Please find attached the Wells House Road Residents Association response to the HS2 AP2 ES consultation. Many thanks

Transcription

1 Please find attached the Wells House Road Residents Association response to the HS2 AP2 ES consultation. Many thanks

2 WELLS HOUSE ROAD RESIDENTS' ASSOCIATION RESPONSE TO AUGUST/SEPTEMBER 2015 HS2 ENVIRONMENTAL STATEMENT AP2 CONSULTATION (CFA4 Kilburn to Old Oak Common) - 5/9/ Wells House Road Residents' Association ('WHRRA') represents residents living in Wells House Road, East Acton ward, in the London Borough of Ealing ('LBE'), London NW This document is our response to the August 2015 HS2 AP2 Environmental Statement (the 'Proposed Scheme') Consultation relating to Phase One of HS2 and specifically addresses the impact of HS2 on Wells House Road (WHR), Old Oak Common Lane (OOCL) - and other areas affected by HS2 located in East Acton ward, in LBE, London NW Wells House Road is a triangular cul de sac of around 125 homes of which 45 are occupied by people who have lived in the street for years. At least ten homes are occupied by the children of the original residents and many are caring for elderly parents in these homes. It is a culturally diverse and integrated street, that includes both white British and first generation immigrants from the Caribbean, many of whom have grown up and played in the street together. In short, this is a traditional family community that has a strong desire to retain its integrity as such. It should also be noted that many people chose to move to Wells House Road as it is an oasis of peace and quiet, close to West London areas such as Notting Hill, Shepherds Bush and Kensal Rise and with excellent transport connections. There are around 25 children under the age of 18 living in Wells House Road who can be seen and heard playing safely in the street. 4. Wells House Road also has exceptional views across London to the London Eye and the Shard. 5. It should be noted that Wells House Road residents share the majority belief that the negative impact of HS2 on communities along the length of the line, the economy, the environment and broader rail improvements far outweigh any tangible benefits. Indeed, as specified in the Environmental Statement, there will be significant job losses in the 'deprived' Old Oak Common Park Royal area while demolitions and construction are underway, causing many businesses to close. To date, HS2 Ltd and the DfT have failed to provide evidence of a business case for HS2. 6. We would also like to highlight HS2 Limited's reluctance to respond to any of Wells House Road's consultation responses. We still have received no answers to questions and issues raised over the past 5 years. 7. In addition, the information we receive from HS2 Limited continues to be incomplete and often misleading and inaccurate. HS2 Limited staff have not engaged with residents and are not proactive in providing information, even during the drop-in for this consultation

3 8. The staff who are tasked with dealing with Wells House Road are junior and demonstrate a lack of understanding of residents needs and the issues at hand, and are not empowered to provide solutions. 9. Overall, the 'community engagement' is grossly inadequate. Considering the nature of the extreme impact (namely, that Wells House Road is probably the worst impact street in the UK) and the longterm stress and anxiety it has caused residents, the process and HS2 staff interfacing with residents demonstrates a total lack of understanding and empathy. A cynical person could easily believe that the process and approach has been designed to frustrate, exhaust and put off the victims of HS2. Overall concerns 10. Objections are being presented around numerous issues arising from the scheduled works and proposed amendments to the Bill in the Old Oak Common area in the London Boroughs of Ealing and Hammersmith and Fulham, the lack of mitigation of effects and the lack of compensation for communities impacted by the construction and operation of HS These objections are in addition to those presented in the previous Wells House Road petition and Environmental Statement response. 12. WHRRA objects to AP2 as it both ignores the past 4-5 years of consultation submissions by Wells House Road Residents Association, offering no solutions for the negative impacts and, in fact, worsens the already extreme and long-term impact on residents' homes, lives and the community. 13. It should be noted that HS2 Ltd has yet to respond in writing to any of the past consultation responses by Wells House Road Residents Association and individual residents. Old Oak Common Lane (OOCL) closure mitigation 14. Within AP2, there is provision for temporary road and footpath closure of OOCL for a period of approximately 12 months during the works to the lower the road at OOCL. However, AP2 also states that this access can be removed at any point during construction. 15. We not believe that all options have been explored to keep the road open for vehicles, including cars and buses. WHRRA does not believe sufficient measures have been taken to support vulnerable people who need access to shops and services south along OOCL. Nor is there sufficient mitigation for bus users or pedestrians who cannot walk long distances. 16. WHRRA requests that firstly HS2 Ltd revisit whether vehicular access could be maintained in some form and there are more stringent restrictions on the ability to remove access at periods during construction. Also, WHRAA requests that further mitigation is provided, including but not limited to the following measures: Transport to pick children up from Wells House Road (there are currently approximately 20 school age children living in the road with many more pre-school) or from directly below the bridges by Old Oak Common and run them to the various schools south of Wells House Road Measures to help elderly and less-mobile persons who need to access shops, doctors, hospitals and services south of Wells House Road Requirement for payments for grocery delivery services Requirement for taxi service for residents returning to WHR after dark/after 10 p.m. from East Acton Requirement for 228 rerouting on shortest possible route and a turning point close to Wells House Road Requirement for regular shuttle bus to take residents to Harlesden, North and East Acton, and to

