High Speed Rail (Preparation) Bill

Written evidence from CPRE London (HSR 10)

CPRE London response

This is a brief response to the draft Environment Statement from the Campaign to Protect Rural England London Branch. We are holding a member event in September from which we will draw more in-depth local views on the proposal to support a submission in relation to the hybrid bill. In general however we are concerned about the current proposal and its underpinning argument that HS2 will deliver wide economic and environmental benefits. A number of local London-based groups  and local government actors have raised clear concern that the socio-economic impacts of HS2, as well as the impacts on open space and nature conservation. In respect of the latter, and assuming that HS2 were to be built, they are suggesting that these impacts have been underestimated and insufficient measures for mitigation of these impacts have been identified.

Our key concerns are outlined below.

Economic case. One report has suggested that whilst the official cost-benefit ratio for HS2 is 2.0 the Centre for Economics and Business Research (CEBR) estimated it is likely to be nearer 0.5 which would significantly undermine the main economic rationale (Regeneris, 2013). Other recent reports, including from the National Audit Office, have also questioned the economic case. We have also seen additional requests calling for a proper debate about the merits of linking up the ‘Core Cities’, not London, and to allow for a better debate about the case for enhancing the existing infrastructure as an alternative project.

Life-time carbon footprint of HS2, including construction and running - There is a lack of information on greenhouse gas (GHG) emissions in the current draft statement. HS2 Ltd’s previous Appraisal of Sustainability (AoS) suggested that a GHG assessment would be completed in 2011. This needs to be completed to give full picture of the carbon impacts, one of the key rationales for the scheme.

Air quality, noise, dust and traffic impacts during the construction phase. The cost of construction to local areas such as from air pollution and congestion of local roads, particularly in areas that already exceed European air quality standards e.g. Euston Road and Ickleford, need to be fully assessed and mitigation steps outlined in detail. No transport assessment (TA) has been completed to complement the draft environment statement which would provide important supporting information in that regard.

Houses, property and heritage impacts. Construction of the scheme would require the demolition of up to 215 homes in Camden, loss of a number of commercial buildings, railway buildings and other structures. Significant harm will be caused to a number of heritage assets. They include St. James’s Gardens burial ground, the site of St. James’s chapel, 51 Kentish Town Road, 110 Camden Road, Primrose Hill station, and the central section of the Up Empty Carriage Tunnel, North London Line brick arch rail viaduct, the Grade II listed Camden Road station and the Old Oak Common carriage shed. Construction of the scheme would result in the destruction of archaeological remains associated with Iron Age and Romano British settlement, Bronze Age cremations, a medieval moated site at Brackenbury Farm and Bourne Bridge. Various other listed buildings and conservation areas will be lost or impacted (e.g. South Kilburn conservation area, Queen’s Park Estate, Kensal Green conservation area, Kensal Green Cemetery conservation area, Grand Union Canal)

Transport impacts. HS2 will boost demand on the Northern and Victoria lines; the Mayor’s transport strategy will need to bring forward further major upgrades and schemes. The increase in taxi movements and private car drop-off and pick up activity would have a significant effect on traffic flows on 13 roads around London Euston station and a significant effect on safety at two junctions. See also above regarding the need for a full transport assessment.

Ecological impacts, assessment and mitigation. Despite the tunnel extension in Primrose Hill, Ealing, construction would result in the loss of key ecological habitats and cause permanent land loss from a number of sites, including a summary list below. CPRE London supports the London Borough of Camden in requesting that National Vegetation Classification Surveys need to be completed at various key sites, not only in Camden, to identify where wild flowers may be present as well as identify sites that may offer potential mitigation. Mitigation responses also need be identified in relation to tree impacts, particularly ancient woodland which may be permanently affected. According to the Woodland Trust 21 ancient woods, covering a combined area of 409ha, will suffer direct loss in the entire route and a further 12 are at risk from noise, vibration and further infrastructure such as roads.

Taking the above areas of concern together, CPRE London believes that the case for HS2 offering net benefits to London or the UK as a whole have not yet been made .

Annex A

Green spaces impacted in Greater London

Listed here are key green sites in Greater London which we expect to be directly impacted by the proposed route, as outlined in the draft Environmental Statement. Many smaller green sites of environmental sensitivity or special value will be also indirectly affected.

· St James’s Gardens 'Site of Importance for Nature Conservation' (SINC),

· Euston Square Gardens

· Regents Park Estate open space

· Hampstead Road Open Space

· Adelaide Road Nature Reserve Site of Borough Importance (SBI) & Local Nature Reserve

· (7.4.6) The London’s Canals Site of Metropolitan Importance (SMI)

· Kensal Green Cemetery (SMI, Grade II* registered park and garden)

· Old Oak Common Sidings Birch Wood (SBI.I)

· Wormwood Scrubs Railway Embankment (SBI)

· Central Line West of White City (SBI)

· Silverlink Metro between Brondesbury and Willesden Junction (SBI)

· Park Royal Railway Land (SBI.II)

· St Mary's Cemetery (SBI.II)

· Ruislip Woods National Nature Reserve

· West Ruislip Golf Course and Old Priory Meadows Site of Borough Importance Grade I (SBI, 10% land loss)

· Newyears Green SBI (16% of site lost)

· Brackenbury Railway Cutting Grade II (SBI II, facing 58% land loss)

· Victoria Road Railway Banks

· Yeading Brook (Roxbourne Pk-Ruislip Gdns) adjacent to track river and riparian habitats

· Colne Valley SSSI and SMI

July 2013

Prepared 12th July 2013