Monday, 5 July 2010

Northern Line Extension (NLE) Consultation

Subject: NLE Consultation
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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