4 alternative transport hubs Security measures to protect pedestrians using a non-vehicular route, particularly since they will need to pass through a tunnel surrounded by a building site, often in the dark of winter West Coast Main Line turnback 17. Within AP2 there is provision for a flyover south of Wells House Road with three turn-back sidings for the Crossrail service and passive provision for a West Coast Main Line Crossrail link to enable up to 12 trains per hour to be turned back at Old Oak Common. We believe this will be a 24-hour a day operation with one or two trains every 5 minutes at 30 or 40 mph. The height of the flyover is likely to mean it is at the same height as the upstairs bedrooms of properties along Wells House Road. The noise, light, and visual impact would impact severely on the quality of lives, both during construction and operation. 18. In addition, at meetings between Wells House Road residents and HS2 Ltd staff, they had provided reassurances that after constructions works, the area south of WHR would be changed into woodland, however this is now not the case. 19. We believe that some woodland will be restored but Wells House Road will no longer gain benefit from this as there will be a viaduct between homes at the southern side of the road and the woodland. 20. In addition, this woodland is home to a diverse range of wildlife and we require an ecologists report to ensure that this is preserved. 21. We would also request that part of this woodland is turned into a space that local children could use during and after HS2 operation. 22. WHRRA request that further explanation is given to residents regarding the details of the flyover, including the height and what other options have been looked at which would mean the flyover has less of an impact on residents. WHRRA requests that further mitigation is provided, as there appears to be no mitigation for residents affected during the construction of the flyover and afterwards during the operation of the railway. WHRRA also requests that HS2 Ltd explain to residents the extent of temporary and permanent land take of their gardens behind the turnback and behind Old Oak Common Lane. 23. It should be noted that Wells House Road was made aware of the plans for a flyover before the Select Committee visit to the area but that during the visit, HS2 Ltd informed residents that the Crossrail/WCML link was unlikely to take place due to cost and therefore we were not permitted to discuss this with MPs on their visit to Wells House Road. WHRRA would like to understand why HS2 Ltd was not open with residents over such an adverse impact and did not engage with residents on this before the AP2 was published in order to allow time to explore other options. Impacts from construction traf ic 24. With AP2 there are now significantly more traffic movements that affect additional roads and residential areas within the Old Oak and Acton area. There are 700 two-way lorry movements now planned - double the original number stated. This appears to be as a result of the removal of a haul road, which would have taken lorries off normal roads which local people use, and it is also as a result of the delayed Hex depot relocation. We would also like clarification as to whether these are 350 versus 700 lorry movements each way, the latter adding 1400 lorry movements to the area. 25. WHRAA do not believe that any mitigation has been proposed for this construction impacts which will affect residents and have possible knock-on impacts including:

