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IN PARLIAMENT HOUSE OF COMMONS SESSION 2014 - 2015 HIGH SPEED RAIL (LONDON -WEST MIDLANDS) BILL SKELETON SUBMISSIONS ON BEHALF OF HS2 ACTION ALLIANCE ON STANDING 1. This skeleton outlines HS2 Action Alliance's submissions to the Select Committee on Stn July 2014 in response to the Secretary of State's Notice of Objection. 2. The Notice of Objection raises two points: (a) HS2 Action Alliance do not have and should not be given locus standi (para 1-7, 10); (b) The matters in the petition are principally ones which `affect the public at large' and the Select Committee cannot consider matters which may be considered by a Standing Committee (para 8) and that `certain' (but unidentified) objections go to the principle of the Bill (para 9). Standing (locus standi) 3. There are two types of standing: standing as of right where the petitioner's property or interests are directly and specially affectedl or where the Standing Orders give an entitlement 2 to be heard; and standing granted by the committee. 3 In the latter cases, standing has been given without a hearing, in the absence of a challenge. 4. The Select Committee is asked to admit HS2 Action Alliance to be heard as an association representing interests in the districts to which the Bill relates (SO 95(1)) and representing the inhabitants of areas alleged in the petition to be injuriously affected by the Bill (SO 96(2)). In the Standing Orders as in legislation generally, 4 singular includes plural, so an organisation representing inhabitants or interests across a long line is within these provisions. 5. The facts of this representation are set out in the petition (paragraphs 60 to 61) and elaborated upon in Hilary Wharf's witness statement. In addition letters from action 1 Erskine May page 958. 2 Standing Orders 93, 97, 102. 3 Under Standing Orders 92, 95, 96, 99, 100, 101. 4 Interpretation Act 1978.

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IN PARLIAMENTHOUSE OF COMMONSSESSION 2014 - 2015

HIGH SPEED RAIL (LONDON -WEST MIDLANDS) BILL

SKELETON SUBMISSIONS ON BEHALF OF HS2 ACTION ALLIANCE ONSTANDING

1. This skeleton outlines HS2 Action Alliance's submissions to the Select Committee on

Stn July 2014 in response to the Secretary of State's Notice of Objection.

2. The Notice of Objection raises two points:

(a) HS2 Action Alliance do not have and should not be given locus standi (para 1-7,

10);

(b) The matters in the petition are principally ones which ̀ affect the public at large'

and the Select Committee cannot consider matters which may be considered by a

Standing Committee (para 8) and that ̀ certain' (but unidentified) objections go to

the principle of the Bill (para 9).

Standing (locus standi)

3. There are two types of standing: standing as of right where the petitioner's property or

interests are directly and specially affectedl or where the Standing Orders give an

entitlement2 to be heard; and standing granted by the committee.3 In the latter cases,

standing has been given without a hearing, in the absence of a challenge.

4. The Select Committee is asked to admit HS2 Action Alliance to be heard as an

association representing interests in the districts to which the Bill relates (SO 95(1))

and representing the inhabitants of areas alleged in the petition to be injuriously

affected by the Bill (SO 96(2)). In the Standing Orders as in legislation generally,4

singular includes plural, so an organisation representing inhabitants or interests across

a long line is within these provisions.

5. The facts of this representation are set out in the petition (paragraphs 60 to 61) and

elaborated upon in Hilary Wharf's witness statement. In addition letters from action

1 Erskine May page 958.2 Standing Orders 93, 97, 102.3 Under Standing Orders 92, 95, 96, 99, 100, 101.4 Interpretation Act 1978.

groups and residents directly affected by the scheme explain that HS2 Action Alliance

represent them, see the appendices to Ms Wharf's statement. Some of those residents

and groups have petitioned themselves and their standing is not challenged. It follows

that HS2 Action Alliance represent persons who do have standing. The Secretary of

State (through Mr Mould QC) explicitly accepted in the High Court that HS2 Action

Alliance represents the interests of village residents associations and individuals

affected by generalised blight.5

6. HS2 Action Alliance's contribution to the scrutiny of HS2 has been accepted and

welcomed by Parliamentary Committees, the Courts, the Secretary of State and HS2

Limited.6 This Select Committee invited HS2 Action Alliance to attend and speak at

the programming hearing and we did so.

