Review of the HS2 Phase One Environmental Statement Carbon Impact Aspects

Transcription

1 Review of the HS2 Phase One Environmental Statement Carbon Impact Aspects Version - Final On behalf of the HS2 Action Alliance February 2014

2 HS2 Action Alliance i EXECUTIVE SUMMARY HS2AA has requested to review those parts of the HS2 Phase 1 environmental statement (ES) in respect of the HS2 project which relate to carbon footprint and energy supply, and in particular, the impacts associated with the construction and operation of the proposed HS2 rail project. The scope of work is based on three specific tasks as follows: Task 1: A review of the robustness of the methodologies and assumptions used in the carbon modelling in the ES; Task 2: A review of the assumptions on future energy mix informing the basis of the carbon emissions associated with the use of electrical energy as detailed in the ES; and Task 3: Consideration of the potential impact on the electricity grid of the additional electrical power load generated by the project. A high level review of two carbon impact reports prepared for the HS2 Phase 1 ES indicates that the assessment is based on appropriate calculations methods and that these are in line with industry standards. The reports identify the key parameters and sensitivities, however some of the key parameters include inherent uncertainties (and therefore should have further sensitivities assessed). In addition, other parameters (relating to offsets) are questionable, and in s opinion should be excluded from the carbon impact results. The key issues are summarised below: Decarbonising of Grid Electricity: The two grid emission factor profiles modelled assume aggressive decarbonisation of the national grid. Although decarbonisation of the grid will occur as a result of Government Energy policy and market interventions, the resultant speed and scale of the decarbonisation is uncertain. Decarbonisation of the national grid is outside the control of HS2. Mode shift air to HS2: The modal shift of passengers from domestic air travel to HS2 for journeys from the West Midlands to London, in particular for connecting international flights at Heathrow Airport is deemed unrealistic. It is recognised that Phase 2 (which may involve a direct link to Heathrow Airport) may offset some domestic flights; however the ES relates to Phase 1 only. Consulting Limited

3 HS2 Action Alliance ii Freight uptake and offsets: The carbon impact assessment includes assumptions regarding the benefits of shifting freight from the road network to the classic rail system (as passenger mode shifts from classic rail to HS2 releasing rail slots on the classic rail network). There is currently an under utilisation of the classic rail network for freight, and therefore some expansion of freight movements by rail could be accommodated on the existing classic network. The actual likelihood of freight modal shift from road to rail is uncertain (and outside the control of HS2) and therefore accounting for these benefits is disingenuous. The ES does not consider whether the routes used for rail freight are the same corridors as the West Coast Main Line, which is the primary line HS2 is designed to relieve. Tree planting: In certain strictly controlled scenarios, offsets associated with tree planting are allowable in Defra GHG reporting guidelines. However, the application of offsets is restricted and must only be applied ex-post, i.e. they can only be issued (and therefore accounted for) after the emissions reduction has taken place. It is anticipated that the tree planting will be along the line of the HS2 route (to mitigate visual and noise impacts and replace lost ancient woodland); as such it is unclear whether such a scheme would be able to achieve validation and verification, and thus truly be included as an offset against the significant carbon impacts of HS2. To represent the potential implications, a high level modification of the key parameters (grid decarbonisation assumption, offsets from tree planting and freight movement from road to classic rail) have been developed. The results of which indicate the total carbon impact of Phase 1 of HS2 could be in the order of 6,500,000 tco 2 e. This is over two and half times the current carbon impact estimates presented in the HS2 ES documentation. The carbon impact equates to carbon emissions from the energy use of 1.44 million UK households 1, equivalent of 5.4% of households in the UK 2. The review of energy policy and future energy mix has shown that the approach taken by HS2 is broadly in line with Government Policy and expectations. However, the UK Government recognises that there are uncertainties in predicting and subsequently delivering grid decarbonisation and subsequently incorporated sensitivity analyses into forward projections. Since these uncertainties have been recognised at Policy level it would 1 Energy use in the home accounts for around 4.5 tonnes per household. 2 There were 26.4 million households in the UK in

4 HS2 Action Alliance iii be appropriate for this to be carried through to the assessment of impacts for major infrastructure projects such as HS2. It is normal practice when conducting carbon assessments to undertake an assessment of uncertainties. It is noted that the energy required to operate HS2 is at a level that will have a significant impact on the UK s energy supply infrastructure. Phase 1 peak load is estimated to be 350MWe and the annual energy requirements, whilst representing only 0.4% of the total UK energy consumption, are equivalent to the energy requirements of a city the size of Birmingham. Electricity will be supplied at four strategic points along the route. Given the level of power requirement, it is inevitable that grid reinforcement (which could include additional pylons, uprating existing pylons, new or upgraded substations) will be required presenting additional disruption and environmental impact to communities along the route. Finally, an assessment has been carried out to compare the project energy requirements against typical characteristics for low carbon and renewable energy generation technologies. This assessment has shown that if the energy could be sourced from solar or wind that the land take requirements for energy generation would be some 10 times larger than the landtake for the HS2 route itself. However, these technologies are intermittent and not dependable and therefore unsuited to providing electricity to HS2. Biomass, an alternative more dependable source would result in a land area equivalent in size to London for the supply of domestically grown energy crops or for the more likely scenario the import of over 1 million tonnes of wood chip from North America, the primary source of most wood destined to energy generation in the UK currently. The import of this quantity of woodchip would have a significant associated carbon burden predicted to be in the order 500,000 tonnes CO 2 e annually or 30 million tonnes CO 2 e over the operational lifetime of HS2 (60 years). Given that the implications of energy supply to the HS2 project are so significant it would appear somewhat disingenuous to give this subject so little attention in the Environmental Statement.