5 Air pollution: that will have particularly negative impact on the young children, elderly and people with pre-existing lung and heart conditions and asthma. Noise and vibrations: that will impact particularly on backs of homes on the eastern side of Wells House Road, rendering rooms and gardens unusable. Congestion: this will impact on everyone using local roads and will further isolate Wells House Road. Residents will have difficulty using cars or buses and congestion will particular impact on the many residents who use their cars and vans for work. It will also increase journey time to work, leading to lower productivity/lower earnings, and increase journey time to school. WHRAA are also concerned that lives will be endangered due to slower access to emergency vehicles. Importantly, as traffic in the area gridlocks, air pollution will increase, negating the benefit of the 'smaller' HGV vehicles. Destabilising the Wells House Road Retaining Wall: Vibrations from additional traffic will increase the deterioration of the retaining wall, made from Victorian clinker. The homes and gardens on the eastern side of Wells House Road, are likely to be at risk of subsidence or even collapse. WHRRA requires the wall to be temporarily reinforced until it is rebuilt during the time that Old Oak Common Lane is lowered. 26. WHRAA requests that HS2 Ltd: Look at impacts on local junctions in particular around Atlas Road Satellite Compound. Rethink the activities that are done in the many construction compounds close to Wells House Road in order to minimize lorry movements. Explore further use of rail and the canal must be explored first Use further opportunities for construction tunnels and canals for transportation. Maximize use of the conveyor belt whilst also mitigating impacts to properties close to the conveyor belt. 27. WHRAA would also like to highlight that Old Oak Common Lane has never been identified as a main thoroughfare for traffic for the HS2 Station and we request that its use for HGV vehicles does not lead to road widening or earmarking as a main access route. Electricity sub-station 28. Within AP2, an electricity sub-station is being relocated in close proximity to at least six properties that we do not think is acceptable or necessary. WHRAA requests that an alternative location is chosen which would have less of an impact on residents. There is much space along the railway lines that does not impact on residents. This actually seems like a vindictive decision by HS2 Limited. Second World War Pillar Box 29. WHRRA requested that the Second World War Pillar located within Old Oak and outlined in AP2 as scheduled to be demolished, is instead relocated. 30. We believe there may be other similar structures that should be removed rather than destroyed. Mitigation required for Wells House Road residents 31. WHRRA would like to re-emphasize and request resolution of points made within our original petition that have been ignored. These include: a) WHRAA believe that Wells House Road is one of the most impacted streets along the proposed HS2 line. Given the community impacts are widespread over such a considerable period of time and extremely high in terms of adversity, we believe Wells House Road should

6 be classified as 'sensitive receptors' and therefore treated as a special case that merits further review and mitigation proposais to better deal with the acknowledged significant impacts. The need for Wells House Road to be recognised as 'sensitive receptors' has been repeatedly stated by Ealing Council and Wells House Residents Association and continues to be ignored. b) Whilst HS2 Ltd has held a series of community forums and met with the residents of Wells House Road, not all impact has been communicated e.g. at the one-day AP2 drop-in, the impact to the wider area via the 700 HGV journeys was not mentioned. In addition, the needs of residents regarding mitigation of impact measures and property compensation laid down in our 50-page response to the HS2 Environmental Statement consultation has received no response. c) HS2 Ltd must provide the exact route for the HGV vehicles and how this would be impacted by the proposed ban on HGV vehicles turning left. d) In addition, HS2 Ltd continues to downplay the loss of amenity, multiple impacts and overall isolation, using terms such as 'negligible to moderate' despite the scale and duration of impact on residents. e) Currently, the only compensation available to Wells House Road residents is via the 'Need to sell' scheme. WHRAA believe this is grossly inadequate due to a number of reasons. In summary, the current value of properties does not allowing residents to purchase alternative homes of the same size and quality in the area and thus being driven out by the development would have severe negative impact on the quality of residents lives. In addition, the current scheme excludes a) people who 'want' to move in the next 10 years; b) landlords; c) people purchasing after 2010; d) people in Shared Ownership, housing association and council properties. f) Compensation should be developed to allow for the exceptional circumstances of Wells House Road. This should be more in line with rural areas but should include compensation over and above this to allow for the multiple impacts on the immense scale that it is. This should also allow for people who wish to/need to move and for people who wish to stay but to retain their current quality of life, i.e. free from noise and pollution. g) Further, we are concerned that the option to sell to the government will negatively impact on community cohesion and that those of us who chose to stay could become isolated in a broken community, surrounded by empty homes or homes rented to undesirable tenants. This would further devalue property prices and our quality of life and is likely to lead to an increase in crime. h) Overall, WHRAA believe a scheme should be developed that allows residents the choice to stay, leave or temporarily leave their properties without adverse impact to their quality of life. i) Regarding the CPO of gardens on the eastern side of Wells House Road for the lowering of Old Oak Common Lane, residents continue to receive conflicting responses from HS2 Ltd. Clarity is needed as to the impact on residents and to understand what will be offered by way of compensation and mitigation for use and/or destruction of gardens. j) In addition, we have repeatedly requested sound proofing behind gardens on the eastern side of Wells House Road to mitigate the impact of construction and operation. Recently, we have been told by HS2 Ltd, without written confirmation, that a second wall will be built to encase the existing sustaining wall. However, no commitment for sound-proofing was forthcoming and when we suggested HS2 planted sound-absorbing foliage above the new wall, it was suggested residents paid for planting themselves. Again, WHRAA require their voices to be heard and for these types of issues to be resolved. k) There is widespread concern over dust and noise created by the conveyor belts, in view of past experiences of residents around the Crossrail conveyor belts. Again, WHRAA require more details as to what measures will be taken to avoid air pollution and noise, e.g. covering the containers on the belts. l) No benchmark nor corresponding impact measures have been set for the air pollution, noise, vibrations, light pollution or visual impacts across the entire development. WHRAA still awaits answers and solutions. m) WHRAA have requested provisions for temporary housing when noise, pollution or disruption is untenable.