7. The special role of HS2 Action Alliance in contributing to the Committee's processes

is recognised by:

(i) The letter from Rt Hon John Bercow MP, Rt Hon Cheryl Gillan MP

and Rt Hon David Liddington MP and from the 51 M group of local

authorities (both dated 30th June 2014) explaining their helpful and

representative role and supporting their standing;

(ii) The local residents and groups who explain that they have not

petitioned on particular matters because they were being taken by the

HS2 Action Alliance in its petition. They were sensibly leaving

matters to the route-wide scope and the pooled expertise of HS2

Action Alliance

8. The Secretary of State did not object to HS2 Action Alliance's presence and role at

the programming hearing. If he considered that we should not be heard by the

Committee then he should have taken the point prior to or at that hearing.

9. The hybrid Bill process needs to achieve the objectives of the Environmental Impact

Assessment Directive for the exception to the Directive's requirements to apply. A

failure to be within that exception would mean that a planning permission or

development consent order would be needed (going through fresh processes) to

5 See Mr Mould's submissions in the High Court.6 See petition para 64.~ EIA Directive, Article 1(4).

authorise the works and the compulsory purchase powers could not be exercised

before that further authorisation was in place.

10. Giving effect to the requirements of the Aarhus Convention, the EIA Directive gives a

special status to the ̀ public concerned' who are ̀ the public affected or likely to be

affected by, or having an interest in, the environmental decision-making procedures

referred to in Article 2(2).g For the purposes of this definition, non-governmental

organisations promoting environmental protection and meeting any requirements

under national law shall be deemed to have an interest.'9 The status of environmental

NGOs, such as HS2 Action Alliance, is the same as the public affected by the

proposal —that is, those entitled to locus standi. It is the public concerned who are

entitled to `early and effective opportunities to participate in the environmental

decision- making procedures' and consultation10 and their views require particular

consideration.l l Whilst the principle of the Bill is considered by the House at Second

Reading, detailed environmental impacts and the measures to address them are

considered by the Select Committee. The roles of the Public Bill Committee and

Report stages are inevitably more general. The Select Committee can only deal with

points raised by petitioners — it does not have a roving brief —and so the public

concerned must have standing to petition on environmental matters.

11. In achieving the objectives of the EIA Directive the Secretary of State for Transport

has relied in Court on the Select Committee process and in particular national non-

governmental organisations such as Save Britain's Heritage and the Ramblers

Association participating at the Crossrail Bill Select Committee stage.12

$ Derived from Article 2(5) of the Aarhus Convention.~ Article 1(2)(e).10 Article 6(4), (5), for example by written submissions or by way of a public inquiry.11 Article 9(1).12 R(Buckinghamshire County Council) v Secretary of State for Transport [2013] EWHC 481 (Admin) perOuseley J summarising the Minister's submissions ̀ 256 The Select Committee would be an important part ofthe overall process in the eyes of the SST; "authorities concerned by the project by reason of their specificenvironmental responsibilities", who had to have an opportunity to express their views on the environmentalinformation and the request for development consent, (Article 6), would have locus standi at the SelectCommittee. The range of persons with locus under Standing Order 96 was extensive since it covered thosewhose property interests were specifically and directly affected, trade bodies representative of those affected inan area, bodies representing amenity, educational, travel or recreational interests which were materiallyadversely affected, local authorities of any area affected injuriously, the inhabitants of such an area, commonsConservators and the like.257 It was up to the promoter to take a locus objection; none had been taken on the Crossrail Bill. NGOs such asSave Britain's Heritage and the Ramblers Association had participated at the Committee stage. Published rulesgoverning participation at an oral stage before the decision-maker were not incompatible with the objectives ofthe Directive.'

