Dear Sir/Madam,

SUBJECT: LONDON BOROUGH OF EALING RESPONSE TO THE HS2 PHASE ONE ENVIRONMENTAL STATEMENT In response to the recent consultation on the HS2 Ltd Phase One Environmental Statement (ES), Ealing Council hereby submits its formal response. This is divided into two main sections around the two community forum areas that cover the Borough (Area 4: Kilburn to Old Oak Common and Area 5: Northolt Corridor) and comments are presented under the relevant section heading under the area reports. To assist focus in what is an understandably complex task at this point I have in general restricted comment to areas where there is either obvious contradiction or substantial impact suggested. Community Forum Area Report - 4 Kilburn (Brent) to Old Oak Common Overview of the Area and Description of the Proposed Scheme A lot of the plans produced make it extremely difficult to fully comprehend some of the proposed measures. For example, a key local impact is the “construction of retaining walls to accommodate widening of and improvements to Old Oak Common Lane”. This is meant to be shown on Map CT-06-009a but it is not visible or annotated on the plan and no further detail appears to have been provided. More detailed plans and sections would help us better understand these key local impacts allowing us to comment more effectively. Section 2.3.26 refers to a number of elements that require further detail. This includes the lowering of Old Oak Common Lane under the GWML Bridges. Paragraph 2.7.18 mentions that “separate bus lanes will be created” but given only the low frequency 228 bus uses this section, the Council would like to explore the design and rationale for the proposed changes as well as working with TfL to review the bus network as a whole during the planned works.

FREEPOST RTEC-AJUT-GGHH HS2 Phase One Bill Environmental Statement PO Box 70178 London WC1A 9HS

Ealing Council Perceval House 14/16 Uxbridge Road London W5 2HL Tel: (020) 8825 8078

Your ref: My ref: Please ask for: Date:

Nick O’Donnell 27th February 2014

Transport Planning Service

The Council would also request more detail on sensitive works such as new boundary retaining walls along the A4000 Victoria Road and extending the existing bridge on the A4000 Victoria Road above the London Underground Central line to provide a pedestrian footway. In relation to the construction of the retaining walls, the Council would like assurances that there will be no permanent land take of residential and business properties in this area and that full details of the walls are agreed with the Local Authority in advance of any works. Given the works in paragraph 2.3.26 are on Borough roads and public rights of way, we require a condition to see full details and sections of these plans and to better understand the nature of the works planned here. Again, these are not annotated in sufficient detail on any plans to enable appropriate comment. In 2.3.26 there is also reference to “widening and improvements to the A4000 Victoria Road to provide four traffic lanes from the junction of Old Oak Common Lane/Old Oak Lane/Atlas Road southwards to Wales Farm Road at Gypsy Corner junction”. The Local Authority has not been provided with any detail of this aspect of the project nor any of the supporting traffic modelling work to demonstrate its impact on the local and wider network. The plans provided also do not show this widening south of Garrett Close. We would request this information and clarification accordingly along with further discussion on any of the planned “modifications to junctions on Old Oak Common Lane and the A4000 Victoria Road with adjoining roads, private accesses and frontages to take into account the widened roads and changes in levels at the boundaries of the road improvements” and any modifications to footpaths in the area such as “The footpath and steps between Wells House Road and Old Oak Common Lane will be realigned”.

The Council would like to better understand what alternative options were explored for the construction of new pedestrian subways and associated retaining walls on either side of the A4000 Victoria Road under the Cricklewood to Acton Wells Line (paragraph 2.3.26) and the “widening of the A4000 Victoria Road requiring the removal of the pavements either side of the road carriageway and the creation of two underpasses” (paragraph 2.7.28). There does not appear to be any drawings of these and the Council has some serious reservations on these measures given the lack of detail and the mention of “the closure of the Cricklewood to Acton Wells Line and the A4000 Victoria Road for different periods of time”. The cumulative impact of these closures along with significant planned restrictions on Old Oak Common Lane does not appear to have been covered in the ES.

It should be noted there is a general London wide policy of not building new subways as many have security issues and are being infilled. Indeed, TfL has a policy to remove subways and replace them with surface crossings where it is feasible to do so and TfL’s Streetscape Guidance (2009) states that “when reviewing the streetscape of the TLRN, opportunities for introducing safe new at-grade pedestrian crossings as alternatives to subways should be explored”. Accordingly, we would like to explore what other alternatives may be possible

to both avoiding pedestrian subways but also reviewing alternative options and details for the works around the A4000 Victoria Road.

In addition, paragraph 2.3.29 refers to the footpath and steps between Wells House Road and Old Oak Common Lane being realigned. We would like to see full details of this prior to any works. Paragraph 2.4.25 states that “There will also be movement of construction plant and materials via the rail network”. The Council would like to see greater detail of what exploration of non-road transport has been considered as part of the project (including rail and water transport) and what commitments could be provided in relation to minimum levels of transport by these modes to reduce the impact on the road network.

Furthermore, the Council would like to see greater commitments towards regulating car use by the workforce on the project from the surrounding worksites. The temporary haul road proposed in paragraph 2.4.26 will require a temporary bridge over Old Oak Common Lane. The Council would request details over the design and operational hours of the road and associated bridge. One the single biggest concerns for the Council is the statement in paragraph 2.4.40 “temporary closure of Old Oak Common Lane will be required for a period of approximately one year to allow for lowering and widening the road beneath the GWML rail bridges”. Given the significant impact of this closure, coupled with the planned restriction on cyclist and pedestrian movement to the south, the Council would like alternative options explored and evidenced. This should include options around avoiding the closure, single lane restricted operation and temporary footbridges for pedestrians and cyclists. Paragraph 2.4.59 indicates the Atlas Road Satellite Compound will necessitate the demolition of an existing bus depot. However, paragraph 10.4.1 states that provision has been made to ensure that two bus depots at Atlas Road can remain operational throughout the works through reconfiguration of their facilities. The Council would welcome clarification on the impact to bus facilities in the area and what agreements have been reached with the relevant operators on the impacts and it would welcome information as to the reconfiguration being suggested. Air Quality

Paragraph 4.4.10 predicts that during construction there will be “substantial adverse impacts on NO2 concentrations on Shaftesbury Gardens and Victoria Terrace, Victoria Road and that “These impacts will result in a temporary significant effect for these receptors”. However, the end of the same paragraph also states “These impacts will not result in significant effects for receptors”. The Council would like clarity on this issue. We also assume the

reference to “Victoria Terrace” is meant to refer to “Midland Terrace”. Similar clarification on this would be welcome.