5 HS2 Action Alliance iv TABLE OF CONTENTS 1 INTRODUCTION TASK 1: ROBUSTNESS OF THE METHODOLOGIES AND ASSUMPTIONS USED IN THE CARBON MODELLING TASK 2: ASSUMPTIONS ON FUTURE ENERGY MIX INFORMING THE BASIS OF THE CARBON EMISSIONS ASSOCIATED WITH THE USE OF ELECTRICAL ENERGY TASK 3: CONSIDERATION OF THE POTENTIAL IMPACT ON THE ELECTRICITY GRID OF THE ADDITIONAL ELECTRICAL POWER LOAD GENERATED BY THE PROJECT CONCLUSIONS APPENDIX 1: LIST OF DOCUMENTS APPENDIX 2: ELECTRICAL GRID IMPACT ESTIMATES BACKGROUND CALCULATIONS... 46

6 HS2 Action Alliance 1 1 INTRODUCTION (i) Instructions 1.1 On behalf of the HS2 Action Alliance (HS2AA), a review of the Environmental Statement (ES) for Phase 1 of HS2, that has been prepared and submitted by HS2 Limited, has been carried out by Consulting Limited (). 1.2 is one of the UK s leading consultants to the environmental sector and employs over 300 staff at 19 office locations in the UK and has overseas operations in the USA, Canada, South Africa, Ireland and Australasia. (ii) Scope of Work 1.3 HS2AA has requested to review those parts of the environmental statement (ES) in respect of the HS2 project which relate to carbon footprint, and in particular, the impacts associated with the construction and operation of the proposed HS2 project. 1.4 As agreed with HS2AA, given the timescales within which the consultation response to the ES has had to be prepared, the review of the carbon impact aspects of the application proposals and assessment of the adequacy environmental impact assessment which is reported in the ES has focussed on relatively high level issues. 1.5 The scope of work is based on three specific tasks as follows Task 1: A review of the robustness of the methodologies and assumptions used in the carbon modelling (Chapter 2); Task 2: A review of the assumptions on future energy mix informing the basis of the carbon emissions associated with the use of electrical energy (Chapter 3); Task 3: Consideration of the potential impact on the electricity grid of the additional electrical power load generated by the project (Chapter 4). 1.6 The scope of work has involved review of the following documents which are incorporated in the ES: Volume 3, Chapter 5 - Route Wide Effects;

7 HS2 Action Alliance 2 Volume 5 Technical Appendices - Summary carbon calculation outputs (CL ) Volume 5 Technical Appendices - Resilience to impacts from climatic conditions (CL ) 1.7 A full list of documents included within s review is presented in Appendix 1.

8 HS2 Action Alliance 3 2 TASK 1: ROBUSTNESS OF THE METHODOLOGIES AND ASSUMPTIONS USED IN THE CARBON MODELLING This chapter considers the following: Method of calculation and in particular compliance with industry reporting standards (refer Section i and ii). Operational impact assumptions and concurrence with other technical reports (for example traction energy modelling) (refer Section ii). Review and commentary on background and reference documents (refer Section ii). Relevance and applicability of carbon offset assumptions for example tree planting (refer Section iii). Level of uncertainty and sensitivities considered in the calculations (refer Section ii and iii). Summary of findings (refer Section iv). (i) Introduction 2.1 This chapter summarises a high level review of key documents relating to the estimated carbon impact of the HS2 scheme. The chapter considers the carbon impact results and the key assumptions applied. Furthermore, the chapter comments on the appropriateness of the assumptions and identifies, in s opinion, where additional sensitivities should be considered to demonstrate the impacts of the level of uncertainty involved in the calculations. 2.2 The HS2 carbon impact assessment (presented in the Hybrid Bill) considers Phase 1 development only (i.e. the route between London and the West Midlands). 2.3 The carbon impacts of Phase 2 could be significant with large stretches of tunnelling or cuttings necessary to accommodate the topography along the route. At this time, a carbon impact assessment of Phase 2 has not been undertaken due to uncertainties regarding route alignment. Thus, the HS2 scheme as a whole, and the cumulative Phase 1 and 2 carbon impacts have not been considered in the decision making process. 2.4 The Phase 1 carbon impact assessment is based on construction ( ) and operation for the period HS2 Ltd report that the construction carbon impacts will be in the range of 5,300,000 to 6,460,000 tonnes carbon dioxide

