Report On Post Phase Two Consultation Compressed

Thames Tideway Tunnel Report on post phase two consultation
List of contents
Page number
1 2
Foreword ........................................................................................................... 1 Introduction ...................................................................................................... 2 2.1 2.2 2.3 2.4 2.5 The purpose of this report........................................................................ 2 The proposed project ............................................................................... 3 Route to consent ..................................................................................... 3 Pre-application consultation and engagement to date ............................. 4 Structure of this report ............................................................................. 5 Introduction .............................................................................................. 7 Consultation report .................................................................................. 8 Our consultation strategy ......................................................................... 8 Targeted consultation .............................................................................. 9 Section 42 consultation ......................................................................... 14 Responding to requests for information ................................................. 16 Access for all ......................................................................................... 16 Means of providing feedback ................................................................. 16 Consultation feedback ........................................................................... 17 Method of analysis ................................................................................. 17 Our responses ....................................................................................... 21 Presentation of our findings ................................................................... 21 Introduction ............................................................................................ 23 Number of respondents ......................................................................... 24 Feedback in relation to the site access route......................................... 25 Feedback in relation to the PEIR Addendum ......................................... 39 Our view of the way forward .................................................................. 40 Introduction ............................................................................................ 41 Number of respondents ......................................................................... 42
Our approach to post phase two consultation .............................................. 7 3.1 3.2 3.3 3.4 3.5 3.6 3.7 3.8
Method of analysis of feedback and development of our responses ........ 17 4.1 4.2 4.3 4.4
Targeted consultation: Barn Elms ................................................................ 23 5.1 5.2 5.3 5.4 5.5
Targeted consultation: Putney Embankment Foreshore ............................ 41 6.1 6.2
Report on post phase two consultation
6.3 6.6 6.8 6.9 6.10 6.11 7 7.1 7.2 7.3 7.4 7.5 8 8.1 8.2 8.3 8.4 8.5 8.6 8.7 9 9.1 9.2 9.3 9.4 9.5 9.6 9.7 10 10.1 10.2 10.3 10.4 10.5 11 11.1 11.2
General comments ................................................................................ 43 Configuration of the temporary replacement slipway ............................. 60 Main construction site ............................................................................ 71 Permanent works ................................................................................... 76 PEIR Addendum .................................................................................... 88 Our view of the way forward .................................................................. 89 Introduction ............................................................................................ 91 Number of respondents ......................................................................... 92 Construction traffic access route ........................................................... 93 PEIR Addendum .................................................................................. 101 Our view of the way forward ................................................................ 102 Introduction .......................................................................................... 103 Number of respondents ....................................................................... 104 Revised construction site layout and extent......................................... 105 Revised design .................................................................................... 107 Amended proposals for the Tattershall Castle ..................................... 116 PEIR Addendum .................................................................................. 118 Our view of the way forward ................................................................ 119 Introduction .......................................................................................... 120 Number of respondents ....................................................................... 121 Project-wide comments in relation to modifications to site boundaries 121 Feedback in relation to Cremorne Wharf Depot .................................. 123 Feedback in relation to Chelsea Embankment Foreshore ................... 124 Non-site specific feedback ................................................................... 125 Our view of the way forward ................................................................ 128 Introduction .......................................................................................... 129 Number of respondents ....................................................................... 129 Supportive and neutral comments ....................................................... 130 Objections, issues and concerns ......................................................... 130 Our view of the way forward ................................................................ 138 Introduction .......................................................................................... 139 Number of respondents ....................................................................... 140
Targeted consultation: Albert Embankment Foreshore ............................. 91
Targeted consultation: Victoria Embankment Foreshore ........................ 103
Section 42 consultation: Modifications to site boundaries ...................... 120
Section 42 consultation: Modifications to the tunnel alignment ............. 129
Section 42 consultation: Ground water abstraction ................................. 139
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11.3 11.4 11.5 11.6 11.7 12 12.1 12.2 12.3 12.4 12.5 12.6 12.7 13 13.1 13.2 13.3
Potential effects of the project on ground water abstraction ................ 140 The preferred sites .............................................................................. 144 Tunnel route and alignment ................................................................. 164 Consultation process ........................................................................... 164 Our view of the way forward ................................................................ 167 Introduction .......................................................................................... 168 Number of respondents ....................................................................... 168 Feedback in relation to project-wide themes ....................................... 169 General other comments ..................................................................... 183 Feedback in relation to our preferred sites .......................................... 189 Our view of the way forward ................................................................ 232 Feedback in relation to our approach to consultation .......................... 232 Targeted consultation .......................................................................... 240 Section 42 consultation ....................................................................... 241 Next steps............................................................................................ 242
Other comments........................................................................................... 168
Conclusions and next steps........................................................................ 240
Appendices ........................................................................................................... 243 Appendix A :Statutory consultees, local authorities and the GLA .................. 244 Appendix B : List of newspaper advertisements ............................................... 250 Appendix C : Means of invitation and copies of invitation letters ................... 251 Appendix D :Site notices ..................................................................................... 253 Appendix E : List of town halls and libraries where post phase two consultation information was available............................................................................ 254 Appendix F :Targeted consultation exhibitions ................................................. 257 Appendix G : Feedback forms ............................................................................. 258 Appendix H :Modifications to site boundaries ................................................... 260
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List of tables Page number Table 4.1 Means of providing feedback .................................................................... 17 Table 4.2 Number of respondents by respondent group .......................................... 17 Table 5.1 Respondents to targeted consultation and Section 42 consultation in respect of changes to the site boundary at Barn Elms............................. 24 Table 5.2 Statutory consultees and local authorities that responded to targeted consultation and Section 42 consultation in respect of changes to the site boundary at Barn Elms ............................................................................ 24 Table 5.3 Barn Elms: Supportive and neutral comments in relation to the site access route ........................................................................................................ 25 Table 5.4Barn Elms: Objections, issues and concerns in relation to the site access route ........................................................................................................ 26 Table 5.5 Barn Elms: Supportive and neutral comments in relation to the PEIR Addendum ............................................................................................... 39 Table 6.1 Respondents to targeted consultation and Section 42 consultation in respect of changes to the site boundaryat Putney Embankment Foreshore ................................................................................................................. 42 Table 6.2 Statutory consultees and local authorities who responded to targeted consultation and Section 42 consultation in respect of changes to the site boundary at Putney Embankment Foreshore .......................................... 43 Table 6.3 Putney Embankment Foreshore: Supportive and neutral comments in relation to general issues ......................................................................... 43 Table 6.4 Putney Embankment Foreshore: Objections, issues and concerns in relation to site selection ........................................................................... 44 Table 6.5 Putney Embankment Foreshore: Objections, issues and concerns in relation to general issues ......................................................................... 56 Table 6.6 Putney Embankment Foreshore: Supportive and neutral comments in relation to the configuration of the temporary slipway .............................. 61 Table 6.7 Putney Embankment Foreshore: Objections, issues and concerns in relation to the configuration of the temporary slipway ............................. 62 Table 6.8 Putney Embankment Foreshore: Supportive and neutral comments in relation to the extent of the main construction site .................................. 71 Table 6.9 Putney Embankment Foreshore: Objections, issues and concerns in relation to the extent of the main construction site .................................. 72 Table 6.10 Putney Embankment Foreshore: Supportive and neutral comments in relation to the permanent design ............................................................. 76 Table 6.11 Putney Embankment Foreshore: Objections, issues and concerns in relation to the permanent design ............................................................. 79 Table 6.12 Putney Embankment Foreshore: Supportive and neutral comments in relation to the PEIR.................................................................................. 89
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Table 6.13 Putney Embankment Foreshore: Objections, issues and concerns in relation to the PEIR.................................................................................. 89 Table 7.1 Respondents to targeted consultation and Section 42 consultation in respect of changes to the site boundary at Albert Embankment Foreshore ................................................................................................................. 92 Table 7.2 Statutory consultees and local authorities that responded to targeted consultation and Section 42 consultation in respect of changes to the site boundary at Albert Embankment Foreshore ............................................ 92 Table 7.3 Albert Embankment Foreshore: Supportive and neutral comments in relation to the construction traffic access route ........................................ 93 Table 7.4 Albert Embankment Foreshore: Objections, issues and concerns in relation to the construction traffic access route .................................................... 93 Table 7.5 Albert Embankment Foreshore: Supportive and neutral comments in relation to the Albert Embankment Foreshore PEIR Addendum ........... 101 Table 8.1 Respondents to targeted consultation and Section 42 consultation in respect of changes to the site boundary at Victoria Embankment Foreshore .............................................................................................. 104 Table 8.2 Statutory consultees and local authorities that responded to targeted consultation and Section 42 consultation in respect of changes to the site boundaryat Victoria Embankment Foreshore ........................................ 105 Table 8.3 Victoria Embankment Foreshore: Supportive and neutral comments in relation to the revised site construction design and layout ..................... 105 Table 8.4 Victoria Embankment Foreshore: Objections, issues and concerns in relation to the revised site construction design and layout ..................... 106 Table 8.5 Victoria Embankment Foreshore: Supportive and neutral comments in relation to the revised design ................................................................. 107 Table 8.6 Victoria Embankment Foreshore: Objections, issues and concerns in relation to the revised design ................................................................. 108 Table 8.7 Victoria Embankment Foreshore: Supportive and neutral comments in relation to the amended proposals for the Tattershall Castle ................. 116 Table 8.8 Victoria Embankment Foreshore: Objections, issues and concerns in relation to the amended proposals for the Tattershall Castle ................. 116 Table 8.9 Victoria Embankment Foreshore: Objections, issues and concerns in relation to the Victoria Embankment Foreshore PEIR Addendum ......... 118 Table 9.1 Respondents to Section 42consultation on modifications to site boundaries ............................................................................................................... 121 Table 9.2 Statutory consultees and local authorities who provided feedback in relation to modifications to site boundaries ............................................ 121 Table 9.3 Objections, issues and concerns in relation to project-wide modifications to site boundaries ...................................................................................... 122 Table 9.4 Supportive and neutral comments in relation to modifications to the site boundary at Cremorne Wharf Depot ..................................................... 123
Table 9.5 Objections, issues and concerns in relation to modifications to the site boundary at Cremorne Wharf Depot ...................................................... 123 Table 9.6 Supportive and neutral comments in relation to modifications to the site boundary at Chelsea Embankment Foreshore ...................................... 124 Table 9.7 Objections, issues and concerns in relation to modifications to the site boundary at Chelsea Embankment Foreshore ..................................... 125 Table 9.8 Non site-specific supportive and neutral comments in relation to modifications to site boundaries............................................................. 125 Table 9.9 Non site-specific objections, issues and concerns in relation to modifications to site boundaries............................................................. 125 Table 10.1 Respondents to Section 42 consultation in relation to modifications the tunnel alignment .................................................................................... 130 Table 10.2 Objections, issues and concerns in relation to modifications to the tunnel alignment ............................................................................................... 130 Table 11.1 Respondents to the ground water abstraction consultation .................. 140 Table 11.2 Supportive and neutral comments in relation to the potential effects of the project on ground water abstraction...................................................... 140 Table 11.3 Objections, issues and concerns in relation to the potential effects of the project on ground water abstraction...................................................... 141 Table 11.4 Supportive and neutral comments in relation to the preferred sites ...... 144 Table 11.5 Objections, issues and concerns in relation to the preferred sites ........ 146 Table 11.6 Supportive and neutral comments in relation to the tunnel route and alignment ............................................................................................... 164 Table 11.7 Supportive and neutral comments in relation to the consultation process ............................................................................................................... 165 Table 11.8 Objections, issues and concerns in relation to the consultation process ............................................................................................................... 166 Table 12.1 Respondents that provided other comments at post phase two consultation ........................................................................................... 169 Table 12.2 Statutory consultees and local authorities that provided other comments at post phase two consultation.............................................................. 169 Table 12.3 Feedback in relation to project-wide themes ........................................ 170 Table 12.4 Other general comments ...................................................................... 183 Table 12.5 Feedback in relation to our preferred sites ........................................... 189 Table 12.6 Feedback in relation to our approach to consultation ........................... 233
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List of abbreviations CCS CoCP CSO DCO GLA HGV PLA SOCC SuDS TfL Community Consultation Strategy Code of Construction Practice combined sewer overflow Development Consent Order Greater London Authority heavy goods vehicle Port of London Authority Statement of Community Consultation Sustainable Drainage Systems Transport for London
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1 Foreword
Foreword
Thank you to all those who responded to our post phase two consultation held from 6 June until 4 July 2012. This report is the fourth of its kind, and it contains responses to the feedback we received in response to targeted consultation on alternative design solutions at four of our proposed sites, and Section 42 consultation on ground water abstraction licences and on various changes to site boundaries and the alignment of the main tunnel. During our post phase two consultation, we focussed on specific areas of our proposals and received further helpful feedback. We are grateful to all those who also contacted us in relation to the matters we sought views on and with further questions and comments about other sites. We have listened to your views and taken some difficult decisions to get to the point where the proposals are being finalised. We are always very grateful when individuals or organisations take the time to write to us or visit the project team at exhibitions where we have the opportunity to share with you our plans and discuss the project in detail. The views and information received as part of this consultation, and our earlier phase two consultation, enabled us to finalise our proposed sites and publish our plans as part of our Section 48 publicity (16 July to 5 October 2012). The next step, following Section 48 publicity, is for us to submit the application for development consent for the project to the Planning Inspectorate, which we aim to do in early 2013. This means that our proposals will be examined in detail by a panel of independent, specialist planning inspectors who will make a recommendation on the project as a whole to the appropriate Secretaries of State. Please contact us if you have any questions.
Phil Stride Head of the Thames Tideway Tunnel project
Richard Aylard External Affairs and Sustainability Director
2 Introduction
2
2.1
2.1.1
Introduction
The purpose of this report
This report is a record of the consultation that was carried out in relation to the Thames Tideway Tunnel project (the project) after phase two consultation and before the proposed application for development consent (the application) was publicised under Section 48 of the Planning Act 2008 (as amended by the Localism Act 2011) (the 2008 Act). This additional consultation was completed in accordance with Section 42 and Section 47 of the 2008 Act, including our Statement of Community Consultation (SOCC) published on 4 November 2011. Our SOCC recognised that we may need to amend our proposals after commencing phase two consultation and stated that we would consider whether any necessary changes would affect the nature of the comments received at phase two consultation, and (where appropriate) undertake targeted consultation. The following additional consultation was undertaken between 6 June 2012 and 4 July 2012: a. consultation with relevant local communities and other categories of consultees on potential changes to our proposals for four specific sites, namely Putney Embankment Foreshore, Barn Elms, Albert Embankment Foreshore and Victoria Embankment Foreshore b. consultation with landowners on minor modifications to the proposed boundaries of our preferred sites and minor changes to the proposed alignment of the tunnels c. consultation with landowners of properties benefiting from ground water abstraction licences whom we identified that may be affected by the project.
2.1.2
2.1.3
2.1.4
This consultation described in para. 2.1.3 a) above is referred to in this report as targeted consultation. The consultation described in points b) and c) is referred to in this report as Section 42 consultation. The Section 42 consultation on the proposed changes to site boundaries and tunnel alignments (para. 2.1.3 b) above) was undertaken with statutory consultees and with all newly affected landowners. We formed the view that these changes were minor in nature and did not necessitate consultation with the local community, further to the SOCC The Section 42 consultation on ground water abstraction (para. 2.1.3 c) above) was undertaken with landowners further to Section 42(1) (d) of the 2008 Act. We carried out technical assessment work that established that the project may affect the ability of landowners who hold abstraction licences to abstract water or operate ground source heat pumps. As it was only the landowners who would be affected by this, we did not consult the local community further to our SOCC or the other Section 42 statutory consultees.
2.1.5
2.1.6
2 Introduction 2.1.7 This report describes the post phase two consultation undertaken as part of our multi-stage pre-application process. This report describes why and how we carried out our post phase two consultation activities. It sets out the feedback received and our responses. This report also describes the next steps for the project.
2.2
2.2.1
The proposed project

Project context
At present, untreated sewage mixed with rainwater (combined sewage) regularly overflows into the River Thames from Londons Victorian sewerage system via combined sewer overflows (CSOs). Combined sewage discharges must be reduced in order to comply with relevant wastewater legislation. The UK Government is obliged to meet the requirements of the EU Urban Waste Water Treatment Directive (UWWTD) and the Water Framework Directive. Thames Water must meet the requirements of the Urban Waste Water Treatment Regulations 1994 and the Water Environment (Water Framework Directive) (England and Wales) Regulations 2003, which transpose the UWWTD into English law. Solutions to the problem of wastewater discharges into the tidal reaches of the River Thames have been under examination for more than ten years. The project has been determined to be the most technologically-sound and cost-effective means of controlling CSO discharges and satisfying regulatory requirements. This has been confirmed by independent studies and by Thames Water.
2.2.2
2.2.3
The proposed solution

2.2.4 The project would control CSO discharges by intercepting and diverting combined sewage flows into a new storage and transfer tunnel. The tunnel would run from Acton Storm Tanks in west London to Abbey Mills Pumping Station in the east, where it would connect to the Lee Tunnel, which would transfer the flows to Beckton Sewage Treatment Works for treatment. The new infrastructure would protect the tidal Thames from increasing pollution for at least the next 100 years. The current assumption is that main construction would commence in 2016 and be completed by 2023.
2.2.5
2.3
2.3.1
Route to consent
On 23 June 2012, the Infrastructure Planning (Waste Water Transfer and Storage) Order 2012 came into force. This Order was made by the Secretary of State under powers conferred by Section 14(3) and (4) of the 2008 Act. The effect of the Order was to create a new category of Nationally Significant Infrastructure Project (NSIP) for the purposes of the 2008 Act, covering infrastructure for the transfer or storage or waste water. The project falls within this new category of NSIP.
2 Introduction 2.3.2 Article 3 of the Order contains the following supplementary provision: (1) For the purpose of any requirement of any provision specified in paragraph (2), where a project is a nationally significant infrastructure project, by virtue of the amendments made by article 2 of this Order, the Secretary of State may treat anything done before the date on which this Order comes into force as compliance with that requirement, if it would have complied with that requirement had it been done after that date. (2) The provisions referred to in paragraph (1) are any provision of (a) section 2 of Part 5 of the Act; (b) the Infrastructure Planning (Environmental Impact Assessment) Regulations 2009; or (c) the Infrastructure Planning (Application: Prescribed Forms and Procedure) Regulations 2009. 2.3.3 This supplementary provision enables the Secretary of State1 to treat preapplication activities carried out before 23 June 2012 (the date on which the Order came into force) as having complied with the specified statutory requirements, if those activities would have complied with the relevant requirements had they been undertaken after 23 June 2012. The Order came into force after we had commenced our post phase two consultation. However, anticipating that the project would be decided under the 2008 Act, we carried out this stage of the pre-application consultation in accordance with the requirements of Chapter 2 of Part 5 of the 2008 Act, and relevant secondary legislation, as if such had applied. We also had regard to associated published guidance and advice.
2.3.4
2.4
2.4.1
Pre-application consultation and engagement to date

The overriding aim of our public consultation process is to provide all consultees with the opportunity to influence our proposals, in accordance with the requirements of the 2008 Act. Prior to our post phase two consultation, we undertook other consultation and engagement activities, which are summarised as follows: d. Prior to phase one consultation, we consulted with local authorities and statutory consultees on our consultation strategy. e. At the start of phase one consultation (13 September 2010), we published the SOCC, which set out our consultation strategy, in the London Evening Standard. f. We undertook phase one consultation between 13 September 2010 and 14 January 2011.
In this case, the Secretaries of State for the Department for Communities and Local Government and the Department for Environment, Food and Rural Affairs will act as joint decision maker.
2 Introduction g. Our Report on phase one consultation was published in March 2011; this report sets out the feedback received and our responses, including how the feedback influenced the design of the project. h. Following phase one consultation, we identified possible alternative sites and uses to those presented at phase one consultation. Between 11 March 2011 and 11 October 2011, we held interim engagement events to seek comments on our alternative proposals. i. We had regard to comments received at interim engagement when determining our preferred sites for phase two consultation. The feedback from interim engagement and the projects responses are set out in the Interim engagement report and the Interim engagement addendum. We also re-consulted with local authorities and statutory consultees on our revised draft SOCC between 15 June 2011 and 18 July 2011. Details are set out in our Local authority and stakeholder consultation feedback report on the draft Statement of Community Consultation and accompanying draft Community Consultation Strategy, which was published in summer 2011. At the start of phase two consultation (4 November 2011), we published our SOCC, which set out our revised consultation strategy, in the London Evening Standard. We held our phase two consultation between 4 November 2011 and 10 February 2012. We published our Report on phase two consultation in May 2012; this reportsets out the feedback received and our responses, and how the feedback influenced the design of the project.
j.
k.
l.
2.4.2
Post phase two consultation commenced on 6 June 2012 and closed on 4 July 2012.
2.5
2.5.1
Structure of this report

This report is structured as follows:
a.
Section 3 sets out our approach to post phase two consultation and details how we carried out targeted consultation and Section 42 consultation. Section4 explains our method for analysing the feedback from post phase two consultation and describes: i ii iii how we analysed the feedback how we responded to the feedback how the method of analysis and structure of this report reflects the requirements of the 2008 Act and relevant guidance and advice.
b.
c.
Sections 5 to 8 set out the feedback received in relation to the targeted consultation on the proposed amendments at Barn Elms, Putney Embankment Foreshore, Albert Embankment Foreshore and Victoria Embankment Foreshore.
2 Introduction
d. e. f.
Section 9 sets out the feedback received in relation to the Section 42 consultation on modifications to the boundaries of our preferred sites. Section 10 sets out the feedback received in relation to the Section 42 consultation on modifications to the tunnel alignment. Sections 9 and 10 each set out: i ii iii iv details of the respondents and whether any responded late the feedback received our response to the feedback our view of the way forward and how the proposals are likely to change as a result of the feedback.
g.
Section 11 sets out the feedback received in relation to the Section 42 consultation on ground water abstraction, including: i ii iii iv details of the respondents and whether any responded late the feedback received our response to the feedback our view of the way forward and how the proposals are likely to change as a result of the feedback.
h.
Section 12 sets out the feedback received at post phase two consultation that did not relate to the proposed amendments and our responses to this feedback. Section 13 sets out our conclusions from the post phase two consultation including key findings, any changes under consideration and further investigations/assessments that will be carried out as a result of the consultation. It also provides a summary of our next steps.
i.
2.5.2 2.5.3
The appendices provide further information in relation to how we prepared, publicised and carried out the post phase two consultation. This Report on post phase two consultation will inform the Consultation Report that is required under Section 37 of the 2008 Act and will accompany our application for development consent. We had regard to the guidance and advice notes2 produced by the Department for Communities and Local Government (DCLG) and the Planning Inspectorate in preparing this report.
DCLG (2009) Planning Act 2008, Guidance on pre-application consultation;Planning Inspectorate (2012)Advicenote fourteen: Compiling the consultation report; Planning Inspectorate (2012) Advice note sixteen: The developers pre-application consultation, publicity and notification duties; DCLG Guidance on pre-application process: consultation (April 2012).
3 Our approach to post phase two consultation
3
3.1
3.1.1
Our approach to post phase two consultation

Introduction
We have carried out the public consultation for the project having regard to the DCLGs Guidance on pre-application consultation(September 2009), which states that: effective public consultation is an important aspect of the development of major projects prior to the submission for planning approval. The early involvement of local communities, local authorities and statutory consultees at this stage can bring about significant benefits for all parties, such as:
a.
allowing members of the public to influence the way projects are developed by providing feedback on potential options, and providing them with an opportunity to shape the way in which their community develops helping local people better understand what a particular project means for them so that concerns resulting from misunderstandings are resolved early obtaining important information about the economic, social and environmental impacts of a project from consultees, thus helping promoters identify project options which are unsuitable and not worth developing further enabling potential mitigation measures to be considered and, in some cases, built into the project before an application is submitted identifying ways in which the project could reasonably assist in supporting wider strategic or local objectives.
b.
c.
d. e.
Overall, effective pre-application consultation will lead to applications which are better developed, and in which the important issues have been articulated and considered as far as possible in advance of submission to the consent-granting bodies.3 3.1.2 It is important to recognise that the design of the project is driven by the engineering requirements to intercept CSOs and connect them to the main tunnel at fixed locations. For this reason, the main tunnel route and the location of the worksites are more constrained than other types of infrastructure projects. The overriding aim of our pre-application consultation is to inform statutory consultees, local authorities, landowners and the community about the project and to provide them with opportunities to influence the proposals. We provided information on why site boundaries had changed at all affected sites and along all tunnel routes; a PEIR Addendum report, a Design development report Addendum, supplementary site information
3.1.3
3.1.4
DCLG (2009) Planning Act 2008, Guidance on pre-application consultation
3 Our approach to post phase two consultation papers and a book of plans for the four targeted consultation sites; and a consultation project information paper explaining why we were undertaking additional consultation.
3.2
3.2.1 3.2.2
Consultation report
Section 37(3) (c) of the 2008 Act states that an application for development consent must be accompanied by a consultation report. Section 37(7) states: in subsection (3) (c) the consultation report means a report giving details of (a) what has been done in compliance with sections 42, 47 and 48 in relation to a proposed application that has become the application, (b) any relevant responses, and (c) the account taken of any relevant responses.
3.2.3
This report is a record of the post phase two consultation only. Details of all other consultation activities and publicity undertaken for the project will be set out in the Consultation Report that will be submitted with our application. The Consultation Report will contain sections that address the consultation and engagement activities undertaken with statutory consultees, local authorities, landowners and community consultees since 2008. The section on post phase two consultation will be informed by this report, which will be provided in an appendix to the Consultation Report.
3.2.4
3.3
3.3.1
Our consultation strategy

The SOCC and Community Consultation Strategy (CCS) set out our proposed approach to and strategy for consultation. The SOCC and CCS were subject to three rounds of consultation with local authorities and statutory consultees. Full details of these consultations are provided in Section 2.3 of our Main report on phase two consultation. The SOCC in respect of phase two consultation was published on 4 November 2011, consistent with Section 47(6) of the 2008 Act. The SOCC states: We may need to amend our scheme after the commencement of our phase two consultation. Should this be necessary, we would consider on a site by site basis whether our changes would affect the nature of the comments received from the public at phase two consultation, and where appropriate undertake further targeted consultation. This would comprise public exhibitions and provision of project information, and would be for a period of not less than 28 days. We would also give 14 days notice through the publishing of local adverts and provision of information on our website.
3.3.2
3 Our approach to post phase two consultation 3.3.3 Targeted consultation on the proposed amendments at Barn Elms, Putney Embankment Foreshore, Albert Embankment Foreshore and Victoria Embankment Foreshore was undertaken further to the SOCC. We considered the degree of changes, the potential effects on the local community and the likely level of public interest as guiding factors in determining whether further consultation was necessary under the terms of the SOCC. We consider that this approach is consistent with the guidance provided in para. 78 of the DCLGs Guidance on pre-application consultation (2009) and paras. 53 and 54 of the DCLGs draft Guidance on pre-application process: consultation (April 2012).
3.3.4
3.4
3.4.1
Targeted consultation
What we consulted on
We undertook targeted consultation on the following matters:
a. b.
Putney Embankment Foreshore: re-locating the site further away from Putney Bridge and the existing draw dock Barn Elms: a proposed new access route along Queen Elizabeth Walk instead of the previously proposed temporary route alongside Beverley Brook Albert Embankment Foreshore: a proposed alternative construction access route Victoria Embankment Foreshore: a proposed new design for the permanent works.
c. d.
Whom we consulted
3.4.2 In accordance with Sections 42 and 47 of the 2008 Act and our SOCC, we consulted the following groups:
a.
all statutory consultees, including the Marine Management Organisation and the Greater London Authority (GLA) (see paragraph 3.4.3) relevant local authorities, including potentially directly affected local authorities and adjacent local authorities landowners (see para.3.4.6) community consultees, including the general public, local property owners/occupiers, local businesses, community representatives, and community groups, including hard-to-reach groups.
b. c. d.
Statutory consultees 3.4.3 Section 42(1) (a) of the 2008 Act requires applicants to consult certain prescribed persons on their proposals. Regulation 3 of the Infrastructure Planning (Applications: Prescribed Forms and Procedure) Regulations 2009 provides that, for the purposes of Section 42(1)(a), the prescribed persons are those listed in Schedule 1 of the regulations, who must be consulted in specified circumstances. We undertook targeted consultation with the prescribed persons (referred to in this document as statutory
9
3 Our approach to post phase two consultation consultees) listed in Appendix A. We also consulted the Marine Management Organisation in accordance with Section 42(1) (aa), and the GLA, pursuant to Section 42(1) (c) of the 2008 Act. The GLA is included as a statutory consultee in this report. It should be noted that the GLAs consultation response also contained feedback on behalf of Transport for London (TfL). Local authorities 3.4.4 Section 42(1) (b) of the 2008 Act states that local authorities that fall within Section 43 must be consulted. This includes local authorities within whose areas the proposed development is located and neighbouring local authorities. We consulted the 14 London borough councils within whose areas the project as a whole falls, the neighbouring London borough councils and the Common Council of the City of London. In view of the strategic nature of the project, we also consulted the remaining 19 London borough councils and other councils that border London. A list of the local authorities consulted is provided in Appendix A. Landowners 3.4.5 Section 42(1) (d) of the 2008 Act states that each person who falls within one or more of the categories set out in Section 44 of that Act must be consulted by project promoters. Section 44 sets out three categories of persons that must be identified and consulted as follows: a. Category 1: If the promoter, after making diligent inquiry, knows that the person is an owner, lessee, tenant (whatever the tenancy period) or occupier of land required for the development. b. Category 2: If the promoter, after making diligent inquiry, knows that the person (a) is interested in the land, or (b) has power to i) sell and convey the land or ii) to release the land. c. Category 3: If the promoter, after making diligent inquiry, believes that, if the Development Consent Order (DCO) for the project were to be made and fully implemented, the person would or might be entitled a) as a result of implementing of the order, b) as a result of the order having been implemented or c) as a result of use of the land once the order has been implemented, to make a relevant claim. A relevant claim includes a claim under Section 10 of the Compulsory Purchase Act 1965 for injurious affection arising from the construction of the development or a claim under Part 1 of the Land Compensation Act 1973 for depreciation in value of a property interest arising from the operation of the development.
3.4.6
At targeted consultation, we consulted every person who falls within one or more of the Section 44 categories. These persons are collectively referred to as landowners for the purposes of this report. All three categories of persons were identified in our extensive land referencing exercise, which was carried out on all properties potentially affected by the project.
3.4.7
10
3 Our approach to post phase two consultation Community consultees 3.4.8 Under Section 47 of the 2008 Act, applicants must consult the local community in the vicinity of the project. Consultation must be carried out in accordance with the proposed approach set out in the SOCC. Our definition of community consultees includes ward councillors, local MPs and MEPs, and other community representatives, individuals or organisations that formally or informally represent local interests including, but not limited to:
a. b. c. d. e. f. g. h.
individuals, owners/occupiers, businesses and groups based, or living, in the vicinity of (but not on) every site individuals, owners/occupiers, businesses and groups based, or living, further away but that have, or represent, an interest in a given site local people who live near, use or overlook a given site local environmental groups voluntary organisations (including residents associations and black and minority ethnic support groups) faith communities schools and colleges in the immediate vicinity local hospitals, care homes and private healthcare organisations in the immediate vicinity.
3.4.9
We carried out community audits prior to commencing phase one and phase two consultations in order to identify all the groups listed above that have a potential interest in the project. We also liaised with local authorities to identify additional community groups. In order to define the areas around each site in which to notify people of phase two consultation directly in writing, we set a minimum distance of approximately 250m from the site boundary and a broad corridor along the preferred tunnel route. The boundary was applied flexibly according to the scale and nature of the proposed works, having regard to the characteristics of the surrounding area. The publicity methods we employed are detailed below. When developing our SOCC, we consulted with local authorities to ensure that the consultation boundaries were appropriate.
3.4.10
3.4.11
How we undertook the consultation

3.4.12 We carried out the targeted consultation in accordance with our SOCC, which states that targeted consultation would last for a period of not less than 28 days. Targeted consultation was in fact open for a period of 29 days between 6 June 2012 and 4 July 2012 (inclusive). This section sets out how we publicised and carried out the targeted consultation. Publicity 3.4.14 We publicised our targeted consultation in a range of media and public awareness initiatives.
11
3.4.13
3 Our approach to post phase two consultation Advertisements 3.4.15 In accordance with our SOCC, advertisements were placed in local newspapers to inform readers of the nature of the changes at the relevant sites and to advise the specific exhibition dates. The advertisements were placed a minimum of 14 days prior to the start of targeted consultation. The publications and advertisement dates are provided in Appendix B. Letters 3.4.16 A total of 11,874 letters containing information on the project were posted to consultees via Royal Mail on 6 June 2012: 256 letters were sent to statutory consultees, 55 to local authorities, 1,712 to landowners and 9,851 to community consultees. The letter set out relevant details for each site in relation to the scope of the targeted consultation, the planned dropin exhibitions, and the means of providing feedback. Copies of the letters sent to each respondent group are provided in Appendix C. Site notices and leaflets 3.4.17 We also posted site notices in the vicinity of each of the four targeted consultation sites 14 days prior to the start of targeted consultation. The notices set out the proposed changes to our proposals and details of the local drop-in exhibitions, and advised where to find more information and how to provide feedback. Where agreed with the local authority, the site notices also provided details of the language line. A copy of the site notices and details of where they were displayed is provided in Appendix D. Press release 3.4.18 3.4.19 We issued a press release publicising our proposals on 17 May 2012. Consultation website The project has its own dedicated consultation website, which provides information on the project and the targeted consultation. The website formed a dedicated point for respondents to leave feedback. Paper feedback forms were also provided at the drop-in exhibitions and on request. Our website sought to meet best practice standards of accessibility and usability. It provided electronic versions of all the information published for targeted consultation that was distributed at the drop-in exhibitions. The website remains a live resource, and all materials from targeted consultation and previous consultation and engagement activities are available to view. We will continue to update the website with other publications, including Section 48 publicity material, prior to the submission of the application. Provision of written information 3.4.22 We provided a range of both technical and non-technical written information, which was available online. We also produced a Targeted consultation project information paper, which provided an overview of the targeted consultation.
3.4.20
3.4.21
12
3 Our approach to post phase two consultation 3.4.23 Supplementary site information papers were produced for the four targeted consultation sites, which contained the following:
a. b. c. d.
an overview of the changes under consideration at each site activities that would be undertaken at each phase of construction the potential effects of our construction works and how we propose to address them the potential effects of our operational works and how we propose to address them (at Putney Embankment Foreshore and Victoria Embankment Foreshore only) illustrations of the proposed permanent structures and details of the issues that influenced the design (at Putney Embankment Foreshore and Victoria Embankment Foreshore only).
e.
3.4.24
Other documents prepared for targeted consultation were also made available to the public at the drop-in exhibitions and on the website, including:
a. b. c. d. e. f. g.
Design development report Addendum PEIR Addendum to Volume 9: Barn Elms PEIR Addendum to Volume 19: Putney Embankment Foreshore PEIR Addendum to Volume 19: Albert Embankment Foreshore PEIR Addendum to Volume 20: Victoria Embankment Foreshore Book of plans Targeted consultation drop-in exhibitions leaflet.
3.4.25
Documentation from earlier phases of consultation and other project documents were also made available on our website to allow consultees to compare the proposed changes with the earlier scheme. The project information papers, supplementary site information papers, feedback forms and posters were made available at local libraries and on request. A full list of locations at which reference information was made available is provided in Appendix E. Programme of drop-in public exhibitions As stated in our SOCC, we held public drop-in exhibitions in the vicinity of the four targeted consultation sites, which were advertised locally in advance (see paras. 3.4.15 and 3.4.17). The exhibitions were open for two consecutive days in each location, between 2pm and 8pm. Members of the project team (including representatives from the planning, environment, community, property and engineering disciplines) were present to answer questions, assist with interpreting materials or completing feedback forms, and encourage consultees to have a say. A list of all drop-in exhibitions, including the venues, opening hours and the number of visitors is provided in Appendix F. At each exhibition we displayed information to inform visitors about the project and the local worksite(s). The information was consistent with the
3.4.26
3.4.27
3.4.28 3.4.29
13
3 Our approach to post phase two consultation project information papers and supplementary site information papers, and information on our website. We also provided information from the phase two consultation exhibitions to illustrate the proposed changes to those proposals. 3.4.30 Members of the public were encouraged to use our website to register their comments; however, paper feedback forms were also made available at the exhibitions. Where requested, respondents were given support to fill in the feedback form.
3.5
3.5.1
Section 42 consultation
What we consulted on
We undertook Section 42 consultation on the following matters:
a. b. c.
Tunnel alignment: minor changes to the proposed limits of deviation of the main tunnel. Minor changes to the limits of land to be acquired or used to construct and operate the project at all sites. Ground water abstraction: as a result of further technical design work, we determined that our proposals could have an effect on the ability of certain persons to abstract water or operate ground source heat pumps.
Whom we consulted
3.5.2 We consulted the following persons :
a.
In relation to changes to site boundaries, we consulted statutory consultees and every person who, as a result of the boundary changes proposed now fell within one or more of the Section 44 categories described in para. 3.4.5 above (ie, new landowners). We also re-consulted all previously consulted persons where the proposed changes would result in a greater effect than previously anticipated. In relation to tunnel alignment modifications, we consulted statutory consultees and each person who, as a result of the changes proposed, now fell within one or more of the Section 44 categories as described in para. 3.4.5 above (ie, new landowners). We also reconsulted all previously consulted persons where the proposed changes would result in a greater effect than previously anticipated. In relation to ground water abstraction issues, we consulted landowners (as defined in Section 42(1) (d)) of property with the benefit of ground water abstraction licences whom we determined may be affected by the project. We consulted these persons on the basis that they fell within Category 3 under Section 44 since they might have a relevant claim due to the potential effects of the project on their ability to abstract ground water or operate a ground source heat pump.
b.
c.
3.5.3
The Section 42 consultation on changes to site boundaries and modifications to the limits of deviation of the main tunnel was undertaken with landowners newly affected by the project and any previously
14
3 Our approach to post phase two consultation consulted landowners who would potentially experience greater effects as a result of the changes. We did not re-consult other landowners consulted at phase two consultation where the effects on their land would not materially change as result of the proposed changes. We considered that further consultation with such landowners on the proposed changes was not necessary on the basis that the changes were so minor that their responses to the consultation exercise would not be affected. Having regard to the minor nature of the changes, we also formed the view that consultation with statutory consultees under Section 42(1) and the local community further to the SOCC under Section 47 was not necessary. 3.5.4 The Section 42 consultation on groundwater abstraction issues was undertaken only with landowners whose property benefitted from the ability to abstract groundwater under an abstraction licence and would be potentially affected by the project. We did not consider it necessary to consult other persons about these matters.
How we undertook the consultation

3.5.5 We undertook our Section 42 consultation having regard to para. 78 of the DCLGs Guidance on pre-application consultation (2009) and para. 54 of the DCLGs draft Guidance on pre-application process: consultation (April 2012), which state that additional consultation must cover a period not less than 28 days. The Section 42 consultation was open for a period of 29 days between 6 June 2012 and 4 July 2012 (inclusive). This section sets out how we publicised and carried out the Section 42 consultation. Publicity 3.5.7 A total of 3,142 letters containing information on the project were posted to landowners via Royal Mail on 6 June 2012. The letter set out relevant details for each site in relation to the scope of the consultation, and means of providing feedback. It also highlighted that more detailed information on the project was available on the projects consultation website. The 2,014 letters sent to ground water consultees advised them that the dewatering required to ensure safe construction of the tunnel might have an effect on their rights to use groundwater. It also provided a dedicated point of contact for any queries and details of exhibitions attended by members of the project team. Copies of the letters sent are provided in Appendix C. Consultation website 3.5.9 The consultation website provided information on the project and details of the Section 42 consultation. For further information on the consultation website, refer to paras.3.4.19 to 3.4.21. Provision of written information 3.5.10 We provided written information on the changes to the site boundaries and tunnel alignments, which was available online, in the Book of plans and in the Tunnel alignment overview sheet.
3.5.6
3.5.8
15
3 Our approach to post phase two consultation 3.5.11 Documentation from earlier phases of consultation and other project documents were also made available on our website to allow consultees to compare the proposed changes with the earlier scheme.
3.6
3.6.1
Responding to requests for information

