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Thames Gateway Bridge

Rebuttal to Simon Wolff Charitable Foundation

Proof of Evidence

TFL/REB/2065/1

TABLE OF CONTENTS



1 INTRODUCTION ...........................................................................................3



2 THE REALITY CHECK – ARCHWAY AND OXLEAS WOOD ......................5



3 ACCESSIBILITY AND EMPLOYMENT.........................................................6



4 PACKAGE OF MEASURES........................................................................11



5 IMPACT OF CROSSRAIL. ..........................................................................12



6 THE REST OF ROSEWELL’S ARGUMENT...............................................13



7 SUMMARY ..................................................................................................19



8 CONCLUSION.............................................................................................21



9 ANNEX 1 .....................................................................................................22









TFL/REB/2065/1 2

1 Introduction



1.1 This rebuttal to the George Stern proof of evidence has primarily been

prepared by Professor Rosewell with help and support from colleagues at

Transport for London and the GLA. The rebuttal uses the headings and

paragraph numbers of Mr. Stern’s proof of evidence.







1.2 There are two central elements to Mr Stern’s argument:



• That the analysis shows that accessibility worsens employment prospects

rather than improving them

• That a ‘reality check’ shows that people would not live near a bridge





1.3 This argument helpfully highlights the fact that successful regeneration of

the area will have two aspects, as detailed in the following paragraphs.







1.4 First, addressing the disadvantage suffered by existing residents and

communities in the area around the TGB. As the Regeneration Statement

(D822) has shown, and witnesses like Dr Gray have reinforced, this area

has suffered persistent problems of multiple deprivation. These include low

incomes, low employment levels, high unemployment, poor educational

standards, health, housing and access to services (the factors measured by

the Index of Multiple Deprivation). These factors interact in complex ways;

each in turn has complex causes – tackling barriers to employment, for

example, requires addressing issues like access to affordable childcare, the

workings of the housing market, the existence of benefits traps and

discrimination as well as ensuring people can physically access jobs. Mr

Stern criticises Professor Rosewell for not demonstrating that accessibility

is the primary cause of poor employment performance and that tackling this

will have some direct, immediate and quantifiable effect. He suggests that if







TFL/REB/2065/1 3

it cannot explain everything, it explains nothing. The reality is that these

problems are not amenable to simple solutions (if they were, they would

have been resolved by now). All it is possible to do is to identify the

relationship between accessibility and an area’s employment potential and

therefore to highlight what could be possible if the Bridge were to be

provided, and the range of other issues highlighted above were to be

addressed. That is what Professor Rosewell’s analysis seeks to do. One

thing is certain, however – addressing childcare, skills or any of the other

questions mentioned earlier will be of little consequence if those involved

cannot physically reach jobs, either in the immediate area or further afield.

Mr Stern (and indeed none of the other objectors that have appeared before

the inquiry) have not shown that it is possible to improve the economic

prospects of an area by making it less accessible and the fact that this area

has suffered both persistently poor accessibility and high levels of

deprivation provides a suggestive counterfactual.





1.5 The second aspect is encouraging new people and enterprises to move

into, and invest in, the area. This will support the development and

regeneration of the area, and help build the kind of new urban quarter

envisaged in the London Plan (D620). This in turn will help increase the

skills and income levels in the area and provide a wider range of

opportunities and facilities for existing residents. The evidence submitted by

London First shows the importance that developers and potential investors

ascribe to the Bridge and the improved accessibility it will bring; far from

bearing out Mr Stern’s strictures about the Bridge being likely to blight

development, this supports the view that it is essential to it.





1.6 This rebuttal is structured around the sections of Mr Stern’s proof in

dealing with these points.









TFL/REB/2065/1 4

2 The Reality Check – Archway and Oxleas Wood



2.1 Sections 2 and 3 of Mr Stern’s proof argue that the outcome of the

Archway road proposal and the existence of previous proposals in Oxleas

show that roads create slums. He suggests that the Archway is now a

pleasant area although it was long blighted – largely of course by the

failure to resolve the issue one way or another for a long period. Others

have dealt in detail with the proposition that the TGB ‘inevitably’ leads to

the destruction of Oxleas Wood.



