AA/4/1 20Th May 2011 Town and Country Planning Act 1990 Acquisition of Land Act 1981 Inquiry Into

AA/4/1

20th May 2011

Town and Country Planning Act 1990

Acquisition of Land Act 1981

Inquiry into:

City Of Westminster (Victoria Regeneration Permission One)

Compulsory Purchase Order 2011

Stopping Up Order 2011

Proof Of Evidence of

Roy McGowan - Steer Davies Gleave

On Transport Matters

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CONTENTS

CONTENTS ...... 2

1.0 INTRODUCTION ...... 3

2.0 CURRENT SITUATION ...... 7

3.0 COMPLIANCE WITH TRANSPORT POLICY ...... 16

4.0 OBJECTORS TO THE CPO ...... 34

5.0 STOPPING UP ORDER ...... 38

6.0 OBJECTORS TO THE STOPPING UP ORDER ...... 42

7.0 CONCLUSIONS AND SUMMARY ...... 44

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1.0 INTRODUCTION

1.1 Details of the witness

1.1.1 I am Roy McGowan and I am a Transport Planner with 33

years‟ experience. I hold a Masters degree in Transport

Planning and Management. I am a Director of Steer Davies

Gleave which is an independent international transport

consultancy with more than 320 staff.

1.1.2 I joined Steer Davies Gleave in 1992 after 14 years of

transport planning in the public sector and have extensive

experience in regeneration, commercial and residential

development, stations, stadia and major events, transport

interchange and master planning.

1.1.3 My project experience includes the King's Cross Railway

Lands, Channel Tunnel Rail Link, Merseytravel Public

Transport, RAF East Camp (Hendon), Canary Wharf,

London 2012 Olympic and Paralympic Games, Thameslink,

the Royal Opera House, the Arsenal Regeneration Projects

and Emirates Stadium, the Ritz Hotel, Wembley Stadium,

Glasgow Commonwealth Games 2014, Cambridge (Hitchin)

Rail Curve, One Wood Street, One New Change and Victoria

Transport Interchange VTI1 and VTI2.

1.1.4 I am currently directing Steer Davies Gleave's transport

services for the London 2012 Olympic and Paralympic

Games, including pedestrian and vehicle movements for the

Olympic Stadium; Victoria Transport Interchange 2; the

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UEFA Champions‟ League Final Transport & Mobility

Domain Plan; and other commercial development proposals

across central London.

1.1.5 I am the Transport Advisor to the City Property Association

and have provided quarterly briefing papers and transport

advice since 2007.

1.1.6 Appendix A includes my CV and a selection of my project

experience.

1.2 Track record of projects worked on

1.2.1 Steer Davies Gleave has been ongoing transport advisors to

Land Securities for over seven years and was commissioned

in January 2005 to provide transport and passenger

movement advice with regard to the emerging Victoria

Transport Interchange VTI1 and VTI2 proposed development

schemes.

1.2.2 As a company our previous experience includes over 20

years of ongoing transport advice for new developments in

London, supporting the major city developers such as

Canary Wharf Group, British Land and Land Securities. We

are experts in transport planning and pedestrian movement

and modelling, and our most recent ongoing projects include

a study of crowd flow and evacuation routes for London 2012

Olympic Games; the provision of crowd flow and transport

solutions for football stadia worldwide including Arsenal's

Emirates Stadium and World Cup stadia for South Africa and

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Brazil; and passenger modelling for the preferred

development option at Euston Station and for the Crossrail

proposals at Paddington. We have also worked for a number

of London Boroughs assessing pedestrian movement and

the interaction with the public realm and for development

sites such as Centre Point and of course Victoria Transport

Interchange.

1.2.3 In addition, Steer Davies Gleave has extensive experience of

providing transport advice on various aspects of major

transport scheme developments. We are currently working

on the Northern Line Extension project which is being jointly

promoted by TfL, Real Estate Opportunities and Treasury

Holdings Limited. We are preparing the Transport and

Works Act submission and developing the business case

and the Transport Assessment and, with Ardent, undertaking

the public consultation for this new transport infrastructure in

Nine Elms and Battersea. We are also advising Network

Rail on High Speed Rail, the Department for Transport on

the mainline rail network and many of the Public Transport

Executives on the development of their metropolitan

transport networks.

1.3 Personal Involvement

1.3.1 I have personally progressed Land Securities‟ development

proposals at Victoria with the team since 2005 and I have

directed Steer Davies Gleave‟s involvement since 2006.

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1.3.2 Although my role of Project Director indicates a strategic

level of involvement, I have taken a keen interest and hands-

on approach in our work in Victoria.

1.4 Subject matter for Inquiry

1.4.1 The Inquiry is being held to consider the proposed use of

Compulsory Purchase Order (CPO) and Stopping Up Order

(SUO) powers for the development of Permission 1 of the

Victoria Transport Interchange 2 (VTI2) proposals. It is

expected that future phases will be constructed at a later

date.

1.4.2 I am present to help explain and present the transport and

pedestrian assessments and benefits for VTI2 Permission 1

and to discuss any objections on transport grounds for both

the CPO and the SUO.

1.4.3 To avoid repetition I refer to Hugh Bullock‟s proof of

evidence for the details of the sequence of events.

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2.0 CURRENT SITUATION

2.1 Existing Use of the Site

2.1.1 The majority of the site is currently owned by LC25 Limited

and is mixed use. Many of the buildings host offices on the

upper floors and retail at the lower floors, but the site also

provides some residential and hotel spaces1.

2.1.2 Victoria contains one of the busiest transport interchanges in

London. The rail and underground stations accommodate

136.8 million and 80 million people per year respectively2.

This has increased from the best available figures in 2008

when the Transport Assessment was produced referring to

115 million people passing through Victoria mainline station

each year and 75 million using the Victoria interchange each

year3 4.

2.1.3 Victoria is also a hub for tourists due to: the location of the

transport interchange (mainline rail, underground, buses,

coaches and tourist buses); the mainline station being the

terminus for numerous train services to and from Gatwick

airport; the coach station being the central London hub for

national and international coach travel; and the number of

tourist attractions in the vicinity such as Buckingham Palace,

1 Land Securities/Steer Davies Gleave (2009) VTI2 Transport Assessment (CD C13) - Paragraph 2.6 and Table 6.1 2 Westminster City Council (2011) Draft Victoria Area Planning Brief (CD B19) – Paragraph 5.0.2 3 Land Securities/Steer Davies Gleave (2009) VTI2 Transport Assessment (CD C13) - Paragraph 2.5 4 Westminster City Council (2006) Victoria Area Planning Brief (CD B17) – Paragraph 7.6.

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the Houses of Parliament, Westminster Cathedral,

Westminster Abbey and the Royal Parks5.

2.2 Public Transport Provision

2.2.1 The Victoria area is exceptionally well served by public

transport and has a Public Transport Accessibility Level

(PTAL) of 6b. This is the highest level and is regarded as

„excellent‟. The PTAL index is a measure of the accessibility

of a point to the public transport network, taking in to account

walk access time and service availability. The index is

recognised by TfL6.

2.2.2 The key features of the transport network close to the site are:

 London Victoria mainline rail station with Southeastern

and Southern (including the Gatwick Express) trains to

Clapham Junction, Gatwick and the south and east

coasts;

 Victoria underground station with access to the Victoria,

Circle and District Lines7 with extensive VSU (Victoria

Station Upgrade) proposals underway;

 St. James‟ Park underground station with access to the

Circle and District Lines is also close by;

 19 TfL Bus routes which serve the Terminus Place bus

station (in at least one direction). Of these, 12 routes

terminate at the facility and 7 pass through it. In addition

5 Land Securities/Steer Davies Gleave (2009) VTI2 Transport Assessment (CD C13) – Paragraphs 2.57 and 2.60. 6 Land Securities/Steer Davies Gleave (2009) VTI2 Transport Assessment (CD C13) – Paragraphs 2.32 – 2.35 7 Land Securities/Steer Davies Gleave (2009) VTI2 Transport Assessment (CD C13) – Table 2.7

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1 route (route 24) passes through Victoria without serving

the station in either direction8;

 Big Bus (blue and red routes) and Original Tour (yellow

and red routes) tourist bus services;

 National and International coach services from the

Victoria Coach Station and the Green Line stations to the

south of the main Victoria interchange; and

 Taxis / Black Cabs licensed by the Public Carriage Office

at two taxi ranks to the north and south of the mainline

station.

2.1 Highway

2.1.1 The road network around the site is relatively complex and

includes sections of the Inner Ring Road, the TfL Road

Network and the Strategic Road Network9. Part of the local

highway network is also part of the Toll Free western

boundary to the recently reduced central London congestion

charge zone10. This was formerly the Toll Free divide

between the original zone and the now removed western

extension zone (WEZ)11.

