HS2 must prove that their 'Euston Approaches' design is not dangerous
HS2 must prove that their 'Euston Approaches' design is not dangerous
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Latest: Sept. 22, 2020
No news may still be good news!
Having applied on 13 July to the Court of Appeal for permission to appeal the High Court’s decision against me of 5 June, we are still waiting to hear whether or not permission has been granted…Read more
"There is evidence that the proposed scheme poses a serious risk of loss of life and of causing great damage to properties in the area."
The enormous HS2 infrastructure project is threatening the safety and security of thousands of people, could damage historic buildings, and is literally shaking communities across the country to their foundation.
I'm taking legal action to force HS2 Ltd to hand over information about the impact of their activity on our community in North London.
The Judicial Review I and my solicitor will request will be to challenge the decision by HS2 Ltd not to provide me with sufficient information to allow me and my advisers to assess how the latest design for the HS2 railway will affect me and my Human Rights.
HS2 Ltd must be held to account and produce the information that has the potential to have such a negative effect on my community. So far I have taken them on myself but now I need your help. Please contribute now and share this page with your friends, family and on social media.
In March 2017, just after the HS2 bill had been passed, HS2 Ltd announced a major change to the design of the proposed HS2 railway as it comes through the Euston Approaches, just north of Euston station. Since that time I and others have been trying hard to get full details of this new design, so that we can assess its environmental effects and its effects on the stability our homes. The new design moves the HS2 tracks to a lower level, into three tunnels and a vast cavern. Instead of being restricted to the Camden Cutting, the new design covers a larger area, with two of the tunnels passing under the early 20th century Park Village East retaining wall and coming close below some of the Grade II* listed houses, part of John Nash's scheme for Regent's Park.
The change of design worries me particularly because I am old enough to remember a long period of repairs to the retaining wall carried out in the 1960s. I have also seen documents which confirm that the wall had had to undergo fundamental repairs as early as 1920.
In April 2013, HS2 Ltd wrote to the residents of Park Village East: “Our engineers are aware that the retaining wall between the railway and Park Village East has suffered over time from movement and damage... The replacement of this wall ... should address these historic subsidence issues”.
The new design announced in 2017 however, unlike previous designs put forward by HS2 Ltd, does not include rebuilding the retaining wall. Furthermore, if the tunnels are constructed, there will be no possibility of rebuilding the wall at a later date.
An expert report originally written for the Camden Civic Society by Colin Elliff BSc CEng MICE explains how the creation of tunnels actually under the retaining wall will make the wall itself even more unstable. His report states:
“HS2 Ltd has released only a limited number of documents showing the 2017 Three Tunnels design and this has made it difficult to draw definitive conclusions. However, even in this limited documentation, both the size of the proposed underground structures and their proximity to existing structures are readily apparent, and there is a clear risk of catastrophic collapse, both during construction, and also afterwards. To date HS2 Ltd has offered no credible information to explain how this underground structure can be efficiently and safely constructed.
“In general, particular aspects of the 2017 Three Tunnels design so far disclosed by HS2 Ltd carry an unacceptable level of risk of settlement and collapse. It is very difficult to see how the risk can be safely mitigated simply by applying any level of best practice in construction.
“The parallel alignment of retaining wall and tunnel raises the very obvious risk that the concentrated deadweight of the retaining wall – estimated at 130 tonnes per metre – immediately above will cause the tunnel below to simply collapse with catastrophic consequences.
“There is a range of disaster scenarios ranging from the tunnel boring machine becoming trapped underground, to the total structural collapse of the retaining wall into the tunnel. In the worst case this could be a catastrophic collapse which, as well as having a disastrous effect on the infrastructure, could put the personal safety of hundreds of rail travellers and residents at risk.”
My solicitor, Jayesh Kunwardia, Partner at Hodge Jones & Allen, has written: “We have made repeated requests for information from HS2 Ltd about the current design, but nothing new has been forthcoming. There is evidence that the proposed scheme poses a serious risk of loss of life and of causing great damage to properties in the area. It is unacceptable that HS2 Ltd have not given us sight of a complete set of documents and Ms Granger-Taylor is left with no other choice but to take HS2 to court.”
The most recent letter written by my solicitor to HS2 Ltd, as well as asking again for various drawings and studies directly relevant to me and my home, requests assurances from HS2 Ltd that they have assessed whether the construction work they are planning infringes my right to private life and home, and my right to peaceful enjoyment of possessions (Article 8 and Article 1 Protocol 1).
If these documents and assurances are not provided to us by 10th July, and our experience up to now makes us think it very unlikely that they will be, we intend to begin Judicial Review proceedings.
The decision we will ask to be reviewed in the JR process is the decision by HS2 Ltd not to provide the information we have requested. If our application to the court is successful, HS2 Ltd will be obliged to publish full details of their current design as well as to publish any Environmental Impact Assessments they have completed. If they have not done an up-to-date Environmental Impact Assessment, based around the new design, they will be obliged to undertake one.
All these different kinds of information will be very helpful to me and to my neighbours, and to residents and businesses in the broader Euston area. If, when published, it becomes clear that the current design for bringing HS2 trains to Euston is not workable, the viability of the larger HS2 project will be called into question. At the least, the line between Old Oak Common and Euston would need to be very differently designed, and the start of construction work delayed long enough to allow this to happen.
The amount I am hoping to raise
Costs so far have been covered by me and by my solicitors. Mr Elliff has given his time pro bono. The sum of £7,500 I am hoping now to raise from donations is to cover the cost of preparing the initial Judicial Review claim. If the figure of £7,500 is not reached, donations made below that total will be returned to donors.
The further estimated 'stretch' sum of £14,500 would be to cover the cost of the court proceedings, if we are given permission to go ahead with our claim.
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Sept. 22, 2020
No news may still be good news!
Having applied on 13 July to the Court of Appeal for permission to appeal the High Court’s decision against me of 5 June, we are still waiting to hear whether or not permission has been granted. As explained in my solicitors’ Press Release of 13 June below, my appeal request rests in particular on Mr Justice Jay’s reference to ‘calculations’ said by HS2 Ltd’s witness to show that the Three Tunnels design could be constructed safely, but which HS2 Ltd had not included in the papers submitted to the High Court.