2.2 The Archway example is a false analogy. The road proposal that he

mentions was intended as part of a strategic, high capacity motorway

network for London as a whole, and was not intended to support the

regeneration of the Archway area. The Thames Gateway Bridge is

explicitly designed to provide a local link to help support the development

and regeneration of the Thames Gateway area. Unlike the Archway

proposal, it incorporates dedicated public transport facilities. The

existence of tolling arrangements to minimise use for longer distance

through traffic is another difference.



2.3 He also asserts that no one would live near a road bridge over the

Thames. Yet there is considerable evidence to suggest that if suitable

housing is available, then people certainly do. There is considerable high

priced housing in the vicinity of many of London’s bridges, including

Putney, Wandsworth, Battersea, and Hammersmith.



2.4 As the evidence submitted by Stuart Robinson on behalf of London First

shows, there is considerable interest by major developers in making

significant investments in residential and commercial development in the

area immediately around the proposed Thames Gateway Bridge. It is

unlikely that this would be the case if there were a real prospect of the

Bridge having the kind of impact Mr Stern asserts. In fact, London First’s







TFL/REB/2065/1 5

evidence suggests that the area’s real potential is being held back by the

lack of transport infrastructure, including the Bridge.



2.5 The Mayor has consistently made clear that the Thames Gateway Bridge

is intended to support local development and regeneration, and will not

form part of London’s inter-regional strategic road network by being linked

directly to the A2 through Oxleas Wood. Indeed, he directed Transport for

London to dispose of the properties acquired for this purpose for the

former East London River Crossing. The regeneration case put before the

inquiry is based on this assumption; none of the benefits identified depend

on linking the Bridge to the A2 through Oxleas Wood.





2.6 It is further noteworthy that Mr Stern does not address the arguments for

housing and population potential created by the Bridge, and instead

focuses only on employment. As Professor Whitelegg argued in his proof,

there is much more to regeneration than simply providing new jobs, and

we have argued that population increases are a key part of the

regeneration potential of the TGB (see Table 2.2 of TfL/76).



3 Accessibility and employment





3.1 In Section 4 Mr Stern suggests that the core argument in Professor

Rosewell’s proof (TfL/Proof/05/2) is that accessibility is poor, and so are

facilities, while employment rates are also low. This is indeed a description

of the current state of affairs, although it does not describe the core analysis

which has been undertaken to establish the extent to which the TGB might

relieve these problems. The use of the word ‘if’ to which Mr Stern objects

simply refers to a calculation of the scale of local need.





3.2 As a way of scaling the challenge (or sizing it to use Mr Stern’s

terminology), the ‘if’ statement uses a calculation to show how many more







TFL/REB/2065/1 6

jobs there would be if employment were at the same levels as in Western

boroughs. This calculation is an illustration, not the ‘thrust of the argument’.





3.3 In paragraph 4.4, Mr Stern asserts that there is no disparity in health care

provision between east and west London boroughs by adding together

hospital and medical practice activities. The figures he presents show there

are over forty per million fewer primary medical practice activities in eastern

boroughs than in western; the balance is only made up because there are

around 37 per million more hospital activities in eastern boroughs than

western. Given that health policy is to move away from hospital to primary

care, and the disparity in health outcomes between east and west (in 2000,

male life expectancy in Newham was the lowest in London; nearly four

years less than that in Richmond), the situation does not appear to be as

positive as Mr Stern asserts. The larger figure for hospital activities in East

London may also suggest use of hospitals to make up for lack of medical

practice facilities; it also raises the question whether it would be possible to

plan more rationally for health provision given the additional accessibility

the Bridge will bring. Certainly, in West London it is easier for people on

either side of the Thames to access medical facilities on the other side; this

option does not exist for people in this part of East London.