8 Land Securities/Steer Davies Gleave (2009) VTI2 Transport Assessment (CD C13) – Paragraphs 2.48-2.51 and Table 2.8 9 Land Securities/Steer Davies Gleave (2009) VTI2 Transport Assessment (CD C13) – Paragraphs 2.7-2.18 and Figures 2.2, 2.3 and 2.4 10 Transport for London (2011) Congestion Charging zone showing removal of Western Extension from 4 January 2011 (CD D1) 11 Land Securities/Steer Davies Gleave (2009) VTI2 Transport Assessment (CD C13) – Paragraphs 2.3 and 2.14 and Figure 2.2

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2.2 Pedestrians and Public Realm

2.2.1 Due to the significance of the roads around Victoria for the

wider network the roads currently dominate the pedestrian

landscape. Pedestrians must cross the busy road network

frequently when moving around the area and the location of

crossings is largely dependent on maintaining traffic flows

and not pedestrian desire lines12.

2.2.2 The high numbers of rail passengers and bus station users

contribute towards the congested nature of the area. The

footways are extremely congested particularly in the peak

hours and near the underground, mainline rail and bus

stations13.

2.3 Current and Future Challenges

2.3.1 London Buses – As noted in the WCC Committee Report

2009 the Victoria interchange is under stress and has been

identified in the TfL strategy document Transport 2025

(2006) as “one of the (bus) stations in most need of

improvement. One of the critical issues is that the existing

bus station cannot adequately accommodate all existing

services and provides no scope to cater for further frequency

increases” 14.

12 Land Securities/Steer Davies Gleave (2009) VTI2 Transport Assessment (CD C13) – Paragraph 2.19 13 Land Securities/Steer Davies Gleave (2009) VTI2 Transport Assessment (CD C13) – Paragraph 2.20 14 Westminster City Council (2009) Planning & City Development Committee Report –5 February 2009 (CD C2) Page 81

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2.3.2 TfL has not yet taken a decision on the future operation of

buses in the Victoria area and is not currently promoting a

scheme for the Terminus Place bus station15. However, the

VAPB (2011) states that the objectives of Westminster City

Council (the Council) and TfL relating to the provision of

transport in the Victoria area include: the provision of high

quality bus facilities that are appropriate to one of the

principal gateways to London; to improve or maintain journey

times and reliability for buses and general traffic; and create

a seamless transfer of people between all modes, including

reducing walk distance between modes where possible16.

Previously, the VAPB (2006) proposed the “relocation of bus

stands to create public, pedestrian dominated space,

appropriate for the setting of a Station of international

importance17 and to: create a seamless transfer of people

between all modes; “improve or maintain interchange

journey times between modes;” “improve or maintain journey

times and reliability for buses and general traffic;” and

“improve or maintain operational efficiency and resilience for

buses and general traffic” 18.

2.3.3 Further, TfL recognises that they will not be able to

accommodate future growth in bus services within Terminus

Place. In her letter dated 6th February 200819, the Director

15 Greater London Authority (2008) Stage 1 Planning Report (CD C9) – Paragraph 160 16 Westminster City Council (2011) Draft Victoria Area Planning Brief (CD B19)– Paragraph 5.1.1 17 Westminster City Council (2006) Victoria Area Planning Brief (CD B17) – Paragraph 6.44 18 Westminster City Council (2006) Victoria Area Planning Brief (CD B17) – Paragraph 7.17 19 As appended to Gerald Eve (2009) Transport Benefits Briefing Note (CD C12)

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of Planning at the Council confirmed that it is important for

the VTI2 proposals to make provision for a future scheme to

disperse the buses from Terminus Place to the perimeter of

the VTI site. She emphasised that bus dispersal is inevitable

and that the proposals should ensure that this is designed in

to the public realm now, avoiding the need for a retrofit in the

future.

2.3.4 Peak Hour Stresses on the Underground - It should be

noted that the combination of the mainline station and the

underground station makes for unusual transport capacity

issues. Typically central London underground stations have

high numbers of people leaving the station in the morning

peak (commuting in from other areas) compared with lower

numbers of people accessing the station (to commute to

other areas). However, because of the high volume of

people passing through the mainline rail station and

accessing the underground station to reach other central

London destinations, this normal pattern is reversed.

Indeed, the London Underground entry gateline to the

Victoria Line is regularly closed for short periods during the

morning peak due to excessive demand (above existing

capacity thresholds) and sometimes station closures are

necessary to avoid severe congestion20 21.

20 Land Securities/Steer Davies Gleave (2009) VTI2 Transport Assessment (CD C13) – Paragraph 2.41 21 London Underground Limited (2008) Victoria Station Upgrade Statement of Case of London Underground Limited (CD D9) – Paragraph 2.2.2

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2.3.5 The key morning peak movements generated by VTI2

Permission 1 will be from the Underground to the site and

there will be no worsening of the congestion issues as

described and which the VSU project is designed to address.

2.3.6 Victoria Station Upgrade (VSU) – TfL is undertaking works

on Victoria underground station to increase station capacity,

to minimise passenger journey times and to improve quality

of access, interchange and ambience22. These works will

provide:

 a new North Ticket Hall at the junction of Bressenden

Place and Victoria Street with an entrance at street level;

 an enlarged (existing) Victoria Line (South) Ticket Hall;

 new escalators;

 a new interchange tunnel (known as the Paid Area Link)

connecting the two ticket halls; and

 step-free access to the station platforms23.

2.3.7 TfL‟s timeline shows that the construction of the North Ticket

Hall begins in Spring 2011 and the facility will open in

Summer 2016. The extension of the South Ticket Hall will

begin in Winter 2012 and open, on completion of the whole

project, in Winter 201824.

2.3.8 VTI2 Permission 1 has been designed around the

constraints posed by the VSU project requirements and

22 Transport for London (2007) Victoria Station Upgrade Non-Technical Summary (CD D6) – Page 5 23 Transport for London (2007) Victoria Station Upgrade Non-Technical Summary (CD D6) – Page 11 24 Transport for London (2011) VSU Timetable (CD D2)

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program and will significantly enhance the public realm

around the station and particularly around the new North

Ticket Hall entrance. The VTI2 planning application was split

in to three25 due to the constraints posed by the VSU project.

2.3.9 Pedestrians and Public Realm – Both the VAPB (2006)

and the VAPB (2011) establish that pedestrian movement

around sites and within the transport interchange should be

given the highest priority26. VAPB (2006) recognises that the

Victoria Interchange is under stress and highlights that the

limited availability of pedestrian space is one reason for

this27. VAPB (2011) recognises that vehicular and pedestrian

movement generates major conflict at street level and that

“earlier developments have presented physical obstacles for

this movement where pedestrians are pushed to the

margins, corralled, contained and directed on tortuous and

confusing journeys” 28.

2.3.10 The VTI2 Permission 1 development will provide new,

attractive and legible pedestrian routes that provide direct

routes along pedestrian desire lines. Further, the quality of

the environment delivered by VTI2 Permission 1 will create a

place where people will at last want to spend time, and not

pass through to get to one of the many surrounding

important destinations.

25 Land Securities/Steer Davies Gleave (2009) VTI2 Transport Assessment (CD C13) – Figures 1.1 and 5.1 26 Westminster City Council (2006) Victoria Area Planning Brief (CD B17) – Paragraph 3.2 and Westminster City Council (2011) Draft Victoria Area Planning Brief (CD B19) – Paragraph 1.0.1 27 Westminster City Council (2006) Victoria Area Planning Brief (CD B17) – Paragraph 7.7 28 Westminster City Council (2011) Draft Victoria Area Planning Brief (CD B19) – Paragraph 1.1.17

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2.3.11 Conclusion - VTI2 Permission 1 will deliver all the transport

benefits of the VTI2 proposals as stipulated by the Section

106 agreement29.

2.3.12 The VTI2 Permission 1 works have been designed around

the constraints posed by the VSU project requirements and

program and will significantly enhance the public realm

around the station. VTI2 Permission 1 will also provide

additional on-street capacity to facilitate bus operations at

Victoria and dramatically improve pedestrian conditions and

capacities.

29 Westminster City Council (2009) Section 106 Agreement (CD C17) – Schedule 11, Part 1, Paragraph 8 (Page 36)

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3.0 COMPLIANCE WITH TRANSPORT POLICY

3.1 Introduction

3.1.1 In this section I set out how VTI2 Permission 1 fits with

transport policy that was in place at the time of the planning

application in September 2008 and the production of the

revised Transport Assessment in January 2009; and how

proposals continue to satisfy the new and emerging policies

in 2011.

3.2 National Policy

3.2.1 Policy Planning Guidance 13: Transport - The Transport

Assessment was produced in line with Planning Policy

Guidance 13: Transport (PPG13) as published in 200130. In

January 2011 the Department for Communities and Local

Government published an updated version of PPG1331.

3.2.2 The VTI2 proposals directly support the objectives of

PPG1332 by providing a mixed-use development in a location

with excellent transport access and a PTAL of 6b (the

highest level) and by providing improvements to the

sustainable transport options, particularly: walking by

improving the public realm and providing new links along

pedestrian desire lines33; cycling by providing new cycle

30 Department for Communities and Local Government (2001) Planning Policy Guidance 13 (CD A6) 31 Department for Communities and Local Government (2011) Planning Policy Guidance 13 (CD A7) 32 Department for Communities and Local Government (2001/2011) Planning Policy Guidance 13 (CD A6/A7)– Paragraph 4 33 Land Securities/Steer Davies Gleave (2009) VTI2 Transport Assessment (CD C13) – Paragraphs 5.20-5.22

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parking provision and cycle hire locations34; and buses by

providing new on-street stops and stands35.

