IN PARLIAMENT

HOUSE OF COMMONS

SESSION 2005-06

CROSSRAIL BILL

PETITION

Against the Bill - On Merits - Praying to be heard by Counsel, &c.

TO THE HONOURABLE THE COMMONS OF THE UNITED KINGDOM OF GREAT BRITAIN AND NORTHERN IRELAND IN PARLIAMENT ASSEMBLED

THE HUMBLE PETITION of:

PADDINGTON BUSINESS IMPROVEMENT DISTRICT LIMITED

SHEWETH as follows:—

1 A Bill (hereinafter referred to as "the Bill") has been introduced into and is now pending in your Honourable House intituled "A Bill to make provision for a railway transport system running from Maidenhead, in the County of Berkshire, and Heathrow Airport, in the London Borough of Hillingdon, through central London to Shenfield, in the County of Essex, and Abbey Wood, in the London Borough of Greenwich; and for connected purposes.".

2 The Bill is promoted by the Secretary of State for Transport (hereinafter called "the Promoter").

Relevant clauses of the Bill

3 Clauses 1 to 20 of the Bill together with Schedules 1 to 9 make provision for the construction and maintenance of the proposed works including the main works set out in Schedule 1. Provision is included to confer powers for various building and

3606870.01 engineering operations, for compulsory acquisition and the temporary use of and entry upon land, for the grant of planning permission and other consents, for the disapplication or modification of heritage and other controls and to govern interference with trees and the regulation of noise.

4 Clauses 21 to 44 of the Bill together with Schedule 10 make provision for the application with modifications and the disapplication in part of the existing railways regulatory regime which is contained in and in arrangements made under the Railways Act 1993 and associated legislation. In particular, they provide for the disapplication of licensing requirements, the imposition of special duties on the Office of Rail Regulation ("ORR"), the modification of railway access contract and franchising arrangements and the disapplication of railway closure requirements and of the need for consent from Transport for London in relation to impacts on key system assets. Provision is also included to enable agreements to be required as between the nominated undertaker and controllers of railway assets, to govern the basis for arbitration and to provide for the transfer of statutory powers in relation to railway assets.

5 Clauses 45 to 59 of the Bill together with Schedules 11 to 14 contain miscellaneous and general provisions. These include provision for the making of transfer schemes, the designation of nominated undertakers, the devolution of functions and as respects other actions to be taken by the Secretary of State. Provision is also made in particular for the disapplication or modification of various additional miscellaneous controls, for the treatment of burial grounds, for the application of provisions of the Bill to future extensions of Crossrail, for the particular protection of certain specified interests and as respects arbitration.

Your Petitioners and their properties

6 Your Petitioners are the Paddington Business Improvement District Limited ("Paddington BID"), a private company, limited by guarantee. The Paddington BID went live on 1 April 2005 in accordance with the Local Government Act 2003 as a vehicle for carrying out Business Improvement District arrangements.

3606870.01 This was a result of a vote in which the Paddington BID was elected with an overwhelming majority, with 87% of businesses backing the proposal. The purpose of the Paddington BED under the Local Government Act 2003 is to carry out projects for the benefit of the business improvement district or those who live, work or carry out any activity in the district. Paddington BID provides the opportunity for businesses to invest and have a direct say in the management of the business improvement district area ("BID area"), and your Petitioners' members include non domestic rate payers who are responsible for paying the BID levy, Voluntary Members and Residential Members.

The BID area comprises the following streets, either in whole or in part:

Bishop's Bridge Road

Bouverie Place

Chilworth Mews

Chilworth Street

Cleveland Terrace

Conduit Mews

Conduit Passage

Conduit Place

Craven Road

Eastbourne Mews

Eastbourne Terrace

Edgware Road

Harbet Road

Junction Mews

Junction Place

London Mews

London Street

Norfolk Crescent

3606870.01 Norfolk Place

Norfolk Square

Norfolk Square Mews

Praed Mews

Praed Street

Rainsford Street

St Michael's Street

Sale Place

South Wharf Road

Southwick Mews

Southwick Street

Spring Street

Star Street

Sussex Gardens

Talbot Square

Westbourne Terrace

Winsland Mews

Winsland Street

The BID area is wholly within the City of Westminster and the Paddingtbn BID works in partnership with and supplements Westminster City Council local government activities in a number of ways, including—

(a) promoting the BID area as a better place to invest, work, do business and visit;

(b) promoting regeneration in the BID area;

(c) improving environmental standards;

(d) reducing crime;

3606870.01 (e) enhancing the built environment; and

(f) supporting conservation, protection and improvement of the physical and natural environment in the BID area.