9 HS2 Action Alliance 4 equivalent (tco 2 e). This figure represents 1% of the UK s annual carbon footprint of 650 million tonnes carbon dioxide equivalent (tco 2 e) 3, although as shown in Table 1 in excess of 10% of the carbon emissions associated with household private motoring and 109% of the carbon emissions associated with current rail transport services. Table 1: HS2 comparison to UK Carbon Emissions HS2 constructi on emission estimate Total UK carbon footprint (including imports) Direct UK emissions Househo ld private motoring Rail Transport Services Emissions (mtonnes CO 2 e) % of HS2 construction emissions 1.0% 2.4% 10.7% 109.3% 2.5 The operational phase is estimated by HS2 Ltd to deliver a carbon impact of between -2,970,000 and -3,160,000 tco 2 e. Therefore the HS2 scheme is estimated to generate a net carbon impact of between 2,140,000 and 3,490,000 tco 2 e. (ii) Reports Considered 2.6 Due to time constraints, this assessment has focused on two HS2 carbon impact reports. A brief synopsis of each report is detailed below. Section iii and iv extract the key results and assumptions for detailed discussion. London West Midlands Environmental Statement. Volume 3. Route-wide effects. November Chapter 5 of the Route-wide effects report considers Climate impacts. The document provides a general introduction to greenhouse gas (GHG) emissions (different gases and their respective contribution to the total GHG emissions) and describes the key sources of emissions considered by the carbon model (the scope). The policy background to climate change and key targets is summarised, along with an 3 Accessed 17 February 2014

10 HS2 Action Alliance 5 assessment of where HS2 can influence its carbon impacts, and where other influences (such as Government policy and commercial factors) are controlling. The report presents the construction carbon impacts and provides some detail on the breakdown of emissions (by element and scope); summary results are presented for two sensitivity scenarios. The operational carbon impacts are considered, and two scenarios are documented (the scenarios consider differing grid emission factors and uptake of electric cars). 2.8 In presenting the total carbon impacts, the report illustrates a range rather than single value, which is good practice considering the level of uncertainty in the assumptions and analysis. However the presented results do not consider the worst-case construction impacts, and therefore the HS2 report could be considered to be under reporting the potential total carbon impacts. 2.9 The report benchmarks the results against other modes of transport and other sector carbon emissions and also provides an overview of the key assumptions In general, the report provides all the components expected from a carbon impact assessment report background policy, scope of assessment, assumptions, results, discussion and sensitivity analysis. Although has been unable to review the carbon model itself, the analysis is considered to be in broad compliance with industry standards and utilises data from published sources and industry recognised life cycle inventory databases. can see no reason why the carbon model could not be made available for public scrutiny and in a project of this significance would expect it to be so Further review of the assumptions and sensitivity assessments detailed in the Routewide effects report are discussed in section iv of this Chapter. London West Midlands Environmental Statement. Volume 5. Technical Appendices. Summary carbon calculation outputs (CL ) 2.12 The Summary carbon calculation outputs report provides the technical detail and more comprehensive description and review of the key carbon impact assessment assumptions behind the results presented in the Route-wide effects report The report presents the construction and operational carbon impact results and then considers the key inputs and the data sources for assumptions. The key inputs presented in the report are:

11 HS2 Action Alliance 6 electricity grid decarbonisation; emissions from production of steel; emissions from production of concrete; and penetration of electric vehicles and percentage of electric vehicle kilometres The report then presents a series of tables which outline: the carbon factors (and source of the carbon factor) used in the calculation of the HS2 carbon impact modelling; assumptions associated with material densities, worker commuting and transport distances, and; assumptions by sector and area The carbon factors are sourced from a variety of organisations including Defra/DECC, industry federations, academic institutions and life cycle assessment software. Therefore in the absence of undertaking a detailed review of each carbon value, it appears the data is fit for purpose The report also presents a table of known data gaps, which lists 27 partial or full data gaps relating to a number of sectors including construction, maintenance, operation and stations The report contains a reconciliation statement as the Appraisal of Sustainability (AoS) published in 2011 documented construction carbon impacts of 1,200,000 tco 2 e, and the Environmental Statement (published two years later) estimates the construction carbon impacts at 5,600,000 tco 2 e (central case). These figures show that carbon impacts for the HS2 scheme have increased 4.5 times between 2011 and The increase appears to result from more accurate and detailed analysis; since many areas of uncertainty still remain it is quite probable that the final impact will exceed the current forecasted figures.