A Code of Construction Practice (CoCP) is to be developed for implementation along the route with Local Environmental Management Plans (LEMPs) also developed to set out the specific measures to be used in each area. Some example mitigation measures are included in the report. These focus on reducing dust impacts. Measures will also be required to reduce emissions (particularly NOx) from vehicles and plant on site. The Council would want to see the CoCP and LEMPs so we can check the planned mitigation measures to ensure they are adequate. Particular attention will need to be paid to protecting sensitive receptors close to the main construction sites. Community Paragraphs 5.4.7 to 5.4.12 describe a series of significant impacts to the Wells House Road community. This includes:

Being bordered on all sides by construction activity and worksites with access only possible from the north sharing the road with construction traffic

A number of in-combination effects on approximately 100 properties resulting in significant all day and night noise and visual effects over a period of five years which will have a major adverse effect and is described as “significant”

As mentioned previously, the proposed closure of Old Oak Common Lane for a year represents one of the fundamental impacts of the project and a major cause of community concern. The Council would like to better understand what alternative options have been explored around this and ways in which this impact could be minimised further or resolved. Paragraph 5.4.13 refers to 65 properties on Shaftesbury Gardens, Midland Terrace and Old Oak Common Lane experiencing in-combination noise and visual effects during construction as well as a significant increase in HGV traffic for periods of between two to five years which would be a major adverse effect and be considered significant.

Public Open Space

Paragraph 5.4.16 outlines the loss of both the western and eastern side of Victoria Gardens for a two year period. This is described in paragraph 5.4.17 as a “major adverse effect” yet no mitigation is proposed. The Council would like to explore what other options have been explored both in terms of works that avoid the loss of this valuable public open space in an area of open space deficiency and also alternative sites considered for both temporary and permanent reinstatement.

Paragraph 74 of the National Planning Policy Framework states that:

“Existing open space, sports and recreational buildings and land, including playing fields, should not be built on unless:

An assessment has been undertaken which has clearly shown the open space, buildings or land to be surplus to requirements; or

The loss resulting from the proposed development would be replaced by equivalent or better provision in terms of quantity and quality in a suitable location; or

The development is for alternative sports and recreational provision, the needs for which clearly outweigh the loss”

In light of the HS2 Environmental Statement proposing that only 80% of the eastern part and 70% of the western part of Victoria Gardens will be reinstated, the Council does not feel this to be adequate reprovision and would like to explore further options. These open spaces are already very small so further permanent 50% loss of open space will significantly limit their use. With a future loss of this space it seems unlikely that its use as an informal recreational space will continue.

The widening of the A4000 Victoria Road will also require land at Cerebos Gardens, described in the ES as “a strip of grass directly north-east of Victoria Gardens”. Cerebos Gardens currently functions mainly as a narrow buffer where trees improve the street scene with some other occasional recreational activities. Paragraph 5.4.18 proposes the loss of this area for a two year construction period and paragraph 5.4.24 states “the widening of the A4000 Victoria Road requires about 50% of this strip of grassed area permanently”. No replacement space is proposed and the impact is described as not resulting in a significant effect. The Council disagrees with this assessment and would accordingly wish HS2 Ltd to explore alternative options to mitigate this impact. The eastern side of the gardens is not a grassed area. It is full of mature trees which should be protected and as a minimum replaced with semi mature trees.

It is suggested in the documents (Appendix CM-001-004) that the loss of open space could be compensated for by the use of alternative incidental spaces nearby around Shaftesbury gardens but these spaces are private and are not designed or designated as public open space so they have limited use. The same issue arises with the relocation of the play area from Victoria Gardens unless separate arrangements can be made with the landowners of private land there are no obvious alternative sites locally for the proposed temporary play area. The council would like to remove the existing play equipment in Victoria Gardens and relocated it to other parts of the borough before works commence.

This area of the borough is already deficient in open space, therefore the Council would like to see opportunities taken to offset the loss of open space with the creation of new open spaces within other parts of the scheme in the area. We would also like to clarify if the landscaping on the eastern side of Old Oak Lane will incorporate new public open space or green space of some sort. The drawing does show a large area of green space but it is not clear

how these spaces will be used. The size of the local community is rapidly increasing with developments around North Acton Station and will continue to increase so new open space is needed in the local area. The proposals hint at replacement trees to replace those lost but we would like clarity on the level of enhancement. The sites for planting in the street environment in the Park Royal area are very limited due to the level of services in the footways and damage caused by vehicles. With the large scale of the works we would like to see the opportunity taken to create dedicated planting sites for trees. It is noted that a 10m strip on the southern side of Acton Cemetery will be temporally required for the works. We would like further information on whether the 10m strip is within the cemetery or measured from the edge of the boundary fence with the central line. This area does incorporate a public footpath linking Park Royal Road with Chase Road so it is assumed this path would close during the works we would like clarification on this.

Community Infrastructure

The Council would like a commitment that the Transition Skills Centre (used by Kensington and Chelsea College on School Road), which provides training in the skills required for employment in the construction industry, will be relocated with full costs covered by HS2 Ltd into one of the alternative units nearby.

As highlighted in the previous section on Public Open Space, the Council does not consider the proposed mitigation to both the temporary loss and permanent reinstatement of the children’s play area in Victoria Gardens and the land at Cerebos Gardens to be adequate.

Mitigation

The Council feels that much of the identified mitigation requirement set out in this section should have been detailed in the Environment Statement. For example, given HS2 Ltd has been in dialogue with the Council over its concerns on isolation effects on residents in the Wells House Road area for the last two years, we think it not unreasonable that details of potential mitigation should have been captured within the ES.

For the reinstatement of the children’s play area (paragraph 5.4.30), this should be on a minimum like-for-like basis with no reduction in space in our view.

