Chapel Hill Site of Lord Scales’ 14th Century Chapel of the Blessed Virgin Mary and pilgrimage site is on tree line.Chapel Hill chalk ridge between photographs above and below.Chapel Hill Near proposed Eastern Tunnel Entrance and deep cutting, destroying 3,000 year old remains of ancient Britain’s in Bronze Aged Cemetery
The position of Cambridge Approaches on EWR is set out here and has not changed. With the release of the NSC on 14 November we have an opportunity to point out problems for our local communities – and there are many. More people formally asking for something probably increases the chances of it happening. There has been movement on the proposal since the 2021 consultation and our “Great Wall of South Cambridgeshire” campaign, but nothing like enough. For many people it would still be hideous and we would all be affected by the years of construction. I try not to look at this video of Calvert too often and definitely not the section starting around 8:50. It shows what haul roads, construction compounds and balancing ponds actually look like. Something you will never find in EWR documentation. I then imagine the view from Chapel Hill across the Bourn Valley described in one of the most famous poems ever written about Cambridge. Then (in 1912), as now, a sea of wheat fields and one of the defining views of Cambridge that the architects of our green belt wanted to preserve in the mid 20th century.1 They would be turning in their graves. Anyway, here is the section of Rupert Brooke’s poem.
“Is dawn a secret shy and cold Anadyomene2, silver-gold? And sunset still a golden sea From Haslingfield to Madingley? And after, ere the night is born, Do hares come out about the corn? Oh, is the water sweet and cool, Gentle and brown, above the pool? And laughs the immortal river still Under the mill, under the mill? Say, is there Beauty yet to find? And Certainty? and Quiet kind? Deep meadows yet, for to forget The lies, and truths, and pain? . . . oh! yet Stands the Church clock at ten to three? And is there honey still for tea?”
Here are some people who care about that view being interviewed by ITV Anglia as the consultation came out.
There is a story in government about how building this railway will create some sort of economic miracle around the Cambridge Biomedical Campus and they are not letting mere facts get in the way of a good story, but remember this chart.
To quote a recent article about the dire water situation in our area. “You can send your legions to war with reality, but eventually we all lose.” The East West Rail Company are one of those legions, who think there are building a Net Zero Railway.
Bizarrely the Transport User Update which also came out with the NSC only seems to refer to the local plans for housing. Without large amounts of EWR dependent housing we are on £14.88million per Cambridge Commuter and no new Cambridge jobs supported. But hey, it’s only taxpayers money being poured down the drain. Who cares? They don’t seem to.
Well, I feel a bit better after that polemic, so back to the purpose of this article: how to fill in the NSC feedback form. If you care about our area (and I know you do), please have your say.
Online Consultation Questions in Online Feedback Form. The online form allows much more space for answers than the downloadable form.
Croxton to Toft (Question 16)
Comberton to Shelford (Questions 17 to 20)
Cambridge (Question 21)
Route-wide matters (Question 22)
About our consultation (Questions 23 to 25)
I suggest having a look at your relevant map note: there are plans and elevations; read the relevant section or subsection of the Technical Document and start writing in your favourite word processor. When you are ready, go through the dialogue for the online feedback form.3
We have until 23:59 on Friday 24 January 2025.
Some Issues Identified So Far(last updated 8 Dec 2024)
[We hope to update this as we go on but here is a starter for 10.]
Purple construction fields are way too close to houses they should be at least 150m away.
The railway should go under the A603 not over it, and the same is true of the Bourn Brook.
There is no evidence that Green Bridges, and Bat Underpasses work for Barbastelles. The proposed route crosses the Core Sustenance Zone of the Eversden and Wimpole Woods SAC, which is a maternity roost.
Why is the route so close to southern Harston – why not push it a few hundred metres further south? (Hoffer’s Brook permitting)
Having identified the Bronze Aged Cemetery on Money/Chapel Hill, and that it doesn’t even cost more to save it, why is your preferred option to wipe it out? Those people’s remains have been lying in the chalk for 3,000 years, and its one of the most beautiful places in South Cambs (ask Rupert Brooke).
Why was there a mined tunnel through Bourn Airfield in the Feedback Report, but a more destructive cut and cover in the current proposals? You have not withdrawn your ridiculous claim that associates EWR with £163billion GVA increase by 2050 so there can’t be a cost problem, surely?
Why not do a 16km bored tunnel from north of the A428 to the southern entrance to Cambridge? (Same length as the Chiltern Tunnel on HS2 so the precedent is there). The net cost increase would not be that much (see (6) above), it’s 3km shorter (so all those scientists can get to Oxford more quickly). It would reduce local objections considerably, save a lot of farmland and the Wimpole SAC. It would also reduce congestion on the Royston Line.
Given that you have chosen a route that is ill suited to rail freight why not save money and remove support for it?
As we all work on our consultation responses do add your ideas and issues in the comments so other people can see. The more this project gets the criticism it deserves the better. Don’t feel you can only give feedback on the defined questions, you can use Question 22 or even Question 24 to give general feedback like, why on earth are you still working on this project?
*I had to look it up, it means rising from the sea. ↩︎
If you want to look at the downloadable, non extensible feedback form it’s here. The downloadable form might still be useful to look at the questions and prepare the answers in advance ↩︎
*** Health Warning: These drawings date from early 2022 and may not represent the final proposal. ***
Having established the principle that EWRCo. should release these maps, a follow on Freedom of Information request and some encouragement from the Information Commissioner’s office has produced these additional maps. Land Information Questionaires sent by EWRCo. to many residents in the Cherry Hinton / Fulbourn area of Cambridge indicate that EWR Co. propose changes to the line to Newmarket, but so far we still have no details of those.
