- satisfaction of objectives
- cost benefit of the solution
- security of funding
- mitigation of impact of construction on community
Thursday, 3 January 2013
Northern Line Extension Consultation
Representation from the Kennington Association Planning Forum
Who we are
1 The Kennington Association is a voluntary membership association of upwards of 400 members drawn from the wider Kennington area in the north of the Borough of Lambeth. Our aim is to promote and maintain the Kennington area as a good place to live and work, and the Kennington Association Planning Forum is a group of Association members with interest in and experience of planning and development issues, that develops planning policies and makes planning representations on behalf of the wider Association. The Association was a Rule 6 party at the 2010 public inquiry into the Bondway/Octave Tower application, successfully arguing for the centrality of well-planned public spaces to the success of large, dense mixed-use developments.
2 The Kennington area comprises an interspersed mixture of Georgian and Victorian conservation areas and social housing estates, some with significant deprivation. The Association’s concerns therefore include conservation, open space, affordable housing and employment and skills issues in relation to its area, and the extent to which developments in the Kennington and wider VNEB areas, and particularly the NLE will benefit Lambeth residents and jobseekers, or drain away funds better spent on Lambeth purposes, and detract from public amenity.
The Transport and Works Act Order Process
3 This Association has made a number of representations about the NLE, all falling on deaf ears, be it those of TfL or the Mayor of London, and it is clear that the parties are set on an early TWAO application for the favoured NLE route, irrespective of the results of any “consultation”. We therefore focus on the issues likely to be prominent at such a hearing. At a TWAO hearing the Inspector expects to be assured on
4 As regards objectives, what is in question is the appropriate public transport solution for the likely level of demand arising from the agreed (albeit harsh and overdense) VNEB development of 16,000 dwellings and 25,000 jobs. Given the affluent international clientele being courted for the dwellings, and the likelihood of investment properties being left unoccupied, or used as pieds-a-terre, we challenge the trip generation forecasts which assume that all the occupants of such dwellings are normal people, making normal demands on peak hour public transport, and we have reservations about the assumptions fed into the various models about how little abatement there will be in trip generation, despite dwellings and employment being cheek by jowl. By way of example, the 2011 Census allows us to see that 15% of completed dwellings on the St George Wharf development were unoccupied, and that there were no more than 1.42 residents per completed dwelling, well down on the standard 2 per dwelling rule of thumb (or the 2.34 per dwelling assumed by the GLA for VNEB) [Transport Study 2009 para 3.1.1]
5 Realistic trip generation forecasts should then have been fed into a comprehensive assessment of options. Instead, Network Rail options were cursorily dismissed – “single track shuttle train service between Victoria and Battersea Power Station (advised to be
infeasible by NR);” [Transport Study 2009 para 5.2.5] is typical of the depth of analysis deployed, without supporting material. At the same time, a Light Rail/Tram solution, acknowledged to be far more cost effective than the NLE, was set aside on the spurious basis, since shown to be laughable, that the NLE would prove even more cost effective, if only the private sector would build it for free. [“The GLA and TfL expect 100% private funding for the capital cost of the NLE.” [Transport Study 2009 para 9.4.1]. Cue hollow laughter as increases in business rates and CIL funding are set to be sucked up for 30 years to help pay for an NLE and its borrowing costs that, having dipped for presentational reasons from £800m to £564m, have now escalated to £1,000m and beyond. This is a classic example of the evidence being fixed around the policy, given the developer driven desire to be able to frank expensive dwellings and elite shopping with the cachet of “nearby tube access”, without the willingness to pay for it.
6 The public “consultation” on which NLE route to adopt lacked the essential element of cost, and so was practically worthless as a piece of policy analysis.
7 As regards the cost benefit of the solution, this has always been low, quoted as 1.3 to 1, and while we have been beguiled by “Wider Economic Benefits” studies, to try to make the numbers look better, we observe that these rarely appraise the “Wider Economic Costs” of extra congestion from construction work and loss of amenity from closed roads and green spaces. Furthermore, the limited work disclosed on distribution of benefits [Transport Study 2009 page 162 Fig 65] suggests a wide spread of benefits across London, with no particular concentration in Lambeth, raising questions about the equitable distribution of financing, given that no Lambeth developments are dependent on the existence of an NLE.