12 HS2 Action Alliance 7 (iii) HS2 Ltd Estimated Carbon Impacts of the Scheme Construction Carbon Impact 2.18 The estimated carbon impacts of HS2 Phase 1 construction, as described in the Summary carbon calculation outputs report, is between 5,300,000 tco 2 e and 6,460,000 tco 2 e (stretch scenario and worst-case scenario respectively) The stretch scenario, which demonstrates the lowest carbon impact of the two scenarios, takes account of assumed improvements in the carbon footprint of concrete and steel production. However, these improvements are based on forward projections which, in turn are based on optimistic factors and subsequently, the ability to deliver such levels of emissions reduction is uncertain. The impacts of not meeting these emission reduction projections would be a significant additional carbon impact (than that currently reported) given the large quantities of concrete and steel which would be used in the construction of HS2. It is considered highly unlikely that the emissions savings for steel and concrete production assumed in the model could be delivered prior to proposed construction commencement in A summary table (Table 2) of the estimated carbon impacts of construction for the worst-case scenario is presented below. As discussed in more detail below the estimate contains a number of omissions; together with the inherent assumptions in a study of this kind Table 2 should only be seen as an estimate and in s opinion is unlikely to provide an accurate portrayal of the actual carbon impacts in a worst case scenario. The key sources of carbon impact are identified as tunnels, portals and dive-unders ; track ; and bridges and viaducts. Table 2: Construction Carbon Impacts - HS2 Ltd worst case scenario Element Total (tco 2 e) Earthworks 590,000 Construction and demolition waste 40,000 Land use, land use change and forestry 100,000 Bridges and viaducts 910,000

13 HS2 Action Alliance 8 Element Total (tco 2 e) Roads 170,000 Retaining walls, cuttings and embankments 310,000 Tunnels, portals and dive-unders 1,520,000 Tunnel boring machine 280,000 Stations and depots 710,000 Track 1,390,000 Rolling stock 230,000 Other 210,000 Total 6,460, Of concern, is the fact that the estimated carbon impact has increased from 1,200,000 tco 2 e (the Appraisal of Sustainability, 2011) to at least 5,300,000 tco 2 e and up to 6,460,000 tco 2 e in the Environmental Statement (2013). The significant (5 times) increase in carbon impact is accounted for by HS2 Ltd (Section 5 of the Summary carbon calculation outputs report) as being due to changes in scope, route changes and the level of HS2 design detail. Further analysis in Chapter 5 indicates that the significant proportion of the uplift is associated with the widening of the scope of the assessment although no further details are provided The Summary carbon calculation outputs report, which determines the worst case construction carbon impact to be 6,460,000 tco 2 e, clearly states that there are a number of omissions from the current carbon impact modelling. Some of the omissions are partial omissions and others are full omissions. In total, the report identifies 27 data gaps across 7 broad omission areas as identified below.

14 HS2 Action Alliance 9 Table 3: Carbon report data gaps and omissions Sector Data gap Extent of omission Construction Temporary haul roads, pilling crane platforms Partial Partial Construction Temporary roads/road widenings/ roundabouts Partial Construction Temporary compounds Partial Construction Drainage materials Partial Construction Precast concrete units / beams Partial Construction Steel bridge girders / beams Partial Construction Auto-transformer substation bases and access roads Partial Construction Railway material laydown areas Partial Construction Footpath/farm track diversions Partial Construction Road construction - hammer heads/turning circles Partial Construction Utility diversions Partial Construction Drainage ponds and access roads Partial Construction Tunnel Boring Machine related labour data including commuting Full Construction Tunnel fan manufacture, maintenance and transport Full Construction Rail track construction ground stability improvement works Full Construction Disturbance of businesses that may be displaced Full Construction Maintenance lay-bys Partial Maintenance Maintenance activities Partial Movements of excavated material Excavated material conveyor belt energy consumption Full Movements of excavated material Plant data for unloading and packing/setting of fill material Testing, commissioning and trial running of the Proposed Scheme Operation Full Rail track construction Rail weld energy consumption Full Stations Construction waste Partial Stations Retaining walls, bridges, drainage, external walls, bus depot, shafts, pilling, lifts, escalators, ticketing systems Partial Stations Fit-out and mechanical and electrical equipment (such as heating, ventilation and air conditioning and escalators) Full Stations Testing and commissioning Full Road alternative Culverts, underpasses, tunnels, petrol stations, commercial space, road maintenance Full Full

15 HS2 Action Alliance The extent and number of omissions clearly indicates the level of uncertainty associated with the carbon impact modelling and as such the current estimate of carbon emissions is likely to underestimate the overall impact of the construction activities Therefore the construction carbon impact values presented by HS2 Ltd in the ES should be seen as the lowest likely value should all industry emission improvements be delivered and current design data be accurate. The likelihood is that the carbon impact from the construction of HS2 will be greater than that currently predicted due to a number of issues including data omissions, changes to design as information on ground conditions is obtained (HS2 Ltd have recently issued a contract notice for ground investigation works 4 ), and the probability that industry savings relating to construction material carbon impact will fall short of the ambitious projections These issues are considered further in Section iv. Operational Carbon Impact 2.26 Table 4 below presents a summary of the Phase 1 operational carbon impacts for the two scenarios considered by HS2 Ltd in the ES. Scenario A is based on grid emission factors and electric car penetration projections from DECC/IAG and WebTAG; Scenario B is based on grid emissions factor and electric car penetration factors from the Committee on Climate Change (CoCC) The grid emission factor is the average emissions (measured in kgco 2 e) generated from the different electricity producing technologies (coal, combined cycle gas turbine (CCGT), nuclear, hydro, wind etc) to produce a kilowatt hour (kwh) of electricity on the national grid. The grid emissions factor is currently circa 0.5 kgco 2 e/kwh and is anticipated to reduce over time as coal power stations are closed and an increasing proportion of electricity is generated using CCGT, nuclear and renewables. 4 accessed January 2014

