51m response to the
Property Compensation
Consultation
December 2013
51m is the cross party alliance of nineteen local
authorities reviewing and challenging the case for HS2.
Each Council has signed up to the following position statement:
“We are opposed to the current high speed rail proposals as they are presently outlined and
do not believe that they are in the best interests of the UK as a whole in terms of the benefits
claimed in the business case.
We are not opposed to the need for higher speed rail per se and fully acknowledge the need
for strategic improvement to the national rail infrastructure but cannot agree with the
current proposals as the economic and environmental benefits are not at all credible.
We do not believe that all the other alternatives to achieve the transport capacity,
regeneration and environmental benefits have been fully explored by the Government and,
with in excess of £30 billion (now £50 billion), proposed to be invested, we owe it to the
nation to ensure these are fully explored.”
Introduction
51m is submitting this response to the Property Compensation Consultation on behalf of all
affiliated local authorities. It seeks to respond to the questions set in the consultation
document and comment in more detail on those aspects of the proposals that are of specific
concern to the 51m alliance.
The Government is presenting the latest property compensation proposals as a major
improvement on those set out in the consultation document published in October 2012.
Such a portrayal is inaccurate since there is very little difference between the current and
previous consultation and the only reason for carrying it out is the High Court ruling in
March 2013 (Mr Justice Ouseley concluding “The consultation process in respect of blight
and compensation was all in all so unfair as to be unlawful.”).
51m notes the statement at paragraph 2.1.5 that “These proposals are a response to the
exceptional nature of HS2 and should not be seen as setting a precedent for current or
future infrastructure schemes.” Its size, scale and impacts means HS2 must be treated as a
unique project and not compared with other smaller and more local infrastructure projects.
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The Government and 51m recognise that it is a basic human right for people to enjoy their
property. Individuals should be free to move, down-size and / or re-mortgage without
becoming trapped in properties with uncertain future values, impacted by blight and
disruption. Those most likely to be affected will live closest to the line, with more than
172,000 properties within one kilometre of the Phase 1 HS2 route.
For people across Phase One from London to Birmingham, who may lose their home,
business or community facility the detail of these proposals is very important. 51m believes
that the compensation measures proposed are inadequate, failing to address blight and
disruption. Applying the proposals suggested means that less than 2% of properties within
one kilometre of HS2 would receive any form of compensation.
HS2 has repeatedly tried to improve its business case by inflating potential benefits and by
ignoring very real costs. 51m is concerned that HS2 may be seeking to further enhance the
business case, boosting the cost benefit ratio, by severely restricting monies available for
compensation. If HS2 is truly in the national interest, then householders should not be
expected to bear the burden of their own losses.
Whilst the proposals cover a limited number of individual households, they do very little to
compensate landlords, businesses and communities blighted and disrupted during the
construction phase. A more comprehensive approach to compensation must be developed
and adopted to properly address the wide ranging and unique impacts of HS2.
Question 1
What are your views on the criteria put forward to assess options for
long-term discretionary compensation?
On first reading the proposed criteria (fairness, value for money, community cohesion,
feasibility, efficiency and comprehensibility, functioning of housing market) appear to be
sound, but as ever the devil is in the detail. Critical to the consideration is how the criteria
are defined and subsequently applied.
‘Fairness’ is defined thus: “… the Government should ensure that owner occupiers whose
properties (and property values) are most directly and specifically affected by the proposals
for Phase One of HS2 are eligible for compensation; and that those eligible for
compensation receive fair and reasonable settlements reflecting the location and
circumstances of their property.”
The definition offered for ‘value for money’ is: “… the Government should ensure that HS2
property schemes are likely to offer satisfactory value for money to the taxpayer, are
affordable, do not involve disproportionate expense and that any risks relating to the costs
of property schemes can be effectively managed within HS2’s long-term funding
settlement.”
It is apparent from the proposals that the Government has weighed these two criteria and
favours ‘value for money’ rather than ‘fairness’. While 51m accepts that the Government
has a duty to consider the interests of taxpayers, the balance they have struck is wrong. It is
clear they are driven by a desire to manage costs rather than give fair compensation for all
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(and not just most directly and specifically) affected property owners. This is reinforced in
paragraph 2.3.1 where the “Government considers that it is unreasonable to expect
taxpayers to compensate for temporary reductions in property values that subsequently
recover…”
With the initial announcement about HS2 made in March 2010, and statutory compensation
not available until 2027 at the earliest, this temporary period is anything but. The property
owner has no say in the impact of blight, and yet he is being expected to pay twice for HS2,
once from taxes and once by loss of value of his property.