7 n) HS2 needs to deliver a set of plans for the création of both temporary and permanent open space for walkers, children's play areas and dog walkers. o) There is also a lack of sufficient identified mitigation measures to combat landscape and visual impacts both during and post construction. We need to understand the temporary barriers that will be erected around the compounds and the visual impact these will have on homes in Wells House Road. p) Since these structures will be in place for up to 10 years, we feel that these should be designed sensitively to take into consideration: a) visually acceptable to reflect the current and future personality of the area, b) that are functional in terms of being effective barriers to sound and dust, c) that can block lights from the compounds but not take away natural light from homes and gardens. q) Planting of trees will act as natural sound barriers and capture some of the air pollution. We feel planting of mature/semi mature trees should be in the plans from day one. r) The Environmental Statement also fails to mitigate against light pollution and needs to address the need for lighting at night to be invisible to windows overlooking the compounds. Solutions need to be provided for mitigating against light pollution, e.g. lights being switched off at night and only down-lighting to be used. s) No details of HS2 station operation has been provided and therefore WHRAA have no information about the potential impact. We request that more information is provided and that plans are developed to mitigate long-term impacts. t) Overall poor community engagement is yet to be addressed and is exemplified by the lack of inclusion of various marginalised sectors of the community, e.g. travellers, who have at least two sites that will be impacted by HS2; the wider community now impacted by HGV vehicles; people who have no access to online documents or are unable to read or respond to these complex processes. u) After five years of dealing with HS2, WHRAA still have no funding, legal or professional support in dealing with these complex and time-consuming consultations. We request that a budget be provided either direct to residents or via our local authority that can cover the costs of a team of experts. In addition, we would ask for remuneration for loss of income for those people who have had to voluntarily provide time and expenses trying to protect their community from HS Also, within AP2 further impacts are identified as outlined above. Some further soundproofing has been identified by HS2 as being required, however this does not go further enough. All properties on Wells House Road, front and back, will be impacted by noise over a 7-10 year period and up to 24 hours per day. Therefore, WHRAA request robust sound proofing measures to include sound proofing of all doors and windows for all properties in Wells House Road, sound proofing barriers to shield gardens from noise, etc. 33. Importantly there must be effective monitoring of noise, air and light pollution, traffic, visual impact and other impacts from the HS2 construction compounds. In particular, Midland Terrace/Shaftesbury Gardens, Wells House Road and residents in The Island Triangle will be the most affected areas by the HS2 works, in the centre of huge national project employing a big number of sub-contractors and thousands of workers. The existing legal provisions may not be sufficient to deliver effective means of control over operating times, noise, air pollution and behavior of the workers. To survive this vast construction project the local residents need to be assured that their wellbeing is protected effectively. 34. WHRRA would like HS2 Ltd to work with Wells House Road Residents, local London Boroughs, Transport for London, Greater London Authority and Old Oak and Park Royal Development Corporation in order to agree sufficient mitigation for residents in the Old Oak area which reflects impacts arising from the original scheme and AP2 changes. 35. WHRRA would request that HS2 Ltd works with the local London Boroughs, Transport for London, Greater London Authority and Old Oak and Park Royal Development Corporation to improve the Code of Construction Practice.

