high speed rail committee - parliament.uk · ptal – public transport accessibility? 14. mr...

MINUTES OF ORAL EVIDENCE

taken before

HIGH SPEED RAIL COMMITTEE

On the

HIGH SPEED RAIL (LONDON – WEST MIDLANDS) BILL

Monday 15 June 2015 (Evening)

In Committee Room 5

PRESENT:

Mr Robert Syms (Chair) Mr Henry Bellingham

Mr Ian Mearns

_____________

IN ATTENDANCE

Timothy Mould QC, Lead Counsel, Department for Transport James Strachan QC, Counsel, Department for Transport

Timothy Straker QC, Counsel, London Borough of Hillingdon

Witnesses:

David Knowles, London Borough of Hillingdon Rajesh Alagh, London Borough of Hillingdon

_____________

IN PUBLIC SESSION

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INDEX

Subject Page

London Borough of Hillingdon (cont’d)

Mr Knowles, examined by Mr Straker 3

Mr Knowles, cross-examined by Mr Strachan 23

Mr Knowles, re-examined by Mr Straker 33

Mr Alagh, examined by Mr Straker 36

Mr Alagh, cross-examined by Mr Mould 49

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(at 6.31 p.m.)

1. CHAIR: Mr Straker.

2. MR STRAKER QC: Sir, I’m very grateful for the adjournment which occurred.

And as far as the assurance which has been offered, rather close it may be thought in

terms of the line as far as time is concerned, sir, the position is this: that it goes some

way but it doesn’t meet actually the character of the case that we’re presenting to you.

What it provides is a certain amount of modelling which can occur in relation to some

highway junctions with some possibility of works thereafter. But what it does enable

me, sir, to say particularly in the light of your remark earlier on is that I will be

travelling through this evidence, Mr Knowles’ evidence, in some of the slides at what I

will describe at very considerable speed.

3. CHAIR: Faster than we can drive through them.

4. MR STRAKER QC: Yes, and it will be, I suspect, faster than you could possibly

drive through a number of these junctions. Sir, can I then take us all then to 1066(3),

because it’s the middle request to which the assurances have spoken and to which it

goes some way, but not the entire way, of asking.

5. 1066(4) gives the context, and just so we can pick, it’s not shown here Old Oak

Common is the top of ‘H and F’, which is Hammersmith and Fulham, is that right?

6. MR KNOWLES: Yeah.

7. MR STRAKER QC: And we then see, if we can, 1066(5). 1066(5) is population

growth where you’re making the simple point about Hillingdon seeing a substantial

increase, the greatest in fact in London boroughs.


9. MR STRAKER QC: And that in context, please, 1066(6) and the growth which is

expected by 2041; once again you beat the rest of London.


11. MR STRAKER QC: 1066(7): car ownership. You come top as far as

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Greater London is concerned and the number of light commercial vehicles registered is

also the highest.


13. MR STRAKER QC: 1066(8): you do some comparative figures. And 1066(9):

PTAL – public transport accessibility?

14. MR KNOWLES: Correct, yes.

15. MR STRAKER QC: And here the point that you make is that you can see in

Hillingdon the white areas which represent a public transport which is effectively

non-existent.

16. MR KNOWLES: Correct.

17. MR STRAKER QC: We then see that for North London, 1066(10), the

importance of it and who it affects which there are recorded. And we see at 1066(11)

the public transport in London; the want of a train station at Harefield; the limitation on

bus services; and the north-south public transport being deficient, east-west being there.

Is that a feature throughout Hillingdon?

18. MR KNOWLES: It is indeed, yes.

19. CHAIR: It means the public transport you do have is more bus dependent?

20. MR KNOWLES: We have pretty good radial links but the north-south links are

pretty atrocious. But that’s not surprising that a lot of the public transport links radiate

out to the edge of London which is where we’re at.

21. MR STRAKER QC: And then looking at that slide please, left-hand side,

reference is made to Crossrail benefiting Hillingdon but the south of the Borough only.

Reference has earlier been made today, and we’ll come back to it no doubt, as to the

value or otherwise of Old Oak Common as a prospective station. How do you see that?

22. MR KNOWLES: I see it as of marginal benefit certainly to the people of North

Hillingdon. Basically one has to travel in to Old Oak Common, or currently to Euston,

and then basically come out again, if we’re predicated on the basis of HS2, back from

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where you started from really and then make your way on to Birmingham. There may

be other choices which are better than actually doing that.

23. CHAIR: Clearly the transport links might make a bit of difference but the

potential for development, offices and other things is quite substantial, so the impact

may be that people in Hillingdon may get some jobs there.

24. MR KNOWLES: Accepted, but I think, if I may, the point was that it’s been

suggested that transport links provided by HS2 out of London would be significant for

our residents. I think we would contend that going out of London, they are not as

creators as perhaps might be suggested.

25. MR MEARNS: To sum it up, as someone who uses public transport extensively

in your own area as well as when I’m in London, it seems to me that the benefits of Old

Oak Common will go to the areas where the tunnel is and it won’t be felt as well where

the tunnel isn’t. Would that be about right?

26. MR KNOWLES: Yeah, I mean we will not have many benefits because there are

no means to get onto the line other than going in.

27. MR MEARNS: Thank you.

28. MR STRAKER QC: Thank you very much. And then I think your next slide, and

the slide after that, 12, this continues that discussion in a sense, doesn’t it, because what

you’ve done here is look at potential local journeys, what you can do. So you’ve got on

the first one, using a journey planner, Northwood Station across to Terminal 1, 2 and 3

and how it takes one hour five by train; 28 by car.

29. MR KNOWLES: Correct, yes. So this is just by way of illustration the point that

we make that our north-south links are relatively poor; the east-west links are relatively

good. I came this morning from West Ruislip Station and as it happens I came on the

Central Line; I could have got to Stratford in less time than it would take me had I been

trying to cross the Borough north to south. I just used that as a point of illustration.

And it’s auditable because I’ve used TfL journey planner as a basis.

30. MR STRAKER QC: Thank you. And 13 is the same journey planner and here

you’re contemplating what might happen. So this is contemplating Old Oak Common

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being in existence.

31. MR KNOWLES: This is an attempt to illustrate what the journey might be like

for somebody coming from West Ruislip to Birmingham basically, assuming that it’s

going in the same destination. Obviously these things are open to interpretation but I

am a regular user of the mid-line to Birmingham, as it happens, and I’ll be planning my

journeys. As a resident of West Ruislip I, as I’m sure many other people in my area will

do, actually get to Watford and then go to Birmingham from there, and it tends to be an

easier journey: there are less changes, there’s less possibilities for disruption. And all

I’m trying to suggest is that, all things being equal and assuming both services are

maintained at the same level in the future, that may continue to be the choice.

32. MR STRAKER QC: And the Chiltern Railway also runs towards Birmingham?

33. MR KNOWLES: Yes.

34. MR STRAKER QC: Then 14: the bus network is shown; and you’ve already

given the character of the bus network and it may be that nothing further needs to be

said about that. The effects of unreliability, 15, are seen and no doubt we can all

contemplate circumstances of people being late for various appointments or whatever it

may be in consequence of unreliable transport.

35. MR KNOWLES: Yes, and obviously a corollary of this is if these services are

unreliable then the unfortunate consequence is more people will transfer to the car and

the other forms of transport and using the buses.

36. MR STRAKER QC: Then we have air quality in Hillingdon – 16, please – where

you draw attention to Heathrow; of course to the south of the Borough but the A40 also

is shown as high as far as deficiency in quality of the air is concerned.

37. MR KNOWLES: That’s correct. I mean, I don’t intend to draw out too much in

terms of air quality; it’s not my area of specialism. I think the Committee will hear

more separately about that. But I just think it’s useful to make a point that Heathrow is

the obvious element but also, as that diagram shows, the A40 does suffer from air

quality problems. The next slide, if I’m going ahead of myself, really just makes a more

graphic representation of the existing scenario around the busier section of Swakeleys

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Road which is the one that is perhaps of principal concern ultimately to us and the

Swakeleys Roundabout.

38. MR STRAKER QC: Swakeleys Roundabout, which is a principal source of

concern – yes, it is. And then we go on to number 18, please, you record there HS2

breaking the north / south connectivity.


40. MR STRAKER QC: And we can see ‘HS2’ marked up in blue above the A40 in

green.


42. MR STRAKER QC: With 1, 2 and 3 being some key points for you.

43. MR KNOWLES: Yes, those are links onto the A40 that we have: Swakeleys

roundabout, Hillingdon Circus and Polish War Memorial roundabout. So those are the

means by which our residents get on and off the A40.

44. MR STRAKER QC: And then number 19, please: the congestion hotspots.

45. MR KNOWLES: Yes, we have identified 30 sites across the Borough. This is

something that we’ve identified some years ago. In terms of the science behind it, I

suppose you could say that they are junctions where there’s more than 90% saturation

which is a technical term; but the point is that these are junctions which we say are

likely to be unreliable in terms of capacity. So we have been looking over time to see

what we can do to mitigate problems at those junctions.

46. MR STRAKER QC: And then we have number 20, please: the local road

network, an aerial view. And you have identified certain roads; I suspect we can pass

straight from that to 21 – key roads – where you’ve picked up some key roads and

you’ve shown the line of HS2. Just help the Committee, if you don’t mind for a

moment. We see the line of HS2 there; that’s obviously the surface route.


48. MR STRAKER QC: The problems that are connected with HS2 coming and

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putting itself there, do they repeat themselves if a tunnel came instead?

49. MR KNOWLES: No.

50. MR STRAKER QC: 22, please. We see where people are going, I think, here,

don’t we?

51. MR KNOWLES: This was an attempt to try and give the Committee some idea

about where people are going and coming from. It is a busy slide – I apologise for that

– but it tries to give you a bit of context to people going to Watford to the north; the

number of schools in the area; we have, I think, 65 primary schools with 18 secondary

schools and probably about 35% to 40% are in this area in the north.

52. I think it is also worth briefly mentioning, if I may, that there are two faith schools

in the area which have very wide catchments. They have buses laid on specifically for

them. One is Douay Martyrs, which is a Catholic school; the other one is Bishop

Ramsey which is a Church of England school. And they rely upon crossing the A40 and

the fact the route of HS2.

53. MR STRAKER QC: Thank you. Well then slides 23 through to 26 can be taken,

I think, at pace. We just turn them through because they’re describing various roads and

showing various roads and drawing out observations as to certain difficulties which

exist and persist, and we arrive at 27 where you give the text as to the roads affected by

HS2 alignment.

54. MR KNOWLES: Yes. I mean, the point of drawing these out is we must not

forget from our point of view that there are residents that are affected by displaced

traffic. Obviously a lot of the discussion and the primary concerns of HS2 Ltd has been

upon the managing of their own construction traffic, which is quite rightly part and

parcel of it. The fact of the matter is that there will be a lot of displacement of traffic in

open roads and these roads are amongst those that will be affected to some degree or

other. Whether it is traffic directly associated with HS2 Ltd – probably to a limited

extent. I mean, High Street, Ruislip and Berry Street we’re told might be used on

occasions where there are vehicles that can’t get underneath the Chiltern Railway

bridge. But I believe we have been told that’s the exception rather than the rule; the fact

of the matter is there may be some vehicles.

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55. And the other roads are the network: West End Road, which is the road that leads

from the West Ruislip Depot down to the A40. And obviously as traffic finds it’s hard

to get to the A40 via Breakspear Road South or Long Lane, inevitably local traffic will

try and find another route to get to the A40. It already looks quite busy. Our concern is

this will displace more onto those roads.

