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Standard Consultation questions with proposed Camden response
This appendix provides the proposed Camden response to the 7 formal
questions presented by the HS2 consultation. It should be read alongside a
more detailed assessment of the specific impacts of the proposed HS2
scheme, which are provided in thematic sections in Appendix 2.
In summary, Camden is currently not in a position to support HS2. No
decision should be made on whether to proceed with HS2 until further
information has been provided regarding the potential impacts of the scheme,
and the relative benefits of alternative options (including enhancing capacity
on existing lines), which could be less costly whilst generating significantly
fewer environmental and social impacts.
Question 1. Strategy and wider context: Do you agree that there is a
strong case for enhancing the capacity and performance of Britain’s
inter-city rail network to support economic growth over the coming
decades?
1.1
In principle, Camden supports improvements to public transport links,
including strategic rail links. However there is a need to carefully
consider the impacts of any rail network projects, and to ensure that
the benefits generated by any scheme will outweigh the disbenefits.
1.2
Camden is not currently in a position to support the proposed HS2
scheme and the terminus at Euston Station. There would be negative
impacts on residents including the loss of people’s homes,
businesses and communities in the area, and it is considered that the
business and transport case for the scheme has not yet been made.
1.3
There is also inadequate information to explain how an unacceptable
impact on the existing public transport network would be addressed.
Whilst it is recognised that this is likely to be outside of the brief given
to HS2 Ltd, it has to be an essential part of the decision making
process. Given this lack of evidence and the scale of the negative
impacts in the Euston area the case for terminating the High Speed
line here has not been justified. In addition long-term projects of this
type carry a risk of planning blight, and Euston and the surrounding
area would be negatively impacted.
1.4
Camden has set out its concerns regarding the impacts of HS2 under
a number of themes (see Camden’s main response). The detailed
thematic comments in Camden’s main response set out the likely
impacts of the proposed scheme in relation to Noise and disturbance;
Environment; Housing; Transport; Education; Businesses and
employment; Community and cultural facilities; Crime and safety; and
Blight and compensation. The impacts set out in these sections,
including the loss of existing homes, business premises and open
space, noise and disturbance and impact on existing transport
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networks are of considerable concern to many local residents and
businesses, and to the Council.
1.5
Camden considers that alternative solutions to enhancing the
capacity and performance of Britain’s inter-city rail network should be
given further consideration, including further enhancements to the
capacity of the existing rail network.
1.6
Please see Camden’s response to questions 2-6 below for an
analysis of the proposed route.
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Question 2. The case for high speed rail: Do you agree that a national
high speed rail network from London to Birmingham, Leeds and
Manchester (the Y network) would provide the best value for money
solution (best balance of costs and benefits) for enhancing rail capacity
and performance?
2.1
No, the proposal from HS2 Ltd does not provide a full business case
comparison of the alternatives which include enhancing the capacity
of the existing rail network on an incremental basis. It is therefore
difficult to accurately determine if this is the best value for money
solution. A proper assessment of the costs and benefits of upgrading
the West and East Coast Mainlines should be undertaken which
includes:
 Optimising existing capacity by converting some first class
carriages to standard class at peak times.
 Operating longer trains, without major infrastructure expenditure
 Infrastructure modifications to selected bottlenecks to increase
frequencies.
 Investment into platform lengthening, track reconfiguration and
additional platforms where required.
2.2
A proper comparison would need to look at a number of factors
including:
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2.3
Impact on existing and potential rail passengers
Impact on local and national economy
Impact on other rail networks e.g. Crossrail, Heathrow, HS1
Impact on road and aviation
Impact on other public transport services.
Impact on residents and businesses
Extent of demolition and extent of areas of blight etc.
Impact on environment - noise, air pollution, open space etc.
Regeneration impacts
Cost, covering both construction and operations.
The Eddington Transport Study (DfT 2006) considered the relative
costs and benefits of high speed rail compared to other measures to
improve public transport capacity. The study (volume 3 paragraph
4.173) commented that “the evidence on the costs and benefits of
new North-South high speed rail lines available to this study suggests
returns at the lower end of the distribution compared to the returns
available from other policy options. These relatively modest returns
are likely to be driven by several factors including the following:
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 the UK’s compact economic geography means that most major
urban areas are already close together when compared to many
European and international competitors;
 for those economically important connections that are more
distant, such as London to Edinburgh and Glasgow, air services
already provide fast, frequent connections serving business
needs and other markets at relatively low cost. The new rail link,
therefore, would not be a step change as the link is already there
and there is very little evidence that high-speed rail links help
regional performance;
 the benefits accruing to intercity business and non-work/leisure
travellers in the UK from this new link are likely to be subject to
significant uncertainty and speculation because the demand for
the link has not been tested and proven;
 history has shown that for large-scale infrastructure projects that
rely on emerging technological solutions, costs tend to increase
by an order of magnitude against original estimates; and
 in addition, where new rail lines are added and speeds greatly
increase, there are likely to be very significant environmental
implications from the need for land take, plus emissions and
noise”.
2.4
The Study concluded that, whilst new high speed rail lines would
deliver capacity increases in London and selected urban areas (by
removing some or all interurban trains from commuter and freight
lines), “these goals could be achieved by other solutions, and
perhaps at much lower cost. The range of policy measures would
include fares pricing policy, signal-based methods of achieving more
capacity on the existing network, and conventional solutions to
capacity problems e.g. longer trains. Indeed, in keeping with a nonmodal approach, the measures assessed should include
improvements to other modes that support these journeys (e.g.
motorway, bus, and urban access improvements)” (The case for
action: Sir Rod Eddington’s advice to Government, figure 15).
2.5
The information provided in support of the proposed scheme does not
provide sufficient evidence to demonstrate that the scheme would
offer the best value for money, and that the potential negative
impacts generated by the scheme (which are detailed in Camden’s
main response) would be outweighed by its benefits.
The financial case for High Speed 2
2.6
Camden is concerned that the cost of the proposed High Speed 2
scheme, at £32 billion, may not be justifiable at a time of significant
public sector funding shortages and spending cuts.
2.7
More cost effective solutions to enhance capacity and service
reliability whilst avoiding the significant costs associated with the
proposed scheme (both financial and environmental) should be
considered. It has been suggested that upgrades to the existing
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network (including the use of longer trains), additional and longer
platforms at key stations and better scheduling of services could meet
forecast demand, at less cost and significantly lesser impact on the
environment and on local communities.
2.8
Part of the case made for High Speed 2 relates to increased business
productivity as a result of reduced journey times. The government’s
methodology for calculating the benefits of the proposals include the
time savings business might achieve through shorter journey times.
However, any assumptions regarding improved productivity may be
questionable, given that time spent on conventional rail is not
necessarily wasted, with people continuing to work on laptops and
mobile phones. Indeed, this is acknowledged in the government’s
main consultation document, which states that “as information and
communications technologies develop, time spent travelling by rail
can be used increasingly productively” (High Speed Rail: Investing in
Britain’s Future; February 2011, p50).
2.9
It would appear that the Government has not assessed the wider
economic impacts that would be generated by capacity increases to
existing conventional rail services, which could help to significantly
boost productivity (by reducing crowding) (Oxera Review of the
Government’s case for a high speed rail programme, June 2011: see
paragraphs 3.2-3.5). Such alternatives offer the opportunity to
generate productivity benefits without the significant financial,
environmental and social costs that would be generated by the
proposed High Speed 2 scheme.
2.10
The cost/ benefit ratio provided in the supporting information (2.0)
(High Speed Rail: Investing in Britain’s Future; February 2011,
paragraph 3.7) indicates that the projected benefit ratio is relatively
tight. Given that some of the details supporting the economic case for
the scheme appear to be questionable, the likely value for money
provided by the scheme would appear to be open to doubt.
Furthermore, it would appear that HS2 has not yet properly 'costed'
the environmental impacts of the scheme and the likely disruption
HS2 would cause to businesses and residents in Euston and along
the route. This consideration must be taken into account when
assessing the overall value for money offered by the scheme.
2.11
Alternative rail enhancement options, in particular projects to improve
the capacity of existing conventional rail services, may deliver the
required enhancements to strategic public transport capacity and
reductions in overcrowding, whilst maintaining productivity benefits.
The government should therefore consider whether such works,
including further improvements to the West Coast Main Line, would
offer a better value for money option.
2.12
It is noted that the supporting Economic Case for High Speed 2
(paragraph 7.3.10) suggests that that the redesign of Euston station
could deliver benefits of between £900 million and £1.5 billion. This is
based on a supporting Technical Note by Atkins (January 2011). The
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Note comments that the lack of specific details on the scheme at this
initial stage "precludes any detailed and robust calculation of station
benefits at this time". The figures provided are therefore based on
figures relating to the business cases prepared for two other major
rail station schemes (Birmingham Gateway and Nottingham Hub).
Camden considers that the figures provided cannot be relied on as
accurate indication of the potential benefits of the proposed HS2
scheme to Euston, given that:
2.13
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there are no details regarding the design and scale of the HS2
Euston scheme;
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the figures provided in the Technical Note are based on
comparative figures of two schemes that are different to the
proposed HS2 scheme, which involves a high speed line and
would generate significant impacts on the local community, and
which are in very different locations to London Euston; and

