HS2 Phase One environmental statement consultation

Response Form
This consultation will close on 27 February at 23:45 On 25 November the High Speed Rail (London West Midlands) Bill was introduced to Parliament seeking the powers necessary to construct and operate HS2 Phase One. In line with Parliamentary Standing Orders an Environmental Statement has been produced to accompany the Bill. A consultation is now being held on the Environmental Statement to ensure that the decision taken by Parliament at Second Reading of the Bill is informed by the publics views on the Bills environmental impacts. You can respond to this consultation by emailing your comments to: HS2PhaseOneBillES@dialoguebydesign.com Or writing to: FREEPOST RTEC-AJUT-GGHH HS2 Phase One Bill Environmental Statement PO Box 70178 London WC1A 9HS You can also respond by downloading and saving this response form to your computer, completing it, and then attaching it to an email and emailing your comments to HS2PhaseOneBillES@dialoguebydesign.com . You can also print your form and send it to the address above. Please only use the channels described above when responding to this consultation. We cannot guarantee that responses sent to other addresses will be included in this consultation. For more information about the consultation please visit www.gov.uk or call the HS2 Public Enquiries Team on 020 7944 4908. Please write your response clearly in black ink within the boxes and, if you require further space, please attach a further sheet to the response form. 1

Information about you It is important to give us your name to ensure your response is included First name: Rt Hon Sir John Surname: Randall Address: House of Commons, London Postcode: SW1A 0AA Email: randallj@parliament.uk Are you responding on behalf of an organisation? If so, please state your organisations name and your position below:
Member of Parliament, Uxbridge and South Ruislip

Confidentiality and data protection

Anyone wishing to send comments should note that responses will be published on a publicly-accessible website in due course, but we will not publish names, addresses and signatures of individuals. As it is not possible for us to check whether the substance of responses contains other personal data, you should not include information in your response that could identify you unless you are happy for it to be made public. If you do not want any of your response to be published you should clearly mark it as Confidential in the subject of the email or at the top of your letter. However, please note the following two paragraphs.
If you want the information you provide to be treated as confidential, you should be aware

that all information provided in response to this consultation, including personal information, may be subject to disclosure in accordance with access to information regimes (these are primarily the Freedom of Information Act 2000 (FOIA), the Data Protection Act 1998 (DPA) and the Environmental Information Regulations 2004). Under the FOIA, there is a statutory Code of Practice with which public authorities must comply and which deals, amongst other things, with our confidentiality obligations. In view of this it would be helpful if you could explain in your response why you regard the information you have provided as confidential. If we receive a request for disclosure of the information you provide we will take full account of your explanation, but we cannot give an assurance that confidentiality can be maintained in all circumstances. An automatic confidentiality disclaimer generated by your IT system will not, of itself, be regarded as binding on the Department for Transport or HS2 Ltd. Please note that all responses received, whether marked Confidential or not, will be passed on in full to the Houses of Parliament and their appointed Assessor, who will analyse the responses and make a report to Parliament. That report will not contain your personal data.

I wish my response to be treated as confidential (please write your reasons below)

N/A.

The Environmental Statement is made up of a number of documents. The Non-Technical Summary provides a summary of all the information contained in the Environmental Statement. Volume 1 provides an introduction to the Environmental Statement including an overview of the impact assessment process and consultation undertaken to date, and the main strategic, route-wide and local alternatives considered. The line of route between London and the West Midlands is described in Volume 2, which has been divided into 26 smaller geographical sections called Community Forum Areas (CFAs) and each area is covered by its own separate report. Volume 3: route wide effects described the likely route wide environmental effects of the construction and operation of Phase One of HS2. Volume 4: off-route effects describes the likely significant environmental effects of Phase One of HS2 expected at locations beyond the route corridor, such as rail stations, rail depots and rail lines. This volume covers areas not included in the community forum area reports in volume 2. Volume 5 contains technical appendices, including the response to the draft Environmental Statement consultation and the draft Code of Construction Practice, setting out baseline data and other technical information.

Please let us know your comments on the Environmental Statement in relation to the Non-Technical Summary and five volumes.