8 Your Petitioners represent and have concerns in relation to the interests of the BED area. The BID area has a diverse and valuable heritage, with over 400 businesses operating in the area contributing to Paddington's economy. These include more than 80 hotels, and more than 60 restaurants, cafes and public houses. The Paddington BID has an interest in the BID area's amenity and the viability of local businesses. Its members own or have an interest in properties within the BID area, some of which are subject to compulsory acquisition or use under the Bill, and some of which, whilst not subject to the compulsory purchase proposals of the Bill, are in the immediate vicinity of the proposed works and liable to be injuriously affected by them.

9 Your Petitioners support the proposed project and welcome the decision to construct Crossrail, so long as the works are carried out so as to ensure that the burdens on your Petitioners and businesses within the BID area are justified by a genuine cross London rail movement. There are, however, many matters which cause great concern to your Petitioners. Accordingly, your Petitioners seek further assurances. Furthermore, it is respectfully submitted that the rights, interests and property of your Petitioners, and those who live and work in the BID area, will be injuriously affected by the Bill if it is passed into law in its present form. Accordingly, your Petitioners object to the Bill for the reasons set out below.

Your Petitioners' concerns

Worksites: general

10 Your Petitioners apprehend that there will be disruptive site preparation and construction activities at four work sites within the BID area, and that the impacts of this activity will continue to be felt throughout the BED area for a period of at least 5 years. Your Petitioners are particularly concerned about the impacts of noise, vibration, dust and dirt, hours of working, visual impact and disruption to the safety of road traffic and pedestrians. Accordingly, your Petitioners submit that the nominated undertaker should agree with Westminster City Council (in consultation with your Petitioners) to suitable standards in respect of each of these matters and that there should be provision for suitable mitigation measures including a code of construction practice and noise insulation policy. Ancillary documentation such as the proposed Code of Construction Practice, which should make this provision, remains in a draft form which is neither acceptable in principle, nor in its presumptions, proposals and extent of detail.

11 Furthermore, your Petitioners are concerned about the potential effects on road traffic, pedestrians and property owners near and en route to the worksites. The physical area and potential impact of each proposed worksite should be kept to a minimum with the safety of the public, whether pedestrians or other road users, being of paramount importance. Your Petitioners submit that there should be suitable compensation provisions in place to ensure that all of the residents, businesses and property owners in the BED area are properly compensated for the damage caused by construction and the use of Crossrail.

12 Your Petitioners represent many hotels in the vicinity of proposed worksites. When taking bookings, hoteliers are required to inform prospective customers of construction works that are likely to affect their stay. Your Petitioners therefore submit that the nominated undertaker should provide them with detailed plans, method statements, work programmes, and schedules of deliveries (particularly abnormal deliveries) in relation to each working site, well in advance of the commencement of operations. Your Petitioners should be notified well in advance of any alterations in methods of construction and construction operations, particularly in relation to site servicing and set up arrangements.

Dust

13 Your Petitioners are concerned about dust and dirt produced during construction. Your Petitioners would wish to see binding commitments imposed on the Promoter to require adherence to agreed measures to reduce dust, and to carry out additional mitigation if dust becomes a nuisance to properties in the BID area. Your Petitioners request that provision be made to ensure that the Promoter takes responsibility for the reimbursement of the property owners affected for additional expense caused by dust and dirt such as more frequent cleaning of the property.

14 Your Petitioners are concerned that the worksites are likely to produce a significant amount of contamination on the worksites themselves, in the surrounding environment and on the highways used for removal of spoil and waste. Your Petitioners submit that the nominated undertaker should be subject to a strict cleansing regime and that there should be strict waste management of the worksites to protect the highways and areas surrounding worksites from spoil, water, waste or similar.

Streetscapes

15 The proposed works are likely to affect a number of streetscapes permanently and temporarily in the Bayswater Conservation Area, much of which falls within the BID area. Your Petitioners submit that the Promoter should be required to carry out detailed surveys as to the location and condition of all heritage materials (including surface paving and historic street furniture) before and after the construction period. The nominated undertaker should be required to reinstate the heritage materials and to enhance the streetscape to a standard specified by your Petitioners.