3.4 By supporting the growth of local population, and supporting the

development of new, sustainable, communities the Bridge will help ensure

that new medical facilities will be provided. It will also enable health

planners to ensure the most efficient use is made of the facilities that do

exist at present. As mentioned in the Interregional Planning Statement

(2004) (TfL/20 paragraph 5.3), “Meeting the demands of both improvement

in services and of growth will have major implications for health care. As an

example of the necessary co-ordination of planning and service provision,

the two Strategic Health Authorities in the London part of the Gateway (i.e.

the NE and SE London Strategic Health Authorities) have made a





TFL/REB/2065/1 7

systematic assessment of healthcare needs up to 2016, including capital

and revenue costs.”





3.5 Mr Stern seems to believe both that services are in fact adequate while the

TGB will cost £2bn (2065 SWCF Proof Paragraph 4.4). It is not clear how

he reaches either conclusion. The total construction cost estimates for the

TGB is £378 million (TfL/Proof/03/2 paragraph 8.1.4), and the total project

funding requirement up to the end of construction of the bridge is estimated

to be around £641 million (in nominal terms) (TfL/Proof/06/2 paragraph

3.1.4).



3.6 In Section 5.1 and 5.2 Mr Stern discusses the comparison of 5 boroughs in

the East and the West at some length as if these are the basis of the

analytical results. This is not the case. The analysis is based on a

comparison of all the wards in London. The tables included in Professor

Rosewell’s Proof of Evidence (TfL/Proof/05/2) provide some illustrative

comparisons of averages for this small selection of boroughs. These

comparisons were included to try and bring to life some of the differences

between east and west London. They are not presented as the basis of the

statistical argument nor can they be used as such.



3.7 Such a small sample cannot be used to provide valid statistical tests of

difference and this is not how it has been used in the evidence.





3.8 Since there are only 10 boroughs in this small selection (and the boroughs

were selected because the analysis is considering the actual situation in

London, not a hypothetical case in which there is an unrestricted range of

places to consider), it is not at all surprising that differences are not found to

be significant. If, however, we perform an analysis of the data for all the

wards in the boroughs, the probability that accessibility in the two cases is

the same becomes extremely small at 0.0001. In other words, there is a







TFL/REB/2065/1 8

99.999 per cent probability that the level of accessibility in these western

boroughs is higher than in the eastern ones.







3.9 One of the reasons is that each borough has a variety of levels of

accessibility within it. He particularly cites the examples of Richmond-upon-

Thames (western and low accessibility) and Newham (eastern and high

accessibility). Richmond’s apparently low accessibility is due to the fact

that it has large areas of open space (Richmond Park at 1,000 hectares is

about one-sixth of the total land area of the Borough); the areas with high

population and employment density (such as Richmond itself and

Twickenham) enjoy high levels of accessibility. Similarly, in Newham the

northern part, around Stratford, enjoy high levels of accessibility and this

skews the figure for the Borough as a whole. Once these distortions are

recognised and allowed for, Mr Stern’s point becomes far less striking.





3.10 Mr Stern also conducts a correlation analysis of these boroughs in 5.2.

Again, this is a partial exercise which cannot be expected with this small

sample size to provide a reliable conclusion.





3.11 Mr Stern’s second table seeks to show that high accessibility “equals” a

high level of residents claiming Job Seekers Allowance (JSA). Again, the

results are distorted by taking boroughs as the spatial framework for

analysis. It focuses on only one element of the index of multiple deprivation

(which also covers income, employment, education, health, housing and

access to services), and the result Mr Stern highlights – that some inner

western boroughs show relatively high levels of JSA claims – is largely due

to the presence of high levels of unemployment in inner London (for a range

of reasons, including lack of affordable childcare, existence of benefit traps,

the housing market and longstanding problems of discrimination), where the

radial nature of the city’s transport network also means that there is high





TFL/REB/2065/1 9

accessibility. In any event, it is not the promoters’ case that a high level of

accessibility “equals” low unemployment, rather that tackling problems of

unemployment is extremely difficult without adequate accessibility

accompanied by necessary complementary measures.





3.12 Mr Stern has therefore set up a straw man which he then demolishes. This

does not in any way provide a refutation of the analysis which has been

developed to establish the role that accessibility has in supporting economic

performance.