3

12. The Select Committee are therefore asked to recognise or grant HS2 Action

Alliance's standing to petition on the Bill.

The scope of the Select Committee's consideration of the Bill

13. There are two limits on the matters which may be raised by petitioners:

(i) They may not argue on matters which do not give them locus standi including

matters affecting the general public;13

(ii) The Committee should stay within the instructions given by the House,

including any instruction as to the principle of the Bill.

14. The concept of the principle of the Bill requires elaboration. The Committee on

Hybrid Bills (Procedure in Committee) Report in 1948, subsequently adopted by the

House, decided that ̀ provided that his arguments do not exceed his locus standi, a

petitioner may traverse the principle of the Bill'.14 In reality the point on principle is

three-fold:

(i) The expediency of the Bill does not have to be proved by the promoter;

(ii) a petitioner may not challenge the public policy decision of the House at

Second Reading15 but may argue about the expediency of the Bill insofar as it

affects it interests including contending that this hardship outweighs the public

benefits; i 6

(iii) The Committee cannot consider matters that it is instructed not to —such as the

principle set out by the House's resolution. Although it can ask the House to

instruct it to consider matters it could not otherwise do.17

15. In practice therefore, the House's instructions limit the scope of the consideration.

16. The application of these conceptual issues is however straightforward for this Bill.

The Court of Appeal and the Supreme Court did not consider whether and how standing would comply with theEIA Directive.13 See the Committee on Hybrid Bills (Procedure in Committee) Report ("the Report") para 21, 34(2), adoptedby the House on 14t" February 1949.14 Report, Para 34(3).is For example, in support of the nationalisation of private companies, but it would be possible to challenge theprinciple of a Bill to acquire land for a particular purpose —see the Report at para 22, 23.16 If such an argument is accepted then the committee would make a special report to the House: Report, para25." Such as the third Instruction to the Crossrail Bill Select Committee to consider extending Crossrail to Readingor Ebbsfleet: Select Committee on the Crossrail Bill, First Special Report of Session 2006-07, para 30, 31.

4

17. The Bill does not affect `the public at large'. It is almost all concerned with the

construction and operation of a particular proposed railway line between the West

Midlands and London. Its powers, impacts and mitigation measures affect interests

on or in the vicinity of the line, including those represented by HS2 Action Alliance.

Whilst many of those are expressed in general terms, they may be petitioned against.

The exception to the Phase 1 project is the right of entry for further high speed rail

links (clause 51) but that specifically affects interests on or near the proposed Phase 2

route so gives standing to those interests. As an integrated route, many of the design

parameters for Phase 2 will be fixed by Phase 1.

18. The particular concerns of petitioners maybe met by general solutions. The Secretary

of State will argue that many concerns are addressed by the general provisions in the

Bill, the general law and by the measures outside the Bill such as the Environmental

Minimum Requirements. The Committee will have to consider their adequacy. It

may find that a particular petitioner's concern should be met by a general amendment

to the Bill.18 In considering whether to make any change, it must address the public

benefits and disbenefits of the existing provision and the possible amendment as well

as the effect on the private or local interests involved.

19. The Secretary of State's Notice of Objection is inadequate and defective as it does not

identify the parts of the petition to which the Minister objects. It should have, shortly,

spelt out the paragraphs or the points so that HS2 Action Alliance could deal with

them.

20. The matters raised in the petition are all ones which affect the interests which it

represents and on which it has standing and which do not contravene the principle of

the Bill. For example, a reduction in the speed of the line will reduce noise impacts

on residents and allow greater flexibility in the detailed alignment of the line (within

the broad route alignment) allowing impacts to be avoided or reduced. One of the

effects of lower speed, which would have to be considered in making that change is

the reduction in carbon emissions which results. The enforcement of the

environmental protections proposed and compensation arrangements are

commonplace matters for railway bill select committees.

i$ Such as limiting the period for compulsory acquisition: Crossrail Select Committee, First Special Report ofSession 2006-07, para 118.

21. The petition of the HS2 Action Alliance is therefore firmly within the scope of its

standing and the Select Committee's deliberations.

