HS2 LONDON - WEST MIDLANDS
“DRAFT ENVIRONMENTAL STATEMENT”
CONSULTATION
RESPONSE TO THE CONSULTATION
BY THE COMMUNITY GROUPS REPRESENTED ON THE
HS2 EUSTON COMMUNITY FORUM
11 July 2013
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“I would wish you to progress the work set out below ...... 1.4 with Camden
Council, Transport for London and Network Rail undertake further work on the
phasing of the redevelopment at Euston, having regard to: (i) residents who would
potentially need to be rehoused; (ii) passengers using Euston; (iii) local businesses
and amenities. This initial further work should be ready for consultation in Autumn
2010, recognising that detailed design work is expected to take several years.”
(Lord Adonis’ Remit Letter to HS2 Ltd (17.3.2010)
CONTENTS
1. Introduction by Frank Dobson MP
2. Executive Summary
3. The HS2 Euston Community Forum
4. HS2’s Engagement with the Local Community
5. Defects in the Consultation Process
6. The Current Proposal for Euston Station
7. Mitigating the Impact of HS2 on Homes
8. Mitigating the Impact of HS2 on Businesses
9. Mitigating the Impact on our Environment
10. Mitigating the Impact of HS2 of Open Spaces, Community Facilities and our Heritage;
11. The Draft Code of Construction Practice
12. Conclusions
Appendices
1. Map of the “Euston area” covered by this Response
2. The Community Groups on the HS2 Euston Community Forum (“the Forum”)
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1. Introduction
The scale, complexity and likely duration of the works proposed at and leading up to Euston
station require specially tailored arrangements to mitigate the impact on local residents and
businesses and to provide compensation generous enough to ensure that no-one ends up
worse off. The draft environmental statement falls far short of what is required.
HS2 Ltd have already been forced to admit that they grossly underestimated the costs of the
works they originally proposed at Euston. They now estimate that their revised and much
reduced scheme will cost at least 40% more than the much larger original. So, both local
people, businesses and the taxpayers will pay more and get less. It is also clear that they
have grossly underestimated the costs of the mitigation measures and compensation
needed to reduce the damage they propose to inflict on local residents and businesses.
When pressed on these issues, HS2 Ltd have come up with no guarantees of any such
measures or compensation. They have treated representations from local residents and
businesses with disdain. When pressed they have fallen back on saying they are simply the
agents of Ministers while at the same time not honouring public commitments made by
Ministers.
I endorse the position taken by the Euston Forum representing 61 Community Groups in the
neighbourhoods affected and call upon Minsters to ensure that the final environmental
statement which must be presented to Parliament responds to the criticism of this draft
statement and comes up with costed mitigation measures and compensation arrangements
which really meet the needs of residents and businesses in and around Euston.
The Rt. Hon. Frank Dobson M.P.
House of Commons
11 July 2013
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2. Executive Summary
(i) This response is made on behalf of the Community Groups who are represented on the
HS2 Euston Community Forum (“the Euston Forum”).
(ii) In this response, “HS2” refers to both the scheme and its two promoters, namely the
Secretary of State for Transport (DfT) and HS2 Ltd. There has been a lack of accountability
for the development of the HS2 project and for this consultation. Based on their track
record to date, we have no confidence that HS2 can be delivered on time, fit for purpose,
and to budget.
(iii) The stated purpose of the Euston Community Forum Area Reports (at [1.2.1]) is to
provide “a summary of the likely environmental issues and proposed mitigation measures
that are being addressed during the design development in the Euston area”. The
consultation is fatally flawed in that it fails to identify any adequate mitigation measures.
There is no attempt to cost either the environmental damage that will be caused or
measures to mitigate that damage.
(iv) This Consultation Report should have been written on the worst case scenario,
identifying alternatives to minimise any environmental damage and costing all possible
options to mitigate that damage. In so far as that damage could be mitigated by
alternatives, the cost of the scheme could be reduced. In the absence of such costed
options, no informed assessment can be made of the overall cost of HS2.
(v) Mitigation and compensation go hand in hand:
(a) HS2 has failed to come up with any compensation proposals which will ensure
that no individual will suffer serious financial loss in the national interest as a result
of HS2.
(b) In this response, we highlight HS2’s manifest failure to propose any realistic
mitigation measures.
(vi) HS2 established the Euston Forum with the objectives, inter alia, of (a) identifying and
discussing local preferences for avoiding, managing or mitigating the impact of the project
during construction and operation and (b) identifying local community benefits and
activities which could be linked to the project. There is little in this report to indicate that
HS2 have had any real regard to the views of the Forum. HS2 rather see the Euston Forum
as a propaganda tool to promote their project.
(vii) The 8 week consultation period for this major consultation has been wholly inadequate.
It is neither “proportionate” nor “realistic” to allow stakeholders sufficient time to provide
considered responses.
(viii) The current proposal for Euston of a “shared station” is the worst possible option for
