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Last Modified: 05 February 2009

Victoria Station Upgrade Public Inquiry - London Underground Limited (LUL) Documents

STATEMENT OF CASE

London Underground Limited (LUL) Statement of Case [184 KB]

PROOFS OF EVIDENCE

Philip McKenna (Scheme Need and Benefits)
LUL.P1 Proof of Evidence of Philip McKenna (Scheme Need and Benefits) [133 KB]
LUL.P1S Proof Summary of Philip McKenna (Scheme Need and Benefits) [37 KB]
LUL.P1A
Appendices of Philip McKenna (Scheme Need and Benefits) Vol 1 [19 KB]
Appendices of Philip McKenna (Scheme Need and Benefits) Vol 2 [8,902 KB]
LUL.P1B Errata to Proof of Evidence of Mr McKenna [8 KB]
LUL.P1C Capital Cost Analysis [7 KB]
LUL.P1D Capital Cost Analysis with footnote added
LUL.P1/REB/OBJ3 Rebuttal Proof of Evidence of Philip McKenna [158 KB]
LUL/P1/REB/OBJ12 Rebuttal Evidence and appendices of Philip McKenna [1,425 KB]
Brian Bell (Engineering and Construction)
LUL.P2 Proof of Evidence of Brian Bell (Engineering and Construction) [157 KB]
LUL.P2S Proof Summary of Brian Bell (Engineering and Construction) [56 KB]
LUL.P2A Appendices of Brian Bell (Engineering and Construction) [3,783 KB]
LUL.P2B Errata to the Proof of Evidence of Mr Bell [12 KB]
LUL.P2C Air Quality Information Note and e-mail sending it to Victoria Interchange Group
LUL.P2D Note and copy of VSU Project Environmental Strategy [1,164 KB]
LUL.P2E Note relating to Diversion of BT Ducts [51 KB]
LUL.P2F Note on Diversion of Telecommunications Services in Victoria Street with reference to a fire in Manchester in March 2004 [698 KB]
LUL.P2/REB/OBJ3 Rebuttal Proof of Evidence of Brian Bell [91 KB]
LUL.P2A/REB/OBJ3 Appendices to Rebuttal Proof [746 KB]
LUL-P2-REB-OBJ12 Rebuttal Proof of Evidence of Brian Bell [585 KB]
LUL-P2A-REB-OBJ12 Appendices to Rebuttal Proof of Brian Bell [1,993 KB]
Alan Finch (Scheme Selection)
LUL.P3 Proof of Evidence of Alan Finch (Scheme Selection) [73 KB]
LUL.P3S Proof Summary of Alan Finch (Scheme Selection) [27 KB]
LUL.P3A Appendices of Alan Finch (Scheme Selection) [10,947 KB]
LUL.P3B Corrigenda to Mr Finch’s Evidence
LUL.P3C Option Plans from Supplementary Environmental Statement with Victoria Palace Theatre and Saudi Building superimposed
LUL.P3/REB/OBJ3 Rebuttal Proof of Evidence of Alan Finch [119 KB]
LUL.P3A/REB/OBJ3 Appendices to Rebuttal Proof of Evidence of Alan Finch [5,729 KB]
Robert Essler (Ground Treatment)
LUL.P4 Proof of Evidence of Robert Essler (Ground Treatment) [93 KB]
LUL.P4S Proof Summary of Robert Essler (Ground Treatment) [34 KB]
LUL.P4A Appendices of Robert Essler (Ground Treatment) [2,714 KB]
LUL.P4B Enlarged versions of Mr Essler’s Appendix 2 of LUL.P4A and Appendices 1 & 2 of LUL.P4A/REB/OBJ3
LUL.P4/REB/OBJ3 Rebuttal Proof of Evidence of Robert Essler [88 KB]
LUL.P4A/REB/OBJ3 Appendices to Rebuttal Proof of Evidence of Robert Essler [5,557 KB]
Chris Williamson (Architecture and Urban Design)
LUL.P5 Proof of Evidence of Chris Williamson (Architecture and Urban Design) [70 KB]
LUL.P5S Proof Summary of Chris Williamson (Architecture and Urban Design) [33 KB]
LUL.P5A Appendices of Chris Williamson (Architecture and Urban Design) [3,322 KB]
Rupert Thornely-Taylor (Noise and Vibration)
LUL.P6 Proof of Evidence of Rupert Thornely-Taylor (Noise and Vibration) [116 KB]
LUL.P6S Proof Summary of Rupert Thornely-Taylor (Noise and Vibration) [32 KB]
LUL.P6A Appendices of Rupert Thornely-Taylor (Noise and Vibration) [157 KB]