In the meantime, my solicitor, Jayesh Kunwardia of Hodge Jones and Allen, has written several letters to the defendants. On 29 June he wrote to the Secretary of State for Transport asking when the Government’s formal response to the Oakervee Report would be published – a DfT witness had previously stated that it would appear before the end of June. In their response of 13 July, the DfT’s solicitor wrote that they would notify us ‘once the decision on the engineering design of the Euston approaches has been made final’. A follow up letter from my solicitor dated 11 September has now been acknowledged but not yet answered. (You will recall that the Oakervee Report questions the safety of the Three Tunnels design, describing it as carrying ‘major risks’.)
On 2 July, my solicitor wrote to HS2 Ltd asking them to produce the missing calculations. This letter has not been answered or even acknowledged, nor have we heard anything from HS2 Ltd since they too were contacted again on 11 September.
Given HS2 Ltd’s failure to produce the calculations they relied on in court, it is difficult to believe such calculations, if they exist, actually support their case. If I am given permission to appeal, the calculations are likely to be made the subject of a court order.
The Court of Appeal returns officially to full-time work on 1 October so it is possible that we shall hear from them before the end of next week.
July 15, 2020
I have applied to the Court of Appeal
We applied for permission to appeal on Monday 13 July. This is the Press Release sent out by my solicitors.
Hero Granger-Taylor launches challenge to the Court of Appeal in continued fight against HS2 Ltd’s ‘Three Tunnels’ design for Euston
Ms Hero Granger-Taylor and her team at Hodge Jones & Allen Solicitors have today submitted an application to the Court of Appeal against HS2 Ltd and the Secretary of State for Transport. This is on the basis that the current ‘Three Tunnels’ design for the Euston Approaches is dangerous.
On 5 June, Mr Justice Jay ruled in favour of HS2 Ltd and the Secretary of State for Transport (the Defendants) in a case brought by Ms Granger-Taylor who had argued that the ‘Three Tunnels’ design risked the catastrophic collapse of the cutting retaining wall along Park Village East.
In Mr Justice Jay’s view, Ms Granger-Taylor had,failed to establish that the ‘Three Tunnels’ design was inherently unsafe. He could not, on the evidence submitted, conclude that the design was so inherently flawed in the vicinity of a 12 metre retaining wall close to Ms Granger-Taylor’s home that no engineering solution could be found to construct it safely.
Ms Granger-Taylor’s grounds for appeal lie with the argument that the Defendants failed in their duty of candour to disclose all relevant evidence to the Judge during proceedings.
It is argued that the Defendants failed to provide sufficient information to demonstrate that the outbound tunnel could be constructed in a safe manner under the retaining wall. Their leading expert. alluded to calculations made, but these were never actually presented.
In his ruling, the Honourable Judge made the following finding: “I have to take Mr Wood’s evidence at its face value and accept that calculations have been performed…. showing that the tunnel can be constructed safely despite the engineering challenges.”
That finding formed part of the reasoning for why Ms Granger-Taylor’s primary submission was rejected by the Court.
As a second basis for appeal, Ms Granger-Taylor’s team challenges what might have been a misunderstanding on the part of the Honourable Judge, perhaps due to hearing having been held remotely, that opposing expert witnesses addressed the structural integrity of the design on two different premises – a 250mm thick reinforced tunnel wall versus one a metre thick without reinforcement.
The appeal comes in the days before the UK Government is due to respond to the Oakervee Review of HS2, published in February 2020, in which major concerns were raised over the design for the Euston Approaches. Mr Justice Jay acknowledged that the Government response to the review still has the potential to derail the ‘Three Tunnels’ design altogether.
Ms Granger-Taylor said: “If HS2 Ltd has calculations which show that there is no risk of the catastrophic collapse of the Park Village East retaining wall, I do not understand why they have not produced them. Instead they have wanted to fight me and would not agree to an adjournment before the High Court hearing in May. This is despite the fact that the Oakervee Report, in what is without doubt a reference to the ‘Three Tunnels’ design, describes HS2 Ltd's current proposals for the Euston Approaches as carrying “major risks” (9.17). My position remains that they do not have a feasible design for bringing their trains into Euston. I have come to the conclusion they want to fight this case because, without Euston as the London terminus, the business case for HS2 does not stack up (Full Business Case, 5.16).”
Jayesh Kunwardia, Partner at Hodge Jones & Allen, who represents Ms Granger-Taylor, said:
“We have concerns over HS2 Ltd’s duty of candour and their provision of all relevant documents during this case. There is evidence to suggest that some information was not disclosed as it should have been. Due the importance and timeliness of this case, we have asked the Court to consider the application for permission urgently and for a decision to be made within four weeks.”
Counsel for Ms Granger-Taylor is Christopher Jacobs at Landmark Chambers.
The case is being funded through Crowd Justice https://www.crowdjustice.com/case/hs2accountability/
July 1, 2020
Fighting on – please support this final stage of my challenge to HS2 Ltd!
As reported in my last update, on 5th June 2020 we received the High Court judgment of Mr Justice Jay, turning down my application for judicial review. The procedure for appealing a negative decision is to apply first to the Judge for permission to appeal and then, if permission is refused, to apply directly to the Court of Appeal. Grounds for appeal were drafted and submitted to Mr Justice Jay for his consideration.
On 22 June Mr Justice Jay refused my application to appeal his decision in favour of HS2 Ltd.
We have got so far, I am not prepared to give up at this stage. I remain extremely concerned about the safety of the Three Tunnels design developed by HS2 Ltd. After a week’s careful thought, today I have decided to go ahead with the application for permission to the Court of Appeal. This will have to be submitted by my legal team at Hodge Jones & Allen and barrister, Christopher Jacobs, by 13 July.
In order to apply for permission to appeal I have to meet urgent upfront legal fees to enable my legal team to draft grounds for the Court of Appeal, submit the Appellant’s Notice and then draft a Skeleton Argument. If permission to appeal is granted, further fees will have to be met to cover responding to the Defendants’ Skeleton Argument and preparing for and attending the hearing.
I am so grateful for all the support I have received so far. But I need to appeal again for assistance to see me through to the end. If you read this, I do hope that you will decide to help me meet the fees needed for the final stage of this fight.
My principal reason for continuing with this case is that it brings into question the engineering competence of the designers of HS2, an aspect of the HS2 scheme which has not been scrutinised publicly at all so far, and certainly not as part of the parliamentary process. An additional issue is whether HS2 Ltd is an honest and trustworthy organisation.
