Barrington Parish Council Response to EWR 2nd Non-Statutory Consultation “Making Meaningful Connections” June 2021
Introduction
Barrington Parish Council (BPC) is responding to the invitation to share our comments on the assessment made by EWR that their preferred route into Cambridge from the south is the correct decision as outlined from Question 1 of the consultation questionnaire:
Please share your view Because EWR alignments closer to north Cambridge are now being considered, we have looked again at whether we were right to have favoured Route Option E and approaching Cambridge from the south as we confirmed after our last consultation. In particular, we have reviewed our previous assessment that concluded approaching from the south was the better option taking account of a Cambourne North Station outside of Route E to see if we would have made a different decision. We consider that the advantages of approaching Cambridge from the south continue to support this conclusion and that a number of challenges remain for a northern approach even with a Cambourne North station. We’d welcome your comments on our assessment.
BPC wishes to make specific comments about the proposed southern alignment and some overall general comments concerning EWR’s approach to assessment and to consultation:
- General Comments about EWR’s Assessment and Consultation Process
- Due Process.
The very question above itself sets out the major difficulty with EWR’s consultation: “…we have reviewed our previous assessment that concluded approaching from the south was the better option…”
In other words – we have had a look, but we are sticking to our decision – but we are not going to provide the evidence. BPC regards this lack of transparency and accountability as totally unacceptable
The rail regulator, the Office for Rail and Road (ORR) holds Network Rail to account over its business plans. Part of that holding to account is in relation to the four tests of Inclusivity, Effectiveness, Good Governance and Transparency, of its stakeholder engagement: https://www.orr.gov.uk/sites/default/files/2020-08/annual-assessment-of-network-rail-stakeholder-engagement-2019-20.pdf
It is clear that EWR’s “non-statutory consultation process” fails all four of these key tests and were EWR to be accountable to the rail regulator in relation to this exercise, it would be held in breach of its licence to operate.
- Inclusivity
Specifically, although Route Option E of the last consultation in 2019 was favoured by EWR over the other options on the table, EWR did not include an option into the north of Cambridge. EWR is therefore unable to say that the southern option is the preferred option – only that it was the preferred option of those that EWR chose to display. BPC has received multiple negative comments from residents about this lack of choice between north and south.
It is becoming clear that a northern route into Cambridge via a station to the north of Cambourne is an expression of the will of a considerable portion of the local population, and that the lack of inclusion of this route at the last consultation was a serious misjudgement. Indeed, it was a fatal omission that a “review” by EWR itself cannot redress.
- Good Governance: Environmental Impacts and the Evidential Basis
There are several significant procedural errors and omissions of evidence that need to be addressed before EWR, let alone BPC can give a measured judgement as to which route is supportable.
There is insufficient information about the difference that would arise from the impact on the environment on both northern and southern options. A full, and independently carried out Environmental Impact Assessment (EIA) should be commissioned for both routes.
South Cambridgeshire District Council (SCDC) has adopted a Doubling Nature Strategy which BPC fully endorses. We note too that the Oxford-Cambridge Arc Spatial Framework will take a “natural capital approach” to inform planning and decision-making. It is not unreasonable, therefore, to expect that EWR should be obliged to follow these precepts and that the results of an independent EIA is essential to underpin the final choice of route.
- Transparency
BPC believes that there needs to be full transparency concerning the business case, and the growth projections both commercially and in terms of population / consumer growth. We have serious misgivings about the viability of this railway if it is to rely on express passenger traffic alone and not commuter traffic or freight traffic. The pandemic seems to have produced a paradigm shift in the way that much of the commuting population will use the railway. The effect on ticket revenue, and hence the business case requires fuller explanation. If the business case is reliant upon passenger growth related to new housing developments – not yet approved – along the route, that needs to be made absolutely clear.
- Effectiveness
BPC believes it was a serious strategic mistake not to take into consideration any freight traffic, or freight and passenger traffic originating from Ipswich and Norwich, into the EWR’s terms of reference. The effectiveness of EWR’s analysis is seriously undermined by this omission.
This failure could have serious consequences in the evaluation of the suitability of northern and southern approaches as it could put significant budgetary constraints on the choice of route which would compromise the quality of the design of both the alignment itself and associated infrastructure. It seems to BPC to be a classic case of a failure of joined-up thinking when compared with the vision of the OxCam Arc with its “infrastructure-first approach to development.”
- Specific Comments about the Southern Alignment
BPC contends that there are a number of severe challenges to the southern route which would affect Barrington directly and which need to be addressed. The evidence basis upon which EWR’s review of the southern route was undertaken is entirely unclear and several issues that are clear to BPC need to be fully addressed prior to any further decisions by EWR being taken.
- Background:
The village of Barrington lies between a long low hill (Chapel Hill) separating it from the villages of Haslingfield, Harlton and Orwell to the north, and the flood plain of the river Rhee (as the Cam is called at this point). The hill is a prominent feature in a flat landscape and of great local significance to the Cambridge community. A glance at a map will show that the village can be accessed by two roads in a southern direction and two roads in a northern direction.