It is equally unfair that only those who are most severely affected are compensated.
Compensation should be for all people who suffer significant loss, a sentiment shared by
Philip Hammond (Transport Secretary) at the time of the HS2 announcement, ‘minimising
uncertainty and protecting the legitimate interests of property owners would be of
paramount importance’.
‘Community cohesion’ is described: “… the Government should maintain as far as
practicable the stability and cohesion of communities along the route, for example by
enabling existing residents to remain in their homes where possible; by minimising the
potential adverse effects of significant population turnover associated with multiple shortterm tenancies; by ensuring that there is the best understanding about the likely effect of
the railway on the enjoyment of properties; and by compensating those most affected by
the project on a fair and reasonable basis.”
51m struggles to find evidence that the Government has seriously tried to address any of
these four principles, apart from maybe the first. The sale and rent back scheme appears
designed to encourage “existing residents to remain in their homes where possible”. If,
however, the scheme is restricted, to properties scheduled for demolition, it will only have a
very marginal effect. Even if it was extended to cover all properties that the Government
agrees to buy, this figure is still unlikely to exceed a few thousand dwellings.
51m is unclear how the Government plans to address the issues created by “multiple shortterm tenancies”. It may become landlord of perhaps a few thousand properties as a result
of applying the property compensation provisions and advises that it will use “standard
assured shorthold leases and commercial management practices”. This gives little
assurance that “multiple short-term tenancies” will be avoided.
HS2 Ltd’s approach to consultation and engagement gives 51m very little confidence that
“that there is the best understanding about the likely effect of the railway on the enjoyment
of properties”. At best, it has been inconsistent and inadequate and their reluctance to
share key information has left stakeholders feeling that impacts and effects are being
underestimated and understated.
The fourth criterion that the Government claims underpins its policy on compensation is
“feasibility, efficiency and comprehensibility”, explained as: “… the Government should
devise clear and easily explained rules so that homeowners can readily understand their
entitlements and the Government can predict how costs will be determined in any
individual case. It is important also to have assurance that any scheme can be administered
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efficiently and effectively to provide good customer service for those whose property is
affected by the railway.”
51m is keen to see how well the Government performs against this criterion, although it
notes that the omens do not look good. The application of the Exceptional Hardship
Scheme (EHS) has been characterised by lack of clarity and its workings have, to a large
extent, been shrouded in secrecy. 51m is concerned that the Government’s intention is to
morph the EHS into the long-term hardship scheme without addressing these shortcomings.
The fifth criterion is “functioning of housing market”, explained as: “… the Government
should enable local residential property markets to function as normally as possible during
the development and construction phases of the project.” 51m is well aware that property
markets between London and Birmingham have been far from normal since Phase One was
announced in March 2010.
This is confirmed by a study undertaken for HS2 Ltd: “Our research found that the housing
markets in areas next to the proposed route have weakened since the announcement.
Generally we found that in these areas house prices and sales volumes have fallen since the
announcement.” The reality is houses failing to attract any buyer interest, very large drops
in market value and the case of a house valued at nothing for mortgage purposes.
51m believes that this proves that the Phase 1 Exceptional Hardship Scheme has done, at
best, very little to improve this situation. With more than 172,000 properties within one
kilometre of the line, it is not unreasonable to assume that a fair proportion of these may be
at risk of blight. But the number of properties that may benefit from the Government’s
compensation proposals is tiny.
Even if a property bond were adopted it is unlikely that it would significantly increase the
numbers receiving compensation, especially if the Government follows advice from Deloitte
and restricts the scheme to properties within a rural support zone. This suggests that in
reality the Government is only prepared to help a tiny proportion of those experiencing
blight. 51m is concerned that there will be no perceptible effect on the “functioning of [the]
housing market” as a consequence of such a miniscule intervention.
In light of this analysis, 51m urges the Government to provide more comprehensive and
explicit definitions of the criteria and to ensure that the independent body responsible for
administering the discretionary compensation scheme balances each of the criteria carefully
and is consistent in the decisions taken. All decisions must be transparent and published to
ensure that those affected and compensated feel and see that they are treated fairly.
