11 July, 2013


This response to the HS2 Draft Environmental Statement is made in a personal capacity. I do not require the response to be treated as confidential.

I have been consulted on, and support fully, the comprehensive response issued by Warwickshire County Council.

As the elected member for the Kenilworth Abbey division of Warwickshire County Council, I wish to focus on three key issues in my personal response:

  • The devastating impact of the current HS2 proposals on the village of Burton Green, especially during the construction phase of the project.
  • HS2’s failure to understand the local and regional importance of the Kenilworth Greenway and Connect2 Kenilworth walking and cycling routes, or to make adequate provision to sustain them during the construction phase and on an on-going basis.
  • The threat to the town of Kenilworth, and in particular its many independent traders, during the construction phase of the project.

In addition, I shall make specific, referenced comments and responses on the draft Environmental Statement documents.


Burton Green

The village of Burton Green, on the northern edge of my electoral division, is arguably the community (outside London) worst affected by the current HS2 proposals over the whole of the Phase 1 route. This is especially the case during the construction phase of the project, when the village would be cut in two for a period of years. The draft document makes several references to “significant adverse effects on the community of Burton Green”.

The draft ES recognises that a bored tunnel under Burton Green would “mitigate much of the construction disturbance and community severance immediately within the village …. It would also decrease the visual and noise impacts during operation.” It is therefore unacceptable that the draft ES dismisses this alternative to the proposed ‘cut and cover’ tunnel without presenting the evidence on which HS2 Ltd based this decision.

It was a clear commitment by HS2 Ltd at the Burton Green Bilateral meeting on 22nd April 2013 that the full “sift” information would be released as soon as possible.  I have chased this information twice in order to inform my response to the draft ES, but HS2 Ltd has failed to provide it. This means one of two things:-


  • Either:  HS2 Ltd has taken the decision to reject all community proposals without completing the full sift evaluation on all of them;
  • Or:  The full sift evaluations have been completed, but HS2 Ltd did not honouring its commitment to release the information in a timely fashion.

HS2 Ltd has made an unquantified value judgement in the draft ES in balancing environmental impact reductions with increased costs, so the scale of those cost differences is highly relevant to the responses being made.

It is my strong conviction that the bored tunnel option remains the only acceptable mitigation option for Burton Green.


Kenilworth Greenway and Connect2 Kenilworth walking and cycling routes

While the draft Environmental Statement is an improvement on earlier HS2 Ltd documents which failed to recognise the existence of the Kenilworth Greenway and Connect2 Kenilworth walking and cycling routes, references to it are inconsistent throughout the ES documentation.

Both routes are of local and regional importance, and are major community assets. The draft ES proposes the closure of both routes during the construction phase for extended periods, without any suitable temporary diversion routes having yet been identified. It is essential that both routes can be kept open throughout the construction phase.

The realignment of Canley Brook will require a permanent diversion of the Connect2 Kenilworth route. It is important that this minimises the additional travel distance between the Kenilworth Greenway and the university campus, and does not introduce adverse gradients.

The permanent diversion of the Kenilworth Greenway, to run alongside the HS2 route north of Burton Green, is not acceptable. The current route is both for walking & cycling and for horse-riders, and is an attractive, scenic path with good tree cover. A permanent diversion route needs to be physically separated from the HS2 line, allowing the re-creation of its scenic aspect and providing the space for effective sound mitigation measures.


Construction Phase Impact on Kenilworth

The construction phase of the project will have a significant impact on the town of Kenilworth, affecting its residents, its commercial traders and its visitor economy. All of the major and minor routes linking the town to the north west, north and north east will be subject to partial or complete closure for extended periods. Many residents of the nearby city of Coventry currently visit Kenilworth regularly for shopping and recreational/leisure reasons, and are major contributors to the local economy and the vibrancy of the town.

It is vital that the planning of road closures and diversions of individual roads is not done in isolation, but takes full account of the cumulative impact on the town.


Volume 1: Introduction to the Draft Environmental Statement

Section/para. Response
2.7.1 It is not correct to state that HS2 Ltd has sought to reduce adverse local impacts “as far as is reasonably practicable”. Local community proposals for improved mitigation have been accepted as practicable but rejected on unquantified cost grounds.
3.4.19 The “former rail corridor” is in fact the Kenilworth Greenway, referred to extensively in Volume 2: Community Forum Area Report 18. It would be helpful if this important sustainable transport route and wildlife corridor were referred to consistently in all HS2 Ltd documentation.
4.3 The failure to assess any cumulative effects of the scheme in the draft ES is a serious omission, particularly localised cumulative effects involving more than one environmental topic.


Volume 2: Community Forum Area Report 18

Section/para. Response
2.1.4 The Kenilworth Greenway should have been mentioned in this summary of land uses within the area.
2.2.4 The “dismantled Kenilworth to Balsall rail line” should be referred to as the Kenilworth Greenway for consistency throughout the draft ES.
2.2.16  The “dismantled Kenilworth to Balsall rail line” should be referred to as the Kenilworth Greenway for consistency throughout the draft ES.
2.5.4 The importance to the local community of the Kenilworth Greenway should have been listed here.
2.6.14 An unquantified value judgement has been made here, without HS2 Ltd presenting any evidence to support it. What would be the construction cost of Option D compared with Option B? On what basis has the admitted “”significant adverse effects on the community of Burton Green” (paras 5.5.5 and 5.5.9) been evaluated and balanced against the extra cost of a bored tunnel?
2.7.3 What does this statement mean? Will the further community proposals be evaluated, and if so to what timescale?
5.4.19 There is also an access point to the Kenilworth Greenway for horse riders from Hodgetts Lane, Burton Green.
5.5.9 This paragraph presents an accurate summary of the huge impact on the community of Burton Green of the current cut and cover tunnel proposal, and a powerful argument as to why a bored tunnel alternative should be selected instead.
5.5.13 The village hall in Burton Green is the heart of the local community, in daily use by a very wide range of community groups. The draft ES presents no acceptable solution to how this facility could be replaced during an extended period of closure. It is essential that a solution is found.
5.5.15 Disruption to access to the primary school and nurseries must be considered not only in terms of motorised travel, but in terms of walking and cycling as well.
5.5.20 It would be unacceptable to close the Connect2 Kenilworth route for a 6-12 month period without the provision of a suitable temporary diversion route.
5.5.21 The Kenilworth Greenway is not only important to Burton Green residents, but to residents of Kenilworth, Berkswell & Balsall Common and the surrounding areas. It is essential that a suitable temporary diversion route be provided during any period of closure.
9.4.2 The “well wooded disused railway embankment between Kenilworth & Balsall Common” is yet another, and inaccurate, description of the Kenilworth Greenway.
12.4.6 The survey data for both the Kenilworth Greenway and the Connect2 Kenilworth route is out of date, and seriously understates the usages of both of these very popular paths.


Volume 2: Community Forum Area Report 23

Section/para. Response
2.2.6 The Kenilworth Greenway is planned to be used as a construction route transporting materials and waste arisings. Will this route extend into the area of the Stoneleigh, Kenilworth & Burton Green Community Forum? There is no mention of this in Report No 18.


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