the Euston Area:
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(a) It causes the greatest damage in terms of loss of homes, businesses and jobs, a
school, open spaces, community facilities and a historic graveyard.
(b) It offers the least in terms of community regeneration.
We discuss this in our separate response to the Refinement Compensation.
(ix) Homes: 216 flats are to be demolished; a further 264 may be at risk. HS2 has failed to
develop a strategy to rehouse the 216 households who will lose their homes or to replace
the low cost housing that will be lost. A further 264 tenants face a stark choice: (a) either
their homes will be demolished or (b) the quality of their environment will be destroyed by
their proximity to the new station. No adequate mitigation measures are proposed. We set
out the guarantees that we seek in Section 7.
(x) Businesses: 2,750 jobs will be lost. We are particularly concerned at the plight of the
traders in the Drummond Street area who will be cut off from Euston station which is their
main source of their custom for a period of ten years. No adequate mitigation measures are
proposed. We set out the guarantees that we seek in Section 8.
(xi) Mitigating the Impact on Our Environment: HS2, when complete, will increase road
traffic in the area by up to 40%. HS2 will lead to unacceptable levels of pollution, both
during the construction and thereafter, in an area where pollution levels are already higher
than permitted standards. We set out the guarantees that we seek in Section 9.
(x) Open Spaces, Community Facilities and our Heritage: We will lose open spaces in St
James’ Gardens, Euston Square Gardens, Hampstead Road and Eskdale. No adequate
mitigation measures are proposed. We set out the guarantees that we seek in Section 10.
(xii) The Draft Code of Construction Practice: Because of our proximity to existing mainline
services, most of the construction work will be executed outside core hours, which will
impact upon residents. No attempt has been made to assess the cost to Network Rail, were
works rather to be carried out within core hours. Had this been assessed, it would have
provided a benchmark for devising mitigation measures and/or compensation for those
whose lives will be blighted by ten years of construction works. We set out the guarantees
that we seek in Section 11.
(xiii) We are being consulted on these half-baked proposals at this stage merely because of
the DFT’s requirement for a hybrid bill to be tabled in parliament by the end of this year.
Given the flawed nature of this consultation, we suggest that there is no prospect that any
hybrid bill will receive the Royal Assent by May 2015.
(xiv) HS2 have signally failed to identify an adequate package of measures to mitigate the
environmental damage which the construction and operation of HS2 will cause to our
vibrant, diverse and densely populated community with high property values. Until that
environmental damage and recommended measures to mitigate that damage have been
assessed, no informed assessment can be made on the feasibility of HS2. There is no basis
for concluding that the current budget of £42.6bn (excluding rolling stock) is any more
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realistic that the initial estimate of £34.5bn. If HS2 Ltd is forced to deliver HS2 within an
unrealistic budget, it will be the Euston community who will bear the cost of their
incompetence, through an unacceptable impact on their homes, families and businesses.
(xv) We understand that HS2 will provide a further Environmental Statement when the
hybrid bill is presented to Parliament. We expect that Statement to include real mitigation
measures based on a worst case scenario and which are fully costed. We oppose HS2 in
principle. However, if this project is to proceed, those who promote it must ensure that
there is a proper set of mitigation and compensation measures to meet the needs of those
individuals who will suffer serious loss in the national interest as a result of the construction
and operation of HS2.
3. The HS2 Euston Community Forum
3.1 This Response is made on behalf of the community representatives on the Euston Form.
It is also endorsed by many of the elected representatives who are members of the Euston
Forum, including Frank Dobson, the MP for Holborn and St Pancras, and our local ward
councillors, Cllrs Nasim Ali, Heather Johnson and Tulip Siddiq. Our membership (61
community representatives) is listed in Appendix 2.
4. HS2’s Engagement with the Local Community
4.1 Under the Terms of Reference which the Euston Forum has agreed with HS2, HS2
commit themselves to the highest standards of administration and to comply with the
Aarhaus Convention on “Access to Information, Public Participation in Decision-Making and
Access to Justice in Environmental Matters” and the twin “pillars” of
(i) Access to relevant environmental Information.
(ii) Public Participation in decision making.
4.2 In practice, community representatives have found their contact with HS2 to be
extremely frustrating. They have only remained engaged because of their concern of the
damage that HS2 will cause to their communities.
4.3 The Forum’s core objectives are (a) identifying and discussing local preferences for
avoiding, managing or mitigating the impact of the project during construction and
operation and (b) identifying local community benefits and activities which could be linked
to the project. At our meeting on 11 June 2013, we asked HS2 to specify the five main
proposed mitigation measures that have been achieved through the work of the Forum. HS2
were unable to satisfy that any significant outcomes have been achieved.
4.4 The following illustrate the difficulties that we have faced:

On 22 March 2011, Camden LBC arranged a public meeting to alert the local
community to proposals for HS2. HS2 refused an invitation to attend. There was an
empty seat for them on the platform.
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
On 19 March 2012, the Euston Forum asked HS2 to acquire the vacant National
Temperance Site to provide alternative accommodation for the residents who were
to lose their homes. The residents affected were given a clear understanding that
HS2 had acquired the site and that this was to be used for replacement housing. On
22 November 2012, we were told that it was rather to be used as a construction site.
There was an unseemly spat between the Leader of the Council and HS2 as to how
this misunderstanding arose. HS2 have failed to identify any alternative provision.
HS2 agreed to enter into a Memorandum of Understanding with Camden LBC to
ensure that there is a framework for improved partnership working. That has still not
been signed. We are told that this in the hands of HS2 Ltd/DfT.

On 22 November 2012, the Euston Forum discussed the Compensation Proposals.
Our Terms of Reference stipulate that papers should be circulated in advance which
are relevant to the Euston area. HS2 provided a standard presentation prepared for
26 Community Forums among the route. This did not address the needs of those
who live or work in the Euston Area as we illustrated in our Ten Case Studies 1. The
local Camden Cutting Group set up a public meeting to discuss the consultation.
Again, HS2 refused to attend. We have asked HS2 to produce a set of compensation
measures tailored made to meet the particular needs of those who live and work in
the Euston area. HS2 have declined to do so.

On 24 January 2013, our meeting was shambolic. None of the papers were provided
in advance. Those which were tabled did not relate to the presentations which were
made.

On 18 April 2013, HS2 presented their Current Plan for Euston Station. Despite the
fact that this was similar to a confidential briefing which had been made to the
Leader of the Council some six weeks earlier, this was still not circulated in advance.
Community representatives were thus afforded no opportunity to prepare for the
meeting or to take soundings from the groups that they represent. Even the Chair of
the meeting was denied the courtesy of an advanced copy.
4.5 These problems may not be the fault of HS2 Ltd. We are told that sensitive papers must
be vetted in advance by DfT. It may also be that HS2 Ltd are unable to make any positive
proposals for mitigation because of the prior approval required from DfT before any
expenditure can be committed. This problem would not exist were HS2 to have made an
accurate assessment of the sums required for compensation and mitigation measures. We
estimate the cost of compensation at £1bn with a further sum required for mitigation
measures. HS2 have significantly underestimated the former, while they have yet to make
any assessment of the latter.
4.6 Our concern is that the government sees the Community Forum as a propaganda tool to
promote HS2 rather than to engage with us in all aspects of the project and to identify real
measures to mitigate the impact of HS2 on our communities. On 11 February 2013, the
Euston Forum complained about a misleading video HS2 suggesting that residents in the
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See http://www.hs2.org.uk/developing-hs2/forums/community-forums/euston-community-forum
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Euston area would benefit from schemes which were restricted to those who live in rural
areas. The Euston Forum produced its own video in response2. DfT and HS2 disagreed with
each other as to who was responsible for the video. The video was withdrawn from You
Tube.
4.7 We emphasise that we make no criticism of the staff employed in HS2’s Community
Engagement Team who are doing their utmost to work with local groups in a very difficult
situation. When we negotiated the terms of Reference for the Euston Forum we sought
resources for a community secretariat and to commission our own independent research.
This was refused and explains why there are no functioning Forums in the two other areas
of Camden. We ask that the issue of resources is reconsidered. HS2 is making wholly
unrealistic demands on the goodwill of those who are willing to commit their time on behalf
of their local communities. A wholly unrealistic deadline of 8 weeks to respond to two
consultations merely adds to these burdens.
4.8 We have recently noticed a more positive response from HS2. We are no longer given an
automatic stock response that information requested will be provided within the timescale
prescribed by the Freedom of Information Act. We hope that this bodes well for the future.
5. Defects in the Consultation Process
5.1 The 8 week consultation period for this major consultation has been wholly inadequate.
The Cabinet Office Consultation Principles prescribe that “timeframes for consultations
should be proportionate and realistic to allow stakeholders to provide a considered
response”. The 8 weeks afforded is neither proportionate nor realistic, particularly given the
vast amount of material that we have been required to assimilate. The extent of the impact
in Camden is such that there are three Community Forum Areas.
5.2 On 11 June, the Euston Forum requested HS2 to extend the deadline. On 25 June, HS2
Ltd’s Chief Executive, Alison Munro, refused to do so. We are aware that the HS2 Action
Alliance wrote in similar terms on 3 June 2013.
5.3 We are satisfied that this unrealistic deadline has been imposed because of the
government’s stipulation that a hybrid bill should be deposited by the end of the year, and
HS2’s abject failure to deliver the project to the stipulated timescale. On 12 January 2012,
the Secretary of State announced the government’s intention to proceed with HS2. Eighteen
months later, its programme has already slipped by some nine months:
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
HS2 was to consult on a new compensation scheme in “Spring 2012”. That
consultation was launched six months later at the end of October. On 15 March,
2013, the Administrative Court ruled that the previous consultation upon which this
consultation was “so unfair as to be unlawful”. HS2 have yet to devise an acceptable
compensation scheme or assess the cost of the same.