Summary
51m believes that:
 Compensation must be for all who suffer significant loss not just those most directly
and specifically affected
 Value for money may be a consideration but it must not be an overriding factor that
leaves property owners paying twice
 Current Government proposals will do nothing for community cohesion
 The housing market requires a larger intervention to continue functioning properly
 Criteria, weightings and decisions must be transparent, explicit and publically available
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Question 2
What are your views on the proposal for an express purchase scheme?
51m notes that the Government has changed the name of this scheme to ‘express
purchase’. This may be to reflect that this proposal will enable affected parties to serve a
blight notice and apply to the Government to purchase their property, ahead of compulsory
purchase powers (given at Royal Assent) or statutory compensation. To serve a blight
notice, an owner must be:
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A resident owner-occupier of a private dwelling
An owner-occupier of any business property where the annual (rateable) value of the
premises does not exceed £34,800
An owner-occupier of an agricultural unit with at least six months occupation of the
whole or part
Certain mortgagees and personal representatives
The express purchase scheme suggests the Government will accept blight notices from all
eligible property owners whose properties are entirely within the safeguarded area. The
property does not have to be needed for construction or operation of the railway and
owners are no longer required to prove reasonable endeavours to sell their property. 51m
welcomes these specific relaxations, but has concerns about other parts of the scheme.
Firstly, the express purchase scheme unfairly excludes larger businesses, landlords of
property, and second home owners. Nor does the scheme apply to properties above deepbored tunnels or other sub-surface works, despite instances where property owners have
failed to sell their property because they live above a planned excavation and possible
buyers have perceived this as a significant and ongoing risk.
Secondly, the concessions, over and above statutory provisions (whilst welcome), are
limited and only a small number of properties stand to benefit. Indeed it is estimated that
the revised scheme will apply to less than 1% of all blighted properties, about 1,000 in total
in the safeguarded area for Phase One.
Third, the proposed scheme suffers from the same issues as the previous ‘advanced
purchase scheme’. The proposal to make a home-loss payment of 10% (unchanged since
2008) is arbitrary, wholly inadequate and fails to reflect that the sale is not at the behest of
the property owner. The Country Land and Business Association recommend a 30% figure.
51m also cannot support capping the home-loss payment at £47,000, since there is likely to
be a link between property values and inconvenience in being forced to move. It does not
accept that this would be an unfair gain for property owners, but rather recognises the type
and effect of loss on people’s lives.
Whilst the scheme is clear about properties wholly within the safeguarding area (i.e. within
60m of the track) it lacks clarity about those that are only partly within the same area. 51m
believes that the absence of detail is wholly unsatisfactory and that the 60m distance fails to
take account of true blight or visual, noise and landscape impacts. This should be remedied.
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51m also urges the Government to ensure that any applicants who have submitted
unsuccessful blight notices to date (and in the future) should be allowed to reapply once an
express purchase scheme is operational, and at regular points thereafter.
Summary
51m believes that the express purchase scheme:
 Should include larger businesses, property landlords and second home owners
 Should not be restricted to the arbitrary safeguarding area but extended further
 Should be more explicit about arrangements for properties partly within (or just
outside) an extended safeguarding area
 Should include a home-loss payment in line with CLA recommendations (30%)
 Should abolish the cap on the maximum home-loss payment
Question 3
What are your views on the proposed long-term hardship scheme?
The Government proposes the long-term hardship scheme because there is likely to be a
significant number of property owners outside the rural support zone with strong personal
reasons to move, but unable to do so and not caught by other proposals. Affected parties
would need to apply and if successful would have their property bought by the Government
at its unblighted open market value.
Applications would be considered by an independent panel (appointed by HS2) and would
be judged on the following criteria:
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Property type - Applicants must be an owner-occupier
Property location - Property in safeguarded area or voluntary purchase zone is ineligible
Effort to sell - Property must have been marketed for more than six months with no
offers received within 15% of its realistic unblighted asking price
No prior knowledge - March 2010 is regarded as the cut-off date
Hardship - Need to move (family circumstances, job, divorce, re-possession, illness)
Under both previous and current proposals the hardship scheme is the only scheme that will
be open to most people impacted and blighted by HS2 (express purchase scheme will apply
to less than 1% of properties within 1km). 51m believes the criteria described above only
serve to reduce the number of people and properties eligible.