16 HS2 Action Alliance 11 Table 4: Operational Carbon Impacts HS2 Ltd Scenario A and B Scenario A (tco 2 e) Scenario B (tco 2 e) Train operation 1,980,000 1,040,000 Train maintenance 290, ,000 Station operation 530, ,000 Tunnel fans 5,000 3,000 Tree planting -500, ,000 Mode shift -3,200,000-2,340,000 Freight uptake of released capacity -2,070,000-2,070,000 Total -2,970,000-3,160, The individual components of the operational carbon impact are considered in Section iii. Total Carbon Impacts of the Scheme 2.29 The Route-wide effects report states that the total carbon impact of the HS2 scheme are in the range 2,140,000 tco 2 e to 2,620,000 tco 2 e. Therefore the HS2 scheme, even when taking account of the optimistic assumptions and inputs, will result in a significant carbon impact over the assessment period (construction and operation 2026 to 2085) The Route-wide effects report acknowledges that should the operational life time of the project (for the carbon impact assessment) be extended a further 60 years, the scheme will still result in a positive carbon impact (i.e. an environmental negative), or at best a small negative carbon impact (i.e. an environmental benefit). However, the application of more conservative assumptions (for example the worst case scenario for construction carbon impacts), would result in a definite positive carbon impact (environmental burden) for both the 60 year and 120 year operational periods (refer Table 5).

17 HS2 Action Alliance 12 Table 5: Total Carbon Impacts 60 and 120 Year Periods 60 year assessment period (tco 2 e) 120 year assessment period (tco 2 e) As reported (Section in Route-wide effects report) Upper Range (construction central and operational Scenario A) 2,620, ,000 Lower Range (construction stretch and operational Scenario B) 2,140, ,000 Application of construction worst case Upper Range (construction worst case and operational Scenario A) 3,490,000 1,230,000 Lower Range (construction worst case and operational Scenario B) 3,300,000 1,390, The Route-wide effects report presents the total carbon impact using the central scenario or the stretch scenario for construction carbon impacts. A more conservative approach would be to present the range upper range value based on the worst case scenario for construction emissions. Taking this approach, the HS2 scheme would generate an estimated carbon impact of between 2,140,000 tco 2 e (Construction stretch case and Operational scenario B) and 3,490,000 tco 2 e (Construction worst case and Operational scenario A) Construction carbon impacts (even when future ambitious emission reductions in the environmental impacts of steel and concrete manufacture are accounted for)

18 HS2 Action Alliance 13 outweigh the operational carbon impacts. Consequently, the HS2 scheme would result in a net increase in the carbon footprint for the UK As stated previously, the carbon impact assessment in the ES relates to Phase 1 of HS2 only, and therefore the development of Phase 2 is likely to develop further significant carbon impacts from the construction and operation activities. It is not clear why the Phase 2 impacts have not been presented in the ES however, as discussed previously the implication of doing so would be a substantial increase in the carbon impacts of the project In general, the carbon impact assessment presented in the ES recognises that there are some significant assumptions. A degree of sensitivity analysis has been undertaken on some of these factors, however consider that further sensitivity should be undertaken to provide a true worst case position The use of a 120 year timeline further compounds the uncertainty of the assessment since it is impossible to predict with any degree of certainty what the commercial and technological environment will be this far into the future. To put this in context it should be noted that 120 years ago the motor car was only just being introduced to the UK The following section considers the key components of the carbon impact, and comments on the assumptions and sensitivities applied. The review indicates that a number of the key assumptions and sensitivities could be viewed as optimistic, and therefore the true net carbon impact of the HS2 scheme is likely to be much greater than that currently stated in the ES reports. (iv) Review and commentary on carbon impact components 2.37 The construction carbon impacts (as summarised in Table 2) demonstrate that the construction of Phase 1 of the HS2 Scheme will generate considerable carbon impacts Table 2 shows that tunnelling and cutting works contribute significantly to the overall carbon impacts. Although the current HS2 carbon impact reports cover Phase 1 only, it is worth noting that the Phase 2 construction is likely to include significant stretches

19 HS2 Action Alliance 14 of tunnelling or cuttings; thus result in further significant carbon impacts and potentially a greater carbon impact than predicted for Phase The sensitivities assessed in the construction carbon impact demonstrate that anticipated efficiencies in steel and concrete manufacturing could help to reduce the construction carbon impacts. Reductions in concrete and steel manufacturing emissions are dependent on a number of factors which are outside the control of HS2 and other factors which are outside the control or influence of the steel and concrete manufacturing industries. Furthermore, it seems unlikely that the assumed manufacturing efficiencies, and hence lower carbon emissions will be implemented prior to proposed project commencement in In the absence of detailed design data, a considerable number of assumptions (including uplift factors) have been made on construction. Given time and information limitations s review does not consider whether the assumptions on construction quantities are sensible, or whether the likely construction process will result in greater impacts than the uplifts or quantities assumed at present Furthermore, the Summary carbon calculation outputs report identifies 17 known data gaps associated with the construction phase as shown below: Table 6: Carbon report data gaps and omissions for construction Sector Data gap Extent of omission Construction Temporary haul roads, pilling crane platforms Partial Partial Construction Temporary roads/road widenings/ roundabouts Partial Construction Temporary compounds Partial Construction Drainage materials Partial Construction Precast concrete units / beams Partial Construction Steel bridge girders / beams Partial Construction Auto-transformer substation bases and access roads Partial Construction Railway material laydown areas Partial Construction Footpath/farm track diversions Partial Construction Road construction - hammer heads/turning circles Partial Construction Utility diversions Partial Construction Drainage ponds and access roads Partial Construction Tunnel Boring Machine related labour data including commuting Full Construction Tunnel fan manufacture, maintenance and Full