56. MR STRAKER QC: Then if we look on 28, you’re simply describing, I think,

what road capacity is.

57. MR KNOWLES: Yes. This is a somewhat dry subject but it’s trying to give some

flavour to what these types of road have capacity for. If one imagines the analogy of a

road being like a sponge filled with water, clearly it gets to a point where it becomes

super saturated and can’t carry anymore; and in road terms what happens is queues

suddenly grow, become enormous and the network becomes unreliable, which is what

we do find at peak times on this road network now. And that is one of the sources of

our concern.

58. MR STRAKER QC: The next slide I think describes various categories of road

types –

59. MR KNOWLES: It does.

60. MR STRAKER QC: – and how they vary from type to type in terms of what they

can carry.

61. MR KNOWLES: Yes. And I’ve tried to be reasonable and give a fair assumption

of a value that could be seen as the capacity for some of these roads – and one could

argue the detail and I suggest that it’s not in anyone’s interest for us to argue too much

about the detail – but about 1,100 vehicles per hour is the capacity for some of these

roads. And therefore if you add that up it’s something like 1,100 vehicles passing an

observer standing by the side of the road in an hour in one direction; 2,200 if you look at

both directions. And if you talk about a 12 hour day time period I think it works out at

something like 30,000. So this is the sort of the numbers that we would imagine at the

minute that these sorts of roads carry.

62. MR STRAKER QC: Very well. Well then we go on please to number 30: the

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road traffic at present. And you are there identifying the numbers.

63. MR KNOWLES: Yes, the numbers. And we could go for 900; we could go for

1,300. We could argue the toss but this is a tool that’s been devised by the Roads Task

Force which was tasked by the mayor to come up with means of dealing with the growth

of traffic in London that’s predicated over the coming period where by 2015 I

understand that the equivalent of the population of Birmingham will be added to

London’s population. So it’s often a well identified issue that there is growth that this is

a tool that’s been identified which we feel is worthy of being used to try and give us a

means to judge what is being predicated for our roads.

64. MR STRAKER QC: Thank you. And then number 31 please: road traffic at

present. You’ve got various roads here. ‘N-S’; I’m guessing north-south?

65. MR KNOWLES: Exactly, and all these numbers are taken from HS2 survey data

which was taken about this time last year, June 2014. We’ve looked at this data and I

see little point in arguing too much with the detail of the source data. All I would make

a point is that actually at this time, sort of mid-June, traffic is actually getting a bit

lighter because of all the things that happen with exams and school – traffic is reducing

to some extent with school leave. And we’ve noticed that our road traffic levels are

dropping slightly. But for the purposes of this discussion I think we accept the figures

that have been presented by HS2; they are done by an independent survey company and

I see no merit in disputing them.

66. MR STRAKER QC: And there you can see cars and HGVs just divided by the

slash.


68. MR STRAKER QC: And we go to 32 please – it’s similar at present but you’ve

looked at midweek values here by particular roads.

69. MR KNOWLES: Exactly, yeah. And not too surprising, the section of Swakeleys

Road which is the one nearest to Swakeleys Roundabout, the same section of road

where if you recall when we looked at the air quality was the issue where there already

were some issues of concern. It’s self-evident that you add the traffic coming from

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Harvil Road and you add the traffic coming from Breakspear Road South – you don’t

have to be a rocket scientist to work out that all that traffic, if it goes to the A40, comes

down that same little stub. And so this shows that at the moment those are very high

levels; and I can testify to that because I use it every day.

70. MR STRAKER QC: Then I think in graphic form, 33, please. That shows,

doesn’t it, in this chart type form.

71. MR KNOWLES: This shows what happens in two levels, one in 2014 and one in

2018. We have applied a growth factor called TEMPro, which I think HS2 Ltd would

probably have used themselves in some of their work, which means Trip End Model

Presentation Program. We love jargon. Basically it’s a tool for predicting growth. I do

note that in HS2’s own documentation they acknowledge the fact that there’s going to

be growth of a number of percent per annum in this section of road.

72. That red line across there is the 1,110 that I referred to earlier as the measure of

capacity. It shows that at peak times it already bumps over the top; it’s super-saturated;

even during the middle of the day it’s still quite high. The maroon bars which show

basically the higher figures that have just grown without the benefit of any HS2 traffic,

so that’s background traffic.

73. MR MEARNS: You’re talking about June last year being the survey date earlier

on.


75. MR MEARNS: Across the country though hasn’t there been a marginal increase

in overall traffic use which has been put down to reductions in fuel costs in that period?

76. MR KNOWLES: You’ve got me there, sir. I mean, I don’t know about the

impact on our residents. Fuel costs have fluctuated; they’ve actually down; probably the

volume of traffic may have gone up. I don’t have any actual evidence to support that.

It’s a fair comment.

77. MR MEARNS: I’ve just got in the back of my mind from about six weeks that

there had been some sort of traffic survey – possibly the AA or the RAC – which had

shown that overall traffic flows across the country had increased and they were putting

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it down to increased use of vehicles because of fuel cost decreases.

78. MR KNOWLES: It could be. I mean, one thing I would just say as a personal

observation – because, as I say, I am a local road user as well as somebody doing

numbers on a chart – I have noticed in the recent weeks that the levels of traffic seem to

be a little bit lighter than they were earlier in the year. But it’s futile to some extent to

try and play too much games with these. If we assume the basis of the numbers, the

numbers I think demonstrate that the roads are full up.

79. MR STRAKER QC: Very well. Well, 34 and 35 and 36 we can pass through

quickly, can’t we, because they are photographs of those roads which are itemised.

80. MR KNOWLES: Those are purely photographic examples taken by me, not me

personally using a phone I hesitate to add.

81. MR STRAKER QC: Hasten to add?

82. MR KNOWLES: Hasten to add, rather. I don’t wish to be fingered in terms of

the law. I’m sure that the Committee will hear further testimony from local residents.

83. MR MEARNS: Well, it’s obvious all those photographs were taken from the

passenger seat anyway.

84. MR KNOWLES: Yes, exactly.

85. MR STRAKER QC: Well then we’ve got Swakeleys Roundabout, 37, which is an

important feature of the A40.

86. MR KNOWLES: It is, and I acknowledge the fact that in the authorities given this

has been identified by HS2 as a mutual source of concern. The A40, Swakeleys

Roundabout, is where all of this traffic comes on and off. It regularly locks up. If you

imagine you’ve got a large amount of traffic in the morning coming in to London from

the M25 which is off to the left coming on the slip roads, up that sort of white bit going

off underneath where it says ‘to M25’. Traffic coming on there pours into the

roundabout and makes it difficult for traffic coming out of Swakeleys Road to come

down. Similar things happen on the other side where the traffic’s coming off the A40 in

the other direction. At times, the circulating traffic can actually run right the way

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around the roundabout so it is already a problem in our view.

87. I’d also make the point, because it’s on this plan if I may, that The Drive which

you’ll see is just shown at the top there is a private road. I believe that the residents of

that road did not petition in their own right but they are very concerned about the

amount of traffic that does divert via their road at peak times. Even we were surprised,

when we did a lot of detailed survey work, that at times in peak level traffic as much as

10 to 15% of traffic will divert via The Drive, and it’s all because of people trying to get

to the Swakeleys Roundabout by other means than Swakeleys Road itself.

88. So the issue for us is that this is an unsignalled roundabout which I think was

constructed about 30 years ago. One small thing: actually the road goes underneath the

pink circle and that’s my limitations of graphics, I’m afraid – it’s just me doing this.

That’s what big maps make it look like; in fact the green should go underneath the pink,

so I apologise for that.

89. MR STRAKER QC: Well, let’s pass on because what we’ve done so far is look at

what the current position is.

90. MR KNOWLES: The current situation, yes.

91. MR STRAKER QC: And then you come, 38, to the impact of HS2 construction.

39, you identify various forms of modelling and I don’t want to trespass upon the

Committee’s time with going through those in terms of what they all signify; various

forms of highway modelling. And we then get to a number of quite intense slides, these

being material produced by HS2 – 40, please.

92. MR KNOWLES: Actually that’s one produced by us, as the council, as an early

response. The next slide – you’re quite right – is derived from a previous exhibition

pack from HS2 Ltd.

93. MR STRAKER QC: But what these slides show is where the consequences are

going to be felt of the surface level and viaduct proposal by HS2.

94. MR KNOWLES: They are indeed. In fact, there are six compounds show there.

There are obviously more compounds in the area but these are the six ones that are

redevelopment to the roads of concern to Hillingdon. From clockwise in the top-left is

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the Colne Valley Viaduct Satellite Compound; Breakspear Road South Underbridge

Satellite Compound; West Ruislip Portal Site Compound; Northolt Tunnel, that’s main

compound; Harvil Road Realignment Satellite Compound; and then last but not least the

Colne Valley Viaduct and South Embankment Satellite Compound / Ickenham

Autotransformer Feeder Stations Satellite Compound.

95. MR STRAKER QC: And would one get anything similar if one were building a

tunnel rather than HS2 as in the Hybrid Bill?

96. MR KNOWLES: Not in my belief. Obviously I am not a tunnelling expert.

There will need to be some compounds – I think there’s been discussion earlier on – but

not to this extent, I’m sure.

97. MR STRAKER QC: That was 41. 42, please.

98. MR KNOWLES: That’s what I’ve raised.

99. MR STRAKER QC: Very well. And then we get 43: you were giving some idea

of the duration of these various compounds. So I think we’ve got a range, haven’t we,

between 18 months and 10 years.

100. MR KNOWLES: Yes, and this is all from the evidence that’s been provided

previously by HS2 Ltd. So this is purely regurgitating, perhaps in a more digestible

form for the Committee, what these numbers looks like. And if you turn to the next

slide it’s just in a graphical form.

101. MR STRAKER QC: So one sees the length of time there; and the Tunnel

Earthworks Main Compound persists throughout the period of time.

102. MR KNOWLES: It does, yes.

103. MR STRAKER QC: And then you’ve got 45, a traffic slide from the exhibition

park; and the purpose of this slide, briefly put, is?

104. MR KNOWLES: It’s to talk about the little numbers on the right there. I mean,

all numbers are very interesting; they’re hard to read which is why I’ve actually

enlarged some of them on the following slides. Rather than taking the Committee ad

nauseam through every single road, we focus on the section which shows ‘G and H’,

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which is the section from Swakeleys Road, between Harvil Road and the A40.

105. MR STRAKER QC: So this gets us to 46 then?

106. MR KNOWLES: It does, indeed, yes.

107. MR STRAKER QC: And so G, Swakeleys Road, B467.


109. MR STRAKER QC: And we look at the cars increase and the HGV increase, this

is an attribution to HS2, is it?

110. MR KNOWLES: It is, indeed. I mean, this is HS2 construction traffic; it’s taken

from HS2’s own data.

111. MR STRAKER QC: So it’s 129% increase as far as HGVs are concerned?

112. MR KNOWLES: Yes and 87% in the other direction. As I say, that’s taken from

the other slide. Now, the point I would make here is that those figures – I have got

15,693 there and 15,131 – if one tries to take an assessment of the capacity of these

roads using that 1,110 figure, if you factor that up it’s 13,320 over a 12 hour period. So

that shows that from this information we are supercharging these roads with this

construction traffic. That’s the message that I’m taking from there.

