To: info@northernlineextension.com
Date: Tuesday, 29 June, 2010, 16:25
You invited comments on these repeated proposals for the NLE.
This Association commented in some detail on this issue, as part of  the consultation on the Draft Vauxhall Nine Elms Battersea Opportunity  Area Planning Framework. One never knows whether such comments are  passed on, or considered at all, so for the record, we make them again  here. 
- It is not at all clear whether these proposals do anything for the residents of Vauxhall, with their increasing congestion problems in accessing the Vauxhall stations, and TfLs apparent unwillingness to engage with the actual community about what if anything can be done about the Gyratory.
- They lack the costing information which was set out in the VNEB Transport Study, which may or may not still be valid. Now is not the time to invest in public works where benefits barely exceed costs - and if the developer builds it for free, he will want equivalent value in extra development over and above the dense development already planned.
- They do not address the likely congestion problems that will set in at Kennington Underground station, (particularly for Kennington residents trying to access the Northern line there via the restricted lift and gate arrangements), both from separation of the Northern line services and the extra movement between platforms arising from the proposed NLE traffic.
- In these more stringent times, there are smaller ticket items, such as gateline relief at Vauxhall (£50m) or escalator expansion at Vauxhall (£100m) or upgrade of Kennington access (£?m) which should be a first call on transport funds
David Boardman
Chair
Kennington Association Planning Forum
28 June 2010
Appendix KAPF Comments on Chapter 8 Draft VNEB OAPF
"Chapter 8 – Transport   
We think the transport  study underlying this Framework, although elaborate and complicated, is  not fit for purpose, because based on flawed assumptions  
·         The PTAL output  measure of accessibility, used in the studies, high levels of which  mandate denser developments under the Mayor’s Plan guidance is itself  flawed. In areas where the issue is congestion and lack of  capacity, it measures the time you take getting to the bus stop, plus  the time you spend waiting at the stop until the first bus arrives, but  if that bus is full, it omits the time you spend waiting until the one  comes with room for you to get on it.. (As the VNEB transport  study notes “PTALs  are only able to represent the ability to reach public transport; they  take no  account of available capacity either on public transport services or at  stations.”)   
·         The “borough  balancing” assumption (p 78, para 8.2) is that for transport  planning purposes future growth from elsewhere in the two boroughs is  reallocated to the VNEB area, to “ensure that this study remains  consistent with the London Plan forecasts” , ie that growth and  transport demand elsewhere will be correspondingly less, as jobs and  housing in VNEB increase. This  seems wholly implausible,  given the “Klondyke” nature of VNEB for developers, and the different  time horizons of the borough plans and strategies and VNEB, and the  overlap of VNEB into two boroughs. (This assumption eg makes the model  predict, in the  absence of a Northern line extension, a reduction of passengers  at Kennington Tube station over time).  
·         The transport modelling  takes no account of the developments at Elephant and Castle  
·         Para 8.3 says that the  intensification of employment in VNEB scenarios leads to “significant  increases in inbound as well as outbound morning peak public transport  trips”. So what assumptions are being fed into the model about  what proportion of VNEB jobs are going to VNEB or neighbouring  residents, whose journeys to work would have much less impact? Are these  standard assumptions or are they tailored to a combination growth of  housing and employment in the same area?  
·         In this regard, it is not  reassuring that the bulk of benefit from the NLE appears to accrue out  of area, both as regards origins and destinations (Transport Study p  161). Is the NLE, designed to raise PTAL ratings in the interior of  the OA, thereby enabling denser housing development, actually just  benefitting through traffic?  
·         The transport modelling  takes no account of the displacement of freight traffic caused by  concentration at Stewarts Road  
·         The Framework’s “Get out  of Jail” card to bring the transport accessibility (measured in PTALs)   in the middle of the VNEB area up to high levels, is an  extension of the Northern Line from Kennington (NLE). Such extensions  are notoriously difficult to cost, and often overrun timetable and  budget. Eg, while developers were initially to pay for a large part of  the Jubilee line extension to Docklands, in the end they paid less than  5% of the total cost of £3.5bn.  
·         Our cockshy estimate of  4.3 extra kilometres of tunnel, at between £180m to £260m a kilometre,  based on 1994 London Underground costings for tunnelling in the  Battersea area, uprated for increases in earnings, suggests a cost of  between £770m and £1.1bn. We note that the transport study at p 97  estimates a cost of between £670m to £1060m, depending on route chosen.   
·         Such an NLE is barely  cost effective unless built for free by developers, and these costs  dwarf other social infrastructure costs (above) and seem beyond the  reach of “normal” S106 charges. Developers asked to stump up the best  part of a billion pounds will in our view inevitably seek to recoup this  sum in extra development density, on what is already expected to be one  of the densest developments in the world.  
We note, at p 171 and  Table 39 of the Transport Study, that further studies are contemplated: 
- Further sensitivity tests assessing the value and effects of:
- borough balancing of future OA development; and
- addition of OA development without applying borough balancing.
- Investigation into the effects of interaction of OA development with adjacent development areas such as the development nodes at Waterloo and Elephant & Castle.
- Revised Scenario 5 Further modelling to assess the impact of the ‘Revised Scenario 5’ which, subsequent to this study was taken forward in the final OAPF document
- A comprehensive review of the Vauxhall gyratory and other key TLRN routes within the OA, with particular consideration for proposals to improve the urban realm and cycling provision. This should be a joint review by TfL and the relevant planning and highway authorities.
- Investigation of the effects of displacement of freight activities following reallocation of existing land use to new developments; this will be further addressed in the final OAPF document.
- Investigation of station design and provision of capacity at Vauxhall, Battersea Park Road, Queenstown Road and Wandsworth Road NR stations.
To be frank, these should have been the starting  points of any study that addressed the realities of the transport  issues underlying the Framework, and we await the results of such a  study with interest. It should also address the station design,  accessibility and capacity of the Grade II listed Kennington Underground  station, under a NLE option – the residents of Kennington do not relish  the prospect of being held at the ground level gates in rush hours  because their limited lift capacity and congested platforms are not  equal to the extra transit traffic generated by a Northern Line  Extension."  
 
 
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