We responded to individual written queries and phone calls at post phase two consultation. Our Customer Centre handled over 348 phone calls and 50 written queries in addition to the written feedback forms and correspondence received.
3.7
3.7.1
Access for all

We sought to ensure that all consultees could respond to the consultation and offered a range of solutions for those who required additional assistance. For example, consultation information was available in large print, braille and audio format on request. Our Customer Centre offered a telephone service to translate consultation materials into any language on request. This service was not requested during post phase two consultation. We reviewed the Customer Centres database to identify consultees in the post phase two consultation who might require special services. No such consultees were identified. We carried out a health and safety audit of the potential exhibition venues for post phase two consultation to strike a suitable balance between accessibility of the buildings and proximity to the residents wishing to attend. All the exhibition locations used were deemed accessible. Members of the project team were in attendance to facilitate access and assist the public.
3.7.2
3.7.3
3.8
3.8.1
Means of providing feedback

Feedback was primarily provided by means of feedback forms, which were available online and in hard copy. We provided one feedback form for the targeted consultation and Section 42 consultation on changes to site boundaries and tunnels alignments. We produced a separate feedback form for the Section 42 ground water abstraction consultation. Copies of these feedback forms are provided in Appendix G. We also received correspondence, which was processed in the same way as the feedback forms.
16
4 Method of analysis of feedback and development of our responses
4
4.1
4.1.1
Method of analysis of feedback and development of our responses

Consultation feedback
A total of 139 respondents provided feedback to the post phase two consultation, of which 12 responded after the close of the consultation period. We analysed and considered their responses nonetheless (see para. 4.2.12). Table 4.1 and Table 4.2 provide a breakdown of the feedback received during the consultation period. Table 4.1 Means of providing feedback
Means of feedback Feedback form (online and hard copy) Correspondence Petitions Number of respondents 85 50 2
4.1.2
Table 4.2 Number of respondents by respondent group

Consultee type Statutory consultees Local authority Landowners Community consultees 8 4 21 104* Number of respondents
* The respondents defined as community consultees under Section 47 of the 2008 Act (with the
exception of two) were identified from those who identified themselves as local residents, organisation in Question 2 of the targeted consultation and Section 42 consultation feedback form. Two community consultees responded using the groundwater consultation feedback form; see para. 4.2.3 for our definition of community consultees. A copy of the feedback forms is provided in Appendix G.
4.2
4.2.1
Method of analysis
We received feedback by various different means including online/hard copy feedback forms and correspondence such as letters, emails and petitions. This section sets out our approach to analysing the feedback received.
Feedback forms
4.2.2 4.2.3 We received feedback forms online via our website and in hard copy. Logging of feedback forms Before analysing the content of the feedback forms, we took the following steps:
17

a.
Each feedback form was logged and given a unique reference number. Respondents who submitted their feedback forms online were assigned a unique 13 digit reference code. For the purposes of this report, we used unique five digit ID numbers. The online system enabled respondents to submit feedback forms as many times as they wished. In order to ensure that our analysis was not skewed by multiple submissions from a single respondent, all feedback received from one respondent was allocated the same ID number. Our analysis was based on the number of respondents rather than the amount of feedback submitted by any particular respondent or group. The Consultation Report that must accompany our application for development consent will detail the feedback from each group of respondent (Section 42 of the 2008 Act) and from the community (Section 47 of that Act). The targeted consultation and Section 42 consultation feedback form requested respondents to state the capacity in which they responded. Respondents were assigned to a group as follows: i ii iii statutory consultees: respondents listed in Appendix A local authority: respondents listed in Appendix A landowners: respondents on the list of identified landowners we verified the status of respondents who identified themselves as landowners, but if respondents did not identify themselves as such, we did not carry out any verification checks community consultees: respondents who selected the local resident/organisation groups and respondents who did not fall into any of the three groups above other: respondents who selected other were re-assigned to one of the four groups above in accordance with the categories set out in the 2008 Act. Respondents who selected this group were checked against the list in Appendix A and the results of our land referencing exercise and designated as a statutory consultee, local authority or landowner if there was a positive match. Where there was no positive match, respondents were designated as community consultees.
b.
c.
iv
d.
In order to understand how respondents to the groundwater consultation might be affected by the project, they were asked to state their capacity on the feedback form as follows: i ii iii an owner, lessee or occupier of a premises that enjoys the benefit of ground water abstraction a person who uses such premises or is otherwise interested in them an agent acting on behalf of a person in the above categories.
e.
We followed the same process for logging feedback as for targeted consultation and the Section 42 consultation.
18
4 Method of analysis of feedback and development of our responses Analysis of feedback received 4.2.4 The targeted consultation and Section 42 consultation feedback form comprised three questions. The first two questions requested respondents details and the capacity in which they responded. The third sought feedback on the proposed site-specific changes and the modifications to site boundaries and the tunnel alignment. The ground water abstraction feedback form was divided into two parts. The first part requested respondents details and the capacity in which they responded, and sought comments on the projects potential to affect ground water abstraction during the construction period. The second part of the form comprised a slightly modified version of the phase two consultation feedback form to afford this group of consultees the opportunity to provide full comments on both strategic and specific elements of the project. Copies of both feedback forms are provided in Appendix G. We broadly analysed the feedback against the questions in the feedback forms, except where it was clear that comments under a particular question in fact related to another question on the forms. This enabled us to analyse comments of a similar nature together. In order to ensure consistency with the approach we adopted for previous phases of consultation, we classified feedback according to a number of themes, such as transport and access. The comments were also categorised as supportive and neutral comments, or objections, issues and concerns. The unique ID numbers for each respondent (recorded with every comment) enabled us systematically to identify where the same comment was made by more than one respondent and thereby determine the volume of feedback received under each theme. We sought to take account of all responses, whether or not they were in the minority.
4.2.5
4.2.6
4.2.7
4.2.8
Correspondence
4.2.9 In addition to the feedback forms, we also received consultation responses in writing (by email and post) for both targeted consultation and Section 42 consultation. As with the feedback forms, we carried out the following steps before analysing the content of the correspondence:
a. b.
All correspondence was assigned a unique ID number. We checked whether the respondent had previously submitted feedback. If they had, the correspondence was assigned the same ID number as the first submission. We logged the capacity of the respondent (see para. 4.2.3). We analysed the correspondence against the questions on the feedback form. The following points should be noted: i On the feedback form, respondents were asked to state their view on certain questions by means of tick boxes. Where respondents did not expressly identify a view that matched the options set out in each question, no view was assigned.
c. d.
19
4 Method of analysis of feedback and development of our responses ii 4.2.10 Feedback that did not respond to any of the questions in the feedback form was classified as other comments.
Having completed these steps, we followed the same process as for the feedback forms to identify themes within the feedback.
Petitions
4.2.11 We received two signed petitions expressing views on our proposals at targeted consultation and Section 42 consultation. The process for analysing petitions was the same as for correspondence. In this report, petitions are discussed alongside community consultees and are counted as one petition response. The number of signatories is provided. Petitions were assigned an ID number with the suffix PET.
Late responses
4.2.12 Any feedback received after the close of post phase two consultation at 5pm on 4 July 2012 was categorised as a late response. Any feedback submitted between the close of consultation and 13 July 2012 was also considered and categorised as a late response. This approach follows preapplication consultation guidance provided by the DCLG. Depending on the form in which the late responses were received, they were analysed according to the processes set out above. In addition to unique ID numbers, they were assigned the prefix LR (late response). The number of late respondents is indicated at the start of each section of this report.
4.2.13
Cross checks
4.2.14 In accordance with Planning Inspectorate Advice Note Fourteen (April 2012) we implemented safeguards to ensure that the comments were grouped appropriately. Firstly, we categorised the comments as supportive or neutral, objections, issues or concerns or mitigation, suggestions or alternative solutions and then assigned them to a topic sub-theme, such as heritage or transport and access. We also compiled a list of anticipated comments that could be adapted as necessary. We then followed a series of processes to ensure that similar feedback was dealt with in a consistent manner. The processes included:
a. b. c. d.
The sub-themes were assigned to members of the analysis team, who then analysed all the feedback on that theme. Where our existing sub-themes did not accurately summarise the feedback received, we adapted them as necessary. We created new sub-themes for any new points raised by respondents that were not on our list of anticipated comments. We adapted our anticipated comments to include specific details raised by respondents. For example, the anticipated comment: should use/consider an alternative site was updated to include detailed feedback in relation to Putney Embankment Foreshore as: should use/consider an alternative site that would cause less nuisance to residential properties.
20

4.2.15
A team member who was not directly involved in the analysis of the comments then reviewed samples of the feedback allocated to the other members of the analysis team to check that these processes were followed correctly.
4.3
4.3.1
Our responses
Having completed the process of logging and categorisation, we reviewed all the feedback, having regard to engineering, planning, environment, and property and community considerations. We then considered how the feedback might influence the development of the project. Sections 5 to 12 set out how we propose to address the feedback received. Where our proposals remain the same as presented at post phase two consultation, we have provided appropriate justifications.
4.3.2
4.4
4.4.1
Presentation of our findings

In producing this report we had regard to advice relating to the content of the consultation report required under Section 37(3) (c) of the 2008 Act published by the Planning Inspectorate and guidance from the DCLG. We will also prepare a full consultation report in due course, which will accompany our application for development consent. We had regard to paras. 94 to 102 of the DCLGs Guidance on preapplication consultation (September 2009). The Planning Inspectorates Advice note fourteen: Compiling the consultation report (April 2012) also provides guidance on how to present feedback in the consultation report. At the start of each section of this report (5 to 12), we have indicated the form in which feedback was received (feedback form, correspondence etc,) and the number of respondents in each group (statutory consultees, local authorities, landowners, community consultees and petitions). The feedback for each site is grouped by theme in order to aid navigation and reduce repetition. The respondent groups(s) that submitted each feedback comment are identified in the appropriate table. In each section, we set out the feedback received in tables, together with our response to every comment. Firstly, we address the supportive and neutral comments followed by the objections, issues and concerns. Each section ends with a sub-section entitled Our view of the way forward, which summarises our overall response to the feedback received. Where appropriate, we state any changes that are under consideration. In Sections 5 to 8, and 11 to 12, each table containing the objections, issues and concerns includes a final column entitled C (change). In this column, we indicate whether the feedback led to a change or no change, as defined below:
a.
4.4.2
4.4.3
4.4.4
4.4.5
C: In response to the feedback received, we are considering or now propose a change (including mitigation)4 to our phase two
Mitigation here refers to a wide range of measures set out in our phase two and targeted consultation proposals including, for example, the Code of construction practice and other documents, as well as the mitigation measures set out in the PEIR Addendum and our Section 48 publicity materials.
21
4 Method of analysis of feedback and development of our responses consultation, targeted consultation and Section 42 consultation proposals.
b. c.
N: We do not propose to change our proposals. N/A: Any feedback that did not relate to sites, route, design, form or scale of the scheme. The Planning Inspectorates Advice note fourteen (April 2012) states that feedback should relate to at least one of these categories.
4.4.6
We adapted this approach from that recommended for the consultation report in the Planning Inspectorates Advice note fourteen (April 2012), which suggests classifying issues according to whether they directly resulted in a change, mitigation or no change. In this report, we only state whether feedback led to a change or no change. We did not include mitigation as a separate category. We consider that the distinction between change and mitigation' is often artificial because in many cases changes are proposed in order to mitigate effects identified by respondents. Following the close of post phase two consultation and before publicising our proposals in accordance with the requirements of Section 48 of the 2008 Act, we reviewed all of the feedback received to determine whether any changes to our preferred scheme were required. On 16 July 2012, we commenced our Section 48 publicity. As this report was published after the start of Section 48 publicity, we note (where appropriate) where further information is available in our Section 48 publicity materials.
4.4.7
22
5 Targeted consultation: Barn Elms
5
5.1
5.1.1
Targeted consultation: Barn Elms

Introduction
Our proposal
We still propose to use the southeastern corner of the sports field of the Barn Elms Schools Sports Centre for our construction works and to accommodate the permanent structures required to operate the main tunnel. The site would be used to connect the existing local CSO, known as the West Putney Storm Relief CSO, to the main tunnel. At phase two consultation, we proposed that construction traffic would access the site via a temporary access road along the northern side of the Beverley Brook watercourse. In response to feedback from phase two consultation, we now propose that construction traffic would access the site from Upper Richmond Road (A205), travel along Rocks Lane (A306) and turn right into Queen Elizabeth Walk. For further information on our amended proposals for this site at targeted consultation, refer to the Barn Elms supplementary site information paper.
5.1.2
Structure of this section

5.1.3 This section sets out targeted consultation feedback in relation to the proposed amendments at Barn Elms, together with Section 42 consultation feedback in respect of changes to the site boundary. Feedback that related to Barn Elms, but not to the proposed amendments at this site at targeted consultation, is outlined in Section12: Other comments. This section is organised as follows to reflect the scope of targeted consultation:
a. b. c. d.
5.1.4
Section 5.2: Number of respondents Section 5.3: Site access route Section 5.4: PEIR Addendum Section 5.5: Our view of the way forward.
5.1.5
In Sections 5.3 to 5.4we detail the groups and total number of respondents, the comments received and the projects response.
23
5.2
5.2.1
Number of respondents
A total of 38 respondents provided feedback in relation to Barn Elms at targeted consultation and Section 42 consultation in respect of changes to the site boundary, of which two responded after consultation had closed. The number of respondents in each group is set out in Table 5.1.
Table 5.1 Respondents to targeted consultation and Section 42 consultation in respect of changes to the site boundary at Barn Elms
Respondent group Statutory consultees (SC) Local authorities (LA) Landowners (LO) Community consultees (CC) Petitions (PET) 2 1 4 31 0 Number of respondents
5.2.2
Table 5.2 sets out the statutory consultees and local authorities that provided feedback for this site. Table 5.2 Statutory consultees and local authorities that responded to targeted consultation and Section 42 consultation in respect of changes to the site boundary at Barn Elms
Statutory consultees English Heritage (EH) Transport for London (TfL) Local authorities London Borough of Wandsworth (LBW)
5.2.3
Feedback in relation to this site was received in a number of forms, including feedback forms and correspondence (emails and letters).
24
5.3
5.3.1
Feedback in relation to the site access route

This section sets out feedback in relation to the proposed construction site access route at Barn Elms. The supportive and neutral comments are provided in Table 5.3 and the objections, issues and concerns in Table 5.4. The comments are grouped by theme, as denoted by the sub-headings shaded in orange.
Supportive and neutral comments

Table 5.3 Barn Elms: Supportive and neutral comments in relation to the site access route
Ref 5.3.2 5.3.3 5.3.4 5.3.5 5.3.6 Supportive and neutral comments Proposals would not affect wildlife. Proposals would not affect the enjoyment of the open space. Proposals would not affect sporting activities at the Barn Elms Schools Sports Centre. Proposals would be less intrusive on the greenfield site. Support for the proposed access route as Queen Elizabeth Walk is already an established thoroughfare. 1 1 1 1 9 Total/ID number 14038 14038 14127LO 14115 14004, 14024, 14028, 14033, 14038, 14106, 14114, 14115, 14119 LBW Our response Your comment is noted and welcomed. Your comment is noted and welcomed. Your comment is noted and welcomed. Your comment is noted and welcomed. Your comments are noted and welcomed.
5.3.7
Support for the proposals subject to resolution of detailed matters including: a. Thames Water should provide new, permanent changing rooms that should be open before carrying out works b. minimal disruption to the playing pitches during construction and in the long term.
Your comments are noted. As detailed in our PEIR Addendum (Volume 9, Section 2.3), alternative changing rooms and track and field facilities would be provided within the Barn Elms Schools Sports Centre grounds prior to demolition. If the proposed changes are taken forward, the exact location of the new changing rooms would be agreed with the London Borough of Wandsworth, which owns the site, and the London Borough of Richmond, which is the local planning authority. It is likely that new changing rooms
25

Ref Supportive and neutral comments Total/ID number Our response would be provided in close proximity to the existing facilities. We can confirm that the replacement facilities will be included in the application. Your comments are noted and welcomed.
5.3.8
The proposed access route is an improvement on the proposals presented at phase two consultation. Support retaining this route as the permanent route following construction. Note the London Borough of Wandsworth would consider removing the existing route that runs across the playing field area. Proposals would be less disruptive to local traffic. Queen Elizabeth Walk is suitable for heavy construction traffic. Reassured by the limited number of construction vehicles expected (16 movements per day).
LBW, 14011, 14108
5.3.9 5.3.10 5.3.11
1 1 1
14115 14106 14107
Your comment is noted and welcomed. Your comment is noted and welcomed. Your comment is noted and welcomed.
Objections, issues and concerns

Table 5.4Barn Elms: Objections, issues and concerns in relation to the site access route
Ref Objections, issues and concerns 4 Total/ID number CABE, LBW, 14060, 14062 Our response The proposed access route that was presented at targeted consultation would require trees along the alignment of the construction access road to be pruned or removed. The two lime trees that would be removed are young and there are no plans to remove the mature conifers on-site. The phase two consultation proposals made provision C N Natural environment (terrestrial) 5.3.12 Proposals would result in the loss of trees including: a. period lime trees b. several mature conifers. 5.3.13 Ensure that tree protection measures are put in 1 LBW
26

Ref Objections, issues and concerns place, including for the trees in the vicinity of the boathouse. Total/ID number Our response to remove and prune mature trees near Beverley Brook and the highway access point on Rocks Lane. In the targeted consultation proposals, fewer mature trees near Beverley Brook by the main construction site and along the northern and eastern perimeters of the Barn Elms Schools Sports Centre would be removed. Our draft CoCP (Section 11.6) sets out how we would protect existing trees during construction. Measures such as protective fencing and prohibition of storing material in the protected area would be implemented, as specified in British Standard BS5837, where practicable and in consultation with the London Borough of Richmond upon Thames tree officer. The PEIR Addendum (Volume 9, Section 4.3) states that as the main construction site would lie at a distance from the WWT London Wetland Centre Site of Special Scientific Interest (SSSI), the only potential effects on this receptor would be intermittent disturbance from passing construction traffic. The assessment of effects on notable species and the WWT London Wetland Centre SSSI will be set out in the Environmental Statement that will be submitted with our application. All other potential construction effects remain as predicted in the phase two consultation PEIR. It should be noted that the proposed construction lighting would only be for the winter months, when lighting would be required in the early morning and evening. There would be no operational lighting at the site. As a result, the PEIR did not assess the operational phase. C
5.3.14
Concerns regarding possible effects on the natural environment included: a. the proximity to the WWT London Wetland Centre's wildlife and habitats b. the potential effect on protected species of bats.
14127LO, 14107
5.3.15
Ensure that lighting for changing rooms or 1 relocated track and field facilities would minimise any effects on wildlife, including any disturbance to bat corridors and foraging areas in the immediate vicinity.
LBW
27

Ref Objections, issues and concerns Total/ID number Our response All construction lighting would be designed to minimise any effects on ecology and amenity. The draft CoCP sets out a range of measures in relation to construction lighting that the contractor would be required to adhere to. Furthermore, the contractor would be required to prepare a Lighting Management Plan that would set out appropriate lighting solutions for the site. We prefer the proposed construction access route at targeted consultation for the following reasons (see Volume 9, Section 4.3 of the PEIR Addendum): a. The Barn Elms Playing Field Site of Importance for Nature Conservation would not be affected by the proposed development. b. c. Fewer mature trees would be removed. The main construction site would be at a suitable distance from the WWT London Wetland Centre SSSI, therefore the only potential effects on this receptor would be intermittent disturbance from passing construction traffic. N N C
5.3.16
Prefer the access route put forward at phase two 1 consultation as the disturbance to the ecology of the common would be temporary.
LR14064
5.3.17 5.3.18
Ensure the loss of trees would not affect bat or bird populations. Proposals should minimise damage to ecology.
1 1
LBW 14035
The scheme at this site was designed to minimise likely significant effects on wildlife and habitats where possible and, where such effects were identified, mitigation was built into the design. Likely significant effects will be assessed and set out in the Environment Statement that will be submitted with our application. The CoCP, a draft of which was provided for Section 48 publicity, would ensure that works comply with applicable legislation and relevant nature conservation policies and guidance, including the Mayor of
28

Ref Objections, issues and concerns Total/ID number Our response Londons Biodiversity Strategy and local biodiversity action plans. Where species are protected by specific legislation, approved guidance would be followed, appropriate mitigation proposed and any necessary licences or consents obtained. Before re-planting the lime trees, we would seek advice from both the London Borough of Richmond (the local planning authority) and the London Borough of Wandsworth (the owner of the site). We do not currently propose to provide natural screening. It should be noted that the Cyprus trees lining Queen Elizabeth Walk and the proposed hoarding that would be erected on either side of the construction access road would provide a certain degree of visual screening. The draft CoCP sets out a range of measures that would be adopted by the contractor to minimise noise and the visual effects of construction. The measures include the use of enclosures, hoardings and screens, which would be designed to reduce the impact of the construction works on the local townscape. Specific measures such as acoustic suppression systems, operating equipment in a mode that minimises noise, and shutting down equipment when not in use are also included in the draft CoCP. Full details of the measures to minimise construction effects will be set out in the CoCP and Environmental Statement that will be submitted with the application. C
5.3.19
Tree re-planting should be undertaken under the guidance of the council's Tree Officer.
LBW
5.3.20
Provide appropriate natural screening to reduce noise and visual effects on the WWT London Wetland Centre.
14107
29

Ref 5.3.21 Objections, issues and concerns Concerns regarding the effect of the proposals on sporting activities, including the demolition and reconstruction of the sports pavilion. Concerns regarding the effect of the proposals on local residential amenity included: a. noise and dust pollution b. the effect on residents of Queen Elizabeth Walk. 5.3.23 Proposals would result in the permanent loss of playing fields that are a much-used and essential lifeline for thousands of local residents. Proposals would result in the permanent loss of open space that is vital to schools and the public. It is viewed as a cheap alternative to buying commercial land. Ensure that disruption to playing pitches is minimised. 2 14005, 14037 2 Total/ID number 14127LO, 14003 14111LO, 14020 Our response The sports pavilion would not be affected by the revised construction access route. Therefore it would not be necessary to provide a replacement facility. The PEIR Addendum (Volume 9, Section 4.6) recognises that, while the revised access route introduces new residential receptors on Queen Elizabeth Walk, the effects on residential amenity from noise, vibration, air quality and visual effects would remain minor adverse overall (see paras. 10.5.27 to 10.5.35 of Volume 9 of the PEIR assessment). The PEIR Addendum (Volume 9, Section 4.6) recognises that the new route would result in a temporary loss of a small area of peripheral open space during the construction phase. However, the potential alignment of the construction access road would not affect playing pitch capacity. The PEIR Addendum states that the effects during construction would be negligible, including the effect of temporary land take and demolition/provision of alternative facilities on users of the Barn Elms Schools Sports Centre. The Environment Statement for submission with the application will set out the operational effects of the proposed development (based on any new information). The PEIR Addendum (Volume 9, Section 2.3) states that alternative changing rooms and track and field facilities would be provided within the Barn Elms Schools Sports Centre grounds prior to demolition. If C N
Open space and recreation
5.3.22
5.3.24
14037, 14062
5.3.25
LBW
5.3.26
Replacement changing rooms should be provided. Comments included: a. specification and location should be decided with the London Borough of Wandsworth
LBW, 14115
30

Ref Objections, issues and concerns b. should be opened before carrying out works c. should be included in the application d. should consult with Wandsworth Council and the managers of Barn Elms playing fields. 5.3.27 5.3.28 Gym facilities should be relocated. Replacement track and field facilities must be provided. 1 1 14010 14003 Total/ID number Our response the proposed changes are taken forward, the exact location of the new changing rooms would be agreed with the London Borough of Wandsworth, which owns the site, and the London Borough of Richmond, which is the local planning authority. It is likely that replacement changing rooms would be provided in close proximity to the existing facilities. We can confirm that the replacement facilities will be included in the application. The PEIR Addendum (Volume 9, Section 4.6) notes that the proposed route would introduce new residential receptors on Queen Elizabeth Walk and at the junction between Queen Elizabeth Walk and Rocks Lane. However, amenity effects for residents and users of the open space and the Thames Path are expected to remain as predicted in Volume 9 of the PEIR assessment. We therefore consider that the potential changes to the proposed route would result in material changes to the socio-economic assessment during construction at phase two consultation. However, the effects would be not significant. We consider that the realignment of the construction access route to the north of the playing fields in the targeted consultation proposals would have a lesser effect on residents of Horne Way and Stockhurst Close than the phase two consultation proposals. The PEIR (Volume 9, Section 10) and PEIR Addendum (Volume 9, Section 4.7) provide a preliminary assessment of the likely significant socioC
N N
Socio-economic 5.3.29 Prefer the access route put forward at phase two 1 consultation as there would be much less disruption to human activities. LR14064 N
5.3.30
Concerns regarding the effect of the proposals on local residential amenity, including residents of Horne Way and Stockhurst Close.
14010
31

Ref Objections, issues and concerns Total/ID number Our response economic effects, which built on the preliminary findings on a range of topics including noise and vibration, air quality (including dust emissions and odour), and transport, based on a methodology that was agreed with the London Borough of Richmond. We are preparing an environmental impact assessment that will include a comprehensive assessment of the likely significant effects of the proposals. The findings of the assessment, together with any recommendations for mitigation, will be set out in the Environmental Statement for submission with the application. The proposed access route was developed based on feedback from previous phases of consultation. We consider it the most suitable route: it is a sustainable option that would make use of existing roads and create a permanent new access road. The proposed option is also supported by statutory consultees. The proposal includes measures to enable construction traffic to negotiate the junction. The PEIR Addendum (Volume 9, Section 4.8) concludes that the movement of heavy goods vehicles (HGVs), the proposed changes to the highway layout and potential delays to journey times due to increased vehicle movements would have a minor adverse effect on all road users. This is an improvement on the moderate adverse effect predicted in the PEIR. In the PEIR, we expected that the vehicular access off Rocks Lane would result in a greater adverse effect as construction vehicles would need to make an uncontrolled right turn into the playing fields. C
Transport and access 5.3.31 Do not support the proposed access route as future developments need to be sustainable, and value the culture and heritage of the country. 8 14127LO, 14111LO, 14013, 14020, 14040, 14057, 14062, LR14064 14127LO, 14020 14013 N
5.3.32 5.3.33
Prefer the access route put forward at phase two 2 consultation. Prefer the construction traffic access route proposed at phase two consultation for the following reasons: a. It would avoid the congested five-way junction. 1
N N
32

Ref Objections, issues and concerns b. It would maintain the amenity of Queen Elizabeth Walk. c. It would be safer for the local community. d. It would separate people from construction traffic. Total/ID number 1 1 1 14013 14111LO 14013 Our response Please refer to para. 5.3.35. Please refer to para. 5.3.36. The new proposals would still segregate pedestrians from construction traffic; the access route would be hoarded before turning into a private road near the Barn Elms Schools Sports Centre. At phase two consultation, we proposed to remove the access route following construction, leaving capacity for future traffic increases. The proposed road at targeted consultation would be permanent. Construction vehicles would travel 0.9km along the targeted consultation access route, compared to 1.3km along the route at phase two consultation. The PEIR Addendum (Section 4.6) states that amenity effects on users of the Thames Path would remain negligible overall (as predicted in paras. 10.5.44 to 10.5.52 of Volume 9 of the PEIR). This is because there would be less of a visual effect than proposed at phase two consultation. The Thames Path was not identified as an air quality, dust, noise or vibration receptor, therefore users of the path would not experience any significant effects on overall amenity. Any potential effects on the Thames Path will be considered in the Transport Assessment for submission with the application. It should also be noted that the hoarding along the access road would be hoarded and an existing concrete wall between the playing fields and the Thames Path would minimise any visual effects. C N N N
e. It could be retained post-construction. f. It would have capacity for future traffic increases. g. Construction vehicles would travel a shorter distance to Rocks Lane. 5.3.34 Proposals would interfere with access to, use, enjoyment and tranquillity of the Thames Path. Proposals would negatively affect the enjoyment of the Thames Path, which attracts many people to Barnes.
1 1 1
14111LO 14111LO 14111LO
N N N
14037, 14145, 14005, 14013
33

Ref 5.3.35 Objections, issues and concerns Potential effect on access to, enjoyment and tranquillity of the WWT London Wetland Centre, which has a single vehicular access route from Queen Elizabeth Walk. Proposals would negatively affect the enjoyment of the WWT London Wetland Centre, which attracts many people to Barnes. Concerns regarding the effect of construction traffic on the safety of pedestrians, cyclists and local residents as it is a well-used recreational area. Concerns regarding the effect on Queen Elizabeth Walk included: a. It is a very busy access to the WWT London Wetland Centre and the River Thames for cyclists and pedestrians, including children. b. It is an important recreational route for cyclists, children, and the elderly. c. Disturbance would be similar to that during the construction of the WWT London Wetland Centre. 3 Total/ID number 14037, 14107,14145 Our response The PEIR Addendum (Volume 9, Section 4.3) states that, as the main construction site would be a sufficient distance from the WWT London Wetland Centre, the only potential impact on this receptor would be intermittent disturbance from passing construction traffic. The PEIR Addendum (Volume 9, Section 4.8) states that there would be a negligible increase in traffic flow along Queen Elizabeth Walk and therefore increased severance for pedestrians crossing Queen Elizabeth Walk. However, due to the low number of construction vehicle movements, during construction, the effect on pedestrians would remain moderate adverse and the effect on cyclists would be negligible. The project has a target zero health and safety objective. All site accesses and sites would be designed and operated to meet health and safety standards. The CoCP for submission with the application will include a requirement for a Traffic Management Plan to carefully control construction traffic in order to minimise any potential effects on the road network, residential amenity or access to the local area. The CoCP will also set out construction traffic routes, site access/egress points, signage and monitoring procedures. Data relating to recent accidents will be reviewed in the Transport Assessment for submission with the application. The proposals will be subject to an independent external review by TfL and the local highway authority to ensure that proposed highway layouts and vehicle movement arrangements are as safe as possible. These issues will be addressed further in the C N
5.3.36
14020
5.3.37
14111LO, 14040, 14013, LR14064
34

Ref 5.3.38 Objections, issues and concerns More information is needed on the access proposals and associated effects, including: a. how the access road would be made b. how intrusive the access road would be in relation to the Thames Path and frequency of use c. whether there would be any temporary or permanent closure of the Thames Path or Queen Elizabeth Walk, which are extremely popular with walkers, runners and cyclists d. whether the internal road would be visible or blend into the natural beauty of Barn Elms and the Thames Path. 5.3.39 The access road should be a reinforced structure through which grasses can grow, which would be suited to the infrequent maintenance access requirements, and preferable to a tarmac road. Concerns regarding the size of the internal road. 1 Total/ID number 14030 Our response Transport Assessment. Further details on the construction methodology will be included in the application for development consent. For details of the effects on the Thames Path, see para. 5.3.34. For details on frequency of use, see para. 5.3.47. We do not propose to close the Thames Path or Queen Elizabeth Walk temporarily or permanently. C N
14030
14105
14060
14114
The permanent access road would be built with a reinforced concrete material that allows grass to grow up through it, in order to retain the ecological value and visual amenity of the site.
5.3.40
14060
The PEIR Addendum (Volume 9, Section 2.3) states that the proposed construction route would be 5m wide, which is the same as at phase two consultation. On completion of the works, the construction access road would be reduced from 5m wide to 3m. We can confirm that we undertook traffic surveys in preparing the Transport Assessment for submission with the application. The methodology for the surveys was agreed with the London Borough of Wandsworth and TfL.
5.3.41
Traffic surveys should be completed before the proposed access route is considered further.
14111LO
35

Ref 5.3.42 Objections, issues and concerns Local residents should have the final say on the proposals. 1 Total/ID number 14011 Our response The project programme specifically reserved time to undertake public consultation and address the feedback received. Our approach to consultation was agreed with the potentially directly affected local authorities, (see the SOCC). The approach is consistent with guidance provided by the DCLG and advice from the Planning Inspectorate on preapplication consultation. We are confident that it complies with the pre-application requirements of the 2008 Act. It should be noted that the access route at targeted consultation runs along the opposite side of the Thames Path. The route at targeted consultation was proposed in response to comments from phase two consultation, and is supported by a number of statutory consultees. All alternative access routes have been considered. C N
5.3.43 5.3.44
Alternative access route suggestion: run the road on the other side, not along the tow path. Alternative construction transport access route suggestions included: a. Bridge Beverley Brook and cross Putney Lower Common, a much more direct route, which would avoid congestion altogether. b. Examine other possibilities of accessing the site from the east such as only using the river or using the river and limited use of the Embankment.
1 2
14062 TfL, 14013
N N
5.3.45
Give careful consideration to proposed junction modifications and the location of any new stop lines to safeguard pedestrians, cyclists and other vulnerable road users. Traffic light phasing would require modification. Planning conditions should restrict the number of construction vehicle trips to ten per day and speed to 10mph. More information is required on the proposed
14107
5.3.46 5.3.47
1 1
14028 14040
5.3.48
14010
The proposed changes to the junction of Queen Elizabeth Walk and Rocks Lane include temporarily moving the stop line by 0.5m. Signal optimisation at the junction could minimise effects on road users. Further details will be agreed with stakeholders prior to submission of the application for development consent. Appendix A of the Section 48 Transport Strategy states that an average of six HGVs per day would access the site during the construction period. This
N N
36

Ref Objections, issues and concerns changes at the intersection and the anticipated effect on traffic. Proposed site access and associated modifications to the junction between Queen Elizabeth Walk and Rocks Lane would exacerbate existing traffic congestion. Comments noted: a. current delays at the weekend and regularly during the week b. worsening traffic levels and congestion since 1998 c. existing difficulties exiting the junction due to the busy WWT London Wetland Centre and Barn Elms sports facilities d. previous traffic calming measures that proved unsuitable e. existing high levels of air pollution. 1 14013 9 Total/ID number Our response would rise to a peak of 22 HGVs per day for a onemonth period. The Section 48 Project description and environmental information report (Section 5.3) considers the potential for likely significant effects arising from the increase in HGV movements and states that construction activity would likely result in a minor adverse effect on road network operations and delays. This issue will be addressed further in the Transport Assessment for submission with the application. We have carried out traffic surveys. The CoCP for submission with the application will include a requirement for a Traffic Management Plan to carefully control construction traffic in order to minimise any potential effects on the road network, residential amenity or access to the local area. The CoCP will also set out construction traffic routes, site access/egress points, signage and monitoring procedures. The S48 Project description and environmental information report (Section 5.3) recognises that the Barn Elms site falls within the London Borough of Richmond upon Thames Air Quality Management Area, in which air quality objectives are currently exceeded at roadside locations in the vicinity of the site. We consider that there would be a minor adverse effect overall on local air quality from construction road traffic and construction plant at the WWT London Wetland Centre and residential properties. There would likely be a negligible effect on users of the Barn Elms School Sports Centre, Barn Elms Boathouse and playing fields. C
5.3.49
14111LO, 14010 14022, 14023, 14024, 14028, 14040, 14145, LR14064
37

Ref Objections, issues and concerns Total/ID number Our response The PEIR Addendum (Volume 9, Section 4.2) concludes that, while the new proposed access route would introduce new receptors and result in material changes to the phase two consultation air quality assessment during construction, the effects would still not be significant. The PEIR Addendum (Volume 9, Section 4.8) states that the volume of construction traffic movements would have a negligible effect on bus users and operators. The new access route alignment would not require the relocation of any existing bus stops, and is therefore preferred to the phase two consultation access route. At most sites, we plan to carry out the majority of works within standard working hours, which are 8am to 6pm weekdays, and 8am to 1pm on Saturdays. However, in view of the unique nature of the Barn Elms site and the fact that peak usage falls on weekends, we are considering prohibiting construction traffic on Saturdays. We might occasionally need to carry out works outside of standard working hours in order to undertake large concrete pours, deliver abnormal, large and heavy loads at times when there is reduced traffic, or make connections onto the existing sewer system at night when there is low sewage flow. Continuous 24-hour working would be required during the tunnelling and secondary lining phase of construction; however, noise would be limited as much as possible at night and there would be no HGV movements in or out of the site. C
5.3.50
Concerns regarding the effect of the proposed access route on local bus stops and services, including the 33 and 72 routes along Rocks Lane, which already experience significant delays. Restrict or limit working hours when construction and related vehicles access local roads, including rush hours.
14010
5.3.51
14023, 14024
38

Ref 5.3.52 Objections, issues and concerns Consult with TfL to appraise junction modelling for proposed adjustments to signal timings/phases and safety audits at appropriate stages. Provide alternative car parking in consultation with Wandsworth Council. 1 Total/ID number TfL Our response Discussions with TfL and the London Borough of Richmond are in progress. C N
5.3.53
14115
As set out in the PEIR Addendum, approximately 30 spaces on Queen Elizabeth Walk would be relocated. Discussions with the London boroughs of Wandsworth and Richmond regarding provision of parking in this area are on-going.
5.4
5.4.1
Feedback in relation to the PEIR Addendum

This section sets out feedback in relation to the Barn Elms PEIR Addendum. The supportive and neutral comments are set out in Table 5.5. No objections, issues or concerns were raised. Table 5.5 Barn Elms: Supportive and neutral comments in relation to the PEIR Addendum
Supportive and neutral comments Total/ID number Our response
Ref
Heritage 5.4.2 Support for the treatment of the historic environment in the consultation material; the proposed scope of archaeological works could be applied to the modified engineering programme.
EH
Your comment is noted and welcomed.
39
5.5
5.5.1
Our view of the way forward

We received a range of feedback in relation to our proposals for a revised construction access at this site at targeted consultation and Section 42 consultation in respect of changes to the site boundary, including supportive and neutral comments as well as objections, issues and concerns. We took all the feedback received into account in accordance with the requirements of the 2008 Act. Having considered the feedback received, we still believe that the revised access route is the most suitable. This conclusion is reflected in the material produced for Section 48 publicity. Full details of the proposed scheme will be set out in the application and the accompanying documents.
5.5.2 5.5.3
40
6 Targeted consultation: Putney Embankment Foreshore
6
6.1
6.1.1
Targeted consultation: Putney Embankment Foreshore

Introduction
Our proposal
At phase two consultation we proposed to use the Putney Bridge Foreshore site, which comprised the foreshore of the River Thames to the west of Putney Bridge on the south side of the river. The site would be used for our construction works to connect the Putney Bridge CSO to the main tunnel and to accommodate the permanent structures required to operate the main tunnel. In response to feedback received at phase two consultation and further technical work, we undertook targeted consultation on our proposals to change the location of the site to the Putney Embankment Foreshore site, the layout of the temporary works and the design of the permanent works. The key proposed changes comprise:
a. b. c.
6.1.2
relocation of the permanent area of hardstanding approximately 30m to the west re-configuration of the temporary replacement slipway to include a prefabricated steel structure that would be assembled on-site a new construction traffic route to the temporary slipway site that would run westwards along Lower Richmond Road, turn right into Glendarvon Street and right onto Embankment; construction vehicles would exit from Embankment via Thames Place and onto Lower Richmond Road temporary relocation of an existing houseboat during the construction period.
d.

