The Sevenoaks Rail Travellers Association has responded to the draft Kent Route Study. Here is what we said:

We are grateful for the opportunity to comment on the draft Kent Route Study.

The Sevenoaks Rail Travellers Association represents commuters and other rail users from the Sevenoaks area. We represent the stations of Sevenoaks, Dunton Green, Bat & Ball, Otford, Shoreham, Eynsford, Kemsing and Borough Green. The area generates 5.5m passenger journeys a year, with substantial growth coming from new developments at Dunton Green and, in the future, Fort Halstead. The area is on the boundary of the London Rail Area and so both mainline and metro trains are important services to many of our members as part of their journeys to work in the London area.

Our major observation is that the Kent Route Study does not provide solutions to current and increasing pressures on mainline capacity into London Bridge and Victoria, especially after 2024. The challenge is real. Many peak-hour passengers between Sevenoaks and London Bridge already have to stand, contrary to the DfT’s own “Passengers in Excess of Capacity” rules. For us, “capacity” means seats. And in future Network Rail’s own Market Study shows that 12% more vehicles are required on London Bridge mainline services by 2024 and 39% more vehicles by 2044. There are similar pressures on London Bridge Metro Services (11% and 33%) and a growing pressure on Victoria Mainline services after 2024 (19% by 2044). The conclusions of the Market Study are supported by aggressive house building targets on key West Kent districts; indeed the housing targets set by central government are higher than historic rates of growth for Sevenoaks, Tonbridge and Tunbridge Wells.

It is particularly disappointing to note that the issues of demand on the Kent mainline significantly exceeding planned capacity were identified in the 2011 Kent Utilisation Study. That study found that 44% of those boarding at Sevenoaks during the morning peak hour had to stand (and 8% were standing from Tonbridge). Yet once more we have a study that describes the problem but does not suggest the strategic and long-term investment programmes needed to provide sufficient seats to meet the demand.

To meet the capacity requirement for 2024 it is proposed that:

(1) all trains are lengthened to 12 cars (although it is recognised that this only gives a small increase since most trains are already of this length). The BCR of 3.0-4.4 is excellent compared to other options for the use of the rolling stock. We welcome this.

(2) a timetable rewrite in the Tonbridge area and on the two-track section between Tonbridge and Orpington is used to create an additional “robust path into Cannon Street”. We concur that Cannon Street would be the desirable destination since those trains tended to be even more heavily loaded than Charing Cross trains in the high morning peak. However the key word is “robust”. Network Rail have themselves pointed out that the South-East network is already timetabled to the full extent possible, with the lack of contingency causing cascades of delays and prolonged service recovery (sometimes evening services are still disrupted from events in the morning peak). The Kent Route Study needs to explain how an extra path could be created without putting service performance at risk.

(3) the conversion of the Metropolitan Reversible Line into a 12-car siding for Cannon Street. While this is an ingenuous and economical solution, we consider that further efforts should be made to make the Metropolitan Reversible Line usable as a siding in the peaks without losing the value of having a route from Charing Cross to London Bridge via Cannon Street in abnormal situations. For instance, before the London Bridge rebuilding the Metropolitan Reversible was used to provide services to Charing Cross when there were weekend engineering possessions in the Borough Market area, and the critical nature of the infrastructure in this area means that it will regularly need possessions for preventative maintenance.

However beyond 2024 the Kent Route Study simply says that “a strategy for providing additional capacity for Kent [mainline] services is far more challenging”. The final version of the Study really needs to spell out what are the “number of steps that need to be undertaken over the next funding period to determine the appropriate strategy for Kent including identifying where additional terminal capacity can be provided and where the identified bottlenecks can be relieved”. It will be important not to make the same mistake as the 2011 Kent RUS and simply postpone these vital matters for a further cycle: the final version of the Kent Route Study should set out a clear strategy for addressing all the issues and bottlenecks in a holistic way and set out a coherent, complete, package for funders to consider.

We also consider that it would be unwise to rely on Traffic Management and the Digital Railway to provide a major part of the solution needed to create the 39% more seats required. While they will have their place, we consider that their major contribution will be in protecting the reliability and resilience of services in an increasingly intense timetable.

The Kent Route Study also suggest the rebuilding of Charing Cross “over the river”. While we can see that this could remove some of the train length and other operational constraints of the current station, we do not see how this will lead to the major increase in terminal capacity required if the station still has six platforms. Moreover, as the Kent Route Study says, increasing the capacity of Charing Cross would then “move the bottleneck to other locations on the route, including North East Kent Junction, Lewisham, Parks Bridge Junction and the two track section between Orpington and Sevenoaks. That is why a strategic and holistic strategy is urgently needed for the entire route, addressing all the bottlenecks, as we have suggested above.

In addition we would welcome an improvement in passenger facilities at Charing Cross, and this should be at the heart of any rebuilding. However we do not regard a station entrance at the southern end of Hungerford Bridge as an adequate connection to Waterloo. Whatever happens at Charing Cross Waterloo East should be kept open to provide good connectivity to Waterloo Main and also to the Jubilee Line at Southwark station and buses to the City on Blackfriars Road.

We would value the opportunity to discuss these and other points in more detail with Network Rail during the next stage of finalising the Kent Route Study.