Coalition of Lambeth Residents c/o 52 Claylands Road, London SW8 1NZ

Secretary of State for Transport c/o Transport and Works Act Orders Unit General Counsel's Office Department for Transport Zone 1/18 Great Minster House 33 Horseferry Road London SW1P 4DR 18th June 2013 Dear Mr McLoughlin, Re: The Northern Line Extension Transport and Works Act Order This letter is intended to summarise the views of a number of residents groups in Lambeth on the application for the Northern Line Extension Transport and Works Act Order, submitted by Transport for London on 30 th April 2013. Residents groups which have come together to provide a common view on TfL's proposals include: Kennington and Walworth Neighbourhood Action Group Heart of Kennington Association Claylands Green NLE Action Group IMPACT SW8 Vauxhall Spring VNEB DATA Fentiman Road Residents Association In addition, this letter summarises views from other residents from South Lambeth Road, Albert Embankment and other affected areas in Vauxhall and Kennington. The group wishes formally to request the Secretary of State to call a public inquiry into TfL's application for a Transport and Works Act Order, since we believe there are a large number of legitimate questions that should be answered about TfL's proposals, and that assertions made by TfL should be justified. In particular, we are concerned about the following issues Noise and vibration (see Annex A) For the majority of Lambeth residents on the NLE route, noise and vibration in particular during ongoing operations - are likely to be the single biggest source of nuisance and health impacts. 1) We believe that TfL is capable of delivering a system which reduces operational noise levels to below its suggested 35 dB L(A) max, fast and that a 1

2) 3) 4) 5)

target of 30 dB L(A) max, fast is a suitable target for TfL to aim for in designing the Northern Line Extension, and would be better for health than the which TfL is currently aiming to deliver. We need further answers as to how TfL intends to procure contractors who are able to operate at the cutting edge of noise mitigation technology TfL should explain what standards it intends to hold its contractors to on noise issues, as part of a wider requirement on TfL to demonstrate that it is using best practical means to reduce operational noise levels TfL does not offer any remedies for residents if it turns out at a later date that noise levels are above those predicted in the Environmental Statement included in the TWAO application The TWAO application does not set out what standards will be in place to reduce construction noise to a minimum, nor is there evidence of the role local authorities intend to play to enforce these standards.

Ground settlement (see Annex B) The TWAO application sets out a desk-based exercise which claims that the large majority of Lambeth buildings will be affected by ground settlement only to a negligible or very slight degree. Yet TfL has not conducted building-based surveys which could justify this. The modelling of ground settlement effects should be tested in a public inquiry, and the robustness of the model results should be justified. Furthermore, the TWAO does not set out how TfL intends to engage with property owners, whose property is modelled to lie within the 10mm ground settlement contour. TfL should respond to its intentions regarding mitigation of ground settlement effects, site surveys and possible compensation for damage caused by their proposals. Transport case (see Annex C) Despite repeated requests, TfL has never justified an overarching transport case which demonstrates the need for a NLE in order to deliver the VNEB regeneration and in particular why similar numbers of new residents could not be serviced using a combination of other transport modes, should line capacity be upgraded as appropriate. A public inquiry should be called to test the need for the NLE altogether Kennington Underground Station (see Annex D) The TWAO application proposes changes to Kenningon station at platform level, which have not been consulted upon at all, and which are only very recent developments. As recently as March 2013, TfL told LB Lambeths Consulting Engineers, Ramboll, that they did not intend to make modifications to Kennington Station as part of the NLE It is essential that a public inquiry is called, in order to test the robustness of TfL's proposals for Kennington station, since there has been no public engagement on the issue to this point. Transport modelling (see Annex E)

There are apparent discrepancies between the figures for estimated passenger usage of the NLE that are described in the TWAO, and previous modelling provided by TfL to local residents. In particular, we believe that TfL is seriously underplaying the risk of overcrowding on the Northern Line which would come about from the design of the NLE, and in particular on the already-overcrowded Bank branch. A public inquiry is necessary in order to test the robustness of TfL's passenger modelling NLE funding and financing (see Annex F) The funding and financing plan for the NLE does not seem robust, and relies on assumptions which TfL has made, and which have not been open to public scrutiny. In particular, TfL should justify its financing statement, which is based on incremental business rates revenue coming in from economic growth in the VNEB region, and which is required in order to service up to 1bn debt which the GLA will be issuing. A public inquiry is needed in order for TfL to justify its funding approach, and to give assurances to local residents that other infrastructure improvements needed in the VNEB area (as outlined in the 2010 Development Infrastructure Funding Study) will not be sacrificed should costs of the NLE overrun, or revenues from incremental business rates or CIL be delayed. Individual residents and residents' organisations will also have other issues of most concern to them and you will receive separate representations from such groups outlining their further reasons for urging you to call a public inquiry However, the scale of the concerns, and the interests of public scrutiny and transparency, make us confident you will agree that a public inquiry into the Northern Line Extension Transport and Works Act Order application is necessary and appropriate.

Yours sincerely

Donald Stark on behalf of a coalition of Lambeth residents and residents' organisations