The earlier release between Caxton Gibbet and Great Shelford is available here. See also the maps between Clapham and Caxton Gibbet here.
*** Health Warning: These drawings date from early 2022 and may not represent the final proposal. ***
Having established the principle that EWRCo. should release these maps, a follow on Freedom of Information request and some encouragement from the Information Commissioner’s office has produced these additional maps. The earlier release is available here. So we now have a complete set of the “core section” or new track from Bedford to Cambridge as the proposal stood in early 2022.
***It is clear that the section from Wyboston to the East Coast Mainline had changed by May 2023 *** (map 0412) to the “Tempsford Variant 1A” which runs south of the Black Cat roundabout. A map of this has also been released by EWRCo. and is included. Unfortunately, is does not include details of land required for construction and biodiversity net gain shown in the other maps and dates from November 2021.
Although following an existing route, the section of EWR from Shepreth Branch Junction (SBJ) (just north of Gt. Shelford) into Cambridge Station (CBG) is £500million project. When we first heard about that, we assumed it would be the end of the southern approach to Cambridge or indeed the straw that broke the camel’s back on CS3. However, the government’s fixation (based on flawed evidence see here and as explained further here) on connecting EWR directly to the Cambridge Biomedical Campus has been used to over ride the recommendation from EWRCo.s own technical partner Arup that the southern approach to Cambridge was really difficult. Not least in terms of how much disruption would be caused during its construction.
Costain performed a “constructibility assessment” for the southern approach to Cambridge and the results of this have been released (at the request of Great Shelford Parish Council). In releasing the information, EWRCo. added the caveat that they are still working on these and that the information provided dates from 2022. These reports (see below) show the many years of disruption coming to Cambridge residents if this project were to go ahead. It involves
Major remodelling of Cambridge Station
Re-laying all the tracks in the busiest section of the rail network – between SBJ and CBG
Temporary closure of Long Road Bridge
Whatever delightful feature it is that has caused the LIQs to be sent to Cherry Hinton remains to be revealed. (probably a freight loop)
These documents mainly concern Cambridge, but there is a document on the whole core section (the new track from Hauxton Junction to Clapham Green) which includes for example the construction depot on the ECML near Little Barford.
Here are two more accessible versions of the four Arup maps we published in our previous post.
Firstly, for orientation here is a low resolution composite of all four maps together on top of the Google satellite image for the area (many thanks to our map expert Leigh for this).
Secondly, a downloadable a high resolution version of the same map which can be downloaded. It is a 207.5MB file so be patient. Apologies our web server is not up to viewing this on line. After downing the .png file you should be able to zoom in to areas of interest and go back to the maps in the previous post for the key.
The overall picture is a 500 metre wide strip of land 50km long from Hauxton south of Cambridge to Clapham north of Bedford. And then there are the new towns at Cambourne north 53,400 people (Cambourne increases in size by a factor of 6.8*) and Tempsford 44,000 people, bit of these sites will also need biodiversity net gain. The land take is colossal.
How we got the maps and what has happened since they were published.
It took 3 years and multiple legal appeals for Cambridge Approaches (and Leigh Day, and our local MP’s office) to get EWRCo. to release these maps which show the scheme in a level of detail we have not seen before – including the land take for construction and biodiversity net gain (BNG). Oxford Prof. David Rogers confirmed to me that construction land cannot be used for BNG, since that must start from day one of the construction. Consequently BNG land would be compulsory purchased along with the land for the railway. Refer to the previous post for the key to these maps.
Of course, EWRCo. will have been working on these plans since January 2022 when the versions here were completed. One naturally expects to see this level of detail in a planning application for a new house or extension in order to be able to comment on it. Why is it so difficult to get EWRCo. to do the same?
Suspension of Farm Business Interviews
In the same way as some of the thousands of affected home owners between Bedford and Cambridge were sent Land Information Questionnaires, farmers are being offered Farm Business Interviews (FBIs). These interviews (I attended one) are again to collect information but they are much more useful from the farmers’ perspective if they can see the details of the proposal – even if it is out of date. In the light of these maps, another farmer (who wishes to remain anonymous) came forward and said to EWRCo.’s agents that he would, after all, like to have an FBI. Here is the response he received from the EWRCo. representative:
“Many thanks for your e mail and no need to apologies (sic) for the delay in responding.
We are accompanied by another person for the FBI meetings, but only as there is a ‘no lone working’ policy in place at EWR. The other person in attendance is from Ardent who are undertaking the land referencing on behalf of EWR, and, being the company involved with the various surveys, can also answer any questions you may have on the surveys taking place on your land. Although we are all representatives of EWR in some form, unfortunately they will not be able to answer more general questions relating to the project.
Following the publication of the 2022 detailed scheme design plans by Cambridge Approaches, EWR have asked us to pause surveys until further notice. Following re-commencement of the meetings I will be in touch with you to arrange a meeting where we can discuss the impact of the scheme on your holding, and consider ways of mitigating this impact.
If you have any further questions please do not hesitate to contact me.”
We then asked Ardent when the FBIs would resume and why they had been suspended and received the following answer.
“Just writing to acknowledge receipt of your below email. I am in discussions with the relevant team at EWR and will revert back to you once I hear further.” 13th May 2024
Well I guess we are still waiting for an explanation of why EWRCo. do not want to meet people can who see (albeit out of date) information about how this scheme affects their homes and farms.