113. MR STRAKER QC: And you contemplate what if you could reduce those by

15% in 47?

114. MR KNOWLES: I’m sure that HS2 responsibly will be looking to see how it can

reduce its reliance upon road construction and HGV traffic so I just took a 15%

reduction, and the point is that the numbers are still very high because we are building

upon a very high base. So even if you reduce the numbers – that’s not done with any

sort of science to assess that – by that percentage the number of saturation is still very

high.

115. MR STRAKER QC: 48, you make a comparison with HS2.

116. MR KNOWLES: This is with HS2 using the HS2 construction traffic figures.

Basically it’s a similar picture to what we had before. It’s our assessment of the impact

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on the traffic flows. It’s done on the basis of the limited information that we had about

distribution of HS2 timelines. We had very approximate indications of busy times and

less busy times so this is an indication; but it’s no surprise that this shows that the

numbers are significantly larger than even my earlier slides.

117. MR STRAKER QC: And then we’ve got on 49, you’ve done the exercise in

graphic form so as to show coloured the HGVs from HS2 and the cars and light goods

vehicles from HS2.

118. MR KNOWLES: Yes, this is again based upon our early efforts with the numbers

that were provided. I accept the fact that in the past few days HS2 did produce more

traffic slides with more information which may put a slightly different complexion on

this, but I think what is telling is that the background growth, which are the mid-blue

and maroon coloured sections of the bar, are growing and show that they are making an

existing matter of concern worse.

119. MR STRAKER QC: Then 50 please: you ask the question about reassignment –

‘where will it go?’. In other words, traffic which gets fed up waiting, can it find

somewhere else to go somewhere?

120. MR KNOWLES: Well, the question here is there’s been a lot of talk – and this is

standard traffic engineering talk when one’s working with models and we’ve been

working with these things like the Weller model and up and down the country I’m sure

that other models are being used in a similar tone – and there’s a lot of talk about

reassignment; but that’s obviously assuming that there’s somewhere else for the traffic

to reassign to. There are no alternatives to Harvil Road, Breakspear Road, South

Ickenham Road and West End Road as I’ve described. So it’s not a case of all the

traffic that goes down one road will suddenly find another corridor to go down; there

aren’t many corridors for them to go. And what tends to happen at the moment – and

I’ve highlighted some roads, Copthall Road West, The Drive, Woodstock Drive – lots of

these roads are local roads that are well known to our residents and they’re already

vulnerable to ramp running. And our concern, which is shared by our residents, is that

in fact that latch running as an indirect consequence of this extra traffic will simply

increase. And I think I’ve mentioned earlier on, West End Road there will be traffic

impacts indirect on that. And I’ve just quoted a statement there from HS2 which is a

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reasonable statement which says, ‘We will work actively with relevant local and

highway authorities. The final decision over which roads are eventually used as a lorry

route will therefore generally be subject to local authority approval.’ I mean, that’s a

reasonable statement to make. There isn’t an answer at the other end of that question.

The question is where will these other roads be and we do not see the roads easily

identifiable where this traffic will go. So we work from the implication behind that but

we don’t see what the answer necessarily is.

121. CHAIR: Given the way the bar is developed, presumably if there were an easy

scheme putting in additional road capacity presumably you’d have already been to the

Department of Transport here.

122. MR KNOWLES: Well, you also need to look at the context of where we are in

Greater London. Major road building in Greater London has not really happened in the

past few years. We have to comply with all sorts, the London plan – we have to stand as

we are, within the aegis of GLA and TfL. The last major road that we built in

Hillingdon probably was 20 or 25 years ago. Clearly if we were talking about bypasses

or things like that, they open up a whole raft of other questions. There’s been talk about

them but, you know, just as HS2 are finding difficulties in getting a consensus on

building a railway the difficulty of the consensus of building the bypass through a mixed

urban and rural area would be no less difficult. And I think, perhaps unfortunately, the

time that is available that’s predicated by this whole project, we don’t have any bypasses

in our back pocket if that’s your question.

123. CHAIR: There are one or two communities further up the line that are managing

to do that.


125. CHAIR: And this would be if you had some bright ideas it would be a brilliant

time to go to the Department of Transport and say ‘we’d like this scheme to do x, y and

z’. But I know it’s not simple.

126. MR KNOWLES: It isn’t and I have listened to some of the presentations and

there were some very eloquent presentations from Northamptonshire, places like that,

where they in their back pocket had ideas for bypasses or for junction improvements and

18

things which this could accelerate. Unfortunately we don’t have anything quite like

that.

127. MR STRAKER QC: Thank you very much. Thank you, sir. Number 51, please:

traffic cost implications. And here I’d just like to touch on this for a moment please,

bearing in mind the previous witness was concerned with people getting about the place

and being impeded from getting about the place and therefore there was a cost which

was incurred even though it may not be capable of measurement.

128. MR KNOWLES: Yes. I mean, Mr Cringle spoke at some length about all

unquantified costs and clearly there are cost implications to traffic in general. There

will be cost implications for any project that is predicated on the use of construction

traffic on roads. I suppose the issue for us to make sure that ultimately we arrive at the

situation with the minimum impact.

129. MR STRAKER QC: Thank you. Then we switch track a little, do we, because

then we go to footways, right of ways and bridleways and the impact of HS2 on those.

And for that you see at 53 a line of HS2 cutting across various lines which you’ve drawn

on the plan being byways, footpaths and other –

130. MR KNOWLES: Yes, exactly. And obviously the Committee will have heard

previously from people who are passionate about their footpaths and their rights of way

and you will hear further, I’m sure, from other people on the same subject. The fact of

the matter is these paths serve many purposes. They are not simply a matter of

commuting from A to B; they are a facility that is valued by people for recreational use.

And clearly we need to be concerned with the impact of closures or diversions on

whether they will continue to be attractive for their primary purpose which is for people

to use for recreational purposes. Did you wish to elude to…?

131. MR STRAKER QC: Well, if we go to 1066.54, please, next one. We can see

there that you identify a footpath which is closed, some footpaths which will be lost –

Crossfields to the Grand Union Canal circular walk – and then local walking

connectivity to Ickenham and West Drayton Station would disappear.


19

133. MR STRAKER QC: You were talking a moment ago it’s not only people to-ing

and fro-ing to work and so forth but other categories of walkers; but that would appear a

matter of walking to the station to work?

134. MR KNOWLES: Well, it’s a combination. These things are used for a

combination of things clearly. Sometimes they’re used for schoolchildren may be

walking to school; walking to the station. There are some paths near West Ruislip

Station which are used by local people to get to and from the station. I would use them

if I was going to West Ruislip Station. Clearly there has been some dialogue, I

understand, about some of the implications so there has been recognition, I believe,

about the impact of some of the diversions that have been proposed to the public rights

of way.

135. MR STRAKER QC: But you record here none would happen with a tunnel.

136. MR KNOWLES: Yes, that’s my argument. It’s one of the many things that, in

our view, would not happen with a tunnel. Or if there is something that requires a

diversion we think it would be far less than the current promoted scheme.

137. MR STRAKER QC: Then we look at 55, please – 1066(55).

138. MR KNOWLES: Lots of pretty pictures which try and give a flavour for what

we’re talking about in terms of these paths. I suggest you don’t necessarily need to

linger too long but just to show that this is why people value these things: that they are

attractive leisure walks, to walk the dog or to bide their time enjoying the outdoors.

139. MR STRAKER QC: And plainly HS2 have come up with some suggested

diversions or alterations to routes to maintain them. And if we look at 56 we see one

such suggestion I think.

140. MR KNOWLES: Well, this is something that has been covered by a letter of

assurance, to a degree, that the Council has received on 11 June. When we first looked

at the proposals one of the routes was going to be diverted onto Breakspear Road South

where there are no footpaths. Clearly I would imagine that our colleagues at HS2 have

recognised the folly of that notion. So in the letter of assurance there has been

discussion about the construction of temporary walkways along the side of the road

20

which is a welcome recognition of a problem. All I would make at this point as an

observation is that I would be very interested to know how those would be created and

constructed in a way that makes them attractive for people to use. If their purpose is for

recreational use, the idea of walking on an elevated walkway constructed over a ditch

alongside a busy road with many HGVs passing alongside it, I think we could argue

whether that is going to be an attractive feature. But I think there has been recognition

that there was an issue.

141. MR STRAKER QC: Thank you. Then we get 57 please: footpaths facing

diversion or closure. Once again we’ve got that nothing like this would happen with a

tunnel. And we see the various footpaths facing diversion or closure.

142. MR KNOWLES: Little red circles, just for your information, this was taken as a

snapshot from a promotional leaflet for the walk and they’re just attractions along the

way. There’s nothing more sinister than that.

143. MR STRAKER QC: Very well. And then we go to a bridleway facing diversion

or closure at 58.

144. MR KNOWLES: Yeah. Something which is popular with local horse riders. It

links Breakspear Road South and New Years Green Lane. I think it may be one of the

ones that’s affected by the assurances. But clearly these are things we don’t want to

lose.

145. MR STRAKER QC: Thank you. And cycling we then come to on 59.

146. MR KNOWLES: Yes. I don’t wish to seem alarmist because clearly putting the

blame for cyclist deaths at a single construction project would be totally unreasonable,

but a number of fatalities have hit the headlines associated, in some cases, even with

Crossrail. There have been at least two reported in the media which were involved with

contractors working on behalf of Crossrail. I’m sure that the contractors were signed up

to all of the most high level of standards and codes of construction practice, all the

things one would expect. I’m sure the lorry drivers were all FORS accredited and

everything else. All I would make the point is that by simply increasing significantly

the numbers of HGV traffic on these roads, which are being used more by cyclists than

they were previously, there is inherently a risk; and I think it would be wrong of us to

21

ignore that fact.

147. MR STRAKER QC: Page 60 continues to refer to cycling: you’ve sought to

promote it.

148. MR KNOWLES: Yeah, we’ve sought to promote it. So we do a lot of training.

We do adult cycling training which is available to our residents. We also work with

businesses. We do an awful lot of work. We’ve got a university which we’ve worked

with the mayor to try and make a cycle university, if you like, rather like one would

imagine Oxford or Cambridge. So we’re doing an awful lot of work behind the scenes

to encourage responsible and safe use of cycling. If you were to go to West Ruislip

Station this morning there’s 17 cycle stands there; all of them were double counted with

cycles. So, in other words, the number of cyclists is growing. Each time we add more

cycle stands at stations they become used up.

149. So my point here is to say that we obviously wish to promote cycling and getting

people out of cars as much as we can. So we need to be concerned about the impact

indirect. We’ve talked about delivery time slots. You know, this is driver pressure it

could be that they’re held up in traffic queues. There are all manner of factors that

could be brought to bear. Potential for driver error. And if we’re talking about a

10 year intensive construction project the likelihood of serious cyclist injury is

heightened, and I don’t think anyone could really argue with that. I’m sure there would

be all sorts of arguments about mitigation of that by proper construction plans.

150. MR STRAKER QC: Then you mention route planning to avoid interactions with

cyclists is difficult on construction projects.


152. MR STRAKER QC: And 61 shows key cycling concerns where you’ve identified

some particular places.

153. MR KNOWLES: Yes, and I think rather than taking the Committee through this

line by line I’ll just make the point that at the top right there is a picture outside West

Ruislip Station where you’ll see those cycle stands I referred to all well used.

