NEAHS2 Response to the HS2 Draft Environmental Statement and Design Refinement Consultations








1.    North Ealing Against HS2 (‘NEAHS2’) is a non-profit affiliation of residents, residents’ associations, businesses, schools and other community organisations located in the north of the London Borough of Ealing (‘LBE’), and specifically along the route of the HS2 phase one scheme in the areas of Northolt, Greenford, Perivale, Hanger Lane and North Acton. 


2.    Nothing in this consultation response indicates or may be construed to indicate NEAHS2’s support for, agreement with or acceptance of the HS2 scheme in whole or in part.


3.    This consultation response does indicate, on the assumption that HS2 will be built, NEAHS2’s reasoned preference for the design refinement proposal concerning the Northolt Corridor, which is outlined in Chapter 4 of the London – West Midlands Design Refinement Consultation Document published by the Department for Transport in May 2013 (‘Design Refinement Consultation Document’). This proposal is more specifically detailed in the Draft Environmental Statement Community Forum Area Report relating to the Northolt Corridor published by HS2 Ltd in May 2013 (‘CFA5 Report’).


4.    This consultation response responds specifically to the question contained at paragraph 4.5 of the Design Refinement Consultation Document (relating to the current Northolt Corridor proposal) with reference to the CFA5 Report

5.    NEAHS2 welcomes and supports the design refinement proposal for a tunnel for the HS2 route through the Northolt Corridor and welcomes the fact that the full tunnel as opposed to the short tunnel option (more particularly described at paras. 2.6.7 to 2.6.8 of the CFA5 Report) for the area was developed as the Proposed Scheme for the area. NEASH2 notes that ‘…the short tunnel would have been more expensive to build’ (para. 2.6.8, CFA5 Report)


6.    While NEAHS2 would welcome a local passenger service with local stations serving Northolt, Greenford, Perivale, Hanger Lane and North Acton operating on the New North Main Line/ Acton Northolt Line that runs parallel to the Central Line through the Northolt Corridor NEAHS2 stresses that the New North Main Line/ Acton-Northolt Line is unsuitable for HS2 or any high speed rail services. If there were any future plans for passenger rail services for the New North Main Line/ Acton-Northolt Line NEAHS2 and its members would expect and strongly campaign for such services to run at conventional speeds and serve the local areas of Northolt, Greenford, Perivale, Hanger Lane and North Acton with stations or connections to existing stations.


7.    NEAHS2 recognises, in respect of HS2 being tunneled under the Northolt Corridor/ LBE, that:


  • ‘This option would avoid the level of traffic disruption caused by the surface works including Hanger Lane Gyratory and would eliminate the risks associated with construction alongside and over the Central Line. It would also avoid the need to demolish a block of eight flats, two community halls and around 50 commercial units, which would be required for the surface option’ (para. 4.3.3, Design Refinement Consultation Document)


  • ‘The cost of constructing a continuous tunnel is now estimated to be broadly comparable to that of constructing the surface route in light of the additional scale and complexity of surface works, although the risks to cost and construction timetable would be greater for the surface option’ (para. 4.3.5, Design Refinement Consultation Document)


  • ‘The Secretary of State is minded to replace the surface section of track with a continuous tunnel extending all the way from Old Oak Common to West Ruislip. This would reduce as far as practicable disruption during construction and loss of property. It would be no more expensive to construct than the surface route, would involve less risk, and could be completed in less time’ (para. 4.4. Design Refinement Consultation Document) NEAHS2 understands from a HS2 Ltd press release that the time saving achieved from a tunneled route as opposed to a surface route is 15 months.


  • ‘A tunneled scheme would reduce the need for demolitions and eliminate the need for the replacement or provision of more than 20 bridges and other structures along the route.’ (para. 2.6.3, CFA5 Report)


  • ‘The full tunnel route from Old Oak Common to West Ruislip was found to effectively cost the same as the January 2012 announced scheme. The additional costs of tunneling would be offset by the cost saving associated with not having to demolish and rebuild over 20 bridge structures crossing the route, nor build the North Acton and East Ruislip portals’ (para. 2.6.9, CFA5 Report)


  • ‘A number of policies from the LBE Development (Core) Strategy (2012), LBE UDP (Saved Policies 2007)… seek to prevent the loss of affordable housing, community facilities, social infrastructure and open space. These seek: to minimize the net loss of affordable housing – Policy 1.2a Ealing Core Strategy; To support the retention and enhancement of existing community, leisure and cultural facilities – Policy 1.2d, 5.6 and 6.3 Ealing Core Strategy… To prevent the loss of open space, land for sports, play and informal recreation… Saved Policies 3.4,3.5 and 3.6 of the Ealing UDP; To prevent the loss of community facilities – Saved Policy 8.1 of the Ealing UDP…’ (para. 5.2.3, CFA5 Report)


  • ‘The route would be entirely in tunnel through the area. Disturbance at ground level would be limited to construction activities at the vent shaft locations…’ (para. 7.4.3, CFA5 Report)