3.3 London Policy

3.3.1 The London Plan - The VTI2 Transport Assessment was

produced in line with the London Plan (2008): Consolidated

with Alterations since 2004 (CLP)36.

3.3.2 While the process of revising the plan is underway it is still

the CLP 2008 that holds legal status and that this will be the

case until the replacement plan is formally published.

However, the Draft Replacement London Plan (Draft RLP)

will become a material consideration and will gather weight

towards the publication of the replacement plan37.

3.3.3 VTI2 Permission 1 aligns with both versions of the London

Plan (the CLP and the Draft RLP), in particular by delivering

a mixed-use development, public spaces and improvements

to the public realm at the important Victoria transport hub38.

3.3.4 Mayor’s Transport Strategy (MTS) – The Transport

Assessment was produced in line with the MTS 200139 and

the Transport 2025 documents40: Transport challenges for a

34 Land Securities/Steer Davies Gleave (2009) VTI2 Transport Assessment (CD C13) – Paragraphs 5.27 and 5.33 35 Land Securities/Steer Davies Gleave (2009) VTI2 Transport Assessment (CD C13) –Paragraph 5.24 36 Greater London Authority (2008) The London Plan: Consolidated with Alterations since 2004 (CD B1) 37 Greater London Authority (2009) The London Plan: Consultation Draft Replacement Plan (CD B2) – Paragraph 0.18 38 The London Plan: Consultation Draft Replacement Plan (CD B2) identifies Victoria as an Opportunity Area (Map 2.4) and supports mixed use development and public realm improvements in this area (Annex 1, Reference 29) 39 Transport for London and the Greater London Authority (2001) Mayor’s Transport Strategy (CD B21) 40 Transport for London and the Greater London Authority (2006) Transport challenges for a growing city (CD B9) & Transport vision for a growing world city (CD B10)

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growing city & Transport vision for a growing world city

(2006).

3.3.5 Following his election in May 2008, the Mayor Boris Johnson

published a statement of intent „Way to go!‟ for a new MTS in

November 200841 and published a Public Draft MTS in

October 200942. Following statutory and public consultation

periods the new MTS was approved in May 201043.

3.3.6 The VTI2 Permission 1 development supports the MTS

(2010) by providing a mixed-use development that is

thoroughly integrated with sustainable transport modes44.

3.4 Local Policy

3.4.1 Unitary Development Plan / Local Development

Framework - The Transport Assessment was prepared in

line with the City of Westminster Unitary Development Plan

(UDP), published in 200745. Although this has been partly

replaced by the Core Strategy, adopted in January 201146,

the transport policies TRANS 1 to TRANS 27 have been

retained47.

41 Transport for London and the Greater London Authority (2008) Way to go! (CD B8) 42 Transport for London and the Greater London Authority (2009) Draft The Mayor’s Transport Strategy 43 Transport for London and the Greater London Authority (2010) Mayor’s Transport Strategy (CD B7) 44 The Mayor’s Transport Strategy (CD B7) recognises Victoria as an Opportunity Area which means it is one of “London’s principal opportunities for accommodating large scale development to provide substantial numbers of new employment and housing. Each typically has more than 5,000 jobs and/or 2,500 homes, with a mixed and intensive use of land and assisted by good public transport accessibility” (Policy 23 and Page 366). 45 Westminster City Council (2007) Unitary Development Plan (CD B11) 46 Westminster City Council (2011) Local Development Framework: Core Strategy (CD B12) 47 Westminster City Council (2011) List of Retained UDP Policies (CD B11)

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3.4.2 VTI2 Permission 1 supports the aims of the relevant

transport policies and adheres to car parking, disabled

parking and cycle parking standards, as well as off-street

servicing policies48.

3.4.3 Victoria Area Planning Brief (VAPB) – The Transport

Assessment was produced in line with the VAPB as adopted

in 200649. The Council produced a revised Draft VAPB in

May 201050 which was subject to consultation in May and

June 2010. A new VAPB51, updated following the

consultation, was discussed at the City of Westminster‟s

Planning Sub-Committee (Planning Briefs and Local

Development Framework) on 11th May 2011. The Sub-

Committee agreed to recommend to the Cabinet Member for

the Built Environment that the revised planning be adopted

as a Supplementary Planning Document (SPD)52.

3.4.4 In line with the VAPB (2011), the proposals for VTI2

Permission 1 will deliver a unified pedestrian strategy for the

site that will ensure ease of movement and make key routes

legible and permeable. It will also provide new cycling

facilities and Barclays Cycle Hire stands; offer the potential

for future expansion or alteration of bus services; and

facilitate the VSU. These are discussed more fully in relation

to the objectives of VTI2 Permission 1.

48 Land Securities/Steer Davies Gleave (2009) VTI2 Transport Assessment (CD C13) 49 Westminster City Council (2006) Victoria Area Planning Brief (CD B17) 50 Westminster City Council (2010) Draft Victoria Area Planning Brief (CD B18) 51 Westminster City Council (2011) Draft Victoria Area Planning Brief (CD B19) 52 It is anticipated that the revised VAPB will be adopted as an SPD prior to the CPO public inquiry in June

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3.4.5 The VAPB (2011) sets out the objectives for the Victoria

area53. Although it is recognised in the brief that Victoria

Interchange is heavily constrained and it may not be possible

to meet all of these objectives54, LC25 Limited has sought to

tackle all of these points with the VTI2 Permission 1

proposals while providing an exceptional opportunity to

regenerate the area around Victoria Station by creating a

high quality mixed-use scheme adjacent together with the

potential for high value and much needed public transport

capacity improvements.

3.4.6 The relevant transport related objectives are taken in turn in

the text below.

3.4.7 Public Realm and Pedestrians - VTI2 Permission 1 helps

achieve the following objectives:

 “create a coherent sense of place and urban quality

appropriate for an international interchange including

improved and more legible street design;”

 “improve walking and cycling networks and facilities to

promote these as attractive transport options;” and

 “provide ease of passage for non-passenger pedestrians

through an improved environment which makes walking

easier, more direct and attractive” 55.

53 Westminster City Council (2011) Draft Victoria Area Planning Brief (CD B19) – Paragraph 5.1.1 54 Westminster City Council (2011) Draft Victoria Area Planning Brief (CD B19) – Paragraph 5.1.4 55 Westminster City Council (2011) Draft Victoria Area Planning Brief (CD B19)– Paragraph 5.1.1

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3.4.8 The VTI2 Permission 1 development will provide new,

attractive and legible pedestrian routes that provide direct

routes along pedestrian desire lines.

3.4.9 These pedestrian routes include the provision of a new

north/south pedestrian route. The new route follows the

same path as that proposed in the VTI1 application. The

City of Westminster Officers‟ Committee Report to the

Planning and City Development Committee in December

200756 welcomed the proposed new route which it

considered would increase pedestrian capacity. It went on to

state that the route would complete the desire line and

ensure connectivity between Victoria Street and the areas to

the north. It concluded that it was “a major enhancement of

the urban fabric” and that the addition of a major new route

to correspond with the desire line northwards was

considered to be very positive. It concluded that the walking

routes from Victoria Station would be demonstrably improved

by the implementation of the scheme. This was further

reiterated in the letter from the Director of Planning and City

Development on 8th February 2008 on the emerging VTI2

Permission 1 development which welcomed the provision of

a route which facilitates movement along this desire line57.

3.4.10 In addition to the proposed north/south route, a proposed

east/west pedestrian route will connect Victoria Square with

Cardinal Place significantly enhancing pedestrian movement

in the area. This route will be pedestrian only between

56 Westminster City Council (2007) Planning and City Development Committee Report (CD C1) 57 Gerald Eve (2009) Transport Benefits Briefing Note (CD C12) – Paragraph 3.24 – 3.25

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Allington Street and Buckingham Palace Road and will link

into the main north-south route that runs parallel to

Buckingham Palace Road58.

3.4.11 The VTI2 Permission 1 proposals include the widening and

resurfacing of Allington Street with widened footways. The

proposed buildings on the west side of the street will be set

back from the existing building line. These proposals will

provide a more attractive pedestrian and cycle route.

3.4.12 The VTI2 Permission 1 development will also provide space

for the Barclays Cycle Hire Scheme which will help promote

cycling in the area.

3.4.13 Public Transport and Interchange – VTI2 Permission 1

helps achieve the following objectives:

 “create a seamless transfer of people between all modes,

including reducing walk distance between modes where

possible;” and

 “improve user assurance through journey certainty,

safety, ambience, environmental quality and shelter from

adverse weather” 59.