HS2 was to put in place the new blight scheme and safeguarding zone by “Autumn
2012”. HS2 put in place the new safeguarding zone on 9 July 2013. Whilst this will
Available at http://www.youtube.com/watch?v=cqcKd6QiMKs&feature=em-share_video_user.
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trigger the statutory blight procedures under the Town and Country Planning Act
1990, it does not include the additional measures required to secure fair
compensation for those affected by HS2.
5.4 The Euston Forum was not alerted in advance as to the date on which the consultation
was to be launched. This precluded us from arranging a series of workshops at which we
could have focused on specific areas. We would have wished to include members of the
public to enable them to make a more informed response than is possible from the two
walk-in surgeries which HS2 arranged. The scope of our response is inevitably limited by the
sheer volume and extent of the material that we have been required to assimilate and the
limited time in which we have been afforded in which to do so.
6. The Current Proposal for Euston Station
6.1 The Euston Forum opposes HS2’s Current Proposal for Euston Station. In our response
to the Refinement Consultation we set out why we consider that this option causes the
greatest damage whilst offering the least in terms of community regeneration. The
approach adopted conflicts with the latest Remit Letter which was issued by the Secretary
of State to HS2 Ltd on 27 June 2013. This enjoins HS2 to use the project as an engine for
growth and local economic development.
7. Mitigating the Impact of HS2 on Homes
7.1 HS2 assess that 216 homes in the Euston area will be demolished. We suggest that a
further 264 are at real risk. Four blocks on the Regents Park Estate are to be demolished,
namely Eskdale (60 flats), Silverdale (69 flats), Ainsdale (39 flats) and Stalbridge House (20
flats). A further 28 homes are to be demolished in the Drummond Street area in Cobourg
Street, Melton Street and Euston Street.
7.2 The majority of residents have occupied their homes for more than 5 years. The majority
are secure tenants. However, a number of residents have acquired leases of their homes
under the Right to Buy legislation. These homes on the Regents Park Estate were built in the
1950s. There is a close-knit community. Some of the residents have lived here since their
blocks were built. Some are in their eighties and nineties. Some residents have lived here
all their lives. Many want to remain within their existing communities. Some flats have been
specially adapted for disabled residents. We have a rich cultural mix. There is a large British
Bangladeshi community.
7.3 The residents at Stalbridge House are long lessees of a private landlord. The block is exrailway stock. These residents face the same problem as the Right to Buy lessees in that the
compensation offered by HS2 is inadequate to enable them to buy alternative
accommodation in the Euston area. There is a chronic shortage of affordable
accommodation, whether to rent or to buy.
7.4 Local residents were informed that HS2 would acquire the National Temperance
Hospital for replacement housing. On 22 November 2012, the Euston Forum was informed
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that HS2 now intend to use this site as a construction site. No alternative housing has been
identified.
7.5 A ward councillor recounts the plight of Mr B, a ninety year old tenant who lives in
Silverdale. He seeks reassurance that he will not face imminent eviction from the home
which he has occupied for the last 50 years. He is infirm and cannot take a lift. His
consultant has confirmed that he requires accommodation on the ground or first floor. He
seeks further reassurance that he will be able to remain in the local area in proximity to his
current neighbours. The councillor is unable to give him any reassurance as to his future.
7.6 No resident has any idea of what is proposed for them. It is understood that HS2 have
been negotiating with Camden LBC over a Memorandum of Understanding for the past six
months. We are concerned at HS2’s failure to conclude this. At the meeting of the Euston
Forum on 11 June 2013, Cllr Sarah Hayward, the Leader of Camden Council, outlined a range
of housing developments in the area in which it would be possible for HS2 to participate.
Tenants again showed their frustration at HS2 refusal to provide any assurance that
practical steps are being taken to secure alternative accommodation. We are satisfied that
HS2’s failure to establish an effective relationship with Camden LBC is not the fault of the
local authority. Similar problems are reported further up the line.
7.7 Three other blocks on the Regents Park Estate (Cartmel, Langdale, and Coniston), and
further properties in Cobourg Street, Drummond Street and Starcross Street, may also be at
risk. It seems that the plight of those who remain in blocks adjacent to the new line may be
worse than those who will lose their homes:

Residents in Cobourg Street will look out onto a “Berlin Wall” for ten years which is
to be erected down the centre of their street whilst the new station is constructed.
Thereafter, this quiet residential street will be used as the main transport route for
the new station, being a drop-off and pick-up point for taxis and the drop off location
for private cars. Vehicles will not only travel down Cobourg Street from the north.
To add in salt to the wounds of local residents, vehicles will then be directed by a
roundabout at the bottom of their street back up Cobourg Street and out onto
Hampstead Road. The current proposals are wholly unacceptable.

Residents at Langdale, Coniston and Cartmel will look down onto a building site for
10 years whilst the new station is constructed. HS2 tell them that works are likely to
be undertaken outside the core hours to minimise the interference with existing
Network Rail services. Nothing is proposed to mitigate the impact of the
construction works. In 2026, or when construction is complete, they will look down
directly onto the new station. They will be subjected to noise nuisance from the
station tannoy system. They will have no access from Varndell Street onto
Hampstead Road as the level of this road will be raised on its approach to the new
Hampstead Road Bridge. The impact on their local environment could be mitigated
were the new station to be decked over and landscaped to create imaginative open
spaces in the area around the new bridge. This would compensate them for the
open spaces which they are going to lose. No such mitigation is offered.
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7.8 The Euston Forum seeks the following guarantees in respect of the loss of homes in our
area:
(i) There will be no overall loss of low cost homes in the Euston area as a result of
HS2, this includes both social housing to rent and low cost ownership.
(ii) HS2 will fund the replacement of all lost homes, currently a minimum of 216
dwellings.
(iii) All tenants, leaseholders and owner-occupiers will be offered genuine, suitable
alternative accommodation.
(iv) All such homes should be in the neighbourhood, if that is what residents desire.
(v) All Council tenants should be entitled to remain tenants of Camden LBC, if that is
what they want.
(vi) Camden LBC will remain the landlord of existing leaseholders, if that is what they
want.
(vii) Alternative homes will be provided straight away and no resident should have to
move to temporary accommodation.
(viii) Nothing should affect the security of tenure enjoyed by any resident.
(ix) Neither rents nor service charges will be higher than if residents had not been
forced out of their homes.
(x) There will be access to free legal advice for all residents to enable them to make
an informed decision on the options available to them. This is no longer available
under the legal aid scheme.
7.9 The Euston Forum raised similar demands in January 2013. These are not reflected in the
consultation paper. Despite HS2’s stated commitment to consultation and to devise a
mitigation strategy which is real and effective, our reasonable demands are falling on deaf
ears.
7.10 The only commitment that HS2 offer is that “where reasonably practicable” secure
tenants will be rehoused locally and will only be required to move once. This is not
acceptable:

It is reasonably practicable to secure replacement for low cost homes that will be
lost prior to the commencement of construction works. What is lacking is the
political will to secure this.
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
HS2 is only contemplating rehousing for “secure tenants”, probably some 50% of
those whose homes will be demolished. Right to Buy tenants will be left to hang
out to dry.

No loss of low cost home ownership in the Euston area is acceptable. We wish to
retain our existing and mixed community.
7.11 The Euston Forum seeks the following further guarantees in respect of the tenants
whose blocks are under threat, but whose plight may be made worse by living adjacent to
the new line:
(i) Current plans for Cobourg Street will be taken back to the drawing board. The
impact of the current proposals on residents is unacceptable, both during the ten
year construction period and in the longer term when the new station is opened. The
drop-off and collection points for vehicles must be integrated into the new station,
preferably underground. It is not acceptable for traffic to blight the lives of local
residents.
(ii) HS2 will come up with a realistic package of mitigation measures for the residents
at Langdale, Coniston and Cartmel both in respect of the ten year construction
period and after the new station has opened. Nothing is offered to them in the
current consultation.
8. Mitigating the Impact of HS2 on Businesses
8.1 A number of large business premises and two hotels in the Drummond Street area are to
be demolished to make way for the new station. HS2 estimate that these businesses
employ 2,750 people. The area is already blighted with three large premises to the west of
Hampstead Road standing derelict, namely the garage, the former BHS warehouse and the
National Temperance Hospital. It is believed that the latter has now been acquired by HS2.
HS2 has failed to adopt any policy to abate the blight.
8.2 In 2009, Camden LBC agreed “Euston: A Framework for Change – Supplementary
Planning Document”. This set out an ambitious plan to develop the existing mainline station
and the surrounding area promising 1,000 new homes and 5,000 extra jobs. New public
open spaces would have been created. But for the current proposals for HS2, this
regeneration would be well in hand. The claim that HS2 will help to stimulate a stagnant
economy has a hollow ring in the Euston area.
8.3 The Euston Forum has focused on the smaller traders in the Drummond Street area.
Drummond Street is a unique area of Camden with a range of shops, restaurants and cafes
run predominately by the British Bangladeshi Community. They rely on much of their
business from those using the existing Euston station. A “Berlin Wall” is to be constructed
down the centre of Cobourg Street. For ten years, this will cut off Drummond Street traders
from their main source of customers. These businesses are anxious to remain in the
Drummond Street area. They will not be able to do so unless there is a range of mitigation
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measures to enable them to remain trading and in business over the period 2017-2026 that
the new station will be constructed.
8.4 The Euston Forum seeks the following guarantees to safeguard these businesses during
the construction phase:
(i) HS2 will adopt a strategy to mitigate the blight that it is causing in the Euston
area.
(ii) Drummond Street, Starcross Street, Euston Street and Stephenson Way will not
be used for construction traffic.
(iii) Throughout the period of construction, direct access will be retained between
the mainline station and at Drummond Street. Access to Drummond Street from the
existing station will be signposted.
(iv) HS2 will promote marketing initiatives to retain the existing customer base from
the station and to attract new customers. Drummond Street will be promoted to
construction workers.
(v) There will be effective pest control measures.
(vi) Traders will be compensated by HS2 for any loss to their trade, particularly
through rent reductions. The Compensation Scheme upon which HS2 consulted last
year offered no effective compensation to these traders.
(vii) There will be a community benefit fund to ensure that traders are able to
survive ten years of disruption.
(viii) There will be access to free legal advice for all residents to enable them to make
an informed decision on the options available to them.
8.5 The Euston Forum seek the following further guarantees in respect of the new station:
(i) The existing traders in Drummond Street will be fully integrated into the new
station.
(ii) Cobourg Street will not be used as a taxi collection point. Taxi drop-off and
collection points should be incorporated within the existing station, preferably
underground.
(iii) Drummond Street will retain its existing character. Local traffic will be able to
circulate within the area, including via Cobourg Street.
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9. Mitigating the Impact on our Environment
9.1 In November 2012, HS2 first approached our Chair about identifying sound monitoring
locations. Our Chair pointed out that identifying points 150m, 250m and 500m from the
proposed track seemed inappropriate for an urban area. Further, it would be impossible to
find appropriate “fields” and “verges” within these locations upon which to place the
equipment. It was apparent that HS2 had failed to apply their minds to monitoring for noise
in an urban area such as Euston.
9.2 On 17 April 2013, HS2 wrote to local residents in the Camden Cutting area to carry out
sound and vibration surveys. A number of residents agreed to assist. Nothing further has
been heard.
9.3 We predict gridlock in the Euston area for a minimum of ten years whilst the new station
is constructed. A number of streets within the footprint of the new station are to be close,
which will displace traffic onto neighbouring residential streets. Bridges in Mornington
Street, Granby Terrace and Hampstead Road are to be demolished and rebuilt. For at least
two years, works will be executed on all three bridges concurrently. Whilst access will be
maintained over Hampstead Road, this will be restricted to one lane in each direction for a
period of at least five years (from the existing six lanes). The gridlock will be aggravated both
by the 250 – 375 construction vehicles accessing the area each day and the congestion
caused in the Camden Town area by the proposal for the HS1/HS2 link along the North
London Line. No acceptable mitigation measures are identified.
9.4 Once the new station is open, HS2 estimate that there will be an increase of more than
40% in the traffic flows in Park Village East, Mornington Street and Arlington Road. There
will be an increase in Hampstead Road and Eversholt Street of 20 to 39%.
9.5 This will lead to unacceptable levels of pollution both during the construction works and
after the station is opened. HS2 predict moderate or major adverse NO2 impacts at various
junctions in the Euston area. Annual mean NO2 levels on the Euston Road are more than
double the binding EU value limits. There is also a danger that the limit values for Particular
Matter could also be breached. Listed buildings are at risk. No mitigation measures are
identified to address this. This is wholly unacceptable.
9.6 The problems of pollution will be aggravated by the removal of a number of mature
trees, particularly in St James’ Gardens, but also along Hampstead Road. Open spaces will be
lost. No adequate mitigation measures are identified.
9.7 Most of the houses adjacent to the Camden Cutting are more than 170 years old and
have uncertain structural stability. Many sit on C19 century backfill and have subsidence and
movement issues that will be aggravated by HS2 construction. The vibration limits must
reflect this. Procedures for surveying and monitoring existing properties must be
straightforward and comprehensive.
9.8 Many houses, including the whole of Mornington Terrace, are listed. The Nash houses in
Park Village East are Grade II*. This may preclude the use of acoustic installation for
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mitigation. When the West Coast mainline was upgraded, financial compensation was
offered which enabled residents to vacate their properties during the worst disruption. HS2
should consider a similar approach.
9.9 The Euston Forum seeks the following guarantee:
(i) No pollution caused either as a result of the construction or the operation of the
new station will be permitted to exceed either domestic or binding EU limits.
(ii) Noise insulation will be provided, or temporary rehousing where required, well in
advance of construction. This should extend to all properties adjacent to the
proposed line.
(iii) All properties adjacent to the new line and station will be surveyed and assessed
for vulnerability to damage from vibration.
(iv) All properties adjacent to routes used for construction traffic will be similarly
surveyed and assessed.
(v) Traffic measures will be introduced to ensure that traffic is not displaced into our
quiet residential streets by the closure of Granby Terrace or the traffic restrictions on
Hampstead Road.
10. Mitigating the Impact of HS2 on Open Spaces, Community Facilities and our Heritage
10.1 Considerable damage is to be caused to our open spaces and community facilities.