6.1.3 6.1.4 This section sets out targeted consultation feedback together with feedback from Section 42 consultation in respect of changes to the site boundary in relation to the proposed amendments at Putney Embankment Foreshore. This section is organised as follows to reflect the scope of targeted consultation:
a. b.
Section 6.2: Number of respondents Section 6.3: General comments
41

c. d. e. f. g.
Section 6.6: Configuration of the temporary replacement slipway Section 6.8: Main construction site Section 6.9: Permanent design Section 6.10: PEIR Addendum Section 6.11: Our view of the way forward.
6.1.5
In Sections 6.3 to 6.10 we detail the groups and total number of respondents, the comments received and the projects response.
6.2
6.2.1
A total of 57 respondents provided feedback in relation to Putney Embankment Foreshore at targeted consultation and Section 42 consultation in respect of changes to the site boundary, of which four responded after consultation had closed. The number of respondents in each group is set out in Table 6.1. Table 6.1 Respondents to targeted consultation and Section 42 consultation in respect of changes to the site boundaryat Putney Embankment Foreshore
Respondent group Statutory consultees (SC) Local authorities (LA) Landowners (LO) Community consultees (CC) Petitions (PET) 4 1 6 45 1 petition with 65 signatories Number of respondents
42
6 Targeted consultation: Putney Embankment Foreshore 6.2.2 Table 6.2 sets out the statutory consultees and local authorities who provided feedback for this site. Table 6.2 Statutory consultees and local authorities who responded to targeted consultation and Section 42 consultation in respect of changes to the site boundary at Putney Embankment Foreshore
Statutory consultees Design Council CABE (CABE) Transport for London (TfL) Port of London Authority (PLA) English Heritage (EH) Local authorities London Borough of Wandsworth (LBW)
6.2.3
Feedback in relation to this site was received in a number of forms, including feedback forms and correspondence (one petition, emails and letters).
6.3
6.3.1
General comments
The supportive and neutral comments are set out in Table 6.3. The objections, issues and concerns in relation to site selection and general issues and how we propose to address them are presented in Table 6.4 and Table 6.5. The comments are grouped by theme, as denoted by the sub-headings shaded in orange.

Table 6.3 Putney Embankment Foreshore: Supportive and neutral comments in relation to general issues
Ref 6.3.2 6.3.3 Supportive and neutral comments Proposals for the site are an improvement from phase two consultation. The revised proposal is an improvement in terms of the effect on the historic environment, specifically: a. the Grade II listed bridge 3 2 Total/ID number 14036, 14058, 14122 EH, LR14124LA Our response Your comments are noted and welcomed.
43

Ref 6.3.4 Supportive and neutral comments b. the historic slipway. Support the location of the projection into the River Thames as: a. it creates separation between the new structure and the slipway an important feature within the heritage setting that includes the listed bridge and arches b. it is further from the Grade II listed bridge, and there is much less alteration proposed around the historic slipway which we consider provides a significant positive contribution to the character and appearance of the Embankment Conservation Area. 6.3.5 6.3.6 The revised proposal provides better access to the structure from Embankment. Support for the proposals subject to resolution of detailed matters, the London Borough of Wandsworth would welcome continued cooperation and discussion of these matters. 1 1 LBW LBW Your comment is noted; we will continue to work with the London Borough of Wandsworth in the development of our proposals. 2 Total/ID number CABE, EH Our response
Site selection
Table 6.4 Putney Embankment Foreshore: Objections, issues and concerns in relation to site selection
Ref Objections, issues and concerns 3 Total/ID number 14103LO, LRMD14101LO, 14015 Our response The sites that we consulted on were identified through an extensive site selection process (see the Site selection methodology paper). We consulted on and agreed the methodology with key stakeholders C N/A Site selection 6.3.7 Object to the use of this site.
44

Ref Objections, issues and concerns Total/ID number Our response including potentially directly affected local authorities. We utilised a multidisciplinary approach to assess potential CSO sites against engineering, planning, environmental, property and community considerations. We recognise that, given the locations in which we are seeking to construct and operate the main tunnel, many of the shortlisted sites are constrained. However, based on our assessment we consider that, on balance, Putney Embankment Foreshore is the most suitable site. This is because, in comparison to Lower Richmond Road Foreshore, Putney Embankment Foreshore is located further from the Grade II listed Putney Bridge, which would reduce the impact on its setting. The revised location of the permanent structure would also improve the relationship with the historic slipway and would enable boats to moor safely against the side of the historic slipway. For further details on the site selection process, including our assessment of shortlisted sites, refer to Appendix D of the Section 48: Report on site selection process. The site was relocated in response to phase two consultation feedback in relation to positioning the permanent structure further away from the Grade II listed Putney Bridge in order to reduce the impact on setting, reduce physical and visual effects on the public drawdock/slipway, enable mooring along the drawdock/slipway following construction, and mark the start of major river events in the newly created area of public realm. We are carrying out noise and townscape and visual C
6.3.8
Object to the relocation of the site further west because: a. the visual and noise nuisance of the preferred site at phase two consultation would be marginal compared to the new proposed site and this is therefore an inadequate reason to relocate the site
N/A
45

Ref Objections, issues and concerns Total/ID number Our response impact assessments, which will be reported in the Environmental Statement for submission with the application. The proximity of the site to this and other sensitive local receptors was one of the considerations in the site selection process. The Environmental Statement for submission with the application will consider the likely significant effects of the proposed development including effects on local properties. 1 14106 We consider that we have conducted a thorough and comprehensive consultation exercise. We carefully considered the information we made available at targeted consultation to ensure that consultees had sufficient information in relation to the proposed changes to our proposals to respond to the consultation. The Putney Embankment Foreshore supplementary site information paper provided details on the reasons for the revisions to our preferred site and why we consider Putney Embankment Foreshore to be the most suitable site. See para. 6.3.7. In relation to the specific alternative site suggestions: Sites were selected on the basis of needing to intercept existing CSOs. CSOs are in fixed locations and sites to intercept them need to be on the line of, or in close proximity to, the sewer. Putney Bridge CSO is located under Putney Bridge, so the CSO needs to be intercepted on the southern side of the river in the vicinity of the CSO. The foreshore at Hammersmith on the northern side of the river is too far away from the C
b. the new location is closer to the Star & Garter Bar and local residents.
N/A
6.3.9
More information is needed on changes to the site location since phase two consultation.
N/A
Alternative sites 6.3.10 Consideration should be given to the use of alternative sites. Suggested sites included: a. Hammersmith foreshore, which is more industrial in character a six foot ventilation column would be in keeping here 1 14034 N/A
46

Ref Objections, issues and concerns Total/ID number Our response Putney Bridge CSO to be considered as a potential site. C
b. The phase one consultation preferred site, because it uses Waterman's Green, is closer to the CSO and would cause less disturbance to properties on Lower Richmond Road and Putney Embankment.
14059
c. East of Putney Bridge (site 1 at phase one consultation). Reasons included: i It would not cause as much disruption to the church and mainly residential
LRMD14101LO
See para. 6.3.7. N/A The phase one consultation site included a small proportion of the temporary construction area on Watermans Green; however the majority of the site and main works were located in the foreshore (as in the targeted consultation proposal). In response to phase one consultation feedback, we removed Waterman's Green from the temporary construction area. This was to reduce the likely significant effect on the natural environment and the loss of open space during construction. It would also maintain emergency access to the adjacent vaults, and avoid affecting the potential future development of the vaults. Although the phase one consultation site was closer to the CSO, in view of all the considerations in our site selection process, we moved the site marginally to the west to reduce the likely significant effect on the setting of the Grade II listed Putney Bridge and to improve the location and design of the permanent structure. The Environmental Statement for submission with the application will assess the likely significant effects of the proposed development, including effects on local properties. Due to the flexible nature of foreshore sites, in order to N/A be consistent with other foreshore sites and to more accurately reflect what was presented at phase one and phase two consultations, we re-organised our internal site referencing to include a new area of
47

Ref Objections, issues and concerns buildings in that area, and any disruption would be limited to the construction period. ii It is more suitable in heritage, landscape and visual terms although it is within the setting of the listed church and bridge, the visual effect on the other heritage assets would be limited because of the height of the bridge. The area is also more urban in character due to Putney Wharf Tower and recent associated development. iii Objections to this site can be refuted: the slipway is not a listed structure, so its relocation might not be ruled out. However, the whole area west of the bridge was identified as having a wellpreserved Victorian character that would be spoilt by any of the CSO sites west of the bridge. iv The site is accessible via Brewhouse Lane and the completed CSO structure would not be detrimental to the modern buildings along this section of the riverside and would provide an additional public area. v There is a large level difference between the existing outfall and the proposed tunnel; so there would be sufficient fall to enable the CSO drop shaft to be located a long way from the bridge, particularly in a downstream (easterly) direction. The Total/ID number Our response foreshore that had not previously been covered. One of the new sites included was Putney Wharf Foreshore, which overlapped the two phase one consultation sites east of Putney Bridge. In our post phase two consultation assessment, the new Putney Wharf Foreshore site replaced the two sites east of Putney Bridge, which were not considered further. We consider that Putney Wharf Foreshore would be less suitable than Putney Embankment Foreshore. This is because Putney Wharf Foreshore would disrupt more sensitive receptors and equality groups, such as users of the church and the childrens nursery group. Furthermore, the adjacent Putney Wharf Tower and nearby Boathouse public house would experience more direct disruption than from the Lower Richmond Road Foreshore and Putney Embankment Foreshore sites. Moreover, as construction access to the site would need to be via the narrow Brewhouse Lane and across a pedestrianised area, the residential properties and businesses in the vicinity would experience more construction-related effects on Lower Richmond Road if a site on the foreshore to the east of the bridge were used. For further details on the results of the site selection process including the assessment of shortlisted sites, refer to Appendix D of the Section 48: Report on site selection process. C
48

Ref Objections, issues and concerns cost of the connecting culvert or sewer would be higher, but this is assumed to be a small part of the total cost. vi Access is more difficult but this could be addressed by use of river transport and by a temporary vehicle access arrangement over the pedestrian only area during the construction phase only. d. East of Putney Bridge (site 2 at phase one consultation). Reasons included: i It would cause least disturbance to businesses and residential properties. 1 LRMD14101LO N/A Total/ID number Our response C
ii It is the closest site downstream of the existing CSO. iii It is less preferable than site 1 at phase one consultation in heritage terms since it would have a detrimental effect on the listed site. iv Access is more difficult but this could be addressed by the use of river transport and by a temporary vehicle access arrangement over the pedestrian only area during the construction phase only. e. East of Putney Bridge would be more in keeping with the modern feel; the piazza could be extended. f. It would be possible to build a chamber further up the sewer and divert the overflows via a new sewer laid along one lane of the 1 14062 N/A
LRMD14101LO
Laying new upsized pipework would require the construction of a new interception chamber within the carriageway of Lower Richmond Road. This
N/A
49

Ref Objections, issues and concerns existing highways. There would be traffic disruption, but it would allay heritage concerns regarding works to the bridge and the need to lay a culvert in the foreshore. The diverted sewer could be routed to sites to the west of Putney Bridge via Lower Richmond Road and Thames Place or to the east along Putney Bridge Road. Total/ID number Our response carriageway currently rests on a number of underground vaults. Constructing the chamber would require the demolition of these vaults and a large, deep excavation, which would likely require the closure of Lower Richmond Road. Any new pipework to the CSO at Dormay Street would need to be aligned along Putney High Street and Putney Bridge Road. The diameter and significant depth of the new pipework would likely require significant traffic management during construction and the associated utility diversions. We consider that the disruption, duration and cost associated with these works would be greater than with the current proposals. Sites were selected on the basis of the need to intercept existing CSOs. CSOs are in fixed locations and sites to intercept them need to be on the line of, or in close proximity to, the sewer. Putney Bridge CSO is located under Putney Bridge, and therefore needs to be intercepted in the vicinity. Sites further east and west of Putney Embankment Foreshore (including the site of the temporary slipway, which is to the west of our preferred site) were considered too far away and therefore not suitable. C
g. Construct the CSO drop shaft at the site of the temporary slipway. Major works are planned here anyway, so the change would just be a longer construction period. The only adjacent properties are the Boat Builders and the back gardens of a few residential properties. It is noted that the site is important in heritage terms so any major change in its appearance would compromise the setting of the heritage site. h. Wandsworth Park the CSO drop shaft structure could provide a new public viewing platform with good views up and down the River Thames.
LRMD14101LO
N/A
LRMD14101LO
N/A
i. Bell Lane Creek the extra cost of the 1 transfer culvert length would be offset by eliminating one drop shaft structure and connection. The area is also more suitable as it has predominantly commercial and
LRMD14101LO
N/A
50

Ref Objections, issues and concerns industrial uses, with a solid waste transfer station on the far side of the River Wandle. Disagree with/not commenting on site selection due to wider objections to the proposed solution and/or the need for the project. Reasons included: 1 Total/ID number Our response C
6.3.11
LRMD14101LO
The need for the project is set out in detail in the Needs Report. It is also summarised in a nontechnical form in our publications Why does London need the Thames Tunnel? and Why does Londons economy need the Thames Tunnel? The need for the project was confirmed and reaffirmed both by the past and present governments. This was clearly stated in written Ministerial Statements to Parliament in September 2010 and in November 2011. The need for the project is further reinforced in Defras Creating a River Thames fit for our future: a strategic and economic case for the Thames Tunnel and Costs and benefits of the Thames Tunnel (November 2011). The National Policy Statement for Waste Water (the Waste Water NPS), which was designated on 26 March 2012, clearly states that the need for the project has been demonstrated. It concludes that detailed investigations have confirmed the case for a Thames Tunnel5 as the preferred solution. The designation of the NPS was supported by an Appraisal of Sustainability Post-Adoption Statement, which contains further detail on the significant amount of work undertaken to establish the need for the project and assess alternatives. Having regard to the extensive work that has been undertaken since 2000, we consider that the need for the project has been adequately demonstrated.
N/A
The project changed its name from the Thames Tunnel project to the Thames Tideway Tunnel project in July 2012.
51

Ref Objections, issues and concerns a. Putney Bridge CSO discharges 0.17 per cent of the annual discharge of the 57 CSOs along the River Thames. b. If Putney Bridge CSO were not connected, discharges would only increase to six per cent and required water quality improvements might still be achieved. This could be monitored and the Putney Bridge CSO connected only if the quality improvements were not achieved. c. SuDs would cost about the same as connecting the CSO to the project and would reduce the volume of discharge by 76 per cent; this alternative would be just as effective in this location. Total/ID number Our response The Needs Report identifies the Putney Bridge CSO within the category of CSOs that most urgently needs to be addressed. Table 4.2 of the Needs Report provides further details. Based on the Environment Agency's assessment, this CSO must be intercepted. C
We considered a wide range of options to reduce and control the volume of untreated sewage that flows into the River Thames, including local storage and treatment, SuDS, separation of the sewerage system, and bubblers and skimmers. None of these options were considered practical; they costed more and often would not provide the same level of CSO control or the same benefits at the tunnel solution. The project could also be implemented more quickly than SuDS or the separation of sewerage system. We assume that the 76 per cent volume reduction refers to the implementation of the PWG disconnection strategy (using SuDS) published in Appendix E of the Needs Report. The PWG disconnection strategy represents disconnecting approximately 52 hectares of hard surfaces such as roofs, drives, car parks, roads and pavements to reduce rainfall run-off entering the local Putney combined sewer catchment. This is a considerable area, equivalent to approximately 75 football pitches and represents over 35 per cent of the total area. Although this level of SuDS implementation would
52

Ref Objections, issues and concerns Total/ID number Our response produce a significant volume reduction at Putney Bridge, the number of individual CSO discharge events in a typical year would remain high. We concluded that SuDS alone would not provide sufficient CSO control to eliminate the need for additional CSO control facilities at Putney Bridge. Furthermore, the PWG disconnection strategy did not take account of factors such as cost (initial capital, operation and maintenance), who pays, public and planning acceptance, environmental and social cost/benefit. The strategy was considered to be the maximum level of disconnection that could practically be applied, however it was insufficient to meet the environmental CSO control requirements; it would also take significantly longer to implement and affect far more local residents compared to the project CSO control option. A further iteration of the disconnection strategy was developed by PWG to provide a more realistic and practicable refined disconnection strategy for SuDS in the Putney Bridge sewer catchment. The refined SuDS option would remove a smaller area of impermeable surfacing that contributes to the combined sewer, however analysis showed that this option would also fail to meet the CSO control requirements (in the EU Urban Waste Water Treatment Directive, the UWWTD). The Thames Tideway Tunnel project and the Lee Tunnel project would provide over 1.5 million m3 of storage for CSO wastewater discharges that currently enter the tidal Thames and would reduce the number of CSO discharge events from over 50 in a typical year to four or less. Although the main tunnel would C
d. if a replacement CSO ultimately proves necessary, the preferred option would be to eliminate the need for a Putney Bridge CSO by providing additional capacity for land based sewers or a long transfer culvert to the Bell Lane Creek CSO
53

Ref Objections, issues and concerns Total/ID number Our response provide a considerable storage volume, on occasion significant rainfall events would fill the tunnel and CSOs would discharge to the river. These discharges would occur at existing CSO locations or at reconstructed CSO discharge points built as part of the project site works because the storm relief sewers drain into these locations. CSOs would discharge to the tidal Thames following construction of the project when the tunnel system has reached capacity and the local combined sewer is full. There is limited space for additional storage in the Putney Bridge network and there will always need to be a CSO discharge point for significant rainfall events, even if it is rarely active. A long transfer culvert would require significant design, planning and ultimately construction work along the River Thames, which would affect a large number of local residents. The culvert would require a constant gradient to prevent sediments building up from wastewater travelling along it. Air treatment equipment would also be required. The CSO discharge culvert would need to allow wastewater to travel along it and discharge at a similar height (relative to the foreshore) as existing, however, the constant gradient of the culvert that would be required would not enable this when it reaches other sites. Furthermore, the other CSO locations were designed and built to have capacity for their storm relief sewers; therefore, if the Putney Bridge CSO were culverted to another location, a new CSO discharge point would be required in the Embankment or river wall. This new CSO would likely be opposed by the Environment Agency, especially at Bell Lane Creek, which has less C
54

Ref Objections, issues and concerns Total/ID number Our response river flow than the tidal Thames and discharges would have a greater impact on local river water quality. See para. 6.3.10 for our response to providing a long transfer culvert to the Frogmore Storm Relief Bell Lane Creek CSO. We undertook detailed modelling studies throughout the process of determining the most appropriate solution to unsatisfactory CSO discharges into the tidal Thames. These studies informed the projects design development. The Needs Report details the catchment-wide modelling of sewer separation, local storage increases and the use of SuDS as an alternative to the project. It concluded that sewer separation would cost significantly more than the tunnel solution and it would affect almost every resident in London as most roads would require construction works to separate the combined sewers underneath. Local storage for each CSO was also investigated and it was demonstrated that in order to meet the requirements of the UWWTD to limit discharges into the tidal Thames, the required storage volume would be significant. In the Putney Bridge CSO catchment area, storage could not be provided in the existing network and would have to be constructed in a similar location to the proposed site. The cost of building storage, air treatment facilities and a pumping station to return wastewater to the sewer when water levels subside following storm events would be greater than the project works and would likely require a larger construction site for a significant period of time and more maintenance when complete. C
e. A detailed modelling study of the local sewerage system should be undertaken to see what improvements or alterations could be made to create more storage or conveyance to reduce the size and frequency of the overflows at the Putney Bridge CSO. The study could also look at surface water connections to see if these could be separated and routed to the River Thames directly rather than into the combined system, which would also reduce the need for CSO operation.
55

Ref Objections, issues and concerns Total/ID number Our response Implementing SuDS as an alternative to the project for the Putney Bridge CSO catchment was also modelled. The maximum possible SuDS implementation would disconnect approximately 52 hectares of hard surfaces such as roofs, drives, car parks, roads and pavements to reduce rainfall run-off entering the local Putney Bridge combined sewer catchment. This is a considerable area, equivalent to approximately 75 football pitches and represents over 35 per cent of the total area. Even with this level of disconnection, it was demonstrated that the Putney Bridge CSO would still not meet the requirements of the UWWTD. C

Table 6.5 Putney Embankment Foreshore: Objections, issues and concerns in relation to general issues
Ref Objections, issues and concerns 2 Total/ID number LRMD14101LO, 14036 MD14134 Our response We recognise that the site is in close proximity to a number of local historic and listed structures (see the Putney Embankment Foreshore supplementary site information paper and the PEIR Addendum (Section 4.4)). In designing the scheme, we sought to preserve and enhance the character and appearance of the Putney Embankment Conservation Area and to reduce likely significant effects on the setting of the Grade II listed Putney Bridge and the Grade II* listed St Mary's Church. We are carrying out a historic environment assessment, which will be reported in the Environmental Statement for submission with the application. This assessment will set out any likely C N Historic environment 6.3.12 Concerns regarding the effect on the historic environment including the historic slipway, the setting of Putney Bridge, Putney Pier, the Star & Garter and the Victorian character of the area. 6.3.13 More information is needed on the effect on St Mary's Church during construction.
56

Ref Objections, issues and concerns Total/ID number Our response significant effects of the construction activities, including effects on the setting of historic assets, such as Putney Pier and the University Boat Race Stone, and any mitigation required to address these effects. The draft CoCP (provided at phase two consultation) stated that works to or in the vicinity of listed buildings would be undertaken in accordance with all required consents and licences and that protection measures would be put in place at the start of the works. We would also notify English Heritage and the local planning authority prior to commencing works. We are aware of recent planning applications and are discussing our proposals with the London Borough of Wandsworth. C
Planning and development 6.3.14 Consideration should be given to recent planning applications when developing proposals including the application for a restaurant in the vaults of 4-6 Lower Richmond Road and seating on Waterman's Green. Socio-economic 6.3.15 Concerns regarding the effect on local businesses during construction and operation, including effects on: a. the Star & Garter Restaurant and Bar b. the Thai Square Restaurant c. river bus services operated by LRS, which are to be trebled from Putney to Blackfriars from October 2012.
MD14134
LBW, LRMD14101LO, MD14134
As stated in the PEIR (Volume 10, Section 10), we believe that any potential effects on business amenity would likely only affect a relatively small number of businesses at this site. We are in discussions with each of the businesses in question. The PEIR Addendum (Section 4.6) states that amenity effects on residents and businesses resulting from noise, air quality and visual effects during construction remain as predicted in the PEIR assessment. The Environmental Statement for submission with the application will assess the likely significant effects of the proposed development. We have also published a Guide to the Thames
57

Ref Objections, issues and concerns Total/ID number Our response Tunnel compensation programme, which sets out details of compensation that would be available to address damage or loss due to construction, required protection measures or compulsory purchase. Landowners may have a statutory entitlement to claim compensation for the diminution in the value of their property due to the construction of the tunnel. In addition to the statutory process we have published an Exceptional hardship procedure, which sets out how we would assess claims from householders who contend that they are suffering exceptional hardship as a result of being unable to sell their property because it is potentially affected by our currently published proposals. We have also published a Guide to the Thames tunnel compensation programme, which sets out details of compensation that would be available during construction for damage or loss, required protection measures or compulsory purchase. The PEIR (Volume 10, Section 9) provides a preliminary qualitative assessment of the potential effects of noise and vibration arising from the proposed construction activities and associated traffic. The noise and vibration assessment was updated in the PEIR Addendum (Section 4.5) to take account of the proposed changes at targeted consultation. The PEIR Addendum (Section 4.6) states that amenity effects on residents and businesses resulting from noise, air quality and visual effects during construction remain as predicted in the PEIR (Volume 10, Section 10). The Environmental Statement for submission with the C
6.3.16
Concerns regarding the provision of suitable compensation, which may not fully address the loss of business at the Star & Garter Bar and Restaurant and Thai Square Restaurant. Concerns regarding the effect of construction on property values, including Star & Garter Mansions.
14015, MD14134
6.3.17
14044LO, 14135LO, 14031
6.3.18
Concerns regarding the effect on local residents included: a. the effect on quality of life b. the effect of noise pollution on residential amenity c. the effect of three and a half years of disruption on residents of Star & Garter Mansions d. the effect of noise, vibration, dirt, extra traffic and loss of views on quality of life at Kenilworth Court
14103LO, 14134LO, LR14063, MD14134
58

Ref Objections, issues and concerns e. effect on property values. Total/ID number Our response application will assess the likely significant effects of the proposed development. Details of the measures to be adopted during the construction works will be set out in the CoCP for submission with the application. We consider that we conducted a thorough and comprehensive consultation exercise. The access proposals were set out in our targeted consultation materials. We carefully considered the possible options for the temporary diversion of the Thames Path and cycle-path in developing our proposals. As illustrated in the Putney Embankment Foreshore supplementary site information paper, this route was proposed because we consider it to be the best option for the temporary diversion. Any diversions would be agreed with the London Borough of Wandsworth and TfL. We carefully considered the information we made available at targeted consultation to ensure that consultees had sufficient information to respond. Information on how we would transport construction materials and our preliminary assessment of transport effects were set out in the PEIR (Volume 10, Section 12) and PEIR Addendum (Volume 10, Section 4). In our Section 48: Transport Strategy we increased our commitment to river transport since phase two and targeted consultation. At this site, we propose to use river transport to remove excavated material from the shaft and the connection tunnels, interceptions and associated structures and to import and export cofferdam fill materials. However, it is not generally practical or cost-effective to transport all materials by C
Transport and access 6.3.19 More information is needed on the potential temporary or permanent closure of the Thames Path, which is extremely popular with walkers, runners and cyclists. 6.3.20 Concerns regarding the diversion of the Thames Path during construction.
14105
TfL
6.3.21
Object to the proposals as no reassurances have been given that all materials would be transported by river only. More information is needed on the extent of construction traffic including the number of lorries and barges expected to be used each day and what materials would be transported.
14005
6.4
6.4.1
MD14134
6.5
59

Ref Objections, issues and concerns Total/ID number Our response barge therefore some materials would still be transported by road. The Section 48 Transport Strategy states that our increased commitment to river transport would have considerable benefits in terms of reducing total vehicle numbers and associated impacts. At Putney Embankment Foreshore, the overall predicted HGV numbers were reduced by 28 per cent from phase two consultation (from 4,650 to 3,350 HGVs). The daily peak average of HGV movements during construction would be 21 per day and two barges per day. The length of the construction period indicated in the phase two consultation documents is the maximum period. The programming of works at all sites would be configured to reduce the duration of works and associated disruption to the local area as far as possible. We will discuss details further with TfL and the London Borough of Wandsworth to ensure that any significant transport effects are identified in the Environmental Statement for submission with the application. C
6.6
6.6.1
Configuration of the temporary replacement slipway

This section sets out the feedback in relation to our proposed configuration of the temporary slipway required as part of the works at Putney Embankment Foreshore. The supportive and neutral comments are set out in Table 6.6 and the objections, issues and concerns in Table 6.7. The comments are grouped by theme, as denoted by the sub-headings shaded in orange. All feedback on this issue relates to the construction phase.
60

Table 6.6 Putney Embankment Foreshore: Supportive and neutral comments in relation to the configuration of the temporary slipway
Ref 6.6.2 6.6.3 6.6.4 Supportive and neutral comments General support for the provision of a temporary slipway during construction. Support the fact that a cofferdam is no longer required. Support the reduction in construction duration associated with the use of a prefabricated temporary slipway. Support the revised configuration of the temporary slipway including bringing support services onshore and using floating working platforms. This is not only a more efficient design, but the footprint of the works would be reduced by about 70 per cent, which would result in considerable time and cost savings. Proposals for the temporary slipway are an improvement from phase two consultation and comments made at phase two consultation have been taken into account. 1 3 3 Total/ID number 14011 14122, 14132, MD14134 14115, 14122, MD14134 14050, 14115, 14132 Our response Your comments are noted and welcomed.
6.6.5
6.6.6
14132, LR14130
61

Table 6.7 Putney Embankment Foreshore: Objections, issues and concerns in relation to the configuration of the temporary slipway
Ref Objections, issues and concerns 2 1 Total/ID number PLA, 14131 LR14130 Our response We consider that we conducted a thorough and comprehensive consultation exercise. We carefully considered the information we made available at targeted consultation to ensure that consultees had sufficient information to respond to the consultation. The construction site must be able to accommodate the necessary works. The Putney Embankment Foreshore supplementary site information paper details the maximum area of the construction site for the temporary slipway construction phase. The construction site layout was developed to minimise the area required. In response to phase two consultation comments, we reconsidered our approach to delivering the temporary slipway. Our proposals for the construction of the temporary slipway at targeted consultation required a smaller site than at phase two consultation as we removed the cofferdam to reflect the solution of using the temporary slipway. The site layout is indicative only, and the contractor may arrange the site differently depending on construction methods. The temporary slipway surface would be designed to provide the necessary slip resistance for its location and function in line with health and safety requirements. A suitable surface would be overlaid on the steel structure if required, such as corrugated C N N Construction site design and layout 6.6.7 More information is needed to justify the extent of the temporary works. 6.6.8 Object to the size and extent of proposed construction site for the temporary slipway, which is larger than necessary.
6.6.9
Concerns regarding the choice of materials for the temporary slipway: lorries and forklifts could slip on a steel structure and in winter it could freeze.
14116
62

Ref Objections, issues and concerns Total/ID number Our response steel, wood or concrete planks. We recognise that the site is in proximity to a number of local historic and listed structures (see the Putney Embankment Foreshore supplementary site information paper and the PEIR Addendum (Section 4.4)). In designing the scheme, we sought to preserve and enhance the character and appearance of the Putney Embankment Conservation Area. We are carrying out a historic environment assessment, which will be reported in the Environmental Statement for submission with the application. This assessment will identify any likely significant effects of our proposed construction activities and any mitigation required to address them. The Putney Bridge Foreshore site information paper states that the contractor would be required to implement noise and vibration control measures at the site, in line with the requirements of the CoCP. The contractor would also be required to gain approval from the London Borough of Wandsworth prior to commencing construction through a Section 61 application under the Control of Pollution Act, which would set out specific working methods and measures to reduce noise and vibration. The measures would be agreed with environmental health officers from the local authority. Furthermore, we would implement measures to C
Historic environment 6.6.10 Concerns regarding the effect of the construction traffic access route on the historic environment; the stretch of Lower Richmond Road in the traffic route is part of the Embankment Conservation Area.
14090
Noise and vibration 6.6.11 Concerns regarding the effect of vibration on buildings included: a. the effect from construction traffic b. the effect from construction of the cofferdam, the main tunnel and the Putney Bridge connection tunnel c. the effect on old buildings such as Warwick Mansions and adjacent residential properties d. the effect on Kenilworth Court.
14090, 14122
63

Ref Objections, issues and concerns Total/ID number Our response reduce noise and vibration from plant and works, including the selection of appropriate plant and equipment, the suitable siting of equipment and the use of site enclosures to provide acoustic screening. Details of the measures to be adopted for the construction works will be set out in the CoCP to for the application. In the unlikely event of any damage to property due to our construction works, disturbance compensation may be available (see A guide to the Thames Tunnel compensation programme). We acknowledge that this stretch of the river and riverside is well used. We would endeavour to reduce any inconvenience to recreational users of the river. The new configuration of the proposed temporary slipway would reduce the size of worksite required to construct and eventually remove the temporary slipway. It would also reduce the duration of its construction. The Environmental Statement for submission with the application will assess the likely significant effects on recreational users and other groups. The Environmental Statement for submission with the application will assess the likely significant effects on recreational users, businesses, the economy and tourism and will set out mitigation measures to address them. If development consent is granted, we anticipate that the DCO would contain a series of requirements (similar to planning conditions) to control the development. We expect that the mitigation C
Open space and recreation 6.6.12 Concerns regarding the effects of the temporary works on recreational users of the River Thames.
PLA
6.6.13
Ensure that mitigation measures identified to address the effect of the temporary slipway on users of the River Thames are delivered.
PLA
64

Ref Objections, issues and concerns Total/ID number Our response measures set out in the Environmental Statement would form part of these requirements. The supplementary site information paper states that, during the construction and removal of the temporary slipway, it may be necessary to move six to eight boats from their existing moorings opposite the site. We are also investigating the possibility of temporarily relocating these moorings, in consultation with the PLA, the London Borough of Wandsworth and the mooring occupants. We propose to move the permanent works 30m to the west and to extend the size of the main construction site, therefore it would likely be necessary to move one existing houseboat moored at Putney Pier during the construction period. The temporary relocation of the houseboat would be for two short periods of up to three months. The PEIR Addendum discusses the option of relocating the houseboat from the eastern side of the pier to the western side. We will continue to consult with the PLA, the London Borough of Wandsworth and the occupiers of Putney Pier and the houseboat in developing our proposals. We are carrying out an assessment of the likely significant effects of ground movement in advance of the works and, where necessary, we would carry out protective measures. We would monitor actual ground movement during and after the tunnelling to check that the ground is reacting as predicted. We would also carry out a defects survey on buildings located over, or close to, our tunnels and worksites C
6.6.14
Object to the temporary relocation of existing boat moorings; no boats need to be moved and there is enough room for rowing.
LR14130
6.6.15
Temporary relocation of existing boat 2 moorings/residential vessels at Putney Pier must be discussed with the Putney Pier owners, the houseboat owner, the PLA and the London Borough of Wandsworth to find suitable alternative moorings.
PLA, 14115
Structures and utilities 6.6.16 Structural monitoring of buildings should be undertaken including the Lower Richmond Road buildings of Kenilworth Court (namely blocks H, I, A and B). The effect on the river walls, especially to the east of the bridge where they are less stable, should be assessed. 1 14122 N
6.6.17
MD14134
65

Ref Objections, issues and concerns Total/ID number Our response where we consider it necessary. The method we would use to assess settlement is similar to that used for the Channel Tunnel Rail Link, the Jubilee Line Extension, and Crossrail. In the unlikely event of any damage to property due to our construction works, disturbance compensation may be available (see A guide to the Thames Tunnel compensation programme). The Putney Embankment Foreshore supplementary site information paper states that the configuration of the temporary replacement slipway was changed to respond to phase two consultation comments. The PEIR Addendum (Section 2.3) states that access arrangements for the construction of the temporary slipway would change from phase two consultation. Vehicles accessing the site would travel one-way via Lower Richmond Road, turn into Glendarvon Street, and turn right onto Embankment to reach the site. Vehicles would exit the site via Embankment, turn into Thames Place and then Lower Richmond Road (as stated in the PEIR). The revised access arrangements are required because the temporary slipway construction site would not provide sufficient room for construction vehicles to turn. The PEIR Addendum (Section 4.7) states that, due to the low number of construction vehicle trips along Glendarvon Street, the effect on residents, pedestrians and cyclists and other road users is expected to be negligible. We do not consider that the limited potential changes to access C
Transport and access 6.6.18 Do not support the proposed construction traffic access route for the temporary slipway via Glendarvon Street. Concerns included: a. It is a narrow residential road that is unsuitable for heavy construction traffic, in particular the junction of Glendarvon Street and Embankment.
LBW, 14019, 14061, 14115, 14125, 14123PET
N N
6.6.19
6.6.20
b. The road would be used for general construction traffic, not just traffic associated with the temporary slipway. c. The road would become more congested as road users seek alternative routes to avoid construction traffic associated with the Putney site as traffic cannot access the river during the construction of the permanent area of hardstanding d. Vehicles and properties would potentially suffer damage from construction and other traffic. e. Further assessment of the size of vehicles
14126, 14123PET 14029
6.6.21
14019, 14126, 14123PET LBW, 14116
6.6.22
66

Ref Objections, issues and concerns that could easily use this route is required and there is a need to ensure that there would be no access problems for lorries and 40ft trunkers [sic]. f. Local residents would experience disruption from heavy construction traffic including increased noise in a quiet residential area and house and car alarms triggered on the road. g. There would be disruption and noise along Embankment. 6.6.24 6.6.25 h. Air quality on Glendarvon Street and Lower Richmond Road would be reduced. i. The safety of pedestrians, cyclists and local residents would be affected. Appropriate mitigation measures should be put in place to ensure the safety of road users. 14019, 14126, 14123PET 14019, 14061, 14126, 14123PET TfL 5 Total/ID number Our response arrangements and vehicle numbers would change the transport effects predicted in the PEIR. The new configuration of the temporary slipway would also reduce the duration of the construction works proposed at phase two consultation. The Transport Assessment for submission with the application will assess the likely significant construction transport effects of the proposed development on pedestrian and cycle routes; bus and other public transport routes and patronage; parking; highway layout, operation and capacity; and residential amenity. It will also analyse the size of vehicles that could use the new route. Preliminary findings show that the proposed route would be satisfactory for the planned construction vehicles. In addition, we will undertake condition surveys of the road both before and after our works. The Transport Assessment includes an assessment of new receptors since phase two consultation along Glendarvon Street (see the PEIR Addendum). Due to the low number of construction vehicle trips along Glendarvon Street, the effect on residents, pedestrians, cyclists and other road users is expected to be negligible. The Transport Assessment will also review data relating to recent accidents. The proposals will be subject to independent external review by TfL and the local highway authority to ensure that the proposed highway layouts and vehicle movement arrangements are as safe as possible. The Section 48 Transport strategy states that the peak average of HGV movements during the construction period C
6.6.23
14019, 14061, 14126, 14141, MD14134
N N
6.6.26
67

Ref Objections, issues and concerns Total/ID number Our response would be 21 per day. The CoCP for submission with the application will include a requirement for a Traffic Management Plan to carefully control construction traffic in order to minimise any potential effects on the road network, residential amenity or access to the local area. The CoCP will set out construction traffic routes, site access/egress points, signage and monitoring procedures. It will also require the contractor to manage lorry deliveries to reduce the risk of collisions. However, in the event of any damage to a third party vehicle due to the project, the standard insurance claim process would apply. We propose that vehicles would travel one-way on Glendarvon Street. Approximately five pay and display vehicle parking bays would be suspended along the southern end of Glendarvon Street to facilitate access to the temporary slipway. We expect that a total of 15 to 20 parking bays would be suspended on Glendarvon Street and Embankment. The PEIR Addendum states that the overall effect on parking would remain minor adverse, taking into account the required suspension of parking on Embankment. This assessment is consistent with the PEIR at phase two consultation. We would discuss the reallocation of parking bays with the London Borough of Wandsworth. Further information on car parking will be provided in the Transport Assessment for submission with the application. C
6.6.27
Consideration should be given to making construction access to Glendarvon Street oneway only. Concerns regarding the loss or suspension of car parking bays in Glendarvon Street where residential parking is already limited.
14116
6.6.28
1 0
LBW, 14019, 14061, 14115, 14125, 14126, MD14134, 14123PET 14125, 14132
6.6.29
Consultation is required with the London Borough of Wandsworth to allow zone A1 residents to park in other adjoining zones. Suspension of parking on Embankment would result in a need for temporary provision of parking permits in the adjacent zone A5. 1
6.6.30
14126
68

Ref 6.6.31 Objections, issues and concerns Proposed construction site access would exacerbate existing local congestion including through-traffic to Wimbledon, Kingston, Richmond and Barnes. Concern regarding the effect of the construction traffic access route on Lower Richmond Road. Lorry movements associated with construction traffic should be kept to a minimum. 2 Total/ID number 14031, MD14077 Our response We will develop mitigation measures to reduce any likely significant effects arising from congestion identified in the Transport Assessment. The CoCP for submission with the application will include a requirement for a Traffic Management Plan to carefully control construction traffic in order to minimise any potential effects on the road network, residential amenity or access to the local area. The CoCP will also set out construction traffic routes, site access/egress points, signage and monitoring procedures. The PEIR Addendum states that Thames Place would be used as part of a one-way access route. The configuration of the temporary replacement slipway was changed to respond to phase two consultation comments. We reduced the size of the worksite required to construct and eventually remove the temporary slipway. The revised access arrangements are required because the temporary slipway construction site would not provide sufficient room for construction vehicles to turn. Therefore, it is not possible to use solely Thames Place to access the site. In our Section 48: Transport Strategy we increased our commitment to river transport from phase two and targeted consultation. At this site, we propose to use river transport to remove excavated material from the shaft and the connection tunnels, interceptions and associated structures and to import and export cofferdam fill materials. The Section 48 Transport Strategy states that our increased commitment to river transport since phase C N
6.6.32 6.6.33
1 1
14060 14115
N N
6.6.34
Consideration should be given to alternative construction access routes for the temporary slipway, including Thames Place, which is not a residential road; It is easy to navigate, much wider and never blocked.
14019, 14115, 14125, 14126, 14123PET
6.6.35
Concern regarding the disruption to local traffic from the proposed construction access route when all materials could be transported by river. Use the river to transport more/all construction materials and spoil. Concerns regarding the duration of construction traffic movements including that increased traffic on the road could last beyond the duration of the
MD14077
6.6.36 6.7.1
3 3
14125, 14126, MD14134 14019, 14126, 14123PET
6.7 N
69

Ref Objections, issues and concerns temporary slipway site works. Total/ID number Our response two consultation would have considerable benefits in terms of reducing total vehicle numbers and associated impacts. At Putney Embankment Foreshore, the overall predicted HGV numbers were reduced by 28 per cent since phase two consultation (from 4,650 to 3,350 HGV movements). The peak average of HGV movements during the construction period would be 21 per day and two barges per day. However, it is not generally practical or cost-effective to transport all materials by barge therefore some materials would still be transported by road. The length of the construction period indicated in the phase two consultation documents is the maximum period. The programming of works at all sites would be configured to reduce the duration of works and associated disruption to the local area as far as possible. We will discuss the details further with TfL and the London Borough of Wandsworth to ensure that any significant transport effects are included in the Environmental Statement for submission with the application. We are carrying out fluvial modelling of the temporary foreshore works to establish the likely significant effects of the development on the river. Preliminary findings informed the design of the site at targeted consultation. We are also carrying out scour modelling and we will discuss the results with the PLA and the Environment Agency. Further modelling will refine the operational designs, where appropriate, including the use of scour protection, and will inform the Environmental Statement for C
Water and flood risk 6.7.2 6.7.3 Concern regarding the effect of the temporary works on river flows and currents. Concern regarding the effect of the temporary works on river erosion and scour. 1 1 PLA PLA N N
70

Ref Objections, issues and concerns Total/ID number Our response submission with the application. The modelling studies will support agreements with owners of third party assets, where relevant. The PEIR Addendum (Section 3.6 and Section 3.7) states that the proposed changes to the scheme are unlikely to result in any significant changes to the phase two assessment of surface water or of flood risk during construction or operation. If significant scour is predicted during construction, we propose to monitor the riverbed and undertake remedial works if/as required. Any additional consents would be acquired. C
6.8
6.8.1
Main construction site

This section sets out feedback in relation to our proposals for the main construction site at Putney Embankment Foreshore. The supportive and neutral comments are set out in Table 6.8 and the objections, issues and concerns in Table 6.9. The comments are grouped by theme, as denoted by the sub-headings shaded in orange. All feedback on this issue relates to the construction phase.