3.4.14 The VTI2 Permission 1 development proposals will help

improve movement and pedestrian conditions – including

safety, ambience and environmental quality - across the

Victoria area by delivering significant public realm

improvements. The development will also accommodate the

58 Gerald Eve (2009) Transport Benefits Briefing Note (CD C12) – Paragraph 3.30 59 Westminster City Council (2011) Draft Victoria Area Planning Brief (CD B19) – Paragraph 5.1.1

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VSU development which will deliver access and interchange

benefits.

3.4.15 Buses and Traffic – VTI2 Permission 1 helps achieve the

following objectives:

 “provide high quality bus facilities that are appropriate to

one of the principal gateways to London;” and

 “improve or maintain journey times and reliability for

buses and general traffic” 60.

3.4.16 The VTI2 Permission 1 development provides space for the

dispersal of buses on-street, which was deemed to be the

optimum opportunity available for a solution to the buses by

the officer‟s report on the VTI1 proposals to Committee in

December 2007. This report concluded that the likely

increase in bus demand will inevitably result in the buses

being dispersed around the site and stated that if VTI were

not being proposed dispersal would take place without

bespoke changes to the existing constrained public realm to

best serve the reconfigured arrangement and the congestion

in the surrounding streets would be unresolved61.

3.4.17 Indeed, in her letter dated 6th February 2008, the Director of

Planning at the Council confirmed that it is important for the

VTI2 Permission 1 proposals to make provision for a future

scheme to disperse the buses from Terminus Place to the

perimeter of the VTI site. It was emphasised that bus

dispersal is inevitable and that the proposals should ensure

60 Westminster City Council (2011) Draft Victoria Area Planning Brief (CD B19) – Paragraph 5.1.1 61 Gerald Eve (2009) Transport Benefits Briefing Note (CD C12) – Paragraph 3.2

23 20.05.11

that this is designed in to the public realm now, avoiding the

need for a retrofit. Further the letter welcomed the above

proposals as a benefit that facilitates a possible future use of

Terminus Place as a new public space that in turn can easily

link in to the VTI2 Permission 1 site and be incorporated into

emerging schemes from either London Underground,

Crossrail or Network Rail62.

3.4.18 The overall potential development area of the VTI2 site has

been reduced to provide increased setbacks from existing

road and building alignments in order to provide significant

transport benefits in terms of new space allocated for future

bus stops and stands and improved pedestrian footways

around the entire site boundary, as stated for the VTI1

proposals, the TfL Feasibility Report 2008 which has been

signed off by TfL (as noted above all the transport benefits

associated with the VTI2 proposals as a whole are delivered

with Permission 163). The TfL Feasibility Report 2008

confirms that the VTI scheme “does achieve a workable

solution which involves the dispersal of buses to the street

network leaving more public space in front of the station” 64.

TfL also accepted within the GLA‟s Stage 1 report for VTI2 of

12 November 2008 that “the provision of widened

pavements and bus stops/stands by space around the

perimeter of the development is considered to provide a

62 Gerald Eve (2009) Transport Benefits Briefing Note (CD C12) – Paragraph 3.3 63 Westminster City Council (2009) Section 106 Agreement (CD C17) – Schedule 11, Part 1, Paragraph 8 64 Gerald Eve (2009) Transport Benefits Briefing Note (CD C12) – Paragraph 3.4 -3.5

24 20.05.11

transport benefit and is likely to be required by TfL” 65. The

bus stops/stands on Buckingham Palace Road in particular

will provide important additional bus stop and stand capacity

that will be available to be an integral part of future bus

planning and capacity requirement going forward. Even if

TfL decides not to take the full VTI1 public transport

interchange proposals forward, between 27% and 38% of

peak hour passengers can be relocated from the bus station

to Buckingham Palace Road under the benefits available

from VTI2 proposals, together with 20% of buses passing

through the bus station66.

3.4.19 By designing the VTI2 Permission 1 scheme to deliver the

transport benefits, as described, LC25 Limited has not taken

opportunities to use the land in different ways. Providing the

new kerb and bus stops and stands reduces the available

space for the building footprint and the opportunity cost of

this reduction equates to a loss of £17.6 million associated

with Building 5 and £1.911 million associated with Building

7a67.

3.4.20 Accessibility - VTI2 Permission 1 helps “promote an equal

and inclusive transport network accessible to all” 68.

3.4.21 The VTI2 Permission 1 development will dramatically

improve pedestrian conditions and make the public realm

safer and easier for people with disabilities. The public

65 Greater London Authority (2008) Stage 1 Planning Report, Land Securities‟ Development Site, Victoria - 12th November 2008 (CD C9) – Paragraph 44 66 Gerald Eve (2009) Transport Benefits Briefing Note (CD C12) – Paragraph 3.7 67 Gerald Eve (2009) Transport Benefits Briefing Note (CD C12) – Paragraphs 3.8 - 3.11 68 Westminster City Council (2011) Draft Victoria Area Planning Brief (CD B19) – Paragraph 5.1.1

25 20.05.11

realm has been designed in line with guidance from the

Department for Transport69 and provides extensive level

pedestrian areas.

3.4.22 Future Capacity - VTI2 Permission 1 helps achieve the

following objectives:

 “provide adequate capacity to cater for future demand

requirements for transport and pedestrians;” and

 “provide flexibility and safeguarding to accommodate

future transport developments” 70.

3.4.23 As well as providing for future growth of the bus services at

Victoria (as detailed above in paragraphs 4.1.13 - 4.1.18),

the VTI2 Permission 1 development will accommodate the

delivery of the VSU proposals. London Underground

confirmed its support for the VTI2 development, stating in its

letter of December 2nd 2008 “LUL support the VTI2

development as detailed in the three planning applications

recently submitted to the Council. Together these two

projects will bring significant public transport and

regeneration benefits to Victoria” 71. As noted above all the

transport benefits associated with the VTI2 proposals as a

whole are delivered with Permission 172.

3.5 Wellbeing

3.5.1 Section 266 (1) of the Town and Country Planning Act 1990

as amended by Section 99 of the Planning and Compulsory

69 Land Securities/Steer Davies Gleave (2009) VTI2 Transport Assessment (CD C13) – Paragraphs 3.55 – 3.58 70 Westminster City Council (2011) Draft Victoria Area Planning Brief (CD B19) – Paragraph 5.1.1 71 Gerald Eve (2009) Transport Benefits Briefing Note (CD C12) – Paragraph 3.14 72 Westminster City Council (2009) Section 106 Agreement (CD C17) – Schedule 11, Part 1, Paragraph 8

26 20.05.11

Purchase Act 2004 Compulsory Purchase Order requires

that development proposals contribute to the achievement of

the promotion or improvement of the economic, social or

environmental wellbeing of the area.

3.5.2 The transport benefits delivered by the VTI2 Permission 1

development proposals will contribute to the economic,

social and environmental wellbeing of Victoria and the City of

Westminster as a whole.

3.5.3 Economic – The Council‟s Cabinet Report on the CPO

states the transport related economic benefits of VTI2

Permission 1 as “the transportation improvements of the

VTI2 scheme as a whole – including the distribution of bus

stops around the site, provision for London Cycle Hire

Scheme and work to Allington Street – are cumulatively

valued at £12.55m and will be beneficial to Victoria as a

public transport hub” 73. Improvements to the public realm

with new active frontages will help transform the retail

productivity and retail convenience of the Victoria area as

explained in Hugh Bullock‟s proof of evidence.

3.5.4 The improved access to the transport interchange delivered

by VTI2 Permission 1 will help support economic

development. The MTS 2010 illustrates the relationship

between economic development and improving people‟s

access to jobs and improving access to commercial

markets for business travel74. It also recognises the

73 Westminster City Council (2009) Cabinet Report 23 September (CD C4) – Paragraph 3.2 74 Transport for London (2010) Mayor’s Transport Strategy (CD B7) – Figure 3

27 20.05.11

relationship between improving transport opportunities for all

Londoners and supporting wider regeneration75.

3.5.5 The MTS also refers to key interchanges where routes

converge as “central hub(s) of huge transport and

economic significance” 76. Victoria is a key example of

such a location and as such it is vital to support access to

and regeneration at this important location.

3.5.6 Victoria is designated as an Opportunity Area in the Draft

RLP77 and the MTS 2010 states that “improving connectivity

will be a key priority for … Opportunity and Growth Areas,

where accessibility for business, retail opportunities and

freight, as well as education, health and other services, is

important for social and economic development” 78.

3.5.7 Social – The improvements to the public realm delivered by

VTI2 Permission 1 will improve safety and security by

reducing the number of pedestrian and vehicle conflicts,

through a dramatic increase in pedestrian space79. “The

Government places great emphasis on people being able to

travel safely whatever their chosen mode. The planning

system has a substantial influence on the safety of

pedestrians, cyclists and occupants of vehicles through the

design and layout of footpaths, cycleways and roads.