51m challenges the inclusion of the hardship criterion in this scheme. Hardship relates to an
individual’s circumstances and bear no relation to the extent of blight, i.e. diminution of
property value. As such 51m urges that the hardship criterion is dropped. This would not
set a precedent (see Stansted airport expansion, 2004). A far better replacement would be
a properly developed property bond scheme.
There are very few differences between the long-term hardship scheme and the exceptional
hardship scheme, beyond a change in name. If similar outcomes are achieved, it should be
noted that the numbers assisted by the EHS are far outnumbered by those rejected and the
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reasons given for rejection were in some cases, incomprehensible. This would build the
case for relaxing the LTHS criteria rather than making them stricter.
Property type
51m feels it is unfair to exclude large businesses, landlords, commercial and residential
tenants, and those with second homes, who may also have a pressing need to relocate or
need money for retirement.
Property location
This requires the panel to consider if a property will be ‘substantially adversely affected’.
51m is concerned that such a judgement is entirely subjective. It believes a simpler, more
transparent approach would be to use a property’s market value and whether it has fallen
with the construction / operation of the railway.
Effort to sell
51m feels the six month period is excessive and should be reduced to 3 months as it is for
the EHS and other schemes such as Crossrail. The LTHS is long-term (i.e. for 15 years or
more) and should be appropriate to varying property market conditions.
Offers
51m believes that the Government has failed to recognise the range of different property
markets within the UK. Suggesting that ‘offers within 15% of a realistic asking price’ should
disqualify an applicant is unfair in the extreme. Rural property markets operate on the
offers in excess of asking price principle, whilst Hometrack data suggests that for other areas
the average difference between sale and asking priced is 7.5%. If LTHS is to be pursued the
percentage threshold should be changed and reflect differing property markets.
No prior knowledge
Individuals may have very good reasons for acquiring properties in spite of HS2. If a
property is beyond 200m then it is unreasonable to expect them to have had knowledge of
HS2 as early as March 2010. This makes it unfair to exclude them from the LTHS. 51m
welcomes the fact that route change announcements will be recognised as some route
changes have made matters worse for some property owners.
51m believes that if the Government, contrary to advice received, chooses to adopt a longterm hardship scheme it must ensure that the panel appointed to consider applications is
wholly independent and publishes its decisions. Decisions should also be subject to an
independent appeals procedure and individuals should have an opportunity to reapply.
51m expects to see a fast-track process adopted for urgent cases of hardship (such as
terminal illness). It also expects the panel to carry out site visits when considering
applications to ensure that panel members are better informed of local circumstances.
Further clarity is required about, how a property owner will prove that HS2 is the reason for
an inability to sell; how additional evidence will be shared between parties prior to the
panel hearing; and how upfront fees given to estate agents to market properties will be
refunded as part of the compensation package.
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Summary
51m believes that the proposed long-term hardship scheme:
 Should be replaced by a Property Bond scheme, fairer for all concerned
 If adopted, should benefit from more relaxed, not strict, criteria
 If adopted, should include all property types and owners - not just owner-occupiers
 If adopted, should use property’s market value as a guide
 If adopted, should cut effort to sell to just three months (comparable with Crossrail)
 If adopted, should revise the offers criterion - 15% is unfair and limiting
 If adopted, should discount the ‘no prior knowledge’ criterion
 If adopted, must be transparent, fair, impartial and open to challenge
Question 4
What are your views on the sale and rent back scheme?
This scheme enables owners whose property requires demolition to sell their home but
remain living there as tenants until the railway requires their possession. This is similar to
the 2012 proposal but has been extended to apply to all properties acquired by the
Government for HS2.
In general, 51m welcomes the sale and rent back proposal, since it allows property owners
to rent back their property and helps reduce the number of empty properties within
communities affected by HS2. But it is only a cautious welcome, since once again second
home owners, businesses and landlords are excluded. Exceptions are suggested but no
detail is provided about how these might be applied.
The implication is that the scheme will be very limited, with very few beneficiaries. One way
to address this would be for the Government to extend to the scheme to all properties that
it purchases under the compensation regime and not just those scheduled for demolition.
51m also wants to see more detail about how the market rent will be calculated to ensure
fairness and maintain community cohesion.
There is, after all, no explanation provided about the level of market rent. It must be clear
that this will be much less than the unblighted market rent, having taken account of HS2.
The ‘value for money test’ should be applied in appropriate circumstances only, to avoid
penalising individuals and families in poorer areas.