16 Your Petitioners are concerned about the potential damage to trees in the area and submit that measures should be taken to protect trees from damage or loss during construction.

Subsidence, settlement and associated damage to properties during and after construction

17 Your Petitioners are concerned about settlement effects on properties in the BID area, in particular along Spring Street, Sussex Gardens and Eastbourne Terrace,

3606870.01 where Works 1/3A and 1/3B, being the twin-bore central London tunnels, are located. Your Petitioners have particular concerns as regards listed buildings and buildings in the Bayswater Conservation located above and adjacent to the tunnels, and envisage that significant damage could be caused to such properties as a result of the works.

18 Your Petitioners humbly submit that the Promoter should be required to take all practical measures to prevent damage and injurious effects, including constructing the proposed works at the safest practical depth and to carry out prior subsoil investigation. Your Petitioners require continuous monitoring of all the properties along Spring Street, Sussex Gardens and Eastbourne Terrace, and of any properties in Craven Road and Conduit Place whose owners request it, to be undertaken during construction of the works and for arrangements to be made for the carrying out of remedial works at the Promoter's expense. All of these matters should be agreed with the owners before the properties are allowed to be interfered with.

19 There must in your Petitioners' submission be thresholds agreed between Westminster City Council and the Promoter, in consultation with your Petitioners, for ground and building movement within the vicinity of the properties located above the tunnels and distortions of their structure. If a threshold is exceeded then, depending on the safety of continuing work, the Promoters should be obliged to carry out remedial measures while continuing work, or should cease construction until such time as remedial measures are in place which will minimise settlement affecting such properties.

20 Furthermore, your Petitioners respectfully submit that the Promoter should be required to agree necessary safeguarding or remedial measures with the property owners, to be carried out at the expense of the Promoter, and to use all available grouting, de-watering, freezing and pressure-working methods as well as to carry out agreed underpinning and strengthening works.

21 Your Petitioners request that provision be made for all damage or other defects occurring to properties in the BID area or any part of them caused by tunnelling or the operation of the project at any time be made good by the Promoter at the Promoter's expense immediately upon request by the owner and to the owner's satisfaction and in accordance with method statement agreed by the owner. Your Petitioners request that provision be made for all necessary statutory consents to be obtained by the Promoter at its cost. Your Petitioners request that provision be made for the owner to be compensated immediately by the Promoter for all damage to contents by replacement cost as new for new items, or the insurance valuation for any antique items or otherwise as appropriate.

Noise and vibration impacts

22 Noise and vibration arising from the construction and operation of the railway and its associated works and structures also concerns your Petitioners. Your Petitioners are concerned that the Environmental Statement fails to properly identify all those properties likely to be significantly affected by noise impacts and which require mitigation, for example properties near the Circle Line Link Worksite, hi particular, the Environmental Statement appears to ignore entirely the likely impact on sensitive locations, such as pubs and restaurants, in Craven Road and Conduit Place. Your Petitioners wish to see a further analysis of the noise impacts in those streets, and appropriate mitigation methods agreed to by the Promoter.

23 A number of buildings in the BID area are above or near the proposed line of the railway, or nearby, and which are likely to be sensitive to noise and vibration during the construction period, and when the railway conies into operation. These buildings include residential and commercial properties (including hotels, public houses and hairdressers) and buildings with occupied basements. It is particularly important for businesses such as hotels, public houses and hairdressers to provide a pleasant environment in order to attract and retain custom. Your Petitioners are concerned that the standards proposed by the Promoter are insufficient and are concerned that noise and vibration may radiate into buildings even if those standards are met. Your Petitioners submit that the Promoter should be subject to tighter design standards and compelled to use best available materials and techniques in the construction (and operation) of the railway and its associated works and structures to ensure that these adverse effects are minimised. In particular, these should include agreed measures to dampen track vibration and, where the railway passes near noise sensitive buildings, the nominated undertaker should be'required to install additional appropriate procedures and design methods to inhibit the transmission of noise and vibration into such buildings. Furthermore, your Petitioners wish to see strict construction standards set to which the Promoter and nominated undertaker must be made liable to comply. This should include compliance with a Code of Construction Practice agreed with Westminster City Council, including a comprehensive consultation and noise monitoring scheme, and a compensation code where agreed noise and vibration standards are breached. Your Petitioners should be consulted on the development . of this Code.