St James’ Gardens will be closed for 10 years during the construction and only 25%
would be reinstated on the completion of the works. The site of the chapel will be
demolished. The burial ground was used for about one hundred years from the
1800s. Some 50,000 people are believed to have been buried in the area, of whom
some 35,000 within the footprint of the proposed new station. There are a number
of people of renown. We are advised by HS2 that both burial and ecclesiastical law
will be displaced by the hybrid bill. The park has a number of mature trees which
play an important role is absorbing some of the carbon emissions in the area. There
seems no reason why the 25% of the gardens which are not required for the new
station should be needed as a construction site.

The Hampstead Road open space will be lost permanently. Use of the Eskdale Open
Space and Euston Square Gardens will be lost for a minimum of 10 years.

The Maria Fidelis Lower School in North Gower Street will be forced to relocate. We
have heard nothing to reassure us that HS2 have adequately addressed this.

Hampstead Road Bridge will be rebuilt. The new bridge will be some 4 metres higher
than the existing bridge. It will be much wider than the existing bridge to
accommodate the additional lines. It is likely to act as a barrier dividing the
community in Mornington Terrace from that on the Regents Park Estate. This could
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be abated were the new line bordered by Granby Terrace, Barnby Street and Cartmel
to be decked over and grassed to restore lost open space.

The Silverdale Tenant’s Hall will be demolished. The Ampthill Square Tenant’s Hall
remains under threat – we note that it is still included in the Safeguarding Zone
confirmed on 9 July 2013.

The Bree Louise Public House in Cobourg Street will be demolished.