A key point in Mr Justice Jay’s judgment of 5 June is where he accepts that ‘calculations’ referred to in a key defence witness statement show ‘that the tunnel can be constructed safely despite the engineering challenges’. However, HS2 Ltd has not at any point produced these calculations and it is not certain whether they a) exist, b) refer to the part of the Three Tunnels design which is directly outside my house or c) actually show that the tunnels can be constructed safely.
A secondary ground is essentially a misunderstanding: in his judgment, Mr Justice Jay assumed that my expert witness, Colin Elliff, did not know that the proposed tunnels, to be made by the Sprayed Concrete Lining method, would include a reinforcement formed from steel rods. This misunderstanding could probably have been ironed out if the hearing had been held in an open court room and not, because of the emergency, remotely via Skype.
We are very glad that New Civil Engineer in its news bulletin of 22 June, as an appendix to a short article on my case, published Colin’s own calculations. These confirm the danger that the weight of the Park Village East retaining wall above could cause the uppermost tunnel to collapse during excavation, inflicting major damage on the existing railway and on the nearby historic buildings.
We still await the response of the Government to the Oakervee Review, in which Douglas Oakervee had identified ‘major risks’ inherent in what is clearly also the Three Tunnels design (9.17).
I know the coronavirus emergency has made this a very difficult time financially for a majority of people. But at the same time, our current state makes the absurdity of the Government continuing to spend such a huge amount of money on a badly designed railway scheme even greater.
Hero Granger-Taylor 1/7/20
June 5, 2020
Disappointing news from the High Court today but not the end of the line
This is the text of my solicitor's Press Release just sent out:
5 June 2020
Hero Granger-Taylor versus HS2 Ltd
Judge rules in favour of HS2 Ltd, Ms Granger-Taylor to launch appeal
Mr Justice Jay has today ruled in favour of HS2 Ltd and the Secretary of State for Transport in a case brought by Ms Hero Granger-Taylor, a resident of Camden, against the ‘Three Tunnels’ design proposed for the Euston Approaches.
Mr Justice Jay could not conclude on all of the evidence that the ‘Three Tunnels’ design was so inherently flawed in the vicinity of the retaining wall that no engineering solution could be found to construct it safely. He remarked it was impossible to accept that HS2 Ltd was so reckless and wilful as to persevere with a concept that it does not believe can be delivered safely.
The UK Government is still to respond to the Oakervee Review of HS2, published in February, which raised issues over the Euston Approaches. Mr Justice Jay acknowledged that the Government response to the review, expected in June, still has the potential to derail the ‘Three Tunnels’ design altogether.
Ms Granger-Taylor and her solicitors at Hodge Jones & Allen are seeking permission to appeal the ruling and have seven days to provide their submission.
Ms Granger-Taylor said: “I remain convinced that the flaws in HS2 Ltd's ‘Three Tunnels’ design are so great it can never be made safe. Having lived in my house all my life (66 years), I am fully aware of its structural frailty, as well as that of the 120 year-old railway retaining wall only 17m away. I continue to be dismayed that HS2 Ltd and their contractors can show so little regard for the stability of mine and my neighbours’ houses, and of the retaining wall, that our lives may be at risk. The Oakervee Report, in what is without doubt a reference to the ‘Three Tunnels’ design, describes HS2 Ltd's current proposals for the Euston Approaches as carrying “major risks” (9.17). I appeal to the Government to apply common sense without further delay.”
Jayesh Kunwardia, Partner at Hodge Jones & Allen, who represents Ms Granger-Taylor, said:
“We will be seeking the Judge’s permission to appeal in the next week. We have concerns over HS2 Ltd’s conduct and lack of transparency during this case. There is evidence to suggest that some information was not disclosed as it should have been. We will carefully consider the judgement to identify other grounds of appeal as well.”
Counsel for Ms Granger-Taylor is Christopher Jacobs at Landmark Chambers.
May 16, 2020
Hearing has finished and judgment will be given in late May or early June
The full hearing of my claim for Judicial Review, lasting a day and a half, took place last Wednesday and Thursday, 13- 14 May. It was held remotely via Skype for Business. The judge was Mr Justice Jay and the court will reassemble for his judgment not later than the first week in June, after he has carried out the Review itself, looking in more detail at the submitted documents and the relevant case law.
On my side, we remain cautiously optimistic of the outcome. Mr Justice Jay showed by his keen questioning of the two barristers that he was on top of the subject matter. At one point he commented ‘we really are confronting the most extraordinary Judicial Review’ (the transcript will be published in due course).
The Defendants’ counsel, Timothy Mould QC, was quite prepared to concede that HS2 Ltd had as yet no answer to the main point in Colin Elliff’s report on the Three Tunnels design, that tunnelling under the Park Village East retaining wall would destabilise the wall, at worst causing it to collapse into the outbound tunnel: HS2 Ltd’s position remained that they would still find a way to build this design safely, even though they have already reached the final ‘Detailed Design’ stage. The principal argument against this, put by my barrister, Chris Jacobs, was that the Three Tunnels design for the HS2 Euston Approach dated officially to March 2017 (and in reality, we now know, to the spring of 2016) so that, if a solution existed, they would have already found it.
On Thursday 7 May we had received the documents HS2 Ltd had been ordered to disclose by Mrs Justice Lang. These helped my case considerably but meant that Chris had to spend the whole of the Bank Holiday weekend reading through them. But by the start of the hearing he had put together a very effective case, ably supported by my solicitor, Jayesh Kunwardia. I must particularly acknowledge Colin, who was not required to speak but whose report was really the star of the show. Inevitably, his reward was to have his professional standing impugned by Mr Mould (who called me ‘an implacable opponent’ of HS2, an exaggeration but accepted as a badge of honour!).
My fundraising appeal remains open – this has been the most expensive phase of my claim. Once more, I owe huge thanks to all of you who have already contributed. Please pass on the link to this page in any way that you are able.
May 9, 2020
Full steam ahead to court hearing next week!
We have now passed the point where the Defendants, HS2 Ltd and the Department for Transport, could have asked for an adjournment. If all participants remain in good health, the full Judicial Review hearing will go ahead as listed, starting on Wednesday morning and probably continuing to Thursday lunchtime, 13-14 May. Because of the Coronavirus crisis, this will be a ‘remote’ hearing, conducted over Zoom. It is very disappointing that the practical arrangements do not extend to allowing the public to attend.
