Rebuttal of Appendix F

The Northern Approach to Cambridge in the EWR Co. 2021 Consultation

In the light of their emerging preference for a route with a station to the north of Cambourne, EWR Co. have correctly decided to reconsider the northern approach to Cambridge. Their high-level assessment of the northern approach is presented in Appendix F of the Technical Document from page 44 onwards. In this post we focus on the top-level points paragraph-by paragraph that they make in section 1 of Appendix F. The EWR Co. text is repeated in italics for convenience.

1.1.1 This appendix reviews the potential for EWR to approach Cambridge using a northern alignment between Cambourne and Cambridge via Milton. EWR Co has considered this route in order to verify the decision taken to prefer Route Option E, which approaches Cambridge from the south. This is necessary because route alignments in Section E might serve a station to the north of Cambourne. Such a station could be broadly equidistant by rail from Cambridge station, serving which is an objective for EWR. This appendix considers whether a northern route into Cambridge could satisfy the objectives for the EWR project and the extent to which a northern route compares with the southern alignments considered in Section E, F and G of the Technical Report. 

EWR Co. correctly say that a station at Cambourne North would be broadly equidistant from Cambridge Station with a southern route or a northern route. However, we know that Cambridge is not intended to be the final stop for EWR services; the plan is that it will extend to Norwich via Ely and Ipswich via the Cambridge to Newmarket line.  

EWR Co. do not insist that passenger trains via Bletchley have to go in and out of Milton Keynes, nor do passenger trains from Bicester to Winslow have to go in and out of Aylesbury.  In the same way, passenger trains between Cambourne and Waterbeach do not all have to go in and out of Cambridge. Taking the northern approach the Cambourne Waterbeach link is 12 km shorter than going via the southern route and the three large new towns to the north and west of Cambridge become well connected. 

1.1.2.  The approach to considering this that EWR Co has taken is first to consider if a change in circumstances that could affect the decision not to prioritise northern routes into Cambridge has taken place. It has concluded that routeing via a Cambourne North station is such a change. It has then looked at other new and more detailed factual information available to it in order to establish if the decision would be different had that information been known at the time. To do this, EWR Co has considered a northern route from Cambourne North. 

Cambridge Approaches (CA) have been considering this issue for several months and have used broadly the same southern approach that EWR Co. are now proposing for their preferred alignment 9 in their comparisons. The CA comparisons are presented here and here.

1.1.3.  The selection of a preferred route option in 2020 following the previous public consultation was based on an assessment of how the various options performed against a combination of fifteen Assessment Factors, which included transport user benefits as well as capital and operating costs, and against the overall programme objectives for EWR. The decision to enter Cambridge from the south was based on engineering, operational, economic, and environmental reasons. This appendix considers how a route approaching Cambridge from the north would perform in relation to the same topics. 

The methodology used by EWRCo. in their previous assessment is set out in §5.4 and §5.21 of their Preferred Route Option Report. It is clearly not an exact science, however among the “second set” factors listed in §5.21 and still not correctly addressed in this report are: 

1. “Short distance passenger services and connectivity to support commuting into key employment hubs (current and future)”
2. “Consistency with plans for the location of local settlements”
3. “Satisfying existing and future freight demand (as anticipated by the freight industry) where affordable.”

We make no comment about whether these factors were important for choosing between options A to E, but they are definitely important when choosing the route into Cambridge to the north or south.

There are significant new towns to the north, and a development void to the south. Freight can bypass Cambridge to the north but will have high residential impact to the south. The local transport services to the north would be greatly helped by a northern approach.

1.1.4 In engineering terms, a northern route from Cambourne to Cambridge is feasible, although it would be complex and expensive to consent, construct and operate. A northern route would cross the newly upgraded A14 trunk road to the west of Girton, which at this location is an eight-lane dual carriageway. This would therefore require a substantial bridge structure. The prevailing low-lying land levels mean that this structure would be a prominent feature in the surrounding landscape. 

The idea at the railway would cross the A14 here with a bridge is not the only option. It is surprising that EWR Co. do not mention CBRR’s notes on the preliminary railway alignment.  They would have found that under Map 6 it states “East of the station it leaves the A421/A428 alignment and drops steadily while heading north east to the Dry Drayton and passing below the A14 near the Cambridge Crematorium. By crossing below the A14 the impact on the crematorium will be reduced”. The notes have been available on the CBRR website for years and the impressive CVs of the consulting engineer designers of this route are given at the end of the document. They have designed railways around the world.