Maps in the Statutory Consultation (SC)
With part 1 of the SC due to start sometime “in the summer” we might expect that a full set of up to date construction maps will be published including the land take for construction, biodiversity net gain and a description of the likely impact of the construction project. All the sort of stuff that local residents need to understand about the project. However, at the “Community Conversation Event” held in Cambourne on the 10th May 2024 the following information was displayed.
So it’s just high level information on the environment, traffic and construction considerations. EWRCo. clearly have a lot of detailed design. How much will they actually share? Apparently not much.
*I have taken the base population of Cambourne as 9250 as in the EWR data, but and aware that the 2021 census figure is a little higher. It is assumed here that this is due to different definitions of what is included in the Cambourne population
*** Health Warning: These drawings date from January 2022 and may not represent the final proposal. ***
On the 10th of May 2021 our lawyers Leigh Day sent a Freedom of Information request to EWRCo. After nearly 3 years of legal and other pressure we received some answers. One of the questions was this. “EWR is asked to provide any report or other analyses it holds which caused it to conclude that embankments and viaducts will be required between Cambourne and Hauxton Junction on the southern approach.“
The response was a series of detailed plans and vertical sections as follows:
(The plans are in PDF format, they can also be downloaded as high resolution PNG images – see at the bottom of the webpage).
These plans date from January 2022 and so may be out of date. Notice the fields marked in purple which will be needed for construction work. If you don’t know what that looks like have a look at this video of EWR CS1 under construction at Calvert.
We also asked about the vertical alignment for the northern approach to Cambridge and the following section diagrams were provided.
Thanks to everyone who attended the presentations and discussion on the 26th March 2024 we had around 180 people register for the event. For those of you that could not make it, or those who want to review the material here are the recordings.
I am grateful again to Annabel Sykes for this guest postassessing recent claims from EWRCo.as they continue to their increasingly desperate search to find a compelling use for completing EWR to Cambridge.
I feel reasonably well-qualified to comment on how much substance there is to the ease and speed of travel claims EWRCo is making from Cambridge, as I live a short walk from Shelford station on the West Anglia Main Line (WAML) and my children are (or were) at Edinburgh and Bristol universities. We all like, and regularly use, trains.
EWRCo’s current proposals and journey times along EWR
The Route Update Report (“RUR”) proposes four trains per hour to Cambridge. Two will originate in Bedford and two in Oxford. From information in the RUR and accompanying Economic and Technical Report (“ETR”), respective station-to-station to journey lengths are expected to be 23 minutes (between Cambridge and Tempsford), 35 minutes (between Bedford and Cambridge) and 89 minutes (between Oxford and Cambridge).
No journey time is given between Cambridge and Bletchley in these documents, but the 2021 Economic and Technical Report suggests that it will be approximately 60 minutes. It may now be expected to be longer than this because the RUR says “we’re also suggesting capping the line speed [on the Marston Vale Line] below the 100mph originally proposed”.
EWRCo tends to merge Bletchley and Milton Keynes when talking about journeys, although a person travelling from Cambridge and other places east of Bletchley will need to change trains at Bletchley to reach Milton Keynes Central. The journey time between the two stations is 5 minutes, making no allowance for changing platforms or waiting for a train. There are currently four trains per hour between Bletchley and Milton Keynes Central. This will presumably increase to six when the proposed two EWR trains per hour between Oxford and Milton Keynes Central are running. By contrast, EWRCo seems to regard Cambridge North station as on a different planet from Cambridge station, even though there are five trains an hour between them and the journey time is 5 minutes.
Where can I already get to by rail from Cambridge?
Anyone who lives in or near Cambridge is already lucky, because it is a city that is very well-connected by rail. Looking at the EWRCo map, I can already catch a direct train from Cambridge to Ipswich, Norwich, King’s Lynn, Peterborough, Birmingham and Thameslink destinations such as Gatwick Airport and Brighton. I can reach Birmingham International (for the airport) by changing at Birmingham New Street.
Peterborough gives me access to fast trains on the East Coast Mainline (“ECML”) to Leeds, York, Newcastle and Edinburgh (and, via Edinburgh, to Glasgow). By contrast, Network Rail indicated in its East West Rail Main Line Strategic Statement (“the Strategic Statement”) that it was unlikely that ECML fast trains would stop at any new EWR station[1]. Network Rail also looked at the rail journey between Cambridge and Peterborough in the Strategic Statement using generalised journey times[2] and concluded that using EWR would add 21 minutes to the journey time between Cambridge and Peterborough. This is despite the fact that the Strategic Statement also says “Rail connectivity … is …circuitous to Cambridge along the East Coast Main Line branch”[3]. From the perspective of a resident of Cambridge, EWR will not change the position as regards destinations on, or beyond, the ECML.
I can also catch a direct train from Peterborough to Nottingham and Sheffield. Despite what the map reproduced above implies, there are no direct trains from Bedford to Nottingham or Sheffield. It seems vanishingly unlikely that it will be quicker to travel from Cambridge via Bedford to these places, rather than via Peterborough.
As regards the journey to Birmingham, my rough estimates suggest that the journey time using EWR and changing at Bletchley (and possibly again at Milton Keynes Central) will be roughly the same length or likely slower once train changes and waits are taken into account. It is possible that the journey to Birmingham International might be slightly faster via Bletchley, but it seems unlikely to be materially faster or more convenient.
If I take a train to Ely (a journey of roughly 18 minutes with a very regular service) I can catch a direct train to each of Manchester and Liverpool. I accept that there is no direct train from Ely to Blackpool, Oxenholme, Carlisle or Glasgow but nor is there from Bletchley – as noted above, no direct Cambridge to Milton Keynes train is planned for EWR. In any event, there are not many direct trains to these places from Milton Keynes. There is also no direct train to Worcester or Hereford, but I can get one from Birmingham to which (as noted above) I can travel directly from Cambridge. It seems unlikely that a journey via Oxford to either place will be materially more convenient or quicker.