154. MR STRAKER QC: And you observe that none of it would happen with a tunnel.

22

155. MR KNOWLES: No.

156. MR STRAKER QC: And then you pose and ask the question: how will cyclists

cope with HS2 construction traffic. 62 takes us back, by flashback perhaps, to 56 which

is the Breakspear Road. And you’ve simply imposed upon that.

157. MR KNOWLES: Now, this could seem to be alarmist because clearly this

situation doesn’t happen every second, but what we do have to acknowledge is that an

increase in the construction traffic means that the likelihood of HGVs reaching each

other is significantly increased. If the figure is 1,000 per day, it’s something like one

every 43 seconds or something like that. So clearly the likelihood of this happening is

already noticeable, that anyone who cycles along this road, pauses as construction traffic

tries to get past, I just make the graphic point that HGVs are large vehicles; the roads

that we’re dealing with are really country roads that are being expected to deal with

over-levels of traffic.

158. MR STRAKER QC: Thank you. And then we come at the end to 64: your

requests which start with a tunnel to remove most of the traffic footway and related

disruption already described. And that language to remove ‘most of the traffic’, does

that contemplate that even with a tunnel you would have some traffic?

159. MR KNOWLES: Yes. You know, we have to be realistic that with any project in

an area which involves some construction work there’ll be some construction traffic.

The argument really is to what extent that will manifest itself; how heavy will that

traffic be and where will it go? But our contention is that a tunnel will result in far less

traffic.

160. MR STRAKER QC: Thank you. And then you mention the other ones which I

don’t think we need to go through, including the request for support and investment in

improving north-south public transport links but they would still have to use the existing

road network which we’ve seen.


162. MR STRAKER QC: And I think therefore that concludes your evidence-in-chief.

Thank you very much. Thank you, sir.

23

163. CHAIR: Well done.

164. MR KNOWLES: Thank you.

165. CHAIR: You went speedily through that. At some point we’re going to have a

division as the Minister is on his feet. If the bells ring I will adjourn for 15 minutes and

there are subsequent divisions for subsequent times. Mr Strachan.

166. MR STRACHAN QC (DfT): Yeah, I’ve just got a few questions, Mr Knowles.

Can we just go back please to A1066(3)? And this is where you started, Mr Knowles,

and you explained that your principal ask is for a tunnel to be extended under the

Colne Valley. We see that in the first bullet point.

167. MR KNOWLES: We do indeed and that’s really aligned with all the evidence

that’s been heard.

168. MR STRACHAN QC (DfT): And what you’ve described, and the reason why

you seek that, is because of what you say would be the construction effects of the

scheme as currently proposed.

169. MR KNOWLES: Exactly.

170. MR STRACHAN QC (DfT): So it’s all about construction activity.

171. MR KNOWLES: From my perspective there are many other aspects clearly to

this.

172. MR STRACHAN QC (DfT): I understand that; I’m only asking about what

you’ve been saying.

173. MR KNOWLES: That’s fine.

174. MR STRACHAN QC (DfT): And just looking at the other two asks, the

construction logistics plan and support of an investment in north-south public transport

links, so far as construction logistics plans and assessments, that’s the subject of the

assurance that you were looking at a short while ago.

175. MR KNOWLES: The assurance that has been delivered to us today really talks –

I don’t have a copy of it to hand here – about junction modelling on some of those

24

busiest junctions, which is something that we have asked for; in fact if you look at my

ask at the end they’re slightly different from the one at the beginning. So we welcome

the fact that that is to be done. All I would caveat that welcome with is to say that we

feel, with respect, it’s something that should have been done earlier because the use of

the strategic model, which we again respect, as a starting point does not deliver as

clearly as has been recognised by this assurance letter the detailed modelling of the

junctions themselves. So this is an important step which has been suggested and we

welcome the fact that this step has been acknowledged as being required. Where I

would perhaps have a note of caution from the council’s perspective is we remain to be

convinced that even that step, as welcome as it is, will deliver a magical solution at the

end.

176. MR STRACHAN QC (DfT): I’m not going to get drawn into what modelling has

been done already. Leave that by the side. That’s very helpful to explain your position

on the second and third items. So really we come back to this principal case that you’re

putting forward that the tunnel is requested because of the construction effects of the

scheme.


178. MR STRACHAN QC (DfT): And it’s fair to say, isn’t it, that in order to make

that request you would need to compare the construction effects of the scheme with the

construction effects of the Colne Valley Tunnel proposal that your council is putting

forward.

179. MR KNOWLES: Self-evidently, yes.

180. MR STRACHAN QC (DfT): And just to be clear, we’ve been through your slides

– there isn’t such comparison that you’ve put forward, is there?

181. MR KNOWLES: No, because I am not a consultant who’s been engaged to do

that type of work. I am, in fact, working on behalf of the local authority and my

principal concern has been to share with the Committee our concerns about the existing

traffic situation and how we feel that whatever is imposed upon it will cause problems

for our network.

25

182. MR STRACHAN QC (DfT): I understand, Mr Knowles, but the simple position

is that whether the scheme is built as currently proposed or, as you would ask, in a

tunnel, there will be construction effects in Hillingdon and inevitably one would have to

compare the two.

183. MR KNOWLES: Absolutely agree with you on that. If I may just add to that, it’s

just to say that clearly then the discussion will be what are the levels of those traffic

impacts.

184. MR STRACHAN QC (DfT): Yes, that’s what I’m going to come to now because,

as I said, you haven’t put forward those levels but we have, but we’ll come to that in a

moment. Can we just deal with A1066(49) which you showed the Committee a little

while ago? And can we just agree – and I’ll take you to a slide in a moment,

Mr Knowles –

185. MR KNOWLES: I’m sure you’re going to take me to it.

186. MR STRACHAN QC (DfT): Yes, exactly. What you’re showing here is an

assumption that the levels of traffic on Swakeleys Road at their peak period of activity

continue for some seven or eight years. That’s what you’re showing.

187. MR KNOWLES: You’re broadly correct. What we looked at is where your

compounds switch on and switch off and we’ve taken a fairly worst case scenario

because in the absence of any information that we had of anything better we had to take

the worst case scenario.

188. MR STRACHAN QC (DfT): We can agree very quickly, can’t we, Mr Knowles,

that that’s not what’s proposed by way of traffic effects in this area, is it?

189. MR KNOWLES: Well, I would be very pleased to see the convincing argument

that you’re putting forward to actually show, based upon the detail, of actually where

your traffic flows vary. I’ve done this on the basis of information that was available to

me within the capacity available to me. I’m sure you will bring forward your own

compelling reasons.

190. MR STRACHAN QC (DfT): Well, let’s just look at it rather than take the time

about whether you had the information before.

26

191. MR KNOWLES: Okay.

192. MR STRACHAN QC (DfT): P6223.

193. MR KNOWLES: Yes, your histogram.

194. MR STRACHAN QC (DfT): Yeah, so we’re all looking at the same point. We’re

looking at Swakeleys Road, G and H, which is the point you’ve flagged up a moment

ago. This is all information derived from the environmental statements with now the

additional provision proposed, APT. So there’s a reduction in traffic but broadly

speaking it’s translating activity at these various compounds into levels of traffic at

particular points in time, isn’t it?

195. MR KNOWLES: It is. I mean, just one comment, and it may be you can answer

this question for me, but this histogram has five compounds on it; I thought there were

six. Unless your sixth compound is regarded as not relevant to this.

196. MR STRACHAN QC (DfT): Well, I don’t know which one you think is missing

but certainly one of the ones, Northolt Tunnel and Earthworks Main Compound –

197. MR KNOWLES: Colne Valley Viaducts Satellite Compound; number 1 on the

HS2 slide.

198. MR STRACHAN QC (DfT): Right, well I’ll ask Mr Smart to deal with that.


200. MR STRACHAN QC (DfT): But can we just stick with the main principal of

what this shows?


202. MR STRACHAN QC (DfT): Again, this is taken from information you can get

from the ES, but just going back to the slide you showed a moment ago, what one gets

from this is that there is a peak period of activity of nine months approximately when

those traffic levels peak at that high point here. I’m just pointing on the slide.


27

204. MR STRACHAN QC (DfT): On Swakeleys Road.

205. MR KNOWLES: Yes, indeed.

206. MR STRACHAN QC (DfT): And that is when the earthworks are being brought

in to construct the trace. At the Northolt Tunnel and Earthworks Main Compound

they’re coming in in order to carry out works before the railhead has been constructed

after which more material can be taken off site, avoiding the roads.


208. CHAIR: Presumably when you construct the construction compounds as well

there’s more heavy traffic initially.

209. MR STRACHAN QC (DfT): Yes, there is some traffic associated with that. I’ll

come back to that in a moment, if I may, sir, because that’s quite an important point.

But that peak period of activity we see is approximately nine months.

210. MR KNOWLES: Right.

211. MR STRACHAN QC (DfT): And then it drops off into what I call ‘Phase 2’, and

I’ll explain that in a moment. Phase 3 it starts to drop off and then Phase 4, which is a

longer period, it’s dropped off to 200 vehicles movements which is 100 each way,

which is effectively when the cement is being brought in for the casting of the segments.


213. MR STRACHAN QC (DfT): And then one starts with the tunnel fit out.

214. MR KNOWLES: Yeah, okay.

215. MR STRACHAN QC (DfT): Okay? So can I just show you P62091? You’ve

probably seen these slides but just to give you a bit more flavour; and I hope this

answers your question, sir, as well because this gives you an idea of what’s going on.

Some illustrative phasing.

216. CHAIR: I’m trying to think what I was told in March before everything blew up.

217. MR STRACHAN QC (DfT): These are some further illustrations of the point.

28

218. CHAIR: The point was made earlier that traffic off the roundabout, there’d be lots

of heavy goods vehicles to start with at the beginning of the project –

219. MR STRACHAN QC (DfT): Certainly.

220. CHAIR: – and then it would stabilise, as you’re saying.

221. MR STRACHAN QC (DfT): Yes, that is certainly right. This tries to illustrate in

diagram form what’s in the histogram. But you can see here – I’m going to call this

‘Phase 1’ which we saw in the histogram a moment ago – Phase 1 is about 18 months,

you can see with the red phasing in year 1 and 2. And this is when the sites are being

set up. And you can see, if you can just zoom in on this box here, Swakeleys Road.

Swakeleys Road G and H point is 80 vehicles each way, HGVs. Do you see where I’m

pointing?

222. MR KNOWLES: I can see where you’re pointing, but I can’t actually see them.

My eyesight is not that good.

223. MR STRACHAN QC (DfT): Okay, it is 80 northbound and 80 southbound.


225. MR STRACHAN QC (DfT): I’m sure we can zoom in there. Which translates to

30 on Harvil Road, 30 on Breakspear Road South and 20 on the High Road.


227. MR STRACHAN QC (DfT): So this is when the sites are being set up and it’s a

period of 18 months. And if we go to P62092, once the sites are set up we see that peak

period of activity occur. Phase 2 we recall from the histogram, and if we could just

again zoom in onto Swakeleys Road. With the reduction in traffic through the

additional provision we see 530 HGVs on Swakeleys Road each way.