  • ‘… Proposed measures that have been incorporated into the design of the Proposed Scheme include adopting a tunnel rather than an overground option, to avoid and reduce the potential effects on landscape character and visual amenity’. (para. 9.6.1, CFA5 Report)


  • ‘No significant direct effects on employment have been identified within the area…’ (para. 10.5.1, CFA5 Report)


  • ‘Within the Northolt Corridor, it Is expected that there would be minimal traffic and transport impacts related to the main construction site compounds at the West Gate, Greenpark Way and Mandeville Road as most traffic and transport effects have been avoided by the route being in tunnel under this area.’ (para. 12.5.2, CFA5 Report)


  • ‘…no excavated material would be removed from the tunnels in [the Northolt Corridor] area’ (para. 2.3.7, CFA5 Report)


8.    NEAHS2 notes that ‘the full tunnel and part tunnel options would substantially increase the volume of excavated material to be removed compared with the January 2012 announced scheme…’ (para. 2.6.11, CFA5 Report) and ‘The tunneled option would also mean an increase of around 1.3 million cubic metres in excavated material that would need to be removed – as much as possible by rail – from the tunnel worksites located in the industrial areas adjacent to Old Oak Common station and at West Ruislip’ (para. 4.3.4, Design Refinement Consultation Document).


9.    NEAHS2 therefore welcomes the fact that, considering the additional excavated material produced by the Northolt Corridor tunnel in LBE ‘The review of options concluded that the Proposed Scheme should be a twin bored tunnel driven from West Ruislip and another driven from the site at Victoria Road, where there is the opportunity to remove excavated material by rail in both locations’. (para. 2.6.14, CFA5 Report)


10.NEAHS2 understands from para. 2.6.14, CFA5 Report, quoted above, that excavated material from only 3.5km of the 9km twin bore tunnel route through the Northolt Corridor/ LBE will be removed in Ruislip via rail using the Chilterns Line and that therefore West Ruislip will not be further adversely impacted by the construction of the Northolt Corridor/ LBE tunnel proposal than would have otherwise been the case prior to the current Proposed Scheme. NEAHS2 welcomes the fact that boring the tunnel from both the West Ruislip and Victoria Road ends will minimise the additional impact on communities and local transport infrastructure resulting from the construction of the Northolt Corridor/ LBE tunnel.


11.NEAHS2 would nonetheless stress the primordial importance of locating and securing deposition sites in respect of the Northolt Corridor/ LBE excavated material (if this has not already been achieved) in order to inform and determine excavated material removal methods and routes at the earliest opportunity. 


12.NEAHS2 notes that ‘The impact of construction traffic has been assessed on the assumption that all excavated material from the worksites would be removed by road, although investigation will continue to establish the possibility of movement by rail.’ (para. 12.3.3, CFA5 Report). NEAHS2 would welcome as much excavated material from the Northolt Corridor/ LBE tunnel as possible being removed by existing rail networks – and even canal (as suggested inter alia by TfL) if that were a feasible option – so as to reduce the impact on local road networks outside of the Northolt Corridor area.


13.NEAHS2 is concerned that ‘The strengthening of major utilities plant may involve partial or full road closures (e.g. at Hanger Lane east bridge and elsewhere) and result in wider area traffic diversions which will be assessed and reported in the formal ES.’ (para. 12.3.8 CFA5 Report). NEAHS2 stresses that any partial or full road closures, particularly involving the Hanger Lane Gyratory should be kept to a minimum.


14.NEAHS2 has a number of minor but significant concerns relating to the impact of the LBE/ Northolt Corridor tunnel proposal within the LBE/ Northolt Corridor. These relate to the impact of the proposed ventilation/ intervention shafts along the Northolt Corridor and in particular the proposed ventilation/ intervention shaft located at Mandeville Road. NEAHS2 has passed on these concerns to the London Assembly Environment Committee for inclusion in its response to the Draft Environmental Statement and Design Refinement Consultation.


15.NEAHS2 notes that the Mandeville Road ventilation/ intervention shaft would/ is anticipated to require the demolition two semi-detached residential buildings – nos. 39 and 41 Mandeville Road and the pumping station on Mandeville Road (para. 5.5.2, CFA5 Report). NEAHS2 observes that the statement that the ventilation shaft ‘…would require the demolition of two dwellings on Mandeville Road (numbers 39 and 41)’ at para. 5.5.2 of the CFA5 Report contrasts with the statement ‘Two residential properties may need to be demolished depending on the size of the construction site at Mandeville Road, which is still to be finalized’ at para. 4.3.4, Design Refinement Consultation Document – and would appreciate more clarity on the necessity of this demolition.


16.NEAHS2 notes that ‘The vent shaft site at Mandeville Road is mostly densely covered with mature and semi mature trees and scrub’ (para. 2.2.15, CFA5 Report). Given that ‘Residential receptors (i.e. residents) have a high sensitivity to change and are located in streets close to the proposed vent shaft sites, most notably at Mandeville Road’ (para. 9.4.5, CFA5 Report) and ‘Changes would be most notable at the vent shaft site at Mandeville Road where the construction works would affect users of Mandeville Road, the residential properties on Carr Road and Badminton Close. Some of the properties would benefit from screening elements to the rear of the gardens’ (para. 9.5.6, CFA5 Report).