As regards Cardiff, Bath, Exeter and Penzance, even with EWR, it appears that each of these places would require two changes from Cambridge – there is no direct train from Oxford. I think I will stick with WAML to London Liverpool Street (or a Thameslink train to Farringdon), a short walk to the Elizabeth Line which goes directly to Paddington and a train from Paddington. I simply don’t believe that travelling via Oxford will be measurably faster or more convenient. This tallies with the conclusion that Network Rail reaches in the Strategic Statement. Using generalised journey times, it concludes that journeys from Cambridge to Bristol and Cardiff will be slower on EWR (by 8 and 59 minutes respectively)[4].
Cambridge to Watford might be slightly quicker via Bletchley than travelling into London and out again. However, the proposed HERT (Herts Essex Rapid Transit), linking Hemel Hempstead to Harlow (and communities in between, including Hatfield), may prove a competitive alternative when combined with a rail journey to Hatfield. In addition, neither seems likely to be particularly competitive with a direct journey by car.
Airport journeys
EWR makes some claims about journeys to Gatwick, Birmingham, Luton and Stansted airports. I have considered the position as regards travelling from Cambridge to Gatwick or Birmingham airports above.
Stansted airport is on the WAML. I live close to a WAML station and about 30 minutes’ drive from the airport. There are two direct Cambridge to Stansted airport services per hour, which are reasonably fast (around half an hour). However, they are at roughly 10 to the hour and 10 past, so I could have a long wait if I arrived in the 40 minute interval. Neither train calls at Shelford station and only one of them calls at the reasonably close alternative of Whittlesford Parkway. The journey from Shelford station itself involves a change and takes around an hour. As a result, I don’t generally travel to or from Stansted airport by train. Perhaps this situation will improve when Cambridge South station opens, but I still think there are too few trains between Cambridge and Stansted airport for the service to be a useful one. May be EWRCo would like to consider a northern approach to Cambridge and carrying on through to the airport?
Luton airport is a roughly 50 minute drive from my home. The Strategic Statement gives a generalised journey time to Luton of 110 minutes, using EWR. First, this is likely to Luton station, rather than Luton Parkway, and secondly, it is necessary to change onto the Luton Dart to get to the airport from Parkway. So, catching an EWR train to Luton airport will involve two changes and (estimating) have a generalised journey time of about 120 minutes. Alternatively, I could catch a National Express coach from the Trumpington Park and Ride, with an estimated journey time of 55 minutes or I could catch a train to Hitchin (slightly over half an hour) and take that same National Express coach from the station to Luton airport (estimated journey time of 20 minutes), with the alternative of a more frequent, but slower bus leaving from the centre of Hitchin (about ten minutes’ walk from the station).
Conclusion on travel from Cambridge
EWRCo claims thatEWR “will bring you closer to towns and cities across the UK by connecting with the country’s main north to south railway lines and linking into wider existing services, allowing you to easily explore the north of England and Scotland…or head west to cosy up in the Cotswolds, the West Country or Wales”.
My personal conclusion, from the parochial perspective of a Cambridge resident is that, save for stations actually on EWR, it will make very little difference to getting out and about across the UK. Even for EWR’s stations, I personally remain to be convinced. If I am going to Ikea in Milton Keynes or Bicester village, I am still likely to choose to go by car and not only because I won’t want to lug my purchases home on the train.
Conclusion on travel from other EWR stations
But what about getting out and about across the UK from other EWR stations? The Strategic Statement concludes that rail journeys from Oxford, Milton Keynes or Bedford to Peterborough using EWR will be materially faster than the alternative. It is therefore true that a link to the ECML might well result in some journey time benefits from these stations on journeys to Edinburgh and places between it and Peterborough. However, as the Strategic Statement shows, a detailed exercise is needed to determine whether these benefits are more illusory than real. For example, an Oxford resident can already travel by rail to Edinburgh with a change at Wolverhampton or Birmingham New Street. Someone living in Milton Keynes already has a direct rail link to Edinburgh.
Network Rail has already looked at this in some detail
Those making bold claims about the increased ease of getting out and about as a result of EWR would do well to read pages 30 to 37 of the Strategic Statement. Network Rail’s generalised journey time analysis suggests that the journey time to Cardiff will be worse using EWR from all of Cambridge, Bedford and Milton Keynes (it is obviously unchanged from Oxford). The Strategic Statement notes an improvement in journey time between Bedford and Bristol using EWR, but a worse journey time to Bristol from Milton Keynes and Cambridge.
Network Rail’s conclusion in the Strategic Statement is “three broad generalisations can be inferred from the data [we have analysed]:
1. East West Rail services will radically improve rail connectivity within a ‘core’ geography between Oxford, Cambridge, Milton Keynes and Aylesbury….,
2. East West Rail services will offer marginal or no improvement … between key locations within that ‘core’ geography and those further to the east and west [later, the Strategic Statement gives an example of a 16 minute improvement between Milton Keynes and Ipswich]
3. East West Rail services will not offer a viable alternative for longer distance journeys between the extremes of the given geography, where interchange at London remains more efficient.”