24 Your Petitioners are also concerned to ensure that the hours during which tunnelling takes place are programmed and managed so as to prevent undue noise and vibration to residents and sensitive businesses. Appropriate standards should be incorporated in the contracts between the Secretary of State and the nominated undertaker to ensure that the nominated undertaker meets those standards. Your Petitioners are also concerned to ensure that high standards are met in terms of the lifespan and maintenance of the running tracks.

25 Your Petitioners wish to see an effective noise mitigation and monitoring system in place before commencement and during construction of the works. There must in your Petitioners' submission be a threshold agreed between your Petitioners and the promoter of the Bill. If that threshold is exceeded, the nominated undertaker should be obliged to cease construction until such time as remedial measures are in place which will reduce noise levels below the agreed threshold.

26 Your Petitioners also respectfully request that the nominated undertaker be required at its own cost to provide adequate sound proofing measures, including double glazing in order to reduce the impacts of noise and dust on the hotels, public houses, restaurants, cafes, hairdressers and other sensitive business properties in the BID area.

10 Traffic and Pedestrian impacts

27 Your Petitioners apprehend that the Paddington BID area, in particular around Praed Street, London Street, Craven Road, Sussex Gardens, Spring Street and Eastbourne Terrace will be subject to considerable disruption over an extended period. Your Petitioners submit that procedures should be in place to ensure proper highway management throughout the Paddington area.

28 At the north-west end of Spring Street at the intersection with Praed Street will be located a major worksite (the Circle Line Link Worksite) which will have a major impact on the surrounding area. Immediately to the west another major worksite (Eastbourne Terrace Worksite) will be the source of further major disruption. The Red Star Deck Worksite to the north of Paddington Station and the Platform la Worksite near platform 1 of Paddington Station will also add to the disruption in the BID area. The Environmental Statement anticipates that these works will take approximately 5 years to complete.

29 Your Petitioners have most severe reservations about the proposed work sites at the Praed Street/Spring Street junction (the Circle Line Link Works) and-at Eastbourne Terrace. Your Petitioners apprehend that these sites and the works proposed to be carried out within them will bring about a general disturbance and loss of amenity to the areas involved, arising especially from—

(a) the temporary road closures proposed;

(b) construction traffic;

(c) restricted access to buildings.

30 Your Petitioners are concerned about the cumulative traffic impacts of the four worksites in the BID area. Your Petitioners believe that the nominated undertaker should take account of the impact of all the worksites when developing the construction methodology so as to ensure the accumulation impacts are kept to a minimum. Furthermore, your Petitioners submit that there should be an analysis of the potential traffic impact of all the combined worksites, and sections of the

3606870.01 11 highway to be acquired or used. This should take into account the extensive traffic rearrangement effects on the roads network in the BID area.

31 It is clear that the construction sites in the BED area will be centres to and from which large quantities of construction materials and equipment will be transported, together with staff. There will also be the problem of removal of spoil from the working sites. Your Petitioners submit that the nominated undertaker should be required to use every endeavour to utilise rail for transport purposes. The nominated undertaker should also be required to minimise the cumulative impact of lorry movements by properly managing, and keeping to a minimum, the number of such movements, using only the parts of the strategic road network specified in the Environmental Statement (Edgware Road, Sussex Gardens, Spring Street and Eastbourne Terrace), and confining movements to normal worksite hours.

32 Your petitioners are concerned about the interrelationship between the implementation of the proposals and the congestion charge and in particular, its proposed extension. In the BID area, Crossrail construction traffic will be using the boundary roads of the proposed extended congestion charge zone. The Environmental Statement and its Supplement severely lack detail about effect of the congestion charge on the volumes of traffic along the proposed construction routes, making it impossible now to properly assess the impact of those routes.

33 Your Petitioners are also concerned to ensure that the hours during which tunnelling and excavation of the stations and spoil removal from the tunnelling and excavation takes place are programmed and minimised so as to minimise the impact of lorry movements at sensitive times of the day. Your Petitioners wish to see a commitment from the Promoter that the nominated undertaker will carry out the tunnel construction in such a way as to remove as much spoil as possible by rail.

