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

Secretary of State for Transportc/o Transport and Works Act Orders UnitGeneral Counsel's OfficeDepartment for TransportZone 1/18Great Minster House33 Horseferry RoadLondon 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 inLambeth on the application for the Northern Line Extension Transport and Works ActOrder, submitted by Transport for London on 30th April 2013.

Residents groups which have come together to provide a common view on TfL'sproposals 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 AssociationIn addition, this letter summarises views from other residents from South LambethRoad, 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 thereare a large number of legitimate questions that should be answered about TfL'sproposals, 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 inparticular during ongoing operations - are likely to be the single biggest source ofnuisance and health impacts.

1) We believe that TfL is capable of delivering a system which reducesoperational noise levels to below its suggested 35 dB L(A) max, fast and that a

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target of30 dB L(A) max, fast is a suitable target for TfL to aim for indesigning the Northern Line Extension, and would be better for health thanthe which TfL is currently aiming to deliver.

2) We need further answers as to how TfL intends to procure contractors whoare able to operate at the cutting edge of noise mitigation technology

3) TfL should explain what standards it intends to hold its contractors to on noiseissues, as part of a wider requirement on TfL to demonstrate that it is usingbest practical means to reduce operational noise levels

4) TfL does not offer any remedies for residents if it turns out at a later date thatnoise levels are above those predicted in the Environmental Statementincluded in the TWAO application

5) The TWAO application does not set out what standards will be in place toreduce construction noise to a minimum, nor is there evidence of the role localauthorities 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 largemajority of Lambeth buildings will be affected by ground settlement only to anegligible or very slight degree. Yet TfL has not conducted building-basedsurveys which could justify this. The modelling of ground settlement effects shouldbe tested in a public inquiry, and the robustness of the model results should bejustified.

Furthermore, the TWAO does not set out how TfL intends to engage with propertyowners, whose property is modelled to lie within the 10mm ground settlementcontour. TfL should respond to its intentions regarding mitigation of groundsettlement effects, site surveys and possible compensation for damage caused bytheir proposals.

Transport case (see Annex C)Despite repeated requests, TfL has never justified an overarching transport casewhich 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 acombination of other transport modes, should line capacity be upgraded asappropriate.

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 recentdevelopments. As recently as March 2013, TfL told LB Lambeths ConsultingEngineers, Ramboll, that they did not intend to make modifications to KenningtonStation as part of the NLE

It is essential that a public inquiry is called, in order to test the robustness of TfL'sproposals for Kennington station, since there has been no public engagement on theissue to this point.

Transport modelling (see Annex E)

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There are apparent discrepancies between the figures for estimated passengerusage of the NLE that are described in the TWAO, and previous modelling providedby TfL to local residents. In particular, we believe that TfL is seriously underplayingthe risk of overcrowding on the Northern Line which would come about from thedesign 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 passengermodelling

NLE funding and financing (see Annex F)The funding and financing plan for the NLE does not seem robust, and relies onassumptions 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 incrementalbusiness rates revenue coming in from economic growth in the VNEB region, andwhich 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 giveassurances to local residents that other infrastructure improvements needed in theVNEB area (as outlined in the 2010 Development Infrastructure Funding Study) willnot be sacrificed should costs of the NLE overrun, or revenues from incrementalbusiness rates or CIL be delayed.

Individual residents and residents' organisations will also have other issues of mostconcern to them and you will receive separate representations from such groupsoutlining their further reasons for urging you to call a public inquiry

However, the scale of the concerns, and the interests of public scrutiny andtransparency, make us confident you will agree that a public inquiry into the NorthernLine Extension Transport and Works Act Order application is necessary andappropriate.

Yours sincerely

Donald Starkon behalf of a coalition of Lambeth residents and residents' organisations

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