The Strategic Statement goes on to say “The use of high frequency, fast services via existing main lines effectively cancels out the advantage accrued from the shorter physical distance travelled using East West Rail. This is due to the need to interchange repeatedly and the potential for misalignment between existing and East West Rail services (which are of a lower frequency, particularly west of Bletchley)… For those journeys where either the origin or destination, or both, lie off the core route, travel by road is likely to remain a more efficient and convenient option given the length of existing journey times and the marginal improvement offered by East West Rail. To return to the previous example, generalised journey time between Bedford and Swindon would – when using East West Rail services – drop from just under four hours to just over three and a half hours. Travel by private car would typically take between two and two and a half hours for the same journey. Improvements on present generalised journey times by rail would need to be greater if East West Rail were to offer a competitive alternative to road in this instance.”
Final thoughts
So why did EWRCo make the poorly verified claims about EWR’s usefulness through this map and accompanying articles and video? It seems to me that this reflects an unresolved schizophrenia about its purpose and possibly also project inertia[5]. It is not sure whether it is supposed to be providing a fast end-to-end service between Oxford and Cambridge or a commuter service taking workers into each of these relatively small cities and the somewhat larger Milton Keynes. The RUR and related documents seem to make clear that it is the latter, but EWRCo is nevertheless attempting to be all things to all people. This may not be surprising given its apparent lack of strategic focus[6] – why does freight have such a low profile, for example, when it seems critical to achieving net zero – and unconvincing business case[7].
EWRCo has a good deal of homework still to do. Even in its own backyard, as William’s 13 May 2022 “Will the EWR compete with Road?” makes clear, any advantage it may have is by no means overwhelming. When the really significant cost of rail travel and station parking is taken into account, together with the first mile/last mile issue (which EWRCo appears slow to address), that advantage may well melt away.
[1] This is because of the potential for unacceptable detriment to journey times or capacity of these services if they were to do so.
[2] The concept is explained at 4.1 of the Strategic Statement.
[3] My own personal experience is that this journey does not compete well with road.
[4] The Strategic Statement also says “The opening of the Elizabeth Line will improve connectivity between Paddington and Liverpool Street for long-distance journeys to East Anglia”, so the difference may be even greater now (the Elizabeth Line opened after the Strategic Statement was published).
[5] The continuing preference for southern approach may also be a consequence of project inertia. EWRCo accepts in the RUR that “a northern approach is potentially quicker to construct and is likely to cost less than a southern approach. The extent of work required is less, including less disruption to the existing network…[it]…may have less potential environment impact”. The ETR gives more detail on the environmental impact question saying “there are higher presence of higher value habitats and higher embodied carbon than for a northern approach”. The Cambridge Independent of 3 August quotes EWRCo’s chief executive as saying “quite honestly, when I started, I didn’t think that the northern approach was viable at all”. It is a pity that she did not start the job with an open mind regarding the approach to Cambridge.
[6] The Strategic Statement says “The statement outlines a vision for an East West Main Line …which is aimed at gaining the most from the investment made in the new infrastructure and providing a railway that delivers for passengers and freight users into the future.” It goes on to make six suggestions, which include optimisation for freight, provision of a strategic route for service re-routing, planned diversions, and operational flexibility in times of perturbation and electrification.
[7] EWRCo has a singular focus on transporting workers to theoretical job growth at or near the Cambridge Biomedical Campus. Its Theory of Change is not based on the years of detailed and recent work and public consultation carried out by Greater Cambridge Shared Planning in preparing the draft Local Plan, but on a 2017 National Infrastructure Commission (“NIC”) report “Partnering for Prosperity: a new deal for the Cambridge-MiltonKeynes-Oxford Arc” and an earlier Cambridge Econometrics report, “Cambridge, Milton Keynes, Northamption Growth Corridor,” commissioned by the NIC. Both reports are pre-pandemic and so take no account of really significant changes in commuter travel patterns and rail revenue or the lack of a centralised housing plan envisaged by the now-defunct central Government Ox-Cam Arc proposals.
File Containing Reasons for EWRCo. Chosen Approach To Cambridge and the Business Case.
The previous version of this saga was provided in this post back in February 2022. Here is an update.
Recap
During the EWRCo. 2021 consultation, we wanted to understand the fundamentals of how EWRCo. had arrived at their proposed approach to Cambridge. If an approach that required a Great Wall to be built through our villages, severing communities etc. was the best option, then so be it, at least we would understand why that was so. We have the same issues with the business case, but the FOIs for that are another story.
Previous experience with freedom of information requests indicated that we needed the request to be carefully written as any mistake might be used by EWR Co.’s legal team as a reason not to release the information. The Freedom of Information Act and the Environmental Information Regulations contain many exceptions and no doubt for good reasons. We had also noted that EWRCo. tended to refuse requests that other public bodies had accepted. This was in cases where people had asked EWRCo. and another public body for the same information.
We engaged our lawyers at Leigh Day to write a limited FOI request for the most important information. Separately we sent a less formal letter asking for information that did not fit the criteria for the Leigh Day letter. Leigh Day were asking for information already referred to in the 2021 consultation, but not provided. As always EWRCo. waited the full 20 working days before responding to Leigh Day. They then threw the book at us. They went through all the requests CA had made and bundled that with the Leigh Day Letter. They worked out exactly how many hours they had spent responding to our requests. We would view that as time spent providing information that should have been available in the first place. Noting the association between CA and local parish councils, they even went through parish council minutes looking for statements they felt were unreasonable.
In their lengthy refusal letter, the request was labelled “manifestly unreasonable” and “vexatious”. We were a bit surprised, since all we were doing was asking for information that they must have had to support their 2021 consultation and preferred approach to Cambridge. They also accused us of deliberately timing the letter to land when they were busy with the consultation.