3.13 In paragraph 5.4 Mr Stern suggests that the TGB does not make a

significant difference to accessibility in East London. He states that he has

already shown that a difference of 12 is not significant and TGB (without

Crossrail) only makes a difference of 6 points. This not a valid procedure

even on Mr Stern’s own terms. His original test looks at the probability that

two sets of data (in this case the two groups of boroughs) can be

considered to be significantly different. He concludes in section 5.1.7 that

the differences between them are not large enough to be able to draw this

conclusion.



3.14 However, testing the impact of the TGB on accessibility on one set of

boroughs only, i.e. the eastern set of boroughs, requires a different

statistical test. A suitable test for significance that we can use in this

instance is known as the paired t-test. As we are looking at a before-and-

after scenario on an identical set of areas, using the same index, this test is

entirely appropriate. This test is not to be confused with the basic t-test,

which is used to compare sets of values that cannot be paired, for example

when comparing boroughs in the East with boroughs in the West.





3.15 The paired t-test works by looking at the set of differences between the

paired values, and calculating how likely that the average of this set is equal







TFL/REB/2065/1 10

to zero. Comparing the average accessibility of the five boroughs in East

for 2016, with and without the TGB in place (assuming that Crossrail has

not been built) we have a set of positive differences equal to 5, 9, 7, 3 and

4. As all five of these differences are positive, casual observation would

suggest that there is a slim chance that the average of the values is equal

to zero. This is confirmed by the paired t-test which shows that the

difference is significant at the most demanding level1.



4 Package of measures





4.1 Mr Stern’s approach to accessibility is purely quantitative. He does not

address the different roles that each mode makes to development and

regeneration – access by road over the Bridge is not the same as access

by train via Crossrail or by other forms of public transport. This point is

particularly relevant when delivery of goods and services is considered.

Goods vehicles comprise 20% of peak hour TGB flows and 21% in the

inter-peak (Table 10 of TfL/Proof/04/5). This is one of the primary reasons





1

The paired t-test can be defined in the following way. Given two paired sets Xi

and of Yi measured on n values, the paired t-test determines whether they differ

from each other in a significant way under the assumptions that the paired

differences are independent and identically normally distributed. The test

statistic t is defined as:



n(n − 1)

t = (X −Y ) n

ˆ

∑(X ˆ

− Yi ) 2

i

i =1





ˆ ˆ

where X i = ( X i − X ) and Yi = (Yi − Y ) . This test statistic has (n -1) degrees of

freedom.



Our data returns a t-value of 5.20 of 4 degrees of freedom. Examining what is

known as the Student’s t-distribution we find that the probability of observing a t-

value this large, or greater, is equal to 0.0065. In other words, there is less than

a 1% chance that there is no difference in average accessibility through the

introduction of the Thames Gateway Bridge.





TFL/REB/2065/1 11

why it is only sensible to consider the Bridge as part of a package of

transport proposals to support development of the Thames Gateway area.





4.2 It is not clear what point Mr Stern is trying to make in 5.5.1. Mystagogy is

defined as a process of settling into the Church post Baptism, which Is not

very helpful. TfL regards the package of measures as important and not a

distraction.



4.3 The analysis presented in the Regeneration Statement (D822) and

Professor Rosewell’s proof (TfL/Proof/05/2) shows that there is a

relationship between accessibility and employment and population

potential. It also suggests as do all other sensible analysis that other

policies will be needed to realise that potential. The ‘package of measures’

outlines the other policies in place to show that there is some likelihood that

potential can in fact be realised.



5 Impact of Crossrail.





5.1 Crossrail is indeed important and in the annex to TfL/76, Professor

Rosewell has calculated in potential employment and population impact

(with and without TGB). Crossrail but it is also different from the TGB and

provides different benefits. For Bexley in particular both are needed, as

shown by Table 2.1 and the annex to TfL/76. These are different not

alternative investments. Moreover, Crossrail in orders of magnitude is more

expensive and therefore its benefits also need to be greater to justify it.



