Examination of Witnesses (Questions 2800
- 2819)
2800. What is shown as the boundary on this
drawing for the worksite layout on Fox and Knot Street?
(Mr Morton) It certainly
appears that my technician has drawn it on our drawing, which
is tab seven, correctly.
2801. Did he produce this drawing in 5A?
(Mr Morton) That was produced
by Crossrail's engineers presumably.
2802. So now that you have been able to compare
the two, is there any need to change your plan at tab seven at
all?
(Mr Morton) No, there is
not.
2803. You were asked a series of questions about
site constraints and maybe if we keep the drawing at 5A open,
can you say please what, if any, clash there would be between
your options and the site constraints identified by Crossrail
to you in cross-examination?
(Mr Morton) If you look
at plan 5A, clearly the storage of the rings and the—
2804. Forgive me: I put the question wrongly.
I am going to go on to materials in a moment but you were asked
first about the site constraints like location of buildings, and
the location of the emergency access I think arose at this point.
Having regard to those things what, if any, clash is there between
those site constraints and your options?
(Mr Morton) There is none
at all as far as I can see.
2805. Just after lunch you were asked a number
of questions about piling and what that would involve. Can you
say practically what, if any, real hurdles are presented by a
secant pile approach here?
(Mr Morton) I do not think
there are any significant problems other than the fact that the
thickness of the shaft wall is going to be greater. You have all
the engineering problems at the base of the shaft that are the
same as for the segment system. You have got to link that in with
the exits at the base. You have got to construct your floors.
It is a different way of doing it but I do not see any particularly
onerous problems associated with it.
2806. Comparing the two in terms of the Promoter's
proposals, segment against secant pile approach, is your approach
significantly more expensive or time-consuming so as to make this
other than an option?
(Mr Morton) I do not believe
it is any more expensive but also you have to look at the fact
that it is accepted that the segment system can generate settlement
of adjoining buildings and thus it can generate settlement of
the building we are trying to hold up. I accept that there is
within the Crossrail general documents provision for measuring
settlement and when the settlement gets to more than 10 millimetres
warning bells start to ring, but if you can avoid that situation
by using the secant pile system it seems logical to do it.
2807. You were asked some questions about arranging
the site and a drawing was produced which I think has the reference
P38. It is the second one of the two that were stapled together.
Do you have that?
(Mr Morton) Yes, I do.
2808. You told us in your evidence in chief
that you would be able to use the building if it was retained
in storage. Looking at this drawing, what elements could be transferred
to within the building to free up further space?
(Mr Morton) Certainly office
facilities could be accommodated within the building. Toilet facilities
could be accommodated within the building and generally any other
accommodation that is required on the site for people to use.
2809. What, if any, space could be used for
storage of certain items?
(Mr Morton) It would be
possible to use the ground floor internally for storing items
but, of course, unless you are going to take the gable wall out
there is not going to be easy access to that ground floor.
2810. Keeping that plan open can I ask you to
go back to the one at 5A and compare the areas of the site proposed,
particularly at the apex end between what we have at 5A and what
has just been put in today? What extra space would be available
if the hoardings were as shown on the proper Crossrail plan?
(Mr Morton) What comes out
of that question is that you look at the plan given to us today,
which showed the green storage area at first floor, and you look
at the storage shown on 5A and you see that there is significantly
more on the plan given to us today than there was on the drawing
5A which was produced some while back.
2811. Looking at the hoarding line, which I
think is shown in red on both drawings, particularly at the apex,
can you see any difference between the two?
(Mr Morton) The line is
different, is it not? It is a diagonal line which on one drawing
is a fairly flat diagonal and on the other drawing is much more
acute.
2812. So, having regard to the position of the
building, for example, what extra space would be available if
the hoarding was put where it was originally proposed on 5A?
(Mr Morton) There is rather
more space to be able to think of putting the crane in that corner.