In response to Mrs Justice Lang’s order of 28 April, HS2 Ltd have produced many new documents. My team - Jayesh Kunwardia solicitor, Christopher Jacobs barrister, Colin Elliff, expert witness and I - are now going carefully through them.
The Department of Transport, who Mrs Justice Lang ordered to state their up-to-date position on whether the Three Tunnels design would proceed, have provided an additional witness statement but this still has not made their position clear.
Fortunately, the newly disclosed documents appear to support my position rather than that of HS2 Ltd: there is plenty of evidence here of the instability of the Park Village East retaining wall. So I remain optimistic about the outcome of the hearing.
Whatever the result, I believe my case will have successfully brought into question the adequacy of all areas of the HS2 design. And it should certainly make better known the barriers that have been thrown up against proper public scrutiny.
My fundraising to cover legal fees still has a long way to go. The coronavirus lock-down has made almost everyone’s finances more precarious, I know. But small donations from many people can make a big difference.
So please make a contribution yourself and in addition pass on my appeal to as many people you can think of.
Once again, my heartfelt thanks to all who have already contributed.
April 26, 2020
Omens good for full hearing on 13-14 May but more funds urgently needed!
Despite the coronavirus lock-down, the full High Court hearing of my Judicial Review claim now looks very likely to go ahead on the scheduled days, 13-14 May, but remotely (via Zoom or similar).
The 'additional hearing' I wrote about in my last update has not taken place: instead the Judge will decide on my 'request for specific disclosure' on the on the basis of papers submitted. We expect the outcome shortly.
In the meantime, though hampered by HS2 Ltd's refusal voluntarily to produce all the evidence they have referred to, we must get on with preparations for the full hearing, and this is now a very short time away!
If the interim 'additional hearing' had happened, as explained in my update of 13 April, this would have provided an opportunity for the Judge to have 'rolled up' the case without the full hearing: for this reason I did not seek donations at that point.
But going forward to a full hearing, expected to last a day and a half, I need to raise now an additional £15,000 to cover the legal fees.
I know that the current coronavirus crisis has created major financial difficulties for most people: forgive me for asking for your support at this time. But there will be legal and publicity gains to be made by continuing to the full hearing.
Whatever the outcome, this hearing will end with a judgment which will become case law. Because my case is going through on Human Rights arguments, if the judge's decision is in my favour, this will provide a precedent which should help other private litigants who bring similar cases in the future. My solicitor, Jayesh Kunwardia, believes that this is the first time that Article 8 of the UK Human Rights Act will have been applied to a case concerning construction/a structure (the construction that HS2 Ltd proposes and its effect on me, my family and an existing structure, my home).
Secondly, the full hearing should generate useful publicity, shining a light on the frailty of the engineering of HS2 as a whole, on the inadequate procedures for assessment followed by HS2 Ltd and their contractors, as well as on HS2 Ltd's now systemic secretiveness.
Thirdly, it ought to hasten the Government's announcement on the future of HS2 at Euston and, with luck, the acceptance at the Department for Transport that, as advocated in the Oakervee Review, only a much simpler design for the Approaches, with not more than 14 trains per hour, is actually feasible here.
I am not allowed to share the most significant documents we have received from the Defence side, but I can report that we have just been sent a letter confirming that no assessment has yet been made of the effects of the Three Tunnels design on the existing structures around it, including its effects on the unstable Park Village East retaining wall directly above. This can be contrasted with the statement from HS2 Ltd given in an article on my case in the Times for 18 April: 'We strongly dispute any suggestion that the current design poses any threat to the structural integrity of the retaining wall at Park Village East and have provided robust evidence to the court to that effect'. So far, my side has received no such evidence and we have no expectations of receiving ‘robust’ evidence of this kind in the future.
There are many other inconsistencies between HS2 Ltd's public position and the evidence so far released to us and it is these in particular which make me hopeful of a successful outcome next month.
With best wishes for everyone's good health, Hero
April 13, 2020
HS2 Ltd are still unable to prove that their Three Tunnels Design is safe!
Among documents now submitted to the Court by HS2 Ltd there is still nothing indicating that there has been a proper assessment of the part of the design where the tunnels pass below the unstable Park Village East retaining wall.
Additionally, the submissions from HS2 Ltd and a witness statement from the second Defendant, the Department of Transport, show that there is a fundamental disagreement between them, with the DfT repeating the criticisms of the Three Tunnels Design expressed in the Oakervee Review (for the latter, please see below, my update of 13 February).
I must apologise for the delay in providing this new update. My side received documents from the Defendants as expected on 28 February. But we were taken aback by the contrast between the positions of HS2 Ltd and the DfT. Another problem was that the range of evidence submitted by HS2 Ltd was much more restricted than we had hoped. Furthermore, their whole bundle had been poorly scanned, making the drawings in particular difficult to read.
We sent our response documents to the Court on 3 April. Three days earlier, on 31 March, we had also submitted to the Court an ‘Application for Specific Disclosure’, along with a list of the documents we were still asking HS2 Ltd to provide and, to this end, a request for a short additional hearing in front of Mrs Justice Lang.
My solicitor, Jayesh Kunwardia, was able to add to this application a further request, that Mrs Justice Lang compel both Defendants to clarify their position concerning the Three Tunnels Design, in particular in relation to the Oakervee Review.
We understand that the Defendants have now agreed to an additional hearing and in theory this could take place quite soon (though because of the coronavirus emergency it would probably have to be via Skype or similar). However, it may be that Mrs Justice Lang will require the two Defendants to make clear their position in writing beforehand. It is not impossible that HS2 Ltd, which, after all, is wholly owned by the Department for Transport, as a result will be forced to admit that it cannot safely build the Three Tunnels Design, thus effectively resolving my claim.
Whether or not the additional hearing goes ahead, it now seems to me unlikely that it will be necessary to continue on to the full Judicial Review hearing scheduled for 13-14 May.
A Press Release issued by my solicitors last Thursday can be found here: https://www.hja.net/press-releases/law-firm-calls-on-government-to-confirm-stance-on-oakervee-claim-that-hs2-tunnels-into-euston-pose-major-risks/
The Press Release also raises a more immediate issue, that parking suspension notices in the neighbourhood indicate that HS2 Ltd wants its Main Works contractor, Skanska Costain Strabag JV, to resume work as soon as 20 April. Among the ‘early work’ (i.e. pre-construction work) planned is the insertion under the Park Village East houses of two banks of closely-spaced ground anchors. The purpose of the ground anchors would be to help stabilise the retaining wall, even though, as HS2 Ltd admitted to the House of Lords Select Committee in 2016, they themselves will cause a degree of settlement damage to the Grade II* listed houses. In any case, as Colin Elliff in his updated expert report has again explained, if tunnelling under the retaining wall was ever carried out, as in the Three Tunnels Design, the ground anchors could not stop the wall collapsing downwards into the tunnel, indirectly causing much more serious damage to the houses as well as to the existing railway.