228. MR KNOWLES: That’s per day.

229. MR STRACHAN QC (DfT): Per day, yes.

230. MR KNOWLES: It’s 500 each way so it’s 1,000.

29

231. MR STRACHAN QC (DfT): Exactly. And that splits into Harvil Road,

Breakspear Road and Swakeleys Road but most of it is going along Harvil Road. And

that’s a period of nine months – that’s the spike I was talking about – that’s a period of

nine months where earthworks is being brought in to construct the trace. And then

Phase 3, the next slide, the traffic immediately drops off after that nine month period

when the sites have been established. Sorry, it’s taking a while to load. And we can see

it’s back down to 200 HGVs in Phase 3 each way.


233. MR STRACHAN QC (DfT): And that’s another period of nine months. And

then, just to complete the picture, if we go to Phase 4 and 5 because those are the

longest periods of construction but the lightest in HGV traffic.

234. MR KNOWLES: Yeah. Phases 4 and 5, yeah?

235. MR STRACHAN QC (DfT): Yeah. Phase 4 is three years, so now the site is set

up, it’s operating and material – the tunnelling is going on but traffic is now reduced

along Harvil Road to just 100 HGVs each way during the day. On Breakspear Road

South it’s gone down to zero, and High Road, Ickenham it’s gone down to zero. So you

have those two nine month periods and then for a period of three years while the tunnel

is being constructed you go down to this level of HGV traffic. And then at the final

phase, which is an important phase because it’s fitting out the railway, Phase 5… We

may have to come back to it.

236. CHAIR: Order, order. Adjourn for 15 minutes at least.

Sitting suspended

On resuming—

237. CHAIR: Order, order. Mr Strachan?

238. MR STRACHAN QC (DfT): Thank you very much. I was just taking you

through, Mr Knowles. We did Phase 4 a moment ago, which was the three year period.

And then we were turning to Phase 5, and I’m just showing you the slide. Phase 5 is

four years when the tunnel fit out and commissioning is taking place from the railhead

that’s being created in the Harvil Road area. I’m just showing you where the railhead is

30

over here. It’s a system-wide fit out. A period of four years. And the HGV traffic has

dropped to 20 HGVs each way per day on Harvil Road and Swakeleys Road, zero on

Breakspear Road and zero on the Swakeleys Road/High Road Ickenham. Do you see

that?

239. MR KNOWLES: I accept that’s printed on your plan, yes.

240. MR STRACHAN QC (DfT): Yes. And so just comparing that level of activity

and remembering as we looked at, that the nine month period in Phase 2 when there’s

that peak period of traffic activity, which is what you were concerned about, just doing

the part of the comparisons that you haven’t done, if we take up P6222(2), so, this is our

assessment of a Colne Valley tunnel. And you’ll recall, Mr Mould asking questions of

Mr Blaine as to where the Colne Valley tunnel would have its railhead for systems fit

out. And Mr Blaine said he hadn’t got one yet. But, the only feasible option that we can

see a is a railhead in the same location to fit out the tunnel. And if it is in that location,

you have the same construction activity peak periods. G to H, which is not very clear if

you just scan. G and H, they’re approximately 680. I don’t know if you can make it

out. But, 680 on G and H, in order to construct the railhead to fit out the tunnel for your

proposal.

241. MR KNOWLES: This for the railhead turn out cavern? Is it?

242. MR STRACHAN QC (DfT): No. Over here.


244. MR STRACHAN QC (DfT): This is a Northolt tunnel and earth works main

compound, which is being used to construct, you’ll see the whole tunnel, the whole

route and tunnel here. This is our interpretation of the only way you could make your

Colne Valley tunnel proposal work in practice.


246. MR STRACHAN QC (DfT): I say that because we’ve done the assessment. I’m

not saying this critically, but I’m just pointing out, you haven’t done an assessment. Mr

Blaine hasn’t had identified how he would carry out the tunnel fit out, as you heard

earlier, but, it needs to be done, obviously.

31

247. MR KNOWLES: I would accept.

248. MR STRACHAN QC (DfT): And if it’s done in this way, you have no

improvement, if that’s the right word, over the peak period of construction activity. It’s

going to happen in the proposed scheme as it would with the scheme you’re suggesting

by the way of a Colne Valley tunnel.

249. MR KNOWLES: On the assumption, which again I’m not an expert in

tunnelling, but, on the assumption obviously that this is required. You stated that in

your opinion it is. I’m not qualified to know if it is or isn’t.

250. MR STRACHAN QC (DfT): We’re putting forward evidence as to how you

might do it. The alternative which was raised I think was using the TFL depot. And

Mr Blaine agreed that if you would do that, of course, you have to construct the TFL

depot in the same way as you would the Harvil Road depot. You have to bring in, using

HGVs, to construct it before any railhead is created. Do you recall that?

251. MR KNOWLES: I do recall that. I can only imagine there are magnitudes of

construction involved in one of the other which may or may not be comparable. I’m not

in a position.

252. MR STRACHAN QC (DfT): Yes. The simple point though, Mr Knowles, is if

one did that then one would be accessing the TFL depot from precisely the same road

network which you’re concerned about, although it would be on the West End Road.


254. MR STRACHAN QC (DfT): Which in fact in your exhibit is a worse road for

traffic congestion. It gets a red hot spot. That’s right, isn’t it, Mr. Knowles?


256. MR STRACHAN QC (DfT): So, if you were to use the TFL depot, you would be

transferring the same traffic problem but on to a more congested system of roads,

raising the same issues that you’re raising about this proposal.

257. MR KNOWLES: Based upon what you’ve said, yes. Clearly, I don’t know what

the duration or the extent of that other traffic disruption on the West End Road would

32

be.

258. MR STRACHAN QC (DfT): Can I just get you to revisit the answers you gave to

the committee earlier? When you said: with a tunnel, one doesn’t get any of the

construction traffic disruption that you were talking about. We can see that is not

correct. With the tunnel option you’re proposing, one would have either the same or

worse construction traffic affects from constructing a tunnel in this location.

259. MR KNOWLES: There would be, based upon what you’ve said, some impacts.

Again, I’m not really.

260. MR STRACHAN QC (DfT): Yes. I say equivalent or worse because we’re

looking at 680 on this proposal, or transferring the problem to the West End Road.

261. MR KNOWLES: Again, predicated on the basis that this is the option that has to

be delivered. Yes.

262. MR STRACHAN QC (DfT): And can I very quickly, you referred to footpaths.

There is an assurance letter which you kindly referred to.


264. MR STRACHAN QC (DfT): Which has dealt with a lot of the footpath issues

you raise. But, the same point applies to footpaths, doesn’t it? There would be an

interruption, temporary interruption of certain footpaths with our scheme as with a

tunnel scheme, as you can see from what I’m showing on the screen at the moment. If

you had to construct the Harvil Road railhead, you will have interference with footpaths

and equally, if you did it over at TFL depot, there’ll be a temporary construction effects

with the footpaths. So, it’s a neutral point.


266. MR STRACHAN QC (DfT): You can accept, there will be, obviously,

interruption from construction affects on footpaths which have been mitigated in the

way we suggest, in the assurance, but, it is not cured by your Colne Valley tunnel

proposal, is it?

267. MR KNOWLES: On the basis of what you’ve shown here, then, it would appear

33

not.

268. MR STRACHAN QC (DfT): Thank you very much.

269. CHAIR: Okay.

270. MR STRAKER QC: Thank you very much. If I can, can we just take that

sequence, please? And can we first start where Mr Strachan’s started, with Phase 2 on

6223, please? Because he was saying, well, we’ve got this peak, and then we’ve got the

position we make of comparison with the tunnel. So, we’ve got the peak at 6223 and

your attention was drawn to that at 6223 and it’s a Phase 2, is that right?

271. MR KNOWLES: That’s correct, yes.

272. MR STRAKER QC: Within the sequence of construction proposed for the at

surface and viaduct.


274. MR STRAKER QC: Can we then go to where Phase 2 is applicable? Where we

need to see whether or not that would be something which would be repeated or occur if

one is building a tunnel? Phase two being the peak. And for this purpose we go to

6210. There in the timeline one sees Phase 2, so ones aligned the peak with what it is

which is happening. There’s the Phase 2. Can we see what it is which is happening and

then I’d invite your view as to whether or not that would happen if one was building a

tunnel? If we look up, it describes on this plan what is taking place. And we’ve got a

exercise whereby we can see Breakspear Road South and then works above that,

Breakspear Road and river pin works. Are those works of embanking?

275. MR KNOWLES: It would appear so, yes.

276. MR STRAKER QC: And then one travels across and sees that there are works, in

construction of the three Harvil Road bridges in process, one has roads to cross. One

also looks up, one’s got sustainable placement.


278. MR STRAKER QC: Now, is any of that happening if one is building the tunnel?

34

279. MR KNOWLES: I assume not because unless there is some requirement for this

turn out that is referred to. But, no, there is nothing equivalent in terms of sustainable

placement or anything like that.

280. MR STRAKER QC: Oh, well, that was the foundation of the questions put. And

can we just look then finally, and this little sequence which we can take briefly at 6222?

When we have Harvil Road as a sites shown. We also have another site shown over

here, Ruislip. And, I’m not sure whether you will here earlier on when there was

discussion about these matters and the views of Transport for London?


282. MR STRAKER QC: As to what one is carrying from Ruislip?


284. MR STRAKER QC: And if one doesn’t need Harvil Road at all and is simply

working from Ruislip, the foundation of the questions that were put to you as to the

volume of traffic, are they affected?

285. MR KNOWLES: I would think so, yes. I’ve not really had a chance to assess

this in great detail.

286. MR STRAKER QC: Very well.

287. MR KNOWLES: It would appear to me that the volumes of traffic involved in

this project, I would imagine, are far less in terms of the construction, the movement of

material, basically, at the early stages of the project. It would appear to me that there’s

an order of magnitude difference between what is proposed under the promoter’s

scheme for the construction work opposite West Ruislip portal and the work to prepare

the site adjacent to depot.

288. MR STRAKER QC: That order of magnitude difference, a suggestion was made

to you that there would be more for the tunnel. Help the committee, please, as to which

way the order of magnitude difference goes.

289. MR KNOWLES: Oh, I think it would be significantly less for the tunnel.

35

290. MR STRAKER QC: Thank you. Now, then, the other matter just to touch upon,

is rights of way. First of all, as far as rights of way are concerned, during the

operational period of the HS2, at surface and on viaduct, will there be continuing effects

upon rights of way?

291. MR KNOWLES: On which scheme? The promoter scheme?

292. MR STRAKER QC: The promoter scheme.

293. MR KNOWLES: Yes, there will be operational effects upon the public rights of

way, which is why, I am sure, that there’s been letters of assurance has been received

that the efforts will be made to mitigate or reduce these.

294. MR STRAKER QC: And would there be any need to mitigate or reduce them in

the tunnel scheme?

295. MR KNOWLES: On the basis of my assessment to date, no.

296. MR STRAKER QC: And in the construction scheme, we saw earlier a picture

where we have a number of construction bases scattered around. Help the committee is

to once again an order of magnitude effect on rights of way as between the tunnel

scheme and the HS2 scheme, please.

297. MR KNOWLES: Well, clearly, there are six compounds that were predicated on

the promoter’s scheme, which have massive effects in places like Harefield, as well as

Ickenham and in Ruislip. And clearly, this is a more contained, more focused impact

upon, presumably, far less rights of way than otherwise would have been the case.

298. MR STRAKER QC: Thank you very much. Thank you very much, sir.

299. CHAIR: Okay. Mr Knowles, you’ve been a transport officer, you live in the area,

if there was a magic, elegant solution, I presume you would have fallen out of bed in the

middle of the night and found it already.