Maybe they were a bit stressed. Maybe their supporting information was not all that it should have been. After all who worries about documents that are never going to be published.
We then asked Leigh Day to write an appeal letter for an internal review, explaining in legal terms why the request should be answered including case law supporting that (especially the Dransfield case on vexatious requests).
To their credit EWR asked another senior member of staff to look at the case, he was an Engineer rather than a lawyer. In any event when the pressure of the consultation was over and they had time to look again at our request … they decided to stick with the decision not to disclose and for the same reasons as before. It was still in their view manifestly unreasonable and vexatious.
At this point we decided to refer the matter to the information commissioner’s office (ICO) along with another letter from Leigh Day explaining legally why the request should have been accepted. The ICO accepted that there was a case to answer but did not have anyone available to properly look at it.
Update since February 2022
Time passed and we published a post on this blog setting out the information we had requested and our experience up to that point in getting it. As a result of that, local MP Anthony Browne took up the case and wrote words to the effect that whatever issues EWRCo. had with Cambridge Approaches, he would like to see the answer to those questions.
EWRCo. refused that request as well on the grounds that the matter was now with the ICO. Clearly, it’s not about who asks for the information or when.
I note that the recent Lib Dem Statement on EWR, read out at the last SCDC meeting and kindly copied to us by Cllr Bridget Smith, contains the following paragraph.
“EWR is a Government scheme being delivered by a private company resulting in poor accountability and little transparency. It has been an enormous frustration that government has kept residents completely in dark for years now about their intentions. This is a pitiful way of delivering a major piece of public transport infrastructure.”
It seems that locally at least, there is some crossparty agreement on EWRCo.’s lack of transparency.
Months later and about a year after the original FOI request, the ICO looked at the case. They started by asking us if we still wanted the information. We did. They also asked EWRCo. if they would now provide it. They would not.
Time passed and eventually the Information Commissioner ruled that EWRCo. could not use the argument that the request was vexatious etc and they should respond again within a certain number of days without using that exemption.
We waited, were EWRCo., actually going to supply the information?
Well, the latest news is that EWRCo. have appealed the Information Commissioner’s decision, so the saga continues and we will provide evidence to the tribunal next month.
If you want to make your voice heard about the OxCam Arc (of which EWR is a part) one thing you can do is to have a look at the 5 minute questionnaire put together by a group called StopTheArc – it asks some of the fundamental questions not in the official MHCLG consultation. They were kind enough to ask Cambridge Approaches to review it before publishing.
Still No Published Business Case
One of the things we do on this Cambridge Approaches blog is to ask questions about the business case for the central section of the EWR.
We know from EWR Co.’s Preferred Route Option Report published in January 2020 that the estimated total cost was £5.6Bn (having risen from £1.9Bn a year earlier) and, since we understand that this will be funded by the taxpayer, it’s not unreasonable for us to ask for the business case. For comparison, would the EWR Co. management team get very far in raising £5.6Bn on Dragon’s Den if, after working on their project since 2018, they still won’t share a business case with the people that they want to fund it? Put another way, they are taking us for granted.
For the record, the public line on the lack of business case from EWR Co. in response to our Freedom of Information request at the start of 2021, was that public servants need a safe space and that it is not normal for a business case to be published at this stage. People are sufficiently disturbed by the proposals so that they received 190,000 responses to the 2021 consultation, but it’s too early to publish the case for the project. Really?
This questioning of the business case was followed by Anthony Browne MP asking about the effect of COVID on travel patterns which will likely permanently reduce passenger numbers by 40% as people have learnt to work from home. EWR Co.’s recent video from EWR Co on the 23rd August 2021 talks about this problem (see 3:07 into the video) without any convincing resolution. Covid-19 will pass, but the technology that allows people to work from home is here to stay and employee expectations have now changed.
As EWR Co point out (video 2:36), the hope is that people will move into the area to live and work and set up businesses so it might be that this influx of people will to some extent counteract the others working from home. Indeed, the NIC report “Partnering for Prosperity” set out a target of 1.1 million additional jobs in the area by 2050 corresponding to about 2 million more people and 1 million more homes. We assume that the focus of this growth is intended to be along the EWR around the initial stations and any new ones that are added over the lifetime of the railway. (If not what is the point of the railway exactly?) The impact of this on existing residents will be higher than that of the railway alone.
The second EWR consultation ended in June 2021 and we still have a lot of unanswered questions. Looking at the consultation responses from bodies like the South Cambridgeshire District Council and the Cambridgeshire County Council, we were not the only ones with outstanding questions. You can read the Cambridge Approaches consultation response here and some others here.
In the Cambridgeshire County Council 2021 EWR consultation response we find the following:
Growth: The East West Rail Central Section should support growth and enable sustainable transport patterns to be realised from that growth. The detailed alignment of the Central Section should be considered alongside the consideration of appropriate locations for growth in the Ox-Cam Arc, and the appropriate scale of that growth. The strategy for station provision on the Central Section must be informed by the consideration of appropriate locations for growth.
This is an appeal for the route alignment of the EWR central section and its station locations to follow a co-ordinated housing plan.
South Cambridgeshire District Councils 2021 EWR consultation response says:
Significant further work is still needed to understand the localised impacts of the scheme, the options for mitigation, their effectiveness and implementation including the sequencing with wider strategic infrastructure and development.
Again, they are concerned that the railway is not aligned with the housing and economic plan for the area.
So, some of the outstanding questions centre on how the route relates to other plans for the area e.g. for economic growth, housing and local transport. Unfortunately for all concerned, the EWR Co. management team are not in a good place to answer these questions because they are being pushed by the Department for Transport to get the route defined in advance of key decisions by other bodies. This heightens the risk that EWR will not choose the right approach which will be to the detriment of its business case, local residents and potential users of the service.