Wishing everyone good health, Hero
Feb. 25, 2020
Defence documents from HS2 Ltd now due 28 February
HS2 Ltd asked the court to extend the deadline for providing me with the their defence documents to this coming Friday 28th January. When they arrive, we shall need to spend some time digesting them. I hope to post a new update early next week.
Feb. 13, 2020
The Prime Minister’s Statement and the Euston Approaches
The Court Order has been delivered which requires HS2 Ltd to hand over the drawings and other documents on which they have been depending for evidence. They must supply these to me by Monday 17 February at the latest.
While waiting for these documents, I thought some notes on the Government’s decision on HS2 might be useful.
On Tuesday, the part of the Prime Minister’s statement on Transport Infrastructure which related to HS2 was actually quite brief. We gathered that all of Phase 1 between Old Oak Common and Birmingham and all of Phase 2a between Birmingham and Crewe had been given a ‘green light’. But the parts of HS2 further north, Phase 2b, would be taken away from HS2 Ltd and combined with Northern Powerhouse Rail to form a single scheme, High Speed North, under the direction of a new body
As for HS2 between Euston and Old Oak Common, the Prime Minister referred only once to Euston in the statement itself: I will create new delivery arrangements for both the grossly behind-schedule Euston terminus and phase 2b of the wider project. He gave a little more detail in an answer to Hammersmith MP, Andy Slaughter, whose constituency covers part of the Old Oak Common site: …. We will make sure that we take control properly of the management of that fantastic project [i.e. Old Oak Common]. …. We will also ensure that we take proper control of what is happening at Euston which, he would agree, has been a shambles.
HS2 Ltd therefore has ceased to be in charge of its own part of Euston station, of its line between Euston and Old Oak Common, and apparently also of Old Oak Common station.
The Oakervee Review was finally published on the same day as the Prime Minister’s statement. It is evident that the two are closely related (gossip suggests that Doug Oakervee may have been adjusting his text to fit in with the Government’s position right up to the last minute.) Therefore the Oakervee Review gives a good idea of the Government’s broader intentions. This is from the main section on Euston station: 9.20 An in-depth study needs to be undertaken to improve the efficiency of the future Euston station as a whole. ……The Review strongly recommends that this is undertaken under the leadership of the Senior Responsible Owner (SRO) together with Network Rail, the DfT, HS2 Ltd, Lendlease, the Shadow Operator, Camden Council (without undermining their role as a planning authority) and appropriate independent experts.
The ‘Senior Responsible Officer’ is a Civil Service term which in this case must refer to someone within the Department of Transport.
Also in section 9, Oakervee Review indicates that the aim now will be to redevelop Euston station as whole: 9.19 ….. HS2 Ltd and the DfT, together with Lendlease and Network Rail, have been exploring options for amending the design of Euston station to potentially reduce the size and number of platforms and encourage a single build.
This new policy for Euston, if combined with the ‘in-depth study’ mentioned by Oakervee at 9.20, and the redesign of this part of the project which is likely to follow, will evidently put back the start of construction by a further extended period, almost certainly several years. .
But if in the meantime the destructive and menacing activities of HS2 Ltd and their contractors are halted, this will mean a blessed period of respite for us residents. And if Euston station is eventually redeveloped in one go, this should mean a shorter period of construction than the Act’s three phases would have required, and should end in a better integrated and more coherent station building.
In the context of my Judicial Review claim, the Oakervee Review is particularly interesting about the ‘HS2 approach’ to Euston. Paragraph 9.20 also says that the envisaged in-depth study should ‘seek to avoid the complicated HS2 approach to Euston station and minimise risk’. The last phrase is better understood if read together with this: 9.17 The plans for HS2 tunnels running from Old Oak Common to Euston have provided major challenges due to the potential conflict with the existing railway entering Euston. ……. The existing [i.e. presently] planned construction of the approach has taken the form of a tunnelled dive-under which is likewise expensive and exposes major risks to the existing railway and [train] services during construction.
The ‘complicated HS2 approach’ is clearly a reference to the subject of my Judicial Review claim, what we refer to as the Three Tunnels design. This does incorporate a ‘dive-under’ or ‘grade-separation’. Here is a diagram of the proposed tunnels taken from slides shown at Netley School, Camden, on 6 November 2018 by the Main Work’s contractors Skanska Costain Strabag JV.
In the diagram here, the dive-under is created where the red western inbound tunnel passes under the green outbound tunnel.
Since the HS2 approach as currently designed is in tunnels, the ‘major risks’ to the ‘existing railway and services’ mentioned by Oakervee must refer to substantial settlement of what lies above the tunnels or even collapse of one or more tunnels. Where they are not beneath the Park Village East retaining wall and road, these proposed tunnels lie under the existing tracks within the Camden Cutting, including the tracks of the West Coast Main Line.
I do not know when references to the ‘tunnelled dive-under’ were incorporated into the Oakervee Review; the whole document is dated December 2019. But since the Review is so explicit that the current design creates ‘major risks’, I and my lawyers will have to ponder why it was that HS2 Ltd did not simply admit to us that their design had 'major risks' and could not be built, but instead defended it, most recently at the Judicial Review permission hearing at the High Court on 16 January.
HS2 Ltd’, in their Summary Grounds of Resistance of 11 November 2019, quote a letter sent to my solicitors on behalf of HS2 Ltd by the Government Legal Service on 10 July 2019. This letter states that ‘the First Defendant does not agree with Mr Elliff’s appraisal of the Three Tunnels scheme, and has emphasised that risks of the magnitude which the Claimant’s solicitors had described in correspondence by reference to the report “would not be considered acceptable by HS2 Ltd in any design which it sought to implement”.
Before finishing, I must thank once again everyone who has contributed to my appeal. I receive no list of who has given money and only know when someone agrees for their name to be posted, and then still might not be certain which David or Sarah it was. So please forgive me if I do not immediately thank you directly if we meet in person.