20 HS2 Action Alliance 15 Construction Construction transport Rail track construction ground stability improvement works Disturbance of businesses that may be displaced Full Full 2.42 Some of the data gaps are partial, and some are full. Some data gaps such as Footpath/farm track diversions (Partial) are unlikely to have a significant additional carbon impact, however other data gaps may be more significant, such as Rail track construction ground stability improvement works (Full) Although these omissions have not been quantified, their existence and identification does indicate that the increase in construction carbon impacts from 1,200,000 tco 2 e (AoS) to a minimum of 5,300,000 tco 2 e (ES) are likely to rise further during the detailed design stage and actual construction period. As such, it would be prudent to utilise the worst case construction carbon impact scenario The operational carbon impacts from the ES (as presented in Table 4) are subdivided into 7 components. The most significant operational carbon impact is Train operation (i.e. electricity consumption for traction power). The positive carbon impacts are offset by negative carbon impacts (benefits), the most significant source being Mode shift and Freight uptake of released capacity. Each component of the operational carbon impact is considered below. Train Operation 2.45 The carbon impacts associated with Train operation are estimated to be between 1,040,000 tco 2 e (scenario B) and 1,980,000 tco 2 e (scenario A). The major element of the Train operation carbon impact is electricity consumed for traction power (estimated to be 350MWe peak for Phase 1) The carbon impact of the electricity consumption is highly sensitive to the assumed grid emission factor. The actual decarbonisation of the national grid against the assumed profiles used in Scenario A and B is therefore a critical factor Scenario A is based on grid emission factor profiles from DECC/IAG projections; this profile translates to a grid emissions factor of circa 0.19 kgco 2 e/kwh in 2026 (first year of HS2 operation) decreasing to circa 0.03 kgco 2 e/kwh in 2050 (DECC/IAG -

21 HS2 Action Alliance 16 rail specific profile). Scenario B is based on CoCC grid emission factor projections which translate to a grid emission factor of circa 0.15 kgco 2 e/kwh in 2026 decreasing to circa 0.01 kgco 2 e/kwh in The CoCC projections are based on decarbonising the grid by 70% from the current gird emission factor of circa 0.5 kgco 2 e/kwh to 0.15 kgco 2 e/kwh by the start of HS2 operations in 2026 and then further reducing the grid emission factor to near zero carbon emissions by Any failure to meet these ambitious projections, or delay in meeting the timescales will have a significant impact on the operational carbon impacts of HS2 Phase Given the inherent uncertainty in the decarbonisation of the grid emission factor, it is suggested that the ES would benefit from an alternative sensitivity Scenario C. The Scenario C would present a less ambitious decarbonisation profile Figure 1 below presents the grid emission decarbonisation profiles for Scenario A (red line) and B (blue line), and also presents a suggested alternative scenario (green line) whereby significant decarbonisation of the grid occurs between now and 2030 (a factor of 0.1 kgco 2 e/kwh is achieved) and then this value is straight lined from 2030 forward. Even this alternative sensitivity could be deemed to be overly optimistic to the year 2030 given the current grid emissions factor of circa 0.5 kgco 2 e/kwh. Figure 1: Grid Emission Factor Profiles

22 HS2 Action Alliance Without access to the carbon impact models, is unable to generate fully accurate results for this alternative scenario. However, a high level calculation has been undertaken from the above graph to estimate the carbon impact of applying the alternative sensitivity profile to Scenario A and B Train operation results. The average emission profile of each scenario has been compared to the alternative sensitivity profile to generate a ratio; this ratio is then applied to the Scenario A and B results. The resultant carbon impact for Scenario C is estimated in the range of 2,246,400 tco 2 e and 2,748,600 tco 2 e. Table 7: Train Operation Carbon Impacts Including Additional Sensitivity Train operation carbon impact (tco 2 e) Scenario A 1,980,000 Scenario B 1,040,000 Scenario C 2,246,000 2,748, The above analysis demonstrates that a, relatively small, change in the grid emission factor assumptions can have a significant impact on the carbon impact from the Train operation. Higher grid emission factors (than those modelled) for the early years of HS2 operation is arguably quite possible, and will have a considerable impact on the overall operational carbon emissions of the new line. Train Maintenance 2.53 Train maintenance activities are identified as including embedded emissions in replacement parts and energy consumption in routine activities (such as cleaning). No further breakdown of the Train maintenance carbon impacts are provided in the Route-wide effects report or the Summary carbon calculation outputs report, and therefore further assessment is difficult However, given that Train maintenance includes energy consumption, the same alternative sensitivity for the assumed grid emission factor can be modelled. Taking in to consideration the uncertainty regarding achieving such aggressive