It is not only the impact on the crematorium that will be reduced, but also the visual impact on the whole area. In EWRCo.’s statement on mitigating noise and vibration we find the following statement “Sometimes we will need to elevate the track, for instance when trains intersect with roads and cross land in a floodplain. However, where it’s practicable we will consider building the track low in the landscape.”

CBRR based their proposal on the design by one of their engineers which was used on HS1 at the tunnel portal approach structure near Ripple Lane, west of Dagenham: with the trench deep enough, roads crossing the railway need climb no higher than the top of the trench’s flood wall.  CBRR are not the only people proposing, or indeed using, trench railways as a solution for low environmental impact railways including those crossing in flood plains. Consider for example the section of this high-speed railway from Brussels to Amsterdam where the track is in a trench before passing under a tidal river – see Figure 2. It is not clear why EWRCo. have not considered this approach. There are many examples around the world; the San Gabriel trench railway recently won a design award in California. We don’t think that the currently proposed Great Wall is likely to win many design awards. 

1.1.5.  An additional station could be provided to the near Oakington, south-east of Northstowe, but this area is low-lying and forms part of a floodplain so the station and its approaches would necessarily be elevated. A junction with the existing West Anglia Main Line (WAML) would be located north of Milton and this too sits in a floodplain. This location was also granted outline planning permission for the proposed Cambridge Sports lake. 

Firstly, only 700 of the planned 10,000 houses in Northstowe have been built. These additional houses will bring the development right up to Oakington. Why don’t EWR Co. know this?  Why are they talking about people walking for an hour to get to the station? The new town of Northstowe will be the largest new town in England since Milton Keynes and current plans will make it bigger than Ely. It is also likely that in future local plans Northstowe will grow further. The Cambridge Autonomous Metro (CAM) is a possible solution (to supplement the existing, at capacity, guided busway), but it currently lacks funding. Why are EWR Co. referring to the County Council plans to develop the busway – isn’t this now the responsibility of the Combined authority? Why don’t EWR Co. know this?

Secondly, trench railways work in flood plains. Going back to the notes produced by CBRR we find the following under Maps 7 & 8: 

“North-east of the A14 the line passes to the south-east of Oakington, where a station is proposed to serve Oakington and Northstowe. It then has to cross the fens for about 9km before joining the Cambridge – Ely line. For the fen crossing it is proposed to once again lower the alignment to below existing ground level and contain the line in a structural trench with walls up to flood protection level. This allows it to pass below the Oakington – Girton road, the guided busway, B1049 north of Histon, Landbeach Road, and the A10 north of Milton. The advantages of keeping the line low are reduced visual impact, the ease of building over-bridges, and the avoidance of new embankments which would cause continuing settlement for years for years after construction. After crossing the A10 the line bends to the south and rises to the level of the main Cambridge – Ely line which it joins once at the correct level. The line continues south south-west to Cambridge North Station.”

So, the station would not need to be elevated at Oakington. 

Thirdly, why do EWR Co pay such attention to the proposed sporting lake at Milton? It did not have planning permission or funding at the time it was mentioned in Chapter 16 of the Preferred Route Option Report in January 2020. It does not have either now. If it did get planning permission then the railway could slide underneath it in a trench as proposed by CBRR in Map 8b of their notes on the preliminary railway assessment.

1.1.6.  The route into Cambridge would be via the WAML, a two-track line which would need to be upgraded to a four-track line to accommodate the additional EWR services. The WAML corridor between Milton and Cambridge is much more constrained than a southern approach with properties against the railway boundary and multiple highway crossings with adjacent properties. This would necessarily require demolition of residential and commercial property and the widening or replacement of several substantial structures, including the A14 bridge at Milton, and a new bridge over the River Cam. Cambridge North station would also need to be modified to accommodate the additional lines. In addition, the road bridges carrying the A1303 Newmarket Road, Coldhams Lane and Mill Road in Cambridge would all need to be replaced and widened to accommodate the extra tracks. 

EWR Co. assert that the WAML would need to be 4-tracked. This would clearly be a significant project, comparable in scale to the 4-tracking required from Shepreth Branch Junction to Cambridge Station with the southern approach. But where is the evidence that the 4-tracking is required?