8 As regards security of finance, while the Government may be willing to guarantee a £1,000m loan, it will still have to be paid back with interest over 30 years, from gradual business rate increases from a suggested enterprise zone (no whiff of such a thing or its boundaries in the current draft Vauxhall SPD), CIL proceeds and £200m of S106 monies from the developer of Battersea Power Station. Given the up front costs of construction, the drawn out timetable for collecting the increase in business rates, the piling up of financing costs, and the prospects of further cost escalation, there is a significant prospect that CIL funds will be sequestered indefinitely, to the peril of other much needed infrastructure investment.
9 And as regards mitigation of impacts on the community, the resulting traffic forecasts for the Northern line are inconsistent from source to source, and the assumptions about only limited increased passenger transfer at Kennington incredible. Ramboll’s studies demonstrate deficiencies in geological appraisal, with potential consequences for previously unbudgeted engineering expense, an unsatisfactory stance on noise mitigation and a wholly unjustifiable unwillingness to budget, as part of the NLE project, for the upgrading of Kennington underground station to take the increased traffic.
10 In the circumstances, we consider that this NLE proposal is inadequate to proceed to a TWAO Inquiry, and there should now be a proper comprehensive transport study, taking account of the situation as is, not as TfL and developers wish it to be. Given that some information is rather slow in coming, we shall also be making a number of FoI requests, in particular about the basis for dismissing NR options and the distribution of benefits.
11 The Planning Forum is a member of DATA, and wholeheartedly associates itself with the representations made by it.
Kennington Association Planning Forum
31 December 2012
Tuesday, 30 October 2012
Monday, 1 October 2012
VNEB: Development and Transport Action Group
Newsletter Number Three: 12 September 2012
Report on public meeting with Lambeth Council: 10 September
DATA, along with a number of residents associations, has been pressing Lambeth Council for several months to undertake due diligence for its support of the TfL driven project to extend the Northern Line to underpin transport needs of the VNEB development area. We were pleased to learn at a meeting chaired by Val Shawcross on 10 September and supported by Lambeth Council, that they have now appointed the Consultants Ramboll to provide the technical due diligence that is necessary. We were also pleased to learn that Councillor Lib Peck, the Cabinet Lead for Regeneration is taking a close interest in the NLE project.
Val Shawcross said that the meeting marked a new phase in the way in which Lambeth was approaching the NLE proposal. Lambeth Council invites residents to comment on the NLE and has asked Ramboll to assess technical options to meet concerns raised. The Council will use this process to challenge TfL so as to protect and promote the interests of residents.
The agenda gave residents chance to discuss their views on siting of shafts, noise, pollution, and other environmental impact issues. Serious concerns were widespread. Val Shawcross, in the Chair, committed to a desire for highest standards of noise minimisation and conservation. The consultants confirmed that they would press for this. The meeting agenda did not include the question of alternatives to the NLE, but it arose.
Reports from some residents associations and Lambeth Council suggested that TfL are now adjusting original NLE specifications to strengthen their public interests brief rather than the maximised profit brief that had been adopted initially by the now defunct Treasury Holdings. This included widening the tunnels significantly to try to avoid one of the most controversial shafts and to be able to install floating rail systems that would reduce noise. There were a number of other areas where it was identified that additional costs would arise to meet the higher standards desired. There was also confirmation that TfL would need to fund the compulsory purchase orders needed to compensate for land taken beneath freehold property.
DATA made the point that this higher cost requirement would exacerbate an already very serious shortfall in both funding and financing. Either a lot more money/additional long term financing would need to be found, or compromises accepted in the standards discussed.
The Chair allowed a short discussion initiated by DATA which called into question whether the NLE was indeed the right transport solution or a white elephant. There was widespread popular vocal support for this question among residents, many agreeing that insufficient consideration had been given to alternative options, and making reference (as did DATA) to the TfL’s own consultants’ reports that show that the Northern Line was already heavily
overcrowded and would not easily be able to accommodate the increased traffic if extended to Battersea. Val Shawcross added that significant alterations may be needed at Kennington station for the large number of commuters to interchange safely, as the NLE scheme required.
Some residents groups said that they supported an extension of the Northern Line but it emerged that a number were under the impression that there was no alternative, or that the project was now unstoppable so they were focussing on minimising its impact. This is an example of where TfL’s selective marketing/use of statistics has created a misperception. There are other options but TfL have dismissed many of them without real consideration. This includes options that use existing infrastructure and new forms of transport to address road transport congestion, parking, pedestrian access and cycling and which also could integrate with wider transport initiatives such as CrossRail and provide transport connections within the development area. A NLE would do none of this.