the situation regarding over station development and relevant
planning policies that would apply would be very different to the
comparison cases in Birmingham and Nottingham.
A more robust assessment of the potential economic benefits of the
scheme should be developed before a decision is made as to
whether to take the scheme forward. Camden should also be given
an opportunity to analyse the revised assessment and make
comments, before any decision is made.
The environmental case for High Speed 2
2.14
There is no definitive information on the environmental case for or
against HS2 that assesses environmental impacts on HS2 against
business as usual or alternative transport options, taking account of
all whole life cost impacts and benefits. Further, detailed analysis
taking into account all of the factors needs to be completed. It
therefore appears that an adequate environmental case for HS2 has
not yet been made.
2.15
Although initially promoted as a mechanism to help create a low
carbon economy, the rationale used to support a new network has
moved away from a focus on environmental benefits, as it would
appear that these are not as clear as first thought. High speed rail
uses approximately twice the power per mile as conventional rail (and
an increase in speed causes a disproportionate increase in noise).
2.16
It is disappointing that HS2’s own evidence indicates that it is not
possible to establish whether the scheme would result in an increase
or a decrease in CO2. The HS2 Appraisal of Sustainability (Main
Report Volume 1, paragraph 8.3.4) states that the scheme would at
best result in an overall decrease of approximately 28 million tonnes
over 60 years, and at worst result in an overall increase in carbon
emissions of approximately 24 million tonnes. It is noted that the
Eddington Transport Study questions the benefits of high speed rail
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lines with regards to carbon dioxide emissions, in particular given
their relatively high carbon emissions (Eddington Transport Study:
Main Report: Volume 3, DfT 2006- see paragraph 4.182).
2.17
The Oxera Review of the Government’s case for a high speed rail
programme (June 2011, paragraph 3.44) indicates that options to
improve classic rail “could well involve lower carbon emissions” than
high speed options. Such alternative options would therefore allow
capacity improvements that would boost economic productivity (see
paragraphs 2.7-2.9 above) whilst potentially generating significantly
lower carbon emissions.
2.18
Camden considers that enhancements to the rail network should be
planned and delivered in a way that significantly reduces overall
carbon emissions, given the need to reduce the contribution made by
transport emissions to climate change, and to justify the significant
expense and disruption caused by major schemes such as HS2.
Impacts of HS2
2.19
Paragraphs 2.6-2.12 above question the economic case for the
proposed route. In determining the best value for money option, a
wider consideration of the benefits and disbenefits of the scheme is
also required. Another key justification for the introduction of the
proposed route relates to the environmental case. However, the
environmental benefits of the scheme, including in relation to carbon
emissions, are also questionable (see paragraphs 2.13-2.16 above).
2.20
As set out in Camden’s main response, the proposed scheme would
generate significant negative impacts around the Euston area (and
potentially around the proposed vent locations), including:
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2.21
Demolition of existing (affordable) homes;
Loss of business premises;
Loss of open space;
Onward distribution of passengers and potentially unacceptable
pressure on the public transport networks serving the Euston;
Reduction in overall capacity at Euston and on the approach for
WCML services. The potential for delays and reduced reliability
as a result of conflict between trains arriving and departing;
Potential harm to the future viability of Maria Fidelis school as
well as indirect impacts on other local schools;
Noise, disturbance and vibration;
Crime and safety;
Air pollution;
Biodiversity.
Given the limited reduction in journey times, the questionable
financial case of the line and the questionable environmental case for
the scheme it would appear that any benefits of the scheme would
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be significantly outweighed by the considerable negative impacts that
would be generated.
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Question 3. Delivery: Do you agree with the Government’s proposals for
the phased roll-out of a national high speed rail network, and for links to
Heathrow Airport and the High Speed 1 line to the Channel Tunnel?
3.1
No, Camden considers that the case for the roll out of a national high
speed rail network has not yet been made, and therefore is not
currently in a position to support the proposed HS2 scheme and the
terminus at Euston Station. Camden considers that the evidence
provided to date does not prove the transport, economic and
environmental case for a national high speed rail network.
3.2
Notwithstanding Camden’s position regarding the principal of the
proposed new high speed rail network, the comments below set out
Camden’s views on the Government’s proposals for a phased roll out
of the network, and for links to Heathrow Airport and the High Speed
1 line, if the scheme were to go ahead
Phased roll-out
3.3
If the scheme were to go ahead, the phased roll out of a proposed
national high speed rail network is considered to be logical both in
relation to the considerable funds required to finance such a scheme,
and in relation to the management of delivery.
3.4
The existing West Coast Main Line (WCML) serving Birmingham and
Manchester is already overcrowded despite recent major
enhancements. The overwhelming existing passenger demand is
from and to London rather than between other regional cities.
Therefore there is a clear logic to build the network in stages starting
in London to relieve the pressure on the WCML.
3.5
The phasing of development should be managed to minimise impacts
on the local area, including the local road network and pubic realm,
and on local businesses that rely on passing trade. Local road
closures should be kept to a minimum. More detailed comments
regarding the potential impact of the HS2 construction process in
terms of Noise and disturbance, Transport; Businesses and
employment; Community and cultural facilities; and Crime and safety
are provided in Camden’s main response.