It is up to EWRCo. to fully present their justification of this important assertion. In doing so they should consider the following:

1. Is the opportunity being missed to rationalise the many independent rail services that will all be passing between Cambridge South, Cambridge and Cambridge North stations in 2030, especially in the light of the demise of rail franchises? We count 7 different passenger services at the moment, without EWR Co.
2. Britain is already changing from line-side signalling to in-cab signalling. This allows signallers to talk to trains continuously rather than only at fixed points. This will vastly improve line capacity. Thameslink through central London was planned to allow 24 trains per hour rather than the usual rule of thumb of 10 trains per hour. EWR Co. are specifying this in cab signalling for their new trains.
3. Does the benefit of the 4 tph clock-face timetable really outweigh the costs of creating more tracks through Cambridge [and presumably other cities along the EWR]? If this feature triggers 4-tracking,EWR Co. should consider waiting for better signalling before introducing it.
4. With a southern approach to Cambridge and EWR Co.’s current assumptions about 4-tracking to the north of Cambridge, will the 4-tracking from Cambridge to Milton not be necessary anyway for extending EWR’s services further east – or is this considered out of scope? That would be short sighted and would not meet the Sponsor’s Requirements (Technical Report Appendix A §1.6)
5. Given the uncertainties on passenger demand does it make sense to commit to extra tracks through Cambridge for this project? Anthony Browne MP expects that post Covid, people will continue to work at home 2 days per week leading to a 40% reduction in passenger demand long-term.
6. Much play is made of a detailed assessment of the property acquisitions that would be needed with the “NA2” section into Cambridge.  Although the southern approach is EWR Co.’s preferred route, the assessment does not go into as much detail about the property acquisitions it needs or might need.  It does not, for example, explain what the property acquisition impact might be of EWR Co’s current conclusion that the line does not need additional tracks between the new Harston Junction and the existing Shepreth Junction proves “on further investigation in coming design phases” (paragraph 11.1.2 Technical Report) to be incorrect.  This gives the consultee a biased impression in favour the southern approach. 
7. A similar argument can be made as above for possible bridge work for 4-tracking the Shepreth Branch line on a southern approach. If their future investigation is incorrect, the cost consequences of a possible mistake would be far greater than 4-tracking the NA2 section, with modifications required to bridges including crossings of the M11, the Cam, the Newton Road, the B1368, the road between Little Shelford and Hauxton and the A1301 in Great Shelford.
8. The pre-Covid 2018 baseline rail traffic used in the assessment in Appendix F shows that there is a lot less traffic to the north of Cambridge than to the south. There is a major cost saving opportunity available for this section if NA2 were not to require 4-tracking.
9. Given the overloaded nature of Cambridge Station identified above and the need to integrate with local transport schemes EWR Co. should consider having some passengers changing at Cambridge North or South onto existing services (or the CAM, which is proposing to link the three railway stations) rather than adding to the congestion at Cambridge Station. If London allowed all trains to pass directly through or go straight into the centre, the central district would be nothing but railways. It is reported that nearly 12 million passengers per year use Cambridge Station (with over half a million interchanges) while less than 1 million use Cambridge North (with less than 2,000 interchanges). Is the solution really to expand Cambridge Station?
10. If EWR does not take a northern approach, neither the CAM nor EWR is proposing to link Cambourne or towns west of it directly to the northern part of Cambridge.  This seems a major omission, especially as an improved A428 between Black Cat and Caxton Gibbet) may encourage people to drive this route.
11. Transport now accounts for 40% of the UK carbon budget and after the coal-fired power stations have been closed down, future carbon targets will press further on transport construction.  Are unnecessary works in 4-tracking Cambridge really justified and when will EWRCo. publish their carbon assessment?

1.1.7.  Economically and operationally, a northern approach to Cambridge does not provide the same level of benefits as a southern approach and is less able to satisfy the overall objectives of EWR. In comparison with services entering Cambridge from the south, which in all our assessments are assumed to call at the new Cambridge South station that is being developed to serve the heart of Cambridge’s internationally significant Life Sciences cluster in the south of the city en route, the Northern approach would be slower and more complicated. This is because, using assumptions common to both scenarios, if the EWR services entered Cambridge from the north they would need to pass through Cambridge station in order to then turn back at the new Cambridge South station, which would need to be modified. 