5.2 In paragraph 5.5.2 of his proof, Mr Stern appears to be advocating

changing the investment priority within London from east to west. Such an

approach would mean a wholesale change to the strategy outlined in the

London Plan (D620), which has been adopted following an exhaustive

examination in public. This, of course, is based around accommodating job

and population growth within London’s existing boundaries without





TFL/REB/2065/1 12

encroaching either on the Green belt or London’s open spaces. This can

only be achieved if efficient use is made of the city’s land resources

available and east London is made the priority area for new development,

regeneration and investment. A switch of investment of the kind advocated

by Mr Stern would mean consideration would have to be given to less

sustainable options for dealing with London’s growth.



6 The rest of Rosewell’s Argument





6.1 In paragraphs 5.6.1 to 5.6.9, Mr Stern suggests that Professor Rosewell

makes the argument that the TGB is intended to create a catchment area

which will make possible a high wage high productivity economy similar to

that in central London. This is a miss reading of Professor Rosewell’s Proof

(TfL/Proof/05/2) Section 5.1 to 5.5. These parts of her proof firstly illustrate

the change in accessibility that the TGB brings and then whether there is

any site availability to support regeneration. Mr Stern appears to accept the

contention here that neither sites nor infrastructure alone are enough to

create jobs.





6.2 Section 5.5 of Professor Rosewell’s Proof (TfL/Proof/05/2) addresses the

general contention that there is a need in London for more and better

infrastructure. This section cites a number of pieces of analysis, but makes

no assertion that this analysis has direct application to the TGB. It is

therefore incorrect to say as Mr Stern does in 5.6.9, that there are missing

links in the argument here: rather the section aims to establish that it is

worth examining whether such links exist. In her 5.5.4, Professor Rosewell

begins to report on the analysis which was undertaken directly of this

matter.





6.3 In paragraph 5.6.10 of his proof, Mr Stern suggests that Professor Rosewell

has accepted that there is no link between population density and





TFL/REB/2065/1 13

accessibility. This is based on a selective quotation from Professor

Rosewell’s proof; paragraph 5.5.3 reads in full:



“The study also looked at the relationship between population

density and accessibility. This shows that population density

increases with the number of jobs that can be accessed. However,

the relationship is not as strong as in the case of employment and it

reaches a peak at around access to 2 million jobs. As access

increases further, population density does not rise on average. (see

figure E3). The report concluded that ‘accessibility plays some role

in explaining or enabling higher population density but it is clearly

only one of several important factors”





6.4 Mr Stern deals with the results of the analysis of the impact of the TGB in

paragraphs 5.6.11 to 5.7.5. It would appear that he has not noticed that

these results are based on the analysis reported in the Regeneration

Statement (D822), although this is specifically stated in Professor

Rosewell’s 5.5.4. He therefore suggests that the results are contingent on

the inclusion of the City of London, although this is not the case and this

area is excluded from the analysis. Moreover, Professor Rosewell has

explained that the potential influence of central London is moderated in her

results, with the constrained scenario excluding it altogether and the

adjusted scenario providing an estimate midway between the result

including central London and one which excludes it (Technical Appendix to

the Regeneration Statement (D822)).





6.5 Mr Stern appears to attack Professor Rosewell for ‘admitting’ that there is

no perfect model and that causation is not easy to establish. He concludes

that no conclusion can therefore be drawn. However, he himself concludes,

on the basis of a simple analysis of only 10 boroughs, that transport

infrastructure has no effect on employment. If he wishes to argue that a

detailed and careful analysis cannot draw conclusions, then this applies still

more strongly to a crude one. Professor Rosewell has made the careful

conclusion that accessibility is associated with better employment and





TFL/REB/2065/1 14

population performance. She uses this analysis to present the implications

for the area surrounding the TGB of a change in accessibility. She also

concludes that the evidence suggests that a change in accessibility will

require additional policies. This argument appears to be ignored by Mr

Stern.





6.6 Mr Stern takes Professor Rosewell to task (5.6.15) for her comments

regarding other river crossings. The point she was seeking to make is not

that it is impossible to identify regeneration benefits from crossings

elsewhere - although there is some evidence of positive, if modest,

economic impacts from both the Humber and Severn crossings and of

strong population growth around the Tagus Bridge in Portugal (cited in the

Department for Transport’s Transport and City Competitiveness – Literature

Review). Rather it is that this inquiry is considering a proposal in London,

intended to assist with the regeneration of a particular part of the city, and

that nowhere else in the United Kingdom can completely replicate

conditions here.