Lastly I want to express my solidarity with everyone badly affected by HS2 in those parts which have now been given the Government’s ‘green light’. I know many of you want to go on fighting. As long as no formal Notice to Proceed has been issued, there must still be room for some hope.
Feb. 4, 2020
HS2 must give me documents and drawings by 17 February
The Court Order following on from my successful Judicial Review permission hearing on 16 January has now been issued: HS2 Ltd must produce the evidence in support of their position (that their Three Tunnels design is not dangerous) by 17 February. This evidence should include the drawings and other documents which we had been repeatedly requesting from July 2018.
If we find on 17 February that any relevant documents are missing, we will be allowed to apply for them through ‘an order for specific disclosure’.
Once received, my aim will be to make these drawings and other documents publicly available. I am thinking how best to do this.
Oakervee wants a long delay to works here, in order to ‘get Euston right’
Currently, everyone affected by HS2 remains in a frustrating state of ignorance about the future of the project as a whole. We had expected the Government to have made their decision by now. Rumour now suggests that the announcement will be made on 24 February.
We are all also waiting for the publication of the delayed Oakervee report. The BBC has a copy of the final version of this and a BBC reporter, Tom Burridge, has been gradually revealing the contents in a long series of tweets made yesterday and today (@TomBurridgebbc ).
Tom Burridge’s tweets relating to Euston give the impression that Doug Oakervee has realised that the Three Tunnels design can never be made to work. He may also have understood that there is no available solution based on HS2 coming into Euston as a separate high speed line, in addition to the existing classic lines. But his idea of further years of delay ‘to get Euston right’ would mean unbearable continued uncertainty and blight for all those of us who live here.
Tom Burridge has evidently rephrased the Oakervee report somewhat but, anyway, here is the text of his four tweets on Euston: ‘The govt should continue with the Old Oak Common to Euston stretch. Euston is an important part of realising the benefits of HS2.’ ‘Old Oak Common should act as the temporary London terminus for HS2 services until Euston station complete (time to get Euston right shouldn’t delay start of HS2 services).’ ‘Construction of Euston is v challenging’ and government should ‘carry out a study, looking into efficiency of the future station as a whole, including considering options to simplify the HS2 approach to Euston.’ The Government should ‘develop and set out a single plan for overall Euston project with (one body with) overall responsibility … this should not be HS2 ltd.’
We do now have the latest report on HS2 from the National Audit Office, published on 24 January. This also acknowledges the problems with the design of HS2 at Euston and refers to the complexity of building the new HS2 station and ‘tunnelling in an operational railway within a central London location, while the station and conventional railway continues to operate. There is uncertainty regarding the current design of the works.’
Returning to my case, we expect any minute to receive a transcript of the hearing on 16 January. This will include Mrs Justice Lang’s excellent judgment. I plan a further update, based on this.
Jan. 17, 2020
Press release about yesterday's excellent news
Please note, money raised so far has not yet caught up with legal fees incurred so I am not pausing fundraising - all donations most gratefully recieved.
Here is the PRESS RELEASE from my solicitors, Hodge Jones and Allen
17 January 2020
Resident wins right to bring legal case against HS2 Ltd for tunnel design under Euston which poses ‘catastrophic’ threat to lives and property
A homeowner has been granted permission by the High Court to bring legal proceedings against HS2 Ltd for its ‘Three Tunnels’ design into Euston station, claiming that it will endanger the lives and properties of residents nearby.
Mrs Justice Lang DBE yesterday gave Ms Hero Granger-Taylor permission to proceed with the Judicial Review claim she has been fighting for since June 2019.
HS2 Ltd have been ordered to furnish within 21 days the evidence in response to the claim, which in the seven months since proceedings began they have failed to provide.
The judge considered Ms Granger-Taylor’s claim to be arguable on the grounds that HS2 Ltd’s Three Tunnels Design impacts on her rights under Article 8 (right to respect for one’s family life and home) and Article 1 and Protocol 1 (right to peaceful enjoyment of their possessions).
HS2 Ltd’s Three Tunnel Design has added greatly to the stress experienced by local residents.
An expert report conducted by the specialist railway engineer Colin Elliff has revealed the Design could cause a huge 10-metre high, 120-year-old wall to collapse into the new tunnels below or onto the existing West Coast main line, potentially crushing railway passengers. Evidence shows the unstable retaining wall causing 130 tonnes per metre of pressure downwards onto the proposed 9m wide tunnel just 1.5m below.
The report supports the notion that HS2 Ltd’s Three Tunnels Design is a hugely dangerous proposal which causes risk to life. At the same time, any collapse could cause serious damage to the houses in Park Village East. The properties affected are Grade 2*Listed Buildings which form part of the John Nash design plans for Regent’s Park.
Jayesh Kunwardia, Partner at Hodge Jones & Allen, who represents Ms Granger-Taylor, said: “Understandably, we and Ms Granger-Taylor are delighted with the result of the hearing. The judge recognises our claim that the Three Tunnels Design is a potentially lethal proposal and of great concern to the local residents. This latest outcome may result in HS2 Ltd taking the view that the Three Tunnels Design is unworkable and therefore being forced to reconsider the entire scheme.”
Ms Granger-Taylor, who lives half a mile from Euston Station, said: “People in the Euston area have now suffered for ten years the huge uncertainty which the HS2 Ltd scheme has brought with it. It is a real relief to have been vindicated by the law. I am heartened that this decision will have thrown a small spanner into the works of the behemoth which is HS2 Ltd. The lives and properties of those near to Euston cannot just be ignored and we demand proof of basic safety measures so that no lives are at risk.”
The return hearing will take place in May 2020.
Counsel for Ms Granger-Taylor is Christopher Jacobs at Landmark Chambers.
Ms Granger-Taylor is attempting to fund the judicial review challenge through Crowd Justice. Donations can be made at https://www.crowdjustice.com/case/hs2accountability/
For further information, please contact:
Yellow Jersey PR:
Georgina Whittle, Associate Partner
M: +44 (0)7835 770 967 | T: +44 (0)20 3004 9512
Alex Crean, Account Executive
M: +44 (0)7753170777 | T: +44 (0)20 3004 9512
Notes for Editors
Hodge Jones and Allen
Hodge Jones and Allen is one of the UK’s most progressive law firms, renowned for doing things differently and fighting injustice. Its senior and managing partner is Patrick Allen, who has been awarded a lifetime achievement award by Solicitors Journal.