17.NEAHS2 questions whether the Mandeville Road ventilation/ intervention shaft is entirely necessary for the combined LBE and London Borough of Hillingdon HS2 tunnel, given its proximity to the Greenpark Way intervention/ ventilation shaft. On the assumption that the Mandeville Road ventilation/ intervention shaft is necessary, and representing local residents in Northolt, strongly proposes that the ventilation/ intervention shaft at Mandeville Road in particular is screened and either camouflaged or designed to a high aesthetic standard that would complement other recently constructed buildings in the area, such as Northolt Leisure Centre. NEAHS2 notes Photomontage LV-12-15 depicting the Mandeville Road intervention/ ventilation shaft in winter 2026.


18.NEAHS2 notes that: ‘There are plans to locate construction compounds for the Proposed Scheme at the following locations within the CFA: West Gate main site; Greenpark Way main site; and Mandeville Road main site. The use of these sites would result in the creation of up to 1,750 person years of construction employment that, depending on skill levels required and the skills of local people, are potentially accessible to residents in the locality and to others living further afield. It would also lead to opportunities for local businesses to supply the project or to benefit from expenditure of construction workers… It is intended that discretionary enhancement measures, such as business support, supply chain engagement and local construction skills development initiatives to enhance local business performance would be agreed between HS2 and relevant stakeholders.’ (paras. 10.5.3 to 10.5.5 CFA5 Report)


19.NEAHS2 welcomes the fact that the construction of the ventilation/ intervention shafts has the potential to provide significant employment to people in the local wider Northolt Corridor area and supply orders to local businesses. NEAHS2 strongly proposes, as a stakeholder representing local people and businesses, that HS2 Ltd fully exploits this local employment and economic enhancement potential by means of methods such as advertising employment opportunities in local newspapers, trade magazines and websites. 


20.NEAHS2 welcomes the fact that  ‘…there would be minimal traffic and transport impacts related to the main construction site compounds at West Gate, Greenpark Way and Mandeville Road as most traffic and transport effects have been avoided by the route being in tunnel under this area.’ (para. 12.5.2, CFA5 Report) However, while NEAHS2 notes that ‘… the change will generally represent an increase of less than 10% which is regarded as not significant…’ (para. 12.5.5, CFA5 Report) NEAHS2 notes that Table 6 – Typical vehicle trip generation for sit compounds in this area – states that there will be less than 100 typical daily number of two-way trips. This could still amount to 99 daily two-way trips, which would – and any figure approaching this number would – have an appreciable impact on the local road network. NEAHS2 therefore stresses the importance of meeting the measures in the Construction Code of Practice relating to HGV management and control measures.


21.NEAHS2 is concerned that it is merely ‘assumed’ that ‘significant noise effects from the operation of tunnel ventilation shafts would be avoided through the design and specification of the shafts and any fixed plant and equipment’ (para. 11.3.5, CFA5 Report) and would welcome more certainty on this matter.


22.In relation to the Tunnel Boring Machines (‘TBMs’) NEAHS2 notes that ‘Each TBM would be likely to generate ground-borne noise and vibration impacts but only at receptors within a close distance of the centre line of the tunnels and only for short periods of time (a few days)… Overall, the deeper the tunnel the lower the impact. The perceptible noise and vibration would increase as each TBM approaches and diminish as it moves away from the receptor… Vibration from TBMs would present no risk of any building damage… The effects of vibration from TBMs on building occupants would be short term (a matter of days) and hence they are not considered to be significant. Proactive and advanced community relations in advance of the TBM passing under properties would help manage expectations and allay possible concerns over the short-term presence of vibration. Potential construction noise or vibration effects could occur on the receptors closest to the construction areas in the following communities: Properties in the vicinity of Conway Crescent and Bennetts Avenue, during the construction of the Greenpark Way vent shaft… Properties in the vicinity of Badminton Close and Tenby Gardens, during the construction of the Mandeville Road vent shaft (refer to Section 2.2/2.3 of this Community Forum Report and to maps CT-05 Construction features’ (paras. 11.5.3 to 11.5.5 CFA5 Report)


23.NEAHS2 strongly proposes that any property owners and occupants that may be temporarily affected as described in the above paragraph should be advised in advance of the TBM passing beneath their property and reminded and reassured that the vibrations would be temporary and would present no risk of any building damage.


24.while NEAHS2 welcomes the location of the proposed auto-transformer station enabling HS2 to connect to the 400kV National Grid electricity network, adjacent to the intervention and ventilation shaft proposed at Greenpark Way in Greenford (as indicated on map CT-06-012) NEAHS2 is concerned that a feeder station is also required but that its location has not yet been cited.


25.NEAHS2 notes, as a miscellaneous minor point, that at para. 2.1.19 of the CFA5 Report the Brentham Sports and Social Club is incorrectly stated as being located in Perivale.


Alex Nieora (LLB) Chairman – NEAHS2

For and on behalf of NEAHS2


14 June 2013