6.7 Mr Stern in sections 5.7.1 to 5.7.4 draws attention to special characteristics

of the City of London. Since Professor Rosewell’s methodology has not

included the City, Mr Stern’s comments are not considered relevant. In

section 5.7.2 he asserts that the results from the analysis are ‘not exciting’

because the TGB ‘only’ generates an increase in employment of 8 per cent

for the TGB boroughs. It is not clear how he calculates this increase.

Using the data from the modelling exercise the increase in fact ranges

between 5.1 per cent and 7.9 per cent, depending on which scenario is

used. However, in the context of annual average growth of 2 per cent over

the last 8 years, and 1.4 per cent for the five boroughs of most interest, a

potential increase of this scale is considered by Professor Rosewell to be

highly significant.







TFL/REB/2065/1 15

6.8 Mr Stern asserts in 5.7.5 that correlation is the ‘obvious way of finding out if

employment density depends on access’. This is not true. Correlation is a

good screening device but neither it nor multiple regression techniques

provide an absolute test unless one can be sure that all the relevant

variables have been included in the analysis, and moreover that the

relationships are linear. An inspection of the Chart that Mr Stern

reproduces in 5.7.5 makes it clear both that there may well be a link, that it

is complex, and almost certainly non-linear. It is for these reasons that

Cluster analysis has been used. Cluster analysis enables us to capture all

the effects of missing variables and to abstract from them to identify the

impact of accessibility alone.



6.9 Mr Stern attacks the detailed analysis which looks at accessibility,

employment and population for all wards by asserting that it is useless

because it is technical and because no error bounds are presented (5.7.10).



6.10 The analysis is indeed technical. This is because it is a technical problem to

abstract from a range of measured and unmeasured reasons why

employment and population might exist in a particular local area in order to

focus on the variable of interest. The technical route chosen is explained in

both ordinary language and in equations in the Regeneration Statement

(D822). Further development of the approach and explanation in given in

TfL/76 in reaction to the Inspector’s queries. Mr Stern admits in 5.7.10 that

the analysis is not dishonest or discreditable but only that it does not

provide precise numbers.





6.11 Part of Table 8 is taken from Professor Rosewell’s proof (TfL/Proof/05/2)

as providing evidence of results which do not have any error bounds. In

fact Table 8 provides a range of results which cover both uncertainties

about modelling and about the range of infrastructure changes. It is

misleading to say that these forecasts ‘look very precise’ as Professor

Rosewell has been at pains to point out that precision should not be





TFL/REB/2065/1 16

expected. The impression of precision is given solely by this selective

quotation.



6.12 Mr Stern also includes in this table estimates of actual employment. He

does not give a source for these. The latest estimates for employment in

Greenwich and Newham are for 2003 and show 62,614 and 63,611. The

data available at the time the analysis was conducted for 2001 gave 57,989

for Greenwich and 65,597 for Newham. Since then there have been

revisions to the data and the latest estimates for 2001 give Greenwich at

61,495 and Newham at 70,653. On the basis of the most recent estimates

the increases that Mr Stern quotes should read 10.7 per cent and 10.0 per

cent.





6.13 Mr Stern conducts an alternative analysis in paragraphs 5.7.14 to 5.7.18.

He performs a simple linear regression between employment density and

the accessibility index and concludes that it is too poorly specified to draw

any conclusions from. From this in turn he concludes that it is impossible to

draw any conclusions from any other analysis either. This is not valid either

in statistics or logic. The simple analysis is indeed poorly specified. No

valid conclusion can be drawn from any statistics based on this analysis if

there are any missing variables likely to affect the result. The existence of

missing variables means that the coefficients will be biased and so is the

performance of the relationship. Since Mr Stern wishes to argue that

accessibility does not have any impact he must admit that some other

variables are relevant to employment. If they are not included in the

regression analysis he cannot conclude anything about the role of

accessibility one way or the other.