Costs

22. This standing challenge imposes a significant drain on the finances of the HS2 Action

Alliance and so hinder its ability to present a properly funded case on the merits of the

petition. Inflicting the costs of this satellite litigation upon HS2 Action Alliance

undermines their ability to participate and the effectiveness of the process, contrary to

the EIA Directive and the Aarhus Convention.19 The Select Committee are able to

award costs against the promoter.20 The raising of the standing challenge by the

Secretary of State is vexatious and unreasonable.21 In this case a costs order should

not depend upon whether HS2 Action Alliance are able to secure amendments to the

Bi1122 as the effect of this challenge is to reduce its ability to secure those

amendments.

23. The Select Committee are therefore asked to require the Secretary of State to pay the

petitioner's reasonable costs of this issue if the notice of objection fails.

Richard Harwood OBE QC

Thirty Nine Essex Street

4th July 2014

t~ EIA Directive Article 6 (see Commission v Ireland C-216/05 para 43-45) and Aarhus Convention Article 6.zo Select Committee on the Crossrail Bill, First Special Report of Session 2006-07, para 121-123.zl To adopt the language for private Bills in section 10, Parliamentary Costs Act 2006.22 Which is the additional criteria for private Bill costs awards under the 2006 Act.

C~

HOUSE OF COMMONSSESSION 2013-14

HIGH SPEED RAIL (LONDON-WEST MIDLANDS) BILL

Notice of Objection

to the

locus standi

of

HS2 ACTION ALLIANCE LIMITED

WITNESS STATEMENT OFHILARY WHARF

1. I, HILARY WHARF, am a director of HS2 Action Alliance Limited (HS2AA). HS2AA was

incorporated on 19 April 2010 as a company limited by guarantee with a registered office at The

Red House 10 Market Square, Old Amersham, Buckinghamshire, HP7 ODQ.

2. HS2AA is a not for profit organization, with all funds received spent on its objectives and does not

undertake any commercial activities. HS2AA's activities are overseen by five directors -Bruce

Weston, Hilary Wharf, Thomas Crane, Andrew Bodman and Graham Long, who all serve without

remuneration on a purely voluntary basis. Four of the five directors live very near the proposed

route of Phase 1 of HS2. In particular, Bruce Weston and I, who are the only members of the

limited company, both live within 300m of the proposed route of Phase 1 of HS2 and are specially

and directly affected by HS2. Our home falls within the zone of the proposed "home owner

payment" for those properties which are close to the route of HS2.

Objectives

3. HS2AA was set up with the objects stated in Clause 3.1.1 of its articles, namely:

"to question and evaluate the economic case and environmental impact of the proposals for the

HS2 rail link and to communicate the facts about the HS2 rail link in a clear, accurate and timely

manner,

to facilitate co-ordination of community level organisations, specialist companies and government

groups to ensure efforts are maximised without duplication and to pool the best resources and

talent,'

to investigate and implement ways of minimising any adverse impacts the HS2 Rail Link may have

on individuals, communities and the environment."

4. HS2AA was not therefore specifically setup in 2010 to object to the HS2 project.

H2953/00004/76963290 v2 ~ PH/CFS/03 July 2014

5. HS2AA initially worked exclusively on matters of compensation, seeking to develop better

compensation for the generalised property blight caused by the announcement of the preferred

route of Phase 1 of HS2 in March 2010, and the accompanying compensation proposals for an

Exceptional Hardship Scheme. It proceeded from this to explore the economic case for HS2, on

which it was agnostic until detailed investigation demonstrated that it lacked a credible economic,

social or environmental justification. Since then (summer 2010) HS2AA has opposed HS2, but has

continued to represent the interests of those with properties near the line through its pursuit of

better compensation and environmental mitigation. Better compensation and improved

environmental mitigation are the objectives of HS2AA's petition.

6. From the outset, HS2AA has focused on an evidence-based approach, seeking to apply rigorous

standards of research to explore and subsequently challenge the claims made for the HS2 project.