For over 40 years’ the firm has been at the centre of many of the UK’s landmark legal cases that have changed the lives and rights of many people.
The firm’s team of specialists have been operating across: Civil Liberties & Human Rights, Criminal Defence, Dispute Resolution, Employment Law, Family Law, Financial Crime and Regulatory, Housing and Property, Medical Negligence, Mental Capacity, Personal Injury, Wills & Probate.
Jan. 16, 2020
Success in the High Court today!
My case was heard by Mrs Justice Lang who gave me permission to take the Judicial Review claim through to a full hearing and ordered HS2 to give us the documents I had been asking for.
Jan. 15, 2020
Case listed for 10.30 tomorrow morning, Thursday 16th January!!
The list for the cases to be heard tomorrow at the Royal Courts of Justice has just been published. My case appears as here:
Before MRS JUSTICE LANG DBE
Thursday 16 January, 2020
At half past 10
Applications for Permission
CO/4020/2019 The Queen on the application of Granger-Taylor v High Speed Two (hs2) Limited
I am sorry, I cannot give you a better timing than that. It may be quite some time later that we actually get going. Mrs Justice Laing is listed for another case in Court 2 at the same time and the list does not reveal who she will hear first.
The Royal Courts of Justice is in the Strand, just to the east of the Aldwych, the famous Gothic building you will know from the TV news. The postcode is WC2A 2LL.
If coming from Camden you can take the 168 bus and get off at the stop for LSE, which is where the bus has just turned into Alwych from Kingsway.
It will be very good to see as many people as possible. There are no dress requirements but if you arrive late you are supposed to bow to the judge as you come in.
My apologies for suggesting earlier the hearing would be in the afternoon.
Jan. 13, 2020
All set for permission hearing this Thursday 16th January - please come!
Dec. 14, 2019
Returning to urgent fundraising to cover hearing on 16 January
I am returning to urgent fundraising to cover the cost of the oral hearing of my renewed Judicial Review permission application, due to take place on 16 January 2020
We heard on 27 November 2019 that my initial claim for Judicial Review, made on 14 October 2019, had been turned down. We were able to renew the claim, and did so on 5 December 2019. We have just heard, on 11 December 2019, that the renewal application will be considered at an oral hearing at the Royal Courts of Justice in the Strand, London, on 16 January 2019 (the time of day will not be decided until the day before).
The oral hearing will unfortunately involve considerably further expense, not least because of the need to prepare additional documents. So today I am reopening my appeal, with the aim of reaching my current stretch target of £21,500 (the £7,500 of this which has already been raised was used up when first preparing my case).
The decision of Mr Justice Holgate, Planning Liaison Judge, to turn down the first application was made on the basis of the paper documents submitted. Judicial Review claims are currently being rejected at this initial stage at a rate of four out of five, so the fact that mine met the same fate was not altogether surprising.
But other signs have been positive: my claim has been designated as ‘significant’, it has been assigned to the specialist Planning section of the High Court, and the wait between the renewal application and the oral hearing is only five weeks, despite Christmas.
I am writing this on the 14 December 2019, two days after the election, and it is true that, in their manifesto and in remarks made by Boris Johnson, the Conservatives can be interpreted as being distinctly cool on HS2. So the whole HS2 project might now be cancelled or the link between Old Oak Common and Euston might be dropped. But the Government cannot make a decision until they have had the opportunity of to consider thoroughly both the Oakervee report and the ‘dissident’ report due from Lord Berkeley, and this might not be for some time.
Meanwhile, I feel it is important to continue with my case, to show how very unrealistic and dangerous the engineering of this part of the line is and that, by implication, how the design of HS2 overall must remain very questionable. It is still my position that there is not room to bring HS2 through the Euston Approaches as a high speed line in addition to the classic lines already occupying the whole of the Camden Cutting.
All contributions to my case via this CrowdJustice page will be most gratefully received.
More details of the legal aspects of my case.
Most importantly, we have good evidence to counter the principal reason for Mr Justice Holgate’s initial refusal, given as ‘the Claimant has suitable alternative remedies available to her’. His view appears to be based in particular on a statement in HS2 Ltd’s Summary Grounds of Resistance: ‘There are a number of features of the Phase 1 scheme within the Euston Approaches which will require Schedule 17 consents’. (For an explanation of Schedule 17, please see below again.)
The most important point we can make in response is to draw attention again to the fact that HS2 Ltd have already admitted in a Freedom of Information reply that any Schedule 17 application to Camden will not cover details of the design which are underground, while my main concern are the tunnels which HS2 Ltd propose to build. The second point is that there is still no sign of an imminent Schedule 17 application in relation to the Three Tunnels design. ‘Main Works’ construction is now due to start in April 2020. Residents of my street, Park Village East, have just learnt that this work will kick off with the insertion under our houses of a battery of ground anchors at a shallow angle and at a rate of two per meter. During the parliamentary process, it was admitted in principle that ground anchors would cause damage to our houses. This is in addition to the major danger identified in Colin Elliff’s report, the construction of the three tunnels themselves, the key element in my ‘grounds’.
The other remedy which Mr Justice Holgate probably had in mind is an appeal to the Information Commissioner. I did in fact pass all the requests for documents which HS2 Ltd have refused to supply over to the Information Commissioner's Office in July this year. But I had to wait until 1 November 2019 to hear that my appeal had been assigned to an officer there and I have not yet been given a deadline even for her initial response.
Clearly the ICO route would be far too slow as a way to obtain documents showing the environmental and other effects of HS2 work due to start in less than six months. (Another campaigner, Dr Paul Thornton, who had first made a Freedom of Information request to HS2 Ltd in April 2017, after repeated refusals, finally obtained the document he had been seeking when the ICO Tribunal heard his case last month. In this instance it had been worth waiting two and half years because the document eventually released by HS2 Ltd, their report made in the spring of spring 2016 to the Department for Transport on the subject of reducing cost overruns, includes a list of the parts of HS2 scheme which they had redesigned to be cheaper. Among these is the change to the design for the Euston Approaches from the previous AP3 design to the current Three Tunnels design. We now know that this change was made at least partly to save money.)
Lastly, Mr Justice Holgate, while apparently referring to the above planning procedural arguments, does not give any reason in his very short refusal document for dismissing aspects of my case which are based on Human Rights law. My lawyers, solicitor Jayesh Kunwardia of Hodge Jones and Allen and barrister Christopher Jacobs, continue to believe my case is strong on these.