300. MR KNOWLES: Absolutely, sir. Yes.

301. CHAIR: If the promoter are right and the peak of traffic is at the beginning of the

scheme, then it would seem to me that any modelling that was done to at least offset

36

that would need to be done early enough for changes to junctions before the scheme

starts.


303. CHAIR: Okay.

304. MR KNOWLES: Yes. And if I may just continue briefly on that point is that

clearly we’d like some assurance that modelling work, if they are serious, further

decisions to be made on the basis of that, that that’s something that we would like to be

considered, obviously.

305. CHAIR: Okay. Alright.

306. MR KNOWLES: Thank you very much, sir.

307. CHAIR: Thank you very much, Mr Knowles. Thank you very much for also

whizzing through your presentation.

308. MR STRAKER QC: Sir, I hope it was a whiz, but, I hope it wasn’t too fast.

309. CHAIR: No, no. It wasn’t too fast. As I say, we’ve sat in the traffic there.

310. MR STRAKER QC: Sir, I’m sure you’re not alone in that experience.

311. CHAIR: Right. Can we have your next witness?

312. MR STRAKER QC: Yes, sir. So, this will be Mr Alagh, sir, whose slides – can I

first ask, please, that we put up A1067(2), where you ask the question, which I suppose

one often asks of oneself, who one is? And you’ve answered that, I think, in the

preceding slide, but, perhaps you can just help us on that particular question.

313. MR ALAGH: First of all, a very good evening to all of you.

314. CHAIR: Good evening.

315. MR ALAGH: My name is Rajesh Alagh. I am the London Borough of

Hillingdon’s solicitor, a position which I’ve held since February 2000.

316. MR STRAKER QC: Thank you. And you’ve been involved in this scheme for

37

some time, I think? Carry on.

317. MR ALAGH: Yes, that’s correct. I’ve involved since around September 2012.

One of my principal lawyers had the care and conduct of high speed two and she

decided to get pregnant and went on maternity leave, so, I took over.

318. MR STRAKER QC: Thank you. And then if we go to 1067(3), please? We can

see that as you’ve described it, you wear, or Hillingdon wear, a number of different hats,

a significant land owner in its own right, and the focus is, on your evidence, is on the

position of Hillingdon as a landowner.

319. MR ALAGH: That’s correct. As you’ll be aware, local authorities are creatures

of statute and we have a number of express statutory functions which are bestowed upon

us by Parliament. So, we are, for example a local planning authority, a local housing

authority, a flood and water authority, and for the purposes of my evidence this evening,

we are a social services authority, an educational authority and also a provider of

recreational sports and leisure facilities, as well.

320. MR BELLINGHAM: What’s the value of your Council’s land portfolio? Is it

valued in your accounts? The total landholding?

321. MR ALAGH: I haven’t got an exact figure. But, it is a very, very significant

landowner in its own right. And I will be touching upon certain areas within Hillingdon

which the lands fall within the Council function.

322. MR BELLINGHAM: Of course.

323. MR MEARNS: I bet the Borough trade revenue was what the value of the land

holding is.

324. MR ALAGH: Yes, it runs into millions if not billions of pounds. Very, very

significant.

325. MR STRAKER QC: Thank you. And then if we go on, please, to the request that

you’re making of the committee and the principal request which is there recorded,

1067(4)?

326. MR ALAGH: Yes. The principal request is for the high speed railway to be

38

constructed in tunnel through Ickenham and the Colne Valley. You’ve heard evidence

from Peter Brett Associates and from Regeneris and I fully support and endorse that

evidence.

327. MR STRAKER QC: Thank you very much. And the next slide, five, 1067(5),

you tell us, I think, how the London Borough is configured.

328. MR ALAGH: Yes.

329. MR STRAKER QC: And we can see there the size of it. The second largest. I

think the biggest is Bromley.

330. MR ALAGH: That’s correct.

331. MR STRAKER QC: And you’ve got just under 5,000 hectares of greenbelt land,

which of course is protected. You’ve got 676 open spaces covering 3409 hectares. And

you’re the most significant provider of open space in London.

332. MR ALAGH: That is correct. Yes.

333. MR STRAKER QC: And we look on please, to HOAC, number six, 1067(6),

where the committee have visited. And we remember that HOAC is petitioning in its

own right.

334. MR ALAGH: Yes.

335. MR STRAKER QC: But, as you recall, I think, your Council is the freehold

owner.

336. MR ALAGH: That is correct, yes. We are the freehold owner of the land.

337. MR STRAKER QC: And we’ve got next, 1067(7), the construction boundaries

of HOAC, where one can see, can one, on the slide, the area where the activities are

directed from, in the middle. And then the red colouring is that the construction works

and the impact of them described in that way?

338. MR ALAGH: That’s correct. And the line going through the middle of the map

is the proposed viaduct.

39

339. MR STRAKER QC: And I think you’ve been concerned, haven’t you, with talks

and discussions about HOAC ever since you’ve been concerned with HS2?

340. MR ALAGH: That is correct, yes.

341. MR STRAKER QC: Can we then go to eight please, and I would like you to take

us through, please, the matters identified in this because as you indicated earlier the

London Borough of Hillingdon is the authority for social services, the authority for

education services, the authority for a number of other matters.

342. MR ALAGH: Yes. Well, I think first of all it’s important to understand what sort

of a organisation HOAC is. It is a registered outdoor and environmental youth

educational charity and it’s been operating in this form since 1992. The London

Borough of Hillingdon has granted a lease to HOAC and it works in partnership with

HOAC. It does in fact give it a grant on a yearly basis to allow it to function in its

current form. I think it’s also important to note that HOAC serves the whole of the

West London community and it focuses on disadvantaged and disabled youth. And in

fact special needs provision is a very fundamental and integral part of HOAC’s

activities. More than 22,000 people per annum visit HOAC. Not just within the

Borough itself, but, also from across the whole of London. And HOAC provides both

land and water-based facilities. You’d have seen the land facilities when you visited

and at Harefield No 2 lake, it’s a 45 acre lake, and there’s a lot of water-based activities,

principally sailing, which take place on that particular lake.

343. CHAIR: Can I ask a question?

344. MR ALAGH: Yes.

345. CHAIR: Does the water-based activities and the land-based activities all have to

be in the same place? I know there are advantages in that, but.

346. MR ALAGH: Yes. We have discussed the possibility of split sites in the past but

we think that’s unviable because if you have land-based activities at one site and water-

based activities at another site, set a question of transporting children from one site to

the other. A lot of children come to HOAC during the day. They come by coach. And

particularly, if they’re travelling during their lunch hour, it’s very difficult to transport

40

them.

347. CHAIR: They do both?

348. MR ALAGH: Yes.

349. CHAIR: They might sail and then they might go and play.

350. MR ALAGH: Yes. And it would be very cumbersome to transport them from one

site to another. So, it’s best to have it all in one.

351. MR STRAKER QC: Thank you. And so that touches upon, does it, where we see

on the top of the slide, your compromised position, as far as you obligation as education

authority and your obligations as social services authority?

352. MR ALAGH: Yes. That is correct. I mean HOAC is a very, very valuable

educational facility, as I’ve already said. It’s accessed by many, many young people

and it’s also there for the benefit of disadvantaged youth, as well. So, it also fulfils a

very important social services function. The other aspect of the Council’s statutory

duties which I need to touch upon is its duty as a provider of recreational and sports and

leisure facilities and it fulfils the function very much so in the case of HOAC.

353. MR STRAKER QC: Thank you. And you also touch here upon your duties

under the Equality Act and Special Needs provision.

354. MR ALAGH: Yes.

355. MR STRAKER QC: And you refer to the issue of loss of rental income but,

putting that as a secondary consideration.

356. MR ALAGH: Yes. It’s very easy for me to come here today and sort of talk

about the fact that the Council is going to be deprived of its land. I mean, there are

compensation packages available to deal with that, but the most important

consideration, as far as I’m concerned, is the fact that the Council will be compromised

in terms of its ability to provide important statutory functions. We have many

important duties under the Equality Act 2010 and because there is robust system of

special needs provision at HOAC our ability to fulfil our duties under the Equality Act

will also be compromised.

41

357. MR MEARNS: Would I be right in thinking HOAC’s extensively used by people

from outside of Hillingdon as well.

358. MR ALAGH: It is used by people outside of Hillingdon as well, yes. It’s used

across the whole of West London. Yes. It’s a very unique facility. There’s none other

like it.

359. MR STRAKER QC: Well, I think we can probably move to the next slide. The

last two items on that slide indicate discussions on a suitable alternative for location for

HOAC, which none has been identified or provided. Then number nine please?

1067(9).

360. MR ALAGH: Yes. There are three particular requests in this slide. The

principal request is obviously for the tunnel. But, if the committee is not minded to

grant that request, we have three other requests which are set out on the slide. And I’ll

read those out. Firstly, the promoters provide all necessary assistance for alternative

location for HOAC and to meet any improvement costs. Secondly, that the promoters

take all reasonable steps to enhance the environmental value of other areas in line with

the CIC master plan. And thirdly, if HOAC closes and had no alternative location can

be found, the promoters make a contribution to LBH for the opportunity cost associated

with the loss of HOAC in the London Borough of Hillingdon.

361. MR STRAKER QC: Thank you very much. And then if we go to number 10

please. We move to the golf courses where the London Borough happens to own

Uxbridge and Ruislip Golf Courses. And the golf course construction boundary is

noted, and Uxbridge Golf Course can no longer continue as a competition course.

362. MR ALAGH: Yes. I think it’s important to set the context for Uxbridge Golf

Course and indeed Ruislip Golf Course. Both golf courses were managed externally by

an operative who went into liquidation in 2010 and since then the Council has itself

taken over the running of both golf courses. As far as Uxbridge Golf Course is

concerned, it has been configured as an 18 hole golf course, but it is important for me to

draw to the committee’s attention the fact that it’s currently operating only as 12 hole

golf course because there are some pipeline works, which have gone through the golf

course, which has restricted the number of playable holes.

42

363. MR STRAKER QC: Thank you. Well, then we see number 11, 1067(11). The

red area gives the construction works touching upon the Uxbridge course. And I’m not

sure there’s anything particular to draw out from this, is there, other than one can see

where it goes. The holes as they are presently recorded.

364. MR ALAGH: Yes. The holes that are most obviously effected on that map are

the second, third and fourth hole. But, the fifth hole will also be unplayable. And it is

proposed that the national grid pylon is located in the vicinity of the third and fourth

hole. So, that whole area will be a construction site.

365. MR STRAKER QC: Thank you. And then the potential area affected to the

south, this is also the Uxbridge course, is it, the next slide, 12?

366. MR ALAGH: Indeed. And the red line there shows the power supply works for

the tunnel boring machines. We have had an assurance from High Speed 2 Ltd. It came

last week on 10 June. They gave us an assurance that they would do everything possible

to minimise the impact of these works on the golf course and also that they would

reinstate any footways or footpaths which cross Uxbridge Golf Course, and that

assurance, I can tell you, is acceptable to the Council.

367. MR STRAKER QC: And then we have the next slide, 13, please? You recall,

well, Uxbridge presently operates five holes significantly affected. You then have, we

can pass, I suspect, through these quite quickly, 14 and 15, photographs of the second

hole.