LUL.P6B Commitments made by London Underground Limited to Victoria Palace Theatre with respect to noise and vibration [80 KB]
LUL.P6C Information requested of Mr Thornely-Taylor during cross-examination by Victoria Interchange Group
LUL.P6D Note on Involvement of Rupert Taylor’s Practice in the VSU Project [17 KB]
LUL.P6/REB/OBJ3 Rebuttal Proof of Evidence of Rupert Thornely-Taylor [38 KB]
LUL/P6/REB/OBJ12  Rebuttal Proof and Appendices of Rupert Thornely Taylor [149 KB]
Richard Bland (Surface Transport)
LUL.P7 Proof of Evidence of Richard Bland (Surface Transport) [159 KB]
LUL.P7S Proof Summary of Richard Bland (Surface Transport) [48 KB]
LUL.P7A Appendices of Richard Bland (Surface Transport)
LUL.P7B Errata to Proof of Evidence of Richard Bland [7 KB]
LUL.P7C Errata to Rebuttal of Mr Bland to VIG [21 KB]
LUL.P7D Information in response to Items requested of Richard Bland (Part 1) [59 KB]
LUL.P7D(Rev) Revised Clarifications requested of Mr Bland in cross-examination by VIG
LUL.P7E Information in response to Items requested of Richard Bland (Part 2) [26 KB]
LUL.P7E(Rev) Revised Clarifications requested of Mr Bland in cross-examination by VIG Part 2
LUL.P7F Supplementary Information on Pedestrian Signal Times (to be read in conjunction with LUL.P7A Table RB13.1 & LUL.P7 (Rev) [183 KB]
LUL.P7G Note on effect on VSU of removing CCWEZ [169 KB]
LUL.P7G Rev Revised note on effect on VSU of removing CCWEZ
LUL.P7H Response to OBJ/12/P2/A15
LUL.P7/REB/OBJ3 Rebuttal Proof of Evidence of Richard Bland [37 KB]
LUL/P7/REB/OBJ12 Rebuttal Proof of Richard Bland [128 KB]
LUL/P7A/REB/OBJ12 Appendices to Rebuttal Proof of Richard Bland [957 KB]
Colin Smith (Property)
LUL.P8 Proof of Evidence of Colin Smith (Property) [122 KB]
LUL.P8S Proof Summary of Colin Smith (Property) [38 KB]
LUL.P8A Appendices of Colin Smith (Property) [1,196 KB]
LUL.P8B Errata to Evidence of Mr Smith
LUL.P8/REB/OBJ3 Rebuttal Proof of Evidence of Colin Smith [148 KB]
LUL.P8A/REB/OBJ3 Appendices to Rebuttal Proof of Evidence of Colin Smith [2,467 KB]
Robert Thorne (Setting of Listed Buildings and Conservation Areas
LUL.P9 Proof of Evidence of Robert Thorne (Setting of Listed Buildings and Conservation Areas [63 KB]
LUL.P9S Proof Summary of Robert Thorne (Setting of Listed Buildings and Conservation Areas) [15 KB]
LUL.P9A Appendices of Robert Thorne (Setting of Listed Buildings and Conservation Areas) [4,294 KB]
John Mason (Physical Effects on Listed Buildings)
LUL.P10 Proof of Evidence of John Mason (Physical Effects on Listed Buildings) [44 KB]
LUL.P10S Proof Summary of John Mason (Physical Effects on Listed Buildings) [15 KB]
LUL.P10A Appendices of John Mason (Physical Effects on Listed Buildings) [1,269 KB]
LUL.P10B Errata to Mr Mason’s Rebuttal Proof of Evidence [7 KB]
LUL.P10/REB/OBJ3 Rebuttal Proof of Evidence of John Mason [219 KB]
Philip Rowell (Planning)
LUL.P11 Proof of Evidence of Philip Rowell (Planning) [228 KB]
LUL.P11S Proof Summary of Philip Rowell (Planning) [39 KB]
LUL.P11A Appendices of Philip Rowell (Planning) [2,075 KB]
LUL.P11B Errata sheet to Mr Rowell’s Proof of Evidence [7 KB]
LUL.P11C Note on Nitrogen Dioxide at Victoria Street [20 KB]
LUL.P11/REB/OBJ3 Rebuttal Proof of Evidence of Philip Rowell [123 KB]
LUL/P11/REB/OBJ12 Rebuttal proof and Appendices of Philip Rowell [835 KB]
Prof. Robert Mair
LUL.P12/REB/OBJ3 Rebuttal Proof of Evidence of Prof. Robert Mair MA PhD FREng FICE FRS [788 KB]