Table 6.8 Putney Embankment Foreshore: Supportive and neutral comments in relation to the extent of the main construction site
Ref 6.8.2 6.8.3 Supportive and neutral comments Support the revised proposals for the transportation of materials by river. General support for construction proposals. 2 1 Total/ID number 14122, MD14134 14119 Our response Your comments are noted and welcomed.
71

Table 6.9 Putney Embankment Foreshore: Objections, issues and concerns in relation to the extent of the main construction site
Ref Objections, issues and concerns 1 Total/ID number 14059 Our response Our proposed working hours for this site were set out in the phase two consultation materials, (see the Putney Bridge Foreshore site information paper). Most works at this site would be undertaken within standard working hours. Continuous 24-hour working would only be required for the connection tunnel works. At most of our sites standard working hours would be 8am to 6pm weekdays, and 8am to 1pm on Saturdays. We may occasionally need to carry out works outside of standard working hours in order to undertake large concrete pours and deliver abnormal, large and heavy loads at times when there is reduced traffic. C N Construction working hours and programme 6.8.4 Concern regarding the effect of noise pollution during construction working hours, particularly at night and on weekends. 6.8.5 More information is needed on whether construction working hours will be 24 hours a day.
14041
Construction site design and layout 6.8.6 There has been no guarantee that the construction site layout in the site information paper is what would actually be delivered by the contractor.
TfL
The information presented in our consultation material to date included indicative layouts. Contractors would be able to make choices relating to the organisation of the site, however if development consent is granted, we anticipate that the DCO would contain a series of requirements (similar to planning conditions) to control the development. We expect that the mitigation measures set out in the Environmental Statement would form part of these requirements.
72

Ref 6.8.7 Objections, issues and concerns Measures to address the effects of construction should be discussed with groups including: a. the local community b. the London Borough of Wandsworth, to ensure that the effect on local residents is kept to a minimum. 6.8.8 More information is needed on the proposed measures to mitigate the effects of construction. 1 14131 2 Total/ID number LBW, LR14130 Our response Your comments are noted. The development of our proposals takes account of phase two consultation comments as well as on-going discussions with consultees including the London Borough of Wandsworth and TfL. C N
We consider that we conducted a thorough and comprehensive consultation exercise. We carefully considered the information we made available at targeted consultation to ensure that consultees had sufficient information to respond. The PEIR Addendum set out the likely significant effects from construction. The CoCP for submission with the application will include requirements for the contractor to implement noise and vibration control measures at the site. The contractor would also be required to gain approval from the London Borough of Wandsworth prior to the construction work through a Section 61 application under the Control of Pollution Act, which would set out specific working methods and measures to reduce noise and vibration. The PEIR (Volume 10, Section 10) states that we believe that any potential business amenity effects would likely only affect a relatively small number of businesses at this site. We do not anticipate any loss of jobs as a result of the works. The PEIR Addendum (Section 4.6) states that
Noise and vibration 6.8.9 Concerns regarding the effect of construction on residential amenity included: a. noise from 24-hour construction works b. the effect of noise on the Star & Garter mansions c. the effect of an intrusive, expensive and unnecessary project. Socio-economic 6.8.10 Concern regarding noise, dust and visual effects on local businesses during construction.
14044LO, 14103LO, 14134LO, 14135LO, 14015, 14037
TfL, 14015
73

Ref Objections, issues and concerns Total/ID number Our response amenity effects on residents and businesses resulting from noise, air quality and visual effects during construction remain as predicted in the PEIR assessment. The Environmental Statement for submission with the application will assess the likely significant effects of the proposed development. We have published a Guide to the Thames Tunnel compensation programme which sets out details of compensation that would be available during construction to address damage or loss, required protection measures or compulsory purchase. Your comments are noted. As part of the development of our design proposals we will ensure that provision is made for loading activities on the temporary slipway. The Putney Embankment Foreshore supplementary site information paper states that the area of the main construction site is sufficient to allow HGVs to enter and exit the site in a forward direction. The CoCP for submission with the application will include a requirement for a Traffic Management Plan to carefully control construction traffic in order to minimise any potential effects on the road network, residential amenity or access to the local area. The CoCP will also set out construction traffic routes, site access/egress points, signage and monitoring procedures. We carefully considered the possible options for the temporary diversion of the Thames Path and cycleN C
6.8.11
Suitable compensation should be provided for all loss and damage to the Thai Square Restaurant.
LRMD14101LO
Transport and access 6.8.12 Concern that Thames Executive Charters would 1 be unable to load vessels during the construction period due to the loss of the existing slipway. 6.8.13 Concern regarding whether there is sufficient 1 space on-site for vehicles to turn around to avoid need to reverse onto public highways.
14116
TfL
6.8.14
Provide a suitable and safe Thames Path diversion during construction including
TfL
74

Ref Objections, issues and concerns pedestrian crossings and diversionary signage. Total/ID number Our response path in developing our proposals. The route illustrated in the Putney Embankment Foreshore supplementary site information paper was proposed because we considered it to be the best option for the temporary diversion. Any diversions would be agreed with the London Borough of Wandsworth and TfL. The CoCP (a draft of which was provided at phase two consultation), will include requirements for suitable signage, lighting and barriers to be provided for diverted public rights of way. We carefully considered the information we made available at targeted consultation to ensure that consultees had sufficient information to respond to the consultation. In our Section 48: Transport Strategy we increased our commitment to river use from phase two and targeted consultation. At this site, we propose to use river transport to remove excavated material from the shaft and the connection tunnels, interceptions and associated structures and to import and export cofferdam fill materials. The PEIR Addendum (Section 2.3) states that the potential changes would decrease the total vehicle movements from approximately 8,850 to approximately 6,700 over the entire construction period. Numbers would peak in late 2018. However, it is not generally practical or cost-effective to transport all materials by barge therefore some materials would still be transported by road. As stated in our phase two consultation materials, road access to this site is proposed via Putney Bridge Road, Putney High Street (A219) and Lower C
6.8.15
Use the river to transport more/all construction materials and spoil. Reasons included: a. Minimise the local effect of HGVs accessing the site (congestion, air quality etc.). b. Encourage contractors to maximise the use of wharves throughout all stages of construction. c. Since barges would only be used during the set-up and completion/site restoration phases of construction work there should be no restrictions on barge traffic during these phases.
TfL, 14119, 14031
6.8.16
More information is needed on how construction materials would be transported.
14005
6.8.17
Consider amending the proposed construction traffic route; if site traffic operates along Putney High Street it would remove the need for an
LBW
75

Ref Objections, issues and concerns unnecessary detour along Putney Bridge Road/ Wandsworth One Way system/Upper Richmond Road. Total/ID number Our response Richmond Road. We expect that at the peak of the construction period (year three), an average of 15 lorries would travel to and from the site each working day, (see the PEIR (Volume 10, Section 12)). In the context of existing traffic in the local area, this is not considered to be significant. Your comments are noted. We will take account of on-going discussions with consultees including TfL in developing our proposals. C
6.8.18
Any proposed relocation of bus stops must be discussed with TfL.
TfL
6.9
6.9.1
Permanent works
This section sets out feedback in relation to the design of the permanent works at Putney Embankment Foreshore. The supportive and neutral comments are set out in Table 6.10 and the objections, issues and concerns in Table 6.11.

Table 6.10 Putney Embankment Foreshore: Supportive and neutral comments in relation to the permanent design
Ref 6.9.2 Supportive and neutral comments General support for the permanent design and appearance of the site included: a. The proposals show a good appreciation of the unique character of this site. b. The historical aspects of Putney Embankment and the river, including events such as the University Boat Race and the Head of the River Race, are incorporated into the design of useful public space. 2 Total/ID number CABE, 14115 Our response Your comments are noted and welcomed.
76

Ref 6.9.3 Supportive and neutral comments Support for the proposed location and extent of the permanent foreshore structure, including: a. the low key design solution and materials proposed for the interception chamber under the bridge b. the alignment with the University Boat Race start line, which enhances the permanent foreshore structure's relevance and relationship to the river and creates a focal point for the University Boat Race and other key river events. 6.9.4 6.9.5 Support for the revised design proposals for the electrical and control kiosk. Proposals for the electrical and control kiosks are an improvement from phase two consultation. Support the protection of Waterman's Green. Support for the proposals to preserve the historic slipway. Support for the revised design proposals for the ventilation column including the revised location and reduced height. Support for the provision of a new public space along the foreshore. Support for the proposals to make a feature out of the University Boat Race stone and align it with a metal marking strip. Support for the choice of materials and finishes, 2 1 14122, MD14134 LBW 7 Total/ID number CABE, LBW, 14039, 14050, 14115, 14122, MD14134 Our response
6.9.6 6.9.7 6.9.8
2 1 1
14024, 14115 14035 14042
6.9.9 6.9.10
4 5
CABE, LBW, 14042, 14058 CABE, LBW, 14033, 14122, MD14134 CABE, LBW
6.9.11
77

Ref Supportive and neutral comments including: a. the proposal to locate a metal strip in the pavement, running along the stone, across the surface of the structure and down the river wall to mark the start of the University Boat Race b. the details of finishes are yet to be agreed. 6.9.12 Qualified support for the design proposals. Comments included: a. Support the simple, orthogonal geometry of the design, however, the form would benefit from further refinement to ensure that it enhances the setting in both visual and functional terms. The project should test alternative ways of terminating the bridgefacing end, employing views studies from the bridge to inform the chosen solution. b. Welcome the provision of more generous access onto the promontory, which would integrate more strongly with the public realm of Lower Richmond Road. In order to ensure accessibility for all users, further thought should be given to the design of the steps down to the pavement at the western end. c. The additional kiosk could be a positive addition to the scheme; however it does not have an obvious function in relation to the public realm. The design should be reconsidered to allow for other functions in addition to the technical requirements of the tunnel. If sited beside the steps, the design 2 CABE, PLA Your comments are noted and we will consider the detailed points raised as we develop our design for this site. Total/ID number Our response
78

Ref Supportive and neutral comments could incorporate a handrail to provide good access for all. d. No fundamental objections to the amended scheme in relation to navigational safety during the operational phase, although appropriate fendering is required on the downstream face of the structure to ensure the continued use of Putney drawdock. e. Support for the potential for layby (visitor) moorings on the riverward face of the structure, although appropriate fending, bollards and ladders would be required and access must be secured. f. The location of any mooring should be upstream of the storm overflows and it must be demonstrated to the PLAs satisfaction that any discharge from these overflows would not compromise the mooring or vessel approaches to the structure. Total/ID number Our response
Your comment is noted. Fendering will be incorporated into the permanent design.
Your support is welcomed and noted. We are reviewing our design to try to accommodate the PLA's requests for the provision of moorings on the permanent structure. We are undertaking further work to confirm that any moorings would not create potential river navigation issues.

Table 6.11 Putney Embankment Foreshore: Objections, issues and concerns in relation to the permanent design
Ref Objections, issues and concerns 1 Total/ID number 14008 Our response Your comments in relation to the design of our proposals are noted. The design follows our projectwide principles and takes account of comments made at phase one and phase two consultation, ongoing discussions with consultees and our design C N Design suggestions 6.9.13 General objections to the design of the permanent foreshore structure included comments that the proposals are 'hard' and 'new'. 6.9.14 Objection to the modern design of the
14011
79

Ref 6.9.15 Objections, issues and concerns permanent foreshore structure. Proposals for the permanent foreshore structure are unattractive/ugly. Comments included: a. The design looks like a giant shipping container. b. The design is not in character with the history of good architecture and was devised to feed greed. c. The sharp external and internal corners are unattractive. d. The design is bulky, heavy, harsh and uninteresting for such an attractive and pretty location. 6.9.16 The permanent design and finish of the site should enhance and improve the local area. Comments included: a. Integrate Putney Pier, Embankment and the promontory into a 'Masterplan' for the area. b. Coordinate with Putney Pier and maximise opportunities to pedestrianise Putney Embankment in this area. c. The proposals should benefit future generations and act as a conduit for local residents and businesses using the River Thames. d. The proposals should be aesthetically pleasing and consider nature, ecology, and biodiversity as a first requirement, and plan ahead for future generations. 4 14015, 14050,14057, 14131 8 Total/ID number 14030, 14057, 14114, 14131, 14132, 14144, LR14130, MD14134 Our response review with the Design Council CABE. Our Design development report, which was made available at phase two consultation, sets out the principles that informed our design in more detail. Changes to the design since phase two consultation are set out in our Design development report Addendum, which was made available at targeted consultation. We believe that the proposed development at this site would positively contribute to the Embankment and the riverfront; the new pedestrian area would overlook the river and the slipway would be retained. Part of the surface area of the permanent foreshore structure is required for maintenance purposes. We will continue to explore options for outdoor uses with local groups, including temporary uses of the new pedestrian area. The permanent structures need to be located near the CSO interception works and within the area identified for the construction works; therefore, they cannot be located on the eastern side of Putney Bridge in the current design. We will continue to develop the design of this site in light of the targeted consultation feedback. We are exploring how to give the edges of the permanent foreshore structure more of a curve. Further details of the architectural design and treatment will be provided in the Design and Access Statement for submission with the application. C N
80

Ref 6.9.17 Objections, issues and concerns Suggestions for the design of the permanent foreshore structure included: a. Use curved edges to follow the shape of the river bank. b. Protect existing timbers and the slipway. c. Promote the new public space to local residents by including an outdoor caf kiosk with seating and public toilet facilities. 6.9.18 Using Waterman's Green as proposed at phase one consultation provides the opportunity to create an attractive riverside facility as a legacy and to improve the existing situation. Prefer the design of the permanent works at phase two consultation/prefer the design of the permanent works at phase one consultation, which were more aesthetically pleasing and did not dwarf Putney Pier. 1 14059 N 4 Total/ID number 14030, 14035, 14037, 14144 Our response C N
6.9.19
14060, 14062
The Design development report at phase two consultation and the Design development report Addendum at targeted consultation stated that the layout and size of the site were optimised to take account of functional and aesthetic considerations. The size and width of the proposed foreshore structure were reduced since phase one consultation. The proposed permanent platform is now much smaller in scale and protrudes less into the river. We sought to rationalise the footprint of our permanent works to reduce the size of the foreshore structure. We will continue to consider any opportunities to further reduce the size of the permanent structure. We have discussed the development of our proposals with the Design Council CABE and English Heritage, which are supportive of our design. The size of the electrical and control kiosks is dictated by both functional and health and safety
6.9.20
Objection to positioning the second electrical and control kiosk on the permanent foreshore
14115
81

Ref 6.9.21 Objections, issues and concerns structure. Consider mitigation to reduce the size of the second electrical and control kiosk on the permanent foreshore structure. The location of the electrical and control kiosk at phase two consultation should remain unchanged. The London Borough of Wandsworth will continue to work with the project to identify a suitable location for the kiosk in one of the disused vaults. 1 Total/ID number 14115 Our response requirements. The height of the kiosk on Waterman's Green was reduced by 1.5m in response to comments at phase two consultation. This resulted in the need for a second kiosk located on the permanent foreshore structure. We believe that the design of the permanent foreshore structure would enhance opportunities for recreation and enjoyment of the river in this area. We considered positioning the second electrical and control kiosk in the vaults of the arches on Lower Richmond Road, however this would affect existing development proposals for the future development of the local area. Your comments in relation to our design proposals are noted. A ventilation column adjacent to Putney Bridge is necessary to ventilate the interception chamber located beneath the shore arch. The ventilation columns and other structures were designed to meet functional and health and safety requirements. They must be the size presented to ensure the efficient operation of the tunnel system. Our design approach to the ventilation column was to use the height to create a positive feature or local landmark. The proposed design and position are a subtle indication of the structure's role in improving the River Thames. We will take your comments into consideration in developing the final design. We regularly seek advice on our emerging design proposals from statutory stakeholders and local interest groups, and have held two design reviews with the Design Council CABE. We will continue to develop our design proposals for the site in light of the targeted consultation feedback. C N
6.9.22
LBW
6.9.23
Concerns regarding the design and location of the ventilation column, which should disguise its function and visually enhance the area. Consider amendments to the design and location of the ventilation column. Comments included: a. It should look like existing lamp posts. b. It should be aesthetically pleasing and as inconspicuous as possible. c. Relocate it and reduce the size. d. Relocate it near to Putney Bridge. e. Use it to signpost and promote the project by making it a feature of the public realm; suggest aligning the column with the University Boat Race stone and start line.
MD14134
6.9.24
CABE, 14024, 14034, 14050, 14122, LR14130
82

Ref 6.9.25 Objections, issues and concerns Establish a clear link between the University Boat Race stone and the start line, including providing an indication to the public of what this feature signifies. Consider incorporating public art into the design to incorporate and disguise the ventilation column. 1 Total/ID number CABE Our response Your comments in relation to our design proposals are noted. We will explore opportunities to incorporate local river events and public art into the design. C N
6.9.26
LBW, 14114
Historic environment 6.9.27 The permanent foreshore structure should be located away from Putney Bridge and the existing public drawdock. 1 14038 The Putney Embankment Foreshore supplementary site information paper states that we propose to relocate the permanent area of hardstanding approximately 30m to the west. This change is a response to comments received at phase two consultation on the permanent design and the relationship with the public slipway. We believe that the proposed development at this site would positively contribute to the Embankment and the riverfront; the new pedestrian area would overlook the river and the slipway would be retained. The Design development report Addendum, which was made available at targeted consultation, includes proposals for high quality materials, street furniture and surfacing appropriate to the historic setting. Approval for the materials would be sought following submission of the application. The proposals are currently under review following the comments received at targeted consultation. We will seek to ensure that appropriate materials are N
6.9.28
Concerns that the designs for the permanent foreshore structure are not in keeping with their historic setting. Reasons included: a. It is not in keeping with the riverside. b. It would result in the loss of valuable land and heritage.
14011, 14030, 14057
6.9.29
The design and finish of the permanent foreshore structure should be in keeping with its historic setting. Comments included: a. It should not be radically modern. b. Stonework should be sympathetically aged by rounding edges or breaking corners to
LBW, 14024, 14114
83

Ref 6.9.30 Objections, issues and concerns match the existing revetment walls. Reconsider the choice of materials for the permanent foreshore structure. Comments included: a. It should be faced with stonework and new railings should be in keeping with the existing. b. It should be faced with timber, similar to Putney Pier. c. A co-ordinated design approach is required in relation to the kiosk, steps, seating and ventilation column to create an inclusive environment that takes cues from the existing setting. 6.9.31 Consult with the local community, the London Borough of Wandsworth conservation team, the Environment Agency, the PLA and English Heritage to improve the permanent design of the site. 3 14115, LR14130, MD14134 Our public consultations to date have provided opportunities for all those with an interest in the project to comment on our proposals for this site. Our multi-phased consultation approach enabled us to revise our designs in response to comments and concerns. The design follows our project-wide principles and takes account of phase two consultation comments, the design review with the Design Council CABE, and on-going discussions with consultees including community groups, the London Borough of Wandsworth, the Environment Agency, the PLA and English Heritage. The PEIR (Volume 10, Section 5) assessed the likely significant operational effects of the proposed N 4 Total/ID number CABE, 14011, 14030, 14114 Our response used along the Embankment to preserve and enhance the character and appearance of the Putney Embankment Conservation Area and the setting of listed buildings close to the site. Further details of the architectural design and treatment will be provided in the Design and Access Statement for submission with the application. C N
Natural environment (aquatic) 6.9.32 Amend the design of the permanent foreshore structure to reduce potential effects on foreshore 1 LBW N
84

Ref Objections, issues and concerns habitat, which is important for fish breeding. Total/ID number Our response development on aquatic ecology, including the foreshore habitat. It considered the effects on the foreshore and River Thames and concluded that the permanent structure would have a low negative effect due to its small area and the positive effect of the project on river water quality. The PEIR Addendum (section 4.3) states that the effects on designated sites and habitats arising from temporary land take would remain moderate adverse on account of the small increase in overall land take and revised construction techniques since phase two consultation (as predicted in the PEIR (Volume 10, para. 5.5.23)). We are carrying out a full aquatic ecology assessment for submission in the Environmental Statement for submission with the application, which will consider the likely significant effects of the permanent structure on river flow and fish movements. We are already considering using horizontal fenders to secure ecological benefits in developing the design of the permanent foreshore structure. The current design would result in the loss of a single holly tree, which would be replaced. The electrical and control kiosk would be located near the disused toilet block on Watermans Green to reduce the risk of damage to trees. C
Natural environment (terrestrial) 6.9.33 6.9.34 Concerns regarding the location of the electrical and control kiosk on Waterman's Green. Concerns regarding the loss of the holly tree on Watermans Green due to the location of the electrical and control kiosk. A replacement tree of similar size and species should be provided. The location of the permanent works should avoid any damage to or loss of trees on 2 2 14050, MD14134 LBW, MD14134 14122 N N
6.9.35
85

Ref Objections, issues and concerns Waterman's Green. Proposals for the permanent foreshore structure 1 offer no benefit to river users, apart from its main purpose. Total/ID number Our response C
Open space and recreation 6.9.36 14131 We are already considering using vertical and horizontal fenders to provide additional temporary moorings and to secure recreational and ecological benefits in developing the design of the permanent foreshore structure. Your comments are noted. The final design and operational layout will comply with the requirements of the Disability Discrimination Act 1998 and meet the need to ensure accessibility. We do not propose to pedestrianise Embankment as part of this scheme. We will continue to work with the PLA, stakeholders, the owner of Putney Pier and the operator of the river bus services to draw up mitigation measures (where appropriate). The indicative layout and visualisations for this site were provided in the Putney Embankment Foreshore supplementary site information paper. The Design project information paper (at phase two consultation) sets out the common design principles for each site, which include respecting the context and surroundings of each site. The Design development report Addendum (at targeted consultation) sets out the design changes since phase two consultation. N
6.9.37
Provide moorings for boats and investigate design solutions to allow people with impaired mobility to access moored boats, for example via hydraulic steps/ramps. Concerns regarding the effect on residential amenity; pedestrianising Putney Embankment will lead to noise from customers at local pubs. Consult with local residents, the PLA and Livett's Launches Ltd (the owner of Putney Pier) to minimise the effect on business operations.
CABE
Socio-economic 6.9.38 1 14103LO N
6.9.39
14131
Townscape and visual 6.9.40 Concerns regarding the potential visual effect of the permanent foreshore structure from Putney Bridge. 1 14030 N
86

Ref Objections, issues and concerns Total/ID number Our response We conducted a preliminary assessment of likely significant townscape and visual effects (see the PEIR (Volume 10, Section 11)). We updated Volume 10 of the PEIR to take account of the proposed changes and produced an addendum. The PEIR Addendum (Section 3.4) states that the townscape and visual effects of the proposed development are expected to remain the same as at phase two consultation. Our permanent structures would be designed to reduce potential effects on river navigation and other river users. Preliminary discussions with the PLA also informed the design of the site. We are carrying out a Navigational Risk Assessment for submission with the application. Our approach to this assessment is under discussion with the PLA (the body responsible for the River Thames and its users). We are carrying out fluvial modelling of the temporary foreshore works to establish the likely significant effects of the development on the river. The preliminary findings informed the design of the site. We are also carrying out scour modelling and we will discuss the findings with the PLA and the Environment Agency. We will continue to develop the design of this site in light of feedback at targeted consultation. We are exploring ways to give the edges of the permanent foreshore structure more of a curve. We will refine C
Transport and access 6.9.41 Concerns that the revised location of the permanent structure would interfere with river navigation (both commercial and recreational). 1 14038 N
Water and flood risk 6.9.42 6.9.43 Concerns regarding the effect of the permanent foreshore structure on river flows and currents. Concerns regarding the effect of the permanent foreshore structure on river erosion and scour. Consider making the structure more rounded. 3 3 14050, 14131, 14144 PLA, LBW 14144 N N
87

Ref Objections, issues and concerns Total/ID number Our response the designs (where appropriate) in response to further modelling work, which will inform the Environmental Statement for submission with the application. The modelling studies will also form the basis of agreements with owners of third party assets, where relevant. Where significant scour is predicted, we would carry out preventative measures (such as placing rip-rap on the river bed).In all locations we would monitor the riverbed and carry out remedial works if/as required. Your comments are noted. The shape of the permanent foreshore structure is under consideration in order to prevent the accumulation of river debris and other flotsam. We conducted modelling studies to test the effect of the structure on the flow of the river. We will continue to liaise with the PLA to carry out a navigational risk assessment and will implement any necessary mitigation measures identified in the assessment. C
6.9.44 6.9.45
Concerns that the permanent foreshore structure would collect debris. The design of the permanent foreshore structure should: a. be more curved on the internal corners to minimise the risk of collecting debris/flotsam and jetsam and to avoid turbulence b. point the CSO out at 45 to avoid a dead area where rubbish could collect and point the outflows away from Putney Pier.
3 7
PLA, 14132, MD14134 14114, 14115, 14132, LR14130, MD14134, 14122, 14144
N N N
6.10
6.10.1
PEIR Addendum
This section sets out the feedback received in relation to the PEIR Addendum published at targeted consultation. The supportive and neutral comments are set out in Table 6.12 and the objections, issues and concerns in Table 6.13.
88

Table 6.12 Putney Embankment Foreshore: Supportive and neutral comments in relation to the PEIR
Ref 6.10.2 Supportive and neutral comments The proposed scope of the archaeological works could be applied to the modified engineering programme. 1 Total/ID number EH Our response Your comment is noted and welcomed.

Table 6.13 Putney Embankment Foreshore: Objections, issues and concerns in relation to the PEIR
Ref 6.10.3 Objections, issues and concerns There is no substantive evidence as to the effects of the permanent structure on the hydrodynamics of the River Thames, therefore query the conclusions reached in the PEIR Addendum. 1 Total/ID number PLA Our response A preliminary assessment of the hydrodynamics of the River Thames was presented in the PEIR (Volume 10, Section 15). We acknowledge that this is a preliminary assessment. Recommended water mitigation measures will be included in the Environmental Statement for submission with the application. C N Water and flood risk
6.11
6.11.1

We received a range of feedback on our proposals for this site at targeted consultation and Section 42 consultation in relation to changes to the site boundary, including supportive and neutral comments and objections, issues and concerns. We took all the feedback received into account in accordance with the requirements of the 2008 Act. No new information that might change the conclusions of our site selection process was brought to light. Following our targeted consultation, Putney Embankment Foreshore therefore remains our preferred site to connect the Putney Bridge CSO to the main tunnel.
6.11.2
89
6 Targeted consultation: Putney Embankment Foreshore 6.11.3 The targeted consultation feedback included detailed comments in relation to the configuration of the temporary slipway and the design and appearance of the permanent structures. Having considered the feedback received, we still believe that our proposals at targeted consultation appropriately address the local context and that it is not necessary to revise our proposed approach for the application. Full details of the proposed scheme for this site will be set out in the application for development consent and the accompanying documents.
6.11.4
90
7 Targeted consultation: Albert Embankment Foreshore
7
7.1
7.1.1
Targeted consultation: Albert Embankment Foreshore

Introduction
Our proposal
We propose to use the foreshore of the River Thames adjacent to Albert Embankment (A3036) for our construction works and to accommodate the permanent structures required to operate the main tunnel. The site would be used to connect the existing local CSOs, known as the Clapham Storm Relief CSO and Brixton Storm Relief CSO, to the main tunnel. At phase two consultation we received significant feedback from the occupants of Vauxhall Cross, which cannot be made public as it related to security issues. However, the feedback principally addressed how we would carry out the construction works rather than what the works entailed. In response to this feedback, we now propose an alternative access route for construction vehicles between Camelford House and Tintagel House.
7.1.2

7.1.3 This section sets out the feedback from targeted consultation and Section 42 consultation in respect of changes to the site boundary in relation to the proposed amendments at Albert Embankment Foreshore. Feedback that related to Albert Embankment Foreshore but not to the targeted consultation amendments is set out in Section 12, Other comments. This section is organised as follows to reflect the scope of targeted consultation:
a. b. c. d.
7.1.4
Section 7.2: Number of respondents Section 7.3: Construction traffic access route Section 7.4: PEIR Addendum Section 7.5: Our view of the way forward.
7.1.5
91
7.2
7.2.1
A total of 12 respondents provided feedback in relation to Albert Embankment Foreshore at targeted consultation and Section 42 consultation in respect of changes to the site boundary, of which one responded after consultation had closed. The number of respondents in each group is set out in Table 7.1.
Table 7.1 Respondents to targeted consultation and Section 42 consultation in respect of changes to the site boundary at Albert Embankment Foreshore
Respondent group Statutory consultees (SC) Local authorities (LA) Landowners (LO) Community consultees (CC) Petitions (PET) Number of respondents 3 respondents 1 respondent 1 respondent 7 respondents 0 petitions
7.2.2
Table 7.2 sets out the statutory consultees and local authorities who provided feedback in relation to this site. Table 7.2 Statutory consultees and local authorities that responded to targeted consultation and Section 42 consultation in respect of changes to the site boundary at Albert Embankment Foreshore
Statutory consultees English Heritage (EH) Port of London Authority (PLA) Transport for London (TfL) Local authorities London Borough of Lambeth (LBLam)
7.2.3
92
7.3
7.3.1
Construction traffic access route

This section sets out feedback in relation to the alternative construction traffic route to Albert Embankment Foreshore. The supportive and neutral comments are set out in Table 7.3.The objections, issues and concerns and how we propose to address them are set out in Table 7.4. The comments are grouped by theme, as denoted by the sub-headings shaded in orange.

Table 7.3 Albert Embankment Foreshore: Supportive and neutral comments in relation to the construction traffic access route
Ref 7.3.2 7.3.3 7.3.4 Supportive and neutral comments Support for the proposed construction traffic access route. The proposed access route is better than the option presented at phase one consultation. No comment in relation to proposed construction access. 2 1 1 Total/ID number 14119, LR14113 14112 PLA Noted. Our response Your comments are noted and welcomed.

Table 7.4 Albert Embankment Foreshore: Objections, issues and concerns in relation to the construction traffic access route
Ref Objections, issues and concerns 1 Total/ID number TfL Our response Discussions with TfL are on-going. C N Historic environment 7.3.5 Consult with TfL on the intended works, which lie near Vauxhall Bridge a TfL listed structure. Natural environment 7.3.6 Specific mitigation suggestions included: a. respect the natural environment and provide 2 14057, 14140 The Albert Embankment Foreshore site is split into two sections: the northern section lies in the N
93

Ref Objections, issues and concerns recreational places for tourists and office workers b. protect the River Effra. Total/ID number Our response foreshore to the north of Lacks Dock in front of Camelford House, and the southern section lies in the foreshore beneath and on either side of Vauxhall Bridge. The sites would be connected by an underground connection culvert. The foreshore structure in the northern section would form a new area of public realm designed to encourage Thames Path users to pause and enjoy the views. The foreshore structure in the southern section would be accessible for maintenance purposes only, in accordance with comments received from the occupants of Vauxhall Cross at phase two consultation. Any construction activities with the potential to disturb the natural environment would be controlled by measures in the CoCP, such as a requirement for a Landscape and Ecology Management Plan, including monitoring. We sought to minimise the footprint of the structures in the river and we propose to provide new habitat areas in the form of intertidal terraces around the northern structure. The lost River Effra is now contained within the Brixton Storm Relief Sewer. A plaque marks the confluence of the River Effra and the River Thames near Vauxhall Bridge. We would seek to preserve a reference to the River Effra in this location once our works are complete. Both proposed access options require the use of Lack's Dock. We believe that we can safely share access with London Duck Tours during construction, although we recognise that this would require a high C
Socio-economic 7.3.7 Concerns regarding the effects of using Lack's Dock, including access to the river for London Duck Tours.
PLA
94

Ref Objections, issues and concerns Total/ID number Our response level of co-ordination. We are consulting with the users of Lacks Dock in order to minimise the effects on business. Both access options will be considered in the Transport Assessment and we are carrying out a navigational risk assessment. If development consent is granted, the DCO would include powers for the project to acquire land other than Crown Land (which includes land owned by the Duchy of Cornwall for the purposes of the 2008 Act). We will seek consent from the Duchy to include the required land in the application, although the final decision on use of that land would rest with the Secretary of State. The phase two consultation Albert Embankment Foreshore site information paper states that the contractor would be required to implement noise and vibration control measures at the site, in line with the requirements of the CoCP. The contractor would also need to gain approval from the London Borough of Lambeth prior to the construction work through a Section 61 application under the Control of Pollution Act, which would set out specific working methods and measures to minimise noise and vibration. This would ensure that the noise levels are reasonable and best practice measures are applied. The measures would be agreed with environmental health officers from the local authority. We would also implement best practice measures to minimise noise and vibration from plant and works including the selection of appropriate plant and equipment, siting of equipment and use of acoustic C
7.3.8
Object to the proposed land acquisition and do 1 not accept that Thames Water can acquire rights over land at 89 Albert Embankment to accommodate the new development.
14139LO
7.3.9
Concerns regarding the effect on occupiers of Tintagel House and Camelford House included: a. The layout of the buildings will echo construction traffic noise. b. Construction traffic noise will be transmitted without losing intensity. c. The proposed frequency of construction traffic movements is unacceptable. d. Businesses would be relocated.
14139LO
95

Ref Objections, issues and concerns Total/ID number Our response screening enclosures. Full details of the measures that would be adopted during construction will be set out in the CoCP for submission with the application. The PEIR (Volume 19, Section 9) contains details of a preliminary qualitative assessment of noise and vibration from construction site activities, construction traffic on roads outside the site, and from operation of the site on Camelford House. The PEIR Addendum (Volume 19, Section 4.2) concluded that although the potential changes to the proposed development have introduced new receptors, including Tintagel House and the northern end of Camelford House, the construction effects on these receptors would not be significant. In the event that a business suffers financial loss as a result of the works, we have published a Guide to the Thames Tunnel compensation programme, which sets out details of compensation that would be available for damage or loss sustained during construction. We also anticipate that if development consent is granted, the DCO would include a number of requirements (similar to planning conditions) that would safeguard the surrounding area. A full assessment of the likely significant effects of the works on the local economy and businesses will be provided in the Environmental Statement for submission with the application. Existing businesses would receive assistance for relocation (see A guide to the Thames Tunnel compensation programme). C
96

Ref Structures 7.3.10 Concerns regarding the effects of using Lack's Dock, including the effects of construction traffic on the physical structure of the docks causeway. 1 PLA Both access options require the use of Lack's Dock N and will be considered in the Transport Assessment. We are also carrying out a navigational risk assessment. We would monitor any likely significant effects on Lacks Dock and quickly repair any damage that is directly attributable to the project. The PEIR (Volume 19, Section 9) at phase two N consultation included a preliminary qualitative assessment of noise and vibration effects on Camelford House. The predicted effects on buildings or structures from vibration were below the threshold for potential cosmetic damage. The PEIR Addendum (Volume 19, Section 4.2) at targeted consultation concluded that although the potential changes to the proposed development introduced new receptors for noise and vibration assessment, including Tintagel House and the northern end of Camelford House, the effects on these receptors would not be significant. Whichever site access route is selected, the contractor would be required to carry out a condition survey before, during and on completion of the construction works. Any damage directly attributable to the works would be made good, or compensated in accordance with the Compensation Code. Global warming is one aspect of climate change, the effects of which were taken into account in the design development process. Our proposals for the permanent structures were subject to on-going engagement with the London Borough of Lambeth, the Environment Agency and other technical N Objections, issues and concerns Total/ID number Our response C
7.3.11
Concerns regarding structural damage to Tintagel House and Camelford House arising from construction traffic included: a. the effects on retaining walls b. the potential to loosen cladding.
14139LO
7.3.12
Concerns regarding any effects of global warming on the structures if the River Thames rises.
14140
97

Ref Objections, issues and concerns Total/ID number Our response consultees. The project as a whole was developed in line with national, regional and local planning policy, and responds to the need to adapt to climate change. Transport and access 7.3.13 7.3.14 7.3.15 Do not support the proposed construction traffic access route at targeted consultation. Use the Lack's Dock option, which would reduce disruption to residents at Peninsula Heights. The proposed site access at targeted consultation is too narrow and not suitable for heavy construction vehicles. Prefer the Lack's Dock access route at phase two consultation for the following reasons: a. concerns regarding the introduction of a separate access and egress point between Camelford House and Tintagel House given the suitable access at Lack's Dock b. this access is used on a daily basis by London Duck Tours, therefore it is difficult to understand the security risk of the projects vetted construction vehicles, which would still occasionally use this route. 7.3.17 Concerns regarding the construction effects of building a new access route between Tintagel House and Camelford House, including the negative effect on pedestrians and cyclists already diverted from the closed section of the Thames Path. 1 LBLam The PEIR Addendum (Volume 19, Section 4.3), states that the effects on pedestrians, cyclists and other road users would remain as predicted in the PEIR at phase two consultation. We would design site accesses to ensure that they meet design and health and safety standards. N 1 1 1 14139LO 14112 14139LO The PEIR Addendum (Volume 19, Section 3.7) it states that the socio-economic effects during construction and operation would remain minor adverse whichever access route is used. Both options are deemed wide enough for construction traffic. We would undertake works to ensure that the selected access route is fit-for- purpose. Your comments are noted, and both access options will be submitted in the application. The Secretary of State will make the final decision on the most appropriate access route pursuant to Section 3.12 of the Waste Water NPS, which relates to national security considerations. N N N C
7.3.16
LBLam, 14112
N N
98