3.6
If the proposals were to go ahead, it is vital that the construction
phasing does not result in any significant periods of line closures on
existing local lines, which provide essential transport links for people
to access employment and local services.
3.7
In addition the construction phases, should HS2 proceed, need to be
co-ordinated with other upgrade / maintenance works to the transport
infrastructure, such as the underground upgrades, so that a level of
service to all areas is maintained throughout. Please see more
detailed comments on the potential impact of the HS2 in the
Transport section above.
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3.8
HS2 proposes to undertake the redevelopment of Euston in phases
to minimise disruption to existing services and passengers and to
keep the station operating. As a result, the HS2 proposal is to extend
the station to the west initially to provide temporary platforms for the
existing services to operate whilst the remaining platforms and new
station were constructed. A similar phased approach was taken to the
construction at St Pancras which broadly worked well.
3.9
There is currently no indication of how the work would be phased and
for how much of the 7 – 8 year programme services to and from
Euston will be impacted. Should the scheme go ahead, HS2 should
work with Camden to establish how the phasing and detailed
management of the construction process could minimise impacts on
the local area and the transport network, and to develop a detailed
plan for the management of the construction process.
Proposed link between High Speed 2 and High Speed 1
3.10
The council opposes the proposal by HS2 Ltd to connect HS1 via the
North London Line (NLL), as it could have an unacceptable impact on
the existing transport network. In relation to the construction phase,
there is insufficient information as to how the link would be
constructed and how works would impact on existing NLL services.
The required works could involve bridge or tunnel widening
or additional track side infrastructure. The impact of the proposed
High Speed 1 link on Camden's other transports networks ( e.g. the
strategic route network, footpaths, cycle paths, bus services) and
development sites (e.g. Hawley wharf) and open spaces adjacent to
the line is not currently clear and needs to be incorporated into any
proper assessment of the HS1 link and any subsequent
Environmental Impact Assessment.
3.11
Specifically at Camden Road, there are no details about the extent of
the works that would be required to the existing station or platforms.
Camden has concerns about the potential for HS2 proposals to
impact on Transport for London proposals to lengthen platforms and
provide step free access to the station. If the HS2 project does
progress, Camden would expect that HS2 proposals be fully
integrated with Transport for London proposals to minimise disruption
to passengers and provide some benefits to suburban commuters.
3.12
The impact of the line once in operation is also of concern. The
current proposal would have a single track link between Old Oak
Common and then use track on the NLL. This is highly likely to
impact on capacity and services on the NLL which may need to be
reduced to accommodate high speed trains.
3.13
The NLL has seen considerable investment in recent years to
upgrade capacity and reliability on the line. The recent upgrade to
rolling stock and infrastructure has contributed to significant extra
demand which is forecast to increase. There are concerns about the
impact on constraining future capacity enhancements to the NLL.
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There is concern about the impact of the proposed link on the NLL
service patterns and there is no information from HS2 Ltd about the
impact on line capacity or about future proofing the NLL to address
future growth in the NLL or high speed rail.
3.14
The consultation document estimates that a daily demand for through
running international services via HS1 would only be in the order of
6,600 passengers per day at a cost of £0.9Bn. For a comparison, the
number of passengers in the am peak (3 hours) on the NLL is 5,457
(Cross London RUS, 2006, P22, Table 3.2).
3.15
Analysis undertaken by Transport for London shows that with the
existing infrastructure only one high speed train per hour would be
able to use this link (Peter Moffitt, TfL presentation to London
Council’s 11/5/11). However, the current proposal by HS2 is to allow
3 trains per hour to connect to HS1 at substantial cost. Issues that
should be considered include:
 There is no detail on the demand analysis for through running
trains. The analysis needs to clearly demonstrate that the
benefits of such a direct link would outweigh the costs and
impacts on the local community.
 Lack of consideration of a link that would not impact on the NLL
and allow HS2 and HS1 to link to a wider domestic high speed
network in the future.
 Providing the HS2/HS1 link via a single track on the NLL
provides no resilience in the network and alternative options
should be considered that provides a resilient network and
provides a network to future standards.
 Further technical details are needed on the link to fully
understand its impacts including: its alignment, specifications
and impact on bridges and structures. It is understood that HS2
Ltd, together with Network Rail, are undertaking further work on
how this link would be delivered. However, it is understood that
this level of detail will not be available before the closing date for
the public consultation responses. Camden would request that
HS2 Ltd share this additional information at the earliest
opportunity.
3.16
Before a properly informed decision can be made, HS2 should
provide the additional technical analysis required to address the
above issues. Details should be made publicly available, with a
further opportunity to comment, before a decision is made on the
proposed scheme.
3.17
If a link is progressed between HS1 and HS2, the council’s
preference is that it should not impact on the NLL, and proposals
need to be developed to mitigate the impacts on local communities,
Camden's other transports networks (e.g. the strategic route network,
footpaths, cycle paths, bus services) and development sites (e.g.
Hawley wharf) and open spaces. As part of this the businesses cases
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for additional network investment, both on existing networks (e.g.
plans to extend 4 tracks to Camden Road) and the possible Crossrail
2 and DLR extension from Bank to Euston are considered alongside
