- satisfaction of objectives
- cost benefit of the solution
- security of funding
- mitigation of impact of construction on community
Thursday, 3 January 2013
KA Planning Forum Representation on Northern Line Extension
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