Ref Objections, issues and concerns Total/ID number Our response The CoCP for submission with the application will include a requirement for a Traffic Management Plan to carefully control construction traffic in order to minimise any potential effects on the road network, residential amenity or access to the local area. The CoCP will also set out construction traffic routes, site access/egress points, signage and monitoring procedures. The Transport Assessment for submission with the application will review data on recent accidents in the area to inform future mitigation measures. The proposals will be subject to independent external review by TfL and the London Borough of Lambeth to ensure that the proposed highway layouts and vehicle movement arrangements are as safe as possible. The CoCP requires the provision of emergency access routes; details will be provided in the Traffic Management Plan. We are aware of the current emergency access requirements and would ensure that the contractor maintains or addresses them during construction in the CoCP Part B for submission with the application. We will also discuss the arrangement of our works with the management of the buildings to ensure that access for maintenance and cleaning is maintained during construction. We intend to provide suitable signage for the Thames Path diversion. The detailed design of signage would take place at a future stage. See our responses at paras.7.3.7 and 7.3.10. C
7.3.18
The proposed access route at targeted consultation is used by fire tenders and forms an emergency escape route for occupants of Tintagel House and Camelford House. The Thames Path must be maintained as a fire evacuation route for residents of Peninsula Heights, including provision for a one-way exit path to the park area. Access to Peninsula Heights must be maintained for cleaning and maintenance purposes. Suitable signage should be provided for the Thames Path diversion proposed at targeted consultation. Ensure appropriate mitigation measures are
14112
7.3.19
14112
7.3.20
14112
7.3.21
PLA
99

Ref Objections, issues and concerns implemented to address the effects of using Lack's Dock. More information is needed on the construction site access proposals at targeted consultation and the associated effects, including clearer, more detailed drawings. 1 Total/ID number Our response C
7.3.22
14139LO
The plans at targeted consultation were for illustrative purposes only, and further information on site access proposals was published in the Section 48 publicity material. We are preparing detailed plans of the proposed access arrangements and highway mitigation proposals for the Transport Assessment for submission with the application, in consultation with the relevant local highways authorities and TfL. The plans at targeted consultation were for illustrative purposes only. The contractor would be required to propose a scheme to provide an area to hold/inspect vehicles for security reasons (if necessary), which would be subject to consultation and the regular planning process with TfL and the London Borough of Lambeth. The location of these facilities would be subject to approval by the London Borough of Lambeth to ensure that proposed highway layouts and arrangements for vehicle movements are as safe as possible. It is a requirement of the CoCP (available in draft at Section 48 publicity) to consider the access and servicing requirements of Camelford House and Tintagel House, including the use of the car park. We would ensure that public safety is maintained during our works and would discuss our detailed traffic access proposals with the land owners and operators. We would minimise the loss of car parking and compensation would be payable if parking spaces
7.3.23
Concerns regarding access to the on-site holding area from Albert Embankment and the potential effect of any vehicles that are turned away. This needs to be included in any transport assessment for the site to satisfy TfL.
TfL
7.3.24
Object to the lane closure and parking space loss in the basement car park of Tintagel House and Camelford House for the following reasons: a. It would lead to traffic conflicts. b. It would reduce pedestrian safety. c. The parking is also used by residents of Tintagel House. d. More information is required.
14139LO
100

Ref Objections, issues and concerns Total/ID number Our response were unavailable due to construction works. The access ramp to the car park would be returned to the existing layout following construction. A guide to the Thames Tunnel compensation programme sets out details of the compensation that would be available during construction for damage or loss due to required protection measures or compulsory purchase. C
7.4
7.4.1
PEIR Addendum
This section sets out the feedback received in relation to the Albert Embankment Foreshore PEIR Addendum published at targeted consultation. The supportive and neutral comments are set out in Table 7.5. No objections, issues and concerns were raised at targeted consultation. Table 7.5 Albert Embankment Foreshore: Supportive and neutral comments in relation to the Albert Embankment Foreshore PEIR Addendum
Ref 7.4.2
Supportive and neutral comments Given the changes to the scope and scale of the proposed engineering works, the range and scale of the archaeological programme needs to be applied accordingly. Given the complicated archaeological nature of this site, work would need to be undertaken prior to, during and post construction. 1
Total/ID number EH
Our response The PEIR Addendum (Volume 19, Section 3.5) states that limited changes were made to the scheme at targeted consultation. Therefore the effects on historic environment receptors would remain as stated in the phase two consultation PEIR, whichever site construction access is selected. The mitigation measures would remain as stated in the PEIR, including a suitable programme of archaeological investigation before and/or during construction informed by field evaluations. This investigation should achieve preservation by record by advancing understanding of the significance of assets. Both evaluation and mitigation would be carried out in accordance with a Written Scheme of
C N
7.4.3
EH
101

Ref Supportive and neutral comments Total/ID number Our response Investigation. The Written Scheme of Investigation would be agreed with statutory consultees prior to conducting any archaeological fieldwork before or during construction to ensure that the scope and method of fieldwork are appropriate. C
7.5
7.5.1

The alternative construction access between Camelford House and Tintagel House presented at targeted consultation raised objections from stakeholders. This is an exceptional combination of circumstances and we therefore intend to submit both access options in our application for development consent. The access route will be considered and decided as part of the examination of the application. We propose to include measures to manage the current emergency access requirements during construction in the CoCP Part B for submission with the application. We will also discuss with the arrangement of our works with the management of the buildings to maintain on-going access for maintenance and cleaning purposes during the works.
7.5.2
102
8 Targeted consultation: Victoria Embankment Foreshore
8
8.1
8.1.1
Targeted consultation: Victoria Embankment Foreshore

Introduction
Our proposal
We propose to use an area of the foreshore of the River Thames south of Victoria Embankment (A3211) for our construction works and to accommodate the permanent structures required to operate the main tunnel. The site would be used to control the existing local CSO, known as the Regent Street CSO, by connecting the northern Low Level Sewer No. 1 to the main tunnel. In response to feedback received at phase two consultation and on-going engagement with various technical consultees, we undertook targeted consultation on proposals to:
a. b. c.
8.1.2
revise the design of the permanent works revise the layout and extent of the construction site in response to proposed revisions to the shape and extent of the permanent works and to address navigation risks amend our proposals to move the Tattershall Castle back towards its existing position following construction in order to maintain the views along Horse Guards Avenue towards the river. We are also considering an option to remove the Hispaniola permanently and relocate the Tattershall Castle in the Hispaniolas place.
8.1.3
This section sets out the targeted consultation feedback together with feedback to the Section 42 consultation in respect of changes to the site boundary in relation to the proposed amendments at Victoria Embankment Foreshore. Feedback that related to Victoria Embankment Foreshore but not to the targeted consultation amendments is set out in Section12, Other comments.

8.1.4 This section is organised as follows to reflect the scope of targeted consultation:
a. b.
Section 8.2: Number of respondents Section 8.3: Revised construction site layout and extent
103

c. d. e. f.
Section 8.4: Revised design Section 8.5: Amended proposals for the Tattershall Castle Section 8.6: PEIR Addendum Section 8.7: Our view of the way forward.
8.1.5
In Sections 8.3 to 8.6, we detail the groups and total number of respondents, the comments received and the projects response.
8.2
8.2.1
A total of 16 respondents provided feedback in relation to Victoria Embankment Foreshore at targeted consultation and Section 42 consultation in respect of changes to the site boundary. No comments were received after consultation had closed. The number of respondents in each group is set out in Table 8.1. Table 8.1 Respondents to targeted consultation and Section 42 consultation in respect of changes to the site boundary at Victoria Embankment Foreshore
104
8 Targeted consultation: Victoria Embankment Foreshore 8.2.2 Table 8.2 sets out the statutory consultees and local authorities that provided feedback in relation to this site. Table 8.2 Statutory consultees and local authorities that responded to targeted consultation and Section 42 consultation in respect of changes to the site boundaryat Victoria Embankment Foreshore
Statutory consultees Design Council CABE (CABE) English Heritage (EH) Port of London Authority (PLA) Transport for London (TfL) Local authorities City of Westminster (WCC)
8.2.3
8.3
8.3.1
Revised construction site layout and extent

This section sets out feedback in relation to the revised extent and layout of the construction site at Victoria Embankment Foreshore. The supportive and neutral comments are set out in Table 8.3. The objections, issues and concerns and how we propose to address them are set out in Table 8.4. The comments are grouped by theme, as denoted by the subheadings shaded in orange. Table 8.3 Victoria Embankment Foreshore: Supportive and neutral comments in relation to the revised site construction design and layout
Ref 8.3.2 8.3.3
Supportive and neutral comments Support the revised proposals for the site. Support the revised configuration of the temporary construction site. 1 1
Total/ID number 14110 14011
Our response Your comment is noted and welcomed. Your comment is noted and welcomed.
105

Table 8.4 Victoria Embankment Foreshore: Objections, issues and concerns in relation to the revised site construction design and layout
Ref Objections, issues and concerns 1 Total/ID number PLA Our response The Site selection background technical paper (Section 3.3) provides further information on the size and location requirements for CSO sites. The size varies according to a number of factors including physical constraints, access, ground conditions and the size of the connection tunnel. We have revised the design proposals to moor the barges parallel to the flow and tidal sets of the River Thames. This is illustrated in the drawings at Section 48 publicity. We are carrying out fluvial modelling and preliminary findings informed the design of the site presented at targeted consultation. Further modelling will inform the Environmental Statement for submission with the application. There is potential for some loss of river bed due to changes in river flows during construction, which could lead to scour around the flood defences (see Section 48: Project description and environmental information report (Section 16.2 to 16.3)). The effects would be generally be temporary as some natural foreshore restoration would occur once the temporary construction structures are removed. C N Site design and layout 8.3.4 More justification is needed for the extent of the temporary works.
Transport and access 8.3.5 Concerns regarding the location of moorings for barges; suggest mooring them with the flow and tidal sets of the river rather than offset, as currently shown. Concerns regarding the effect of the revised layout and extent of the construction site on river flows and currents. Concerns regarding the effect of the revised layout and extent of the construction site on river erosion and scour. 1 PLA C
Water and flood risk 8.3.6 1 PLA N
8.3.7
PLA
106

Ref Objections, issues and concerns Total/ID number Our response Scour protection would be constructed along the line of the new river wall to protect it and a new apron would prevent scour from any new CSO outfall constructed. Where significant scour is predicted we would carry out preventative measures such as placing rip-rap on the river bed. We would monitor the riverbed and carry out remedial works if/as required. Rip-rap represents a change in habitat rather than a loss. This will be discussed further in the Environmental Statement. We are carrying out a navigational risk assessment for the site and we will continue to work with the PLA during this process. Appropriate mitigation measures would be set out in the Navigational Risk Assessment. C
8.4
8.4.1
Revised design
This section sets out feedback in relation to the revised design at Victoria Embankment Foreshore. The supportive and neutral comments are set out in Table 8.5. The objections, issues and concerns and our proposals to address them are set out in Table 8.6. The comments are grouped by theme, as denoted by the sub-headings shaded in orange. Table 8.5 Victoria Embankment Foreshore: Supportive and neutral comments in relation to the revised design
Supportive and neutral comments General support for the permanent design and appearance of the site. The proposals for the permanent design of the site are an improvement from phase two consultation, in particular the 'island' concept. Welcome the development of alternative design approaches at this site. 1 2 Total/ID number 14143 14011, 14110 Our response Your comments are noted and welcomed. We have amended the layout and shape of the permanent design in response to targeted consultation feedback. The new proposed layout is more formal and symmetrical than at phase two consultation and targeted consultation, and does not project as far into the river. We had regard to comments from English Heritage and the Design Council CABE in developing the revised proposals and the design
Ref 8.4.2 8.4.3
8.4.4
CABE
107

Ref 8.4.5 Supportive and neutral comments The proposals for the permanent design of the foreshore structure have the potential to become a feature. 1 Total/ID number 14110 Our response is now less modern. The design was influenced by the historic environment of Victoria Embankment and aims to emulate the more formal layout of the townscape in Westminster. It combines elements of the engineering design from targeted consultation with the architectural design at phase two consultation. The amended layout was published at Section 48 publicity. There are no proposed changes to the size of the ventilation columns at targeted consultation. The Section 48 Project description and environmental information report (Section 16.3) states that the effect of odours released from the ventilation column would be negligible. Your comments are noted.
8.4.6
Qualified support included: a. No fundamental objections to the amended scheme in relation to navigational safety during the operational phase. b. The proposed maintenance arrangements seem to have been improved.
PLA
8.4.7
a. The ventilation columns have been replaced by two smaller (4m high) chimneys and the filtration system has been improved to reduce the potential effect of emissions.
PLA, 14110
Your comments are noted.

Table 8.6 Victoria Embankment Foreshore: Objections, issues and concerns in relation to the revised design
Ref Objections, issues and concerns 1 Total/ID number WCC Our response Major adverse effects are predicted on the Grade II listed embankment wall due to construction activity, C N Historic environment 8.4.8 Concerns regarding the effect on the Grade II listed embankment wall.
108

Ref 8.4.9 Objections, issues and concerns Minimise the extent of the listed wall to be removed as far as possible and consider reinforcing the linear definition. There are other robust abutments on the footway along the Victoria Embankment and a similar approach is worthy of consideration. 1 Total/ID number WCC Our response including dismantling the parapet, temporarily removing two sturgeon lamps and permanently removing/relocating another lamp (subject to agreement with the local authority). The effects on the embankment wall were minimised as far as possible to accommodate the current design preferred by the City of Westminster, English Heritage and the Design Council CABE. The Section 48 Project description and environmental information report (Section 16.3) states that these assets would be recorded and photographed in line with accepted standards for preservation by record. Two of the sturgeon lamp stands would be reinstated and the third would be relocated. The resulting residual effects on the river wall would be moderate adverse and minor adverse on the lamp stands. As illustrated in the Section 48 publicity material, we have amended the layout and shape of the permanent design in response to targeted consultation feedback. The new proposed layout is more formal and symmetrical than at phase two consultation and targeted consultation, and does not project as far into the river. We had regard to comments from English Heritage and the Design Council CABE in developing the revised design, which is now less modern. The design was influenced by the historic environment of Victoria Embankment and aims to emulate the more formal layout of the townscape in Westminster. It combines elements of the engineering design at targeted consultation with the architectural design at phase C N
8.4.10 8.4.11 8.4.12
Concerns regarding the effect on the conservation area. Concerns regarding the effect on the World Heritage Site. Concerns that the design of the permanent foreshore structure is not in keeping with its historic setting. Comments included: a. The design is not reflective of the very formal and generally commemorative nature of the north bank. b. The design has a jarring presence on the north bank as it unbalances the contrast between the two sides of the river, which is such a critical element of the extraordinary
1 1 4
WCC WCC EH, WCC, 14011, 14026
C C C
109

Ref Objections, issues and concerns quality of this part of Londons historic environment. c. The design could cause substantial harm to the historic environment in this location. d. The artist's impression suggests a discordant and monolithic box-like structure, which will jar with the Victorian/Edwardian character of the surroundings. 8.4.13 Concerns regarding the modern design, which would damage the historic character of London that attracts tourism and visitors a large revenue for the country. Natural environment 8.4.14 8.4.15 Concerns regarding the loss of trees on the Victoria Embankment footway. More information is needed on mitigation, including replacing trees on the Victoria Embankment footway. Provide appropriate replacement trees: a. TfL will provide more detail on exact tree specifications. b. The viability of replanting will need to be determined before any trees are removed. c. There are opportunities for succession planting as part of the scheme. d. Tree planting near flood defences may require flood defence consent from the Environment Agency. Further consultation 1 1 WCC WCC We sought to position the site so as to minimise the loss of trees. The landscaping plans include new trees to replace those that would be lost. The trees that would be lost have low intrinsic biodiversity value and it is unlikely that they support any notable species. However, due to their townscape value, they would nonetheless be replaced. Trees on or close to the site would be subject to tree protection measures, as stated in the draft CoCP. Our contractor would implement the identified measures, where practicable, in consultation with the City of Westminster tree officer and TfL. We anticipate that if development consent is granted, the DCO will include a series of requirements (similar to planning conditions), which could include submitting detailed landscape proposals for the site. N N 1 14057 Total/ID number Our response two consultation. During the design development, we considered the fact that the site is located within the setting of a number of listed buildings and the Whitehall Conservation Area and lies in close proximity to the Westminster World Heritage Site. C
8.4.16
TfL
110

Ref Objections, issues and concerns regarding any proposed tree planting plans will be required (once the plans are approved by TfL). Total/ID number Our response C
Permanent design and appearance 8.4.17 8.4.18 8.4.19 8.4.20 General objection to the design of the permanent foreshore structure. The proposals for the permanent foreshore structure are unattractive/ugly. Concerns regarding the scale of the works in the River Thames. Concerns regarding the effect on views along the River Thames including the sail-like support structure on the island, which could create visual discord with Hungerford Bridge when viewed from Westminster Bridge, further west along the Embankment or the south bank of the river. Concerns regarding the detailed design of the spiral element. 2 1 1 1 CABE, WCC 14008 WCC EH Refer to the response at para. 8.4.10. C C C C
8.4.21 8.4.22 8.4.23
WCC WCC WCC
C C C
Concerns regarding the risk of further design 1 development increasing the bulk of the structure. Concerns that the requirements of statutory consultees (the PLA/Environment Agency) may result in future design changes that would negatively affect the proposed design. The detailed design of the junction with the embankment wall and the re-entrant corners of the T-shaped structure need further consideration to lighten the perceived bulk. The 1
8.4.24
WCC
111

Ref Objections, issues and concerns treatment of the side walls of the structure may also provide an opportunity to minimise bulk. Amend the design to an orthogonal/symmetrical form, which would reduce the perceived bulk and respond to other riverside projections. This would avoid the risk of an unfortunate pipe effect (potentially created by the island design) that would emphasise the function of the new structure something that Bazalgette sought to discrete within an improved public realm function. The more formal symmetrical design in Figures 7 and 8 on p. 39 of the Design development report Addendum is a far more suitable approach for this location, subject to improving the rationale of its ancillary function, and consequent surface and detailing treatments. Amend the design to be formal in nature and to respond to the key heritage assets in the area. The design needs to take its cue from the character of the northern bank, most obviously the National Liberal Club, Whitehall Court buildings, and the Royal Air Force Memorial. Develop alternative design proposals including a more formal approach to the island design or a structure more akin to a peninsula extending into the River Thames. Develop the phase two consultation design further. Comments included: a. There is no need for the structure to be symmetrical to fit with the formal 3 Total/ID number Our response C
8.4.25
CABE, EH, WCC
8.4.26
EH
8.4.27
EH
8.4.28
EH, WCC
112

Ref Objections, issues and concerns surroundings. A less modest proposal could sit comfortably against the broad and open context of the River Thames. It is more important to develop a formal design approach that complements the character of the surroundings and is designed and viewed as a coherent whole. b. Consider how the structure would appear at both low and high tide. In order to mitigate the visual effect, the following options should be explored: i Provide a foreshore and/or stepped access to the river. 1 Total/ID number Our response C
EH
These issues were taken into account in the design development process. We did consider the concept of access to the foreshore from the structure; however it was not deemed suitable for health and safety reasons.
ii Create moorings on the new structure for small boats and make them accessible to people with impaired mobility. c. The entrance/exit to Embankment Gardens should create a visual connection between the gardens and the new public space and potentially a new sequence of public spaces facilitated by a new pedestrian road crossing. 1 EH In light of these comments we will revise the alignment of two of the new kiosk structures to frame the view from Embankment Gardens to the foreshore, which would reinforce the link between the two. We do not propose to implement a pedestrian crossing as this is a major traffic route that has a number of existing crossings in close proximity. As illustrated in the Section 48 Project description and environmental information report (Figure 16.3), an area of shelter is incorporated within the permanent design. Access was carefully considered to ensure that all visitors could use the space, in line with Core Strategy Policy CS27 Urban Design and CS36 Blue Ribbon Network. C
d. Further consideration should be given to the design of the transition between the pavement of Victoria Embankment and the proposed new public space. There is a need to balance openness and enclosure to preserve views towards the river from the pavement and to create a conformable
EH
113

Ref Objections, issues and concerns transition for pedestrians, while providing some shelter from the noisy road in the new public space. e. The ventilation column should be a stronger 1 feature within the design of the new public space and its location carefully considered so that it does not block views of the river. f. The different level changes in the new public space would prevent full accessibility across the structure for all users. g. Co-ordinate the design of the different elements of the scheme, such as the kiosk, ventilation column, seating, handrails, in order to ensure a fully integrated design. 8.4.29 The detailed design of the threshold between the new structure and the existing footway needs to be considered. Is it possible to require the Tattershall Castle to have a complete facelift? It is an eyesore now and will probably look even worse once the works and landscaping are complete. The design and finish of the permanent foreshore structure should be in keeping with the historic setting and blend in with the historic character of the Embankment. Comments included: 1 Total/ID number Our response There would be bronze detailing on the threshold between the existing pavement and the new area of public realm. Illustrative examples can be found in the Design development report Addendum (Figure P.11, p. 44). As illustrated in the Section 48 Project description and environmental information report (Figure 16.3), the ventilation columns would now be positioned in a corner on the upper terrace level where they would not block the principal views. Access was carefully considered to ensure that all visitors could use the space, in line with Core Strategy Policy CS27 (Urban Design) and CS36 (Blue Ribbon Network). We understand the need to ensure the quality of and integration between all elements of the design, particularly at such a sensitive site. See response at para. 8.4.28. C
EH
EH
EH
WCC
8.4.30
14143
Improving the appearance of the Tattershall Castle is outside the scope of our proposed application for development consent. As illustrated at Section 48 publicity, we have amended the layout and shape of our permanent design in response to targeted consultation feedback. The new proposed layout is more formal and symmetrical than at phase two consultation and
8.4.31
14011
114

Ref Objections, issues and concerns a. The rectangular base section abutting the Embankment should be entirely faced with stonework to match and blend in with the existing embankment. b. The new structure should be furnished with railings etc that completely match and blend in with the existing railings and structures on the Embankment. Anything else in such a historic a stretch of the river would simply be an eyesore. 8.4.32 More information is needed on mitigation including clarification of the use of materials. 1 WCC Total/ID number Our response targeted consultation, and does not project as far into the river. In developing the revised design we had regard to comments from English Heritage and the Design Council CABE. Consequently the design is now less modern. The proposals were influenced by the historic environment of Victoria Embankment and our aim is to emulate the more formal layout of the townscape in Westminster. The design combines elements of the targeted consultation engineering design with the phase two consultation architectural design. We considered the fact that the site is located in the setting of a number of listed buildings, the Whitehall Conservation Area and in close proximity to the Westminster World Heritage Site. We are developing our maintenance proposals for the site, which will be discussed with the City of Westminster. C
8.4.33
Concerns regarding the future management and ownership of the new public realm, as any development in this location must be well maintained and cared for in order to avoid harming the historic environment. Concerns regarding the accessibility of the proposed design, as people with impaired mobility would only be able to access the island from one of the bridges.
EH, WCC
Transport and access 8.4.34 1 CABE Most of our stakeholders did not view the proposed design at targeted consultation as an improvement therefore it will not be taken forward. As illustrated in the Section 48 publicity material, we have amended the layout and shape of the permanent design in response to targeted consultation feedback. The revised design does not include any bridges therefore this comment is no longer relevant. N
115

Ref 8.4.35 8.4.36 Objections, issues and concerns Concerns regarding the effect of the permanent foreshore structure on river flows and currents. Concerns regarding the effect of the foreshore structure on river erosion/scour. 1 1 Total/ID number PLA PLA Our response See response at para. 8.3.6. C N N
Water and flood risk
8.5
8.5.1
Amended proposals for the Tattershall Castle

This section sets out feedback in relation to our revised proposals for the Tattershall Castle. The supportive and neutral comments are set out in Table 8.7. The objections, issues and concerns and how we propose to address them are set out in Table 8.8. The comments are grouped by theme, as denoted by the sub-headings shaded in orange.

Table 8.7 Victoria Embankment Foreshore: Supportive and neutral comments in relation to the amended proposals for the Tattershall Castle
Ref 8.5.2 Supportive and neutral comments No in-principle objections to the proposed approach to the temporary and permanent relocation of the Tattershall Castle. 1 Total/ID number PLA Our response Your comment is noted and welcomed. C

Table 8.8 Victoria Embankment Foreshore: Objections, issues and concerns in relation to the amended proposals for the Tattershall Castle
Ref Objections, issues and concerns 1 Total/ID number 14078LO Our response Your concerns are noted. Our application for development consent will seek authorisation for the C Planning and development 8.5.3 Planning consent for the relocation of the Tattershall Castle is unlikely to be granted.
116

Ref Objections, issues and concerns Total/ID number Our response works associated with the relocation of Tattershall Castle. Our preferred option is to relocate the Tattershall Castle to a temporary mooring to the south of our site during construction and then to move her back north as close to her existing location as possible once the works are complete. We are also considering permanently removing the Hispaniola and putting the Tattershall Castle in the Hispaniolas place. Whichever option is selected, we are carrying out an assessment and we will report the potential effects on the affected businesses in the Environmental Statement for submission with the application. We have published an Exceptional hardship procedure that sets out how we would assess claims from householders who contend that they are suffering exceptional hardship as a result of being unable to sell their property because it is potentially affected by our currently published proposals. We have also published a Guide to the Thames Tunnel compensation programme, which sets out details of compensation that would be available during construction for damage or loss, required protection measures or compulsory purchase. C
Socio-economic 8.5.4 Concerns regarding the effect on local businesses (including the RS Hispaniola) and planning 'blight' during and after construction. Object to the temporary and permanent relocation of the Tattershall Castle (preferred option). Support for the preferred option rather than the relocation of the Hispaniola if the relocation of the Tattershall Castle is proved to be necessary. Concerns regarding the proposals for the Tattershall Castle. Relocation of the Tattershall Castle would have a detrimental effect on business, which employs between 20 and 40 members of staff, depending on the season. Relocation and reinstatement of moorings used by Class V operators and the effects on permanently-moored vessels require further discussion with the PLA. Thames Water must take responsibility for securing a replacement mooring for the Tattershall Castle in the immediate vicinity of the existing location, and include in any eventual DCO a replacement mooring in the immediate vicinity of the existing location. Concerns regarding the logistics of relocating 1 14006LO N
8.5.5
14078LO
8.5.6
14078LO
8.5.7 8.5.8
1 1
WCC 14078LO
N N
8.5.9
PLA
8.5.10
14078LO
8.5.11
14078LO
Your concerns are noted. Discussions regarding the
117

Ref Objections, issues and concerns the Tattershall Castle, including the need to liaise with a number of interested parties. Consider an alternative site for the proposed works to avoid effects on the Tattershall Castle. 1 Total/ID number Our response relocation of Tattershall Castle are on-going. All alternative sites have been considered in accordance with the Site selection methodology paper. C
8.5.12
14078LO
8.6
8.6.1
PEIR Addendum
This section sets out the feedback in relation to the Victoria Embankment Foreshore PEIR Addendum published at targeted consultation. No supportive or neutral comments were received. The objections, issues and concerns received and how we propose to address them are set out in Table 8.9. Table 8.9 Victoria Embankment Foreshore: Objections, issues and concerns in relation to the Victoria Embankment Foreshore PEIR Addendum
Ref 8.6.2
Objections, issues and concerns No substantive evidence has been presented on the effects of either the temporary works or the permanent structure on the River Thames hydrodynamics. Query the conclusions reached in the PEIR Addendum. 1
Total/ID number PLA
Our response Fluvial modelling and scour studies on the revised design at Section 48 publicity are on-going. The PEIR Addendum (Volume 20, Section 3.11) states that the flow in the River Thames would be modified by the presence of the temporary and permanent works. This may lead to increased scour or deposition rates on adjacent areas in the river and on river structures, including flood defences. We will undertake modelling of potential effects from the revised scheme, which will be reported in the Environmental Statement for submission with the application. As stated in the Design development report Addendum (Appendix P), heritage assets in close proximity to the site were carefully considered in the design development process. The revised proposals
C N
8.6.3
The PEIR has yet to address the setting of the heritage assets as required by para. 4.10.7 of the Waste Water NPS. This gap in the assessment work, together with the current treatment of visual
EH
118

Ref Objections, issues and concerns effects in this location, demonstrates a weak platform of understanding from which to design this very challenging site. Total/ID number Our response responded to comments from English Heritage and the Design Council CABE at previous phases of consultation. This issue will be addressed further in the Environmental Statement for submission with the application. An Overarching Written Scheme Of Investigation for the Environmental Statement will provide further details of the surveys undertaken. C
8.7
8.7.1 8.7.2

We took all the feedback received on our proposals for this site at targeted consultation into account in accordance with the requirements of the 2008 Act. As illustrated in the Section 48 publicity material, we have amended the layout and shape of the permanent design in response to targeted consultation feedback. The revised layout is more formal and symmetrical than at phase two consultation and targeted consultation, and does not project as far into the river. We had regard to comments from English Heritage and the Design Council CABE in the design development process. The revised design was influenced by the historic environment of Victoria Embankment and seeks to emulate the more formal layout of the townscape in this area. Our preferred option remains to relocate the Tattershall Castle to a temporary mooring south of our site during construction and then to move her back north, as close to her existing location as possible, once the works are complete. We are considering the option of permanently removing the Hispaniola and putting the Tattershall Castle in the Hispaniolas place. Discussions with the owners, the City of Westminster and the PLA are on-going.
8.7.3
119
9 Section 42 consultation: Modifications to site boundaries
9
9.1
9.1.1
Section 42 consultation: Modifications to site boundaries

Introduction
Our proposal
We made some modifications to the proposed site boundaries as a result of feedback at phase two consultation and ongoing design development. A description of the boundary modifications proposed at each site is provided in Appendix H and full details are set out in the updated Book of plans prepared for Section 42 consultation.

9.1.2 This section sets out the Section 42 consultation feedback in relation to the proposed amendments to site boundaries. Where respondents who commented on Barn Elms, Putney Embankment Foreshore, Albert Embankment Foreshore and Victoria Embankment Foreshore made the same comments in relation to the modifications to the site boundaries and amendments to the proposals at these sites, the feedback is reported at Sections 5 to 8 as appropriate. This section is organised as follows to reflect the feedback received at Section 42 consultation:
a. b. c. d. e. f.
9.1.3
Section 9.2: Number of respondents Section 9.3: Project-wide comments in relation to modifications to site boundaries Section 9.4: Feedback in relation to Cremorne Wharf Depot Section 9.5: Feedback in relation to Chelsea Embankment Foreshore Section 9.6: Non-site specific feedback Section 9.7: Our view of the way forward.
9.1.4
120
9.2
9.2.1
A total of five respondents provided feedback on modifications to site boundaries. No comments were received after consultation had closed. The number of respondents in each group is set out in Table 9.1. Table 9.1 Respondents to Section 42consultation on modifications to site boundaries
9.2.2
Feedback was submitted in a number of forms, including feedback forms and correspondence (emails and letters). Table 9.2 sets out the statutory consultees and local authorities who provided feedback on modifications to site boundaries. Table 9.2 Statutory consultees and local authorities who provided feedback in relation to modifications to site boundaries
Statutory consultees Network Rail (NR) Transport for London (TfL) Local authorities Royal Borough of Kensington and Chelsea (RBKC)
9.3
9.3.1
Project-wide comments in relation to modifications to site boundaries

This section sets out the feedback in relation to project-wide modifications to site boundaries. No supportive or neutral comments were received. The objections, issues and concerns and how we propose to address them are set out in Table 9.3.
121

Table 9.3 Objections, issues and concerns in relation to project-wide modifications to site boundaries
Ref 9.3.2 Objections, issues and concerns Previous comments have not yet been addressed and require further work. Total/ID number 1 TfL Our response We have engaged with TfL extensively in relation to our transport strategy and will continue to do so in developing the design for the project. We are happy to discuss our approach to addressing comments from previous phases of consultation at one of our regular meetings with TfL. Your comments are noted. We will continue to discuss our proposals with Network Rail. C N
9.3.3
9.3.4 9.3.5
9.3.6
The information is not sufficiently detailed to fully assess potential impacts of the scheme on the railway. Further information will be required to properly comment on the likely impacts of the proposed scheme. It is likely, however, that the proposals would significantly impact on railway infrastructure. Network Rail will seek protection from any exercise of compulsory purchase powers over its land either for permanent or temporary purposes. Network Rail wishes to agree protection for the railway during the course of the construction works and otherwise to protect its undertaking and land interests. Network Rail is willing to discuss the inclusion of Network Rail land or rights over land on condition that there are no impacts on the operational railway, all regulatory and other required consents are in place and appropriate commercial and other terms are agreed between the parties and approved by the Network Rail Board.
NR
1 1
NR NR
N N
NR
122
9.4
9.4.1
Feedback in relation to Cremorne Wharf Depot

This section sets out the Section 42 consultation feedback in relation to modifications of the site boundary at Cremorne Wharf Depot. The supportive and neutral comments are set out in Table 9.4. The objections, issues and concerns, including suggestions for mitigation, are set out in Table 9.5. Table 9.4 Supportive and neutral comments in relation to modifications to the site boundary at Cremorne Wharf Depot
Ref 9.4.2
Supportive and neutral comments Support the changes to the site boundary to enable barge transport since this is a safeguarded wharf with direct river access. The change to the site boundary would reduce the effect on road transport. The change to the site boundary would have a positive effect on air quality. The change to the site boundary would improve amenity in the area. 1
Total/ID number RBKC
Our response Your support is noted and welcomed.
9.4.3 9.4.4 9.4.5
1 1 1
RBKC RBKC RBKC
Table 9.5 Objections, issues and concerns in relation to modifications to the site boundary at Cremorne Wharf Depot
Ref 9.4.6 Objections, issues and concerns More information is needed on the rationale for the site boundary change in respect of the highway at Lots Road. 1 Total/ID number RBKC Our response The change to the site boundary at Lots Road enables potential modifications to the site entrance, which were identified as part of the Transport Assessment. The Transport Assessment will be submitted with the application. Cremorne Riverside Activity Centre would not be affected by the changes to the site boundary. The centre could continue to operate from its current C N/A
9.4.7
Concerns regarding disruption to recreational activities at the Cremorne Riverside Activity Centre. Alternative recreation facilities for the
RBKC
123

Ref Objections, issues and concerns centre should be provided. Total/ID number Our response location for the duration of our works. The PEIR (Volume 15, Section 10) provides a preliminary assessment of the likely effects of the proposed development on amenity at the centre. We believe that, given the breadth of the river at this point, users would likely be able to avoid the construction works area. Therefore, effects are not likely to be significant. Modifications to the site boundaries would not increase the size of the shaft or other structures on the site. Your comment is noted. The jetty would be maintained to a high standard. C
9.4.8
Reassurance is required that extending the site boundaries would not increase the size of the shaft or other structures on the site. Ensure that the jetty, which is an integral component of the safeguarded wharf designation, is maintained to a high standard.
RBKC
9.4.9
RBKC
9.5
9.5.1
Feedback in relation to Chelsea Embankment Foreshore

This section sets out the Section 42 consultation feedback in relation to modifications to the site boundary at Chelsea Embankment Foreshore. The supportive and neutral comments are set out in Table 9.6 and the objections, issues and concerns in Table 9.7. Table 9.6 Supportive and neutral comments in relation to modifications to the site boundary at Chelsea Embankment Foreshore
Ref 9.5.2
Supportive and neutral comments No comment on the proposed site boundary modification. 1
Total/ID number RBKC
Our response Your comment is noted.
124
9 Section 42 consultation: Modifications to site boundaries Table 9.7 Objections, issues and concerns in relation to modifications to the site boundary at Chelsea Embankment Foreshore
Ref 9.5.3 Objections, issues and concerns Reassurance is required that the extension of the site boundaries will not increase the size of the shaft or other structures on the site. 1 Total/ID number RBKC Our response Modifications to the site boundaries will not increase the size of the shaft or other structures on the site. C N
9.6
9.6.1
Non-site specific feedback

This section sets out the Section 42 consultation feedback in relation to modifications to site boundaries, where it was not clear which site the respondents comments related to. The supportive and neutral comments are set out in Table 9.8 and the objections, issues and concerns in Table 9.9. Table 9.8 Non site-specific supportive and neutral comments in relation to modifications to site boundaries
Supportive and neutral comments Support for the transportation of construction materials by river. 1 Total/ID number 14056 Our response Your support is noted and welcomed.
Ref 9.6.2
Table 9.9 Non site-specific objections, issues and concerns in relation to modifications to site boundaries
Ref 9.6.3 Objections, issues and concerns Amendments to site boundaries may result in additional feedback on the proposals/additional documentation or approvals processes in order to satisfy TfL interests. Concerns regarding the effect of light pollution from traffic flows on the revised access route and offloading, and light pollution from the construction site on businesses and residential properties. 1 Total/ID number TfL Our response Your comment is noted. C N
9.6.4
14081
The draft CoCP states that construction lighting would be provided to ensure the safety and security of the site and would comply with the provisions of BS5489 Code of Practice for the Design of Road Lighting, where applicable. For example, the lighting would be located and directed to minimise intrusion into occupied residential properties and sensitive
125

Ref Objections, issues and concerns Total/ID number Our response areas. See the Managing construction project information paper produced at phase two consultation, for further details. A Lighting Management Plan would also be prepared by our contractor. If development consent is granted, we anticipate that the DCO would contain a series of requirements (similar to planning conditions) to control the development. We expect that the mitigation measures set out in the Environmental Statement would form part of these requirements. In addition, we would oblige our contractor to comply with the CoCP in the construction contract, which would require the adoption of appropriate measures to avoid creating statutory nuisances, where necessary. We would agree appropriate lighting for any part of the site within the foreshore with the PLA. Where appropriate, we would include lighting to the site boundary to provide safe routes around the site in line with industry standards. During working hours, artificial lighting would be used as necessary. The CoCP for submission with the application will provide further details on lighting during the construction phase. As stated in the site information papers produced at phase two consultation, the contractor would be required to implement noise and vibration control measures at all sites, in line with the requirements of the CoCP. The contractor would also be required to gain approval from the relevant local authority prior to commencing construction through a Section 61 application under the Control of Pollution Act, which would set out specific working methods and the C
9.6.5
Concerns regarding noise from the construction works due to the funnelling effect of the adjacent concrete buildings, which would noise into the river and reverberate onto the residential properties opposite.
14081
126

Ref Objections, issues and concerns Total/ID number Our response measures to minimise noise and vibration. This would ensure that the noise levels are reasonable and best practice methods are applied. The measures would be agreed with environmental health officers from the local authority. We would also implement measures to minimise noise and vibration from plant and works, including the selection of appropriate plant and equipment, the suitable siting of equipment and the use of site enclosures to provide acoustic screening. Details of the measures to be adopted for the construction phase will be provided in the CoCP for submission with the application. C
9.6.6
Concerns regarding the effect of dust from the construction works on (historic) buildings.
14081
The Managing construction project information paper N produced at phase two consultation and the draft CoCP (an initial draft was produced at phase two consultation and a revised draft at Section 48 publicity) set out how dust control measures and dust monitoring equipment would be implemented to minimise likely significant effects of dust from construction activities. The draft CoCP states that an Air Management Plan would be prepared and implemented for each site to control dust, and proposed techniques would comply with best practice guidelines. We conducted a preliminary assessment of air quality effects, which was presented in the PEIR, and considered the likely significant effects of dust at each construction site. Further assessment will be undertaken as part of our on-going environmental impact assessment work, which will be reported in the Environmental Statement for submission with the application.
127

Ref 9.6.7 Objections, issues and concerns Concerns regarding the increase of permanent structures in the river. 1 Total/ID number 14056 Our response In view of the layout of the Victorian sewerage network and the constrained urban environment, in some locations there was no feasible alternative but to encroach into the River Thames. In such cases, we sought to minimise the footprint of the works and balance any loss against the long-term improvements that the project would make to the water quality of the River Thames. However, CSOs drain downhill towards the River Thames and must be intercepted and directed to the tunnel very close to its banks. To a large extent, this means that permanent development along the banks is essential. C N
9.7
9.7.1

We received a range of feedback in relation to our proposed modifications to site boundaries at Section 42 consultation, including supportive and neutral comments and objections, issues and concerns. We took all of the feedback received into account in accordance with the requirements of the 2008 Act. No comments were received that would lead us to change the proposed boundary modifications. Accordingly, the proposed limits of land to be acquired or used remained the same at Section 48 publicity.
9.7.2
128
10 Section 42 consultation: Modifications to the tunnel alignment
10
10.1
10.1.1
Section 42 consultation: Modifications to the tunnel alignment

Introduction
Our proposal
We first presented our preferred tunnel alignment for comment at phase two consultation. Since then, we have made some modifications to the proposed alignment in response to phase two consultation feedback and on-going design development. More information on the proposed modifications to the alignment is provided in the updated Book of plans published at post phase two consultation.