51m supports the approach proposed by Hillingdon that suggests the following:
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The Government completes a legal agreement to purchase the property at a future date
Full purchase price paid to owner on exchange of contracts
Legal completion set for when the property is required for construction
As purchase price paid & completion delayed, property owner pays agreed monthly sum
This avoids the need for a landlord and tenant relationship to be created between the
Government and property owner and removes the requirement for the proposed ‘value for
money test’. In turn, this reduces overall costs for all parties.
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Summary
51m believes that the sale and rent back scheme:
 Should be extended to all properties purchased by the Government
 Should be clear about how market rents will be calculated
 Should apply to all classes of property, including landlords and business premises
 Should be replaced by a scheme similar to that proposed by Hillingdon (see above)
Question 5
What are your views on alternative proposals for renting properties to
their previous owners?
This, at first, appears a better option than the ‘sale and rent back’ scheme considered
above. After all, in this instance, the anticipated type of tenancy is described. Whether an
assured shorthold tenancy offers individuals security of tenure is debatable, and it certainly
does little to maintain community cohesion.
51m is also concerned that this scheme only assists a small number of homeowners and fails
to address the overall general blight problem created by HS2. Once more restrictions apply
to landlords, larger businesses and second home owners. The biggest difference between
the two rental options (Questions 4 and 5) is the form of lease to be offered.
In the scheme restricted to properties for demolition the Government is prepared to give an
assurance that it will serve notice on the tenant only in certain circumstances, with the
assumption being that the former owner will stay in the property until it needs to be
demolished, it becomes certain that it will not be demolished, or the rental becomes
uneconomic.
In the alternative approach the Government plans to ‘use standard assured shorthold leases
and commercial management practices’, meaning the security of the tenancy is less
assured. A further important aspect is the Crichel Down rules that must be applied to all
homes in the safeguarded area.
Summary
51m believes that alternative proposals for renting properties to previous owners:
 Is a prescriptive approach using standard methodologies
 Fails to address the general blight created by HS2
 Must include rigorous application of the Crichel Down rules
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Question 6
What are your views on proposals for a voluntary purchase scheme
within a ‘rural support zone’?
The Government suggests that properties close to the line, but outside the safeguarding
area, may become difficult to sell. It therefore proposes a ‘rural support zone’ for
properties in rural areas, up to 120m from the line. This is apparently based on experience
applying the Exceptional Hardship Scheme for High Speed 1. The proposal is that this
scheme would stay in operation until after the railway had been operational for a year.
51m is disappointed that the Government has chosen to restrict this proposal to rural areas
alone, without providing adequate explanation. It fails to see why this zone should not be
extended to urban areas and over deep bore tunnels (or other excavations) since property
blight is already suffered and will continue until at least 2026.
Once more landlords, second homeowners and larger businesses fail to qualify for this
voluntary purchase scheme. 51m is concerned that such exclusions are discriminatory and
urge the Government to review their approach. It is also unclear how the Government
plans to respond to properties only partly within the zone. Clarification is needed.
The Government is proposing a distance-based limit for the ‘rural support zone’, namely
120m from the line. This extends property compensation to a further 1,000 properties
(maximum) compared to an estimated 100,000-250,000 properties blighted by the HS2
Phase One proposals. Blight cannot, is not and never will be limited or restricted to an
arbitrary or artificial distance.
Blight extends for different distances, dependent on so many factors including landscape,
topography and tranquillity. 51m is therefore disappointed that HS2 Ltd has accepted
advice from Deloitte and set a limit of 120m either side of the line. Exceptional hardship
scheme cases have been accepted for properties more than 1000m away, whilst estate
agents recognise blight impacting up to three miles away.
51m believes a simpler and fairer approach would be to define properties that qualify or are
eligible as suffering a ‘loss in market value’, applied equally across urban and rural areas
(including areas above tunnels). If a distance based criterion had to be used for this zone,
51m believes that it should be measured from the furthest point / outer boundary of the
safeguarded zone and not the track centre-line.
51m also expects flexibility to be applied when considering the voluntary purchase scheme
– adjacent houses or individual dwellings in a block must be treated equally regardless of
where the boundary falls. Moving costs and home-loss payments should also be provided in
these circumstances, since moving is not the homeowner’s choice.