8 36. WHRRA request that an Independent Body responsible for monitoring the Code of Construction Practice is set up and is easily accessible and contactable by emergency phone number and . In addition, setting up portable air quality monitoring stations in the affected residential areas, under the Monitoring Body's control, with its data available to representatives of local residents. Compensation required for local communities 37. Also, as identified in our original pétition, the existing community fund does not go far enough. And given the changes in AP2, further compensation should be given to the communities affected by living in close proximity to multiple constructions compounds associated with the Old Oak Common Station and the HS2 rail line. 38. WHRAA requests that the existing community compensation fund is increased and residents in London areas have different circumstances therefore should have a larger pot. 39. For the foregoing and connected reasons WHRRA respectfully submit that, unless the Bill is amended and undertakings given as proposed above, the provisions of the Bill, so far affecting WHRAA, should not be allowed to pass into law. 40. There are other clauses and provisions in the Bill which, if passed into law as they now stand will prejudicially affect WHRAA and their rights, (including their human rights) interests and property and for which no provision is made to protect WHRRA and other clauses and provisions necessary for their protection and benefit are omitted therefrom. On-going dialogue 41. Since the plans for HS2 are being continually amended, WHRRA requests the development of a responsive and transparent community engagement programme that can address new developments as they arise. For example, Wells House Residents have been repeatedly told that they will 'benefit' from a view over a state-of-the-art station design. However, we believe agreement has now been reached to build up to 73 storeys above the station. This would effectively block light and views and render gardens unusable. We request a collaborative channel that includes local residents before decisions are reached that negatively impact on Wells House Road, Midland Terrace, Shaftesbury Gardens, the Island Triangle and other people living and working in the area. 42. Importantly, we have asked for an option to be considered to move the HS2 Old Oak Common Station to the east. We believe that if the OPDC had been formed when HS2 was first conceived, this would have been a logical solution. The moving of the station would offer multiple benefits: It would add distance from Wells House Road and all residential properties and thus reduce the impact. The station would be located in the centre of the OPDC Old Oak Common area and be a benefit to a greater number of new residents and businesses. It would allow the access point to Wormwood Scrubs to be to the east, i.e. where the playing fields are rather than the current solution of accessing the area through the bird sanctuary. The main station would be closer to the new Overground at Hythe Road. In a recent from HS2 to Nick O'Donnell of London Borough of Ealing, HS2 offered no evidence why the station should not be moved. 43. Although HS2 Ltd gave no information on the access to the Old Oak Common station site at their drop-in in Old Oak Common, we believe from their maps that there will be a compound entrance opposite the entrance to Wells House Road. This would basically isolate Wells House Road and would cause extensive congestion on Old Oak Common Lane and the wider area. We again require

9 information on this and if, indeed, there is a plan for the works entrance to be located opposite Wells House Road, we would request this is moved. 44. In the detailed in the appendix, we are led to believe that there will be 'engineering earthworks' and that "There are two entrances off Old Oak Common Lane planned to access the station as described in the ES". It should be noted that HS2 Limited never addressed this in the drop in with any residents and we thus need clarification as to a) what 'engineering earthworks' are and how these will impact on Wells House Road residents and b) since the diagram is unclear, we need the exact location of the 'entrance' and to understand what this is an entrance to, how it will be used and what HS2 Ltd will provide to mitigate any impact on residents. 45. Overall, we have been shown three different maps from HS2 and all illustrate impact differently. These are large print outs shown to us at the drop-in, the AP3 books and the original plans on the Government website. We require full details of which plans are correct. 46. WHRAA requests, under the Freedom of Information Act, to see the agreements made between HS2, GLA and TFL at meetings during the week of the recent HS2 Select Committee hearings. We need to better understand any new impacts that have been agreed and request the right to consult, respond and influence all decisions that have a negative impact on our community - past, current and future.