Planning can also influence road safety through its control of

75 Transport for London (2010) Mayor’s Transport Strategy (CD B7) – Figure 3 76 Transport for London (2010) Mayor’s Transport Strategy (CD B7) – Paragraph 49 77 Greater London Authority (2009) The London Plan: Consultation Replacement Plan (CD B2) – Annex 1, Reference 29 78 Transport for London (2010) Mayor’s Transport Strategy (CD B7) – Paragraph 67 79 As shown in Mark Kelly’s Proof of Evidence

28 20.05.11

new development. When thinking about new development,

and in adapting existing development, the needs and safety

of all in the community should be considered from the outset,

and addressed in the transport assessment accompanying

development proposals, taking account of the importance of

good design” 80.

3.5.8 The improvements to the public realm delivered by VTI2

Permission 1 will also have a positive impact on quality of

life. The MTS 2010 also recognises the relationship

between enhancing the quality of life for all Londoners, and

hence wellbeing, with enhancing streetscapes and improving

the perception of the urban realm81.

3.5.9 The mixed-use nature of the VTI2 Permission 1 proposals

will have a positive impact on levels of walking and the

health benefits these deliver. PPG 13 2011 states that

“mixed use development can provide very significant

benefits, in terms of promoting vitality and diversity and in

promoting walking as a primary mode of travel” 82. VTI2

Permission 1 will also support increases in cycling with the

provision of on-site secure cycle parking and Barclay‟s Cycle

Hire Scheme docking stations.

3.5.10 VTI2 Permission 1 will provide jobs, shopping, leisure

facilities and other key services in a location that is very

accessible by public transport, walking and cycling.

PPG13 states ensuring these opportunities are accessible is

80 Department for Communities and Local Government (2011) Planning Policy Guidance 13 (CD A7) – Paragraph 29 81 Transport for London (2010) Mayor’s Transport Strategy (CD B7) – Figure 3 82 Department for Communities and Local Government (2011) Planning Policy Guidance 13 (CD A7) – Paragraph 30

29 20.05.11

“important for all but especially for those who do not have

regular use of a car, and to promote social inclusion” 83.

3.5.11 The integration of VTI2 Permission 1 proposals with the

transport interchange and the VSU scheme will have a

positive impact as recognised by the Draft RLP which states

that “The planning of transport services and the physical

infrastructure they require will need to be carefully

coordinated with the growth and development envisaged by

this Plan and this is a key theme both of this Plan and of the

Mayor‟s Transport Strategy” 84.

3.5.12 Environmental – The Council‟s Cabinet Report on the CPO

states that “the scheme will significantly improve the

transport and pedestrian environment, creating a high quality

public realm whilst integrating with the local community.

Environmental benefits can be measured largely through the

significant physical improvement over the current situation in

addition to the substantial enhancements to the overall

public realm…(which) will have a beneficial impact on well

being” 85.

3.5.13 VTI2 Permission 1 provides a mixed use development and

enhancements to the public realm which will make walking

more attractive and includes key measures that will support

cycling (the provision of on-site secure cycle parking and

Barclay‟s Cycle Hire Scheme docking stations). Thus, VTI2

Permission 1 will deliver environmental benefits associated

83 Department for Communities and Local Government (2011) Planning Policy Guidance 13 (CD A7) – Paragraph 19 84 Greater London Authority (2009) London Plan: Consultation Draft Replacement Plan (CD B2) – Paragraph 1.37 85 Westminster City Council (2009) Cabinet Report 23 September (CD C4) - Paragraph 3.4

30 20.05.11

with transport. The Council highlight this relationship by

stating that the “City Council will seek to improve air quality,

reduce the emission of greenhouse gases and to minimise

noise disturbance to residents and workers. This will be

achieved through… improving provision for, and giving

higher priority to, walking, cycling and the use of public

transport” 86.

3.5.14 The off-street servicing facilities created as part of VTI2

Permission 1 will reduce congestion related to vehicles

loading and unloading on-street and therefore reduce the

associated emissions and negative environmental impacts.

The City of Westminster highlights the relationship between

on-street servicing and congestion by stating “on amenity

grounds and in order to avoid the worsening of traffic

congestion and safety, the City Council will generally require

that the justifiable vehicular servicing needs of developments

are catered for off the street” 87.

3.6 The Timing of the development

3.6.1 It is, in my opinion, vitally important that VTI2 Permission 1 is

progressed now to ensure the delivery of the key transport

benefits that can help to accommodate the future growth and

provide an appropriate setting for the completed VSU

project.

86 Westminster City Council (2007) Unitary Development Plan Policy (CD B11) - TRANS 1 (as retained by the Local Development Framework) 87 Westminster City Council (2007) Unitary Development Plan Policy (CD B11) - TRANS 20 (as retained by the Local Development Framework)

31 20.05.11

3.6.2 The VSU project is expected to be fully delivered in 2018. By

progressing VTI2 Permission 1 now construction could

commence in September 2012 and the development and all

transport benefits could be delivered in 201688. This would

mean that VSU would be delivered in to the improved public

realm delivered by VTI2 Permission 1.

3.6.3 It is also important to appreciate that the existing Terminus

Place bus station urgently needs capacity enhancements.

As noted in the WCC Committee Report 2009 the Victoria

interchange is under stress and has been identified in the

TfL strategy document Transport 2025 (2006) as “one of the

(bus) stations in most need of improvement. One of the

critical issues is that the existing bus station cannot

adequately accommodate all existing services and provides

no scope to cater for further frequency increases” 89. The

Transport Assessment notes that the station is “very

congested… both for vehicles and for pedestrians, and

therefore the facility is prone to conflict between the two” 90

and “at times when there is no kerb space available buses

have been observed to stop in the middle of Terminus Place

carriageway and allow boarding and alighting to take place

whilst buses are up to three metres away from the kerb.”

This blocks other vehicles and exacerbates the problem91.

88 Westminster City Council (2011) Statement of Reasons – Paragraphs 4.3 – 4.4 89 Westminster City Council (2009) Planning & City Development Committee Report 5 February (CD C2) – Page 81 90 Land Securities/Steer Davies Gleave (2009) VTI2 Transport Assessment (CD C13) – Paragraph 2.45 91 Land Securities/Steer Davies Gleave (2009) VTI2 Transport Assessment (CD C13) – Paragraph 2.52

32 20.05.11

3.7 Conclusion

3.7.1 The VTI2 Permission 1 development plans will deliver much

needed transport benefits to the Victoria area and support

the objectives identified in current policy documents.

33 20.05.11

4.0 OBJECTORS TO THE CPO

4.1 Objector No. 8

Plot 19 – Gladys Usher of 5 Allington Street, London SW1E 5EB

4.1.1 The objector considers that there are no risks to pedestrians

in the Victoria area and that she is not aware of any

accidents occurring in the area.

4.1.2 The Transport Assessment provides details of accidents

occurring on the public highway between January 2005 and

December 2007. These figures have been provided by the

Road Safety Team in TfL. The Transport Assessment

highlights 289 accidents in the study area, of which 26% of

these involved pedestrians92. On the roads adjacent to the

site, 12 accidents occurred leading to slight pedestrian

injuries and six accidents occurred leading to serious

pedestrian injuries93.

4.1.3 The VAPB (2011) highlights that there is insufficient space

for pedestrian movement, leading to considerable conflict

with other road users94.

4.1.4 VTI2 Permission 1 will increase both the quality and capacity

of pedestrian space in the Victoria Area95 and will reduce

pedestrian-vehicle conflicts.

92 Land Securities/Steer Davies Gleave (2009) VTI2 Transport Assessment (CD C13) – Paragraphs 2.29 – 2.31 and Table 2.4 93 Land Securities/Steer Davies Gleave (2009) VTI2 Transport Assessment (CD C13) – Figure 2.7 94 Westminster City Council (2011) Draft Victoria Area Planning Brief (CD B19) – Paragraph 5.0.3

34 20.05.11

4.2 Objector No. 9

Plot 26 – Geldards on behalf of Hyder Consulting Group Limited

4.2.1 The objector is concerned that the CPO and SUO are being

dealt with separately and therefore “theoretically our client

could end up in a situation whereby no CPO goes ahead, no

break under the lease is exercised but no access to their

premises is in place.”

4.2.2 On behalf of LC25 Ltd I can confirm that the SUO will not be

pursued if the CPO is not granted and that the premises at

29 Bressenden Place will not be leased without access

rights.

4.3 Objector No. 15

Plot T1-2 AND T2-4 and 5 – Sainsbury’s Supermarkets

Ltd represented by CMS Cameron McKenna LLP

4.3.1 The objector suggests that the transport benefits related to

the CPO are marginal, do not justify the use of the CPO

power and could be achieved without the use of the CPO

powers.

4.3.2 The transport benefits VTI2 Permission 1 delivers are not

marginal and are recognised by the Council. The Council

identifies five transport benefits provided by the

development96:

 Provision of bus dispersal to perimeter of the site

95 Land Securities/Steer Davies Gleave (2009) VTI2 Transport Assessment (CD C13) – Paragraphs 5.20 – 5.22 96 Westminster City Council (2009) Planning Committee Paper, 5 February (CD C2) – Page 107

35 20.05.11

 Accommodating the delivery of the VSU project –

 A widened Allington Street

 Provision for Central London Cycle Hire Scheme

 Provision of north-south and east-west pedestrian

routes.