HS2, not in isolation. In the absence of this the HS2 proposal would
have significant negative impacts.
3.18
In addition agencies such as Central Government, GLA, London
Councils and London Boroughs will need to work together to
understand the wider development of the UK’s and London transport
network to maximise the network benefits of HS2 not just for High
Speed Rail. For example improvements to local and inter-regional
services should be delivered at the same time as creating a HS2 /
HS1 link.
Proposed connection between High Speed 2 and Heathrow
3.19
There is a clear rationale for providing an interchange to Heathrow
via Old Oak Common rather than a direct link on HS2:
 A direct link on HS2 with Heathrow would increase journey times
for all through passengers
 The Old Oak Common interchange would enable HS2 to
connect with the Heathrow Express and Crossrail which would
be high frequency and provide a relatively fast journey time at a
significantly reduced cost than a direct HS2 link.
 An additional station at Old Oak Common would relieve the
pressure on Euston as not all passengers on HS2 would go into
central London
 Those passengers who are most likely to transfer to high speed
rail from air are unlikely to be influenced by how HS2 serves
Heathrow (i.e. Heathrow is not a destination in itself)
 It is not certain that passengers who currently fly from regional
airports to Heathrow in order to transfer to long haul flights would
necessarily switch to high speed rail for this part of their journey.
In addition, given that HS2 is already planned to serve
Birmingham International the case for connecting Heathrow
Airport is far from clear
 In future the case for a direct link from HS2 to Heathrow as part
of phase 2 may be greater, however, at this time it is understood
that the HS2 Ltd’s modelling results for phase 2 are not
available. Therefore there remains a case to include passive
provision for such a link as part of a later phase.
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Question 4. Line specifications: Do you agree with the principles and
specification used by HS2 Ltd to underpin its proposals for new high
speed rail lines and the route selection process HS2 Ltd undertook?
Proposed Euston terminus
4.1
No, whilst the principle of providing a central London terminus for
HS2 may provide passenger benefits, there is currently insufficient
evidence to take an informed view as to whether Euston is the most
appropriate location for that terminus. The HS2 proposals at Euston
would generate significant adverse impacts in Camden, including the
demolition of existing homes (see Section 2a of Camden’s main
response, which provides details regarding the homes that would be
demolished or put at possible risk as a result of HS2), loss of
businesses, loss of designated open space, and major construction
disruptions over many years. These impacts are clearly significant
and of great concern for affected communities and businesses, and
indicate that any benefits of the scheme would be outweighed by the
significant negative impacts.
4.2
The proposed main terminus of HS2 at Euston was selected by HS2
Ltd following their assessment of 27 locations across London
including Paddington, Kings Cross, St Pancras, Old Oak Common,
Stratford and Liverpool Street. The HS2 Ltd requirements for a
terminus included the provision of sufficient space for 10 high speed
platforms, access and dispersal areas, good public transport links
and minimal impact on surrounding area. HS2 Ltd has not provided
sufficient detail or justification as to why alternative locations for the
terminus were discounted. As a result, there is currently insufficient
evidence to take an informed view as to whether Euston is the most
appropriate location for that terminus.
4.3
There are no details as to how the construction would be phased or a
proper assessment on the impacts on the community or on our
transport networks (e.g. the strategic route network, footpaths, cycle
paths, bus services). The construction of the proposed Euston
Station would mean significant negative impacts on the lives of
residents and the viability of businesses in the Euston Area. This
would threaten the overall functioning of Euston as a place and the
potential blight arising from the proposals would stall investment prior
to and during construction. This will be to the detriment of the
communities in and around the proposed station.
4.4
There are also potential longer term impacts on train services
operating to and from Euston as a result of HS2 proposals. A
potential negative consequence of the HS2 proposal is that the
overall capacity at Euston and on the approach for other rail services
will be reduced. The potential for conflict between trains arriving and
departing could increase resulting in delay and reduced reliability.
4.5
The scheme would also require track alterations Hampstead Road
area. The current proposals would require the existing road bridge
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over the tracks to be rebuilt. There are no details about how these
works would be undertaken or an assessment on the impacts on the
community or on our transport networks (e.g. the strategic route
network, footpaths, cycle paths, bus services).
4.6
As indicated in response to questions 1-3, Camden Council considers
that the purported benefits of HS2 do not outweigh the local
disbenefits in the Euston area, around the proposed vent shafts and
along the proposed HS1 link. Please see Camden’s detailed
comments above in relation to the impacts of the proposed scheme in
relation to Noise and disturbance; Environment; Housing; Transport;
Education; Businesses and employment; Community and cultural
facilities; Crime and safety; and Blight and compensation.
4.7
The HS2 consultation document refers to the consideration, and
subsequent rejection of, an option to locate the HS2 terminus at
Kings Cross railway lands. Camden supports the dismissal of this
option by HS2 Ltd, and is strongly against the option of a terminus at
this location. This would undermine a key regeneration area,
jeopardising £2 billion of investment and removing the significant
benefits to be gained through significant improvements to a deprived
area and associated regenerative benefits, and the provision of
additional homes, employment space and other mixed uses including
retail and cultural uses.
Proposed vent shafts
4.8
There is insufficient information as to how the construction of the vent
shafts would be phased or a proper assessment on the impacts on
the community, biodiversity or on our transport networks.