Summary
51m believes that proposals for a voluntary purchase zone, within a ‘rural support zone’:
 Is an inadequate approach to blight issues across Phase One - both urban and rural
 Fail to meet the needs of landlords, larger businesses and second homeowners
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Fails to address the reality of blight by concentrating on a 240m corridor
Should use ‘loss in market value’ as the criterion for such a compensation scheme
Should apply any ‘rules’ flexibly for the benefit of all who are affected
Question 7
What are your views on the option to introduce a ‘time-based’ property
bond scheme within a ‘rural support zone’ as an alternative to the
voluntary purchase scheme?
The suggestion to introduce a ‘time-based’ property bond is probably the only new proposal
in this consultation. There was no equivalent question in the original compensation
consultation. It was rejected by the Government following a previous consultation on
compensation but reappeared because the High Court invited it to think again.
Other aspects of the compensation scheme are presented as integral parts of the package,
rather than optional extras. Comments are invited on the long-term hardship scheme, but
only in terms of detail. It is assumed that it will form part of the compensation package,
come what may. The property bond is examined somewhat differently.
Deloitte was commissioned to produce a report about the property bond. It recommended
that if a property bond were to be offered, it should be on the basis that it was ‘mutually
exclusive’ to the voluntary purchase scheme. This was agreed by the Government but then
included as an option that could take the place of the voluntary purchase scheme.
Key to most property bond schemes is its universal nature, and the geographical limits, if
any, that apply. In its proposal for a property bond scheme the HS2 Action Alliance (HS2AA)
suggests that there should be no such physical limit applying to eligibility, the scheme
should be available to any ‘property owners who suffer a loss in property value due to HS2’,
irrespective of location relative to the line of route.
Such a scheme would minimise the impact on property owners suffering blight, and should
be wide enough to provide greater confidence to the property market. Paragraph 5.2.22 of
the consultation document states that the Government “accepts the Deloitte advice that
property bond schemes which are not defined by a specific boundary would attract many
more valid applications for bonds than options defined by a specific boundary”.
However, the Government also expresses concern that such unfettered schemes “would be
very likely to lead to much higher administrative costs, to cover the necessary costs of
robust, independent property valuations” and that these costs “are hard to predict with any
degree of confidence”. These costs are also described as “up-front”, demonstrating a clear
misinterpretation of the HS2AA proposals, which only require a valuation “if and when [a
property owner] seeks to sell to HS2 Ltd when an open market sale is not possible”.
51m believes that a well-designed property bond scheme would enable property owners to
delay decisions to sell, clearly one of the aims of such a scheme. This in turn means fewer
properties would need to be purchased by the Government and it would therefore save
money. It is therefore disappointing to note that the Government appears to pre-empt the
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outcome of the consultation by stating: “We do not therefore propose to introduce any
property bond scheme that does not feature a clear boundary to define eligibility”.
Ironically, paragraph 5.2.16 states: “We accept that a well-designed property bond scheme,
in theory, may have the potential to improve the position of property owners affected by
HS2 and further our policy objectives relating to fairness, property market function and
community cohesion.”
The theory alone is enough to believe it is achievable. 51m recognises that, to date, no
property bond scheme has yet been developed or introduced by any local / national
government organisation in the UK. HS2, however, is clearly a unique project that merits
the development of new and innovative measures that will help compensate individuals,
groups and organisations for their loss of properties, facilities and amenities.
For maximum benefit (blight reduction and alleviation) there should be no geographic limit
for a property bond scheme - the extent of the blight will set the limit for itself. Only those
property owners who have evidence of the impacts of blight on the value of their property
are likely to apply and bonds will only be able to be cashed in if a loss can be demonstrated.
51m wants to see a properly devised property bond scheme that extends beyond all
previously established boundaries and limits and applies to all property types. To support
this scheme, 51m expects HS2 Ltd and DfT to share all relevant information and data with
Councils, local authorities, groups and individuals to ensure consultees are able to consider
all proposals and are therefore able to offer an informed view.
Summary
51m believes that proposals for a property bond scheme:
 Should be part of a compensation package, not a replacement for other proposals
 Do not require a property valuation when the bond is issued and agreed
 Should not be limited by distance or by other artificial measures
 Should be introduced to meet the extraordinary needs of HS2
 Should go beyond the bare minimum and offer security to property owners
 Should be implemented and monitored by an independent panel of experts
 Should be developed and be subject to further consultation
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