Insufficient regard has been given to our unique railway heritage which is
threatened.
10.2 Open spaces are in short supply in the area. These are an essential amenity. Trees,
particularly mature ones, absorb carbon emissions. As levels of overcrowding and housing
density increase, open space becomes an ever more vital amenity. In the second half of the
nineteenth century, St James’ Gardens was specifically purchased, along with other disused
burial grounds in Camden, to address the desperate need for open spaces in overcrowded
areas of Camden. It is not acceptable to take this away without replacement.
10.3 The original proposal for the Euston Station which was to be constructed below ground
level would have permitted a new urban development at ground level the size of 17 football
stadiums. This would have enabled new open spaces to be created. It would also have
enabled east/west access linking up Somers Town with Regents Park, two communities
which are currently divided by the existing station.
10.4 On 12 April, HS2 announced that the fine 1901 retaining wall in Park Village East is to
be demolished. The cutting is to be widened and the wall is then to be rebuilt, jutting out
over the new line. We understand that this work is considered necessary to enable trains to
travel at 95 km per hour as they come out of the Parkway Portal. We question whether the
design feature is required. It seems most unlikely that trains will travel at this speed such a
short distance before their arrival at Euston Station. If this wall is to be rebuilt, it must be
reinstated with brick facia, using materials, finishing and design as at present. It offers the
opportunity to move the wall further to the east, improving the environment in Park Village
East. The new track below could be covered over to create additional open space and
reduce the impact of noise. Any securing fencing should be constructed inside the cutting
wall.
10.5 Today, we learnt that HS2 now also plan to demolish the retaining wall in the centre of
the existing mainline tracks in front of Nos. 117-125 Parkway. This will increase the noise
nuisance faced by residents both during the construction period and once the new line is
open. Every day, we seem to hear more bad news. What we never hear is positive
measures of mitigation measures to re-assure residents that there is a future for them in the
area.
10.7 The Mornington Street Bridge with its listed piers is to be removed and rebuilt. A
temporary bridge over the Cutting is to be provided. We agree that it should be restricted to
pedestrian, cycle and emergency access. Otherwise, there is a danger that it will be used as
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a rat run, given the disruption that will be caused to traffic by the reduced carriageways on
Hampstead Road, the closure of Granby Terrace and Park Village East. We would urge HS2
to consider the option of reinstating the bridge that existed in the C19 between Mornington
Place and Park Village East, to provide not merely temporary access, but also a permanent
route for pedestrians and cyclists. There should be a dedicated cycle route.
10.8 The draft Environmental Statement offers no adequate mitigation measures. The
Euston Forum seeks the following guarantees in respect of our local community:
(i) There will be no loss of open spaces – both in the short term and once the new
station has been constructed. Areas of the new line should be decked over and
grassed to restore lost open space.
(ii) The Silverdale Tenants Hall will be replaced before construction works
commence. A refuge is required for residents seeking to escape from the nuisance
created by the construction works.
(iii) Only that part of St James Gardens that is required for the new station will be
closed. The 25% that is not required should not be used as a construction site.
(iv) The proposal to reinstate the C19 bridge between Mornington Place and
Parkway will be appraised. This could provide both a temporary and permanent
point of access across the cutting. It should only provide access for pedestrians and
cyclists.
(v) If the Park Village East Retaining Wall is to be demolished and rebuild, the
opportunity should be taken to move the wall to the east, providing the opportunity
to enhance the local environment.
(vi) HS2 will deck over and grass the new line in front of Park Village East to improve
the local environment. A cycle route will be considered.
11. The Draft Code of Construction Practice (“CoCP”)
11.1 The measures outlined in the CoCP, although welcome, fall far short of what is
required. The extent, duration and level of disruption that HS2 building work will cause to
the Euston area are exceptional and require a package of measures tailored to meet the
specific needs of those who live or work in this community. Construction work may affect
part of the Euston area for up to 10 years. Some residents may face works 24 hours a day,
seven days a week. Mornington Bridge will be demolished and replaced by a temporary
structure. Granby Terrace will be closed. Traffic will be displaced by the closure of three
lanes on Hampstead road, leaving just one lane in each direction. Two tenant’s halls will be
demolished. Open spaces will be lost. Noise and air pollution will be increased.
11.2 The cumulative impacts are not assessed. HS2 must recognise that existing statutory
provision and British standards are not designed for a project that will blight the lives of
those who live or work in the area for a minimum of ten years. The limits for noise and
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vibration should be made more stringent, and the provisions for acoustic glazing and
rehousing set at a lower threshold.
11.3 Mitigation and Compensation go hand in hand. In Euston, some 2,000 people live
adjacent to the proposed line whether in Mornington Terrace, Park Village East, the
Cumberland Market Estate, the Regents Park Estate, the Ampthill Estate and in the
Drummond Street area. This is a vibrant, diverse and densely populated community.
Property values are high. Whilst many residents live adjacent to the existing West Coast
mainline, they have learnt to live with a level of background noise. The lines run below
street level, and residents are shielded by a fine Victorian retaining wall. The modest level of
background noise is more than offset by the great sense of space enjoyed by those living in
the area.
11.4 Were we to be living in a rural area, all the properties adjacent to the new line and
station would be included in the safeguarded zone entitling them to compensation under
the advance purchase and voluntary purchase schemes that were proposed last year.
Rather, HS2 continue to treat us with disdain:

On 12 April, HS2 informed residents that they now propose to demolish and rebuild
the retaining wall in Park Village East. The works are stated to take place over a 12
month period in 2017. Residents will have no vehicular access to their homes. They
are still excluded from the compensation scheme.