Role

7. The role of HS2AA is to provide a national organisation, capable of raising funds, undertaking

detailed research, utilizing and co-ordinating the expertise of those on the route, building broader

alliances with other groups and representing the interests of those specifically and directly affected

by engaging with decision makers and the press on HS2. HS2AA has also mounted challenges

where it believes the Secretary of State for Transport has acted unlawfully. This contrasts with

local action groups, who are locality-focused.

8. HS2AA has engaged with Parliament and the broader decision making process on HS2. HS2AA

has provided detailed written submissions to the House of Commons Transport Select Committee

(May, June 2011, November 2013) as part of its review of the proposals for HS2. HS2AA

undertook detailed work to establish the facts on capacity on the West Coast Main Line, including

commissioning an independent report on passenger numbers (December 2011) and producing a

detailed response to the Government's consultation on high speed rail (July 2011). HS2AA gave

evidence to the National Audit Office (2012/13); provided responses to the Safeguarding

Consultation (January 2013); the Draft Environmental Statement Consultation (July 2013); the

Phase 1 Environmental Statement Consultation (February 2014), and the Phase 2 consultation

(January 2014). In addition Bruce Weston of HS2AA was asked to give evidence to the House of

Commons Transport Select Committee (September 2011) as part of the Committee's work on

HS2 and Emma Crane of HS2AA was asked to provide evidence to the HS2 (Preparation) Bill

Committee (July 2013), and the Environmental Audit Committee on HS2 (March 2014). Hilary

Wharf of HS2AA was asked to appear before the Hybrid Bill Select Committee in May 2014.

HS2AA has also engaged directly with HS2 Ltd, the various Secretaries of State for Transport and

Department for Transport. There is a large volume of correspondence contributed by both sides.

9. HS2AA has also been centrally involved in proposals for better compensation arrangements

representing the interests of communities and households blighted by HS2. This has included

H2953/00004l76963290 v.2 ~ PH/CFS/03 July 2014

championing proposals for a property bond to deal with the problem of generalised blight; taking

up issues raised by affected individuals; requiring further data to be published on blight

necessitating an extension to the consultation period; and successfully challenging the 2012

decision on compensation in the courts. HS2AA has worked with property professionals and other

experts on blight issues, conducted surveys, met with representatives of the Department for

Transport, including the Secretary of State for Transport and the Promoter. The Department for

Transport agreed that HS2AA's proposals for a property bond, which reflects private sector best

practice, should be one of the proposals consulted on in the 2011 consultation on high speed rail.

HS2AA has provided detailed responses to the five consultations on compensation (covering the

Phase 1 and 2 Exceptional Hardship Schemes in 2010 and 2013), and the long term proposals (in

2011, 2012, 2013) raising the many concerns expressed by its constituent individual supporters

and its affiliated groups, who are specially and directly affected.

Registered individual supporters and affiliated groups

10. HS2AA operates on the basis that individuals can become registered supporters by signing up at

www.hs2aa.or_y/signup or organisations which agree with the objectives of HS2AA can become

affiliates, who may be viewed at http://www.hs2actionalliance.org/local-_ rq oups/ .

11. HS2AA currently has over 100 organisations signed-up as affiliates. A list of those affiliates is

contained in Appendix 1. Affiliates of HS2AA receive regular campaign updates, they help with

fund raising by donating to HS2AA and contribute ideas, comments, information and evidence for

the HS2AA submissions and analysis it develops and publishes. Affiliates include local anti-HS2

action groups, parish councils and other residential associations and organisations. It is difficult to

put a precise figure on the number of people represented by HS2AA's affiliates but it is reasonable

to assume it is many thousands —given the large number of organisations, the localities they

represent, the impact of the 300 mile high speed line in these areas, and the known number of

properties that lie within 1 km of the line or 250m of a bored tunnel (172,000 within phase 1 alone).