368. MR ALAGH: Yes.

369. MR STRAKER QC: And the 14, is then the third hole.

370. MR ALAGH: That’s correct.

371. MR STRAKER QC: 1067(15).

372. MR ALAGH: Yes.

373. MR STRAKER QC: And we then come to Ruislip, do we?

374. MR ALAGH: We do.

43

375. MR STRAKER QC: Which is number 16. Once again a significant impact on a

course.

376. MR ALAGH: Yes. West Ruislip Golf Course is absolutely adjacent to where the

portal will be constructed. It is an 18 hole golf course. It’s a very flat course. And it’s

fair to say that High Speed 2 Ltd have commissioned a consultant to look at the re-

design of this golf course. We were served with the consultant’s report on 22 May. So,

we’ve not really had sufficient time in which to consider it. Essentially, it sets out four

options going forward. The first is for a 14 hole golf course. The second is for an 18

hole golf course, but, with much smaller area of land. The third is for a nine hole golf

course and a six hole academy course. And finally, a nine hole golf course with a nine

hole academy course. And the cost of these works is estimated at around 2.7 million

pounds. We’ve not had time, as I said, to consider the implications of that report fully.

377. MR STRAKER QC: Thank you. Well, then we go to 10678(18), where we see

the first hole at Ruislip, and 19, where we see the second hole at Ruislip. And then in

respect of both golf courses at 20 you have some observations to make.

378. MR ALAGH: Yes, I do. In respect of both golf clubs, we expect that members

and season ticket holders will leave. And we’re already seeing a pattern of that. We do

get a significant revenue income from both golf courses so there will be an impact on

land. There are lack of other golfing facilities in the Borough as well. The nearest golf

course is at Haste Hill. But, that’s also going to be affected by HGV High Speed 2

construction traffic. And golf is very much a social sport and people are used to playing

on particular courses so it’s not just a case of go and find somewhere else, you know.

These are valuable facilities which will be lost to the residents of the Borough.

379. MR STRAKER QC: Thank you. And at the foot of that slide you mention the

Ruislip Rifle Club.

380. MR ALAGH: I do, yes. The Council doesn’t actually own Ruislip Rifle Club.

It’s co-located with the golf course. It’s privately owned. But, that will also have to

close as well. And the other point which I’d just like to make on this slide as well, just

going back to the Council’s statutory duties, it will be compromised in its ability to

fulfil its statutory duties to provide leisure and recreational facilities.

44

381. MR STRAKER QC: Thank you. And then we have slide 21 please? 1067(21).

382. MR ALAGH: Yes. Again, our principal ask is for a tunnel. If that is not granted,

there are three particular request which I’d like to make to this committee on behalf of

the Council. The first one is a redesign of the courses to the satisfaction of the Council

and the golf clubs. The second is for the promoters to re-evaluate the need for a

construction route through Uxbridge Golf Course and work with LBH meaningfully to

assess the feasibility of using existing nearby construction routes to the east. And then,

finally, if the facilities are forced to close, the promoters fully compensate the Council

and the clubs and make a substantial contribution to the Council to be ring-fenced for

use in the Borough.

383. MR STRAKER QC: Then we move to 22, please? And we move from the world

of golf to the world of agriculture. And this is the loss of agricultural land, because you

own some farmland as well.

384. MR ALAGH: We do. We own extensive farmland. Park Lodge Farm, which is

part of approximately 240 hectares of farmland in Colne Valley. The tenants of Park

Lodge Farm, Mr and Mrs Howie, will be petitioning in their own right to this

committee too. But, the Council, as landowner, also has significant concerns about the

effects of high speed 2.

385. MR STRAKER QC: And then we look at the next slide, number 23, please? We

see the farm boundary edged red, I think, do we?

386. MR ALAGH: We do. Yes.

387. MR STRAKER QC: And we also see contaminated land within the farm, marked

yellow?

388. MR ALAGH: Yes. That’s right.

389. MR STRAKER QC: And land where HS2 want to dump, marked green.

390. MR ALAGH: No. The land affected by high speed 2 is coloured green.

391. MR STRAKER QC: Ah, right.

45

392. MR ALAGH: The proposal to dump soil is hatched green.

393. MR STRAKER QC: Hatched green. I beg your pardon. And would you wish

that to happen, I mean, just in the ordinary course of events, would you want that to

happen? That land build up.

394. MR ALAGH: No. Not at all, no.

395. MR STRAKER QC: Now, 24, please? The next slide?

396. MR ALAGH: Yes.

397. MR STRAKER QC: So, if you can just take us through this one, please?

398. MR ALAGH: Yes. During the construction period approximately 87 hectares of

Park Lodge Farm will be used for sustainable placements, also known as dumping. And

that is the hatched green land which was shown on the previous slide. The net effect of

this will be that both Park Lodge Farm and Dews Farm will be forced to close. Dews

Farm, it is a much smaller farm within Park Lodge and members of the committee may

remember seeing Dews Farm, which is a privately owned building. It just sits outside

the entrance to HOAC. So, both of those areas will be forced to close. There will be

obviously a loss of rental income for the Council as well. And there is a real concern

about the use of this land for dumping and for building High Speed 2 and we would ask

the promoters to carry out a proper assessment of the implications of High Speed 2 on

the agricultural landowners.

399. MR STRAKER QC: And you mentioned this is agricultural land designated as

greenbelt under the Greenbelt Act of ‘38?

400. MR ALAGH: Yes. I mean we don’t actually have a separate planning policy on

agricultural land, per se. It is generally classified as greenbelt land. And because of the

prevalence of greenbelt land within the Council, it is governed by its own greenbelt

planning policies, both national and local.

401. MR STRAKER QC: And then we go through 25, please, where we see Dews Farm

Lane and a view southeast from Dews Farm Lane along approximately the HS2 route and

then we can pass from that to 26, Park Lodge Farm, Dews Farm, it’s headed, ‘View west

46

from Harvil Road.

402. MR ALAGH: Yes. I mean, there certainly captures a very, very small part of the

farm, but I just wanted to give the Committee a flavour or what it looks like.

403. MR STRAKER QC: Very well, well, let’s then pass on please to 27.

404. MR ALAGH: Yes, I mean, once again, I’m setting out my two requests in the

absence of agreement for a tunnel. The first is that the promoters commission detailed,

independent assessment of agricultural impacts of construction and the operation of

authorised works in the borough and that the sustainable agricultural uses be reinstated

wherever feasible, and then secondly, that the council be fully compensated, in its capacity

as landowner, for losses, and the promoters make contribution to the council for use in the

borough.

405. MR STRAKER QC: Then we move from agriculture to angling, 28. I think

Hillingdon’s licensed two fishing lakes at Denham quarry to the Harrow Angling Society.

406. MR ALAGH: Yes. I mean, the word ‘Harrow’ is a bit of a misnomer because it is

an angling society which is very much based in Hillingdon. We granted two licences to the

Society back in May 2012, and the licences are for a period of five years and are due to

expire in 2017. The two lakes in question are Harefield Number 1 and Harefield Number 2,

and you will recall that Harefield Number 2 is the HOAC lake.

407. MR STRAKER QC: And that’s shown on the next slide, 29 please, where Harefield

1 and Harefield 2, right hand side?

408. MR ALAGH: Yes, that’s correct. I think the Committee has already seen this slide

earlier today, but it is just a – just to demonstrate where the two lakes are located.

409. MR STRAKER QC: And then we can see in slide 30 –?

410. MR ALAGH: Yes, you can see Harefield Number 2 as it currently looks, and then

the second picture shows what it would look like with a viaduct.

411. MR STRAKER QC: And then we have 31, we have some pictures of Number 2.

412. MR ALAGH: Yes, we do.

47

413. MR STRAKER QC: And we can move over those, I suspect, at pace, to get to 32.

414. MR ALAGH: Yes. And again, just to reinforce, as with HOAC, the Society does

promote youth activities at the club. It promotes youth angling, and it also, as with HOAC,

obviously, not anglers, but it also accommodates people with disabilities, so again, the

concern is that the council would not only be unable to fulfil its statutory duty as a provider

of leisure and recreational facilities, but it would also be impacted in terms of its ability to

fulfil its statutory duties under the Equality Act 2010.

415. MR STRAKER QC: Thank you. And then we have 33, if the request for a tunnel is

refused, you’re seeking necessary assistance to secure alternative angling facilities for the

Society?

416. MR ALAGH: Yes, and again, these two requests do, to a large extent, mirror the

requests that I made in relation to HOAC; the first is that the promoters provide all necessary

assistance to secure suitable alternative angling facilities for the Society, and secondly if the

Society has to close and no suitable alternative angling facilities can be found, the promoters

make a contribution to the council for the opportunity cost associated with the permanent

loss of angling facilities in the borough.

417. MR STRAKER QC: And then, 34, you touch upon the question of noise; you refer

to how the Committee’s going to hear expert evidence, and Hillingdon will rely upon that as

part of the consortium of local authorities but you draw attention the fact that Ruislip Golf

Course, HOAC and Dews Farm will all be subjected to high noise levels.

418. MR ALAGH: Yes. I mean this part of my evidence was really taken from the

environment statement which was issued in November 2013, and there were suggestions in

the environmental statement that the noise levels in places like the golf course, Ruislip Golf

Course, HOAC and Dews Farm could be, the same as experienced at Heathrow Airport and

we are concerned about noise, and I didn’t want to waste the Committee’s time with that this

evening, because you will be hearing expert evidence from noise experts on a route-wide

basis, and Hillingdon has contributed to the cost of the commission of that expert, and it is

part of the consortium of local authorities who have commissioned the experts, so I just

wanted to make reference to it, but not to major on it this evening.

419. MR STRAKER QC: Thank you and then 35, slide 35 refers to the compulsory

48

acquisition of council owned land. You identify the relevant clauses of the bill and the land

occupied by HOAC, Ruislip and Uxbridge golf clubs, Park Lodge Farm and Harrow

Angling Society.

420. MR ALAGH: That’s correct yes.

421. MR STRAKER QC: I suspect we can then turn on, can’t we, to 36 as to the request

which is made, if the tunnel is refused, because if the tunnel is granted, and the request

becomes otiose.

422. MR ALAGH: Yes. Once again there are two requests, and I will read them out very

briefly. Firstly, that the Secretary of State is not to acquire or use permanently more council

land than required for timely and economic delivery of Phase 1 of High Speed 2, and

secondly that Secretary of State will hand back estate land to the landowner that has been

temporarily occupied, expeditiously after completion of the High Speed 2 works.

423. MR STRAKER QC: Thank you. And then we get to 37 I think, which deals with

Compulsory Acquisition by the Secretary of State, under Clause 47 of the Bill and you draw

attention to Camden giving evidence of this, but you request the clause to be removed,

suggesting that it’s duplicative, effectively, of Part 9 of the Town and Country Planning

Act?

424. MR ALAGH: Yes, that is right. I feel that it is an unnecessary provision because

the Town and Country Planning Act already adequately covers this particular area and in the

information paper produced by High Speed 2 Ltd, which I read, they did suggest that this

power could be used where the required land to be CPO’d falls within the boundaries of

more than one authority and what I’m saying is, there’s no suggestion or evidence that this

will happen in the case of Hillingdon, therefore, I think that the clause is redundant and

should be removed.

425. MR STRAKER QC: Then we come to 38, where you express a concern as to

capacity and resources.

426. MR ALAGH: Yes, I mean, I think this probably applies to a number of local

authorities who have petitioned before this Committee. We have a small core team of

officers, of which I’m one, who deal with High Speed 2. There’s going to be many, many

49

issues going forward, if our request for a tunnel is refused. I accept that if a tunnel through

Ickenham and the Colne Valley is granted by the Committee, there will still be much other

work to do, but it will be minimised, so my parting request or message to the Committee is

that a borough wide tunnel would solve many of the problems which we’re going to face in

Hillingdon.