4.3.3 These are echoed by the Statement of Reasons which

justifies the use of the CPO powers and describes the

widened pavements and pedestrian only routes, the

increased capacity for buses, new pedestrian routes and

inclusion of the cycle hire scheme and accommodation of

VSU within the development97.

4.3.4 These transport benefits could not be delivered without the

use of the CPO and the following paragraphs explain why.

4.3.5 Bus Stops – The bus stops provided, as shown in Figure

5.4 of the Transport Assessment, could not be delivered

without the development. In particular, the stops on

Buckingham Palace Road require the removal of the

roadside buildings to provide space for the road to be

widened in order to maintain appropriate highway capacity,

whilst providing additional bus facilities98.

4.3.6 Pedestrian Routes – The siting, arrangement and footprint

of the proposed buildings have been based on a careful

97 Westminster City Council (2011) Statement of Reasons – Paragraphs 7.16 – 7.19 98 Gerald Eve (2009) Transport Benefits Briefing Note (CD C12) – Appendix C

36 20.05.11

analysis of pedestrian routes and desire lines and are

consistent with studies undertaken by both Intelligent Space

Partnership (ISP) and Alan Baxter99. These pedestrian

routes could not be created without the redevelopment of the

whole site.

4.3.7 Cycle Hire – The current location for cycle hire within the

development site is located at the junction of Buckingham

Palace Road and Bressenden Place and provides 26

docking spaces. The new site will accommodate a total of

44 docking points. Transport Assessment100 shows draft

locations for these points. In my professional opinion the

draft location of these docking stations is more attractive and

easier to access than the existing stand. There are also

more spaces provided.

99 Land Securities/Steer Davies Gleave (2009) Transport Assessment (CD C13) – Paragraphs 5.20 – 5.21 and Figure 5.2 100 Land Securities/Steer Davies Gleave (2009) Transport Assessment (CD C13) – Figure 5.6

37 20.05.11

5.0 STOPPING UP ORDER

5.1 Section 247 Context

5.1.1 On 4 January 2011 I drafted a letter addressed to Mr Jeffrey

Perkins of the Council, under cover of which I applied on

behalf of LC25 Limited for a SUO to permanently stop up

highway, which would be necessary in order to deliver VTI2

Permission 1.

5.1.2 On 7 January 2011 the Council advertised that it proposed to

make an Order under sub-section 247 (2A) of the Town and

Country Planning Act 1990 to authorise the stopping up of

parts of the highway in Allington Street, Warwick Row,

Buckingham Palace Road, Bressenden Place and Victoria

Street101.

5.2 Consultation

5.2.1 The City Council drafted text and arranged for the statutory

notice (s252(1) of the Town and Country Planning Act 1990)

to appear in the London Gazette and the Westminster

Chronicle (Trinity Mirror South) on 7 January 2011. The City

Council also arranged for the notices to be sent to all public

utility undertakers on 5 January 2011102.

5.2.2 The City Council provided the text for notices to be displayed

on site. The text for the notices is included in the Core

101 Westminster City Council (2010) Draft Order Text and plan showing the area to be stopped up (CD D7) 102 Westminster City Council (2009) List of Statutory Undertakers Contacted (CD D3)

38 20.05.11

Documents103. On 7 January 2011 I arranged for 31

laminated copies of the notice to be attached to lamp posts

and other infrastructure in prominent locations around the

public highway to be stopped up at Victoria104.

5.2.3 These notices were subsequently inspected on every

Monday, Wednesday and Friday throughout the statutory

consultation period (7 January 2011 – 4 February 2011), and

the inspector filled out a record sheet for each inspection,

commenting the condition of each notice, and replacing any

notices which had become defaced. The inspector also took

a photograph of each of the notices. Throughout the

inspection period, there were no occasions where a notice

had been removed between inspections and there was no

evidence of vandalism.

5.2.4 The electronic notice records and photographs have been

passed to the Mayor of London together with the necessary

referral material from the City of Westminster. The notices

were removed on 7 February 2011.

5.3 Stopping Up Order Land

5.3.1 It is necessary to stop up the order land as following the

implementation of the consented VTI2 Permission 1

development proposals, it will be either part of:

103 Westminster City Council (2011) Public Notice on the Stopping Up Order (CD D8) - 7 January 2011 104 Land Securities (2009) Map showing the locations of consultation notices (CD D5)

39 20.05.11

 The VTI2, Planning Permission 1 „Walkways

Agreement‟105;

 Land which will be built on; or

 A building maintenance strip of two metre width, along

the eastern edge of proposed Building 6b.

5.3.2 These areas of land are shown in the plans included in

Appendix B.

5.3.3 The method by which the SUO land was identified is

described below:

 The existing highway boundary was identified;

 The proposed VTI2, Planning Permission 1 Walkways

agreement boundary (as per the included plan within

the Section 106 Agreement) was overlaid;

 The proposed VTI2, Planning Permission 1 building

footprints were overlaid; and

 A building maintenance strip (of two metres width) was

added along the eastern façade of Building 6b.

5.3.4 Thus, the existing adopted highway within the VTI2, Planning

Permission 1 Walkways Agreement boundary, the additional

maintenance strip to the east of Building 6b, and (if not

already covered) the adopted highway within the footprint of

105 Westminster City Council (2009) Section 106 Agreement (CD C17)

40 20.05.11

any of the VTI2, Planning Permission 1 buildings is that to be stopped up, and this has been reflected in the SUO plan.

41 20.05.11

6.0 OBJECTORS TO THE STOPPING UP ORDER

6.1 Context

6.1.1 A total of four objections have been received in relation to

the SUO. At the time of writing, three objections have been

withdrawn, whilst negotiations are ongoing to resolve the

remaining one.

6.1.2 The outstanding objection is from the National Grid. Below I

outline the nature of their objection and how efforts have

been made to resolve it.

6.2 National Grid

6.2.1 On 14 January 2011 an email was received by Jeffrey

Perkins at the Council from the National Grid Plant

Protection Team. The email stated that a standard

assessment had been carried out with regard to their

operational gas and electricity apparatus on the site and

confirmed that National Grid objected to the proposed SUO.

6.2.2 Peter Brett Associates replied to the objection by letter on 8

March 2011106. The letter states that it is understood that

National Grid is likely to maintain its objection until such time

as „C4‟ costs have been paid. However, the letter argues that

as the main gas diversion and decommissioning is not likely

to start for a further 18 months to two years, it would be

106 Peter Brett Associates (2011) Letter to National Grid, 8th March 2011 (CD D4)

42 20.05.11

appropriate to formulate an agreement between LC25 Ltd

and National Grid.

6.2.3 The letter goes on to say that this agreement would consist

of LC25 ltd agreeing to pay the „C4‟ costs once notice had

been served on National Grid that it intends to implement the

development. In return for this declaration, National Grid

would withdraw their objection.

6.2.4 We await a response to this letter.

43 20.05.11

7.0 CONCLUSIONS AND SUMMARY

7.1.1 Delivering VTI2 Permission 1 development proposals

represents a significant opportunity to improve the

environment at Victoria and thus deliver improvements to

economic, social and environmental wellbeing. The public

transport interchange is an international gateway into the UK

(through Victoria Station‟s links to Gatwick Airport) and the

current congestion experienced in Terminus Place, at the

bus station and at the entrances to the Victoria Line ticket

hall creates a regrettable introduction to the capital and the

nation. The VTI2 Permission 1 development proposals will

deliver an environmental quality and physical capacity

consistent with the importance of the area, and the

significant demand it experiences.

7.1.2 Without the development proposals, the dispersal of buses

onto the surrounding streets would be at the expense of

highway capacity, but this simply cannot be foregone in this

location, where the mix of the London Inner Ring Road, the

boundary of the Congestion Charging Zone, Ceremonial

Routes and a intricate mix of TfL Road Network and

Strategic Road Network roads create a complex, but

important juncture in the strategic highway network which

serves London. Add in Victoria Coach Station and the Bus

operational hub at Victoria and the need for the highway

network to perform is further highlighted.

44 20.05.11

7.1.3 The bus station is already over capacity, and buses stopping

in the entrance to Terminus Place (sometimes in

Buckingham Palace Road) to allow bus passengers to alight

in time to connect with departing train services serves to

highlight the extent to which the interchange is creaking with

existing demand. The experience for passengers

interchanging from mainline rail to Victoria Line Underground

services in the morning peak has been well documented, but

will be addressed by the VSU scheme, which the VTI2

Permission 1 proposals are consistent with. I re-iterate here

that the key morning peak movement generated by VTI2

Permission 1, will be from the Underground to the site, and

there will be no worsening of the key issue that VSU is

aimed to address. With growth applied to the existing

problems, no one can be sure of what will happen if no

further capacity is provided (in excess of VSU) but the ability

for Victoria to serve its important neighbours and the millions

of people who use the interchange each year will be severely

restricted.