Landscape and Visual Assessment

The temporary effects during construction, most notably the removal of trees and vegetation, is described in paragraph 9.4.16 as resulting in “the loss of key characteristics of the character area”. With the introduction of large scale and prominent features into the area, and significant impacts on local views in

multiple areas, the Council would like to see more significant proposed mitigation to combat these effects as none appear to be described in the ES. Mitigation proposals will only be acceptable if equal to or greater in size of habitat loss and existing species richness.

Paragraphs 9.5.31 and 9.5.36 note that tree planting after construction will not have established sufficiently to provide any screening in year 1 of operation. The Council would like to explore further options for enhanced screening during the critical first year of operation.

As stated previously the statement in paragraph 9.5.46 that the “play area and other open spaces in Victoria Road will be permanently reduced” is not fundamentally acceptable to the Council. Further options will need to be proposed to adequately mitigate this impact.

With regard to change in business amenity value, it is noted in paragraph 10.4.4 that “The Holiday Inn on Victoria Road may experience potentially significant noise and visual effects as a result of the proposed construction activities associated with the Victoria Road crossover box main compound”. Given these effects will occur over a five-year period and is deemed to have a “significant amenity effect on this business”, the Council would like further commitment from HS2 Ltd on how this business (and others affected) will be supported through these works. 38 business units within this area will be directly impacted, yet the ES fails to provide any proposed mitigation which is very worrying.

Paragraph 10.4.18 indicates the need for demolition of a warehouse/distribution centre at 96 Victoria Road and a large retail warehouse on Atlas Road. The Council would like to see a commitment from HS2 Ltd to the permanent relocation of these businesses with full costs covered by HS2 Ltd into alternative accommodation nearby allowing for local employment continuity. Whilst paragraph 10.4.27 describes “additional support over and above statutory requirements to facilitate this process”, greater clarity is needed on the extent of this and particularly what provisions will be made for the Holiday Inn.

In light of the above described significant impacts, the Council strongly disagrees with paragraphs 10.5.2 and 10.5.3 that state “There are no resources considered likely to experience significant direct effects during the operational phase of the project within this area” and “No businesses have been identified within the area that are expected to experience significant amenity effects as a result of the Proposed Scheme”. These statements directly contradict statements made earlier.

Sound, Noise and Vibration

This section fails to provide sufficient detail of the measures to mitigate the effects on residents in this area. Whilst paragraph 11.3.12 states that mitigation measures on individual dwellings will ensure that noise inside all dwellings will not reach a level where it will significantly affect residents, the

Council would like to see further commitment on the measuring and monitoring of the sensitive receptor areas we have suggested, built into the draft Code of Construction Practice (CoCP).

There is considerable airbourne noise anticipated with resulting direct effects to communities along with ground-borne noise and vibration direct effects on non-residential receptors. These are set out in Table 15 and paragraph 11.3.19. However, the only mention of mitigation is in paragraph 11.3.28 which states “HS2 Ltd will continue to seek all reasonably practicable measures to further reduce or avoid these significant effects”. This is not deemed sufficient and the Council would have expected the ES to provide some indication of the sort of measures likely to be considered.

In addition, within Table 1 of Volume 5 Technical Appendices CFA4 Construction assessment (SV-003-004), the mitigation steps are not listed. The only column headed “mitigation effect” is blank, except where it is advised that noise insulation will be offered (NI) for dwellings suffering significant adverse effects. It should be noted that no specifications are given for the sound insulation which would be fitted or the criteria it will meet. At Appendix SV‐001‐000: Annex C (Airborne sound – Assessment methodology) generalised information is given on mitigation. LB Ealing considers that it is not sufficient enough to state that lead contractors will seek to obtain s.61 consent. If full mitigation measures are not to be specified at this stage, then there needs to be a firmer commitment with regard to s.61 consents, by a statement that “contractors and sub-contractors will be contractually bound to submit applications for consent under the s.61 procedure to LBE, for all works”. A specification for the quality, stability, preservation and laboratory testing of barriers is not given. Operation of stationary plant and machinery At Appendix SV‐001‐000 Annex E ‐ Operation of stationary systems it is advised that the assessment methodology used for the sound and vibration assessment is based on the principles set out in BS4142:1997 and that this methodology requires an assessment of the sound produced by the stationary system under assessment against the background level. It is further advised that SMR Table 34 outlines that impacts due to stationary sources are identified where the rating level of the new source exceeds the background level by a margin greater than 5 dB. The semantic scale is set out at Table 1 as reproduced below:

This scale was challenged by the Council’s Pollution Technical Team (PTT) in a document issued on 30 May 2012 (see Appendix 1). The comments were comprehensive and referred to the need to take account of uncertainty in methods to predict noise and vibration and in the selection of criteria and it was expected that a full response would be received because of the impact that the proposal would have within the London Borough of Ealing. However, no response has been received to date.

A further reply to Arup on the 18th June 2012 advised that the following matters had been raised by LBE in the original comments:

Need to deal with prediction uncertainty.

Need for more information on barrier design and testing to ISO standards.

Adequacy of scale for quantifying the magnitude of impact.

Adequacy of BS4142 scale.

No reply was received to this communication. A further HS2 project meeting took place between PTT and the Temple Group acoustic consultancy at LBE offices on 16th August 2012. This was to to seek the views of local authority on the adequacy of the assessment points shown on draft maps for baseline noise and vibration surveys. At the meeting representatives of PTT:

Handed a copy of PTT comments (dated 30th May 2012) to the Temple Group representatives.

Advised that no direct comments had been received from the co-ordinator for Arup, but that a general email had been received with the key comments and actions.

Stated that the reply did not reflect the detail of the comments made by PTT and attributed comments on uncertainty solely to LB Camden.

Advised that an email had been sent to the Arup co-ordinator about this and that the majority of the detailed points were not covered.

A reply was received from the co-ordinator, advising that another person had taken over and that person was copied into the email and asked to respond.

No reply had been received from the new co-ordinator.

The Temple Group representatives undertook to take the matter up with Arup, however no further reply has been received and all of the matters raised have not been referred to at the ES Volume 5, Methodology, assumptions and assessment (route-wide) (SV-001-000). The Council considers that there should have been a full response to its document issued on 30th May 2012, in view of:

The length of the project and the significant adverse impacts identified in respect of the Old Oak Common Station and interchange and at the area surrounding the ventilation shafts in the Northolt corridor

The importance of demonstrating that the predictions are accurate within reasonable limits and that the adopted criteria are adequate enough to quantify the various impacts and set standards for effective mitigation.