10.1.2 This section sets out the Section 42 consultation feedback in relation to the proposed amendments to the tunnel alignment. Feedback that related to the tunnel alignment but not to the Section 42 consultation amendments is set out in Section 12 Other comments. This section is organised as follows to reflect the feedback received at Section 42 consultation:
a. b. c. d.
10.1.3
Section 10.2: Number of respondents Section 10.3: Supportive and neutral comments Section 10.4: Objections, issues and concerns Section 10.5: Our view of the way forward.
10.1.4
10.2
10.2.1
A total of 25 respondents provided feedback in relation to modifications to the tunnel alignment at Section 42 consultation, of which two responded after consultation had closed. The number of respondents in each group is set out in Table 10.1.
129
10 Section 42 consultation: Modifications to the tunnel alignment Table 10.1 Respondents to Section 42 consultation in relation to modifications the tunnel alignment
Respondent group Statutory consultees (SC) Local authorities (LA) Landowners (LO) Community consultees (CC) Petitions (PET) 0 5 18 1 with 54 signatories Number of respondents 1 Transport for London (TfL)
10.2.2
Feedback was submitted in a number of forms, including feedback forms, correspondence (emails and letters) and a petition.
10.3
10.3.1

No supportive and neutral comments were received.
10.4
10.4.1

The objections, issues and concerns in relation to the modifications to the tunnel alignment and how we propose to address them are set out in Table 10.2. Table 10.2 Objections, issues and concerns in relation to modifications to the tunnel alignment
Objections, issues and concerns Do not agree that the Abbey Mills route is the correct alignment, particularly at Lillian Road. Reasons included: 6 Total/ID number 14104LO, 14052LO, 14098, 14099, LR14092, 14096PET Our response As set out in the Route and tunnel alignment project information paper at phase two consultation, the Abbey Mills route is our preferred route because: it is the shortest route; it is the least disruptive and most cost-effective option, costing 20 per cent less than the other two options, while meeting all the required environmental objectives; it requires the least number of worksites; and it requires less
Ref 10.4.2
130

Ref Objections, issues and concerns Total/ID number Our response tunnelling at depth through Chalk in the east. Deep tunnelling through Chalk is potentially more difficult and gives rise to greater health and safety issues. The alignment at Lillian Road is our preferred alignment because it avoids two existing tunnels at a similar depth to the main tunnel, which cross the River Thames north of St Pauls School. This alignment would run under fewer buildings than other possible alignments. We have met with Lillian Road residents and representatives of St Pauls School since Section 42 consultation to discuss our proposals. The Site selection background technical paper makes the case for our preference for the horizontal alignment of the main tunnel to follow the River Thames. It also sets out where the route needs to deviate from the river. There are a number of constraints that lead to our preference to deviate from the River Thames in this location. This alignment minimises the overall potential for likely significant effects. The tunnel alignment was developed to avoid residents as far as possible in line with other constraints, such as: the need to connect to the existing sewer system; the angles that tunnel boring machines of the size required for the main tunnel can construct; existing or planned underground developments; known sensitive structures and monuments; and health and safety of workers during construction and maintenance. In the St Paul's School/Lillian Road area, the proposed alignment runs along the back of residents gardens, however it avoids the school itself and the foundations of properties on Lillian Road. The preferred alignment also runs under fewer buildings than other alignment options.
a. The tunnel no longer follows the River Thames as previously proposed.
b. The tunnel crosses underneath the back gardens of properties on the north side of Lillian Road.
131

Ref 10.4.3 Objections, issues and concerns More information is required on the alignment. Requests included: a. details of the relevant underground conditions at St Paul's School/Lillian Road 6 Total/ID number 14118LO, 14120LO, 14052LO, 14089, 14097, 14142 Our response We carefully considered the information we made available at Section 42 consultation to ensure that consultees had sufficient information to respond. The amendments to the tunnel alignment are set out in the Book of plans. Additional information is available in our phase two consultation material, in particular the Route and tunnel alignment project information paper. We are confident, therefore, that the information we provided was sufficient. In relation to the specific information requests: Beneath St Pauls School and Lillian Road, the ground conditions comprise approximately 6m of made ground over clay. Refer to our response at para. 10.4.2. We are carrying out an assessment of the likely significant effects as a result of the works as part of the Environmental Impact Assessment, which will set out necessary measures to mitigate any significant adverse effects that arise. The findings of the assessment will be included in the Environmental Statement for submission with the application. The initial environmental assessment work to date is provided in the PEIR and PEIR Addenda, which are available on our website. The Section 48 Project description and environmental information report provides limited environmental information to assist stakeholders to understand the nature and location of the proposed development. See Section 2 of that document for information on the likely effects from the construction and operation of the tunnels. Information on the tunnelling process is provided in the Build project information paper and the Site selection background technical paper.
b. why the tunnel passes under houses at Lillian Road if the project aims to avoid this c. details of engineering aspects and impacts
132

Ref Objections, issues and concerns d. details of the proposed location/alignment and depth of the sewer Total/ID number Our response The alignment of the main tunnel in the St Paul's School/Lillian Road area is illustrated in the Book of plans at Section 42 consultation. At this point in the route, the main tunnel would be approximately 35m below ground level. Further details were also made available at Section 48 publicity. Refer to the Section 48: Book of plans for further details. Refer to our response at para. 10.4.4. The main tunnel would be only 6.5m wide in the St Paul's School/Lillian Road area. The drawings provided in the Book of plans illustrate the limits of deviation for the main tunnel, that is, the area in which it would be constructed. A certain degree of flexibility in the alignment is required in order to accommodate alignment modifications that may arise as a result of detailed design. 8 14118LO, 14120LO, 14097, 14099, 14142, LR14092, MD14102 We assessed the ground settlement/movement that would potentially be caused by the tunnelling works along the entire route. Where possible, we developed an alignment that avoids the potential for building settlement. We will engage with the relevant owners of all the structures that the tunnel would pass under, or close to, that might be affected by settlement. Monitoring requirements and mitigation measures will be set out in the CoCP for submission with the application. The phase two consultation Settlement project information paper describes how we propose to avoid causing damage to buildings. We are carrying out a more detailed assessment of the risk of tunnelling in proximity to existing buildings at St Paul's School and properties on Lillian Road. We anticipate that some negligible effects may arise from the tunnelling
e. the impacts on residential properties at Lillian Road f. the leeway the tunnel has to pass under gardens or extensions between St Paul's School and Lillian Road.
10.4.4
Concerns regarding the effect on above and below-ground infrastructure and buildings including existing buildings at St Paul's School. Comments included: a. The drains on the northern side of Lillian Road run under the back extensions and are extremely fragile. b. Vibration from construction of the tunnel could crack drains and underfloor heating.
133

Ref Objections, issues and concerns Total/ID number Our response works. We will carry out a full condition survey at Lillian Road prior to commencing construction. In view of the assessment to date, the proposed alignment through this area remains our preferred route. Landowners may have a statutory entitlement to claim compensation for any diminution in the value of property due to the construction of the tunnel. In addition to the statutory process, we have published an Exceptional hardship procedure, which sets out how we would assess claims from householders who contend that they are suffering exceptional hardship as a result of being unable to sell their property because it is potentially impacted by our currently published proposals. We have also published a Guide to the Thames Tunnel compensation programme, which sets out details of compensation that would be available during construction for damage or loss, required protection measures, or compulsory purchase. We will not enter into any Party Wall Agreements for the works within the scope of the application for development consent and will disapply the Party Walls Act so far as it affects the project. However, as part of our design development work, we will identify any particularly sensitive properties and include special powers in the application to protect and repair such properties. For properties that do not fall within this category that may potentially be significantly affected by our works, we will produce a Settlement Policy. This policy will set out how we propose to address effects arising from our works. In the case of residents at Lillian Road, our design work to date only indicates the potential for insignificant damage. Therefore the properties would not be subject to the provisions set out in the preceding paragraphs. Notwithstanding this, we have agreed with residents of
c. Request confirmation that Party Wall Agreement inspections will apply to Lillian Road, and will include CCTV inspection.
134

Ref Objections, issues and concerns Total/ID number Our response Lillian Road to undertake pre-condition surveys of sewers, drains and every house on both sides of Lillian Road within the next six to 12 months. Refer to our response at para. 10.4.2.
d. Why does the tunnel pass beneath St Paul's School rather than following the alignment of the River Thames more closely? Query whether alternative alignments have been assessed? e. Request details of the precise alignment and depth of the tunnel to assess whether there is any direct conflict with the planned major renewal programme. f. Request details of the methodology for tunnelling. 10.4.5 Clarification requested on the reasons for the proposed re-alignments. It should also be noted that amendments to the tunnel alignment may result in additional feedback on the proposals/additional documentation or approvals processes in order to satisfy TfL interests. 1 TfL
Refer to our response at para. 10.4.2.
Information on the tunnelling process is provided in the Build project information paper and the Site selection background technical paper. The reasons for the specific tunnel re-alignments vary for each amendment. In summary the reasons include: a. Connection tunnel to main tunnel junction: The boundaries at the end of connection tunnels where there is a junction with the main tunnel were widened to optimise the location of the junctions. Information on ground conditions to determine the optimum location may not be available until after the main tunnel drive. This applies to the connection tunnels associated with the following sites: Hammersmith Pumping Station, Barn Elms, Putney Embankment Foreshore, Dormay Street, Falconbrook Pumping Station, Cremorne Wharf Depot, Chelsea Embankment Foreshore, Heathwall Pumping Station, Albert Embankment Foreshore and Victoria Embankment Foreshore. b. Connection tunnel relocation: The boundary of the
135

Ref Objections, issues and concerns Total/ID number Our response connection tunnel at Putney Embankment Foreshore was moved due to a change in the location of the site. c. Protecting connection tunnel from development: The boundary of the connection tunnel at Falconbrook Pumping Station was widened to avoid the foundations of a planned residential development affecting the tunnel alignment. Main tunnel location: The boundary of the main tunnel was moved closer to some CSO drop shafts in order to reduce the length of the required connection tunnels in Lambeth Group ground conditions at Heathwall Pumping Station, Albert Embankment Foreshore and Victoria Embankment Foreshore.
d.
10.4.6
Concerns that the alignment illustrated in the drawings will not be the alignment that is constructed. Reasons included that the school does not want the project to move in its direction because of the depth of the foundations of their new buildings, meaning that any movement would be towards Lillian Road. Concerns regarding the effect of tunnelling under houses on property value.
14118LO, 14120LO, 14097, MD14102
The main tunnel would be only 6.5m wide in the St Paul's School/Lillian Road area. The drawings provided in the Book of plans illustrate the limits of deviation for the main tunnel, that is, the corridor in which it would be constructed. Some flexibility in the alignment of the main tunnel is needed to accommodate modifications that may arise in the detailed design. The drawings at Section 48 publicity illustrate the proposed alignment for submission with the application. Landowners may have a statutory entitlement to claim compensation for any diminution in the value of property due to the construction of the tunnel. In addition to the statutory process, we have published an Exceptional hardship procedure, which sets out how we would assess claims from householders who contend that they are suffering exceptional hardship as a result of being unable to sell property because it is potentially impacted by our currently published proposals. We have also published a Guide to the Thames Tunnel compensation programme,
10.4.7
14097, 14098, 14099, 14109, 14142, LR14092 14109
10.4.8
Concerns regarding disruption from the tunnel during construction and operation and in particular the difficulty of selling a property due to disruption from the project.
136

Ref Objections, issues and concerns Total/ID number Our response which sets out details of compensation that would be available during construction for damage or loss, required protection measures, or compulsory purchase. We are holding discussions with St Paul's School regarding its proposed renewal programme.
10.4.9
Concerns regarding the effect on planned development. In particular, the implementation of the major renewal programme at St Paul's School. The proposed buildings would likely have piled foundations to a depth of 35m; constructing a tunnel under the site could sterilise land that has planning permission for development. Concerns regarding the effect of construction activities on residential amenity.
14118LO, 14120LO
10.4.10
14104LO
The PEIR provides a preliminary assessment of the likely significant effects of the project on a range of topics including: noise and vibration; air quality (including dust emissions) and odour; and transport, based on a methodology agreed with the potentially directly affected local authorities. A full assessment will be provided in the Environmental Statement for submission with the application. Mitigation measures will be put in place to address any likely significant effects identified, in addition to the measures set out in the draft CoCP. We are also carrying out a Health Impact Assessment, which will examine the likely significant effects of the proposed development on human mental and physical health and well-being and possible effects in the population. The findings of this study will inform the design for this site and mitigation measures to address any likely significant effects. The construction of the main tunnel would not affect the day-to-day operation of St Paul's School.
10.4.11
St Paul's School will not object if the construction phase has no material impact on the day-to-day operation of the school in terms
14118LO, 14120LO
137

Ref Objections, issues and concerns of teaching/curricular activities and the use of the playing fields for sport and other activities. Total/ID number Our response
10.5
10.5.1

We received a range of objections, issues and concerns in relation to the proposed modifications to the preferred tunnel alignment at Section 42 consultation. The majority of comments were received in respect of the Lillian Road/St Pauls School area. We took all of the feedback into account in accordance with the requirements of the 2008 Act. No comments were received that would lead us to change the proposed modifications to the preferred tunnel alignment. Accordingly, the proposed tunnel alignment remained the same at Section 48 publicity.
10.5.2
138
11 Section 42 consultation: Ground water abstraction
11
11.1
11.1.1
Section 42 consultation: Ground water abstraction

Introduction
Our proposal
The project has the potential to affect ground water abstraction processes during the construction period. We undertook Section 42 consultation in respect of ground water abstraction with parties that have ground water abstraction rights whom we considered might be affected by the proposed works. Parties were invited to comment on the potential effects of the project on ground water abstraction and on the project as a whole, including the preferred sites, tunnel route and alignment and the consultation process.

11.1.2 This section sets out the feedback received from Section 42 consultation in relation to potential effects on ground water abstraction. It also sets out the feedback from consultees that were not directly consulted on the potential effects on ground water abstraction but nonetheless made comments in this regard. This section is organised as follows:
a. b. c. d. e.
11.1.3
Section 11.2: Number of respondents Section 11.3: Effects on ground water abstraction Section 11.4: Feedback in relation to the preferred sites Section 11.5: Feedback in relation to the consultation process Section 11.6: Our view of the way forward.
11.1.4
139
11.2
11.2.1
Feedback in relation to ground water abstraction was received in a number of forms, including feedback forms and correspondence (emails and letters). A total of ten respondents provided responses to the ground water abstraction consultation, of which two were received after consultation had closed. The number of respondents in each group is set out in Table 11.1. The Royal Borough of Kensington and Chelsea was consulted in its capacity as a landowner, and as such is identified as a landowner in this part of the report. Table 11.1 Respondents to the ground water abstraction consultation
Respondent group Statutory consultees (SC) Local authorities (LA) Landowners (LO) Community consultees (CC) Petitions (PET) 0 Westminster City Council(WCC) 7 2 0 Number of respondents
11.3
11.3.1
Potential effects of the project on ground water abstraction

The supportive and neutral comments received in relation to ground water abstraction are set out in Table 11.2. The objections, issues and concerns and how we propose to address them are set out in Table 11.3.

Table 11.2 Supportive and neutral comments in relation to the potential effects of the project on ground water abstraction
Ref 11.3.2 11.3.3 Supportive and neutral comments No comment on ground water abstraction. Not qualified to comment on ground water abstraction; will accept the decision put forward 1 1 Total/ID number RBKC-LO 15008LO Our response Your comment is noted. The purpose of consultation is to explore as fully as possible what those with an interest in the project think
140

Ref Supportive and neutral comments by Thames Water. Total/ID number Our response about our proposals. We will have regard to comments received from both technical and non-technical consultees.

Table 11.3 Objections, issues and concerns in relation to the potential effects of the project on ground water abstraction
Ref 11.3.4 Objections, issues and concerns General concerns regarding the loss of borehole water supply to buildings, whether residential, commercial or other. Concerns regarding the effects on heating and hot water provided by Ground Source Heat pumps, specifically hot water and heating services provided to Sir Francis Drake Court, 43-45 Banning Street. Concerns regarding the effects on local business and building operations if ground water abstraction from local boreholes is limited. St Martin-in-the Fields Church holds a license to abstract water through its borehole for six months of the year to cool underground spaces, and a license to discharge water back into the aquifer. This system is important for the operation and sustainability of its buildings. Concerns regarding the potential effect on proposals for redevelopment: part of the Kirtling Street site also falls within the proposed Battersea Power Station redevelopment site, which has been granted planning consent for a mixed-use 1 Total/ID number WCC Our response Dewatering would be required around the central sections of the main tunnel in order to lower groundwater levels to enable the construction of shafts. Dewatering may lead to adverse effects on groundwater in these areas. In addition, dewatering the Thanet Sands formation, mobilising contaminants and mixing groundwater types in the central and eastern areas may lead to a deterioration in groundwater quality and give rise to adverse effects. The significance of these effects would be reduced by site-specific mitigation measures, such as ground treatment around shafts, lowering pumps at licensed sources to reduce effects on licence holders, and other remediation measures. Further information on the possible effects of the proposed de-watering activities and appropriate mitigation will be set out in the Environmental Statement for submission with the application. C C
11.3.5
15006LO
11.3.6
15002LO
11.3.7
15009LO
141

Ref Objections, issues and concerns development. Redevelopment is expected to take place from 2013 to 2018, which overlaps with the projects construction period (2015 to 2022). During the redevelopment of the Battersea Power Station site, the owner will carry out extensive construction and redevelopment activities and abstract water. The owner has two abstraction licenses from the Environment Agency, and is also investigating the use of ground source heat pumps/geothermal boreholes. Abstracting water via the borehole is a critical part of the energy and sustainability strategy for the development approved by the GLA and the London Borough of Wandsworth, and is an integral part of the environmentally sensitive development plan. Further information and/or modelling is required in relation to: a. evidence that water abstraction would be affected b. the length of time it would take for ground water levels to return to normal once the project works are complete c. details of the proposed compensation payable or alternative arrangements to negate the detrimental impact of the project on the Battersea Power Station development. 11.3.8 Network Rail railways, undertakings and land interests must be suitably protected. Protection from both temporary and permanent compulsory purchase powers will be sought. 1 NR-LO Your comments are noted. We will continue to discuss our proposals with Network Rail. N Total/ID number Our response C
142

Ref Objections, issues and concerns Network Rail is, however, willing to discuss the use of Network Rail land or rights over land, on the condition that there would be no impact on the operational railway, all regulatory and other required consents would be in place, and appropriate commercial and other terms would be approved by the Board of Network Rail. Concerns regarding the financial effects on local residents if required to use alternative mains water supplies, rather than boreholes. Query whether compensation will be payable. 1 Total/ID number Our response C
11.3.9
15003LO
We recognise that effects on ground water abstraction in certain locations may give rise to relevant compensation claims. Further details on our compensation programme are provided in A guide to the Thames Tunnel compensation programme, which is available on our website. We sent a letter to over 2,000 parties with ground water abstraction rights whom we considered might be affected by the proposed works. The letter provided contact details for a specialist adviser at the project, who was available to deal with queries and to provide further information. We are carrying out modelling of the predicted draw down effects of the proposed de-watering activities, which will be set out in the Environmental Statement for submission with the application. Appropriate mitigation will be considered where any significant adverse effects are predicted.
11.3.10
Thames Water has provided insufficient information on ground water abstraction for respondents to understand the scale of any likely effects and/or to comment on the proposals. Further information is requested in relation to how long and where abstraction from boreholes would be affected/prevented. Request a full assessment of the scale and duration of the potential effects of dewatering on ground source heat pumps. The assessment should include details of proposed mitigation measures, compensation and proposals to ensure that heating and hot water would not be interrupted during construction (if it proves necessary to interrupt supply, either temporarily or permanently).
15003LO, NR-LO
11.3.11
15006LO
143
11.4
11.4.1
The preferred sites

This section sets out the ground water abstraction consultation feedback in relation to the preferred sites. Comments were received on the following sites:
a. b. c. d.
Kirtling Street Victoria Embankment Foreshore Beckton Sewage Treatment Works Jews Row.
11.4.2
The supportive and neutral comments are set out in Table 11.4. The objections, issues and concerns and how we propose to address them are set out in Table 11.5. The feedback is grouped first by site (as denoted by the sub-headings shaded in blue) and secondly by theme (as denoted by the sub-headings shaded in orange).

Table 11.4 Supportive and neutral comments in relation to the preferred sites
Ref Site selection 11.4.3 Dont know/unsure whether Victoria Embankment Foreshore should be the preferred site. 1 15002LO Your comment is noted. Supportive and neutral comments Total/ID number Our response Victoria Embankment Foreshore
Identification of key issues during construction in the phase two consultation Victoria Embankment Foreshore site information paper and measures to address them 11.4.4 Dont know/unsure whether the right key issues associated with construction at the site and measures to address them were identified in the phase two consultation Victoria Embankment Foreshore site information paper. 1 15002LO Your comment is noted.
144

Ref 11.4.5 Supportive and neutral comments Dont know/unsure whether the right site-specific issues that influence the permanent design for the site were identified. 1 Total/ID number 15002LO Our response Your comment is noted.
Permanent design and appearance of the site
Identification of key issues associated with the operational site in the phase two consultation Victoria Embankment Foreshore site information paper and measures to address them 11.4.6 Dont know/unsure whether the right key issues associated with the operational site and measures to address them were identified in the phase two consultation Victoria Embankment Foreshore site information paper. 1 15002LO Your comment is noted.
Beckton Sewage Treatment Works Identification of key issues associated with construction at the site in the phase two consultation Beckton Sewage Treatment Works site information paper and measures to address them 11.4.7 Agree that the right key issues associated with 1 construction at the site and measures to address them were identified in the phase two consultation Beckton Sewage Treatment Works site information paper. 1 15008LO Your comment is noted and welcomed.
Jews Row 11.4.8 Not qualified to dispute Thames Waters proposals.
15008LO
The purpose of consultation is to explore as fully as possible what those with an interest in the project think about our proposals. We will have regard to comments received from both technical and non-technical consultees.
145

Table 11.5 Objections, issues and concerns in relation to the preferred sites
Ref Kirtling Street Site selection 11.4.9 Opposed to the use of this site: Battersea Power Station has planning permission for redevelopment and the project should avoid sites that have been allocated for, are known to be awaiting, or have received planning permission for redevelopment. 1 LR15009 We took account of the planning status of sites along with a range of other considerations in the site selection process (see the Site selection methodology paper). We exercised our planning teams professional judgement to assess the potential impact on the planning status of each site. It should be noted that allocated or approved planning permissions do not preclude the use of sites. Where a planning permission would be implemented, it may still be possible to phase construction work in order to construct both the approved development and the project. Designated regeneration areas do not necessarily preclude the use of sites as, in many cases, our proposed use may be complementary or beneficial to some of the regeneration aims. In this case, while the use of the Kirtling Street site to construct the tunnel would render it unavailable for redevelopment in the short term, on completion of our works it could be redeveloped in line with its allocation and planning consent. The proposed permanent structures on the Kirtling Street site were designed and positioned to ensure that the majority of the site allocated for mixed-use redevelopment would not be permanently affected. We understand that the elements of the planning N Objections, issues and concerns Total/ID number Our response C
146

Ref Objections, issues and concerns Total/ID number Our response consent for Battersea Power Station that affect part of our preferred site are only required in the latter phases of the overall scheme. We believe that the construction timescales of both developments are complementary and could accommodate our temporary use. For further details on the site selection process at this site, see Appendix L of the Section 48: Report on site selection process. The sites consulted on at phase two consultation were identified through an extensive site selection process (see the Site selection methodology paper on our website). We consulted on and agreed the methodology with key stakeholders, including potentially directly affected local authorities. We utilised a multidisciplinary approach to assess potential main tunnel drive sites, having regard to engineering, planning, environmental, property and community considerations and our teams professional judgement. All the assessments were based on the information available at the time and the related stage in the projects development. We recognise that, given the locations in which we are seeking to construct and operate the tunnel, many of the shortlisted sites are constrained. However, based on our assessment we consider that, on balance, Kirtling Street is the most suitable site. This is because it is brownfield land in a predominantly industrial area. Furthermore, and in part due to the proposed regeneration of the area, it has greater potential to accommodate main tunnel double drive tunnelling activities than other areas. It also has good access to the river in order to C
11.4.10
Request for further information regarding the rationale for preferring this site, including choosing it over other options such as Battersea Park and New Covent Garden Market.
LR15009
147

Ref Objections, issues and concerns Total/ID number Our response transport excavated materials by barge and vehicular access directly from Nine Elms Lane (A3205). Unlike many of the shortlisted sites, use of this site would avoid the need to cross Nine Elms Lane in order to access the River Thames. Distance from the River Thames was one of the main reasons why the New Covent Garden Market site did not progress through the site selection process. Moreover, use of the preferred site would avoid the loss of greenfield land at Battersea Park (a Grade II* registered park and garden) and effects on listed buildings at Battersea Power Station. Additionally, Cringle Wharf is a safeguarded wharf and our proposed use would be consistent with this designation. Importantly, the main shaft could be located adjacent to the river, which would reduce the likelihood of the main tunnel alignment passing under any significant buildings. Although a section of the site forms part of the Battersea Power Station redevelopment proposals, it is required for the later phases of the development. We believe that the timescales for the works for both developments are complementary. Finally, it appears likely that use of the Kirtling Street site would cause less disruption to residents of Elm Quay than at other sites considered. For further details on the site selection process, including our assessment of the shortlisted sites, see Appendix L of the Section 48: Report on site selection process. C
148

Ref Alternative sites 11.4.11 Another shortlisted site is more suitable: a. Shortlisted site 1 Battersea Park is more suitable because it is a large open space that would not affect existing development proposals in Nine Elms, and would avoid undue interference with public access and use. There is also better scope to retain the permanent structures to access and operate the main tunnel without interfering with longterm development plans for Nine Elms. 1 LR15009 We consider that this shortlisted site could be suitable as a main tunnel site; however, it was less suitable than our preferred site for the following reasons. Battersea Park is a Grade II* registered park and garden. Use of this site would lead to a temporary loss of an area of public open space that is well used and valued by the local community and visitors. It would also conflict with a number of planning policies. There would potentially be adverse effects on heritage features, landscape, ecology, townscape, and archaeology. The permanent above-ground structures would also be less suitable in this location. Shortlisted site 4 is our preferred site to intercept the Heathwall Pumping Station and South East Storm Relief CSOs. At phase one consultation, we proposed to use this site as a main tunnel drive site and to intercept the two CSOs in conjunction with the adjacent S79 Tideway Walk site. However, the Tideway Walk site became unavailable due to permission for a residential development. Demolition work had commenced on-site. The Heathwall Pumping Station site is not large enough on its own to accommodate a main tunnel site. The site selection back-check process identified Kirtling Street as our preferred main tunnel site at phase two consultation and Heathwall Pumping Station as our preferred site to intercept the two CSOs. For the purposes of the back-check, the Heathwall N Objections, issues and concerns Total/ID number Our response C
11.4.12
b. Shortlisted site 4 Heathwall Pumping Station and Middle Wharf should be used because it is close to the River Thames and follows the preferred route. It would be suitable if used in conjunction with shortlisted site 6.
LR15009
149

Ref Objections, issues and concerns Total/ID number Our response Pumping Station site was assessed as a potential split main tunnel drive site in conjunction with either S86WH Post Office, Nine Elms Lane or S94WH Post Office Way. Neither option was preferred for a number of reasons, but principally due to the fact that the route to the river for the removal of excavated material would be more difficult than at sites immediately adjacent to the River Thames. This site was not preferred as it is further from the River Thames; the main tunnel route would have to divert inland and potentially pass under built-up areas and Battersea Power Station. The site does not have direct river access therefore excavated materials would need to be transported over Nine Elms Lane (A3205) on overhead conveyors. There is also a strong possibility that this site is contaminated due to its former use as part of Nine Elms Gas Works. The New Covent Garden Market site was ruled out at the long list to draft short-list site selection assessment, predominantly due to its distance from the River Thames. This site would also require the main tunnel to divert inland and potentially pass under built-up areas. Furthermore, it does not have direct river access therefore excavated materials would need to be transported over Nine Elms Lane (A3205) on overhead conveyors. C
11.4.13
c. Shortlisted site 5 Post Office Nine Elms should be used because it is less advanced in terms of planning than the preferred site.
LR15009
11.4.14
New Covent Garden Market should be used instead of the preferred site.
LR15009
Identification of key issues during construction in the phase two consultation Kirtling Street site information paper and measures to address them 11.4.15 Do not agree that the right key issues 1 LR15009 The purpose of the key issues in the Kirtling Street N
150

Ref Objections, issues and concerns associated with construction at the site and measures to address them were identified in the phase two consultation Kirtling Street site information paper. Total/ID number Our response site information paper and measures proposed to address them was to provide a broad overview of likely significant effects associated with the site during construction. It is not, however, an exhaustive list. A more detailed description of likely significant effects and the methodology to identify and assess them is provided in other technical reports, including the PEIR (Volume 17), the Phase two scheme development report, the Site selection methodology paper and the Site selection background technical paper. We are carrying out an environmental impact assessment, which will include a comprehensive study of likely significant effects arising from the proposals and measures to address them. The findings of the assessment, together with any recommendations for mitigation, will be provided in the Environmental Statement for submission with the application. The proposed layout of the construction site was informed by the size of the functional infrastructure, the necessary construction methods and the location of neighbouring buildings and structures. All these elements were developed to minimise effects on the local community and the environment. Particular factors at this site included: a. We considered the relationship with neighbouring developments, the potential effects on the local highway network, and river access to nearby wharves. b. The site layout would enable the continued use of C
Construction site design and layout 11.4.16 Thames Water has not considered the most efficient use of the preferred site or sufficient options for removing some construction functions off-site (for example car parking and maintenance facilities). 1 LR15009 N
151

Ref Objections, issues and concerns Total/ID number Our response the concrete batching works or the batching works could be removed. We consider that consolidating the construction site into one area is more efficient than locating certain elements off-site. The internal construction site layouts illustrated in the Kirtling Street site information paper at phase two consultation are for illustrative purposes only. The contractor may arrange the layout within the boundary in a different way, depending on the chosen construction methods, and provided that any environmental effects are appropriately managed. We will consider opportunities to integrate our works with other projects in the local area and will continue to liaise with the developers and the London Borough of Wandsworth. Planning and development during construction 11.4.17 Thames Water has not taken account of the full extent of the effect of project construction on the construction activities at the Battersea Power Station site during the same period, including construction of the Northern Line Extension. The project has also failed to take account of the planned regeneration in the wider Nine Elms area in the same period. This includes Royal Mail, Embassy Gardens, US Embassy, Riverlight, New Covent Garden Market, Marco Polo House, Sainsburys and, in particular, the cumulative effects on vehicle and barge movements in the area. 1 LR15009 We recognise that much of the site is allocated for a mixed-use development and that it falls within the wider Vauxhall/Nine Elms/Battersea Opportunity Area. In preparing this policy and determining subsequent planning applications in the local area, the local authority has had regard to the projects requirements. Furthermore, we note that a safeguarding direction has been issued in respect of this site by the Secretary of State, which reflects the Governments commitment to delivering the project in line with the Waste Water NPS. Although the use of this site during construction would preclude it from redevelopment in the short term, the site could be redeveloped in line with its allocation on completion of the project works. The N C
152

Ref Objections, issues and concerns Total/ID number Our response design and location of our permanent structures on Kirtling Wharf were agreed with the operator to ensure that the majority of the site allocated for mixed-use redevelopment would not be permanently affected. We are also aware that part of the site is subject to a planning permission for a mixed-use redevelopment as part of the wider Battersea Power Station redevelopment. We understand that the proposals that affect our site are only required during the latter phases of the overall scheme. We believe that the timescales of the developments are complementary and could accommodate our temporary use. Our methodology for assessing the cumulative effects of developments in the local area complies with the Infrastructure Planning (Environmental Impact Assessment) Regulations 2009. We took account of applications that had been referred to the GLA to identify schemes in the local area for inclusion in the assessment, in line with the Planning Inspectorates Advice Note Nine. The PEIR (Volume 17, Section 2) describes any relevant developments that will be taken into consideration at Kirtling Street. This includes the regeneration of the wider Nine Elms area, the redevelopment of Battersea Power Station, the Northern Line Extension, the Post Office Depot, Embassy Gardens, the US Embassy, the Riverlight development, New Covent Garden Market, Marco Polo and Nine Elms Sainsburys. The assessments will consider the cumulative effects of these developments with the project where the construction programmes overlap. C
153

Ref Objections, issues and concerns Total/ID number Our response We will continue to monitor proposed developments in the local area and any cumulative effects will be reported in the Environmental Statement for submission with the application. In relation to vehicle and barge movements, the Transport Assessment makes use of TfL strategic traffic models that take account of future growth and development across London. The Settlement project information paper provides information on our approach to controlling and limiting ground movement, which can cause settlement, associated with construction of the tunnel. We acknowledge that construction of the tunnel would cause some small movements in the ground, the level of which would depend on a range of factors including the size and depth of the construction works and the existing ground conditions. The use of modern tunnelling methods and the depth of our tunnels, which are generally much deeper than most other tunnels under London, would minimise the likelihood of ground movement. We are carrying out an assessment of the potential effects of ground movement in advance of the works and, where necessary, we would carry out protective measures. We would monitor actual ground movement during and after the tunnelling to check that the ground is reacting as predicted. We would also carry out a defects survey on buildings located over, or close to, the tunnels and worksites where necessary. The method of assessing settlement is similar to that used for the Channel Tunnel Rail Link, C
Structures and utilities during construction 11.4.18 Further information is required regarding possible ground movement and how this would impact on proposals for the redevelopment of the Battersea Power Station site. 1 LR15009 N
154

Ref Objections, issues and concerns Total/ID number Our response the Jubilee Line Extension, and Crossrail. In the unlikely event of damage to property due to our construction works, disturbance compensation may be available (see A guide to the Thames Tunnel compensation programme). Transport was one factor considered as part of the site selection process. For further information on the site selection methodology, refer to the Site selection methodology paper. For further information on how transport matters were considered in relation to Kirtling Street, refer to Appendix L of the Section 48: Report on site selection process. We published a Transport strategy at Section 48 publicity, which states that at this site we propose to transport the following materials by barge: main tunnel excavated material (export), cofferdam fill material (import/export), and sand and aggregates for main tunnel secondary lining (import). We are carrying out a Transport Assessment for submission with the application, which assumes that a minimum of 90 per cent of these materials would be transported by river. This allows some flexibility to use road transport where river transport is unavailable or for material that is unsuitable for river transport, such as excessively wet spoil or contaminated materials. We intend to incentivise our contractor to move as much material by river as practical with the aim of achieving 100 per cent river transport. The Section 48: Project description and environmental information report (para. 13.2.7) C
Transport and access during construction 11.4.19 Thames Water has not considered the effect of using Kirtling Street as an access and transport route to the preferred site, and how this would affect the Battersea Power Station site owner's access along the same route. Request for further information regarding traffic management proposals and how these were taken into account in the site selection process. 1 LR15009 N
155

Ref Objections, issues and concerns Total/ID number Our response states that vehicle access to the site during construction would be via three access points, two off Cringle Street and one off Kirtling Street. Vehicles would travel to and from Nine Elms Lane as illustrated in the construction phasing plans for this site (see Section 13 of the Section 48: Book of plans). The northern arm of Kirtling Street would be closed to the public during construction in order to provide an internal site access road. We are reviewing the proposed routes for construction traffic for the Transport Assessment, which will also assess cumulative transport effects of traffic associated with other developments in the local area. We agreed which developments to assess in the transport modelling with TfL and local highways authorities. We will develop mitigation measures to minimise any likely significant effects arising from congestion identified in the Transport Assessment, which may include transporting the majority of materials in and out of the site during non-peak periods. The CoCP for submission with the application will include a requirement for a Traffic Management Plan to carefully control construction traffic in order to minimise any potential effects on the road network, residential amenity or access to the local area. The CoCP will also set out construction traffic routes, site access/egress points, signage and monitoring procedures. We did not undertake a navigational risk assessment as part of the site selection process. We did, however, consider transport effects as part of our assessment. For further information on how transport C
11.4.20
Request confirmation that the navigational risk assessment in the site selection process took account of vehicle and barge movements from the Battersea Power Station site during its
LR15009
156

Ref Objections, issues and concerns redevelopment, including spoil removal from the Northern Line Extension. Total/ID number Our response matters were considered in relation to Kirtling Street, refer to Appendix L of the Section 48: Report on site selection process. We are preparing a Navigational Risk Assessment for submission with the application. Our approach to this assessment is under discussion with the PLA (the body responsible for regulating the use of the River Thames in London). The assessment will consider existing river traffic but exclude unknowns such as use of the River Thames for the redevelopment of Battersea Power Station and the Northern Line Extension. We have also discussed the use of the river for transporting materials with the PLA. Details of our proposals in this regard are set out at para. 11.4.19. Discussions to date concluded that our proposals would not have a detrimental effect on river navigation or commercial or leisure river users. We will amend our proposals or provide appropriate mitigation in agreement with the PLA to address any adverse effects on navigational safety. We are reviewing the proposed construction traffic routes for the Transport Assessment, which will also assess cumulative transport effects of traffic associated with other developments in the local area. We agreed which developments to assess in the transport modelling with TfL and the local highways authorities, including Battersea Power Station and the Northern Line Extension. We will develop mitigation measures to minimise any likely significant effects arising from congestion identified in the Transport Assessment. C
157

Ref 11.4.21 Objections, issues and concerns Do not agree that the right site-specific issues that influence the permanent design for the site were identified in the phase two consultation Kirtling Street site information paper. 1 Total/ID number LR15009 Our response Our view of the most significant site-specific issues in relation to the permanent design for the site is set out in the Kirtling Street site information paper. It is not, however, an exhaustive list, and further potential issues associated with the site are set out in the PEIR (Volume 13), the Design development report, the Phase two scheme development report, the Site selection methodology paper and the Site selection background technical paper. We are carrying out an environmental impact assessment that will include a comprehensive assessment of likely significant effects arising from the proposals. The findings of the assessment, together with any recommendations for mitigation, will be provided in the Environmental Statement for submission with the application. We positioned our main tunnel site to optimise critical engineering requirements and to avoid compromising the future redevelopment of the site. A combined ventilation structure between 4m and 6m high comprising a ventilation column and an electrical and control kiosk would be positioned on the existing concrete batching works site on the RMC Battersea (Metro Graham) safeguarded wharf, adjacent to the River Thames. This location avoids the need to move the main tunnel alignment inland where it would pass beneath more existing thirdparty infrastructure. The layout of the shaft and permanent structures was designed to minimise impacts on the regeneration of the wider area and should not preclude the use of the RMC Battersea C N
Permanent design and appearance of the site
11.4.22 11.4.23
Do not support the proposals for the permanent design and appearance of the site.
LR15009 LR15009
N N
Thames Water has not taken the Battersea 1 Power Station site owner's plans into consideration in determining the permanent design for the site. A permanent ventilation shaft on the site and the associated permanent access rights, together with the possible relocation of the Thames Path along the riverfront would significantly affect the consented redevelopment of the Battersea Power Station site.
158