ADDITIONAL DOCUMENTS

LUL.1 Opening Submissions on behalf of London Underground Limited [124 KB]
LUL.2 Note setting out background to Statement of Proposed Planning Conditions
LUL.3 Statement of agreement/points noted and taken away following a meeting between Land Securities and LUL 31 October 2008 [1,951 KB]
LUL.4 Not Used
LUL.5 Update on Code of Construction Practice and Proposed Conditions
LUL.6 Note on Funding of Victoria Station Upgrade [638 KB]
LUL.7 List of Plans and Drawings for Approval [40 KB]
LUL.8 Note on letter from Network Rail 31 dated October 2008 [49 KB]
LUL.9 Note relating to Further Information [64 KB]
LUL.10 Counsel’s note on Article 38 of the VSU TWA Order [1,241 KB]
LUL.11 Detailed plan of Bus Stop P Locality [63 KB]
LUL.12 Statement of Common Ground between LUL & the Council of the City of Westminster (signed version) [1,643 KB]
LUL.13 Note on VSU Health Impact Assessment Methodology [22 KB]
LUL.14 Statement of Common Ground Changes Changes from October Issue 15th December 2008 [11 KB]
LUL.15 Matters arising from Land Securities (LS) Withdrawing its Objection [44 KB]
LUL.16 Response to London Taxi Drivers Association [61 KB]
LUL.17 Response to The Westminster Society [23 KB]
LUL.18 Note on how Statutory Requirements have been met [80 KB]
LUL.19 Summary of Responses to Objections not provided elsewhere [511 KB]
LUL.20 New Approach to Transport Appraisal Framework [86 KB]
LUL.21 Copy of Draft Agreement between London Underground and City of Westminster [165 KB]
LUL.21A Note on Revised Agreement between London Ungerground and City of Westminster together with 'track changes' and 'clean' copies of Agreement
LUL.21B Final Agreement between London Underground Limited and City of Westminster
LUL.22 Matters Arising from Victoria Palace Withdrawing its Objection [27 KB]
LUL.23 LUL’s Position on Olympic Road Network Consultation [39 KB]
LUL.24 Statement on how Mitigation Matters will be brought into effect [45 KB]
LUL.25 Impact of Scheme on Rights of Access to Property and Archaeological Remains [52 KB]
LUL.26 Drawings to Assist in Orientation for Visit to basement of Victoria Main Line Station [215 KB]
LUL.27 Response to Points made by VIG on Code of Construction Practice [57 KB]
LUL.28 Matters arising from withdrawal of objection 9 by Live Nation (Venues) UK Ltd
LUL.29 Note on Responses to Further Environmental Information
LUL.30 Response to VIG’s Note on Article 38 of the Order
LUL.31 Note on Position in respect of Objection 45 Select Service Partner
LUL.32 Closing Submissions [362 KB]
LUL.33 Note of oral addition to closing submissions responding to VIG closings