23 HS2 Action Alliance 18 decarbonisation of the national grid, it is reasonable to assume that the Train maintenance impacts are currently under reported. Station Operation 2.55 Station operation carbon impacts are a further key component of the positive operational carbon impacts with an estimated carbon impact of between 420,000 tco 2 e (Scenario B) and 530,000 tco 2 e (Scenario A) As above, there is no further breakdown of the Station operation carbon impacts in the two reports considered; however it is anticipated that the majority of the carbon impact is associated with electricity use from the national grid. Thus, a further sensitivity using a more conservative decarbonisation of the grid emission factor (as discussed in Train operation) could be applied to the Station operation elements of the carbon model. Utilising the high level ratio calculated from Figure 1, Station operation carbon impacts increase to approximately 736,000 tco 2 e to 907,000 tco 2 e. Tunnel Fans 2.57 The carbon impact from Tunnel fans is relatively small in comparison to the other components of the operational carbon impact. However, as the carbon impacts will be almost wholly in relation to electricity use, the conservative decarbonisation grid emission factor described for the alternative scenario above should be considered The carbon impact of the Tunnel fan operation increases to approximately 6,500 to 7,000 tco 2 e when using the alternative sensitivity profile. Tree planting 2.59 In addition to the positive carbon impacts (i.e. environmental burdens) described above, a number of components included within the operational carbon impact total exhibit negative carbon impacts (i.e. a carbon benefit). Tree planting is the first component, and this accounts for -500,000 tco 2 e (applied to both Scenario A and B).

24 HS2 Action Alliance Defra Environmental Reporting Guidelines for the reporting of company GHG emissions 5 does allow the benefits (offset) of tree planting schemes to be included in the net carbon impact. However, offsets can only be included under strictly controlled circumstances that meet Defra s Good Quality criteria which are as follows: Additionality projects must demonstrate that they have produced a saving in carbon that would not have happened otherwise; Avoiding leakage the project must demonstrate that it has not caused an increase in carbon emissions elsewhere; Permanence if the project could be impermanent, (e.g. forestry projects are at risk of disease or fire) then this must be addressed by the project developer or offset provider; Validation and verification the project must receive independent verification. The verifier must be an accredited and recognised independent third party; Timing carbon credits should be ex-post, that it, they must only have been issued from the project after the emissions reduction has taken place; Avoiding double counting a registry must be used to register, track and permanently cancel credits to avoid double counting or double selling; and Transparency credits should be supported by publically-available information on a registry to set out the underlying projects, the quantification methodology applied, independent validation and verification procedures, project documentation, proof of credit ownership and date of retirement of credits Therefore, in order to apply offsets, it must be demonstrated that the saving in carbon would not have happened otherwise (tree planting could go ahead without HS2); that the project is permanent (forestry projects are at risk of disease and fire which could make the project impermanent); that the project can be verified (through Woodland 5 accessed January 2014

25 HS2 Action Alliance 20 Carbon Unit scheme) and that the timing is correct (credits can only be issued - and therefore offsets applied - after the emissions reduction has taken place) The inclusion of tree planting offsets within the HS2 operational carbon impact total is therefore questioned given that the tree planting could go ahead without HS2 development, the tree planting in question is assumed to be along the route of the HS2 line (to mitigate visual and noise issues) and therefore it is unclear whether the scheme could gain validation and verification under the Woodland Carbon Units scheme due to accessibility for assessment and verification audits. The tree planting offsets should also not be accounted for until the emissions reduction has taken place therefore they should not be included within the planning stages of the project. There is no mention of validation in the Environmental Statement In addition to the above, the HS2 project would involve the destruction of existing ancient woodland and therefore in part some of the fresh tree planning is replacing lost trees. The Woodland Trust s initial review of the ES 6 identifies 33 ancient woods threatened with loss or damage on Phase 1 alone and 43 sites in Phase 2 7. The Woodland Trust estimate a further 24 woodlands should also be classified as ancient If the offset is legitimate and meets Defra s strict requirements, the organisation should report gross carbon emissions and then apply the offset to generate a net carbon impact. Therefore the HS2 carbon impact assessment should present the total construction and operational carbon impacts and then account for carbon offsets in a later stage of the report. The offset from tree planting should be used as a possible way of mitigating environmental impacts rather than an inherent component of the carbon calculation. The inclusion of carbon offsets at this stage is therefore considered to be unusual and not in accordance with standard carbon reporting protocols Considering the above factors, the inclusion of carbon impact offsets associated with tree planting within the carbon impact assessment of the HS2 Scheme is not in 6 accessed February January 2014 accessed