Councillor Peck has confirmed that Lambeth Council would press TfL for removal of the gyratory and for improved cycling facilities, better bus services, and less traffic congestion in the Vauxhall Supplementary Planning Document. But the very high cost and stand-alone nature of the NLE makes it is difficult to see how this can be achieved.
One residents group from the
area was concerned that any NLE service would be full on departure from
Battersea, making it unusable by Nine Elms residents. They were also worried
about traffic and pedestrian concentrations to and from Nine Elms station in
the very narrow approach roads. Concerns were also raised that TfL might not
build a station at Nine Elms, just a box for future development, due to
shortage of funds. Lambeth Councillors and residents reacted to this strongly because
this station is acknowledged to be the only real benefit for Lambeth from the
NLE scheme, with most benefit going to neighbouring Wandsworth. The fairness of
Lambeth making such a large financial contribution to the NLE scheme, when most
benefits fall to Wandsworth, was questioned.
DATA asked for a further public meeting to discuss whether the NLE was indeed the right transport strategy for the VNEB development. DATA was directed to discuss with Ward Councillors. DATA agreed with Councillor Lib Peck and a senior representative of the Consultants, Ramboll, to remain in touch and exchange information. DATA has, separately, also had confirmation that TfL is ready to resume discussions and is waiting for dates.
There was common ground at the meeting that the original Treasury Holdings proposals for a NLE were based on profit over people and money over mobility, something TfL have also acknowledged. Is it not reasonable, in the light of this admission, to ask for a review of whether the decision to ignore all other options and opt for a NLE was based on the same profit rather than transport benefit motive?
A development the size of the VNEB, and the complexity of Lambeth’s transport challenges, requires an independent strategic transport needs analysis. So much depends on getting this right. The transport strategy should give priority to the needs of residents and integrate with wider transport initiatives, such as CrossRail, making a reality the Mayor’s vision of an integrated transport and fare network across
If you think the real facts on the NLE should be aired and an independent transport needs analysis undertaken please tell Lambeth Council now at: firstname.lastname@example.org and make your voice heard with TfL at: email@example.com and SMBNLE@tfl.gov.uk
Thursday, 19 July 2012
VNEB: Development and Transport Action Group
Newsletter Number Two: 12 July 2012
The recent advertising campaign by TfL in support of their Northern Line Extension project is, to say the least, wholly misleading. The selective use of information is manipulated to look as if there is a vast majority of residents in favour (untrue); that the Northern Line is the best transport option for the development along the development zone (unproven, but unlikely); that the Northern Line can cope with the added pressure of commuters (even though it is even more overcrowded at the moment than the Victoria Line); and that it is both affordable and funded (both untrue and unlikely).
Let’s spell this out a bit. The DATA Group, an umbrella organisation covering many residents associations in the area that focuses on development transport issues, has been in touch with TfL since January so we are in a position to speak with some clarity.
TfL claims 90% of the local population support the NLE. But let’s see how many people this covers and what they were agreeing to. The figures are in TfL’s NLE 2011 Consultation document (page 5). A total of 1661 responses is the basis of the survey. Compared to the tens of thousands of residents in the Borough this is a meaningless survey both statistically and morally: it certainly is not enough of a positive response to make a claim that there is majority support for the project. Indeed, the question that is asked is not whether a Northern Line Extension is the best transport option for the VNEB development, but:
‘When asked if they thought the proposed scheme would bring transport benefits to the area of Nine Elms and Battersea, 90% (1,597) either agreed or strongly agreed, compared with only 4% (64) who strongly disagreed’
This is hardly a decision based on an informed choice. We wonder what the response rate would have been had the options and consequences been spelled out: which we shall do here.
TfL is arguing that the NLE is the best transport option for the VNEB development and that the Northern Line can accommodate the predicted increased traffic. DATA has discussed with TfL alternative transport options that have not been considered at all, or only in a cursory way, including a mixed transport, staged approach that would develop ahead of the building development curve, and be flexible enough to cope with changes over time. A core longer term aim could be to link in with CrossRail 2 in line with the Mayor’s vision of integrating tube and overground services. We discussed these ideas with TfL in January and have been in email contact with them regularly since then but, despite several reminders, we still have not been provided with information that would take forward discussions on these points, or the follow-up meetings we were promised on both NLE and the Vauxhall gyratory. None of what we have discussed has been taken into account: so the claim in the recent advertising that TfL is responding to local views is worthless. Meanwhile, our own preliminary studies of travel density (more details soon) on the Northern Line indicate highly crowded conditions at peak times, and the need to look at platform and surface level capacity at Kennington, and signalling and track layout issues along the Northern Line, before adding an extra branch line serving the VNEB development. We challenge TfL’s curious assumption
that passengers will only use the less crowded parts of the Northern Line. In a nutshell, we doubt that the Northern Line is suitable for taking large numbers of additional passengers, without evaluating the full cost of other works to the Northern Line network as a whole.