Barrington has one of the largest village greens in the country (22 acres) and the whole of the centre of the village is a Conservation Area due to the beauty of the Green and the arrangement of houses around it. https://www.cambridge-news.co.uk/news/local-news/gallery/barrington-cambridgeshire-village-one-longest-20745772
There are over twenty thatched cottages intermingled with others of more modern aspect. The whole area projects an aura of beauty, peace and tranquility which the Parish Council makes great efforts to preserve, recognising its value both to the residents of the village and the visitors who are attracted to it as a place for recreation and relaxation.
Chapel Hill is the site of a major and significant natural resource of limestone with significant archeological and historic fossil findings dating back to the iron age are on display at the Sedgwick Museum in Cambridge.
- The impact of the proposed rail alignment (Block E) on village access.
BPC observes that, of all the Blocks denoted along the proposed alignment, the only block to have no zone of uncertainty is Block E. This is interpreted to mean there is no possibility of negotiation for a change in the alignment in the block that affects Barrington the most.
Running from Harlton through to Harston, the alignment cuts through Chapel Hill to a depth of up to 12m – effectively severing one of Barrington’s historic access routes to the north during the construction phase.
Given the location of the village on the edge of the flood plain, during the winter months the access routes into Barrington from Foxton and from Shepreth are often flooded and impassable for days at a time. In exceptional years the road from Harston to Haslingfield is also impassable for days at a time. Variability in extreme events from climate change will only exacerbate this danger.
The consequence of this would be that if the road to Haslingfield is compromised, the road to Orwell and thus to the A603 would be the only means of access to and egress from the village. As the A603 is already heavily congested at important times of the day, the detrimental effect upon Barrington is undeniable. It will impose a constraint on access for residents of Barrington both for the general conduct of their lives and for the emergency services: it would effectively render them prisoners if any circumstance were to block free access to the outside world via this route.
Haslingfield road is also the site of a major housing development of 220 new units that will need to exit the village via Haslingfield. Cutting them off from this route will force them all through the already over-used roads in the historic Conservation Area..
For these reasons it is imperative for the residents that the Chapel Hill road from Haslingfield to Barrington is never blocked. Severing the connection between Barrington and Cambridge via Chapel Hill is totally unacceptable under all circumstances.
- The Need for Tunnelling
BPC therefore insists that, instead of a cutting through Chapel Hill, a tunnel is created. It seems sacrilegious to us to cut through a site of an ancient chapel revered by previous generations as the cult of the Lady of White Hill without at least some nod to the genius loci invested in it when there is a reasonable alternative.
BPC also asserts that the whole line from Chapel Hill to Shepreth Junction should be built below the surface and that the alignment should cross the river at Harston and the A10 south of Harston underground – i.e., via tunnelling.
A major consideration is the prospect of 24/7 freight movements. Apart from the unacceptable visual effect upon a flat and open landscape in this area, the residents of Barrington will be vulnerable to noise disturbance at all times of the day and night if the line crosses the A10 above ground level. The residents of Glebe Road, Barrington, and Barrington Road, Foxton will be particularly harmed as the alignment rises to cross the A10 south of Harston.
- Landscape and Visual Impact
Barrington village is surrounded by highly productive agricultural land in the Green Belt, as are all the villages directly on the proposed southern alignment.
The irrevocable loss of this land along the route and its potential to generate food and to contribute to the local ecosystem cannot be overestimated. Any form of mitigation is to be encouraged but the most effective would be to place the track below ground level.
BPC vigorously supports any proposal to lay the track in a trench along the whole of Blocks E and F thereby saving as much land as possible and the minimisation of visual blight as possible. Tunnelling between the entrance to Chapel Hill to the grade separated junction with WAML is essential.
Notwithstanding the need for a fully independent EIA as emphasised above, the business case comparison between the northern and southern routes must take into account these essential mitigation measures to protect the residents and historic environment of Barrington.
- Overall Conclusions
- BPC rejects entirely any proposals to build the railway connection into Cambridge at the lowest cost regardless of the direct and indirect impacts during both construction and operation.
- BPC insists that a full, transparent and independent comparative analysis of both northern and southern routes into Cambridge is undertaken and does not accept any “review” by EWR without clear access to the evidence base and the methodology employed.
- None of the villages on the southern route East of Cambourne derive any direct benefit whatsoever from the railway. EWR should therefore design as much of the alignment as possible in a trench and, instead of a cutting through Chapel Hill, should tunnel the alignment through the hill and as far as possible. These mitigation measures should be included in the business case when considering a comparative analysis between the northern and southern routes into Cambridge.
- Finally, BPC believes that EWR’s approach to its “non-statutory consultation” on the route into Cambridge has not met the industry’s key tests of inclusiveness, effectiveness, good governance, or transparency. It will therefore consider how best to escalate its concerns unless the above issues are fully addressed by EWR.