HS2 now propose to erect a “Berlin Wall” along the centre of Cobourg Street for a
period of 10 years. Those residents whose homes in Cobourg Street will remain, will
look out onto this for a period of ten years. The whole of Exmouth Mews is inflicted
with a double whammy: the construction of the new station to the east and a
construction site to the north. They are currently excluded from compensation. No
mitigation measures are proposed.
11.5 The cost of the works, the time required and the disruption to local residents would be
substantially reduced were Euston Station to be closed whilst the London terminus for HS2
was constructed. Old Oak Common could be used as the initial terminus for London. We are
concerned that this option has not been appraised.
11.6 There will be an inevitable tension between the need for Network Rail to maintain
existing services and the need to use best possible methods to reduce the nuisance caused
to local residents and business. We are concerned that Network Rail will exercise an
effective veto over Camden’s use of their powers under Section of the Control of Pollution
Act 1974. We seek an assurance that Camden LBC will be the final arbiter of “best possible
means” to minimise nuisance associated with the construction works.
11.7 Most of the activities taking place in the Euston area are exempted from the “core
working hours” because they involve works adjacent to live operational tracks, concrete
pours, piling, diaphragm wall works or tunnelling. This blanket exception is not acceptable.
HS2 must justify all works outside core working hours on a case by case basis.
11.8 We welcome the proposal for a small claims policy whereby minor claims of damage to
property caused through construction can be resolved without the usual lengthy insurance
18
claims or court processes. However, we suggest that the maximum level of £5,000 is much
too low given property values and repair costs in London. We rather suggest a figure of
£25,000.
11.9 The Euston Forum seeks the following guarantees:
(i) Noise and vibration limits will be set at a lower level to reflect the cumulative
impacts on those who live and work in the Euston area.
(ii) Camden LBC will be the final arbiter under Section 61 of the Control of Pollution
Act 1974 for all consents to measures for the control of noise and vibration in
connection with the construction works.
(iii) HS2 will justify, on a case by case basis, all work undertaken outside core working
hours.
(iv) Where works are necessary outside core working hours, HS2 will offer both
compensation and a range of mitigating measures.
(v) Particular measures will be devised for vulnerable residents, such as those who
are elderly, have families or are disabled.
(vi) Roads will only be used for construction traffic when it is not possible to use rail.
The same will apply to all excavated material and waste. Where it is not practical to
use rail, HS2 will offer both compensation and a range of mitigation measures to
residents and businesses who will be adversely affected. The Euston area cannot
cope with 250-375 construction vehicles per day.
(vii) No construction materials or waste will be transported at night.
(viii) The small claims level will be increased to £25,000
(ix) There will be a community benefit fund for local communities with the Euston
area to compensate them for the disruption to their daily lives.
11.10 The CoCP is general and often non-committal, leaving most of the important issues to
the Local Environmental Management Plans (“LEMPs”). As the LEMPs will not appear until
after the hybrid bill receives the Royal Assent, it is essential that key commitments are made
for the Euston area in the Environmental Statement which is to be tabled with the hybrid
bill.
12. Conclusions
12.1 On 17 March 2010, when Lord Adonis issued his first Remit Letter to HS2, the
estimated cost of £33bn for Phases 1 and 2 of HS2 was largely speculative. It was based on
the best estimate of what it would involve. It was also a decision that was politically driven,
rather than one based on a strict cost/benefit analysis3.
3
See Lord Mandelson, Financial Times (2.7.13).
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12.2 Over three years later, HS2 have still failed to make any accurate assessment of the
cost of bringing HS2 into a densely populated high value area such as Euston. Despite Lord
Adonis’ Remit Letter, HS2 have failed to devise proposals for the residents who will be
displaced, a station that will be able to cater for the increased number of passengers that
will use it, or a strategy to protect and promote our local businesses and amenities.
12.3 On 18 April 2013, HS2 reported to the Euston Forum that they were abandoning their
plans for a new station at Euston because they had underestimated the cost of the new
station4. We are now being consulted on a new cheapskate tack-on station which causes the
greatest damage in terms of loss of homes, jobs and businesses, a school, open spaces,
community facilities and a historic graveyard and offers the least in terms of community
regeneration. In effect, we are being required to pay the cost of HS2’s incompetence.
12.4 We are now being consulted on a flawed environmental consultation which signally
fails in its stated objective of identifying the mitigation measures proposed to abate the
damage that HS2 will cause to the Euston area. HS2 make no attempt to assess the cost of
either the damage that will be caused to the Euston area or of the measures to abate that
damage.
12.5 Mitigation and compensation go hand in hand. The necessary resources must also be
made available for both mitigation measures and compensation to ensure that no one in the
Euston area suffers significant loss in the national interest as a result of HS2. We estimate
the cost of compensation at £1bn with a further sum required for mitigation measures. HS2
have significantly underestimated the former, while they have yet to make any assessment
of the latter.
12.6 We understand that the next stage will be for HS2 to present an Environmental
Statement to Parliament. We expect HS2 to propose mitigation measures for the Euston
area to comply with the reasonable guarantees that we seek. It will then pass from HS2 to
Parliament to decide the extent to which HS2 should be required to comply with the
government’s stated objective that no one should suffer serious loss in the national interest
as a result of HS25. Those who live and work in the Euston area should not have to pay the
cost of this unwelcome project.
Robert Latham
Chair, HS2 Euston Community Forum
On behalf of the Community Groups represented on the Forum and the Regents Park
Ward Councillors
11 July 2013
(Robert Latham can be contacted on r.latham@doughtystreet.co.uk; 077366 70315 or 0207387 0565)
4
We were informed that they had underestimated the cost by “30-40%”. It is now apparent that they had
underestimated the cost by “67%” (the estimated cost increasing from £1.2bn to £2bn).
5
Philip Hammond, Secretary of State for Transport (20.12.10)
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