Putting EIA on the right track

26th August 2015


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IEMA

Paul Suff learns about the challenges faced by practitioners assessing the impacts of the planned high-speed rail link

At about 50,000 pages, the environmental statement detailing the outcome of the environmental impact assessment (EIA) for phase one of the proposed high-speed rail link (HS2) between London and Birmingham is one of the largest produced in the UK.

But, as Paul Johnson, director of environmental consulting at Arup and one of the EIA experts who had overall responsibility for managing the assessment, says: "HS2 is simply bigger than any other infrastructure project. At 225km, it is more than double the length of HS1 [London to the Channel Tunnel]. That doesn't mean you write twice as much, but the statement has to be a certain size because it has to contain a lot of information. There is also a legal requirement that, on a development of such scale, the EIA reports every significant environmental effect."

In his opinion, the environmental statement is a proportionate document and, because of the way it is structured, it is also accessible. Three of its five volumes include: area reports for each of the 26 community forum areas established by HS2 Ltd, the public company created to deliver the project; a report on route-wide effects; and detailed information for each of 14 environmental topics assessed. It is supported by a code of construction practice, health and equality impact assessments, a transport assessment and a sustainability statement.

The direction of the environmental statement was the responsibility of the environmental team in the technical directorate at HS2 Ltd. This was led by environment and planning director Peter Miller, supported by the route-wide environment manager Christian Bonard, from the company's development partner, CH2M. Building on the strategic environmental work undertaken by HS2 Ltd in 2010-11 for its appraisal of sustainability, initial work on the EIA started in early 2012 and the draft statement was published online for consultation on 16 May 2013. The main environmental statement was submitted on 25 November 2013. Since submission, work has continued to refine the design and two "additional provision" environmental statements were published in September 2014 and July 2015.

Although the HS2 EIA was similar to that for assessments of other nationally important infrastructure projects, its high-profile, scale and consenting mechanism gave rise to some unique challenges.

A hybrid process

The government has opted to secure consent for HS2 through a hybrid bill rather than one of the other legislative mechanisms for approving new infrastructure projects, such as a development consent order (DCO) or orders under the Transport and Works Act. A similar hybrid approach was used for HS1 and Crossrail, the east-west London link. It means the determining authority is parliament, which has implications for the EIA. The environmental statement accompanies the bill.

The EIA must comply with EU and domestic legislation, and, like other assessments, statutory bodies and the public have to be given an opportunity to scrutinise and comment on the environmental statement. The hybrid bill process also introduces a "petitioning period", which is managed by parliament and its representatives. Individuals, groups of people and organisations that can demonstrate they are directly and specifically affected by the project can oppose any aspect of the bill, although not the principle of the project. These so-called "petitions" are considered by the House of Commons and House of Lords select committees, which have the power to change the bill if they agree with the petitioners' objections. The HS2 consultation and petitioning period for the main environmental statement ran from 25 November 2013 to 27 February 2014.

Stuart Coventry, director of planning and environment at AECOM (formerly URS), supervised the overall EIA process with Johnson. Coventry points out that parliamentary consent through a hybrid bill does not formally impose the same level of engagement with stakeholders as is demanded under a DCO for a nationally significant infrastructure, for example. "However, we took the decision to follow the same engagement procedures as a DCO," he says. "We didn't want it to be any different. Public engagement was a crucial part of what we did."

HS2 Ltd established 26 community forums across five regional areas, each covering about 10km of the proposed track. The company describes the forums as community engagement to discuss local design and environmental issues. The environmental statement includes a report on each forum area. "This was to ensure someone would have read only what was relevant to them without having wade through the whole statement. That was different on this project," says Coventry.

He explains that careful thought was given to where one area stops and another starts: "We wanted to keep to a minimum the number of people that would have to look at two reports. I think that is something we would repeat." Johnson agrees. "On a linear project of the scale of HS2, you need to focus on bite-size chunks of information. That makes it more accessible," he says.

The teams of EIA consultants (EIAC) were spread across the five areas for contractual reasons. Several environmental and engineering consultancies, either on their own or as part of a consortium, won EIA contracts (see panel, below). Dividing the contracts among some of the UK's biggest consultancies was an acknowledgment that not all the technical skills and best people in rail infrastructure are in one company. "Because of the scale of the project, no one firm could deliver the numbers of highly experienced people across the range of skills required," says Johnson.