12. HS2AA currently also has over 15,000 individuals who have signed up as registered supporters. A

significant proportion of HS2AA's registered supporters live in communities close to the proposed

route, both on Phase 1 and Phase 2. HS2AA's registered supporters campaign against HS2,

engage with their elected representatives on HS2, as well as engaging with HS2AA, and provide

donations to HS2AA. HS2AA volunteers also provide assistance to registered supporters faced

with difficult personal circumstances due to blight. HS2AA also pools and follows up on ideas and

issues raised by its registered supporters and affiliates, and gives guidance on responding to the

numerous consultations since 2010, as well as utilising web tools to aid individuals responding.

13. HS2AA represent these groups and individuals on matters related to the Hybrid Bill, seeking in

particular better compensation and mitigation for those specially and directly affected by the

proposed works and operations. That HS2AA represent these groups and individuals is evidenced

by the letters stating just this, sent by affiliated groups and registered individuals in support of

H2953/00004/76963290 v2 ~ PH/CFS/03 July 2014

HS2AA's right to be heard by the Select Committee. Examples of these letters can be found in

Appendix 2 along with letters from John Bercow MP, Cheryl Gillan MP, David Lidington MP,

Andrea Leadsom MP, Michael Fabricant MP, Chris Pincher MP, Jeremy Lefroy MP Frank

Dobson MP and Councillor Martin Tett —Chairman of 51 m.

14. The current Hybrid Bill process concerns (inter alia) how the adverse environmental impacts of

HS2 can be more appropriately mitigated. Petitioning has a crucial role in seeking deficiencies in

the Environmental Statement be put right and more appropriate and superior mitigation

introduced. A problem with the Environmental Statement and the mitigations contained in bill is

that the issues are often highly technical and are beyond the expertise of any single affected

individual. Obtaining specialist technical advice on the environmental impacts covered in the

Environmental Statement is also beyond the financial capability of all but the most wealthy

individuals and local groups. In this context, HS2AA has served the crucial role of employing

experts on behalf of the groups and individuals it represents, and responding to the Draft

Environmental Statement and Environmental Statement from an expert perspective, exposing the

inadequacies of the proposed mitigations. HS2AA's petition seeks that the systematic

understatement of adverse environmental impacts be corrected. The understatement arises from

misapplications of national policies, the failure to correctly implement environmental legislation,

and disregard for the unfairness of imposing property blight without adequate compensation. Its

consequence is that the Hybrid Bill proposes needlessly bad environmental impacts and

inadequate mitigation.

15. HS2AA notes that the Promoter is now contesting that HS2AA represent people who are specially

and directly affected when in front of Mr Justice Ouseley, Mr Mould QC, for the Secretary of State,

argued that HS2AA did represent groups and people affected by property blight. In particular he

stated at the High Court hearing on compensation:

".... the claimant ~HS2AAJ is clearly representing a wide range of interests, including the interests

of village residents association, and indeed individuals, who are concerned about the impacts of

the proposed railway from London to Birmingham on their property values." (transcript of Judicial

Review, 13 December 2012, page 42 lines 7-12)

And again:

"... In other words, in its representative capacity, the alliance was able to say that all that it wished

to say on, firstly, the principle of a generalised blight discretionary package. Secondly, on the

relative merits of the components of such a package, responding to the options set out by the

Secretary of State in annexe A, and thirdly, to explain in detail why, in the alliance's judgment, the

property bond component should be included as the optimal solution to meet the principle of fair

compensation that it said was appropriate, in order to alleviate generalised blight. ..." (page 68,

lines 6 to 17)

H2953/00004/76963290 v2 ~ PH/CFS/03 July 2014

16. Of course, as Mr Wolfe, QC, (acting for H52AA at the same hearing) stated, HS2AA is

representative in the way of "an umbrella representative organization", which does not mean that

the local groups and individuals represented cannot have their own separate views, as indeed

they do, or that they are represented in the way that a level of government represents them. The

Promoter previously concurred with our affiliates and individual supporters that HS2AA represents

a large number of people who are specially and directly affected on the matters on which HS2AA

is petitioning.