Even TfL are cagey when they speak about funding of the NLE scheme. In discussion with DATA (and with resident groups with whom we share information) TfL appears to have no clear plan at all of how they can meet the growing funding and financing gap. Vague discussions of additional forms of what amounts to business levy and borrowing money from the market on the basis of fares income over the future years is hardly reassuring given the current economic conditions. TfL told DATA in February that they were re-evaluating the figures and would advise when they had some clearer estimates, but nothing further has emerged. At about the same time DATA’s investigations had revealed a funding gap of at least £570 million, about half the projected cost. Put bluntly, there is a huge hole in the sums. TfL does not have the money to pay for this scheme even with virtually all of the Lambeth Council allocation of regeneration funding (which would otherwise be spent on libraries, recreation facilities and the like). Not only don’t they have the money for the project, but they also have no clear plan, or realistic expectation, of how to get it.
TfL – Our message to you is to listen to local residents and look for alternatives. Do not commit to a huge project that will not provide the much needed transport infrastructure for the VNEB development and that will almost certainly need a government bale out to build and very risky, speculative financing to run. Consider also that the huge amount of funding that Lambeth Council is scheduled to provide will take virtually all the budget for community improvements and will leave very little indeed for ancillary regeneration. A NLE is not, as you claim, ‘essential to support the transformation of Vauxhall and Nine Elms’. Indeed it is likely to do the opposite, and prevent any transformation by sucking out regeneration funds from Lambeth’s budget. What is needed for VNEB development is an effective and affordable transport strategy: not a tube tunnel from Battersea to Kennington.
People of Lambeth – Our message to you is to make Lambeth Council and TfL listen to sense. For some reason the Council is willing to give your money to this cockeyed scheme without due diligence. Get the planning department to open up and be transparent for all development issues, including the NLE. We need the development fund money to keep open our libraries, provide other community amenities, improve our living environment, and address wider transport issues such as the Vauxhall gyratory. If we do nothing, the Council plans to pour virtually all of the money available for these purposes down a NLE black hole, never to be seen again. Moreover, it plans to finance the running of this transport project through increased business levies in the future.
DATA is in touch with TfL direct who know how to contact us if they want to discuss further. We are also in touch with a number of Lambeth Councillors, and want to engage more with Lambeth Council, who, so far, will not take our points seriously.
Comments and feedback to the DATA group via your residents associations please – or make representations direct to TfL and Lambeth Council. TfL have advertised their project team contact email in a recent misleading pamphlet as: firstname.lastname@example.org and the new Consultation and Engagement staff member, Brigid Burnham, at TfL recently emailed ‘stakeholders’ from: SMBNLE@tfl.gov.uk . If you want TfL to stop and think again before they spend all your money on a transport scheme that is not fit for purpose, email them to say so.
Thursday, 12 July 2012
KA PLANNING FORUM UPDATEAt the March 2012 Vauxhall Triangle Public Inquiry we opposed Kylun Ltd’s “Twin Towers” development as contrary to good strategic planning in London, given that Lambeth was still trying to get its game together on a coherent Vauxhall vision. We also found the affordable housing offer deficient, and the open space compensation offer inadequate. But we were able to support the St Anselm’s development at Kennington Cross in March, and the Beefeater Gin Visitor Centre proposal in April. In May we had a joint presentation on the Beaufoy redevelopment from Bellway Homes (for the housing development) and Diamond Way Buddhists (for the refurbishment of the Beaufoy itself as a residential study centre). This would refurbish a neglected Grade II listed building, yield neighbourly-styled flats in scale with adjacent buildings, and provide 40% affordable housing, and we judged that in planning terms this would be a satisfactory outcome. Finally, in June, we also supported the Sainsbury’s supermarket redevelopment, which provided interesting private open space in a roof garden over the new store, and, in the circumstances, a reasonable affordable housing offer. But we criticised Lambeth for downplaying the legal limitations on use of Sainsbury’s S106 monies, when handing the bulk of them over to the VNEB Strategy Board.