In addition to providing oversight of all environment work between London and Birmingham, Johnson and Coventry were tasked with establishing the environment standards and scope, and the methodology for the assessment. "We put in place all the programmes and management processes to enable the EIA consultants to do their work," says Johnson. "We established the ways for collecting and processing baseline data to ensure the EIAC teams weren't using slightly different methodologies. So, for example, the HS2 team agreed with Natural England how to assess bats across the entire route."

In a departure from normal practice, the draft scope and methodology report was published for public consultation in autumn 2012. Johnson says only minor amendments were necessary after receiving feedback. "This was because we'd already discussed it with statutory bodies like the Environment Agency and English Heritage (now Historic England)," he says. "The professional institutes also set standards and publish documents on how to carry out impact assessments, so you ensure your approach complies with the relevant guidance."

Common way of working

Adopting a common approach across the project for the types of surveys and other technical information required to assess effectively the potential environmental impacts was important for writing the environmental statement. "The teams would submit their EIA reports for us to review," says Johnson. "We had to turn those into one consistent document. Even though the submissions would differ slightly in terms of writing style, the fact that they had followed the same methodology and templates helped us to create a relatively seamless statement."

Coventry says settling on consistent outcomes was important. "We were focused on getting the right mitigation answers in each locality, but we also had to ensure we reached common solutions where the same problems arose. We spent a lot of time considering those answers and the descriptions of them."

Johnson agrees: "A solution suggested by a team in one area might not be the same as that put forward in another. There might be very good reasons for that - maybe the areas differ or the issue is not quite the same - but we had to be fair and consistent and apply similar levels of mitigation across the project."

Noise was one topic examined locally and across the route. The EIAC teams looked at construction noise effects on communities and the central overview team led by Johnson and Coventry examined operational noise for when trains start running. "This is so we can design the track and barriers to reduce noise impacts," says Johnson. Climate impacts and greenhouse gas emissions were also assessed across the planned 225km line.

Filling in the gaps

The next step after agreeing the scope and methodology report was to produce a draft environmental statement. However, some of the environmental impact consultants encountered problems accessing sites. This posed a major challenge. "There is considerable local opposition to HS2 and a lot of people did not want to have consultants on their land gathering information," says Johnson. "We had a considerable amount of information for some areas and not very much for others - and, in some locations, little hope of getting more. That's not unusual. It's rare to have all the information you need and you often have to assume some things. Nonetheless, we had to make a decision on how to deal with this on HS2."

The answer was to construct a "reasonable worse case" scenario in the areas where information was scarce. This was acknowledged in a letter from HS2 Ltd to Joan Walley MP, who was then chair of the environmental audit committee, on 29 October 2014. HS2 Ltd wrote: "The assessment was based on known, reliable sources of information, such as from Environmental Resource Centres, and, where practicable and where access to land was made available by third parties, appropriate surveys on the ground. Where access was not available the assessment was based on a precautionary approach, which was developed using existing data, to present a reasonable worst case of the likely significant environmental effects."

Coventry describes it as an exercise in filling in the gaps. "We started with desk-based research, using information from organisations, such as the wildlife trusts, extrapolating from what we did know about one area to another. We might know a lot about a similar piece of habitat a few miles away and we took that information and developed a reasonable worse case baseline for the one where we do not have enough data."

Johnson explains that aerial and satellite pictures were valuable: "We would assume species were present. If the pictures showed a pond, we'd assume it contained great crested newts. If there were large trees or suitable woodland, we'd assume bats were present. We wrote the environmental statement and designed the potential mitigation on the basis of those assumptions."

This approach was subsequently proven to be sound in many cases. After the draft statement was published, consultants did obtain access to some of the areas that had previously been out of bounds and carried out ecological surveys. "We made a few discoveries, but in most cases they confirmed our assumptions," says Coventry.

Johnson says access also improved in some areas, as it became increasingly likely that the project would get the green light. He also points out that the extent of access required was sometimes a factor in getting permission from the landowner: "Ecological surveys to monitor bats, for example, require multiple visits, whereas others may require several specialists to attend together, but only on one occasion."