Question 1. Please let us know your comments on the Non-technical summary. My comments on the Non-technical summary are:
The case for HS2 Many of the original alternative options to HS2 were ruled out because of matters related to speed. As speed is no longer the primary argument for HS2 (the primary case currently refers to enhancing capacity and connectivity) we should review the original options which include slower but cheaper alternatives. The Government has decided that it is not in the public interest to release the 2011 Major Projects Authority Project Assessment Review report into HS2. The exercise of the executive override under section 53 of the Freedom of Information Act 2000 was signed on 30 January 2014. Given the Major Projects Authority exists to improve project performance for the taxpayer who rightly expect the government to keep tight control over how their taxes are spent on major projects will be disappointed not to see this report. I think the decision not to publish should be reviewed and overturned as a matter of urgency. If the public are to be convinced of the probity of the processes, transparency should be a priority. The primary case for HS2 currently refers to enhancing capacity and connectivity. However the newest list of the top ten overcrowded train services in England and Wales (Autumn 2012) published on 24 July 2013 by the Department for Transport lists only one train service on the West Coast Main Line. The full list is provided here: https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/224894/top10-crowded-autumn-2012.pdf.

Question 2: Please let us know your comments on Volume 1: Introduction to the ES and Proposed Scheme. My comments on Volume 1 are:
The Proposed Scheme Provision has been made for future extensions to the railway on either side of the Colne Valley for the potential future link to Heathrow Airport. However the planned interchange at Old Oak Common will already offer a connection on to services direct to Heathrow Airport. Indeed, the station will include eight platforms on the GWML for main line services to the west including Heathrow and Crossrail services. It would make sense, therefore, to scrap the Heathrow spur straight away. It would help immeasurably if there was no Heathrow loop, because the tunnelling could be extended past the houses in Ickenham. This should be done forthwith.

Question 3: Please let us know your comments on Volume 2: Community Forum Area reports. You are welcome to comment on one, a number or all the reports listed below. Please tick the reports described below that your comments apply to. If making comment on more than one report, please indicate clearly in your response the report to which your comments relate.
Please tick those reports you wish to comment on below:
CFA 1 Euston CFA 15 Greatworth to Lower Boddington

CFA 2 Camden and HS1 Link

CFA 3 Primrose Hill to Kilburn (Camden)

CFA 16 Ladbroke and Southam

CFA 17 Offchurch and Cubbington

CFA 4 Kilburn (Brent) to Old Oak Common

CFA 5 Northolt Corridor

CFA 18 Stoneleigh, Kenilworth and Burton Green

CFA 19 Coleshill Junction

CFA 6 South Ruislip to Ickenham

CFA 7 Colne Valley

CFA 20 Curdworth to Middleton

CFA 21 Drayton Bassett, Hints and Weeford

CFA 8 The Chalfonts and Amersham

CFA 9 Central Chilterns

CFA 22 Whittington to Handsacre

CFA 23 Balsall Common & Hampton-in-Arden
CFA 24 Birmingham Interchange and Chelmsley Wood

CFA 10 Dunsmore, Wendover & Halton

CFA 11 Stoke Mandeville and Aylesbury

CFA 12 Waddesdon and Quainton

CFA 13 Calvert, Steeple Claydon, Twyford and Chetwode

CFA 25 Castle Bromwich and Bromford

CFA 26 Washwood Heath to Curzon Street

Dont know

CFA 14 Newton Purcell to Brackley

My comments with regard to the reports ticked above are:

CFA 6 South Ruislip to Ickenham Agriculture, forestry and soils The total agricultural land used during the construction phase will be 110.6ha, but only some 5.9ha (5.3%) will be restored and available for agricultural use following construction. Approximately 75ha of the 104.7ha of agricultural land that will be permanently required following construction and restoration will be used for the sustainable placement of surplus excavated material. The majority of the land required temporarily for sustainable placement of surplus excavated materials will be planted as part of the ecological and landscape mitigation and the assessment assume that none of this land will return to agriculture. It is not clear why this land will not return to agriculture. The three areas identified for the sustainable placement of surplus excavated materials and the proposed restoration of the land for landscape and ecological planting will result in land taken from 10 small agricultural holdings which are unlikely to remain viable as agricultural businesses.