Friday, 27 April 2012
Premises and Entertainment Licence Application, The Mansion House, 48 Kennington Park Rd, SE11 4RS
Objection on behalf of the Kennington Association as to proposed permitted hours
Who we are
1 The Kennington Association is a voluntary membership association of upwards of 400 members drawn from the wider Kennington area, whose aim is to promote and maintain Kennington as a good place to live and work. The Kennington Association Planning Forum (KAPF) is a group of Association members with interest in and experience of planning, development and licensing issues, which develops planning policies and makes planning and licensing representations on behalf of the wider Association.
2 The notice of application was initially posted inaccessibly, and, contrary to the express requirements of the notice, the proposed operating hours were not stated. Consequently, this application, for the re-opening of a public house, next to another, the Old Red Lion, did not attract much attention initially. Now that these deficiencies have been rectified, (proposed operating hours now added to the notice in another hand – see photograph), we and others have a proper basis for objection, and the Committee should be slow to disregard ostensibly late representations, when the 28 day notice period for display of all salient particulars was not properly observed.
Objection on grounds of Public Nuisance
3 The proposed opening hours for this reopened public house would be 7am till 4 am in the morning, every day. These vastly exceed those of the adjacent public house, the Old Red Lion ( 4pm till 11pm, Mon to Thursday, 4pm till midnight Fridays, noon till midnight Saturdays, and noon till 11pm Sundays), and are totally unacceptable for a residential area out of the local Kennington centre, with no local precedent for such a late night economy.
4 As shown in the attached plan, the application site is on the Lambeth/Southwark boundary in a short parade of shops surrounded by dwellings, with a small park to its rear, a churchyard opposite it across Kennington Park Road, and the green curtilage of blocks of flats nearby. Given the efforts of Vauxhall interests to limit sales of alcohol in small quantities, to discourage street drinkers, such activity is being displaced in part to Kennington, and the combination of late night off sales and open space is likely to encourage nuisance drinking and other anti-social behaviour.
5 The aspiration for live and recorded music, on and off sales, pavement seating (whether the frontage on which they would be placed is private or the public pavement is not clear) and vastly extended hours add up to a serious nuisance to nearby residents unless the hours are significantly curbed, and stringent conditions are imposed. Having regard to Sections 5 and 9 of the Council’s Statement of Licensing Policy, we urge
- That the late night hours permitted be no later than those for the adjacent Old Red Lion, and the earliest hours permitted should be 9 am
- That no external music be permitted, and conditions be imposed as to full sound proofing (no music to be audible outside the premises) to prevent disturbance to neighbouring residential properties
- That no drinking should be permitted outside the premises after 9 pm at night
- That the operating statement should address the issue of outside smoking, as required by Para 5.7 of the Statement
D J Boardman 27April 2012
Kennington Association Planning Forum
39 Chester Way
London SE11 4UR
Tuesday, 13 March 2012
As many of you may already know, VNEB Development and Transport Action Group (DATA for short) was formed at the end of last year to provide an umbrella group for all residents who may be affected by the Vauxhall Nine Elms Battersea developments. Members of DATA are all from local organisations including Kennington Association, Vauxhall Society, Viva Vauxhall and Lansdowne Gardens Residents Association, and DATA is keen to ensure that all residents organisations in SE11 and SW8 are aware of our existence.
Accordingly, I enclose our first Newsletter, and I would be grateful if you could circulate it around your organisation, so that as many people as possible become aware of the issues we are covering.
Four of us from DATA (Ross Davies and Malcolm Russell from Vauxhall Society and David Boardman and myself from Kennington Association Planning Forum) have already met with Transport for London to discuss transport issues relating to VNEB, including funding and financing of the proposed Northern Line Extension, timescales and alternative transport strategies. These discussions are ongoing, and we are also scheduled to meet with them concerning the Vauxhall gyratory.
It is also timely to remind everyone about Lambeth Council's Open Days about the Vauxhall Area Supplementary Planning Document (SPD) on Wednesday and Thursday of this week from 3pm to 8pm at Unit 13A, St Georges Wharf, Vauxhall, SW8 2LL. Please try to encourage people to go to this.
As our Newsletter says, DATA welcomes ideas and feedback on the proposed NLE and related issues via residents' groups or community associations, and we look forward to hearing from you. Please feel free to contact any one of us (Andrea Hofling, Brian Vos, Colin McCall, David Boardman, Malcolm Green, Malcolm Russell, Ross Davies and me).
Posted by Kennington Association at 09:46