He confirms that some assessment work continues. "Where there are protected species, such as bats, we need to record their movements and population numbers over time. New information on ancient woodland characteristics has also been collected. The updates are necessary to refine our mitigation plans."

The central team managing the EIA received around 21,000 comments on the draft environmental statement and some 22,000 comments on the main environmental statement. These all had to be examined, evaluated and considered. "We did discover some additional information, which was helpful," says Coventry.

Tried and trusted

Johnson says the environmentalists working on HS2 have followed tried and trusted techniques to assess the project's environmental effects. Irrespective of its scale, he says the objective of the HS2 EIA is the same as for any assessment: "You have to produce compliant documents." He noted that legal advisers were on hand to confirm adherence to relevant environmental legislation and parliamentary procedures.

Coventry explains that he or Johnson had to sign off every document submitted by the EIA consultants and that a technical specialist "peer" review mechanism was established to ensure the correct approach was taken at all times. "On every occasion, we challenged the EIA teams to look at what they were doing in terms of compliance and using the right tools and processes." HS2 Ltd also has its own team of EIA managers and specialists. "They would check and challenge what we produced," he says.

Coventry believes that level of integration between the environment professionals and the engineers designing the HS2 route has been unprecedented. "There has been a willingness at the heart of the engineering and environment interface to get it right," he says. "In a way, that reflects a natural evolution in which designers have become more familiar with environmental issues and environmentalists have greater understanding about design. That integration has reached a new high on this project." An example is the re-use of surplus excavated materials from the tunnelling and cuttings that will be used to blend the railway into the landscape, restore agricultural land and help mitigate noise.

Ultimately, the environmental statement is a working document, says Johnson: "All the environmental mitigation and controls in the statement have to be implemented. The deemed planning consent granted by the legislation [when the bill becomes an Act] will guarantee that what is in the statement is taken forward. The provisions are like planning conditions in other schemes and cannot be ignored by the contractors."

Construction work on HS2 should begin in 2017. The first trains are due to start running on phase one of the line in 2026.


In praise of EIA

"Environmental considerations go to the heart of the HS2 project. The professionalism demonstrated by our consultants and our staff through our environmental assessment work has enabled the government to select a route and parliament to adopt the principle of new high-capacity, high-speed rail for the country. It's important to understand EIA is not static - the wide-ranging documents present evidence, the public participation enables those affected to have their say and, through parliament's select committees, the route is being scrutinised and changes made. The environmental statement sets a benchmark from which future improvements are encouraged through design and construction to further benefit local people and the natural environment. Our continued commitment to take practical steps and seek improvements will challenge our supply chain as we deliver this next generation of sustainable transport.''

Peter Miller, environment and planning director HS2 Ltd


Scope of the HS2 EIA

  • Agriculture, forestry and soils.
  • Air quality.
  • Climate.
  • Community.
  • Cultural heritage.
  • Ecology.
  • Electromagnetic interference.
  • Land quality.
  • Landscape and visual assessment.
  • Socio-economics.
  • Sound, noise and vibration.
  • Traffic and transport.
  • Waste and material resources.
  • Water resources and flood risk assessment.

The EIA team

The environmental assessment work for phase one of HS2, from London to Birmingham, was split into geographical "packages" under four contracts:

  • West Midlands: covering Birmingham and Solihull - Arup and AECOM.
  • Rural north: covering Warwickshire and Staffordshire - Atkins.
  • Rural south: covering Buckinghamshire, Hertfordshire, Oxfordshire and Northamptonshire - ERM, Temple Group and Mott MacDonald consortium.
  • London metropolitan and Euston: from Euston to the edge of London and M25 - ERM, Temple Group and Mott MacDonald consortium.

Traffic assessments were provided by the area engineering consultants: Arup (West Midlands and Euston), Atkins (rural south), Capita (rural north) and Mott MacDonald (London metropolitan).

Arup and AECOM (formerly URS) also provided environmental overview services for phase one, which involved providing technical leadership and coordinating the work of the EIA consultants as well as delivering compliant assessment documents, including the project's environmental statement.

Direction of all environmental work on phase one, culminating in the main environmental statement, was led by the technical directorate at HS2 Ltd supported by its development partner, CH2M.


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