4.9
Further details and specification is required regarding the proposed
vent shafts in relation to their height and overall scale and bulk. The
shafts would need to be sized and designed so that the amenity of
neighbouring premises is protected, and so that they fit into the wider
streetscape. If necessary, the shafts should be carefully landscaped
to minimise their visual impact. The detailed physical specification of
the line itself has not yet been set out. The lines should be futureproofed to allow for any changes in the future in relation to the nature,
design and weight of trains.
Proposed tunnelling
4.10
The proposed tunnels that would link Euston Station with Old Oak
common also raise concerns regarding noise, disturbance and
vibration, both during the construction phase and when in operation.
Please see section 4 of Camden’s main response for detailed
comments regarding noise, disturbance and vibration in relation to
the proposed tunnel.
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Question 5. The route: Do you agree that the Government’s proposed
route, including the approach proposed for mitigating its impacts, is the
best option for a new high speed rail line between London and the West
Midlands?
Proposed route
5.1
No, Camden considers that insufficient evidence has been provided
to demonstrate that the scheme would represent the best option
available, given the significant negative impacts that would be
generated by the scheme.
5.2
Whilst the principle of providing a central London terminus for HS2
may have passenger benefits, there is currently insufficient evidence
to take an informed view as to whether Euston is the most
appropriate location for that terminus.
5.3
The HS2 proposals at Euston would generate a range of negative
impacts for Camden, including the demolition of a large number of
existing homes (see Section 2a of Camden’s main response, which
provides details regarding the homes that would be demolished or put
at possible risk as a result of HS2), loss of business premises, loss of
designated open space, and major construction disruptions over
many years. These impacts, which are also considered above in
response to questions 1-4, and set out in more detail in Camden’s
main response, are clearly significant and of great concern for
affected communities and businesses. Camden therefore considers
that the consultation documents do not provide sufficient evidence to
show that the negative impacts on Camden (including on local
community, existing transport networks and on the local environment)
would be outweighed by the benefits.
5.4
Camden considers that insufficient information has been provided to
justify HS2 in transport terms, and considers that the business case
and environmental case for the scheme are open to question. The
proposal from HS2 Ltd does not provide adequate detail or a full
comparison of the alternatives. These alternatives include expanding
and enhancing the existing rail network on an incremental basis,
which would deliver capacity improvements whilst avoiding the
significant negative impacts associated with the current scheme.
West Coast Main Line
5.5
A proper assessment of the costs and benefits of upgrading the West
Coast Mainline should be undertaken before a decision is made as to
whether to proceed with HS2 is taken. The options considered should
include:
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 Optimising existing capacity by converting some first class
carriages to standard class at peak times.
 Operating longer trains, without major infrastructure expenditure.
 Infrastructure modifications to selected bottlenecks to increase
frequencies.
 Investment into platform lengthening, track reconfiguration and
additional platforms where required.
Old Oak Common
5.6
If the proposed High Speed 2 scheme were to go ahead, the use of
Old Oak Common as an interchange station would remove the need
for significant demolition and disruption at Euston as well as reducing
the overall project costs significantly. TfL have undertaken
assessments that highlight concerns about Crossrail having sufficient
capacity to cope with the extra passenger demand from HS2 between
Old Oak Common, Paddington and Central London. Further
consideration is required by TfL and HS2 Ltd to resolve if Old Oak
Common would be an appropriate terminus for HS2.
5.7
The option for an intermediate and interchange station at Old Oak
Common provides an opportunity to provide good connections to the
High Speed and classic rail network without the need for some
passengers to use Euston, the Underground or other rail termini. The
HS2 proposals would see services on both First Great Western and
Heathrow Express stopping at Old Oak Common providing direct
connections to Heathrow and the west. An Old Oak Common station
would help to reduce crowding at Paddington and Euston. The station
is also proposed to have an interchange with Crossrail and the North
London Line which has further benefits for passengers and
congestion relief on the Underground.
5.8
There is a good case for an intermediate and interchange station at
Old Oak Common and there should be further consideration by TfL
and HS2 Ltd to resolve if Old Oak Common would be an appropriate
terminus for HS2.
Mitigating impacts
5.9
Should HS2 go ahead and the central London termini be agreed to be
at Euston there are a number of issues that will need to be
addressed. The current proposals do not include sufficient
information regarding the potential impacts of the scheme (for
example in relation to noise and air quality), and it would appear that
some of the likely impacts may have been underestimated. For
example, whilst the consultation documents refer to the demolition of
216 dwellings and 20 business premises in Camden as a result of the
HS2 works, it would appear that the eventual losses that would be
required could potentially be significantly above this (see sections 2a
and 7a of Camden’s main response). Similarly, the AoS does not
appear to provide sufficient consideration of likely impacts in terms of
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noise, vibration and air quality (see Camden response to question 6
below).
5.10
An initial assessment of the impacts of the proposed scheme on
Camden, and the measures required to mitigate these, is set out in
Camden’s main response (sections 1-10). Were high speed rail to
progress as currently proposed then Camden would need to be
convinced that the mitigation needs highlighted in Camden’s main
response have been addressed, at no cost to the Council. Key
mitigation requirements include:

Replacement of existing homes to be demolished: In
addition to the 216 homes that HS2 predicts would be lost,
Camden is concerned that the viability of a further 264 homes
could be at risk due to their proximity to the expanded station
area and rail tracks (see Section 2a of Camden’s main
response, which provides details regarding the homes that
would be demolished or put at risk as a result of HS2). Any
homes that would no longer be viable for continued residential
habitation would need to be re-provided by HS2, with additional
financial compensation to be provided as necessary.

Further support to residents during the process, including
advice and financial support to cover expenses incurred.

Mitigation works to existing premises (such as noise
insulation measures) that would not require demolition but that
would experience a negative impact on their living environment
as a result of the construction and/ or operation of HS2.

Re-provision of open spaces: the open spaces and habitat
areas that would be lost, including at St James Gardens and
Adelaide Road, would need to be provided. Such re-provision
should be at least equivalent to existing in terms of size, quality
and location.

Funding to improve impacted schools, including relocation
support if necessary.

Protection of existing rail network. Planning of construction
process// phasing and operational routes to minimise impact on
existing rail services (including local/ suburban rail services).

Onward distribution of passengers from Euston station: the
accommodation of onward journeys and the funding of upgrades
will be a vital consideration as to whether Euston is the right
location for the HS2 terminus. A full assessment of the transport
needs arising from HS2 should consider:
o
Significant additional investment in new and improved
public transport and walking/ cycling routes would be
required, as the capacity of existing and planned
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infrastructure will not be sufficient to cope with additional
passenger numbers.
o
implementation of capacity upgrades to Euston and
Euston Square Underground stations (including a subsurface link).
o
Crossrail 2 (Chelsea – Hackney line) including a station
at Euston.
o
DLR extension between Bank and Euston. Significant
investment to encourage walking and cycling to/from
Euston including a new station access from the south
side of Euston Road.
o
Please see section 5 of Camden’s main response for
more information regarding the mitigation measures
required for the scheme.

Proper planning for the above station/ track development:
The HS2 proposals would involve the location of all platforms
and train lines below ground level, with the ground level
providing a large area for development (approximately 65% the
size of King’s Cross Central). Should the project go ahead,
future proposals above the station would provide the opportunity
to include space to re-provide homes for people displaced,
provide new homes, employment opportunities, shops and new
open space as well as providing the opportunity to improve eastwest linkages. Camden would encourage the use of space
above the station and the maximum amount of decking over the
railway tracks to make the most of opportunities to provided
uses to mitigate losses and to minimise noise disturbance of
local areas by the new rail lines.

Interim anti -blight strategy:

Development and implementation of a strategy to prevent or
minimize the blight of land, buildings and businesses in the
area which should be developed in conjunction with Camden
and should include;
Pre construction




Upfront funding for re-provision of homes planned to
be lost as a result of expansion of Euston;
Funding for and cooperation in the production of a
joint Blight Mitigation Strategy for the Euston area,
alongside Camden,
Support and financial assistance for local businesses
to allow them to function effectively in an area with an
uncertain future;
Funding for interim improvements to public transport
and other infrastructure and around the station which
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
are needed now and may otherwise be withdrawn in
anticipation of the potential construction of HS2;
Short term lets for blighted properties.
Construction related




Funding for resident support during the construction
and relocation process;
Support for businesses that would experience
disruption as a result of the lengthy construction
period;
Careful phasing and management of construction to
minimise impacts on local communities and on the
existing transport network;
Measures to minimise noise and disturbance during the
construction process
5.11
Should HS2 proceed the Council would be keen to work closely with
HS2 to ensure that the longer term benefits are maximised and the
impacts of construction on our residents, businesses, public transport
and streets are minimised.
5.12
Camden notes the HS2 commitment to produce a ‘joint strategy’ for
Euston (HS2 consultation document ‘High Speed Rail: Investing in
Britain’s Future’ February 2011: see pages 20 and 82). It is essential
that proper mechanisms are put in place to ensure the full
implementation of all mitigation measures required to address the
impacts of the scheme:

Relevant physical measures should be included in the Area
Planning Framework for Euston, which would form a key part of
the joint strategy for the area. The planning framework should
be taken into account as part of the Environmental Impact
Assessment;

All required mitigation measures (as set out above and in the
main Camden response) should be set out in the Environmental
Statement for the scheme. The implementation of these
measures should then be secured as part of the statutory
framework for the delivery of the scheme, whether by an
undertaking given to Parliament or by other appropriate means;

As part of the joint strategy for the Euston Area, Camden would
seek to be involved in the procurement process for the above
station development.
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Question 6. Appraisal of Sustainability: Do you wish to comment on the
Appraisal of Sustainability of the Government’s proposed route between
London and the West Midlands
6.1
Camden is concerned that the AoS has not properly identified all the
potential impacts on Camden. There is no definitive information on
the environmental case for or against the scheme that assesses
environmental impacts on HS2 against business as usual or
alternative transport options, taking account of all whole life cost
impacts and benefits. Therefore further, detailed analysis taking into
account all of the factors needs to be completed by HS2 Ltd.
6.2
Given the limited information available regarding the potential impacts
of the scheme, it is considered that there is currently insufficient detail
to allow the government to reach a properly informed in-principal
decision as to whether to go ahead with the scheme. Therefore no
decision should be made until further technical analysis regarding
potential impacts has been properly carried out. This additional
research should be made public, with an opportunity for further
comments to be made before any decision is made regarding the
scheme.
6.3
Key deficiencies in the current AoS (and thus the evidence base in
support of HS2) include:

Air quality: The AoS indicates that the potential impacts of the
scheme in terms of air quality and noise are ‘unknown’, as it has
not been possible to assess these issues. Impact on air quality
and noise during the (potentially lengthy) construction process
are crucial issues that must be considered closely before a
decision is taken as to whether the scheme should go ahead.
Section 3 of Camden’s main response indicates that the scheme
could generate significant air quality issues, including in relation
to dust created during construction and from vehicular
movements associated with the construction process. This
should be considered in more detail before an informed decision
can be reached on the scheme.

Noise: The AoS indicates that there would be a neutral impact
in terms of the change in the population potentially annoyed by
operational noise along the proposed links to HS1. Given the
proximity of this line to residential premises, this conclusion is
considered to be questionable, and should be carefully
considered. Section 4 of Camden’s main response highlights the
considerable potential noise impacts of the scheme both relating
to the construction process and during the operation of the
proposed new line. This is a highly important issue that must be
assessed in more detail before an informed decision can be
made as to whether to g ahead with the proposed scheme.
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
Vibration: The AoS acknowledges that the scheme could have
a negative impact in terms of the local vibration environment
(nos. of residential properties at risk of vibration and reradiated
noise). However, this is only acknowledged for the Old Oak
tunnel and the proposed HS1 link: the appraisal indicates that
there would be a neutral impact at Euston. Given the extensive
works that would be required at Euston (including major piling,
superstructure works and excavation), and the proximity of the
proposed western flank of the station to neighbouring properties,
the potential impact of the works at Euston in terms of vibration
should be more carefully considered.

Heritage: The listed buildings that would be affected by the
works have not all been correctly identified both in terms of what
is in the footprint of the expanded station area, and what is close
to the footprint.

Crime and safety: The AoS also indicates that the potential
impact of the proposed scheme in relation to crime and safety is
‘unknown’. Camden’s experience from the current construction
of the new Crossrail interchange at Tottenham Court Road is
that such works can generate significant problems in relation to
crime and safety, with numerous incidents reported at the
construction site. Please see Section 9 of Camden’s main
response for further information regarding crime and safety.

Economy: The AoS indicates that the HS2 scheme as a whole
would have a very positive impact in terms of support for wider
economic growth and employment opportunities. However, the
appraisal should also consider the impact on local economies,
and the negative impact that the scheme would have on local
businesses both through the demolition of properties belonging
to existing businesses (a number of which have built up trade
and local reputation over a number of years) and through blight
caused by extensive street closures (and consequent loss of
passing trade), for example along Eversholt Street. See Section
7 (b) of Camden’s main response for further information
regarding the impact of the scheme on local businesses.

Employment: In relation to regeneration benefits associated
with new employment opportunities at Euston, AoS volume 2
(p30) states that “Development around Euston station would not
necessarily provide employment benefits to residents in the
immediate area due to mismatches between skill levels and the
nature of jobs attracted as well as the nature of the London
labour market”. Camden does not agree with this viewpoint, as
measures could be taken to ensure that local residents can
benefit from the opportunities generated by the scheme. Were
the scheme to go ahead, Camden would expect a commitment
to jobs training in order to allow local access to the new jobs
created (see Section 7 (d) of Camden’s main response).
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
Transport: The AoS does not give adequate consideration to
the potential negative impacts of the scheme on existing public
transport networks. As well as potential disruption during the
construction works, there could be ongoing disruption to North
London Line services as a result of the proposed link to HS1.
The North London Line provides a key east-west link, and any
disruption to its services would have a harmful impact on public
transport accessibility in the area. See Section 5 of Camden’s
main response for further information regarding the impact of the
scheme on existing transport networks.

Open space: The AoS acknowledges the loss of the St James
Garden open space in relation to impact on townscape
character and impact on existing habitat. However, the
substantial loss of this open space would also have a negative
impact on the quality of life of residents and, potentially,
community cohesion through the loss of an important community
space. These impacts should also be acknowledged in the AoS.