6.14 Second, it does not follow from the fact that a simple analysis does not work

that a more careful one which tries to address the issue of missing variables

therefore fails. While the desire to ‘size’ a potential relationship at the





TFL/REB/2065/1 17

outset is a sensible one, only the resultant more careful analysis can

support conclusions.



6.15 In paragraph 6, Mr Stern concludes that Professor Rosewell has shown that

growth may come with better access but also that decline may come. This

is not the result of the analytical analysis which shows that in London, better

access generally leads to better performance, though the extent of change

varies. He also draws the conclusion from a very limited data set that better

access goes with greater unemployment as a generality, whilst he attacks

Professor Rosewell for drawing conclusions from a much wider data set.

Finally he states that his is a common sense conclusion, that a slum will be

created by ‘putting the place people want to live and work next to or under a

motorway’. But he presents no evidence himself to support such a strong

contention.





6.16 Mr Stern argues in 5.6.14 that ‘In general, her whole approach of relating

access to employment, seems dubious’. As he suggests in his proof, It is

worth doing a reality check on this statement. If access had no role to play,

then it is hard to see why cities would exist. Cities impose costs on their

inhabitants, yet people are willing, and indeed increasingly willing, to inhabit

them. To state the obvious, cities bring people and activities together – in

other words gives them access. It seems fairly obvious that access has

something to do with why people live and work in cities. It then becomes an

empirical question to try and disentangle this effect from all the other

elements in the drivers of activity. This has been attempted here, with

reasonable robustness. It is not the whole story, which requires other

policies too.



6.17 Because this is an empirical question, other locations and places are not

relevant. We cannot compare the impact of accessibility on a major world

city with its impact in rural locations, or cities with different sets of activities.









TFL/REB/2065/1 18

There are many examples of where links have led to prosperity. Almost all

towns are built around such links.







7 Summary





7.1 Mr Stern says that Professor Rosewell’s figures show a negative link

between accessibility and employment. Nowhere does he show this. He

does use a correlation between unemployment and accessibility for five

boroughs but this is neither the same thing nor valid.





7.2 Mr Stern says that Professor Rosewell uses a complex argument to link

accessibility and employment. Professor Rosewell considers it simple and

straightforward to say that the ability to access an area will have something

to do with employment. Mr Stern then says Professor Rosewell relies on

rail data to prove this, which is not the case. The data used in the analysis

of the impact of the TGB covers all principal forms of access and not rail

data alone.





7.3 The City is excluded from the analysis of the impact of accessibility

changes from the TGB so it is not valid to say the theory has been built

around the City.



7.4 Mr Stern asserts that no reference is given for the conclusion that

employment density in London is associated with a strong economy, though

this is clearly referenced in paragraph 5.4 of Professor Rosewell’s proof as

The Case for London (D752). Moreover, this is not key to the argument

about a link between accessibility and employment potential. He says that

Professor Rosewell admits there is no link to population. Nothing could be

further from the case. Although it is the case that the population effect of

increasing accessibility tails off in comparison with employment (Professor









TFL/REB/2065/1 19

Rosewell (TfL/Proof/05/2) paragraph 5.5.7), the effect of TGB is large for

the particular changes which it creates.





7.5 Mr Stern misunderstands how modelling has been used. A partial model

which purported to capture accessibility effects while leaving variables

unmeasured would not be valid. Equally a model, as created here, which

employs a technique to wrap up all the effects other than accessibility

cannot guarantee that all the other effects will remain constant in the future

while only accessibility changes. It is for this reason that the calculation of

the impact of the TGB have been labelled ‘potential’ employment and

population changes. Changes in other aspects of the situation will also be

needed to realise potential.



7.6 No reference is given for Professor Rosewell stating that any level of

employment can be reached either with or without the TGB.



7.7 Mr Stern states that the proposition that accessibility is a necessary though

insufficient condition for employment is not proven. But he sets no standard

that he would be willing to accept that for proving such a proposition. He

then repeats that better accessibility is associated with lower employment

which Figure 1 in his 5.7.5 shows clearly not to be the case.