Train Wreck in St. Neots
EWR Co.‘s Simon Blanchflower post consultation press release celebrated the scale of response:
The number of responses we’ve received, the breadth of information and level of detail they contain demonstrates the value of consulting with local people at an early stage, and the huge level of public interest in East West Rail.
But a strong response should not be taken as meaning respondents are in favour of what is being proposed.
We are surprised that EWR has aligned its preferred routes in close proximity to one of the largest housing developments in the East of England. None of the five corridors considered in the first phase of the consultation included this land, and the late inclusion has come as a shock to residents, housing developers and St Neots Town Council.
St Neots Town Council is opposed to the construction of these viaducts and asks EWR to urgently reconsider plans to align these routes with the eastern edge of our town.
EWR are proposing 12m high viaducts through St. Neots East reminiscent of the Great Wall they have proposed between Cambourne and Hauxton. There is also no station at St. Neots, maybe that is because of the Tempsford development, but since we don’t even have a vision for the OxCam Arc Spatial framework who knows? More to the point how do EWR Co. know?
Greater Cambridge Shared Planning (GCSP) Local Plan
On the 31st August 2021 an update to the local plan was published. It is currently under consideration by councillors and will not open to public consultation until later in the year (November?). The updated plan will run to 2041 (previously it ran from 2011-2031).
Figure 1 shows an overview map of the developments proposed.
Note that no new housing development is proposed around Cambridge South Station, despite this being one of the repeated justifications for the southern approach to Cambridge for the EWR. This diminishes both the justification for the EWR southern approach route and the business case for the central section of the railway. In contrast, significant new development around the northern route proposed by CBRR is confirmed and developments in Northstowe and Waterbeach are to be accelerated together with new brown field developments to the north and east of Cambridge.
The Mythical Houses Around Cambridge South Station
The myth of significant housing growth around Cambridge South Station has been discussed in a recent letter from a local resident to local District Councillors as follows:
“…the county council’s 2019 response to EWR Co (repeated in the third bullet of paragraph 2.3 of the covering note to the draft response) said ” The ability of EWR services to … provide for the very significant planned economic and housing growth in the south of the city including at the Cambridge Biomedical Campus”. This was an odd statement in 2019, given that the county council is not the planning authority, and it was, at the time, not evident from the Local Plan what housing development the county council had in mind in saying this. It appears even odder now, given the variety of housing development options under consideration by Greater Cambridge Shared Planning (“GCSP”) – see their November 2020 development strategy options assessments and the emergence of the North East Cambridge Action Plan.
In 2019, the constituent authorities of what is now GCSP made clear a new local plan was coming and that they would be looking at all reasonable development strategies and SCDC at least has repeated this point in its response to this consultation. Notwithstanding this, what the county council said in 2019 appears to be understood as fact not just by EWR Co, but also by EWR Consortium.
Among the papers for the EWR Consortium 9 June meeting (not, in fact, discussed) is this one under the heading “realising the potential of EWR” which says (emphasis added):
Cambridge South: Cambridge South [station] will be located near to Addenbrooke’s Hospital and Cambridge Biomedical Campus – key employersand site for new homes in the south of Cambridge.Planned to open in 2025, the station will be on the Cambridge line and West Anglia Main Line, and should also sit on the East West Main Line once it opens a few years later.”
It goes on to say that “The Cambridgeshire and Peterborough Combined Authority is working on the Outline Business Case…”. It is not entirely clear what this outline business case is for and could be a historic priority of the former Mayor because the next paragraph of the document mentions the CAM.
It is possible that all these statements can be traced back to what the county council said in its 2019 response which may have served to lead others to believe that there were likely developments in the south of Cambridge. It seems important for both EWR Co and EWR Consortium to understand the true position and the county council should take responsibility for doing this.”
Now would be a good time for EWR Co and EWR Consortium to review the evidence for the southern approach and the whole business case in the light of this new local plan since the local authorities are planning no new houses around either EWR station on the southern approach in Cambridgeshire all the way out to 2041. Do MHCLG people know better that the local experts about how best to develop Cambridge?
Conflicting Plans at Highfields Caldecote
One of the consequences of the EWR route being fixed in advance of related housing plans are conflicts emerging when the housing plans do come out. The detailed costing information that came out with the last consultation indicates that the preferred route had been established in outline all the way back in mid-2019. Such conflicts can no doubt be resolved by adjustments to the railway route or knocking down houses, but they are also symptomatic of the lack of co-ordination between EWR Co. and the other planning authorities.
Here is another example of the issue. EWR Co’s preferred route goes through a station north of Cambourne and crosses the A428 with a long, skewed bridge just north of Highfields Caldecote (see blue route in Figure 2).
Figure 2 EWR Co Preferred Route Crossing the A428
However, the updated local plan has housing across the proposed route of the railway (See Figure 3).
Figure 3 GCSP Local Plan for the Same Area
Rate of Housing growth
The GCSP planners are estimating that to meet the demands of the local economy (i.e. the number of new jobs they foresee over the period) we need to add 1,771 houses per year over the next 20 years leading to a total of 48,794 houses from 2011 to 2041. This is a lot less than the 271,000 houses in the National Infrastructure Commission report (NIC Report) for this end of the EWR central section up to 2050.
It has been acknowledged that the case for the EWR central section depends on housing growth. For example, this is stated in the recent EWR video referred to earlier. In fact, it depends on the transformational housing growth put forward by the NIC report. However, if this level of growth is not going to come from the local plan where could it come from?