Petitioning

17. The Government's submissions in the course of judicial proceedings highlighted the importance of

the petitioning process to raising concerns about the environmental impacts of Phase 1 of HS2

and ensuring better mitigation arrangements. HS2AA therefore applied to the Legal Services

Commission to obtain legal aid for the preparation of a petition on key route wide environmental

impacts. This application was declined. HS2AA was therefore required to identify a limited

number of route wide issues upon which it could utilise its financial resources —which were

landscape, carbon, noise, waste, and biodiversity. By pooling the donations of many hundreds of

individuals and groups, HS2AA was able to commission specialized reports from known experts in

each of these fields. These reports were detailed in HS2AA's Environmental Statement response

and formed the basis of HS2AA's petition.

18. HS2AA`s petition therefore built on the information set out in the response to the Environmental

Statement to argue for three key items:-first that the Environmental Statement be done properly;

second that the speed of HS2 be reduced from 400 km/h to 300 km/h; and third that an

independent ombudsman body be created to oversee mitigation and environmental impacts

effectively. Having an adequate Environmental Statement enables the Select Committee to

evaluate the petitions and for Parliament as a whole to perform its function of adequately

scrutinising the Bill. Reducing the speed of HS2 gives greater flexibility in the route, within the

broad alignment, and so enables impacts on individual residents and property owners —including

other petitioners — to be reduced or avoided. Even with the same route, a reduction in speed will

benefit those living and working in the vicinity. The nature and effectiveness of the mitigation

measures is a critical issue for many petitioners and part of that is the nature of the regulator who

will enforce the requirements. The petition made no suggestion that the line should not be built nor

did it advance any argument against the principle of the Hybrid Bill.

19. In the event that HS2AA's petition is not heard, the Select Committee will not hear from the

experts on the issues highlighted above and hear the arguments as to why each of the requests in

the petition be implemented. Given the complexity and costs involved in bringing these matters to

the Committee, the effect will be to disenfranchise the thousands of people who are registered

supporters or affiliates of HS2AA, and in particular those individuals and affiliated groups who

have relied on the HS2AA petition to take these route-wide points and have not covered them in

their own petitions. A number of the letters included in Appendix 2 make this point.

H2953/00004/76963290 v.2 C PH/CFS/03 July 2014J

believe that the facts stated in this witness statement are true.

Signed

frr~~ ,

Hilary Wharf, Director, HS2AA

Date: 4 July 2014

H2953/00004/76963290 v2 G PH/CFS/03 July 2014

Appendix 1

HS2AA Affiliated Groups

Affiliated member groups include action groups, residents' associations, societies, parish councils andother locally based organisations.

Phase OneEuston Against HS2 Ballinger Road Residents Boddington Parish Council

Association

Stalbridge House Residents Lappetts Lane Neighbourhood Priors Hardwick Stop HS2Association Watch Scheme Action Group

Pan Camden HS2 Alliance Wood Lane Residents Ladbroke HS2 Action GroupAssociation

Camden Cutting Group Speen Area Action Group Southam Area Action Group

Gloucester Avenue Association Chiltern Countryside Group Offchurch Action Group

The Park Village (and Environs) Chiltern Ridges HS2 Action Weston under WetherleyResidents' Association Group Action Group

North Westminster Against HS2 Cholesbury Action Group Cubbington Action GroupAction Group Against HS2

North Ealing Against HS2 The Dunsmore Society Stareton Action Group

South Ruislip Residents HP22 6PN Wendover Action Stoneleigh HS2 Action GroupAssociation Group

Ruislip Against HS2 Wendover HS2 Kenilworth Stop HS2 ActionGroup

Hillingdon Against HS2 Wendover Society Crackley Residents Association

Ickenham Residents Association Stoke Mandeville Action Group Burton Green HS2 ActionGroup

Denham Against HSZ The Aylesbury Society Balsall Common VillageResidents' Association

Harefield Against HS2 Pitchcott Parish, Aylesbury Berkswell Society

Chalfonts NO to HS2 Quainton and Waddesdon Berkswell Parish CouncilAction Group

HS2 Amersham Action Group Twyford HS2 Action Group Heart of England High SpeedRailway Action Group