A short explanation of Schedule 17.
The 2017 High Speed Rail (London– West Midlands) Act itself grants outline planning consent for HS2 Phase 1 but HS2 Ltd must apply under Schedule 17 to the relevant local authority for approval of certain design details. HS2 Ltd’s statement above might have given Mr Justice Holgate the impression that there will be public consultation on all the questionable aspects of the Three Tunnels design when a Schedule 17 application for this design is eventually submitted to Camden. But in reality there are very tight restrictions on what Schedule 17 can cover. HS2 Ltd’s own acceptance of the limits of Schedule 17 can be seen in other papers already submitted in my ‘bundle’, in particular the response dated 8 August 2018 to a Freedom of Information request made by me on behalf of the Camden Civic Society. Here, in answer to my question ‘When will the [Three Tunnels] design be released for public consultation?’, HS2 Ltd have answered ‘the developments referred to .. are a refinement of the design .. and are within the limits of the Act. Therefore there will not be a public consultation on the refinement.’ They add only that ‘There will be engagement on the architectural treatment of the above ground structures’
Hero Granger-Taylor 14.12.2019
Oct. 14, 2019
Judicial Review claim submitted today
I am not sure quite how it has taken us a further four weeks to get to this point, but all involved have worked hard to put together a 'bundle' which is not too long or too dull, but on solid grounds and sufficiently factual. We are satisfied with the result and now must wait three to four months for the judge who receives it in chamber to decide whether my case can go through to a court hearing.
Our 'grounds' rest on the failure of HS2 Ltd to provide the information which would allow an independent assessment of the extent to which their scheme for the Euston Approaches is dangerous. It is therefore just possible that, faced with an actual claim against them, HS2 Ltd will turn around and provide the information I and then my solicitors have been requesting for so long. But on present form this is unlikely.
My fundraising remains paused, but will reopen in due course (I shall post an updated estimate shortly).
Sept. 11, 2019
Putting the finishing touches to the first stage of my JR claim
Once again, many thanks to everyone who has contributed to my campaign. After a pause, using the money raised so far we are now putting the finishing touches to the first stage of my Judicial Review claim, the application to bring forward a substantive claim. We are on course to submit this next week, on 18 September.
Over the five weeks since my last update, I and my solicitor, Jayesh Kunwardia of Hodge Jones and Allen, have tried to obtain a geotechnical memorandum to add to the report which forms the basis of my claim, that by the specialist railways civil engineer Colin Elliff. Our idea was, since Colin Elliff's report is concerned with railway construction matters, to commission a short document to show how the risks he identifies would affect me and my house in particular.
Unfortunately, so far we have not been able to find a geotechnical engineer who would charge proportionately: no doubt many specialist engineers are already working in some way for HS2 Ltd or are unwilling to add their name to a case against them
Fortunately, in the meantime, I rediscovered some documents from 2013 where HS2 Ltd themselves referred to the instability of the existing retaining wall (see photo above) - at that date they were still proposing to rebuild the wall. For example, in a letter addressed to me in person they wrote: "Our engineers are aware that the retaining wall between the railway and Park Village East has suffered over time from movement and damage, which we understand has been a cause for concern for residents. The replacement of this wall using modern construction techniques to minimise ground settlement should address these historic subsidence issues, and so overall would be beneficial for local residents.
The current design for the Euston Approaches, about which HS2 Ltd are still refusing to provide adequate information, proposes not only to leave this old retaining wall in place but also to excavate two large tunnels almost immediately below. These tunnels would add greatly to the potential impact on the nearby houses - one scenario covered by Colin Elliff is the collapse of the wall into a tunnel beneath it. Furthermore, even if the construction of the tunnels were successfully completed, it would become impossible afterwards to rebuild the existing retaining wall.
In short, HS2 Ltd's documents from 2013 establish the connection between the wall and the stability of my house and make a geotechnical memorandum less urgent.
HS2 has been much in the news over recent weeks. Most relevant to my case is the statement made by the new Secretary of State, Grant Shapps, on 3 September. This drew on a 'stocktake' document written by the HS2 Ltd chair, Allan Cook: on timing, Cook "recommends 2028 to 2031 for Phase One - with a staged opening, starting with initial services between London Old Oak Common and Birmingham Curzon Street, followed by services to and from London Euston later." This sentence is ambiguous and could be taken to mean a delay considerably longer than 2031 for HS2 at Euston. But there still seems no immediate possibility of this part of the line being cancelled outright.
As long as the current design for the Euston Approaches is still on the books, I shall continue with my Judicial Review claim. The immediate aim of my action is to get HS2 Ltd to produce the full details of this, so that I and others in my neighbourhood can assess its impact on us. But it also remains my belief that there is no feasible way of building a new high speed railway line through the Euston Approaches. If this is correct, the sooner this can be publicly established the better.
Aug. 2, 2019
First target reached!
We have reached the first target of £7,500. Many, many thanks to all the individuals and groups who have given money, and to all the people who have circulated information about my appeal.
The money raised so far will be enough to cover my lawyers' fees in making the first part of the Judicial Review claim, the application for permission to bring forward a substantive claim.
This initial application can be granted or refused. Since we feel our case is strong, we are hopeful that we shall be given permission to make the substantive claim.
If we succeed in the initial stage, we shall at that point send out a new appeal for donations, for the remaining £14,000 of the 'stretch target'. This additional money would be to cover the costs of the actual hearing.
If our initial application is turned down, something that often happens apparently, we would be able to appeal the decision. But appealing would mean entering into a longer process, and we would have to think carefully before carrying on.
Currently we have no idea about a timetable. I'll add an update to the site when this becomes clearer.
July 12, 2019
Solicitors instructed to proceed to Judicial Review application
On 10th July, we received back from the Government Legal Department a response to our 'pre-action protocol letter'. But none of the hard information we had asked for was included. The letter itself also contained the admission that they had undertaken no risk assessment of the Park Village East retaining wall. And it confirmed that they had done no Environmental Impact Assessment for the Euston and Camden Cutting area since the bill was enacted in 2017, in other words they have done no EIA for the current design for the Euston Approaches, even though this is so different from the earlier AP3 and 'bill' designs.
The response is wholly inadequate so I have instructed my solicitor, Jayesh Kunwardia of Hodge Jones and Allen, to proceed with the application for Judicial Review. So we are on track to force HS2 Ltd to get the whole of their very dubious Euston Approaches design properly studied!
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