The ES states that in avoiding and reducing significant adverse effects of noise, the aim would be to design, construct, operate and maintain the installations so that the rating level LAr,Tr of the fixed installations in normal operation at the worst affected residential receptor, minus the background

level (LA90,T), is not more than ‐5 dB, determined in accordance with BS4142:1997. It should be noted that this is the current LBE planning criterion (set in Supplementary Planning Guidance 10). Within the ES, it is further advised that:

It is anticipated that it will be reasonably practicable to achieve a rating

level minus the background level of not more than ‐5 dB for the majority of the fixed plant that will be required to operate the proposed scheme.

The exceptions to this are the tunnel ventilation systems where, in some locations, it may not be reasonably practicable to achieve the lower design aim.

Robust procedures will be developed and adopted to ensure that sound from all stationary systems is reduced as far as is reasonably practicable. (In this context, reasonably practicable will include consideration of:

engineering feasibility;

cost; and

other design considerations such as the visual appearance of any plant and equipment and any structures which house such plant and equipment.

Where it is not reasonably practicable to achieve a rating level LAr,Tr minus

the background level (LA90,T) of not more than ‐5 dB as described above, installations will be designed, constructed, installed and maintained so that,

the rating level LAr,Tr of the fixed installations in normal operation at the worst affected residential receptor, minus the existing background level (LA90,T) , is not more than +5 dB, determined in accordance with BS4142:1997. A design to rating level LAr,Tr minus the existing background level (LA90,T), of not more than +5 dB would not be acceptable under the LB Ealing’s planning and noise policy, as it is likely to lead to disturbance. As the community impacts are widespread, over a considerable period of time and extremely high in terms of adversity, the Council feels that the residents in the area of Wells House Road, Old Oak Common Lane, Shaftesbury Gardens and Midland Terrace should be classified as ‘sensitive receptors’ and therefore treated as a special case that merits further review and mitigation proposals to better deal with the acknowledged significant impacts. Equally, the ES should detail sufficient details on impacts and potential mitigation options for the Council to fully digest. Given the sensitivities in this particular area, insufficient detail and assurances have been provided for the Council to be able to made adequate judgement. Traffic and Transport The Council’s main concern relates to the “temporary full road and footway closure of Old Oak Common Lane for up to one year”. This represents a significant local issue and along with the other works planned in the area, will have a major adverse impact on the local community. The Council would like to explore what alternatives were considered to this closure and what options could be looked at further to seek to minimise or avoid this impact. The Council would also expect to see that HS2 Ltd has fully considered the wider road network impact of the potential closures and that it can adequately demonstrate that there are no significant knock on effects to other junctions and roads necessitating further mitigation works. In particular, the proposed 3.5km diversion for general traffic (paragraph 12.4.18) is described as a major adverse effect but there is limited detail on this and how it will be managed. This concern is exacerbated by the anticipated construction vehicle movements (e.g. around 360 per day associated with the Atlas Road compound alone). The Council would like a commitment from HS2 Ltd to seeking to use rail and water transport wherever possible as an alternative mode of construction movement. Whilst paragraphs 12.4.24 and 12.4.25 outline the locations where significant congestion and delay are expected to occur, paragraph 12.4.27 contradicts this by stating “Unless separately identified, these changes in traffic levels will not have significant effects on congestion”. The Council would like clarity on this important issue. The impact on the local public transport network is primarily the planned 3.5km diversion of bus route 228. Given the very limited number of bus routes in the area, the Council does not agree with the findings in paragraph

12.4.28 that “No significant impact on public transport is expected”. The Council would like to see the impacts of this planned bus service diversion adequately modelled and the viability of maintaining the service in its present form verified. The Council would also like HS2 Ltd to provide additional transport arrangements or improvements for those residents significantly disadvantaged by this bus route change, including the potential of a more localised shuttle service being provided to help residents reach key services and facilities. These matters need to be explored ahead of the detailed design stage in conjunction with Transport for London. The pedestrian and cycle diversion of up to 3.5km (assuming the simultaneous closure of Old Oak Common Lane) is also not considered reasonable or acceptable. The Council would like to explore options for connecting Wells House Road to Old Oak Common Lane so that pedestrians and cyclists have a more viable alternative route. We also feel that greater consideration should be given to providing alternatives such as temporary footbridges over the railway tracks. We support the concept of the provision of an eastern access road to Old Oak Common station from Scrubs Lane. As this road would enable bus access from a wider area, double deckers on Old Oak Common Lane south of the station may not be necessary and therefore this could lessen the case for the bridge reconstruction with associated road closure. As mentioned earlier the Council would like clarification on the impact on the two bus depots at Atlas Road. Paragraph 12.4.28 states that “The existing bus depot facilities located off Atlas Road will remain in operation within the Atlas Road compound”. However, the Council understands that no formal agreement is in place for this so we would ask for assurances around this provision. Whilst the Council regularly liaises with Transport for London to seek to optimise the operation of signalised junctions within the Borough, the Council does not agree with the conclusion in the ES that junctions with an identified minor adverse effect will be mitigated through adaptive control and therefore there will be no requirement for further traffic and transport mitigation. As recognised in paragraph 12.4.45, this is “less effective where there is an overall increase in traffic” and given the significant expected increase in traffic levels, the Council would like to see the detailed work and assumptions on traffic levels. Paragraph 12.5.20 appears to present contradictory sentences on traffic impact stating “Due to the relatively low number of vehicle movements on routes that are close to capacity, there are few significant adverse effects. However, during both the morning and evening peak hours, they will cause significant [increases?] in congestion and delays, resulting in a minor adverse effect at the Old Oak Common Lane/Du Cane Road junction". Again, an eastern access road from Scrubs Lane should help relieve this by not concentrating all traffic on to Old Oak Common Lane and Scrubs Lane so the

effect of such a road should be modelled. Furthermore, paragraphs 12.5.21 to 12.5.23 outlines significant increases in peak hour traffic flows without any detail on potential mitigation proposals. The Council would expect to see the detail of this work and assumptions made around network impact and junction operation. Community Forum Area Report - 5 Northolt Corridor Whilst the Council welcomes the decision to include a full tunnel option throughout this area, there remain areas of concern arising from the ES. These are fundamentally around the increase in the volume of excavated material, surface settlement impacts and the additional tunnelling/shaft construction compounds. Effects of Impacts and Effects Arising During Construction With regards to temporary effects on residential property, paragraph 5.4.6 explains that the biggest visual and noise effects will be to the residential properties on the south side of part of Carr Road and in Badminton Close. These will be for up to two years and are deemed to be significant. However there is neither detail provided on any mitigation measures proposed nor options explored. The Council would request details of potential mitigation measures that seek to reduce these negative impacts. Open Space and Recreational PRoW

