Aims of RAG
The aims of the Railway Action Group are simple and just two:
1) To persuade Network Rail to meet its statutory obligations and ‘have regard to the purpose of
conserving or enhancing the natural beauty of AONBs.’
Section 85 of the Countryside and Rights of Way Act 2000 states: ‘In exercising or performing any functions in relation to, or so public bodies etc. as to affect, land in an area of outstanding natural beauty, a relevant authority shall have regard to the purpose of conserving and enhancing the natural beauty of the area of outstanding natural beauty.’
Network Rail is not having regard to either conserving or enhancing the natural beauty of the Goring Gap, in fact, quite the opposite. RAG simply wants NR to consider a better (ie less visually intrusive) overhead electrification design for 2 short stretches of the track as it passes through the Goring Gap. The 2 sections (approx. 1 mile in Goring and 1.3 miles in neighbouring South Stoke) are both on elevated sections and embankments where the visual impact of large metal structures is the greatest (See maps in ‘Documents & Downloads’).
There are alternative and much less visually intrusive designs currently in use on the Great Western Line. For instance, the high speed trains on the successful 15 minute, every 15 minute, Heathrow Express service, where 150 trains run every day between the airport and Paddington with 98% reliability.
(Data from ‘Heathrow Express Facts & Figures’).
Network Rail has no plans to replace the Heathrow Express infrastructure with the new one it is installing in the Goring Gap and throughout the rest of the line. It says it is not as reliable as the new system, but has not provided any comparative data to prove this. RAG has asked if a new design could be developed for highly environmentally sensitive locations, such as the Goring Gap, by simply improving this type of existing system rather than the ‘one-size-fits-all’ approach it is employing. This would then go towards meeting its legal obligations of ‘having regard for the natural beauty of the AONBs’ and minimise the adverse visual impact on the landscape in a stroke. Network Rail has not, and apparently, will not, commission its Swiss designers (Furrer & Frey) to produce a less visually intrusive system for AONBs.
The only mitigation Network Rail is offering is planting vegetation. NR has already removed almost all of the vegetation on its own land for operational reasons, the Environmental Statement [para 17.2.21] states that “Within South Oxfordshire, all woody plants and trees that are located within 6.6m of the outside rail on both sides of the track would be removed. The vegetation would be removed during construction and would not be allowed to grow back throughout the operation and maintenance of the Scheme. This vegetation clearance would extend along the entire route of the Scheme within South Oxfordshire at all locations.”
Network Rail wants to keep line sides and electrification wires permanently clear from trees, so it would need to buy adjacent land to plant large trees to have any chance of even partially masking the heavy metalwork.
2) To persuade Network Rail to rewind the clock and consult properly with the local authorities, the Chilterns Conservation Board and the North Wessex Downs AONB
No consultation happened with the Chilterns Consultation Board (CCB) before the installation of the infrastructure began. CCB only found about installation starting in the Goring Gap from local residents when it was underway and the metal goalposts started going up in Spring 2015. The design plans, finalised in December 2014, have still not been made publicly available. It seems clear from the extracts below that Network Rail has failed to consult properly, especially at a time which would allowed interested parties (stakeholders) an opportunity to influence the designs and plan within the Goring Gap.
During a meeting between Network Rail and RAG on 15 July 2015, a senior executive from NR said that the detailed design was still ongoing and that “we are doing a hand-to-mouth process; the design and implementation are to be done at the same time”.
Government guidelines on consultation for government departments and public bodies, such as Network Rail, states: ‘Timing of consultation - Engagement should begin early in policy development when the policy is still under consideration and views can genuinely be taken into account.’
Network Rail’s own specifications for consultation state:
Stakeholder engagement and consultation - In order for Network Rail to deliver its licence obligation with regard to the production and maintenance of RUS, stakeholder engagement will conducted throughout the process’. [Route Utilisation Strategies - Technical Guide 2009, Section 9.1]
Network Rail also states that:
‘The scheme will be delivered under our permitted development rights. However, the principles of good consultation, as set out in the Planning Act 2008, will be applied in order to assist in the project being managed responsibly.’ [Great Western electrification project ‘Frequently Asked Questions’].
The Planning Act 2008 states:
18. Early involvement of local communities, local authorities and statutory consultees can bring about significant benefits for all parties, by:
- helping the applicant identify and resolve issues at the earliest stage, which can reduce the overall risk to the
project further down the line as it becomes more difficult to make changes once an application has been
submitted;
- enabling members of the public to influence proposed projects, feedback on potential options.
The only mitigation Network Rail is offering is planting vegetation. NR has already removed almost all of the vegetation on its own land for operational reasons, the Environmental Statement [para 17.2.21] states that “Within South Oxfordshire, all woody plants and trees that are located within 6.6m of the outside rail on both sides of the track would be removed. The vegetation would be removed during construction and would not be allowed to grow back throughout the operation and maintenance of the Scheme. This vegetation clearance would extend along the entire route of the Scheme within South Oxfordshire at all locations.”
Network Rail wants to keep line sides and electrification wires permanently clear from trees, so it would need to buy adjacent land to plant large trees to have any chance of even partially masking the heavy metalwork.
2) To persuade Network Rail to rewind the clock and consult properly with the local authorities, the Chilterns Conservation Board and the North Wessex Downs AONB
No consultation happened with the Chilterns Consultation Board (CCB) before the installation of the infrastructure began. CCB only found about installation starting in the Goring Gap from local residents when it was underway and the metal goalposts started going up in Spring 2015. The design plans, finalised in December 2014, have still not been made publicly available. It seems clear from the extracts below that Network Rail has failed to consult properly, especially at a time which would allowed interested parties (stakeholders) an opportunity to influence the designs and plan within the Goring Gap.
During a meeting between Network Rail and RAG on 15 July 2015, a senior executive from NR said that the detailed design was still ongoing and that “we are doing a hand-to-mouth process; the design and implementation are to be done at the same time”.
Government guidelines on consultation for government departments and public bodies, such as Network Rail, states: ‘Timing of consultation - Engagement should begin early in policy development when the policy is still under consideration and views can genuinely be taken into account.’
Network Rail’s own specifications for consultation state:
Stakeholder engagement and consultation - In order for Network Rail to deliver its licence obligation with regard to the production and maintenance of RUS, stakeholder engagement will conducted throughout the process’. [Route Utilisation Strategies - Technical Guide 2009, Section 9.1]
Network Rail also states that:
‘The scheme will be delivered under our permitted development rights. However, the principles of good consultation, as set out in the Planning Act 2008, will be applied in order to assist in the project being managed responsibly.’ [Great Western electrification project ‘Frequently Asked Questions’].
The Planning Act 2008 states:
18. Early involvement of local communities, local authorities and statutory consultees can bring about significant benefits for all parties, by:
- helping the applicant identify and resolve issues at the earliest stage, which can reduce the overall risk to the
project further down the line as it becomes more difficult to make changes once an application has been
submitted;
- enabling members of the public to influence proposed projects, feedback on potential options.