7.8 Mr Stern criticises the analysis of employment and accessibility for being

technical and complex. However, the central concepts of the modelling are

straightforward even if the application is technically complex - if the world is

complex, then so too must be the models which try to capture it.



7.9 Mr Stern presents a sizing calculation which is invalid as it relies on an

assumption that no other features are missing from the model.



7.10 In addition to the actual calculation being invalid, Mr Stern’s presentation is

also wrong. He says that his central view is that the TGB would create an

8% increase in employment ±13%. This means that the range in his view is





TFL/REB/2065/1 20

between an increase of 21% (8+13) and a fall of 5% (8-13). Taking his

example of Greenwich, where he says current employment is 85,000, this is

a range of between 102,850 and 80,750. The range of change is between

17,850 and a fall of 4,250. This is certainly not saying that a fall is as likely

as an increase. Further he presents a range of between 54,000 and

129,000 and it is not at all clear how Mr Stern is able to calculate such

figures.



7.11 It should be noted that employment in Greenwich is not anywhere near

85,000, and the latest Annual Business Inquiry gives a figure of 62,614 for

2003 (see paragraph 5.13 of this Rebuttal).



8 Conclusion





8.1 Mr Stern’s criticism of Professor Rosewell’s methods and conclusions boil

down to the fact that she has not claimed them to be something they are

not. If they were presented as forecasts, Mr Stern would doubtless be

critical of them for claiming too much. Critics of more conventional

approaches to identifying the economic development impacts of

infrastructure proposals have rightly pointed to the dangers of claiming

more precision than is possible in reality.



8.2 What Professor Rosewell’s analysis does do is to provide some theoretical

basis for the commonsense proposition that economic and social

development – in short, ensuring sustainable communities – is impossible

without accessibility. While Mr Stern argues this cannot be proven, he

equally does not bring forward any evidence (or “reality check”) to disprove

this proposition.









TFL/REB/2065/1 21

9 Annex 1



Extra Units Costs on Both Sides £840m





9.1 TfL do not accept that any of the additional construction or enhancements

referred to by Mr Stern is necessary.



9.2 In any event, Mr Stern’s figure of £20 million per kilometre for a single lane

is not accepted. The Limehouse Link was one of the most expensive roads

ever built and not a relevant source for costing.



Additional downside to living in Barking





9.3 The average number of households per km of road in inner London tells us

very little about the number of households that might live along widened

roads even if these were to be built. Further there is no evidence that each

household being in such circumstances would lose £10,000.



9.4 Even if roads were enhanced in the manner Mr Stern suggests, it is not

accepted there would be an automatic 16% increase in traffic.



Oxleas Wood





9.5 There is no basis for suggesting that the TGB would be extended via

Oxleas Wood to the A2. Reference should be made to TfL’s rebuttal to the

MTRU report on this subject (TFL/REB/4982/2).



Summary of Costs





9.6 Mr Stern’s figure of £1200m presumably includes Mr Ellison’s figure of £378

million referred to on page 2 of the document. This estimate includes the

cost of approach roads as well as the bridge itself and Mr Stern cannot

include this as any further part of “extra costs”.









TFL/REB/2065/1 22

Pollution





9.7 TfL does not accept any of the following:



• that there would be a 16% increase in traffic

• that a 16% increase in traffic would mean a 16% increase in pollution

• that any increase would apply to the entire population of the area within Mr

Stern’s two circles radius.



Non-Transport Spending





9.8 Alternative options have been assessed in the Annex to Tfl/REB/4982/1.

Since neither a heavy rail nor a DLR extension would meet the needs of

business to carry goods and services across the area.



9.9 So far as non-transport spending TfL agree with Mr Stern that other policies

and programmes are required to ensure that regeneration occurs in this

area.



Transport Spending





9.10 The London Plan (D620) contains proposals for 2 major street tram

systems, both of which are currently being progressed. The TGB serves an

entirely different purpose to these systems.



9.11 It is already intended to construct the GWT and the ELT and connect them

over the TGB using segregated public transport lanes. These will be

supplemented by other bus services. If at any stage there is sufficient

demand justification upgrade to the transit systems this will be considered.









TFL/REB/2065/1 23



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