Approximately 25% of the open space between Mandeville Road and Ealing Road will be required as a utility compound for between one and two years. Given this is recognised as the “central green area in Northolt” and that paragraph 5.4.11 concludes “there are significant adverse effects arising during construction in relation to community resources”, there needs to be consideration of alternative options and if they are shown to be unviable details of mitigation to minimise this impact.

If no alternatives can be found, the proposed temporary compound on open space at the junction of A312 Mandeville Road and Ealing Road (Northolt Village) would require some consultation with the Council to determine the best location to avoid damage to existing mature trees. The creation of a temporary access road on the north side of Lord Halsbury Memorial Playing Fields is noted.

Landscape and Visual Assessment

The highest sensitivities and effects on views during construction will be on properties with a view south on Carr Road and south on Badminton Close. Whilst paragraph 9.4.23 gives consideration to early planting, the Council would like this to be strengthened to an absolute minimum requirement given the expected impacts and potential permanent effects considered.

Sound, Noise and Vibration

The direct adverse effects on residential communities and shared open spaces arising during construction are identified in Table 9. Paragraph 11.3.15 summarises the main direct effects at non-residential receptors. Whilst proposed avoidance and mitigation measures reduce the majority of significant effects, there remain a number of areas where the proposed mitigation is insufficient. On residential properties, paragraph 11.3.19 highlights that issues remain at Carr Road, Badminton Close, Belvue Close and Belvue Road. On commercial properties, issues remain at Westgate House, Westgate Media and Broadcast and AGB House, commercial operations in Westworld, Manhattan House, Greenford Mail Centre and ITV studios at Clausen House.

Whilst paragraph 11.3.21 states that “HS2 Ltd will continue to seek reasonably practicable measures to further reduce or avoid these significant effects”, the Council feels that further detail on measures to achieve this should be contained in the ES and the current proposals are insufficient to adequately mitigation the forecast impacts.

Traffic and Transport

12.4.13 states that partial road closures on a number of local roads may be required but that these would have “no associated traffic diversions or related significant effects”. However, there is no information to substantiate this statement and the Council would wish to see the traffic modelling work undertaken to support this statement.

This is particularly relevant as paragraph 12.4.14 then describes increases in traffic flow and a “major adverse significant effect in traffic-related severance in Friary Road between Horn Lane and the A40 Western Avenue (HGV only)”.

Given the likely partial road closures described in paragraph 12.4.13 (notably those on the A312 Mandeville Road which serves the 90 and 120 bus routes) and the predicted increase in traffic, the Council without evidence to the contrary does not agree with the statement in paragraph 12.4.19 that the proposed scheme will not cause any delays to buses. As such we would request to see the bus journey analysis undertaken to verify this statement.

The Council would also like to see the traffic modelling work that supports the statement in paragraph 12.4.27 that the operation of TfL adaptive signals will mitigate any increased delays or congestion.

The Council is of the view that further evidence is required to demonstrate that the scheme will not affect the local network, particularly in the A312 Mandeville Road area.

Volume 5 - Technical Appendices (Draft code of construction practice) The two main comments on this are:

- Section 11.2.5 provides a scope for ground investigations. It is recommended that, as part of the Preliminary Risk Assessment, appropriate bodies (including councils) are consulted for information.

- Section 11.2.7 - In addition to councils being consulted at the Preliminary Risk Assessment stage, their agreement or approval regarding the design of ground investigation works (as well as any necessary remediation (Section 11.2.7)) should be obtained.

Summary The Council remains supportive in principle to the HS2 Phase One scheme. However, in its present form and with numerous areas of clarification and more information required, the Council will be lodging a holding objection to the plans subject to further discussion to try and resolve the outstanding matters highlighted in this letter. We look forward to further engagement with the HS2 team in seeking to deal with the outstanding matters improving overall project delivery and bettering the outcome for local residents and businesses in Ealing.

Yours faithfully

Julian Bell Bassam Mahfouz

Leader of Ealing Council Portfolio Holder of Transport & Environment

Appendix 1 - Comments from Regulatory Services Section, London Borough of Ealing Council – 30th May 2012

Re: HS2 London to West Midlands EIA Scoping and Methodology Report (A report to HS2 Ltd by Arup/URS) Comments

1. Paragraph 13.2.23 - Ground borne sound – construction and

operational phases and ground-borne sound impact criteria at

Table 21

1.1 Although it is stated at paragraph 13.2.23, that the ground- borne sound impact criteria, specified at Table 21, has been drawn up from similar projects in the UK etc., there is no examination of other research findings on the topic. 1.2 For example at an Institute of Acoustics (IOA) meeting, organised by the IOA Building Acoustics & Noise and Vibration Engineering Group in January 2007, Paul Shields of Scott Wilson summarized the findings of his research into what causes complaints from vibration and ground-borne noise:

1) Vibration complaints often occurred in residential buildings where the

level of vibration was below the threshold of perception. This was

down to ground-borne noise being a problem.

2) LAmax(slow) is commonly used as the index to determine ground-

borne noise issues, but there is no thought given to duration of events

or the spectral content of the intrusive noise.

3) One of the conclusions from a questionnaire given to consultants and

local authorities was that complaints, as a result of ground borne noise,

were more common than complaints of excessive vibration.

4) Most consultants used 40 dB LAmax,(slow) as the maximum level

allowed before mitigation. LAmax,(slow) was 1-2 dB less that

LAmax,(fast) and there was a 2 dB variance depending on where the

measurement was taken in the room.