7.1.4 Aside from the critical opportunity for additional bus and

pedestrian capacity that the VTI2 Permission 1 development

proposals will provide, the quality of the environment

delivered by the development proposals will create a place

where people will at last want to spend time, and not pass

through to get to one of the many surrounding important

destinations.

45 20.05.11 AA/4/2

20th May 2011

Town and Country Planning Act 1990

Acquisition of Land Act 1981

Inquiry into:

City Of Westminster (Victoria Regeneration Permission One)

Compulsory Purchase Order 2011

Stopping Up Order 2011

Appendices to the Proof Of Evidence of

Roy McGowan - Steer Davies Gleave

On Transport Matters

APPENDICES

A Curriculum Vitae of Roy McGowan

B SUO Plans showing

1. Adopted highway to be stopped up via Section 247

2. Adopted highway to be stopped up via Section 247 as a result of

new buildings to be constructed following implementation of VTI2

Planning Application 1

3. Adopted highway to be stopped up via Section 247 as a result of

the Walkways Agreement within the Section 106 Agreement

4. Adopted highway to be stopped up via Section 247 to provide a

building maintenance strip adjacent to Building 6B

Appendix A

Curriculum Vitae of Roy McGowan

Roy McGowan Director

I am a Director at Steer Davies Gleave and joined in 1992 after fourteen years of transport planning in the public sector. I have extensive experience in regeneration, development, stadia and major events, transport interchange and masterplanning. My project experience includes the Kings Cross Railway Lands, Merseytravel Public Transport, Victoria Transport Interchange, Canary Wharf, major commercial and leisure development, Thameslink 2000, the Royal Opera House, the British Museum, The Ritz Hotel, and the Emirates, Lansdowne Road, Soccer City (Jo’burg) and Wembley stadia. As project manager and director for a large number of major projects I have considerable experience of strategic planning as well as managing and co-ordinating large technical teams. I have an in-depth knowledge of masterplanning, stadia design, major events, crowd flow analysis, development planning, interchange design, statutory procedures and is an experienced witness at Public Inquiries.

Knowledge and Expertise Qualifications Major Developments Roy has worked on a large number of major MSc Degree in Transport development proposals, including Victoria Transport Interchange, to Planning & Management deliver regeneration and integrated transport proposals; One New Change Uni of Westminster, 1988 which is a major mixed-used development to the east of St Paul’s

Cathedral; the Thameslink 2000 proposals in London for which he Diploma in Traffic & Highway Engineering presented evidence for Network Rail to the re-opened Inquiry in 2005 Middlesex Poly, 1985 (approved November 2006); Canary Wharf transport strategy; the Royal Opera House, major mixed-use developments in Covent Garden for the HNC in Civil & Traffic Mercers and St Martin-in-the-Fields and the Kings Cross Railway Lands and Engineering, Westminster Channel Tunnel terminal. He prepared evidence on CTRL for the College, 1980 Parliamentary Committee, and has given evidence to the RAF Hendon East Camp Inquiry, the Stadium 2000 Inquiry in Hackney Wick on public Member of the Institute of transport access, the Marylebone Telephone Exchange Inquiry, Thameslink Logistics & Transport 2000, the Victoria Station TWAO Inquiry, the Arsenal Coach Strategy Fellow of the Inquiry, and most recently the TWAO Inquiry for the Hitchin (Cambridge) Institute of Highway rail curve. Incorporated Engineers CPD Policy Support and Development Planning Roy has more than 30 years of Association of Project transport policy and development planning experience. He provided Managers (APM) expert advice and transport studies for the King’s Cross Railway Lands and Accredited, 2007 the Channel Tunnel Rail Link whilst with the London Borough of Camden. Roy also led the Development Control services for Camden providing the Years of Experience transport requirements and policy context for major proposals across the 14 Client side borough. Roy has prepared evidence for and appeared as an Expert 18 Consultancy Witness at numerous public inquiries and TWA inquiries over the last 20 years. (18 years with Steer Davies Gleave) Strategic Planning (Transport Planning) Roy has extensive strategic Based in London office transport planning experience. He has led a large number of strategic transport planning teams for both the public and private sectors including Duties and regeneration projects such as the Kings Cross Railway Lands, Victoria Responsibilities Transport Interchange and the London 2012 Olympic and Paralympic Director Games. Roy also provided Strategic Transport Planning services to Glasgow Planning and Development City Council in support of the City Council bid to host the 2014 Expert Commonwealth Games. Roy also has extensive experience of developing Public Consultation / Public Inquiry traffic and transport modelling commissions and has worked with project Traffic and Transportation teams for crowd flow and pedestrian modelling, simulation modelling such Studies as VISSIM and network modelling such as SATURN. Traffic and Transport Modelling Strategic Transport Planning

ROY MCGOWAN

CV 1 OF 2 Selected Projects

Project Client Year / Location Role 2004-ongoing, Major Development Victoria Transport Interchange Land Securities & TfL Project Director London, UK North West Development – 2007-2010, London, British Museum Project Director British Museum UK 2004-2006, London, One New Change Land Securities Project Director UK 2003-2004, London, St Martins-in-the-Field Dean & Chapter Project Director UK Arsenal Stadium and 2000-2007, London, Arsenal Football Club Project Manager Regeneration UK 1999-2007, London, Wembley Stadium WNSL Project Manager UK 1998-2001, London, Canary Wharf CWG Project Manager UK London Borough of 1988 – 1992, Kings Cross Railway Lands Project Manager Camden London, UK London 2012 Olympic Olympic Delivery 2005 – ongoing, Transport Planning Project Director Transport Strategy Authority London Abu Dhabi Surface Transport Department of 2008 - 2009, Abu Project Director Masterplan Transport, Abu Dhabi Dhabi Glasgow 2014 Commonwealth 2005-ongoing, Glasgow City Council Project Director Games Bid Glasgow, Scotland Kidderminster for Crossley Park 1997-1998, UK Project Manager Colgate Management Hendon for Allied Aerodrome Park 1997-1999, UK Expert Witness Dunbar Bus Priorities for Merseyside: 1992-1997, Merseytravel Project Manager Detailed Study & Designs Merseyside, UK

Park & Ride Study Leicester City Council 1995, Leicester, UK Principal Consultant

Channel Tunnel Rail Link Camden Council 1990, London Project Manager

Event Witness/Public Hitchin (Cambridge) Curve 2009 – 2010, Network Rail Project Director Inquiries TWA Hertfordshire

Arsenal Coach Parking Strategy Arsenal Football Club 2009, London Project Director

Victoria Station Upgrade (TWA) Land Securities 2008, London Project Director

Lansdowne Road Stadium (Oral LRSDC 2006, Dublin Project Director Hearing)

Thameslink 2000 Network Rail 2005, London Project Manager

RAF East Camp Allies & Morris 1998, London Project Manager

Stadium 2000 NHP 1997, London Project Manager

Marylebone Exchange British Telecom 1995, London Project Manager

Channel Tunnel Terminal Camden Council 1990, London Project Manager Parliamentary Inquiry

ROY MCGOWAN

CV 2 OF 2

Appendix B

SUO Plans

2 14

23 20 27 BUCKINGHAM

19 to 24 33 PH 1

The Royal Mews PINE APPLE CT 48 KEY: 26

35 to 37 to 35 41 27

25 39 33

47 Existing adopted highway

boundaryPH

6 to 18 to 6 3 to 5 to 3

43 31 52 Proposed VTI2 Planning WARWICK ROW

51 Victoria Hostel

The Mews

46 35

33 Permission 1 Walkways45

16 12 to 11

to 45 to 17 Agreement Boundary

49 PALACE STAG PLACE 15 to l3 Hotel Rubens

41 Proposed VTI2 Planning Alexandra Buildings LOWER GROSVENOR PLACE STREET

43 Permission 1 Building Footprints

22 10

1 to 16 to 1

5 11

15 30 1 Eland House Proposed VTI2 Planning Bag o'