OxCam Arc Consultation
The Ministry of Housing Communities and Local Government (MHCLG) recently launched a consultation to help them shape the vision for the OxCam Arc. In section 5.8 of this document there is a rather hard-hitting paragraph:
“5.8 In parallel to the development of the Spatial Framework, the government is also exploring options to speed up new housing and infrastructure development in the Arc to help meet its ambitions, where evidence supports it. This includes examining (and where appropriate, developing) the case for new and/or expanded settlements in the Arc, including options informed by possible East West Rail stations between Bedford and Cambridge and growth options at Cambridge itself. The government will undertake additional Arc consultations on any specific proposals for such options as appropriate. The Spatial Framework will guide the future growth of the Arc to 2050, including on the question of new housing and infrastructure and will, as part of its development, take into consideration any significant new housing and infrastructure coming forward to meet the Arc’s ambition.”
They are reserving the right to add housing developments around EWR stations including at Cambridge itself. One assumes that, coming from central government, they would not be small developments. As pointed out by the county council it would be better for the transport infrastructure to fit around the housing plan rather than vice versa. Similar problems occur with the sites for schools and hospitals if the funding and hence the location is controlled by central government.
The housing plan proposed by GCSP considers environmental aspects by choosing dense developments often on brown field sites close in to Cambridge itself. If instead the plan is to be driven by the siting of EWR stations then these benefits will be lost.
Water Supplies
I was looking at the flow of water in the Cam this morning on Stourbridge Common near to Cambridge North Station. Viewed from a footbridge, there were various pieces of vegetation and sticks on the surface, but none of them were moving at all. A recent episode of BBC Radio 4’s Costing the Earth explains why this is happening. The chalk aquifers that feed the rivers having accumulated water over a very long time are now running dry because so much water has been abstracted by the water companies to serve new houses. There is also a waste water capacity problem which leads to overflow events into the rivers. Plans to fix these problems are being studied, but are not expected to be in operation until the 2030s.
GCSP commissioned a study from Stantec on the Water Supply in late 2020 which states:
For water supply, over-abstraction of the Chalk aquifer is having a detrimental impact on environmental conditions, particularly during dry years that may become more frequent due to the impacts of climate change. None of the growth scenarios considered here offer the opportunity to mitigate these existing detrimental impacts. Even without any growth, significant environmental improvements are unlikely to be achievable until major new water supply infrastructure is operational, which is unlikely to occur before the mid-2030s. Therefore, this analysis has focussed on a “no additional detriment” neutral position. To prevent any increase in abstraction and its associated detrimental environmental impacts, mitigation measures will be necessary. All stakeholders agree this should include ambitious targets for water efficiency in new development.
If there is already a problem that won’t be fixed for 15 years why are we planning to accelerate growth in the area now?
There are also significant problems with waste water and flood risk downstream in The Fens. The campaign group Friends of the Cam has a lot more on these issues.
Discussion
In summary, the business case for the EWR central section depends on the housing growth around stations. In South Cambridgeshire the updated local plan to 2041 has accelerated housing growth in Northstowe and Waterbeach new town while Cambourne, Eddington, North East Cambridge and East Cambridge have new developments. This is not at all consistent with EWR Co.s preferred route into Cambridge south.
The level of housing growth has been objectively assessed by the planning officers to meet the needs of the area although it is not clear how the water infrastructure will cope with any more growth. It is also not clear how anyone would objectively assess housing needs – it really depends what assumptions are made. Do we want this to be a high growth area if so why? Are we trying provide more homes for London commuters? Are we trying to encourage migration into the area from other parts of the UK and abroad? Which parts of the economy are we trying to stimulate? For more in depth discussion of why the OxCam Arc is not a good idea see this article. If you would like a say try filling in this 5 minute survey.
Will MHCLG add further housing via development corporations as indicated in their consultation? Well, speaking to Eversden Parish Council recently, Bridget Smith (Leader of South Cambs. District Council) reported the housing Minister, Chris Pincher as saying that there would not be houses in addition to those that the local authorities are planning for. It would be nice to see this in writing.
We conclude that either:
(A)There is no business case for the EWR extending to Cambridge on the southern approach because it will not enable much housing growth OR
(B) Central Government need to push through large housing developments around the proposed route of EWR over and above the needs of the local economy to service additional fast economic growth in the OxCam Arc not recognised by the local planners and to serve more London commuters.
Option A is a waste of public money, option B looks like being even less popular than the railway itself and does nothing for those parts of the county that need levelling up investment.
OxCam Arc Consultations
Given the above situation, one might expect that an MHCLG consultation about the OxCam Arc vision might set out some indicative scale of development around EWR stations. It is instead phrased around prioritising various features of the plan without really setting out the core proposition. See this brief BBC South News report for some detail on the controversy around this consultation. Perhaps MHCLG are taking it a step as a time, but they are so far behind EWR Co. that their spatial framework may not be able to influence the route of EWR. MHCLG’s consultation suggests development is to be set around EWR stations no matter how poor those sites are in planning terms.
We encourage you to respond to the MHCLG consultation by October 12th. The Stop The Arc Group have some great ideas about what you might like to say here, but please also use this post to relate your response to the EWR Central Section.
The Stop The Arc Group have produced a 5 minute survey about the OxCam Arc which asks people some of the more fundamental questions about the Arc. Cambridge Approaches had some minor involvement in the development of the survey and support it.
One of the early results of the 5 minute survey after 1500 responses is that over 90% of people would vote against the OxCam Arc if there was a referendum.