5) More research and best practice measurement and guidance is badly

needed.

2. Paragraph 13.2.29 – Vibration impact criteria for disturbance

(annoyance) of building occupiers – change criteria at Table 23

2.1 At 13.2.29 it is stated that the criteria used at Table 23 is consistent with those applied for other projects such as “HS1” and “Crossrail”. 2.2 There is no discussion on research findings. For example at an IOA meeting, advised at paragraph 1.2 above, there was also a discussion amongst delegates, which revealed the following:

1) A few thought that a maximum vibration dose value (ms-1.75) of 0.2

should be used for the 16 hr day.

2) All thought that a maximum vibration dose value (ms-1.75) of 0.13

should be used for the 8 hr night.

3. Paragraph 13.2.21 - Accuracy of predictions and measurements of

vibration and ground-borne noise

3.1 At 13.2.21, it is stated that the ground borne sound and vibration will be calculated using methods developed and validated for HS1. 3.2 There is no advice on the following:

1) Other research findings on the accuracy of predictions.

2) The uncertainty/errors in the measurements and predictions.

3.3 These matters have been discussed at IOA meetings: a) IOA London Branch Meeting Report for September 2011

(Acoustics Bulletin, January/February 2012) entitled “How to deal

with uncertainty in the planning process”, Dr Bob Peters and

Colin Cobbing.

b) IOA Autumn Conference, in October 2005, Considering

uncertainty when performing environmental noise measurements,

Kerry, G and Waddington D

c) IOA Building Acoustics & Noise and Vibration Engineering Group

Meeting (January 2007).

a) IOA London Branch Meeting Report for September 2011 (Acoustics Bulletin, January/February 2012) entitled “How to deal with uncertainty in the planning process”, 3.4 Dr Bob Peters gave an account of the history of the appreciation of uncertainty in acoustic field measurements and explained how such uncertainties could and should be estimated. 3.5 Colin Cobbing argued:

That the variability of human response to noise and vibration gave rise

to another significant source of uncertainty in the estimation of impact.

There is a need to assess all aspects of uncertainty and report the

findings within an overall framework, so that decision makers and

stakeholders are given a proper appreciation of the overall risk of over

or under-estimating the likely significant effects.

Dealing with uncertainty within a coherent framework presents

opportunities for developers to engage with the Planning Authority to

agree as to how these might be dealt with before the scheme is

permitted and post development.

b) IOA Autumn Conference, in October 2005, Considering uncertainty when performing environmental noise measurements, Kerry, G and Waddington D 3.6 More detailed advice on this subject was provided at this paper.

3.7 An overview is given of the uncertainties associated with environmental

noise measurements. The uncertainty budget is introduced together with the

concepts of reproducibility and repeatability. Meteorology is identified as being

the most significant influence on measurement uncertainties affecting the

generation, transmission and detection of environmental noise. A detailed

analysis is presented of the uncertainties associated with a BS4142

measurements performed on a real industrial situation. c) IOA Building Acoustics & Noise and Vibration Engineering Group Meeting (January 2007) 3.8 Dr Hugh Hunt of Cambridge University Engineering Department advised that his team have developed a new free-ware computer programme that calculates the vibration from trains in underground tunnels. 3.9 Dr Hunt ran the model during his lecture and demonstrated that small changes in receptor locations and other model inputs (such as soil parameters) could make quite large differences in the results. He therefore questioned the ability of any model to predict the vibration input into a building to an accuracy of better than +/- 10 dB. 3.10 Many delegates agreed but some thought that significantly more accurate predictions were possible, but this relied on having accurate information on all elements of the vibration path from the resource to the receiver.

4. Paragraph 13.3.7 – Airborne sound – establishment of baseline &

definitions of survey – accuracy of ISO 9613-2

4.1 Errors and uncertainties for the measurement process should have been stated. See paragraphs 3.3 – 3.6 above. 5. Paragraph 13.3.18 – Calculation of airborne sound generated by construction activities - accuracy of ISO 9613-2 predictions including barrier attenuation 5.1 At 13.3.18 it is stated that the airborne sound generated by construction activities shall be calculated using the method set out at BS5228, Part1. 5.2 It is not stated if computer modelling will be carried out, using the ISO 9613-2 methodology, as will be the case for calculating the noise from rail support systems (13.3.20). 5.3 The methodology needs to be stated and also the errors and uncertainty which will arise in the process (see paragraphs 3.3 – 3.6). 5.4 At the IOA’s Measurement and Instrumentation Group’s meeting of 14 July 2011, entitled “Construction Noise and Vibration”, Andrew Nash of Scott Wilson, advised that a comparison had been undertaken of noise level prediction using a spread-sheet in accordance with BS5228 and ISO 9613 software.

5.5 The ISO predictions were generally lower, particularly when screening was modelled. 5.6 At a Noise-Con 2004 Seminar at Baltimore, Maryland, USA, David Parzych of Power Acoustic Incorporated presented a paper entitled “Handling of Barriers” in ISO 9613-2”. 5.7 He advised that issues associated with the perceived accuracy of the ISO 9613-2 screening algorithm can be broken down into 3 categories:

1) Misinterpretation by ISO 9613-2 users of the formulas/rules that can

lead to erroneous results or discontinuity of the results.

2) ISO 1962-2’s omissions in regard to rules for handling special cases.

3) Physical phenomena that IS0 9613-2 does not account for.

5.8 As regards 3), for example, it is advised that: a) Two weaknesses of the ISO 9613-2 screening algorithm relate to how

the propagation of sound around a barrier truly interacts with the

ground and the effects of wind/atmosphere on the barrier’s ability to

attenuate sound.

b) Research by Y W Lam concludes that energy summation consistently

over predicts the insertion loss of the lower frequency octave bands

with maximum errors of around 9dB.