427. MR STRAKER QC: Thank you, and we’ll leave over that matter of the full list until

tomorrow, if we may. Well, thank you very much for that, sir, and I’m sorry we took a bit

past the witching hour, which you described.

428. CHAIR: Do you want to cross-examine? If so, how long? Otherwise, we’ll wait till

tomorrow if it’s not too long because I –

429. MR MOULD QC (DfT): Can I try and do it in about 10 minutes?

430. CHAIR: Yes, I think – that would leave gentlemen able to do some productive work

tomorrow.

431. MR MOULD QC (DfT): Mr Alagh, I wonder if I could just turn briefly to HOAC.

That’s the Hillingdon Outdoor Activity Centre, I should say. In the papers – I don’t need to

go to it, its reference number is P6207, it’s a report that runs to a number of pages, is a

report that records the extensive work that the promoter has done thus far, seeking to find an

alternative location for the Hillingdon Outdoor Activity Centre to move to, in advance of the

commencement of the main construction works at its existing site.

432. MR ALAGH: Yes.

433. MR MOULD QC (DfT): And, I think, you’re aware, that although we have yet to

find that site, the promoter remains committed to continue with that exercise, and to seek to

do so in collaboration with yourself and other interested parties, including the Outdoor

Activity Centre itself. It’s not a completed exercise, is it?

434. MR ALAGH: Well, yes, it is, to a certain extent, because I think I am allowed to

make reference to a meeting which took place on 9 June, last Tuesday. It was a meeting

between HOAC and High Speed 2 Ltd. The council was also invited as freeholder owner of

the land, and I was the council’s representative, and essentially three alternative locations

have been proposed for HOAC. The first is Denham quarry, and we were told that’s not

50

viable because there has now been discussions with Bucks County Council; there are

problems with the planning permission there, and at the moment, it’s been deemed not to be

a suitable site.

435. The second was Broadwater Lake; there have been discussions about that, and this is

a site where Natural England and Wildlife Trust have an interest in, and they have told us

that it’s not viable because of the birds. There is a bird sanctuary there and they are not

prepared to let us interfere with it.

436. The third alternative was Troy Lake and there is a mansion there, and I understand

that High Speed 2 Ltd have tried to persuade the owner of the mansion to sell his house to

them and he’s not agreed to do that, so the three options that were put forward for alternative

location haven’t really gone anywhere.

437. There were two other proposals put forward. The first was that the construction

work at HOAC takes place whilst the site remains open and what would happen is, we’ve

currently got a 45 acre lake. That would be reduced to 35 acres and the intention would be

that the children and other users of the site would still be able to use the centre, and I

expressed some concerns about that, and so did the owners of HOAC, insomuch as there

would be health and safety considerations for visitors, and also, we think that a number of

people would actually be put off from visiting the site, it if was tantamount to effectively, a

building site.

438. The other proposal put forward was that we revisit the issue of Denham quarry.

There is a 25 acre lake which may be available and the proposal was that over a period of

time, it would be extended. But that would be over a period of 10 years, and HOAC would

be forced to close, because it wouldn’t coincide with the proposed closure of HOAC in April

2017.

439. So, yes, whilst High Speed 2 Ltd may be saying that there are other options for

HOAC, I have to say that I left that meeting feeling that the options on the table were not

viable.

440. MR MOULD QC (DfT): Right. That’s about seven of my 10 minutes.

441. MR MEARNS: When we visited HOAC as a Committee, I did talk to people there

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about the business planning process that they have, because they do rely on bookings from

education establishments, schools and local community interests etc, and the trouble is,

because of the uncertainty, they’re already seeing a drop off in future bookings, which is

going to have a problem in terms of their sustainability financially, because of that

uncertainty, so there are ongoing problems there.

442. MR MOULD QC (DfT): Well, we are doing what we have sought, over the past

year and a half, two years, to find a solution. As Mr Alagh has just said, we haven’t found it

yet, but we are not prepared to say that we’ve reached the end of the road in relation to that,

and I put on the screen a letter from the leader of Buckinghamshire County Council, which I

think the Chair received – it was written on 1 June – which, if we turn to the second page,

suggests that Buckinghamshire County Council is the freehold owner of the Denham quarry

site. They also don’t feel that we’ve reached the end of the road.

443. Mr Tett – if you look in the final paragraph, he suggests that we need to get on, but

he certainly doesn’t say that we’ve reached the end of the road with regard to Denham

quarry. And we’ve written back since then to say, ‘We would like continue talking to you,

as the freehold owner of Denham quarry, and other interested parties, to see whether there is

a way in which that site, for example, can be made to work’. So, you know, glass half-full

and glass half-empty, isn’t it? We’d like to be glass half-full about this, and to see if we can

carry on and not give up now, but let’s carry on whilst we have the time, to see whether we

can find a solution.

444. The reason why we’ve looked at – I’m sorry to answer your question directly, the

reason why we are looking at how far we can accommodate HOAC, whilst the works begin,

is because if we can, as the Chair put it, if we can, at least for a time, allow HOAC to

continue with the majority of its activities, in the early stages of the construction work, it

builds in a little more flexibility about getting a staged relocation to another site, which may

provide us with some help, if Denham quarry turns out to be a workable solution, when we

know that Denham is going to continue to be worked in some shape or form. Now, I say

that: I’m on the public record here, and all of this is work in progress, and there will be no

doubt there’ll be more challenges to come, but let’s not give up on this now and certainly,

our position is, we want to continue with that initiative.

445. MR MEARNS: Just as long as HS2, as the promoter, is cognisant of the fact that

52

HOAC as a going concern, is relying on ongoing bookings and economies of scale say that

they have a level at which they are sustainable, and a level at which they are not, so as long

as you’re cognisant of that.

446. MR MOULD QC (DfT): We’ve made a commitment already to HOAC, we’ve

given them an insurance which you’ll hear about in a couple of days’ time, in which we’ve

said that we will not displace them from their site in any event, until March 2017, so they’ve

got a guarantee there that they will continue to operate from that site, which should go some

way, at least, to meeting the concerns that you’ve just mentioned. We’re looking at the

moment to see whether we can extend that time, a little further, so as to give them a further

period, and to allow us a further period to work with them, to look to relocate them. But

make no mistake, we are committed to trying to find a solution to relocating HOAC within

the local area, if it can be achieved.

447. MR MEARNS: I accept that and that sounds like progress from our visit, because

when we visited there, I think they were being told that there was no certainty that they

could continue beyond summer 2016, I think.

448. MR MOULD QC (DfT): Yes, well there’s been some progress in that respect. I’m

conscious of the fact –

449. CHAIR: Mr Mould next question.

450. MR MOULD QC (DfT): Yes. Golf courses. Can you put up please P6275(2),

Uxbridge Golf course. Whilst it’s coming up, can I just ask you this? There it is, it speaks

for itself. Our objective in negotiation with the council is to seek to do what we reasonably

can to maintain a playable nine hole golf course at the Uxbridge Golf Course, during the

course of the HS2 construction works, which you said yourself, were essentially concerned

with some electricity pylon works. Shall we continue to pursue that as an objective?

451. MR ALAGH: Yes.

452. MR MOULD QC (DfT): Thank you. The next one is Ruislip Golf Course. I think

there was a site visit to that golf course last October, that’s right?

453. MR ALAGH: Yes.

53

454. MR MOULD QC (DfT): We provided a draft report from the expert that we have

retained to advise on finding solutions to the impact of the scheme on Ruislip Golf Course,

sent to you in March of this year. And then a final version of that report sent to you, as you

said, on 22 May?

455. MR ALAGH: Yes.

456. MR MOULD QC (DfT): One of the things we’re waiting for there is for you to

share with us the commercial aspects of that, so we can get a sense of what the likely costs

of accommodating that golf course through remodelling of the course and the residual

compensation that would be payable to you as the owner of that golf course would be. We

do await that information, and it would be helpful if you could tell the Committee that you

will help to share the commercial information with us; no doubt on a confidential basis, so

that we can pursue those negotiations.

457. MR ALAGH: Well I can tell the Committee but I have advised the head of service

responsible for the golf courses to share that information with High Speed 2 Ltd. As I said,

when I gave my evidence, we only received the report on 22 May; it’s dated 5 May, so that

rather begs the question why it took them three weeks to serve it on us. We received it on

22 May, it’s now 15 June. So we’ve had less than a month to consider the implications of

that report, and that’s something that we will be doing.

458. MR MOULD QC (DfT): Let’s not argue about that, let’s agree again that there’s

work in progress there, we can speak to each other, we can seek to, if we can, to find a

solution which works as well as it can for you, in relation to maintaining, on a permanent

basis, a golf course at Ruislip.

459. MR ALAGH: What I would like to say Mr Mould, I know this may not be a direct

question, but if option 4 is pursued in that consultant’s report, that is the provision of a nine

hole course, or a nine hold academy course, the cost of that is estimated at around

£2.7 million?

460. MR MOULD QC (DfT): Yes.

461. MR ALAGH: The discussions we’ve had with High Speed 2 Ltd suggest that the

council may have to pay a proportion of that sum. So what I would say to that, if that is true,

54

then that’s a further burden on the public purse. If a golf course facility is being taken away

from the council, then it should be provided to the council with no extra cost. The other

consideration is that the golf course will have to close for two years, so we will lose valuable

revenue during that two year period, so we await with interest, what High Speed 2 Ltd’s

proposals for compensation will be in that regard.

462. MR MOULD QC (DfT): That’s why we need to see some commercial figures from

you, so we can get a sense of what the likely disturbance compensation might be, for the

closure of that golf course for a temporary period, do you see?

463. MR ALAGH: Yes.

464. MR MOULD QC (DfT): Let’s not negotiate before the Committee, let’s agree that

we’ll pursue those matters –

465. MR ALAGH: I’m not negotiating.

466. MR MOULD QC (DfT): If necessary, we can report back. The Angling Society,

Harefield Lake, after construction of the railway, will have a viaduct going across it, but it

will remain in place as a valuable recreational resource, yes?

467. MR ALAGH: I don’t agree with that.

468. MR MOULD QC (DfT): Alright.

469. MR ALAGH: I think with the building of the viaduct, the lake Number 2 –

Harefield Lake Number 2, as we’ve already heard, will not be operational, the Angling

Society will not be able to function.

470. MR MOULD QC (DfT): Okay, final question, the agricultural – the issue of the

farm that you mentioned; already one of your witnesses has drawn attention today, to the

fact that we have given an assurance that we will not be deploying the main area of land

within the area of that farm holding for use for sustainable placement or, as you put it,

dumping. We’ve given you an assurance to that effect, haven’t we?

471. MR ALAGH: I believe so, yes.

472. MR MOULD QC (DfT): Thank you. Thank you very much.

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473. CHAIR: Mr Straker?

474. MR STRAKER QC: I know when not to re-examine, sir. I don’t wish to

re-examine, thank you very much. I might make some observations in due time over one or

two of the points which have been made.

475. CHAIR: Okay. Thank you very much gentlemen, I think we’ve gone as quickly as

probably we could, in the circumstances.

476. MR ALAGH: Thank you.

477. CHAIR: And we’ll see Hillingdon back tomorrow. Order, order.

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