26 HS2 Action Alliance 21 accordance with national protocols and therefore the offsets from tree planting should be excluded from the carbon assessment. Mode Shift 2.66 The mode shift component of the carbon impact consists of the shift of passengers from classic rail to HS2; passengers from aviation to HS2; and passengers from road to HS2. The two reports do not provide a breakdown of the results for Mode shift carbon impacts. It is therefore difficult to analyse and interpret the emission savings from each element of the mode shift. It is noted that each business case for HS2 has produced numbers for passengers transferring from air and car to HS2 and these figures have declined substantially. The issue of how passenger numbers have been modelled is outside the scope of this report; however given the decline in numbers produced in each business case the robustness of the passenger figures should be reviewed The Route-wide effects report recognises that freight mode shift and released capacity at airports are outside the control of HS2. The inclusion of freight mode shift is considered in the following sub-section Although unable to see the detail behind the Mode shift calculations, questions in general the approach for the inclusion of negative carbon impacts (i.e. benefits) associated with the modal shift from domestic air travel to HS Given the relative proximity of the West Midlands to London (and in particular Heathrow Airport via the M40) questions the number of domestic flights currently operating on this route and therefore the ability to offset such passenger journeys. As mentioned in 2.64, the carbon impact associated with the shifting of passengers from aviation to HS2 is not provided; instead a total Mode Shift carbon impact is reported A search of flight routes using Skyscanner (an online air ticket search engine) confirmed that there are currently no direct domestic flights between the West Midlands (assuming Birmingham Airport) and London (assuming Heathrow Airport). The tickets and routes offered from Birmingham Airport to Heathrow Airport include transfers via Edinburgh, Belfast, Amsterdam (or Frankfurt and Warsaw as a two stop journey).

27 HS2 Action Alliance The use of Phase 1 HS2 from the West Midlands to get to Heathrow (for an international flight) would involve arrival at Old Oak Common, a cross London underground journey to Paddington and the Heathrow Express to the airport. In this situation direct transportation by car would be much quicker and therefore HS2 is unlikely to offset passengers heading to Heathrow Given the uncertainties (which are recognised by HS2), would suggest a scenario is developed where the benefits of modal shift from air to HS2 are removed, thus reducing the carbon impact benefits currently being presented for the scheme. It may be appropriate to include a mode shift from domestic air travel to HS2 for Phase 2, at which time journey distances are greater and the use of HS2 Phase 2 is attractive due to the direct link with Heathrow Airport. Freight uptake of released capacity 2.73 The carbon impact modelling by HS2 Ltd accounts for a mode shift of passengers from classic rail to HS2, thus releasing capacity (freight paths) on the classic rail network for additional freight movements, in turn resulting in a mode shift of freight from road to classic rail (specifically the West Coast Main Line). This mode shift and Freight uptake of released capacity on the classic rail network is modelled to generate a negative carbon impact (i.e. a benefit) but the ES does not provide detail of the methodology used to establish how many freight paths will be used once HS2 is built The carbon impact of Freight uptake of released capacity is significant at -2,070,000 tco 2 e. As mentioned previously, HS2 themselves recognise that the modal shift of freight from road to the released capacity on the classic rail network is outside the influence of HS2 and highly uncertain At the present time, the freight use of the available classic rail slots is only 50% 8. Therefore, currently there is an under utilisation of the rail network for freight movement, and if additional freight services were required, these could be met with the existing rail infrastructure. The use of existing rail capacity on the classic network 8 Route-wide effects report, page 64, Table 5, Released capacity for freight component of the footprint states Currently, on the WCML, there are three standard off-peak freight paths per hour; although currently, approximately 1.5 paths an hour are used. The Government wishes to encourage more freight to shift from road to rail.

28 HS2 Action Alliance 23 for freight has the potential to deliver carbon benefits, and is not reliant on HS2 development It is questionable whether HS2 is necessary to achieve a model shift in freight uptake and whether freight uptake would be of such a scale that additional slots released by mode shift of passengers to HS2 are required, given the classic rail network has 50% availability Considering the uncertainty around the shift of freight to the classic rail network, it is suggested that a further sensitivity scenario is modelled where the carbon impacts of Freight uptake of released capacity is excluded. (v) Summary of findings 2.78 The carbon impact reports prepared for the HS2 Phase 1 ES are based on appropriate calculations methods which are in line with industry standards. The reports identify the key parameters and sensitivities, however some of the key parameters are uncertain (and therefore should have further sensitivities assessed). In addition other parameters (relating to offsets) are questionable, and considered unsuitable for inclusion in the carbon impact results. The key issues are summarised below: Decarbonising of Grid Electricity: The two grid emission factor profiles modelled include aggressive decarbonisation of the national grid. Although decarbonisation of the grid will occur, the speed and scale of the decarbonisation is uncertain, and decarbonisation of the national grid is outside the control of HS2. Mode shift air to HS2: The modal shift of passengers from domestic air travel to HS2 for journeys from the West Midlands to London, in particular for connecting international flights at Heathrow Airport is deemed unrealistic. It is recognised that Phase 2 (which may involve a direct link to Heathrow Airport) may offset some domestic flights; however the ES relates to Phase 1 only. Freight uptake and offsets: The carbon impact assessment includes assumptions regarding the benefits of shifting freight from the road network to the classic rail system (as passenger mode shifts from classic rail to HS2