5.8 In summary, it is advised that the user must use caution to avoid undesirable modelling outcomes. Missing specifications for Environmental Barriers at Draft Scoping Document 5.9 At paragraph 3.3.13, it is stated that sound levels for the operational railway may be reduced through the performance specification of the rolling stock, infrastructure and environmental barriers. Reduction of noise by environmental barriers 5.10 However there is no information to show that the design of environmental barriers will meet criteria imposed by international standards as regards sound reduction, absorption, timber density, thickness, and method of construction, structural stability, preservation and longevity etc. 5.11 The matters which should have been discussed are as follows:

A) APPEARANCE AND LIFE EXPECTANCY OF PROPOSED BARRIER

Highways Agency, HA 65/94, A Design Guide for Environmental Barriers – guidance on installation with regard to the appearance of the noise barrier in the environment.

Highways Agency, HA 66/95, Environmental Barriers, Technical Requirements – requirement to build barriers for 20 years low maintenance and a 40 year operational life.

B) TESTING OF THE AIRBORNE SOUND INSULATION OF THE

PROPOSED BARRIER AND ALSO SOUND ABSORPTIVE PERFORMANCE WHERE APPROPRIATE

BSEN 1794 PARTS 1, 2 AND 3

Test to be carried out in a nationally accredited laboratory with a sample panel of the proposed barrier, mounted in the window between two adjoining reverberant rooms, the sample to include the post and the exact fixings and sealants to be used on site.

Detail report to be submitted on the test conditions, fixings, component sizes and densities.

Not less than category B insulation to be achieved.

Not less than category A3 absorption to be achieved and A4 where the barrier is high and in a reverberant location. C) PERFORMANCE AND SAFETY OF BARRIER UNDER

WINDLOADING BSEN 1794 PARTS 1

Test details or calculation to be submitted to demonstrate that the barrier will have satisfactory performance for wind loading, static loading and safety in collision.

D) QUALITY AND PRESERVATIONS OF TIMBER USED IN BARRIERS

BS 5589: 1989, Sections 1- 6 and Specification of Highway Works Volume 1, Sections 304, 310 and 311

Timber quality and preservation to comply with advice at these standards.

E) THICKNESS AND DENSITY OF PANELS AND COVER STRIPS USED IN TIMBER BARRIERS

In order to achieve the standards and criteria specified above, it is likely that the timber elements of the proposed barrier will need to be constructed as follows:

Spruce

Abutting panels not less than 30 mm thick, with joints sealed by cover strips not less than 30 mm thick, and the strip extending not less than 25 % over adjacent panels.

Tongued and grooved panels to be not less than 35mm.

Douglas Fir

Abutting panels not less than 22 mm thick, with joints sealed by cover strips not less than 22 mm thick, and the strip extending not less than 25 % over adjacent panels.

Tongued and grooved panels to be not less than 27mm.

Design of noise barriers not discussed at Draft Scoping Document – Possible provision of capped barriers (Random Edge and T Top Barriers)

5.12 In addition to the above mentioned missing details, there is no advice that barriers selected will meet the best possible design by taking account of research findings. For example at IOA Acoustic Bulletin, May/June 2010, there is a paper entitled: The performance of noise barriers in attenuating road traffic noise, J Parnell, S Samuels and C Tsitsos, which concludes the following:

Earlier investigations reported in the literature had suggested that the crossover point for performance improvements between conventional barriers and random edge barriers typically occurred somewhere between 2 KHz and 5 KHz. The conclusion of the present study, however, is that the crossover point is closer to 250 Hz for the barriers investigated. The implication of this finding is that random edge barriers of the type studied may provide significant improvements in attenuating road traffic noise within the critical frequency bands of maximum acoustic energy.

5.13 Although this relates to road traffic, there needs to be a commitment to researching the best available design to find environmental noise barriers, which will achieve the best possible attenuation.

Rolling stock pantograph sound and height of noise barriers

5.14 Although it is stated, at paragraph 13.3.10, that a consultation in 2011 raised the need to consider pantograph sound, particularly in respect of the source above ground compared to the height of the noise barrier, there is no statement that research will also be carried out on this matter. There is also no comment that the best designed rolling stock, having smaller pantographs and a better aerodynamic design will be utilised.

Accuracy and limitations of ISO 9613-2 not stated at draft scoping document

5.15 At Section 9 of ISO 9613-2, Acoustics – Attenuation of sound during propagation outdoors – Part 2: General Method of Calculation, the accuracy and limitations of the method are discussed.

5.16 Note 24 states:

“The estimates of accuracy in table 5 are for downwind conditions averaged over independent situations (as specified in clause 5). They should not necessarily be expected to agree with the variation in measurements made at a given site on a given day. The latter can be expected to be considerable larger than the values in Table 5.

The estimated errors in calculating the average downwind octave-band sound pressure levels, under the same conditions, may be somewhat larger than the estimated errors given for A-weighted sound pressure levels of broad-band sources in Table 5.

5.17 Table 5 gives the estimated accuracy for broadband noise of LAT, calculated using equations (I) to (10):

Mean source height (0-5m), distance between source and receiver (0-100m) - +/- 3dB.

Mean source height (5-30m), distance between source and receiver (0-100m) - +/-1dB

Mean source height (0-5m), distance between source and receiver (100-1000m) - +/- 3dB.

Mean source height (5-30m), distance between source and receiver (100-1000m) - +/-1dB

5.18 In summary, the developer needs to demonstrate that caution will be

used to:

Avoid undesirable modelling outcomes and properly allow for

uncertainty.

Ensure that the best designed barriers will be selected and laboratory

tested.

Ensure that the attenuations calculated for barriers will be as accurate

as possible and the uncertainty stated.

6.0 Paragraph 13.3.26 and Table 25 – Magnitude of Impact – Airborne sound from operational trains 6.1 LB Ealing Regulatory Services Section is not in agreement with an impact assessment that relies solely on LAeq and involves a change of LAeq over a whole day or night. 6.2 According to Table 25 of the ARUP draft EIA Scoping Document:

1) There would be a small impact at differences of +/- 1-3 dB LAeq,16hr

or LAeq,8hr over the existing situation.

2) There would be a minor impact at differences of +/- 3-5 dB LAeq,16hr

or LAeq,8hr over the existing situation.