Ref Objections, issues and concerns Total/ID number Our response (Metro Graham) wharf as an operational wharf in the future. Furthermore, consolidating the permanent structures along the western boundary of the site reduces the overall footprint of the permanent works on the safeguarded wharf. The remainder of our site is not required for the operational phase and would be available for redevelopment. Our permanent structures would be positioned to enable the future extension of the Thames Path along the sites riverfront. However, we do not propose to implement the Thames Path in front of Kirtling Wharf because it is currently an operational wharf. Any further improvements or realignments of the Thames Path would be undertaken as part of future development in the area. Appendix L of the Design development report provides further information on the site-specific considerations and principles that informed our proposals for this site. The layout of the shaft and permanent structures on the CEMEX site were designed to enable the site to be used as an operational wharf on completion of the project works. The above-ground permanent structures were consolidated along the western boundary of the site to minimise their footprint and leave the majority of the site available for redevelopment. The area above the shaft could also be used for storage and vehicle parking uses, provided that such could be removed at short notice for emergency Thames Water access. Access to the above-ground structures and access covers of the shaft would also be required periodically for routine inspections and maintenance. C
11.4.24
Further information is required regarding what is left of the CEMEX site and the preferred site in terms of what is developable and what is sterile.
LR15009
159

Ref Objections, issues and concerns Total/ID number Our response We anticipate that the whole of the Battersea Power Station site would be available for redevelopment on completion of the project works. No permanent infrastructure would remain on the Battersea Power Station site on completion of the project works. C
11.4.25
Thames Water has not identified how the Battersea Power Station site owner would be affected in terms of future additional approvals/costs as a result of the permanent project infrastructure that would remain on-site.
LR15009
Identification of key issues associated with the operational site in the phase two consultation Kirtling Street site information paper and measures to address them 11.4.26 Do not agree that the right key issues associated with the operational site and measures to address them were identified in the phase two consultation Kirtling Street site information paper. 1 LR15009 The purpose of the key issues in the Kirtling Street site information paper and the measures proposed to address them was to provide a broad overview of likely significant effects associated with the operational site. It is not, however, an exhaustive list. A more detailed description of likely significant effects and the methodology used to identify and assess them is provided in other technical reports, including the PEIR (Volume 17), the Phase two scheme development report, the Site selection methodology paper and the Site selection background technical paper. We are carrying out an environmental impact assessment that will include a comprehensive assessment of likely significant effects arising from the proposals. The findings of the assessment, together with any recommendations for mitigation, will be provided in the Environmental Statement for N
160

Ref Objections, issues and concerns Total/ID number Our response submission with the application. Our site access proposals reflect the projects requirements only. However, our proposals do not prevent access to the Battersea Power Station Site along Kirtling Street. We are carrying out transport modelling of the area, which will be included in the Environmental Statement for submission with the application and will incorporate traffic figures for future growth and new developments in the area, including the Battersea Power Station development. Permanent vehicular access to the site would be via Kirtling Street. Once the project is operational, Thames Water would need to access the site occasionally for inspection and maintenance purposes. We anticipate that personnel would visit the site approximately every three to six months to inspect and maintain the ventilation equipment. This would likely involve a small van and may take several hours. Once every ten years, a major internal inspection of the tunnel and underground structures would be carried out. This would likely involve a small team of inspection staff and support crew and two mobile cranes to lower the team and inspection vehicle into the shaft. This would likely take several weeks and require temporary fencing around the shaft for safety and security reasons. Thames Water may also need to visit the site for unplanned maintenance or repairs, for example in the event of a blockage or equipment failure. This C
Transport and access during operation 11.4.27 Request confirmation that the road changes shown on the diagrams comply with the approved S278 highway works associated with the redevelopment of Battersea Power Station. 1 LR15009 N
11.4.28
Request clarification of the permanent access requirements to the ventilation shafts and how they would affect the proposed redevelopment of Battersea Power Station. Not enough information has been provided on how Thames Water would access and operate the tunnel in the future, and the effect it would have on current plans for the redevelopment of Battersea Power Station.
LR15009
161

Ref Objections, issues and concerns Total/ID number Our response may require the use of mobile cranes and vans. C
Victoria Embankment Foreshore Structures and utilities 11.4.29 Concerns regarding the risk of subsidence. 1 15002LO The Settlement project information paper at phase two consultation sets out our approach to controlling and limiting ground movement, which can cause settlement, associated with construction of the tunnel. We acknowledge that construction of the tunnel would cause some small movements in the ground, the level of which would depend on a range of factors including the size and depth of the works and the existing ground conditions. The use of modern tunnelling methods and the depth of our tunnels, which are generally much deeper than most other tunnels under London, would minimise the likelihood of any potential ground movement. We are carrying out an assessment of the potential effects of ground movement in advance of the works and, where necessary, we would carry out protective measures. We would monitor actual ground movement during and after tunnelling to check that the ground is reacting as predicted. We would also carry out a defects survey on buildings located over, or close to, the tunnels and worksites where necessary. Our method of assessing settlement is similar to that used for the Channel Tunnel Rail Link, the Jubilee Line Extension, and Crossrail. In the unlikely event of damage to property due to our construction works, disturbance compensation may be available (see A guide to the Thames Tunnel compensation programme). N
162

Ref 11.4.30 Objections, issues and concerns Concerns regarding general disruption to utility services. 1 Total/ID number 15002LO Our response Any utilities close to or within our sites would be surveyed prior to and protected during construction. The presence of utilities would not preclude development at this site. We will continue to hold detailed discussions with the City of Westminster in this regard. We do not anticipate that our construction works would have any effect on access to Trafalgar Square. Construction traffic would access the site along the westbound carriageway of Victoria Embankment (A3211) and the major road network beyond. The PEIR (Volume 20, Section 12) included a preliminary assessment of the construction transport effects on pedestrian and cycle routes; bus and other public transport routes and patronage; parking; and highway layout, operation and capacity. As part of the assessment we considered the effects of lorry and (where applicable) barge transport, based on a methodology that was discussed and agreed with the City of Westminster and TfL. The PEIR was available at phase two consultation. An addendum to the PEIR was produced at post phase two consultation, which concluded that the amendments to the proposals at this site would not materially alter the conclusions of the PEIR. See the PEIR Addendum (Volume 20, Section 3) for further details of the assessment. We are preparing a full Transport Assessment for submission with the application, which will consider the cumulative effects of our works and other C N
Transport and access 11.4.31 Concerns regarding the potential effect of construction activities on general access to Trafalgar Square. 1 15002LO N
163

Ref Objections, issues and concerns Total/ID number Our response strategic developments in the local area. C
11.5
11.5.1
Tunnel route and alignment

This section sets out the Section 42 consultation feedback in relation to modifications to the tunnel route and alignment. The supportive and neutral comments are set out in Table 11.6 and are grouped by theme, as denoted by the sub-headings shaded in blue.

Table 11.6 Supportive and neutral comments in relation to the tunnel route and alignment
Ref Supportive and neutral comments 1 Total/ID number 15002LO, 15008LO, LR15009 15002LO, LR15009 Our response Your comment is noted. Preferred route 11.5.2 No comment on the preferred tunnel route.
Tunnel alignment 11.5.3 No comment on the proposed tunnel alignment.
Your comment is noted.

11.5.4 We received no objections, issues or concerns in relation to the tunnel route and alignment.
11.6
11.6.1
Consultation process
This section sets out the Section 42 consultation feedback in relation to the consultation process. The supportive and neutral comments are set out in Table 11.7. The objections, issues and concerns and how we propose to address them are set out in Table 11.8. The feedback is grouped by theme, as denoted by the sub-headings shaded in blue.
164

Table 11.7 Supportive and neutral comments in relation to the consultation process
Ref Supportive and neutral comments 2 2 2 Total/ID number 15002LO, LR15009 15003LO, 15008LO 15002LO, LR15009 15002LO, LR15009 Our response Previous consultation activities 11.6.2 The identified respondents took part in previous project consultation activities. 11.6.3 The identified respondents did not take part in previous project consultation activities. 11.6.4 The identified respondents attended a drop-in session or other meeting at which a member of the project team was present. 11.6.5 The identified respondents took part in previous project consultation activities including: a. meeting with a member of the project team (June 2012) b. submitting a written letter of objection. 11.6.6 Respondents were provided with sufficient material to enable them to respond to the consultation. 2 15002LO, 15008LO Your comments are noted and welcomed.
Other comments in relation to the consultation process 11.6.7 No further comments on the consultation 3 process.
15002LO, 15008LO, LR15009
Your comments are noted.
165

Table 11.8 Objections, issues and concerns in relation to the consultation process
Ref 11.6.8 Objections, issues and concerns Respondents were not provided with sufficient material to enable them to respond to the consultation. 2 Total/ID number 15003LO, LR15009 Our response C At each phase of consultation, we tailored the N published materials to ensure that sufficient information was provided to enable consultees to respond to the consultation. Our approach to consultation material was to make information available to members of the community in an accessible form and to provide detailed technical information to technical consultees. This is consistent with pre-application consultation guidance provided by the DCLG. The projects live consultation website contains links to all documents made available at each stage of consultation and our consultation reports, and this was available to all ground water abstraction consultees. We do not anticipate that the project would have significant effects on ground water abstraction that would give rise to relevant compensation claims. However, in the event that such effects did occur, relevant claims might arise. We will continue to discuss our proposals with potentially affected parties to understand the possible effects. Further details in relation to our compensation programme are provided in A guide to the Thames Tunnel compensation programme (available on our website). We do not believe that there would be any detrimental effect (see paras. 11.4.9, 11.4.11, N
11.6.9
Further information requested in relation to: a. where and for how long abstraction from boreholes would be affected/prevented, and whether any compensation would be payable
15003LO, LR15009
b. the effects of construction activities and the proposed permanent design and layout of the Kirtling Street site on the redevelopment
166

Ref Objections, issues and concerns proposals for Battersea Power Station and the wider Nine Elms area. Total/ID number Our response 11.4.17, 11.4.18 and 11.4.19). C
11.7
11.7.1

We received a range of feedback in relation to potential effects of the project on ground water abstraction and on the project as a whole, including supportive and neutral comments as well as objections, issues and concerns. We took account of all the feedback received in accordance with the requirements of the 2008 Act. We received no feedback at the Section 42 ground water abstraction consultation that would lead us to change our proposals. Accordingly, the proposed project remained the same at Section 48 publicity.
11.7.2
167
12 Other comments
12
12.1
12.1.1 12.1.2
Other comments
Introduction
In response to the post phase two consultation, we received some feedback that was not directly related to the scope of the consultation (as described at 3.4). This feedback is set out in this section along with our responses. This section is organised as listed below:
a. b. c. d. e. f.
Section 12.2: Number of respondents Section 12.3: Feedback in relation to project-wide themes Section 12.4: Other comments Section 12.5: Feedback in relation to our preferred sites Section12.6: Our view of the way forward. Section 12.7: Feedback in relation to our approach to consultation
12.1.3
In Sections 12.3 to 12.5 and 12.7, we detail the groups and total number of respondents, the comments received and the projects response.
12.2
12.2.1
A total of 58 respondents provided feedback in relation to other issues at post phase two consultation, of which five responded after consultation had closed. The number of respondents in each group is set out in Table 12.1.
168
12 Other comments Table 12.1 Respondents that provided other comments at post phase two consultation
Respondent group Statutory consultees (SC) Local authorities (LA) Landowners (LO) Community consultees (CC) Petitions (PET) 6 2 7 42 1 with 54 signatories Number of respondents
12.2.2
Table 12.2 sets out the statutory consultees and local authorities that provided feedback. Table 12.2 Statutory consultees and local authorities that provided other comments at post phase two consultation
Statutory consultees Marine Management Organisation (MMO) UK Power networks (IDNO) Ltd Design Council CABE (CABE) Transport for London (TfL) Port of London Authority (PLA) Local authorities English Heritage (EH) London Borough of Hackney (LBH) London Borough of Wandsworth (LBW)
12.2.3
The feedback was received in a number of formats, including feedback forms and correspondence (emails and letters).
12.3
12.3.1
Feedback in relation to project-wide themes

The supportive and neutral comments and objections, issues and concerns(and how we propose to address them) received at post phase two consultation in relation to project-wide themes are set out in Table 12.3. The themes are
169
12 Other comments denoted by sub-headings shaded in blue, and the orange sub-headings categorise the feedback as supportive and neutral comments or objections, issues and concerns. Table 12.3 Feedback in relation to project-wide themes
Ref Comments Total/ID number Our response Need to reduce the amount of sewage entering the River Thames Supportive and neutral comments 12.3.2 General support for the project. 1 14057 Your comments are noted and welcomed. The primary purpose of the proposed works is to reduce the amount of untreated wastewater that is discharged into the tidal Thames and to improve river water quality in order to meet legal requirements. The improved river will have benefits for residents, visitors, business and wildlife. The need for a full-length storage tunnel solution is set out in the Needs Report (available on the projects consultation website). The Waste Water NPS, which was designated on 26 March 2012, clearly states that the need for the project has been demonstrated. It concludes that detailed investigations have confirmed the case for a Thames Tunnel as the preferred solution. The NPS was supported by an Appraisal of Sustainability Post-Adoption Statement, which contains further detail on the significant amount of work undertaken to establish the need for the project and assess alternatives. As stated in the Route and tunnel alignment project information paper, the Abbey Mills route remains our preferred route because: it is the shortest route; it is the least disruptive and most cost-effective option, costing 20 per cent less than the other two options, while still meeting all the required environmental objectives; it requires the least number of worksites; and it requires less tunnelling at
Qualified support 12.3.3 Agree with the need to reduce the amount of sewage entering the River Thames, but disagree/concerned with the proposed solution/route/sites. 1 14050
170
12 Other comments
Ref Comments Total/ID number Our response depth through Chalk in the east. Deep tunnelling through Chalk is potentially more difficult and creates greater health and safety issues. The proposed sites that we consulted on at phase two and post phase two consultation were identified through an extensive site selection process (see the Site selection methodology paper on our website). We consulted on and agreed the methodology with key stakeholders, including potentially directly affected local authorities. We used a multidisciplinary approach to assess potential CSO sites and main tunnel/connection tunnel drive options, having regard to engineering, planning, environmental, property and community considerations. We recognise that, given the locations in which we are seeking to construct and operate the tunnel, many of the shortlisted sites are constrained in some way. However, based on our assessments to date, we consider that, on balance, the preferred sites presented at phase two and post phase two consultation are the most suitable (see the Section 48: Report on site selection process). We are carrying out an assessment of the likely significant effects of the works as part of the environmental impact assessment, which will set out necessary measures to mitigate any significant adverse effects identified. The assessment further develops the mitigation proposals set out in the draft CoCP and will inform the CoCP for submission with the application. The findings of the assessment will be provided in the Environmental Statement for submission with the application. Our initial environmental assessment work is set out in the PEIR and PEIR Addendum, which are available on our website. The Section 48: Project description and environmental information report provides limited environmental
12.3.4
Agree with the need to reduce the amount of sewage entering the River Thames, but concerned about the effects that will arise from addressing the problem.
14049
171
12 Other comments
Ref Comments Total/ID number Our response information to assist stakeholders to understand the nature and location of the proposed development.
A tunnel as the right solution Supportive and neutral comments 12.3.5 The tunnel would deliver greatest improvements to water quality. 1 14012 We agree. Analysis was carried out as part of the Thames Tideway Strategic Study (TTSS) and subsequent studies, which demonstrated that a storage and transfer tunnel option, combined with improvements at sewage treatment works, would have the highest net benefits including improvements to river water quality and other environmental benefits. A tunnel would also cause less disruption than other alternatives investigated and offers a solution for at least the next 100 years. This work informed the Ministerial Statement of March 2007 and the Governments request for Thames Water to develop a tunnel solution. The Government also recently published a report entitled Creating a River Thames fit for our future: A strategic and economic case for the Thames Tunnel. This report updates the 2007 regulatory impact assessment and takes account of data that has emerged since that time. It concludes that a tunnel solution remains the most appropriate and cost-effective solution considered. See our response at para. 12.3.3for details on the Waste Water NPS, which confirms the need for the project. Your comment is noted and welcomed. We are carrying out an assessment of the likely significant effects of the works as part of the environmental impact assessment, which will set out necessary measures to
12.3.6 12.3.7
The tunnel would create regeneration benefits. Agree that a tunnel is the right solution but concerned about the impact of the project during construction.
1 4
14012 14027, 14115, 14145, 14049
Qualified support
172
12 Other comments
Ref 12.3.8 Comments Support the project but concerned about the effect on business. 1 Total/ID number 14006LO Our response mitigate any significant adverse effects identified. The findings of the assessment will be provided in the Environmental Statement for submission with the application. Our initial environmental assessment work is set out in the PEIR and PEIR Addendum, which are available on our website. The Section 48: Project description and environmental information report includes limited environmental information to assist stakeholders to understand the nature and location of the proposed development. The programming of works at all sites would be configured to minimise the duration of works and associated disruption as far as possible. The length of the construction period stated in the consultation documents comes from the PEIR/PEIR Addendum. We expect that, in many cases, there will be periods during which there would be no or less intensive activity on some sites. We intend to use the river to remove excavated materials as much as possible, where it is practical and cost-effective to do so. It should be noted that some materials must be transported by road. However, we will seek to reduce the potential for significant effects on local roads and residents, having regard to relevant policies in the London Plan and the Waste Water NPS. This aim is reflected in the phase two consultation materials, specifically the site information papers, which set out the proposed logistics strategy for each preferred site. The Transport project information paper provides a more strategic overview of our proposals. We published our Section 48: Transport strategy at Section 48 publicity, which increased our commitment to river transport since phase two consultation resulting in 40,000 fewer predicted lorry movements. We are also carrying out a Transport Assessment for
12.3.9 12.3.10
Construction traffic associated with the project should focus on river transport.
14012 14005
Support the project but opposed to any aspect of 1 construction that fails to use the river as the sole means of transport for all construction and excavated materials.
173
12 Other comments
Ref Comments Total/ID number Our response submission with the application, which will identify any mitigation measures required to minimise disruption caused by construction traffic. Our initial studies in this regard are provided in the PEIR/PEIR Addendum, which are available on our website. Investigation and analysis of strategic solutions to the problem of CSO discharges into the tidal Thames began in 2000. The need for the project is set out in detail in the Needs Report, which is available on our website. It is also summarised in an easy-to-read and non-technical form in Why does London need the Thames Tunnel? (July 2011). The need for the project was confirmed and reaffirmed both by the past and present governments. This was clearly stated in written Ministerial Statements to Parliament in September 2010 and in November 2011. The need for the project is further reinforced in Defras Creating a River Thames fit for our future: A strategic and economic case for the Thames Tunnel and Costs and benefits of the Thames Tunnel (November 2011). See our response at para. 12.3.3for details on the Waste Water NPS, which confirms the need for the project. Refer to our response at para. 12.3.11. As part of the TTSS work, the Environment Agency assessed and categorised Londons CSOs, and determined which CSOs the project needed to address. It would not be cost-effective to capture all CSO events in a typical year as this would significantly increase the size of the project, which would have far greater impacts and the cost would be prohibitive in comparison with the marginally greater
Objections, issues and concerns 12.3.11 Disagree that a tunnel is the right solution. 1 14030
12.3.12
Unsure of whether it is the right solution as unconvinced that a tunnel would provide a complete solution to the sewage problem or that the cost, disruption and visual effect of the permanent structures would be justified for unproven benefits.
14030
174
12 Other comments
Ref Comments Total/ID number Our response benefits. For example, the project would reduce CSO events from up to 60 per typical year to four or fewer (which would occur during the winter months). However, if the control target were one event or fewer, the tunnels required storage volume (length and/or diameter) would at least double. The Environment Agency agreed that capturing 96 per cent of the current discharge volume in a typical year (leaving four events or fewer) is a practical and cost-effective level of control. Solutions to the problem of sewage discharges into the River Thames have been under examination for more than ten years. The independently chaired TTSS concluded in 2005 that that a large-diameter storage and transfer tunnel is the preferred solution. A comprehensive cost benefit analysis was undertaken at that time, which demonstrated that a storage and transfer tunnel option (comprising the Lee Tunnel project and the Thames Tideway Tunnel project) combined with improvements at the sewage treatment works would have the highest net benefits. Subsequent sensitivity testing and analysis demonstrated that, despite uncertainty regarding some of the underlying assumptions of the cost benefit analysis, the predicted benefits were four times higher than required to be considered positive. Table 5.10 of the Needs Report sets out the cost of the preferred tunnel route in comparison to the alternative routes and solutions. This work informed the Ministerial Statement of March 2007 and the Governments request that Thames Water develop a tunnel solution. The Government recently published a report entitled Creating a River Thames fit for our future: A strategic and economic case for the Thames Tunnel. This report updates the 2007 regulatory impact assessment and takes into account new
175
12 Other comments
Ref Comments Total/ID number Our response data since that time. It also contains an appraisal of alternative solutions and concludes that a tunnel solution remains the most appropriate and cost-effective solution considered. Throughout its development, the project has been and will continue to be closely scrutinised by Defra and the industry economic regulator Ofwat. The European Commission has proceeded with infraction proceedings against the UK Government in respect of frequent discharges of sewage into the tidal Thames. The court has not yet issued its decision, but it has the power to seek fines in the form of a lump sum and a periodic penalty, which could be considerable. Action must be taken to avoid penalties for future non-compliance with the UWWTD. We are aware that construction works can be disruptive, however, we are carrying out extensive technical work and consultation in order to minimise disruption. The project is a long-term solution and would benefit current and future generations. The feasibility of separating the sewerage system in two (one system for foul water and another for storm water) was investigated by the TTSS and is set out in the Needs Report (Appendix D). The separation would involve constructing duplicate pipes throughout London and ensuring that all buildings and roads are connected to the correct system. Constructing a separated system, even only in a limited number of locations, would entail digging deep trenches in most streets in London. It would be extremely disruptive throughout the city and take considerable time to complete. In addition, due to the need to gravity flow the sewage, a number of pumping stations would be required to either lift
Alternative solutions 12.3.13 Prefer separate sewage and storm water systems. In particular, suggest detailed investigations of the local sewerage systems to explore disconnecting surface water discharges to the combined systems and extending surface water only sewerage systems that discharge directly into the River Thames. 1 MD14101LO
176
12 Other comments
Ref Comments Total/ID number Our response foul water to the interception sewers or to pump storm water into the river, at a considerable energy cost. Separate systems would also lead to a net increase in pollutant loadings in the River Thames because polluted street drainage, in particular, would be discharged into the river rather than captured by a tunnel. The construction cost alone was estimated at in excess of 12billion. For these reasons, it was not considered to be a viable option. Separation of the sewerage system is an option for future developments as opportunities arise, but it would not address current problems. The feasibility of implementing Sustainable Drainage Systems (SuDS) to control CSO discharges was investigated by the TTSS and set out in the Needs Report (Appendix E). The Needs Report reaffirmed the TTSSs original conclusion that SuDS are not a practical or costeffective CSO control solution for the following reasons: a. SuDS would not achieve compliance with the UWWTD; they would only partially address the number and volume of discharges and would not meet the environmental requirements. b. SuDS may be technically feasible in some areas; however, there are significant logistical, legal and regulatory impediments to its implementation. c. SuDS could only be implemented in limited areas due to the lack of open spaces in the highly developed areas that generate the most rainfall run-off (which leads to CSO discharges). d. In order to separate wastewater systems in large areas at the required scale to reduce CSO discharges, the construction cost alone would be in excess of 14billion.
12.3.14
Prefer SuDS/green infrastructure.
MD14101LO
177
12 Other comments
Ref Comments Total/ID number Our response e. There would be extensive disruption to streets and parks. f. Parking spaces would be lost and sections of open areas in parks would be used to pond water. g. A high level of property-owner involvement would be required to realise some of the flow reduction. It was concluded that SuDS would not be cost-effective compared to a less expensive tunnel solution that would fully address wastewater discharges from CSOs. However, we recognise that SuDS are a valuable tool as part of a long-term solution to reduce surface water in the sewer system. We will continue to work with the GLA and local authorities to promote the use of SuDS in new developments and as a part solution to local flooding issues. 12.3.15 Prefer an alternative solution to intercept the Putney Bridge CSO. Suggested solutions included: a. Pile a trench at river bed level and work to install pipes inter-tidally. b. Construct a tunnel from the main shaft to a mini shaft at the existing CSO. This would be in London Clay and a small shield would have to be recovered at the bridge. Use the wedge block tunnelling method developed by Thames Water for use in London Clay. The shield is quite small, so the shaft at Putney Bridge would not be enormous. 1 LR14130 In order to achieve this, a significant amount of excavation and construction work, including construction of the CSO interception chamber and connection culvert, would need to be carried out below high tide level. We require a dry site in order to work safely and effectively, and we do not believe that it would be practical to undertake this scale of work inter-tidally. We do not believe that driving a small tunnel from the Putney Embankment Foreshore shaft to the CSO interception location would reduce the programme of works or the amount of disruption at this site. It is not possible to locate a reception shaft or pit for the small tunnel beneath the arches of the bridge due to available headroom and high tide levels. It needs to be located on the adjacent foreshore and requires a safe working area above high tide level. This mini site would be to be accessible to plant,
178
12 Other comments
Ref Comments Total/ID number Our response workers and materials, which would take up the same area of foreshore as our current proposals. We do not believe it would be practical to construct the connection culvert in this way or that it would reduce disruption. It should also be noted that the size of the shaft is not dependent on construction requirements alone; it is also subject to hydraulic and operational access requirements. CSOs are in fixed locations and sites to intercept them need to be on the line of, or in close proximity to, the sewer. Putney Bridge CSO is located under Putney Bridge and splits into two outlets beneath the southern arch of the bridge. Both outlets need to be intercepted therefore the interception point cannot be located inland.
c. The shaft could be sunk from dry land on the Embankment.
Tunnel route Objections, issues and concerns 12.3.16 Request for more information on the tunnel route; it is unclear whether the deviation from the River Thames near Lillian Road and St Hilda's Road is due to cost or other factors. Suggested modifications to the Abbey Mills route included investigating other possible routes for the tunnel north of Barn Elms. 1 LR15001 We carefully considered potential tunnel routes and selected the proposed route for a number of reasons: it is the shortest route; it is the least disruptive and most costeffective option, costing 20 per cent than the other two options, while meeting all the required environmental objectives; it requires the least number of worksites; and it requires less tunnelling at depth through Chalk in the east. Deep tunnelling through Chalk is potentially more difficult and would create greater health and safety issues. A number of variations to the Abbey Mills route were considered in the Engineering options report. The alignment of the tunnel along the Abbey Mills route was optimised to balance a range of factors, including the potential effect of the main tunnel on the environment. We did, however, consider alternative routes for the main tunnel north of Barn Elms. The proposed route avoids two
12.3.17
14096PET
179
12 Other comments
Ref Comments Total/ID number Our response existing tunnels that cross the River Thames north of St Pauls School, which are at a similar depth to the main tunnel, and runs under fewer buildings than other possible alignments. Following phase one consultation, design development demonstrated that a larger diameter connection tunnel was required to connect the Acton Storm Tanks CSO to the main tunnel than originally anticipated at phase one consultation. We therefore extended the main tunnel all the way to Acton Storm Tanks. We consider that the proposed alignment for this extension (presented at phase two consultation, subsequently refined and re-presented at post phase two consultation and Section 48 publicity) is the most suitable route for the main tunnel. It avoids two existing tunnels that cross the River Thames north of St Pauls School, which are at a similar depth to the main tunnel, and runs under fewer buildings. Irrespective of the tunnel route, we would still require a site to intercept the Greenwich Pumping Station CSO. We considered the feedback received at phase two consultation and we still believe that Greenwich Pumping Station is the most suitable site to connect the Greenwich Pumping Station CSO to the Greenwich connection tunnel, and to drive the connection tunnel. We are aware that two businesses on the site would need to be relocated during construction. The Environmental Statement for submission with the application will assess the likely significant effects of business relocations. Our preliminary assessment in this regard was set out in the PEIR (Volume 26, Section 10) at phase two consultation, which established the need to relocate the businesses during construction and that it would result in a moderate
12.3.18
Object to the extension of the main tunnel to Acton Storm Tanks. Reasons included that the revised proposals run under properties at Lillian Road.
14052LO, 14097, 14098, 14096PET
12.3.19
The route should avoid the phase two consultation preferred site at Greenwich Pumping Station and associated effects on Jewson.
15000
180
12 Other comments
Ref Comments Total/ID number Our response adverse socio-economic effect. We would assist the directly affected businesses to find alternative premises. Landowners may have a statutory entitlement to claim compensation for any diminution in the value of property due to the construction of the tunnel. In addition to the statutory process, we have published an Exceptional hardship procedure, which sets out how we would assess claims from householders who contend that they are suffering exceptional hardship as a result of being unable to sell their property because it is potentially impacted by our currently published proposals. We have also published a Guide to the Thames Tunnel compensation programme, which sets out details of compensation that would be available during construction for damage or loss, required protection measures, or compulsory purchase. For further details, see Appendix V of the Section 48: Report on site selection process. We considered three tunnel routes: the proposed Abbey Mills route, the River Thames route and the Rotherhithe route. As stated in the Route and tunnel alignment project information paper and Project overview, one of the reasons why the Abbey Mills route remains our preferred route is that it is the least disruptive of the routes considered. It is also the shortest and most cost-effective option, costing 20 per cent less than the other two options while meeting all the required environmental objectives, including reducing wastewater discharges. Finally, it requires the least number of worksites and requires less tunnelling at depth through Chalk in the east. The Site selection background technical paper makes the case for our preference for the horizontal alignment of the
Alternative tunnel routes 12.3.20 Prefer the tunnel route to follow the river. 1 LR15001
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12 Other comments
Ref Comments Total/ID number Our response main tunnel to follow the River Thames. It also describes where the route would need to deviate from the River Thames.
Tunnel alignment Supportive and neutral comments 12.3.21 12.3.22 No comment on the tunnel alignment. Construction method suggestions included: using two TBMs, one boring from Abbey Mills up river, would reduce the drilling time by a year, save a considerable amount of money, and avoid the need for a site in Southwark. There are numerous examples of dismantling TBMs under water in world-class tunnelling projects. 1 1 15000 14093 Noted. The Build project information paper, Route and tunnel alignment project information paper and the site information papers at phase two consultation describe the tunnel construction process in relatively simple terms; however, we undertook significant in-depth studies and analysis. The reasons for the selected drive strategy are set out in Section 6.6 of the Phase two scheme development report. Following phase two consultation, we reviewed these conclusions in the light of the feedback received. We still believe that our proposed drive strategy is the most suitable. For further details, see Section 7.6 of the Section 48: Report on site selection process. The main tunnel from Acton Storm Tanks to Abbey Mills Pumping Station would be 22 km long; it is normal for a tunnel of this length to be split into sections for a number of reasons including ground conditions and commercial, programme, safety, and technical issues. Several TBMs would be used to complete the work. We consulted specialist consultants and TBM suppliers and had regard to their advice to develop an efficient, safe, and cost-effective strategy. Our studies also demonstrated that Abbey Mills Pumping Station is not suitable as a main tunnel drive site because Objections, issues and concerns
182
12 Other comments
Ref Comments Total/ID number Our response transporting material to and from the site via the River Lee would be very difficult. This is highly undesirable where material needs to be transported daily over a two to three year period, given the volume of excavated material produced at main tunnel drive sites. Given the constraints on using the River Lee to transport materials, we would need to use the surrounding residential roads to access the site. For these reasons, combined with the need to use a slurry TBM to drive any significant distance in Chalk, Chambers Wharf was considered more suitable as a drive site. Abbey Mills Pumping Station will only serve as a reception site.
12.4
12.4.1
General other comments

This section sets out the supportive and neutral comments and objections, issues and concerns at post phase two consultation in relation to other general matters, denoted by sub-headings shaded in orange in Table 12.4 Table 12.4 Other general comments
Comments 1 Total/ID number CABE Our response Your support is noted and welcomed.
Ref
Supportive and neutral comments 12.4.2 Support the design of the ventilation columns, which has the potential to create a strong identity for the project and unify the aboveground works along the length of the tunnel. 12.4.3 Welcome the proposed heights, shapes and pairings of the columns, which successfully address both functional and architectural proportions. 12.4.4 Support the proposed metallic materials for the ventilation columns and suggest, for example,
CABE
CABE
Your support is noted and welcomed. We will consider the suggested approach as we develop the design of the
183
12 Other comments
Ref Comments using cast metal to achieve the necessary combination of durability and long-term architectural quality. Pleased that the Report on phase two consultation recognises the opportunity to maximise the use of water transport. It is logical and cost-effective to maximise the use of barge transport for cofferdam fill and at main tunnel drive sites. The legacy proposals are welcomed but continued engagement with TfL and other stakeholders will be necessary to agree these proposals (eg, required junction improvements, succession planting etc.). The scheme also provides the opportunity to enhance pedestrian and cycle infrastructure and the quality of the general public realm at each worksite. Support the statement in the CoCP that all road freight operators will be members of the Fleet Operator Recognition Scheme (FORS). As part of the DCO, the project should: ensure that all logistics contractors during construction are FORS (Bronze) members; fit safety equipment to vehicles; display prominent safety signage to warn cyclists; undertake driver licence checks; and undertake approved driver training etc. 1 Total/ID number ventilation columns. Our response
12.4.5
14119
Your comment is noted and welcomed.
12.4.6
14119
Qualified support 12.4.7 1 TfL We will continue to engage with TfL and other stakeholders in our design development process.
12.4.8
TfL
Your comment on our proposed designs is noted and welcomed. We will review and consider these comments as we refine our design proposals. Your support is noted and welcomed. Our draft CoCP (Section 5) at Section 48 publicity provides further details on our proposals for lorry management and control. Our proposals include a requirement for lorries to feature active fitted cyclist safety measures and for all drivers to undertake a lorry drivers awareness course.
12.4.9
TfL
184
12 Other comments
Ref 12.4.10 Comments The quality of the design detailing will be extremely important to the success of the columns. Suggest detailing them to at least RIBA Work Stage E to maintain design quality throughout delivery. In taking the detailed design of each site forward it is important to maintain the overarching design vision of the columns. Suggest producing a master plan diagram for the columns across the whole scheme to achieve this vision. Understand that strategic infrastructure projects such as the Thames Tideway Tunnel project are subject to environmental impact assessments. What work/studies have been carried out to date? 1 Total/ID number CABE Our response Your comments are noted. Our application for development consent will contain appropriate information to enable a decision to be made on whether to grant a Development Consent Order. We anticipate that if an order is granted it would include a series of requirements (similar to planning conditions) such as to submit further detailed information for approval. We therefore expect to continue our discussions with the Design Council CABE and other relevant bodies in this regard. Our preliminary assessment of the likely significant environmental effects at a site-specific and project-wide level is provided in the PEIR at phase two consultation and the PEIR Addendum at post phase two consultation. The assessment examined the potential effects of the project on a wide range of environmental topics. We will develop this assessment further in the Environmental Statement for submission with the application. The Environmental Statement will describe measures to mitigate any significant adverse effects on local communities and other receptors. We consulted all relevant stakeholders on the methodology for the Environmental Statement prior to phase two consultation. The CoCP for submission with the application will also contain measures to mitigate local effects. Refer to our response at para. 12.3.9.
12.4.11
LR14117
12.4.12
Evidence from other waterside construction sites including Kings Place, Wood Wharf, and Canary Wharf is that a wide range of construction materials can be moved by water transport. The project could well be underestimating the potential for water transport and should promote
14119
185
12 Other comments
Ref 12.4.13 Comments future use of water transport. Concern that contractors would not consider or adopt water transport. 1 Total/ID number 14119 Our response Following phase two consultation, we reviewed our transport strategy and options for river transport during construction. At post phase two consultation we presented our proposals to increase this where possible. At Section 48 publicity we published our Section 48: Transport strategy, which explains how we reviewed the options for transporting construction materials, including excavated materials, to and from the sites. An Overarching Written Scheme of Investigation will be appended to the Environmental Statement for submission with the application, which will detail the approach to developing more detailed archaeological specifications for all sites. Site-specific written schemes of investigation will be prepared at a later date and incorporate the results of field evaluations that are not yet complete. We will include a requirement to prepare site-specific written schemes of investigation in the application. Options for increasing the river transport of materials are under examination with the PLA, TfL, the GLA and other stakeholders, in addition to the feasibility of these options in respect of social, environmental and economic criteria. Details of our revised transport proposals are available in the Section 48: Transport Strategy. Further information will be provided in the application.
12.4.14
The next stage for the archaeological work will be to provide more detailed archaeological specifications.
EH
12.4.15
Expect Thames Water to develop a logistics and construction strategy through continued liaison with major stakeholders including the GLA and the PLA, that: a. maximises the use of river and rail transport b. minimises the impact on the local and strategic highway networks c. minimises local and overall environmental impacts d. considers all direct and indirect costs and benefits consistent with established government guidance on transport
TfL
186
12 Other comments
Ref investment. 12.4.16 Given the scale of the proposed development, concerns regarding the potential impacts during construction on the TfL Road Network and its users. In order to maintain safe and efficient transport operations and infrastructure during construction, it is essential to identify and minimise these impacts by means of appropriate mitigation measures. Awaiting confirmation from the project that the proportion of construction material (main tunnel spoil, cofferdam fill) that would be transported by barge is approximately 52 to 53 per cent of the total. The Transport Strategy Study demonstrated that there are further opportunities to use river and rail transport for other bulk construction materials and at additional sites. There should be further evaluation of: a. the use of Deptford Creek to and from the Greenwich Pumping Station site by barges b. the use of barges to import tunnel segments to main tunnel drive sites. 1 TfL We are carrying out a transport assessment based on a methodology that was discussed and agreed with the potentially directly affected local authorities and TfL, which will identify likely significant effects of the project and any appropriate mitigation measures. The Transport Assessment will be included in the Environment Statement for submission with the application. As stated in the Section 48: Transport Strategy, we intend to use the river to transport 53 per cent of all materials. Comments Total/ID number Our response
12.4.17
TfL
12.4.18
TfL
We cannot currently commit to using Deptford Creek or using barges to transport tunnel segments. The reasons for this, including the effect of not using river transport on the highway network, are set out in the Section 48: Transport Strategy.
Increasing these uses would reduce the impact of the development on the local and strategic highway networks and users. It would prove particularly important at the proposed main tunnel drive sites, which would require significant HGV movements over a long period of time.
187
12 Other comments
Ref 12.4.19 Comments It would be vital for the scheme promoter to establish a resource or team to centrally coordinate and manage all construction logistics across the development. One of its remits should be adequately to enforce agreed routes for construction traffic to the satisfaction of TfL. Close liaison between this team and TfL/other local highway authorities would help to select the most appropriate HGV routes, delivery hours etc for each site based on the latest network conditions and other works taking place concurrently. 1 Total/ID number TfL Our response The construction traffic routes and the effects of lorry traffic will be assessed in the Transport Assessment. The principles relating to traffic (including lorry) management and control and the working hours for the project are set out in the draft CoCP. The CoCP states that the contractor will produce, coordinate and implement site-specific traffic management plans. The plans will be prepared in consultation with highway and traffic authorities and the emergency services and will be agreed with the relevant highway authorities and TfL (where required). The plans will include local routes for lorries including, where required, holding areas, a route signing strategy, means of monitoring lorry use and any prohibited routes. Your comments are noted and will be taken into account in developing our traffic management proposals.
12.4.20
All proposed site accesses, traffic management arrangements, diversionary routes (for vehicles, pedestrians and cyclists) must be designed and appropriately assessed (using safety audits) so as to minimise the risk of accidents. TfL encourages the use of blindspot safety mirrors (trixis) at every construction site. A final version of TfLs Cyclists at Roadworks will be available shortly and should be referred to in finalising traffic management designs. Every effort should be made to minimise the need for works that entail any loss of lane capacity. The programme for any such works should be kept as short as possible and appropriate mitigation measures should be put in place. The cost of any identified mitigation measures in
TfL
12.4.21
TfL
Our works would be undertaken in as short a period as possible in order to minimise any effects on highway capacity. We also aim to suitably manage any environmental effects of the development by, for example, controlling our hours of working. Suitable mitigation measures will be discussed with TfL and other highways authorities. We have not commenced negotiations on planning
12.4.22
TfL
188
12 Other comments
Ref Comments relation to the TfL highway network (eg, required junction improvements), assets (eg, piers) or services (eg, bus operation costs for service diversions and changes to facilities) must be met by the scheme promoter. Total/ID number Our response requirements or obligations since our design is not yet fixed. We will enter into these discussions shortly and ensure that our proposed requirements and any obligations comply with statutory requirements and relevant guidance.
12.5
12.5.1
Feedback in relation to our preferred sites