34 Your Petitioners are concerned about the potential for "rat running" of traffic and measures should be taken to restrict "rat running" in the BID area. For example, the diversion of westbound traffic on Praed Street into London Street, Sussex

3606870.01 12 Gardens and Spring Street is likely to give rise to "rat running" along the narrow street of Conduit Place. Your Petitioners submit that the nominated undertaker should, before diverting traffic from Praed Street and at its own cost, make Conduit Place one-way (with no entry from London Street) for safety reasons and to prevent "rat running". More generally, your Petitioners request that the Promoter and his nominated undertaker be required to consult with them before imposing any traffic management measures, in order to avoid other similar impacts.

35 Your Petitioners are concerned about the impact of advanced works for utilities diversions on the operation of Eastbourne Terrace and on station passenger set down and pick up and station deliveries. The impact on bus operations and car parking and motorcycle bays along Eastbourne Terrace, including diversions to nearby roads that appear to require buses to conflict with other traffic inappropriately, is also of particular concern to your Petitioners. Your Petitioners wish to ensure that Eastbourne Terrace remains open to traffic in both directions during the construction period. Your Petitioners also wish to ensure that appropriate measures to mitigate the impact of restrictions in Eastbourne Terrace, the closure of Cleveland Terrace, and other traffic proposals, are implemented by the nominated undertaker following consultation with your Petitioners.

36 Your Petitioners are concerned about the impact on taxis servicing Paddington Station and Eastbourne Terrace. The ES proposes the relocation of the existing taxi rank from Departures Road to the former Red Star parcels facility on the northwest side of the station. The ES suggests that this will lead to queuing on the access ramp between that facility and the rebuilt Bishops Bridge Road. Your Petitioners are highly concerned that this solution, which is proposed to last until the end of the Crossrail construction period (five to six years), will significantly reduce Paddington station's taxi capacity, and will make Paddington station and the BED area less attractive to travellers and businesses. Your Petitioners therefore humbly submit that the existing arrangements in Departures Road and Eastbourne Terrace, and any amendments to those arrangements subsequently agreed between BAA pic, Westminster City Council and Network Rail, are

3606870.01 13 reinstated fully on the completion of the Paddington Station works to their pre- existing condition.

37 Your Petitioners are concerned about the potential cumulative impact of the temporary stopping up of Bishops Bridge Road and Eastbourne Terrace at the same time, and your Petitioners seek assurances that both these roads will not be closed at the same time.

38 Your Petitioners note the obligation under paragraph 5(2) of Schedule 3 to the Bill to provide reasonable access for pedestrians going to or from premises abutting a highway that is proposed to be temporarily stopped up. Your Petitioners request that good and open access be maintained in all other cases as well, such as in the event of the erection of hoardings and scaffolding, use of the footway next to the property, the placing of equipment and apparatus there, and the parking, loading and unloading of vehicles. Your Petitioners are also concerned as to the impacts of surface road working and temporary and permanent stopping up and alteration of highways on cyclists and the mobility impaired. Overall, procedures should be put in place to ensure proper highway management throughout the BID area. This may include provision of alternative pedestrian routes, ramps over ground works, accessible pedestrian crossings, the installation of temporary dropped curbs and alternative cycle lanes.

Circle Line Link worksite

39 Your Petitioners object to the cut and cover construction of the link, passage connecting the proposed Crossrail station and the Circle and District Line station, which will result in the demolition of 191-195 Praed Street and have significant impacts on the movement of vehicular and pedestrian traffic along Praed Street. Your Petitioners fail to see the need for the cut and cover construction and the consequential demolitions and other surface impacts, given that the Promoter's intention is to create an underground link between two underground structures. Instead, your Petitioners submit that the underground link should be constructed from the proposed Crossrail station, therefore reducing the impact that this

3606870.01 14 worksite will have on the area. As a minimum, your Petitioners submit that the Promoter should be required to demonstrate why such below surface construction of the link would not work.