Habitat: The AoS states that the proposed works provide the
opportunity for habitat creation, and indicates that this would
have a beneficial impact for the Euston Area and along the link
to Old Oak Common. It is considered that this is misleading: the
loss of existing open space and habitat areas at St James
Gardens and at Adelaide Road would mean that the scheme
would well generate a net loss of habitat. This should be
acknowledged in the AoS

Joint ambition for the Euston area: Volume 1 of the AoS
refers to a ‘joint ambition for the Euston area’ (see paragraph
8.16.2). However, the consultation documents do not specify the
means for achieving the commitment to agreeing a joint
ambition for the Euston area. This should be clearly defined, in
consultation with LB Camden.
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Question 7. Blight and compensation Do you agree with the options set
out to assist those whose properties lose a significant amount of value
as a result of any new high speed line?
7.1
No, the statutory position in relation to compensation for loss of value
on property due to the impact of physical factors from the operation of
HS2 is set out in Part 1 of the Land Compensation Act 1973. Under
this Part of the Act residents would have to wait until the railway has
been constructed and been running for a year to enable the
Government to assess what the actual physical impact has been on
local residents homes, such as noise and then compensate them for
the resulting reduction in value of their properties, if any at all. Until
the one year anniversary of the train line commencing operation, the
affected residents would continue to suffer blight and uncertainty if
they wish to sell their property and occupiers of business properties
may experience a similar drop in trade due to the same factors.
7.2
The Council notes that HS2 is proposing additional discretionary
support, in order to address the interim impacts of blight:
 One approach considered is to buy up properties even if they
are not actually needed for construction. Management
responsibility for these properties would fall to the Department of
Transport (“DOT”), including letting to and managing tenants and
then selling the properties off after the line is constructed and
running. It is considered by HS2 that this would also tend to
break up communities. The Council’s position on this proposal is
that whilst limited buy up of properties in clearly defined areas
may be desirable, as will be clear from the paragraph above this
clearly would not go very far in addressing all of the impacts
affecting Camden which should be compensated for.
Furthermore such a buy out would need to be very carefully
managed were it not to distort the property market in the
surrounding area.
 The first bond proposal referenced (a Property Bond) would take
the form of a guarantee that the DOT will buy people out, if
called upon to do so by the owner, subject to conditions. This
would mean that the owner can stay in their home, but in the
knowledge that should they decide to move home, they can sell
to the DOT. This is likely to encourage people to stay, but has
the disadvantage for DOT that they may end up having to own
and manage properties and could be expensive. The price paid
for those properties would be the usual no scheme world (i.e.
one assumes, no HS2 line).
 . The second bond proposal (a Compensation Bond) in the
Consultation is a guarantee not to buy out the property, but to
meet any shortfall in value if an owner were to sell their property.
This bond would be able to be passed on to a buyer if the
property is sold on in the meantime. However, the compensation
may not be paid out until HS2 is completed which is likely to be
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many years. The Government argues that this would encourage
people to stay in their homes and would presumably be cheaper.
The disadvantage of this scheme is that it would only pay out if
loss can be demonstrated and leaves residents living close to a
major construction site and then a running railway, when they
might prefer to leave.
7.3
The Council’s position on both bond proposals is that whilst the first
option may be acceptable as part of a range of compensation
measures, it would not address all of the impacts on Camden for
which compensation should be given. The second option is only
acceptable if the compensation is paid at a specified trigger date
early in the project implementation process, e.g. the date of
permission under the Act of Parliament, rather than at or close to
completion of the scheme. Furthermore both bond proposals are
unlikely to overcome all distortion of the property market
7.4
The measures proposed also fail to provide a mechanism for allowing
property owners that would lose their homes the opportunity to buy
another property in their area. Given the comparatively low value of
some of the homes that would be demolished, there is a risk that
some owners (in particular those that bought their homes through
‘right to buy’) may not be able to purchase another property in the
area. This could have significant negative impacts on those affected,
as well as threatening the breakup of local communities if large
numbers of people are required to move away.
7.5
Whilst the proposed measures in the Consultation that are targeted at
owner occupiers are noted, the proposed scheme would also have a
significant impact on other sectors including the Council as social
housing provider, Council tenants and local businesses, who could
experience significant disruption as a result of the proposed scheme.
7.6
In respect of Council tenants, and all other occupants who would not
have to move as a result of the line but whose quiet enjoyment of
their home would be detrimentally affected by the construction and
operation of HS2, a package of financial compensation and physical
compensatory measures should be included in the scheme to
mitigate the effects. This could incorporate payments or a scheme for
double-glazing or reconfiguration of blocks/doorways/entrances.
Section 2 above and Annex 1 to this response provide details
regarding affected residential properties.
7.7
The Council would also lose parking revenues as a result of road
closures during the construction period and, over the longer term, the
permanent loss of streets to the west of the station area, which
currently include on-street parking. These losses would need to be
compensated by HS2.
7.8
The prolonged period of scheme development and construction at
Euston Station would threaten to blight buildings and development
sites in the area. In order to address this, HS2 should develop a
proper interim blight strategy, in conjunction with Camden, to address
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potential blight of homes businesses and communities in the
surrounding area (please refer to section 2 of the main Camden
response for details of what this should include).
7.9
Please also note the comments provided in Section 2 of Camden’s
main response, which highlights the shortcomings in the exceptional
Hardship Scheme in addressing the impacts of HS2, including the
need to ensure that compensation arrangements are developed to
allow property owners of properties to be demolished to be able to
afford to purchase another property in the area.