§1.1.7 contains more assertions without supporting evidence. Figure 4 is a map from a Cambridgeshire County Council prepared in connection with the Greater Cambridge Local Plan showing the many major employment sites around Cambridge. It is clear from the map that there are many more employment areas served by a northerly approach than one from the south. The Addenbrooke’s / Biomedical Campus site is number 26 on the map and, independently of the EWR Co. project, will be served by Network Rail’s Cambridge South Station. Cambridge is blessed with internationally significant companies in its Science Parks near to Cambridge North Station (ask yourself why that station was built before Cambridge South).

If not serving Cambridge South directly is a problem, isn’t not serving Cambridge North directly equally a problem? If EWR does go on to serve Cambridge North – as suggested in §1.1.10 (quoted below) – EWRCo. need to explain why this will not trigger a 4-tracking requirement.

On closer examination the argument in §1.1.7 is not a distinguishing assessment factor.

1.1.8.  Furthermore, services on a northern approach utilising the EWR lines to travel further east to Norwich and Ipswich could not do so without reversing manoeuvres at Cambridge station and without the construction of further infrastructure to enable these onward journeys. This would add time to journeys and increase operational complexity. To travel eastwards from the north, without calling at Cambridge station and therefore avoiding the reversing move, a new railway chord would need to be constructed at Coldham’s Common or Ely. This would not meet the Project Objectives as Cambridge station would not be called at. However, future freight on the Newmarket Line could use the chord to avoid Cambridge station. Furthermore, although the length of railway for a northern route and southern alignments is similar (the northern route is approximately 600m longer) journeys approaching Cambridge station from the north would take longer due to any extra time spent at a stop the new Oakington station for Northstowe station. If this intermediate station is omitted, then journey times would be approximately the same as for services approaching from the south. 

In researching the rail passenger services currently passing through Cambridge to the north we notice that there is an hourly service from Birmingham and another from Norwich. Both of these services terminate at Stansted airport. There is clearly significant demand to get to Stansted and it is reasonable to assume that this market demand would also be there for EWR passengers. With the southern approach, passengers would either have to change at Cambridge [South] to get to Stansted or EWR trains would have to reverse out to get there. This is not the case for a northern approach. Why is this situation materially different from these points about Norwich?

The services provided in the Project Objectives should be demonstrated to prove they meet market demands: rigid control of projects from central government does not have a great track record of producing what customers actually want[1] . EWR Co. should publish more results from their transport model, which we understand to their surprise show that 70% of the demand is for local trips. (see East West Railway Project Update 2 December 2020).

If the demand is mostly local, it is surprising, to say the least, that adding a stop at Northstowe, the largest new town in England since Milton Keynes (and one which only has an already overloaded[2]  guided busway) does not benefit the business case for the railway. A stop a Northstowe would greatly benefit employment throughout Cambridge, allowing people living in more affordable housing to travel easily to their places of work. If it is true, perhaps all stations except Oxford and Cambridge should be removed so that the projected 18,000 end-to-end journeys per year can be served uninterrupted. But that would be less than one person per train. 

While on the subject of Milton Keynes, it is clear that there will be trains between Oxford and Milton Keynes, but not whether there will be trains between Milton Keynes and Cambridge.  It looks as though the link is with Bletchley.  Either that or every train journey between Oxford and Cambridge will reverse from Milton Keynes back to Bletchley. Perhaps EWR Co. could clear that one up.

EWR Co. please publish more of the transport model – and the business case.

1.1.10.  Although stopping at Cambridge North would connect existing and planned employment sites and housing to the route, a northern approach forgoes the opportunity to directly connect the new Cambridge South station, and planned growth around it, to the route with fast, reliable east-west public transport. A southern approach is better aligned with the local and national economic and strategic ambition to support Cambridge’s internationally significant Life Sciences cluster. In addition, it would be possible for services approaching Cambridge from the south to continue beyond Cambridge station and serve Cambridge North if required. 

Please provide a reference to the local and national economic and strategic ambition to support Cambridge’s internationally significant Life Sciences cluster over and above other high-tech sectors in Cambridge. Also, please explain why many of the sites in the Life Sciences cluster that are not located in vicinity of Cambridge South are less important? Consider for example this set of life sciences companies on the Cambridge Science Park.