40 If, contrary to your Petitioners' request, the cut and cover construction of the link passage goes ahead, your Petitioners wish to ensure that mitigation measures are implemented, as follows—

(a) If 191-195 Praed Street are to be demolished, there should be a commitment to rebuilding in full consultation with your Petitioners, to ensure that this important part of the streetscape is improved by the Crossrail works;

(b) Full compensation, including assistance with relocation where requested, should be offered to the occupiers of 191-195 Praed Street, and also the Spring Street properties that are required for the proposed worksite;

(c) Measures must be agreed with the owners and occupiers of the properties adjoining those to be demolished, as well as other sensitive neighbouring properties, such as the Hilton London Paddington, in order to minimise the impact of noise, dust and vibration during demolition;

41 Further, the substantial narrowing of the roadway and footway at this location, which will inhibit the free movement of both vehicular traffic and pedestrians in the westernmost section of Praed Street, is of particular concern to your Petitioners, as is the impact of diverted traffic on London Street, Sussex Gardens and the Spring Street area (as described in paragraph 34 above). Your Petitioners wish to ensure that effective pedestrian links to Crossrail and also through to all London Underground lines are provided.

42 Your Petitioners are also concerned about the temporary loss of access to and on- street loading areas in Praed Street due to a restriction in the carriage width. This affects all the businesses in Praed Street, but is particularly important for the security vehicles for the Bureau de Change in Praed Street, which can not be serviced remotely because of their requirement to move large sums of cash on a

3606870.01 15 daily basis. Your Petitioners believe that measures should be taken to assist the servicing of local businesses and that these should include maintaining access and loading bays where possible, or identifying alternative loading areas, and amendments to waiting times.

Eastbourne Terrace worksite

43 In addition, the operation of Paddington mainline Station should not be prejudiced during and after the construction of Paddington Crossrail Station under Eastbourne Terrace. Your Petitioners are concerned about the proposed temporary closure of the pedestrian access to Paddington Station via Departures Road, the Clock Arch and Horse Arch. This would require pedestrians to use the Arrivals Road/Praed Street ramp to access the station, which in your Petitioners' view is likely to be unsafe, as this ramp is already,under pressure from vehicular traffic servicing the station, its retail outlets and the Hilton hotel. Your Petitioners therefore submit that the nominated undertaker should give an assurance that safe pedestrian access routes to Paddington station from the west are provided at all times during the construction process. — — —— ——

44 Your Petitioners are concerned that there is a lack of clarity of detail on proposals to demolish 4-18 Bishops Bridge Road and would urge the promoters to provide full details at the earliest opportunity and to agree appropriate compensation measures with the affected owners and occupiers.

45 Your Petitioners are also concerned about the likely impact on the offices along Eastbourne Terrace, which may be seriously adversely affected by noise, dust and vibration from the Eastbourne Terrace worksite unless adequate mitigation measures are put in place, as set out above, hi addition, vehicular access to these buildings should be maintained where practicable and that compensation be awarded for any costs incurred through the inability to service or park at these properties due to the works.

46 More generally, your Petitioners do not see the need for the proposed cut and cover method of construction at Eastbourne Terrace. Instead, your Petitioners

3606870.01 16 humbly submit that the nominated undertaker be required to lay down a full deck across the worksite, enabling at least pedestrian access to Paddington Station to be maintained.

Red Star Deck worksite

47 Your Petitioners are concerned at the proposed construction of a temporary taxi rank on the former Red Star Parcel Shed. These works are estimated to take over 14 months to complete, and your Petitioners are concerned that at the impact on St Mary's Hospital, which is adjacent to the worksite, over this extended period. Your Petitioners are particularly concerned that the works will give rise to noise, vibration, dust and dirt which will impair the use of the hospital by patients, and at the likely disruption and congestion caused to pedestrians seeking to access the hospital. Your Petitioners submit that the nominated undertaker be made subject to suitable standards in relation to all of the proposed impacts, and that the nominated undertaker should consult your Petitioners before carrying out any works that might affect access to the hospital.

Parking places

48 A significant number of off-street parking places at the Paddington station main car park, and on-street parking places on London Street, Eastbourne Terrace and Spring street, will be lost during the construction period. This will cause considerable inconvenience to those accustomed to parking in these bays. Your Petitioners submit that the nominated undertaker should ensure that alternative places should be made available nearby to replace lost places where this is practicable. The alternative places should be of the same category (including parking meters, pay-and-display, and places for taxis, motorcycles, and coaches) as the places that are lost.