Air quality During the construction period, significant air quality effects from increased NO2 concentrations are predicted at properties close to the B467 Swakeleys Road, between Harvil Road and the A40 roundabout, and at properties close to the A40, west of the roundabout. The peak effects are predicted to last for approximately one year. However there is no further detail to reassure very concerned residents. This is unacceptable. There is no assessment of the reduction in NO2 concentrations arising from the proposed mitigation measures. Again, this information should be provided. Community The Proposed Scheme will require the demolition of: 1. commercial building at Ruislip Rifle Club forcing the closure and demolition of Ruislip Rifle Club 2. the Ruislip Golf Course driving range shelter (partial demolition) 3. outbuilding at Ruislip Golf course north-east of the club house 4. the garage associated with 105 The Greenway 5. the Lodge west of Breakspear Road South 6. buildings to the west of Breakspear Road South (owned by the pharmaceutical research facility) 7. Gatemead Farm 8. the stable and outbuilding at Oak Farm. The potential cumulative impact on the community has seemingly not been considered. Blenheim Care Centre on Ickenham Road is a residential care home for the elderly. Despite the mitigation measures that have been put forward, users are predicted to experience significant residual effects resulting from a significant increase in HGV movements on Ickenham Road and visual effects. Pensioners who have worked hard all their lives should not have to experience long periods of construction activity. While it is stated that the Church of Jesus Christ of Latter Day Saints (also on Ickenham Road) will experience significant noise effects from construction activity for approximately one year, it is not clear for how long the residents of Blenheim Care Centre must endure the noise. This is clearly far from acceptable. Cultural Heritage A range of archaeological assets will be permanently lost due to the construction of the Proposed Scheme; these assets include: Bronze Age cremations at Copthall Covert, possible Palaeolithic artefacts in the Thames Terrace Gravels and a Romano-British settlement north of Newyears Green Farm. A programme of archaeological works will be prepared to investigate, analyse, report and archive these assets. However it is not clear if there will be flexibility to preserve assets if they are discovered after development consent is granted. Ecology The permanent loss of one barn owl territory represents a residual significant effect. It is likely that this will result in adverse effects on the conservation status of this species that is significant at up to the county/metropolitan level. This a species that is extremely uncommon in London and there are very few pairs in Hillingdon.

Land quality The draft Code of Construction Practice (CoCP) requires that a programme of further investigations which may include both desk based and site based work, will take place in order to confirm the full extent of areas of contamination and risk assessment undertaken to determine what, if any, site specific remediation measures will be required to allow the Proposed Scheme to be constructed safely and to prevent harmful future migration of contaminants (draft CoCP, Section 11). Landscape and visual assessment The presence of construction works and changes to the existing landform and vegetation patterns will significantly affect the character and appearance of the local landscape. Socio-economics The section reports the likely significant employment effects during construction and operation of the Proposed Scheme. The single focus on employment has meant that the socio-economic effects of blight have been completely ignored. A full socio-economic assessment of the Proposed Scheme must consider the impact on property prices. Sound, noise and vibration The threat of excessive noise and vibration from HS2 both during construction and operation has been one of the key themes of community fora and workshops. Noise from construction is likely to result in significant adverse effects on residential areas closest to the construction works at Cottesmore House in West Ruislip, The Greenway in Ickenham and Breakspear Road South in Harefield. Potential significant adverse effects are reported for the buildings at Ruislip Golf Centre and The Church of Jesus Christ of Latter Day Saints. Noise from construction traffic is likely to affect a limited number of residential properties on B467 Swakeleys Road in Ickenham. Taking account of the avoidance and mitigation measures and the local context, the residual permanent airborne noise adverse effects on the acoustic character of the community in the north-western edge of Ickenham closest to the route are considered significant on a community basis. On a worst case basis a significant ground-borne vibration effect has been identified on the pharmaceutical research facility84, located near Ickenham. Traffic and transport A number of transport modelling tools have been used to inform the assessment including TfL's West London Highways Assessment Model. The assessment covers the morning (08:00-09:00) and evening (17:00-18:00) peak periods for an average weekday. However in practice morning peak flows will tend to start much earlier than 08:00 as much of the commuter traffic passing through the area is headed further afield. During construction, core site operating hours will be 08:00-18:00 on weekdays and 08:0013:00 on Saturdays, with tunnelling activities occurring on a 24 hour a day basis during the