Amersham and District Residents' Godington Action Group Hampton in Arden ParishAssociation CouncilLittle Missenden Stop HS2 Preston Bissett Action Group Water Orton Stop HS2 Action

Group

Little Kingshill Village Society Chetwode Action Group Middleton Action Group

Hyde Heath Village Society Beachampton Action Group SNOW (Action groups in NorthWarwickshire &Staffordshire)

H2953/00004/76963290 v2 .~ PH/CFS/03 July 2014

Barn Management UK 2 Villages of OxfordshireOpposing HS2

Drayton Bassett HS2 ActionGroup

South Heath Action Group Turweston Action Group Hints and Area against HS2

Great Missenden Stop HS2 Transport Sense Tamworth Action Group

Residents' EnvironmentalProtection Association

Greatworth Action Group Whittington &Lichfield STOPHS2 Action Group

Patter Row Action Group South Northamptonshire ActionGroup

Fradley & Streethay ParishCouncil (Lichfield)

Aston-le-Walls HS2 ActionGroup

Kings Bromley Stop HS2Action Group

Phase Two Manchester

Ridwares Against HS2 Swynnerton HS2 Action Group Agden, Broomedge and LymmEast

Colton Against HS2 Whitmore Heath & BaldwinsGate HS2 Action Group

Warburton HS2 Action Group

Ingestre and Tixall Against HS2 Madeley Stop HS2 ActionGroup

Rixton with Glazebrook HS2Action Group

Staffordshire Against HS2 (Phase2 Staffordshire groups)

Mid Cheshire Against HS2 Culcheth and District RailAction Group

Hopton Against HS2 One Voice Against HS2 inCheshire

Lowton East NeighbourhoodDevelopment Forum

Marston Against HS2 HS2 Parish Council ActionGroup Cheshire East

Phase Two Leeds

Kingsbury and District HS2Campaign Group

Strelley Action Group Altofts and Kirkthorpe AgainstHS2

Polesworth &District ActionGroup Against HS2

& The YRoute

Killamarsh & Renishaw HS2

Action GroupSwillington, Oulton &Woodiesford HS2 ActionTogether

Tonge & Breedon HS2 ActionGroup

STOP HS2 South Yorkshire Church Fenton says NO toHS2 Action Group

H2953/00004/76963290 v.2 p PH/CFS/03 July 2014

Appendix 2

Letters from MPs, 51 m, Affiliated Groups and Registered Supporters

John Bercow MP, Cheryl Gillian MP and David Lidington MPAndrea Leadsom MPMichael Fabricant MP, Chris Pincher and Jeremy Lefroy MPFrank Dobson MPNatascha Engel MPNick Hurd MP51 m Group

Affiliated Groups:Camden Cutting GroupHillingdon Against HS2Denham Against HS2Residents' Environmental Protection AssociationChiltern Ridges HS2 Action GroupWendover SocietyTransport SenseCubbington Action Group Against HS2Heart of England High Speed Rail Action GroupMiddleton Action GroupLadbroke Action GroupSoutham Area Action groupOffchurch Action GroupHints and Area Against HS2Kings Bromley Stop HS2 Action GroupMid Cheshire Against HS2Tonge and Breedon HS2 Action GroupKillamarsh and Renishaw HS2 Action GroupChurch Fenton says NO to HS2

Registered Supporters:Andrew JamiesonAnn and David OutenBeverley MantonCatherine LeaChristopher TriffittChristopher WilsonCreak familyDan MitchellDavid StarrGareth and Stefanie BuckleyGordon FindlayJerry MarshallJohn and Patsy HingsJohn DonovanJohn LeeKeri BrennanKip WarrMargot Barnikel (Mrs)Martin NealMichael JepsonMichael JohnstonePam MatherPauline and John HughesProf Mike GeddesRose-Marie AdamsRosemary Guiot

H2953/00004/76963290 v2 n PH/CFS/03 July 20147