6.3 A +/- 3 dB change would represent a doubling of halving of train numbers and it is hard to see that this would not be noticeable, especially for shorter LAeq averaging at particular times of the day or night. 6.3 The choice of metrics was discussed at a meeting of the IOA Central Branch on 6 December 2011, (Acoustics Bulletin March/April 2012). 6.4 The topic was entitled “A discussion on the relative merits of different noise metrics in the assessment of transportation noise”, and the HS2 rail link was highlighted and formed the general focus of the discussion. 6.4 It is reported that Professor Colin Waters pointed out that the level of impact associated with LAeq analysis depends heavily on the assessment period considered. He asked what it meant to the average person to be presented with a nominal change in LAeq noise level over a whole day or night-time period, when normally no person would be exposed to the noise change over such a period – a resident might have to wait in one place for 18 hours to experience the difference being described. 6.5 Professor Waters suggested that the LAmax metric provides a comparable correlation with human response to noise, which implies that the LAeq is sufficiently valid to be used as the sole metric for all (transportation) sources. Some examples were presented of situations based on high-speed train movements in which the LAeq might be considered to underestimate the actual level of population response. 6.6 Professor Waters highlighted the WHO guidance that noise consisting of “distinct events…as with aircraft or railway noise” requires measurement and consideration of the LAmax/SEL metrics. He also mentioned that the Environmental Noise Directive guidance uses metrics that impose penalties relative to the time of day. 6.7 It was also reported that at this meeting it was generally felt that there was sometimes a difficulty in convincing clients (developers) to present anything other than the best possible perspective on a situation (e.g., by failing to quantify factors such a uncertainty), despite the apparent evidence that such an approach could be counter-productive. LB Hillingdon challenge re PPG24 – 3 dB representing minimum

perceptible change in noise level

6.8 Advice at PPG24 that 3 dB represents a minimum perceptible change in noise level was challenged by Mr Mike Rickaby of London Borough of Hillingdon Environmental Health Department in 1998, in a letter to the Government’s Department of Environment, Transport and the Regions (DETR).

6.9 The Building Research Establishment, the technical advisors to the then DETR provided a written reply to Mr Rickaby. The relevant parts of the reply are:

“It is important to note that the PPG refers to a 3 dBA as the minimum perceptible “change” in level, rather than “difference” in level, and to “normal conditions”.

“Indices such as LAeq,16hr, long term time averages, are only useful as broad indicators of likely community annoyance or

disturbance. All the details of the sounds perceived during the average time period, and other factors likely to affect their perception, are necessarily obscured. It is unwise therefore, in any given case, to expect a 3 dB change necessarily to reflect the minimum detectable change in the value of such an index”.

It might be reasonable to argue that people are quite likely to detect a moderate change in traffic flow, if such a change happened abruptly, and by extension might claim to perceive an increase in the noise level where the LAeq level changed by less than 3 dB.

6.10 LB Ealing Regulatory Services is therefore of the opinion that the matter of impact metrics should be given further consideration and that uncertainty should be specified. 7.0 Paragraph 13.3.28 and Table 26 – Rating Impact of operational static sources 7.1 LB Ealing Regulatory Services Section does not agree with the proposal that operational static sources will only be identified, where the rating level of the new source exceeds the background level by a margin greater than 5 dB. 7.2 It also does not agree with the statements at Table 26, that a rating difference of 0-5 dB should be classified as minor and a rating difference of 5-10 dB as moderate. 7.3 At Annex A of British Standard (BS), 1997, 4142 Method for rating industrial noise affecting mixed residential and industrial areas, BSi, the following worked examples are set out:

Worked example Rating level difference (dB)

Assessment

A1 Example 1 + 21 Complaints are likely

A2 Example 2 + 5 Marginal significance

A3 Example 3 + 10 Complaints are likely

A4 Example 4 (Day) -3 Does not indicate that complaints are likely

A4 Example 4 (Night) +12 Complaints are likely

7.4 It can be seen that assessment process is not very precise in quantifying the community reaction, as it advises that complaints are likely for situations, where the rating level is +10, +12 and +21 dB above background (variations in noise level of up to 11 dB). 7.5 At the foreword to the standard it is advised:

That it is general in character and may not cover all situations.

The likelihood that an individual will complain depends on individual

attitudes and perceptions in addition to the noise levels and acoustic

features present.

Although, in general, there will be a relationship between the incidence

of complaints and the level of general community annoyance

quantitative assessment of the latter is beyond the scope of this

standard, as is the assessment of nuisance.

7.6 It should not be taken that rating levels from +5 dB to + 9 dB necessarily represents a moderate impact, as there could be justifiable complaints and a situation where a nuisance could exist. 7.7 In addition rating level differences at 0 – 5 dB should not be classified as minor, as there will be uncertainty and errors in the measurement process. 7.8 Errors and uncertainties for the measurement process have not been stated, under the uncertainty process discussed at paragraph 3.3 above 7.9 As reported at paragraph 3.7, Kerry and Waddington also gave a detailed analysis of the uncertainties associated with a BS4142 measurements performed on a real industrial situation. References

1 (IOA) meeting, organised by the IOA Building Acoustics & Noise and

Vibration Engineering Group in January 2007.

2 IOA London Branch Meeting Report for September 2011 (Acoustics

Bulletin, January/February 2012) entitled “How to deal with uncertainty

in the planning process”, Dr Bob Peters and Colin Cobbing.

3 IOA Autumn Conference, October 2005, “Considering uncertainty when

performing environmental noise measurements”, Kerry, G and

Waddington D.

4 IOA Building Acoustics & Noise and Vibration Engineering Group

Meeting (January 2007).

5 IOA Measurement and Instrumentation Group meeting of 14 July 2011,

entitled “Construction Noise and Vibration”.

6 ISO 9613-2, Acoustics – Attenuation of sound during propagation

outdoors – Part 2: General Method of Calculation.

7 Noise-Con 2004 Seminar at Baltimore, Maryland, USA, “Handling of

Barriers” in ISO 9613-2”, David Parzych of Power Acoustic

Incorporated.

8 IOA Acoustic Bulletin, May/June 2010: “The performance of noise

barriers in attenuating road traffic noise”, J Parnell, S Samuels and C

Tsitsos.

9 Meeting of the IOA Central Branch on 6 December 2011, (Acoustics

Bulletin March/April 2012), “A discussion on the relative merits of

different noise metrics in the assessment of transportation noise”.

10 British Standard (BS), 1997, 4142 Method for rating industrial noise

affecting mixed residential and industrial areas.