construction period. HS2 Ltd have stated that site staff and workers will therefore generally arrive before the morning peak house and depart after the evening peak hour. This means that the construction workforce will add to traffic congestion at both ends of the more realistic peak hours. This is a very great concern to residents in Hillingdon. An indication of the predicted duration of traffic duration is given in Table 20 of CFA6 (reproduced below). This shows maximum duration of disruption of up to 10 years at Harvil Road, although the maximum intensity is shown as lasting one year. It is unclear as to why there will be 10 years of construction when the start date is in 2017.

Residents have expressed grave concern about the status of West End Road. They are worried that West End Road is not intended as a route for construction traffic and is therefore overlooked in the area report; that vast amounts of traffic will however be displaced here from Ickenham and Northolt as the only other access to the A40 will be via West End Road to the Polish War Memorial; and that West End Road is already over-congested and planned changed in the local area over the next couple of years will increase this further. Planned changes in the local area reportedly include: 1. RAF Northolt flights are due to be increased so red signals will halt traffic more regularly. 2. Ruislip Gardens Primary School the school is expanding from 2-form entry to 3form entry and by 2019 will be accepting over 160 extra children. Ruislip High School is also increasing its intake. 3. South Ruislip Sainsbury due to increase in size which will attract more retail traffic. 4. Potential redevelopment of the Arla site. Water resources and flood risk assessment Residents across Hillingdon are very fearful that the construction and operation of HS2 close to their homes will add significantly to the flood risk. Recent events I believe back this view

up. It is indisputable that both construction and operation will require farmland 110.6 hectares and 104.7 hectares in CFA6 respectively to be taken which for now soaks up surface water and which ought to act as natural flood protection for my constituents. Residents have expressed to me their particular concern that little attention has been given to the high risk of groundwater flooding across the Ruislip Gardens area, West End Road, Bridgewater Road and Long Drive which are all already prone to surface water flooding. Residents will be very concerned by the Flooding Ministers recent admission that the scale of the flood risk associated with HS2 has not been fully assessed for the first phase of the route from London to Birmingham. In response to a Parliamentary Question on 13 January 2014 the Minister said: The safeguarded area for phase one of HS2 crosses just over 100 watercourses, each of which will have a degree of flood risk associated with them. The scale of that risk will depend on the precise alignment of the route. At present this has not been fully assessed, nor has an assessment been made for the phase two routes. I would like to make a special mention of the Hillingdon Outdoor Activity Centre. (HOAC) HOAC was established in 1969 and has been managed as an educational facility. HOAC provides water-based and land-based outdoor activities all year round. The water-based activities are provided on a 45 acre lake. Users include local people, education groups, community groups and those with disabilities for whom special facilities are in place. HOAC is embedded within the local community, serving local schools, local people and clubs and providing volunteering opportunities. HOAC also has a role beyond recreation, providing training for new and existing instructors. There are no other centres providing similar services to those provided by HOAC in neighbouring local authority areas. The following is a summary of their operations: HOAC is a registered outdoor and environmental educational charity which serves Hillingdon and the whole of the West London community and focuses on disadvantaged and disabled youth. The centre is operated as a unique partnership arrangement between the charity and the London Borough of Hillingdon who support and sponsor the centre. Over 22,000 young people from a wide range of economic and ethnic backgrounds come to it. It is clear to me that because of the construction and the viaduct HOAC will not be able to continue to operate. It is of paramount importance that if the route cannot be changed that an alternative is very quickly identified and work commenced to ensure the survival of this extremely valuable amenity whose loss would be immeasurable I cannot over emphasise the importance that this site is to the residents of Hillingdon and wider afield. Although not in my local authority area I would like to highlight the following :In CFA7 the Proposed Scheme would lead to the loss of the following: 19ha (14%) of the Mid Colne Valley SSSi 5.4ha of open water (6% of which is within the SSSi) 2.9ha of running water (50% of the River Colne in the SSSi) 10ha of Woodland (33% of the total woodland area of the SSSi)