2813. Do you think you would be able to accommodate
the crane on the site if it were to be as originally proposed
at 5A?
(Mr Morton) I do indeed.
Indeed, Scanmoor felt that that was a very sensible place to put
the crane. They absolutely dismissed the idea of putting it in
the position shown on drawing 5A.
2814. You were asked about option three and
what was involved in taking down the end three metres. Can you
please compare the difference between total demolition of the
building and taking down the three metres in terms of the risks
and the time and the cost involved?
(Mr Morton) It is a comparatively
easy matter to scaffold up that small section of the building
and literally having it taken down by hand. One would be much
happier doing that. There is the likelihood of, if you like, a
hammer demolition of the whole building which is undoubtedly the
way the way it would go if you were going to demolish the whole
of the structure.
2815. So if you were simply trying to allocate
enough space to do the works which would you recommend: taking
down just the end of the building or knocking the whole thing
down?
(Mr Morton) Oh, taking down
the end without a doubt.
2816. There is one question I wanted to ask
for the sake of clarification. You were asked a question about
your option one and the need for underpinning number 38. Can you
please clarify whether any underpinning would be required to number
38 if you were using secant piling in option one?
(Mr Morton) There would
not be.
2817. The Committee asked you a question in
relation to the length of the building that could be taken down
in option three, three metres, and what that would leave of the
building. Could you say roughly perhaps, if we have a look at
the drawing on the screen at the moment, what proportion of the
length of the building would be left intact compared with what
would be taken down?
(Mr Morton) It must be 80
per cent, 85 per cent perhaps that would be retained.
2818. Thank you very much. Sir, I have no further
questions for Mr Morton so that ends our evidence in relation
to this first of the two matters that we have. I understand the
Promoter proposes to call no evidence in relation to this issue.
There was a debate earlier about whether a note should go in.
What I would like to propose the Committee to consider is that
we go on to close this issue today while it is fresh in our minds.
Sir, you said you would consider whether a note would be allowed
in. What I would propose is that if a note is allowed in and it
raises any issues we can deal with those later by submissions
but the best thing is simply to press on, have closings today
while it is fresh and then have this issue resolved. Sir, that
is what I would propose.
2819. Ms Lieven: Sir, can I say I would
be most unhappy about closing this issue today. These are very
technical issues and we only received Mr Morton's plan after 9.30
this morning and that was the first time he had put options to
us. I have done my best to put the problems to him in cross-examination
but surely the position that the Committee is in is that it has
to weigh what the problems and the pros and cons of this are but
it really cannot do that until it has seen a note as to our view
of the options. It is unrealistic to suggest that I in cross-examination
can genuinely put all the engineering problems with the proper
weight. As you yourself said, although it could have been Sir
Peter, when chairing an earlier session, it is not my function
to give evidence, it is my function to ask questions and the Committee
needs to see the evidence in the form of a note. I would suggest
given that Mr Honey is returning in the very near future, at least
I assume it will be in the very near future as we are moving down
the line, to deal with the rest of Islington's case, the best
way forward is for Crossrail to put in a note and I can undertake
to do that by tomorrow morning so that you have got our position
on the engineering difficulties and when Islington come back we
can close on the entirety of Islington's petition in one go. After
all, the Committee has indicated it is not going to make decisions
on these matters until right at the end of the process, so the
fact that it is not fresh in your mind, as my learned friend puts
it, really is not here nor there, what is important is that on
the record is the clearest possible exposition of both sides'
case so that when the Committee does come at the end of the day,
whenever that may be, to appraise all these petitions it has got
the full statements from both sides.
(Mr Morton) Can I just say
a word because I am rather irritated by what counsel is saying.
We had a meeting with Crossrail, with the particular station manager
there, I think it was Thursday last week, about 10 days ago, when
I went through all our proposals in a note, they knew what we
were proposing and they talked to me about it, there were questions
across the floor. This is not the first they knew of it.
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