Of course, it is beneficial for the EWR to serve Cambridge North directly and, as previously mentioned, this would, by EWR Co.’s logic, trigger 4-tracking on the section of the line to the north of Cambridge Station for a southern approach. This problem is a symptom of the lack of effective integration of the EWR project with local transport projects. Rail passengers going to London do not all expect to get directly to the centre of the city without changing to local transport. Cambridge is starting to show the same problems and the solution is not to add more railway tracks and freight trains through the centre.  It is also a result of the fact that EWR Co’s responsibilities end at Cambridge Station and they don’t look beyond that point unless it suits their argument to do so.

This assessment of the economic impact of the railway on the Cambridge economy might also benefit from closer collaboration with the local experts from Greater Cambridge Shared Planning who do not seem to have been involved in this assessment.  And while EWR Co are speaking to them, they might wish to explain why §2.3.10 appears to be trying to pre-empt decisions on the location of housing growth which are a matter for the relevant local authorities not EWR Co.

1.1.11.  A qualitative assessment of capital costs for a northern route has been completed and the extent and complexity of the structures, poor/wet ground conditions between Oakington and Milton, loss of residential and business properties, and modifications to the railway and existing stations are expected to make this solution more expensive than the southern alignments proposed by EWR Co given that the alignment lengths are similar for each approach. 

We find the idea of a qualitative assessment of capital costs an interesting one.  This assessment is based on the unjustified 4-tracking assumptions we have referred to above. Again, if the EWR is trying to get good connectivity to Cambridge then a solution for all three Cambridge stations and onwards to the east is required.

It also utterly fails to address the issue that the Shepreth Branch line would cost significantly more to 4-track than a northern approach if, as previously mentioned, their track demand assumptions are incorrect for this line. Our studies show that leaving 2-tracks on the SBR places severe constraints on the EWR timetable to say the least.

1.1.12.  The considerations above relate primarily to engineering, operations and economics.

Such a the top-level assessment should also include environmental and residential impacts. Why have EWRCo. still not performed a strategic environmental assessment? (Saying that legally you don’t have to is not a defence). This approach will lead only to mitigation of environmental damage rather than avoiding it in the first place.  The barbastelle bat is one of the UK’s rarest mammals. There are only six known maternity sites in England, including the Wimpole and Eversden Woods, and all are designated as SACs.  The Wimpole and Eversden Woods site is the only one of these sites in Cambridgeshire.  Why do EWR Co think that their impact on it can be mitigated?  There is nothing to support this assumption.

1.1.13.  The route that EWR Co has considered is not designed to the same level of detail as the southern alignments. However, the design level is sufficient to enable a comparison to be made. That design is also sufficient for high level environmental comparisons to be made.

Not entirely true. The assessment of the unjustified 4-tracking to the north is explained in considerably more detail (37 pages, pp. 64-101 in Appendix F)  than the extensive 4-tracking required to the south (4 sparse pages, pp.415-418 in the Technical Report) which concludes with the statement in §11.9.8 “preliminary designs for this section of the Project are being developed and will be introduced as part of a further Statutory Consultation in due course.” We can only conclude that this style of presentation is to exaggerate the case for the southern approach beyond what the facts will sustain.

EWR Co’s statements in their ‘high level environmental comparisons’ are riddled with errors. Examples include EWR Co’s assertion that the N approach would be within 500m of built-up areas of Caldecote, Dry Drayton, Hardwick and Horningsea. In fact, it would pass within about 800m of Caldecote and 1300m of Hardwick. While it is within about 450m of Horningsea, that village is already next to the WAML (and future combined track). EWR Co also talk about impacts on Madingley Hall and the American Cemetery. This is totally misleading – Madingley Hall is about 1.3km away and existing trees would prevent views to the path of the CBRR route. The American Cemetery is 2.4km away and the viewpoint faces a different direction to the CBRR route.

1.1.14.  This appendix demonstrates that an alignment approaching Cambridge from the north remains less attractive than a southern approach into the city, reinforcing the previous conclusion that a southern approach to Cambridge should be preferred and the case for the proposals described in Chapters 9, 10 and 11 of this Technical Report. 

We leave it to the reader to decide whether EWR Co. have done this. Needless to say we do not think so.

If you agree that we are entitled a fair consultation on a northern approach in parity with the southern approach please sign the petition. You will be joining 10,000 others in doing so.

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