0.75ha of swamp vegetation The loss of habitat in the SSSi will result in loss of breeding bird habitat, suitable nesting sites, and an overall reduction in bird numbers including red listed species. I am particularly concerned about the loss of breeding Corn Buntings mentioned in the non-technical summary. This is a species which has declined alarmingly over recent years and I believe that the survival of the species in this area would be severely impacted. Breeding birds using woodland would also be disturbed. 25ha of terrestrial habitat including 18ha of broadleaved woodland in the Mid Colne Valley nature conservation (outside of SSSi) which includes: 2.9ha of Tilehouse Gravel Pits 0.9ha of the River Colne to be realigned 4.2ha of woodland in the Frays Valley 1ha of ancient woodland 170m of River Colne will be modified Other smaller parcels of habitats

Question 4: Please let us know your comments on Volume 3: Route-wide effects.

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My comments on Volume 3 are:

Overall, the agricultural land required for the project will amount to approximately 4,800ha, of which approximately 2,500ha will be high quality land. Following construction and restoration to agricultural land, the area of land that will remain permanently removed from agricultural use will be approximately 2,800ha, of which 1,500ha will be high quality land. This represents approximately 0.03% of the national total and is a likely significant effect. Approximately 330ha of habitats of principal importance will be lost overall, including up to 195ha of lowland mixed deciduous woodland. This includes loss of 32ha of ancient woodland from 19 sites. Approximately 60ha of lowland meadows would also be lost. Ancient woodland is an irreplaceable national resource and its loss is a significant adverse effect. This habitat cannot be offset. Thirteen of Englands 17 resident bat species have been recorded along the route of the project, including Bechsteins bat - which is very rare in the UK - and the rare barbastelle bat. Field survey has confirmed that the Bechsteins bat population flies both across and along the route. This Bechsteins bat population is of national value. Locally there are significantnumbers of Daubentons Bat at Broadwater lake, the impact on these has not been properly assessed. In rural areas along the route there are approximately 27 locations where barn owls are likely to be affected. The construction of the railway will result in the loss of barn owl territories and, during operation, barn owls are also at risk of being struck by passing trains.

Question 5: Please let us know your comments on Volume 4: Off-route effects.

My comments on Volume 4 are:

None.

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Question 6: Please let us know your comments on Volume 5: Appendices and map books. You are welcome to comment on one, a number, or all the appendices. Please indicate in your response which report(s) your comments apply to (e.g. the draft Code of Construction Practice).

My comments on Volume 5 are:

Waste and material resources The Proposed Scheme is forecast to generate the following quantities of waste material for landfill disposal within the South Ruislip to Ickenham area (described in appendix WM-001000, Volume 5): Waste Source Excavated Material: Demolition: Construction: TOTAL Operational: Quantity (estimate) 16,617 tonnes 1,577 tonnes 13,667 tonnes 31,861 TONNES 21 TONNES (PER ANNUM) Landfill Rate 0.312% 10.0% 10.0% ---17.6%

The landfill diversion rates have been selected based on the quantity of unacceptable excavated material, a review of industry good practice landfill diversion rates of other largescale infrastructure projects in the UK (e.g. Crossrail, London 2012 Olympics and High Speed 1), and waste generation data received from Network Rail and standard waste generation rates provided in British Standard. The operational waste landfill rate, at almost 18%, is too high especially as this waste will be generated each year. HS2 Ltd should explore ways to reduce this. It is also important that HS2 Ltd look to improve upon existing landfill diversion rates by exploring innovative uses for waste material rather than simply adopting the status quo rate.

Thank you for completing the consultation response form. Responses to the consultation will be analysed and used to produce a summary report which will help inform Parliaments consideration of the scheme.

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