10 APPENDIX: from of HS2 to of LBE 2/9/15 From: Sent: 02 September :32 To: s Subject: London Borouqh Ealinq Enquiries- s 7th & 28th Auqust 2015 In reference to the questions you raised in your s dated 7th August 2015 and 28th August 2015, please see the below responses from our engineering team. A.) 7 th August 2015 Q -On the turnbacks, can we clarify the land impact. Is it right the works will take WHR gardens right up to their homes? A - There has been no change in land take in WHR related to the provision of turnback sidings. Q -Do you have any idea what the things that look like ordinance survey map rock-formations map on the eastern side of OOCL? are on the A - Engineering earthworks Q - Is there an entrance to the station directly by WHR and Midland Terrace? Can you explain how all this works? A - There are two entrances off Old Oak Common Lane planned to access the station as described in the ES. The attached visualisation shows their location. Q - There was historic promise of woodland to the south of the road (under point 2 above) - what to this? happened A -1 believe answer to this is provided in the second part of point B below Q - Can the station not move further east? (this would benefit the Scrubs as the 'Spanish Steps' access point could go into the playing fields rather than the bird sanctuary, and also it would also make the station closer to the centre of the OPDC area and to the Hythe Road overground station) A - The detailed design of the station has not commenced. However there are severe constraints on moving the surface station eastwards as the GWML tracks must merge into the existing rail corridor east of the proposed station. Q - There is reference to an electricity sub-station close to Wells House Road. Can details of this be provided along with an explanation as to why it is cited where it is and cannot move elsewhere? A - The pro vision of the turnback sidings for the Crossrail service necessitates the relocation of a Network Rail substation. B.) 28 th August 2015 Q - Is that a construction site marked on the map where the Heathrow Express depot entrance is currently? This was certainly never mentioned by HS2 before and would have a massive impact on us (as if we don't have enough already)

11 A - There has been no change to the construction Compounds from those presented in the original Bill. The area highlighted in yellow is main construction compound for the station works and the area highlighted in orange along Old Oak Common Lane is a Satellite construction compound for the road widening. Q - Woodland, south of Wells House Road. I have copied Marc and Caroline Sauzier who live at 89 Wells House Road with their young son. They pointed out that the woodland below the road that is currently going to be taken by the Crossrail/WCML construction is a natural habitat for wildlife. It was this that HS2 had originally agreed to restore after the haul road was closed. They say they see rare birds and animals and this is something they have only recently raised. What can we do to protect this?... But obviously we don't want to put people's homes in jeopardy to save the woodland A - We believe you are referring to the area that is part of the Acton Railsides Site of Borough Importance SBI.I. The temporary loss of this area for the Old Oak Common Lane underbridge satellite construction site was assessed in the main ES as significant. Mitigation was proposed in the form of woodland habitat creation. The proposed amendment in AP2 will increase the amount of land in the SBI area that will be permanently required, thereby marginally reducing the amount of mitigation set out in the main ES, as is noted in paragraph of the AP2 ES. However, the area of mitigation described in the main ES was precautionary, so despite the slight reduction in habitat creation as a result of the amendment no additional mitigation measures are required. In the main ES (paragraph refers), mitigation for the loss of land within the Acton Railsides SBI.I, together with other areas within Ealing SBI.II and the associated mosaic and transition habitat and scrub habitat in the railway land will include the restoration of 11.6ha to equal that lost during construction. These measures, together with the compensatory planting at WormwoodScrubs were considered to reduce the effects on the designated sites (such as Acton Railsides SBI.I) to a level that is not considered significant. We are not aware of rare birds and animals in the area you reference, but I would be happy to ask the Ecology team to look into this in more detail if you are able to provide further details. I hope the above responses provide the detail you are seeking, please let me know if you require and further information Regards Commercial Manager, MOCA (Major Organisations and Complex Agreements) Hybrid Bill HS2 Ltd Facebook Twitter LinkedIn

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