3 Permission 1 building

19 Nails Office of the Deputy Prime Minister (PH) 18 maintenance strip

51 53 Bank 8 GARDENS MEWS EAST 13 13a Proposed VTI2 Planning 15a 16

GROSVENOR BRESSENDEN 22

Shelter

7 Permission 1 Planning Boundary 12 31 VICTORIA SQUARE PLACE 25 26 1 to 29 Proposed VTI2 kerb line

WARWICK ROW

Carrier House 13

Lake View Court 1 to 9

61 to 69 to 61 Carrier

10 20 15 57

1 to 9 Areas to be stopped up within 6 22

24 House Permission 1 Planning Boundary

BEESTON PLACE

1 Royal Westminster Goring

17 Hotel Hotel 26

GROSVENOR GARDENS 75 to 71 Portland House Bank ALLINGTON

19 STREET 21 Allington

Court

BUCKINGHAM PALACE ROAD 20 to 1 15 9

ALLINGTON STREET Bank EATON LANE 13 23 7a

7 19

5a 27 77

Allington Court Bank 5

29 to 33 PH 79 35 El Sub Sta STREET 37 PH Cardinal Place

39 3

44 83 46

GROSVENOR GARDENS VICTORIA STREET 48 Shelter ALLINGTON Theatre

45 Bank

143

145

52 147

Shelter 149 Bank 151 170 150 Bank

172 168 160 153 164 162 Duke of 158 144 138 York 148 146 (PH) 142 140

130 to 134 155 36

163

171

193

189 Bank

10 181

7 42

Victoria Arcade

179

207

175 to 175

191

44 161 GROSVENOR GARDENS 173

3 7 BP House 10 46 2 6

91 to 99 to 91 20 5 9 10 12 14 11 15 16 4 Victoria Bldgs 46 Shakespeare 22

1 to 14 50 (PH) ASHLEY PLACE

Evelyn

1 326 to 330

333

2 33

Mansions

3 15 to 39 Borax House

Terminal CAD REFERENCE: BASED UPON ORDNANCE SURVEY'S MAPS WITH THE PERMISSION OF THE CONTROLLER OF HMSO, (c) CROWN COPYRIGHT. 324 UNAUTHORISED REPRODUCTION INFRINGES CROWN COPYRIGHT AND MAY LEAD TO PROSECUTION OR CIVIL PROCEEDINGS. LA100032379 (2010)

Title: Rev. Date Comments Ckd App Drawn Scale. Rev. Victoria Transport Interchange 2 MSB 1:1250 @ A3 28-32 Upper Ground, London. SE1 9PD Tel: 020 7910 5000 Fax: 020 7910 5001 VTI2 Planning Permission 1 Client : Adopted Highway to be Stopped-up via Section 247 Drawing No. Sheet No. LC25 Ltd. 1 of 4 PLOT DATE:

2 14

23 20 27 BUCKINGHAM 19 to 24 33 PH

KEY: 1 The Royal Mews PINE APPLE CT 48 26

35 to 37 to 35 41 27

25 Adopted highway39 to be stopped up as a 33

47 result of thePH VTI 2 Planning application 1

29 buildings to be constructed

6 to 18 to 6 3 to 5 to 3

31 52

WARWICK ROW

51 Victoria Hostel

The Mews

46 35

33 45

16 12 to 11 38

to 45 to 17

49 PALACE STAG PLACE 15 to l3 Hotel Rubens

41 Alexandra Buildings

LOWER GROSVENOR PLACE STREET

22 10

1 to 16 to 1

5 11

15 30 1 Eland House

Bag o' 3

19 Nails Office of the Deputy Prime Minister

18 (PH)

51 53 Bank 8 GARDENS MEWS EAST 13 13a 15a 16

GROSVENOR BRESSENDEN 22

Shelter

7 12 31 VICTORIA SQUARE PLACE 25

26 1 to 29

WARWICK ROW

Carrier House 13

Lake View Court 1 to 9

61 to 69 to 61 Carrier

10 20

15 57 1 to 9 6 22

24 House

BEESTON PLACE

1 Royal Westminster Goring

17 Hotel Hotel 26

GROSVENOR GARDENS 75 to 71 Portland House Bank ALLINGTON

19 STREET 21 Allington

Court

BUCKINGHAM PALACE ROAD 20 to 1 15 9

ALLINGTON STREET Bank EATON LANE 13 23 7a

7 19

5a 27 77

Allington Court Bank 5

29 to 33 PH 79 35 El Sub Sta STREET 37 PH Cardinal Place

39 3

44 83 46

GROSVENOR GARDENS VICTORIA STREET 48 Shelter ALLINGTON Theatre

45 Bank

143

145

52 147

Shelter 149 Bank 151 170 150 Bank

172 168 160 153 164 162 Duke of 158 144 138 York 148 146 (PH) 142 140

130 to 134 155 36

163

171

193

189 Bank

10 181

7 42

Victoria Arcade

179

207

175 to 175

191

44 161 GROSVENOR GARDENS 173

3 7 BP House 10 46 2 6

91 to 99 to 91 20 5 9 10 12 14 11 15 16 4 Victoria Bldgs 46 Shakespeare 22

1 to 14 50 (PH) ASHLEY PLACE

Evelyn

1 326 to 330

333

2 33

Mansions

3 15 to 39 Borax House

2 14

23 20 27 BUCKINGHAM 19 to 24 33 PH

KEY: 1 The Royal Mews PINE APPLE CT 48 26

35 to 37 to 35 41 27

25 39 Adopted highway to be33 stopped up as a

result of thePH VTI 2 Planning application 1

31 Walkways Agreement

6 to 18 to 6 3 to 5 to 3

31 52

WARWICK ROW

51 Victoria Hostel

The Mews

46 35

33 45

16 12 to 11 38

to 45 to 17

49 PALACE STAG PLACE 15 to l3 Hotel Rubens

41 Alexandra Buildings

LOWER GROSVENOR PLACE STREET

22 10

1 to 16 to 1

5 11

15 30 1 Eland House

Bag o' 3

19 Nails Office of the Deputy Prime Minister

18 (PH)

51 53 Bank 8 GARDENS MEWS EAST 13 13a 15a 16

GROSVENOR BRESSENDEN 22

Shelter

7 12 31 VICTORIA SQUARE PLACE 25

26 1 to 29

WARWICK ROW

Carrier House 13

Lake View Court 1 to 9

61 to 69 to 61 Carrier

10 20

15 57 1 to 9 6 22

24 House

BEESTON PLACE

1 Royal Westminster Goring

17 Hotel Hotel 26

GROSVENOR GARDENS 75 to 71 Portland House Bank ALLINGTON

19 STREET 21 Allington

Court

BUCKINGHAM PALACE ROAD 20 to 1 15 9

ALLINGTON STREET Bank EATON LANE 13 23 7a

7 19

5a 27 77

Allington Court Bank 5

29 to 33 PH 79 35 El Sub Sta STREET 37 PH Cardinal Place

39 3

44 83 46

GROSVENOR GARDENS VICTORIA STREET 48 Shelter ALLINGTON Theatre

45 Bank

143

145

52 147

Shelter 149 Bank 151 170 150 Bank

172 168 160 153 164 162 Duke of 158 144 138 York 148 146 (PH) 142 140

130 to 134 155 36

163

171

193

189 Bank

10 181

7 42

Victoria Arcade

179

207

175 to 175

191

44 161 GROSVENOR GARDENS 173

3 7 BP House 10 46 2 6

91 to 99 to 91 20 5 9 10 12 14 11 15 16 4 Victoria Bldgs 46 Shakespeare 22

1 to 14 50 (PH) ASHLEY PLACE

Evelyn

1 326 to 330

333

2 33

Mansions

3 15 to 39 Borax House

2 14

23 20 27 BUCKINGHAM 19 to 24 33 PH

KEY: 1 The Royal Mews PINE APPLE CT 48 26

35 to 37 to 35 41 27

25 39 Adopted highway to be33 stopped to provide

a maintenancePH strip to building 6B

6 to 18 to 6 3 to 5 to 3

31 52

WARWICK ROW

51 Victoria Hostel

The Mews

46 35

33 45

16 12 to 11 38

to 45 to 17

49 PALACE STAG PLACE 15 to l3 Hotel Rubens

41 Alexandra Buildings

LOWER GROSVENOR PLACE STREET

22 10

1 to 16 to 1

5 11

15 30 1 Eland House

Bag o' 3

19 Nails Office of the Deputy Prime Minister

18 (PH)

51 53 Bank 8 GARDENS MEWS EAST 13 13a 15a 16

GROSVENOR BRESSENDEN 22

Shelter

7 12 31 VICTORIA SQUARE PLACE 25

26 1 to 29

WARWICK ROW

Carrier House 13

Lake View Court 1 to 9

61 to 69 to 61 Carrier

10 20

15 57 1 to 9 6 22

24 House

BEESTON PLACE

1 Royal Westminster Goring

17 Hotel Hotel 26

GROSVENOR GARDENS 75 to 71 Portland House Bank ALLINGTON

19 STREET 21 Allington

Court

BUCKINGHAM PALACE ROAD 20 to 1 15 9

ALLINGTON STREET Bank EATON LANE 13 23 7a

7 19

5a 27 77

Allington Court Bank 5

29 to 33 PH 79 35 El Sub Sta STREET 37 PH Cardinal Place

39 3

44 83 46

GROSVENOR GARDENS VICTORIA STREET 48 Shelter ALLINGTON Theatre

45 Bank

143

145

52 147

Shelter 149 Bank 151 170 150 Bank

172 168 160 153 164 162 Duke of 158 144 138 York 148 146 (PH) 142 140

130 to 134 155 36

163

171

193

189 Bank

10 181

7 42

Victoria Arcade

179

207

175 to 175

191

44 161 GROSVENOR GARDENS 173

3 7 BP House 10 46 2 6

91 to 99 to 91 20 5 9 10 12 14 11 15 16 4 Victoria Bldgs 46 Shakespeare 22

1 to 14 50 (PH) ASHLEY PLACE

Evelyn

1 326 to 330

333

2 33

Mansions

3 15 to 39 Borax House