Dear Sir/Madam,

Thank you for consulting HS2 Ltd on the above matter, we have the following comments and observations to make on the draft document.

As you are aware on 15 November 2016 the government formally announced the preferred route for Phase 2b of High Speed 2 (HS2). The announcement supersedes all of the maps previously produced in 2013 which can be accessed here for reference: https://www.gov.uk/government/collections/hs2-phase-2b-2013-route-announcement-documents.

On 17 July 2017 the Government introduced a Bill into Parliament for the Phase 2a route between Fradley in Staffordshire and Crewe in Cheshire. The Phase 2a route refinement changes around Crewe resulted in the need to revise Safeguarding Directions for Phase 2b. Revised Safeguarding Directions were subsequently issued to reflect these route changes and came into force on 27 September 2017, replacing those previously issued to local planning authorities on 17 July 2017.

These Safeguarding Directions have been issued in order to protect the entire preferred Phase 2b route of HS2 from conflicting development. Safeguarding is an established tool of the planning system designed for this purpose and aims to ensure that new developments along the route do not impact on the ability to build or operate HS2, or lead to excessive additional costs. The full package of supporting documents and guidance for local planning authorities can be downloaded from the HS2 dedicated safeguarding website pages at: https://www.gov.uk/government/collections/hs2-safeguarding.

When the Secretary of State for Transport decided to issue Safeguarding Directions for the preferred 2b route of the railway in July 2017, an Impact Assessment was undertaken (see: https://www.gov.uk/government/publications/hs2-phase-2b-crewe-to-manchester-and-west-midlands-to-leeds-safeguarding-impact-assessment). With reference to the summary section of the Assessment you can see that as well as preventing conflicting development that may otherwise affect the construction or operation of the railway, the Directions were also issued in order to avoid the associated costs to developers as well as to the HS2 project.

The published HS2 guidance on Local Plans offered to Local Planning Authorities in advice accompanying the formal Safeguarding Directions states amongst other things:

23. In preparing any Development Plan Document (an area's Local Plan), the area safeguarded by the Safeguarding Directions should be taken into account. Where a Safeguarded Direction is taken into account in a Local Plan, it should be represented on the Policies Map (in accordance with Regulation 9 of the Town and Country Planning (Local Planning) (England) Regulations 2012 (as amended)).

24. Adding information about the extent of the safeguarded area on the Policies Map is helpful for those considering development in the area. However, it is important to note that the requirements of the Safeguarding Directions apply, in the circumstances described above, regardless of whether the safeguarded area is identified on the Policies Map.

25. Local Plans should state that the Safeguarding Directions have been made by the Secretary of State for Transport. They are not proposals of the LPA and the route in question will not be determined through the development plan process. The route will be considered in Parliament under hybrid Bill procedures, which will provide appropriate opportunities for petitions to be made to Parliament by those directly affected by the scheme.

From an initial look at the document and Key Diagram on p24 sadly above guidance has not been followed as although existing railways are shown, the proposed Phase 2b route of HS2 is not. Furthermore no specific references appear to be made to the HS2 scheme in the draft local plan, which is an oversight given it is formally safeguarded as a nationally significant infrastructure project.

HS2 Ltd looks forward to further consultation on the Submission Draft Local Plan in due course and also encourages the Council to follow ongoing progress of the HS2 programme. In meantime should you have any queries regarding the above comments then please do not hesitate to contact me at: town.planning@hs2.org.uk.