49 Your Petitioners are concerned about the impact of the works on the operation of the Big Bus Tour Company which currently stops at London Street. Increased traffic along this street as a consequence of the construction works will result in

3606870.01 17 the removal of waiting places currently used by these buses. Your Petitioners wish to ensure that a temporary stand is provided to ensure the safety of passengers using the Big Bus Tour Company, and to minimise disruption to traffic in the area.

Operational Railways

50 Your Petitioners are concerned about the impact which the construction works will have on railway services running out of Paddington Station, and in particular mainline services, services on the Heathrow Express and services on the Hammersmith and City Line, District Line and Circle Line. Your Petitioners note that the nominated undertaker will be taking possession of the existing tracks, and are concerned about the proposed duration of the possession. For example, there is a proposed 2 week total blockade and a further 2 week partial blockade which will cause local and Great Western Mainline services to terminate at Baling Broadway. This will inevitably cause disruption to passengers coming in and out of the BID area and your Petitioners therefore seek assurances and guarantees that such track possessions will be kept to—a minimum and- suitable--mitigation measures- employed. Furthermore, your Petitioners wish to ensure that notification of the blockade is given to your Petitioners in advance.

Loss and Compensation

51 The provisions contained within the Bill for compensation for the compulsory purchase of property or of subsoil or new other rights will not enable your Petitioners or other landowners to recover the full loss and expenses which they will incur in consequence of the exercise of such powers. Your Petitioners therefore submit that the Bill should be amended to rectify this.

52 Your Petitioners also object that the compensation provisions of the Bill are inadequate to compensate your Petitioners or others in circumstances where no land (or interests in land) is acquired by the Promoter under the Bill, but where the value of such land and the properties erected on it is reduced or where such land

3606870.01 18 and the properties erected on it is otherwise adversely or injuriously affected by the construction or use of the proposed works. Your Petitioners therefore submit that the Bill should be amended to provide for claims for adequate compensation in respect of damage arising to their property by the execution of the works, or for injurious affection thereof by the execution or working of these works, separately from any claim for compensation in the respect of acquisition of any land (or interest therein) from your Petitioners under the powers of acquisition.

Dissemination of information

53 Your Petitioners respectfully submit that the promoters should be required to ensure that the nominated undertaker will put in place a comprehensive public relations strategy ensuring that information about the construction and operation of Crossrail is disseminated to the businesses who will be most affected. This should include the setting up of a local information centre in the BID area during the construction period to be staffed at reasonable and accessible hours, following consultation with your Petitioners.

General matters

54 As a general matter, your Petitioners submit that provision should be made for the Promoter to repay to your Petitioners all proper costs, charges and expenses (including the proper fees of such professional advisers as they may instruct) reasonably incurred in consequence of the Bill or of any provision made as a result of this Petition.

55 There are other clauses and provisions in the Bill which, if passed into law as they now stand, will prejudicially affect your Petitioners and their rights, interests and property and for which no adequate provision is made to protect your Petitioners.

3606870.01 19 Conclusion

56 Your Petitioners submit that the Bill fails adequately to safeguard and protect the interests of your Petitioners and those who live and work in the BID area and should not be allowed to pass into law without these issues being addressed.

YOUR PETITIONERS THEREFORE HUMBLY PRAY your Honourable House that the Bill may not be allowed to pass into law as it now stands and that they may be heard by themselves, Counsel or Agents and with witnesses in support of the allegations of this Petition against so much of the Bill as affects the property, rights and interests of your Petitioners and in support of other such clauses and provisions as may be necessary or expedient for their protection or that such other relief may be given to your Petitioners in the premises as your Honourable House shall deem meet.

AND YOUR PETITIONERS WILL EVER PRAY, &c.

BIRCHAM DYSON BELL

Parliamentary Agents for

PADDINGTON BUSINESS IMPROVEMENT DISTRICT LIMITED

20 IN PARLIAMENT

HOUSE OF COMMONS

SESSION 2005-06

CROSSRAIL BILL

PETITION of

PADDDSfGTON BUSINESS IMPROVEMENT DISTRICT LIMITED

Against, the Bill - On Merits — Praying to be heard by Counsel, &c.

BIRCHAM DYSON BELL 50 Broadway Westminster London SW1H OBL Parliamentary Agents

15 September 2005