This section sets out the supportive and neutral comments and objections, issues and concerns (and how we propose to address them) at post phase two consultation in relation to our preferred sites. The feedback in Table 12.5 is grouped by site, as denoted by the sub-headings shaded in blue, and the orange sub-headings categorise the feedback as supportive and neutral comments or objections, issues and concerns. Table 12.5 Feedback in relation to our preferred sites
Comments Total/ID number Our response C
Ref Acton Storm Tanks
Objections, issues and concerns 12.5.2 2 The proposed site access is unsuitable. n Reasons included: a. Canham Road is a narrow one-way road: concerned that access to 22-24 Canham Road will be disrupted due to the volume of construction vehicles. b. There is insufficient capacity on the access route, which would result in delays. 1 14085 We carefully considered the options for access to the site; we believe that the proposed access is suitable although we recognise that signal optimisation at The Vale/Warple Way/East Acton Lane junction and the Uxbridge Road/Hanger Lane/Gunnersbury Avenue junction may be required in order to improve capacity on the highway network and reduce effects on highway operations. At this site, we also propose to use most of the excavated material to infill two of the existing storm tanks, which would minimise the number of lorry movements. Our Transport Assessment for submission with the application will set out the required signal optimisation works before construction commences. N
189
12 Other comments
Ref 12.5.3 Comments 2 Need more information on the permanent 2 design proposals. a a n 1 Total/ID number 14085 Our response Details of the phase two consultation design are provided in Appendix A of the Design development report. We had regard to the phase two consultation feedback and amended the design for this site (see the Section 48: Project description and environmental information report and the Section 48: Book of plans). The PEIR (Volume 7, Section 9) provides a preliminary assessment of the likely significant operational noise and vibration effects of the project. No likely significant effects were identified at this site, subject to appropriate noise control measures for equipment in order to meet the targets in BS4142. Therefore we do not expect any effects on occupants or users of adjacent or nearby properties, businesses or facilities, or on any sensitive structures or equipment. The Environmental Statement for submission with the application will provide a full assessment of likely significant operational noise and vibration effects. At phase two consultation, we proposed to house the majority of the above-ground equipment in a ventilation building located in the northwestern area of the site. The equipment included ventilation filters, fans and associated electrical and noise control equipment. In response to phase two consultation comments, we amended the plans and minimised the footprint of the above-ground equipment. At Section 48 publicity we proposed to locate the ventilation filters and noise control equipment in below-ground chambers. C N
Mitigation 12.5.4 1 Ensure that there would be no noise from the 5 large fans in the proposed building. c a z 1 14085 N
12.5.5
2 Reduce the height of the permanent buildings 2 and structures by sinking the building one c storey deep into the existing tanks. p
14085
190
12 Other comments
Ref Comments Total/ID number Our response However, the ventilation fans and associated electrical equipment must be located in aboveground structures because siting such equipment below ground would lead to operational, durability and health and safety issues. Your comments are noted. The materials for the above-ground structures would be agreed at a later stage. C
12.5.6
Specific design amendment: consider a light coloured, well-detailed steel-framed building.
14085
Barn Elms Supportive and neutral comments 12.5.7 Support the changes to the proposed use of the preferred site since phase one consultation. Support the use of this site if the proposals do not involve the pier or waste removal by river. 7 14033, 14039, 14058, 14060, 14107, 14119, LR14064 14004 Your support is noted and welcomed. N/A
12.5.8
Our proposals do not include constructing a pier or removing materials by river. For further details on our latest proposals, refer to our Section 48 publicity material. The sites we consulted on at phase two consultation were chosen by means of an extensive site selection process (see the Site selection methodology paper on our website). We consulted on and agreed the methodology with key stakeholders including potentially directly affected local authorities. We used a multidisciplinary approach to assess potential CSO sites, having regard to engineering, planning, environmental, property and community considerations. We recognise that, given the locations in which we
N/A
Objections, issues and concerns 12.5.9 Disagree with the selection of this preferred site. 1 14145 N/A
191
12 Other comments
Ref Comments Total/ID number Our response are seeking to construct and operate the tunnel, many of the shortlisted sites are constrained. However, based on our assessments prior to phase two consultation, we consider that, on balance, Barn Elms is the most suitable site. This is because we can intercept the CSO directly and avoid the need to construct pipes beneath the high pressure gas main. The proposed site would also reduce encroachment into the playing fields. Since phase one consultation, we amended our proposals to avoid the need to divert the Thames Path. We no longer propose to use Barn Elms as a main tunnel site (our preferred main tunnel site is now Carnwath Road Riverside), we propose to use this site solely to intercept the West Putney Storm Relief CSO. Due to the smaller amount of excavated material that would be produced, materials would now be moved by road. Overall, the likely effects of the project on Barn Elms Playing Fields were significantly reduced at phase two consultation. We then considered the feedback received at phase two consultation and post phase two consultation. We still believe that Barn Elms is the most suitable site to intercept the West Putney Storm Relief CSO. For further details on the site selection process, refer to Appendix C of the Section 48: Report on site selection process. CSO interception sites must be as close to the line of the existing sewer as practicable, which requires a localised approach and there are few options available. In the case of the West Putney Storm Relief CSO, the sewer is located adjacent to a densely residential area that cannot be avoided. C
12.5.10
1 Site selection should avoid sites in residential 0 and/or densely populated areas specifically 1 residents of Horne Way and Stockhurst Close. z
14106, 14108
N/A
192
12 Other comments
Ref 12.5.11 Comments 1 Disagree with/not commenting on site selection 0 due to wider objections to the proposed 1 solution and/or the need for the project. a Specifically, not convinced from the data v provided so far in relation to the necessity and cost-effectiveness of works to this CSO. 1 Total/ID number 14108 Our response The case for the project is set out in detail in the Needs Report, which is available on our website. It is also summarised in a non-technical form in our publications Why does London need the Thames Tunnel? and Why does Londons economy need the Thames Tunnel?. The need for the project was confirmed and reaffirmed both by the past and present governments. This was clearly stated in written Ministerial Statements to Parliament in September 2010 and in November 2011. The need for the project is further reinforced in Defras Creating a River Thames fit for our future: A strategic and economic case for the Thames Tunnel and Costs and benefits of the Thames Tunnel (November 2011). The Waste Water NPS, which was designated on 26 March 2012, clearly states that the need for the project has been demonstrated. It concludes that detailed investigations have confirmed the case for a Thames Tunnel as the preferred solution. The NPS was supported by an Appraisal of Sustainability Post-Adoption Statement, which contains further detail on the significant amount of work undertaken to establish the need for the project and assess alternatives. In view of the extensive work that has been undertaken since 2000, we consider that the need for the project has been sufficiently demonstrated. In relation to the specific point raised, the Environment Agency identified the most unsatisfactory CSOs that cause unacceptable environmental impacts due to the frequency or volume of the overflows, or the fact that they C N/A
193
12 Other comments
Ref Comments Total/ID number Our response discharge into an environmentally sensitive part of the River Thames. The Needs Report (Table 4.2) states that the West Putney Storm Relief CSO falls within the category of CSOs that most urgently needs to be addressed. Monitoring data for the West Putney Storm Relief CSO from 1 October 2010 to 30 September 2011 confirms that it continues to overflow, and 31 distinct discharges were recorded within this period. Bacteria data collected in 2011 indicated high levels of e.coli and the presence of human waste in the discharge, which confirms the health risk of the discharges from this CSO. See the Supplementary report on phase two consultation (Section 2) or of the Needs Report (Section 5) for details of alternative solutions considered. We consider Barn Elms to be the most suitable site. See Appendix C of the Phase two scheme development and Appendix C of the Section 48: Report on site selection process for further details. We are carrying out assessment of the likely significant effects of the project, including cumulative effects with other developments. Our preliminary environmental assessment is provided in the PEIR (Volume 9) and PEIR Addendum (Volume 9). See the draft CoCP (published at phase two consultation and revised at Section 48 publicity)for details. As stated in our Barn Elms site information paper at phase two consultation, the contractor would be required to implement noise and vibration control measures at the site, in line with the requirements of the CoCP. The contractor would also be required to gain approval from the London Borough of Richmond prior to construction through a Section 61 application C
12.5.12
1 Do not consider this site appropriate due to the 0 cumulative effects of the development at the 1 preferred site and other nearby developments, f specifically Putney Hospital. d
14106
N/A
12.5.13
1 Concerns regarding general noise effects 4 arising from construction activities particularly f at night and on weekends.
14041
194
12 Other comments
Ref Comments Total/ID number Our response under the Control of Pollution Act, which would set out specific working methods and measures to minimise noise and vibration. This would ensure that noise levels are reasonable and best practical means are applied. The measures would be agreed with environmental health officers from the local authority. In addition, we would implement measures to minimise noise and vibration from plant and works including the selection of appropriate plant and equipment, the suitable siting of equipment and the use of site hoardings and temporary stockpiles to provide acoustic screening. Details of the measures to be adopted for the construction phase will be set out in the CoCP for submission with the application. At most of our sites we plan to carry out the majority of works within standard working hours, which are 8am to 6pm weekdays, and 8am to 1pm on Saturdays. We may occasionally need to carry out works outside of standard working hours for reasons such as undertaking large concrete pours, delivering abnormal, large and heavy loads at times when there is reduced traffic, or making connections to the existing sewer system at night when there is low sewage flow. Continuous 24-hour working would be required during the tunnelling and secondary lining phases of the works; however at night we would limit noise as much as possible and prohibit HGV movements. The nearest residential properties are on Horne Way, on the opposite side of Beverley Brook. One non-residential noise-sensitive receptor the Sea Cadet Head Quarters to the east of the site across C
195
12 Other comments
Ref Comments Total/ID number Our response Beverley Brook was also assessed. The PEIR (Volume 9, Section 10) contains our preliminary qualitative assessment of noise and vibration from construction site activities, noise from construction traffic on roads outside the site, and noise and vibration from the operational the site on sensitive receptors. The noise and vibration sensitive receptors are listed in the PIER (Volume 9, Table 9.4.1). The PEIR assessment used Defra's London noise maps. Our Environment Statement for submission with the application will include an assessment of likely significant noise and vibration effects, which will be completed in line with a methodology agreed with the London Borough of Richmond that complies with BS4142. We will develop mitigation measures to provide appropriate attenuation for any significant noise effects identified at our sites. There would be continuous working during phase three of the construction works at this site. Further details are set out in the Managing construction project information paper and the Barn Elms site information paper at phase two consultation. Your comments are noted. We believe that the proposed design of the structures that would enclose the interception structures, ventilation structures and control kiosk at this site is a uniform response that would contribute to the site's setting. In light of comments received at phase two consultation, we reviewed the suitability of the proposed habitat walls and amended this element of our proposals. For further details on our revised proposals, refer to the C
12.5.14
3 More information is needed on working hours, 2 in particular, will the work be carried out 24n hours a day seven days a week? 2 Proposals are not in keeping with/would not 2 enhance and/or would have a negative effect l on the character or appearance of the local area. 2 The scale of the permanent buildings and 2 structures is out of keeping with existing a buildings in the surrounding area. a j
14041
12.5.15
14114
12.5.16
14114
196
12 Other comments
Ref Comments Total/ID number Our response materials at Section 48 publicity including the Section 48: Book of plans and Section 48: Project description and environmental information report. Details of the proposed design at phase two consultation are provided in Appendix C of the Design development report. We had regard to the feedback received at phase two consultation and amended the design for this site. Details of the revised design are provided in the Section 48 publicity material including the Section 48: Project description and environmental information report and Section 48: Book of plans. Your comments are noted. In response to feedback at phase two consultation, we considered how to reduce the bulk of the permanent structures at this site. It should be noted that the size and form of the structures associated with the CSO interception are informed by a number of functional parameters, including the hydraulic requirements of the tunnel. Details of our amended design are contained within our Section 48 publicity material including the Section 48: Project description and environmental information report and Section 48: Book of plans. The proposed permanent structures were designed to minimise maintenance requirements. C
12.5.17
2 Need more information on the permanent 2 design proposals, including how the project a proposes to hide construction with a landscaping. n
14030
Mitigation suggestions 12.5.18 2 Reduce the size of the permanent buildings 2 and structures. c q 2 Specific design suggestions included: 2 a. Natural grass mounds would be more in c keeping with the edge of a playing field. a b. j Design the ventilation column to look like something else, for example, a tree. Ensure that the design permits required maintenance works. 1 14114 C
12.5.19
14114
12.5.20
14114
197
12 Other comments
Ref Dormay Street Supportive and neutral comments 12.5.21 Support the changes to the proposed use of the preferred site since phase one consultation. 2 Use the river rather than road to transport c construction materials and spoil using the a nearby wharf. This would remove heavy traffic b from Wandsworths congested roads and reduce the impact on the environment and the communities along the route that the lorries would otherwise use. 1 LR14121 Your support is noted and welcomed. N/A Comments Total/ID number Our response C
Mitigation suggestions 12.5.22 1 LR14121 As stated in the site information paper at phase two consultation, we would transport materials by barge where practical and cost-effective. However, barge transport is not considered viable at this site because Bell Lane Creek is not suitable for efficient use of barges. Furthermore, there is no suitable rail head near the site. Therefore, it would be necessary to move materials by road to a suitable wharf or rail head. However, nearer the time of construction we would consider any opportunities to make further use of river transport. Our contractor might also propose to make further use of the river transport or consolidation centres. N
Carnwath Road Riverside Supportive and neutral comments 12.5.23 12.5.24 12.5.25 Support the use of the preferred site. The site is a brownfield site. The physical characteristics of the site make it suitable; it has river access and would have less environmental effects than alternative sites. 1 1 1 LR15001 LR15001 LR15001 Your comment is noted and welcomed N/A N/A N/A
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12 Other comments
Ref 12.5.26 Comments Dont know/unsure whether the right key issues associated with the operational site and measures to address them were identified in the phase two consultation Carnwath Road Riverside site information paper. 1 Object to the use of this preferred site. There 0 have been no changes to the proposals and 1 concerns raised at phase two consultation do a not appear to have been adequately addressed. 1 Site selection has not incorporated comments 0 and objections from phase two consultation. 1 d 1 Total/ID number LR15001 Our response Your comments are noted. C N/A
Objections, issues and concerns 12.5.27 2 14071, 14072 The sites that we consulted on were chosen via an extensive site selection process (see the Site selection methodology paper on our website). We consulted on and agreed the methodology with key stakeholders, including potentially directly affected local authorities. We used a multidisciplinary approach to assess potential main tunnel sites and drive options, having regard to engineering, planning, environmental, property and community considerations. We recognise that, given the locations in which we are seeking to construct and operate the tunnel, many of the shortlisted sites are constrained. However, based on our assessment prior to phase two consultation, we consider that, on balance, Carnwath Road Riverside is the most suitable site. This is because it is a brownfield site that features wharves. Furthermore, the width of the River Thames at this point would enable the use of larger barges to remove the excavated material produced by a main tunnel site. There would also be much less conflict with recreational users of the River Thames than at Barn Elms. We considered the comments received at phase two consultation, along with new information that had emerged, and undertook further technical work. We N/A
12.5.28
14084
N/A
199
12 Other comments
Ref Comments Total/ID number Our response still believe that Carnwath Road Riverside is the most suitable site to drive the main tunnel to Acton Storm Tanks and receive the main tunnel from Kirtling Street. For further details of how we took account of phase two consultation feedback, refer to the Section 48: Report on site selection process and our Report on phase two consultation. The purpose of the key issues in the Carnwath Road Riverside site information paper and measures proposed to address them was to provide a broad overview of likely significant effects associated with the site during construction. It is not, however, an exhaustive list. A more detailed description of likely significant effects and the methodology used to identify and assess them is provided in other technical reports, including the PEIR (Volume 13) at phase two consultation. We are carrying out an environmental impact assessment that will include a comprehensive assessment of likely significant effects arising from the proposals and measures to address them. The findings of the assessment, together with any recommendations for mitigation, will be provided in the Environmental Statement for submission with the application. Landowners may have a statutory entitlement to claim compensation for any diminution in the value of property due to the construction of the tunnel. In addition to the statutory process, we published an Exceptional hardship procedure, which sets out how we would assess claims from householders who contend that they are suffering exceptional hardship C
12.5.29
Insufficient information was provided on the key issues during construction to enable respondents to judge whether the right issues were identified.
LR15001
N/A
12.5.30
1 Concerns regarding the effect on property 6 prices. j
14084
200
12 Other comments
Ref Comments Total/ID number Our response as a result of being unable to sell property because it is potentially impacted by our currently published proposals. We also published a Guide to the Thames Tunnel compensation programme, which sets out details of compensation that would be available during construction for damage or loss, required protection measures, or compulsory purchase. In our Section 48: Transport Strategy we increased our commitment to river transport from phase two and post phase two consultation. At this site, we propose to use river transport to export excavated material from the main tunnel, shaft, connection tunnels, and associated interceptions, import and export cofferdam fill material, and import sand and aggregates for main tunnel secondary lining. We expect that this would reduce the number of lorry visits to/from this site by approximately 60 per cent or 900 fewer lorry movements than at phase two consultation. Road access to this site is proposed via Carnwath Road, which would link to the major road network to the north via Wandsworth Bridge Road and New Kings Road, and to the south via Wandsworth Bridge Road, as illustrated in the Carnwath Road Riverside site information paper at phase two consultation. Our assessment prior to phase two consultation provided in the PEIR (Volume 13, Section 12) indicated that, at the peak of construction at this site, an estimated average of 33 lorries would enter and exit the site each day. Our increased commitment to river transport would reduce this number. Therefore, we do not expect that construction traffic would have a significant impact in the context of existing traffic in C
12.5.31
2 Concerns regarding the effect of construction a traffic on residential amenity. b
14084
201
12 Other comments
Ref Comments Total/ID number Our response the local area. It would be unlikely to result in congestion on the Transport for London Route Network. We are reviewing the proposed construction traffic routes for the Transport Assessment, which will set out any likely significant effects of potential congestion. We will develop mitigation measures to minimise the effects of any disruption. The full Transport Assessment for submission with the application will consider the cumulative effects of our works with other strategic developments in the local area. The CoCP for submission with the application will include a requirement for a Traffic Management Plan to carefully control construction traffic in order to minimise any potential effects on the road network, residential amenity or access to the local area. The CoCP will also set out construction traffic routes, site access/egress points, signage and monitoring procedures. The permanent design and appearance of the site was illustrated in Figures 3A and 3B of the Carnwath Road Riverside site information paper at phase two consultation. More information on the design proposals is also available in the Section 48: Book of plans and the Design development report (Appendix G). Our view of the most significant site-specific issues in relation to the permanent design of the site is set out in the Carnwath Road Riverside site information paper at phase two consultation. It is not, however, an exhaustive list, and further potential issues C
12.5.32
2 Insufficient information has been provided on 2 the permanent design and appearance of the a site. Respondents were not able to judge a whether the right issues were identified. n
LR15001
N/A
202
12 Other comments
Ref Comments Total/ID number Our response associated with the site are set out in the PEIR (Volume 12) and the Design development report (Appendix G). We are carrying out an environmental impact assessment, which will include a comprehensive assessment of likely significant effects of the project. The findings of the assessment, together with any recommendations for mitigation, will be available in the Environmental Statement for submission with the application. C
Kirtling Street Objections, issues and concerns 12.5.33 1 Concerns regarding the effect of construction 4 noise and vibration on quality of life/residential k amenity. 1 14018 As stated in the Kirtling Street site information paper at phase two consultation, the contractor would be required to implement noise and vibration control measures at the site, in line with the requirements of the CoCP. The contractor would also be required to gain approval from the London Borough of Wandsworth prior to construction through a Section 61 application under the Control of Pollution Act, which would set out specific working methods and measures to minimise noise and vibration. This would ensure that noise levels are reasonable and best practice means are applied. The measures would be agreed with environmental health officers from the local authority. We would also implement measures to minimise noise and vibration from plant and works, including the selection of appropriate plant and equipment, the suitable siting of equipment and the use of site enclosures to provide acoustic screening. Details of the measures to be adopted for the construction N
203
12 Other comments
Ref Comments Total/ID number Our response phase will be set out in the CoCP for submission with the application. The PEIR (Volume 17, Section 9) provides a preliminary qualitative assessment of likely significant noise and vibration effects from construction site activities, noise from construction traffic on roads outside the site, and noise and vibration from the operational site. The proposed measures published in our draft CoCP were included in the assessment. The PEIR assessment used Defras London noise maps. The Environmental Statement for submission with the application will include an assessment of noise and vibration that will be completed in line with a methodology that was agreed with the London Borough of Wandsworth and complies with BS5228, BS6472 and BS7385. We will develop mitigation measures to provide appropriate attenuation for any potentially significant noise effects. Landowners may have a statutory entitlement to claim compensation for any diminution in the value of property due to the construction of the tunnel. In addition to the statutory process, we have published an Exceptional hardship procedure, which sets out how we would assess claims from householders who contend that they are suffering exceptional hardship as a result of being unable to sell their property because it is potentially impacted by our currently published proposals. We also published a Guide to the Thames Tunnel compensation programme, which sets out details of compensation that would be available during construction for damage or loss, required protection measures or compulsory C
12.5.34
1 Concerns regarding the effect on property 6 prices. j
14018
204
12 Other comments
Ref 12.5.35 Comments 1 Concerns regarding the proposal to move 6 boats off the pier at the Nine Elms houseboat a community on either a temporary or permanent a basis. Concerns regarding the cumulative z effect of relocation since temporary relocation is already required as part of the St James' proposals. 2 Total/ID number purchase. 14018, 14049 Our site selection process, as detailed in the Site selection methodology paper, included an assessment of the shortlisted sites in the light of five 'community' considerations in order to determine their suitability. The considerations included proximity to sensitive receptors (including residents and schools), and other socio-economic, health and equality considerations. The Phase two scheme development report and Section 48: Report on site selection process provide an overview of how each site was chosen. The PEIR (Volume 17, Section 10) provides a preliminary assessment of the likely significant effects of the scheme on residential amenity and concludes there could be significant effects. However, we do not anticipate that any residents would need to be re-housed as a result of our proposals. We are preparing an Environmental Statement for submission with the application, which will assess potential effects of the proposed development and identify any mitigation measures, in addition to those set out in the CoCP, required to address them. We will also continue to discuss our proposals with Nine Elms Pier Ltd in order to identify appropriate mitigation measures. Refer to our response at para. 12.5.35. N Our response C
Mitigation suggestions 12.5.36 1 If the difficulties associated with keeping 6 residents on the pier during construction are c insuperable, suggest that the project liaises a with St James regarding the timing of pier 1 14049 N
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Ref Comments improvements and construction to minimise z disruption to local residents. Total/ID number Our response C
Chelsea Embankment Foreshore Objections, issues and concerns 12.5.37 2 The proposals for concurrent closures of a footways and a new signalised pedestrian a crossing along the Embankment require further z work. 1 TfL Your comments are noted. We are preparing a Transport Assessment, which will include a review of pedestrian movements in relation to the proposals for submission with the application. N
Albert Embankment Foreshore Supportive and neutral comments 12.5.38 12.5.39 Support the use of the preferred site. 1 Qualified support for the use of the preferred 0 site subject to: 1 a. the preservation of the 6,000 year old b timbers near Vauxhall Bridge a d 1 1 14012 14025 Your support is noted and welcomed. We recognise that the eastern part of the site falls within the North Lambeth and Lambeth Palace Archaeological Priority Area. Our phase two consultation material included a preliminary assessment of likely significant archaeological effects, which was provided in the PEIR (Volume 19, Section 7). The preliminary assessment demonstrated that the sites main archaeological potential is for prehistoric remains on the foreshore. A prehistoric Mesolithic timber structure was recently exposed by river scour. There is also the potential to uncover the remains of a medieval jetty or wharf and other post-medieval industrial remains. In view of the results of our deskbased study of the site, we do not expect any finds of buried heritage assets of very high significance that might merit a mitigation strategy of permanent preservation in situ. We are carrying out an assessment of the likely significant effects of the N/A N/A
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12 Other comments
Ref Comments Total/ID number Our response project on the historic environment for our environmental impact assessment. We are consulting with English Heritage as a part of this process. Our draft CoCP sets out a range of measures in respect of archaeology that our contractor would adopt. A full assessment of the likely significant effects of the scheme on the historic environment, together with any recommendations for mitigation, will be provided in the Environmental Statement for submission with the application. As stated in our draft CoCP, we would put procedures in place to monitor construction works as appropriate in order to identify and record any archaeological finds. An addendum to the PEIR at post phase two consultation included one potential change in the preliminary historic environment assessment at phase two consultation. The change relates to the removal of approximately a further 4m of the parapet of the unlisted river wall (see the PEIR Addendum (Volume 19, Section 3)). Lack's Dock will continue to operate during and following construction therefore we do not anticipate any effect on income that it generates. We assume that this respondent is referring to the flap valves on the outfalls of the Clapham Storm Relief and Brixton Storm Relief sewers, which used to be the River Effra. Unfortunately the tidal flap valves on the outfalls are not in a suitable condition for reuse. However, we aim to preserve the reference to the River Effra in the design of the permanent works for the site in an appropriate C
b. review of the income from Vauxhall slipway
N/A
c. some form of preservation of the existing River Effra hatches.
N/A
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12 Other comments
Ref 12.5.40 12.5.41 Comments The design proposals will create a new area of public/open space. 2 The design proposals will leave a positive 2 legacy for the future. The Clapham outfall b addition to the public realm would enable safe j access to the inspection chamber as well as enjoyment of the space. It would enhance the views of Lambeth Bridge and the Houses of Parliament. 1 Concerns regarding the effect of construction 0 activities on archaeology. j 1 1 Total/ID number manner. 14026 LBW N/A N/A Our response C
Objections, issues and concerns 12.5.42 1 14027 We recognise that the eastern part of the site falls within the North Lambeth and Lambeth Palace Archaeological Priority Area. Our phase two consultation materials included a preliminary assessment of likely significant archaeological effects (see the PEIR (Volume 19, Section 7)), which stated that the sites main archaeological potential is for prehistoric remains on the foreshore. A prehistoric Mesolithic timber structure was recently exposed by river scour. There is also the potential to uncover the remains of a medieval jetty or wharf and post-medieval industrial remains. In view of the results of our desk-based study of the site, we do not expect any finds of buried heritage assets of very high significance that might merit a mitigation strategy of permanent preservation in situ. We are carrying out an assessment of the likely significant effects on the historic environment as part of our environmental impact assessment. We are consulting with English Heritage as a part of this N
208
12 Other comments
Ref Comments Total/ID number Our response process. Our draft CoCP sets out a range of measures in respect of archaeology that would be adopted by our contractor. A full assessment of the likely significant effects of the scheme on the historic environment, together with any recommendations for mitigation, will be provided in the Environmental Statement for submission with the application. As stated in our draft CoCP, we would put procedures in place to monitor construction works appropriately in order to identify and record any archaeological finds. 12.5.43 12.5.44 Consult with TfL on intended works and the interface with the Victoria Line tunnels. 2 Concerns regarding the disruption to the c Thames Path caused by construction works or diversion. 1 1 TfL 14026 We will continue to engage with TfL on our proposals for this site. The proposed site would require a temporary diversion to the Thames Path, as indicated in the site information paper at phase two consultation and in the supplementary site information paper at post phase two consultation. The diverted Thames Path could remain open during construction to maintain a safe route to local amenities. The detailed route would be agreed with the London Borough of Lambeth and TfL. The diversion would last for the duration of the works, after which the path would be reinstated along its present route. On account of the concerns raised by the occupants of Vauxhall Cross, which cannot be made public for security reasons, it is not possible to permit access to the new foreshore structure to the east of Vauxhall Bridge. N N C
12.5.45
Restricting access to the new foreshore would 2 be detrimental to its appearance and the 2 perception of safety. It would also create n unnecessary additional maintenance costs. The space could lead to anti-social behaviour or a convenient hiding place.
LBW
209
12 Other comments
Ref Mitigation suggestions 12.5.46 1 It may not be possible to preserve 0 archaeological remains in situ, but a full c survey/excavation should be undertaken for a preservation by record. z 1 14027 We recognise that the eastern part of the site falls within the North Lambeth and Lambeth Palace Archaeological Priority Area. Our phase two consultation material included a preliminary assessment of likely significant archaeological effects, (see the PEIR (Volume 19, Section 7)). The preliminary assessment determined that the sites main archaeological potential is for prehistoric remains on the foreshore. A Mesolithic timber structure was recently exposed here by river scour. There is also the potential to uncover the remains of a medieval jetty or wharf and other post-medieval industrial remains. In view of the results of our deskbased study of the site, we do not expect any finds of buried heritage assets of very high significance that might merit a mitigation strategy of permanent preservation in situ. The PEIR Addendum at post phase two consultation confirmed no change in the assessment of likely significant archaeological effects since the PEIR. We are carrying out an assessment of the effects on the historic environment for the environmental impact assessment. We are consulting with English Heritage as part of this process. The draft CoCP at phase two consultation sets out a range of measures in respect of archaeology that would be adopted by our contractor. A full assessment of the likely significant effects of the project on the historic environment, together with any recommendations for mitigation, will be provided in the Environmental Statement for submission with the application. N Comments Total/ID number Our response C
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Ref Comments Total/ID number Our response As stated in the draft CoCP, we would implement procedures to monitor construction works appropriately in order to identify and record any archaeological finds. A temporary diversion of the Thames Path would be required whichever construction access route is selected (via Lacks Dock or between Camelford House and Tintagel House), in order to maintain a safe route to local amenities. The detailed route would be agreed with the London Borough of Lambeth and TfL. The proposed diversion would last for the duration of the works and the path would then be reinstated along its current route. The diversion would be designed to meet all appropriate design and safety standards. In our Section 48: Transport strategy we increased our commitment to river transport from phase two consultation and post phase two consultation. At this site, we propose to use river transport to remove excavated material from the shaft, connection tunnels, interceptions and associated structures and to import and export cofferdam fill materials. This use of barges would remove approximately 11,150 lorries from the road during construction. However, it is not generally practical or cost-effective to transport all materials by barge therefore some lorry movements would still be required. The Section 48: Transport Strategy states that river transport would be used throughout the construction programme at this site. It is not possible to phase the construction site boundaries over the programme. The contractor C
12.5.47
2 Provide a suitable, safe Thames Path diversion c including pedestrian crossings, diversionary g signage etc, which would need to be discussed further with TfL.
TfL
12.5.48
2 Use the river to transport more/all construction c materials and spoil. Comments included: a a. Encourage contractors to maximise the use a of wharves at all stages of construction. b. Since barges would only be used during the set-up and completion/site restoration phases of construction there should be no inflexible restrictions on barge traffic during these phases.
TfL, 14119
12.5.49
2 Suggest phasing the construction site c boundaries over the construction programme
14026
211
12 Other comments
Ref Comments to reduce the effect on the Thames Path. a z 2 Suggest using the remaining structure as a 2 boat platform for river commuters. c a j 1 Total/ID number Our response would need the whole site for the duration of the construction works in order to operate a safe and efficient site. Your comment is noted. We intend that the proposed foreshore extension at Albert Embankment Foreshore would be used as an area of public realm where visitors could enjoy enhanced views along the River Thames. The space is not intended to be used to pick up commercial river boat passengers. C
12.5.50
14140
Victoria Embankment Foreshore Supportive and neutral comments 12.5.51 1 Accept the development at this site due to the 0 significant public benefit for London. 1 Recognise that use of this site reduces the b overall number of sites required and that there a is no flexibility in the engineering parameters to d reduce the protrusion into the River Thames. 4 Concerns regarding the effect of construction e traffic emissions on air quality. 1 EH Your comments are noted and welcomed. As stated in Appendix P of the Phase two scheme development report and Section 48: Report on site selection process, we consider that Victoria Embankment Foreshore is the most suitable site. N/A
Objections, issues and concerns 12.5.52 1 TfL The draft CoCP at phase two consultation sets out measures that would be adopted during construction to limit vehicle and plant emissions, including using low emission vehicles, turning engines off when not in use and minimising vehicle movements around sites. The preliminary assessment in the PEIR (Volume 20, Section 4) stated that, with these measures in place, there would be no significant local effects on air quality from vehicle and plant emissions at this site. The PEIR Addendum (Volume 20, Section 3) at post phase two consultation concluded that the N
212
12 Other comments
Ref Comments Total/ID number Our response amendments to the proposals at this site would not materially alter the effects predicted in the PEIR. We are carrying out a full assessment, including dispersion modelling, for the Environmental Statement for submission with the application. Dispersion modelling assesses the likely significant effects of construction at all the proposed sites in terms of the relevant short- and long-term NO2 and PM10 air quality objectives. Where significant effects are identified, appropriate mitigation would be proposed. At all sites the programme would be configured to minimise the duration of construction and associated disruption to the local area as far as possible. The construction period indicated in the consultation documents comes from the PEIR (Volume 20). We anticipate that there would be periods of no or less intensive activity on some sites. The PEIR (Volume 20) includes a preliminary assessment of the likely significant effects of the project on a range of topics such as noise and vibration, air quality (including dust emissions), odour, and transport, based on a methodology that was agreed with the City of Westminster. A full assessment will be provided in the Environmental Statement for submission with the application. Where likely significant effects are identified we would implement mitigation measures, in addition to the measures set out in our draft CoCP. We are also carrying out a Health Impact Assessment to examine the likely significant effects C
12.5.53
3 Concern that the proposed working hours may 2 cause nuisance to the operation of the hotel a and the residents. a z
LR14117
213
12 Other comments
Ref Comments Total/ID number Our response of the proposed development on human mental and physical health and well-being and possible effects in the population for submission with the application. The planning status of sites was taken into account in the site selection process along with other considerations (see the Site selection methodology paper). Our team then made a professional judgement as to the impact of use of a site on its planning status. It should be noted that allocated or secured planning permissions did not preclude the use of the site. Other factors, such as whether or not the planning permission was likely to be implemented, were also considered. Even then it may be possible to phase the construction work to allow both the approved development and the project to be constructed. The PEIR (Volume 20) includes a preliminary assessment of the likely significant effects of the project on a range of topics, such as noise and vibration; air quality (including dust emissions) and odour; and transport, based on a methodology agreed with the City of Westminster. We are carrying out an environmental impact assessment, which will include a comprehensive assessment of the likely significant effects of the project. The findings of the assessment, together with any recommendations for mitigation, will be available as part of the Environmental Statement for submission with the application. We are also carrying out a Health Impact Assessment that will examine the likely significant effects of the proposed development on human health and well-being and possible effects in the C
12.5.54
1 Concerns regarding the effect of construction 4 noise and vibration on quality of life/residential k amenity for future residents.
LR14117
214
12 Other comments
Ref Comments Total/ID number Our response population. The findings of the study will inform the design for this site and any mitigation measures to address potential significant effects. We consider that we conducted a thorough and comprehensive consultation exercise. We carefully considered the information we made available at post phase two consultation to ensure that consultees had sufficient information to respond to the consultation. This included the PEIR (Volume 20, Section 9) and PEIR Addendum (Volume 20, Section 3),which provided our initial assessment of noise and airborne/groundborne vibration from construction site activities, noise from construction traffic on roads outside the site, and noise and vibration from the operational site. It also includes the assumptions that underpin the proposals in the draft CoCP. The PEIR assessment used Defra's London noise maps. We are confident, therefore, that the information we have provided is sufficient. Our Environmental Statement for submission with the application will include a noise and vibration section completed in line with a methodology agreed with the City of Westminster that complies with BS5228, BS6472 and BS7385. The CoCP for submission with the application will set out measures to be implemented by our contractor during the works to address any likely significant effects of noise and vibration. Our proposals for this site require the removal of four semi-mature London plane trees to enable access. These trees are considered to have a low intrinsic biodiversity value and are unlikely to support any C
12.5.55
1 More information is needed on noise and 4 vibration, including whether a noise report has v been carried out for the construction period and, if so, what the impact might be on residents and hotel customers at 10 Whitehall Place.
LR14117
12.5.56
6 Concerns regarding the loss of trees due to d construction activities.
TfL
215
12 Other comments
Ref Comments Total/ID number Our response notable species; however we recognise that they hold amenity and townscape value. We sought to position our site to minimise any loss of trees and our landscaping plans include replacement tree planting. All other trees on or close to the site would be subject to tree protection measures, as detailed in the draft CoCP at phase two consultation. Our contractor would implement the identified measures where practicable and in consultation with the City of Westminster tree officer. Any utilities close to or within our sites would be surveyed prior to and protected during construction. We do not consider that the presence of utilities precludes development at this site. We propose to continue in depth discussions with the City of Westminster on this issue. The proposed construction site requires a temporary diversion to the Thames Path along the northern footway of Victoria Embankment, as indicated in the site information paper at phase two consultation and the supplementary site information paper at post phase two consultation. The diversion would ensure that a safe route along Victoria Embankment remains open during construction. The detailed route would be agreed with the City of Westminster and TfL. The diversion would remain in place for the duration of the works, after which the current route would be reinstated. We do not currently intend to close Victoria Embankment as it is a key part of the road network. The proposed construction access arrangements preserve two-way traffic along Victoria Embankment C
12.5.57
2 Concerns regarding the effect of construction 7 activities on other proposed below-ground x infrastructure including the pipe subway.
TfL
12.5.58
2 Concerns regarding the disruption to or c diversion of the Thames Path due to construction works.
TfL
12.5.59
2 The proposed access route to the site would t result in local road closures, including Victoria Embankment (westbound).
TfL
216
12 Other comments
Ref Comments Total/ID number Our response (A3212) by reducing lane widths, as stated in the site information paper at phase two consultation and the supplementary site information paper at post phase two consultation. Some temporary road closures would be required elsewhere during construction. We are preparing a Traffic Management Plan that will detail which roads would be closed and the process for notifying closures. The Transport Assessment for submission with the application will also consider the likely significant effects of any closures during the construction period and detail any necessary mitigation measures. We will work closely with the City of Westminster and TfL to develop the proposals. We will also notify any affected parties. We would design site accesses and operate all of our construction sites to ensure that they meet design, and health and safety standards. The CoCP for submission with the application will include a requirement for a Traffic Management Plan to carefully control construction traffic in order to minimise any potential effects on the road network, residential amenity or access to the local area. The CoCP will also set out construction traffic routes, site access/egress points, signage and monitoring procedures. The proposals will be subject to independent external review by TfL and the local highway authority to ensure that proposed highway layouts and vehicle movement arrangements are as safe as possible. The PEIR (Volume 20, Section 12) assessed potential construction transport effects on pedestrian C
12.5.60
2 Concerns regarding the effect of construction a traffic on the safety of pedestrians, cyclists and a local residents due to the narrow carriageway on the Embankment.
TfL
12.5.61
2 Concerns regarding the cumulative transport a effects with other developments in the local
TfL
217
12 Other comments
Ref Comments area, including proposed works at Chelsea m Embankment Foreshore, Victoria Embankment Foreshore and Blackfriars Bridge Foreshore. Total/ID number Our response and cycle routes; bus and other public transport routes and patronage; parking; and highway layout, operation and capacity as well as likely significant effects on residential amenity. The assessment considered the effects of lorry and (where applicable) barge transport, based on a methodology discussed and agreed with the City of Westminster and TfL. The PEIR Addendum (Volume 20, Section 3) at post phase two consultation concluded that the amendments to the proposals at this site would not materially alter the effects predicted in the PEIR. We acknowledge that this is a preliminary assessment. We are preparing a full Transport Assessment for submission with the application, which will consider the cumulative effects of our works with other developments in the local area. In our Section 48: Transport Strategy we increased our commitment to river transport from phase two consultation and post phase two consultation. At this site, we propose to use river transport to remove excavated material from the shaft, connection tunnels, interceptions and associated structures and to import and export cofferdam fill materials. This use of barges would remove approximately 11,250 lorries from the road during construction. However, it is not generally practical or cost-effective to transport all materials by barge therefore some materials would still be transported by road. For further details on our amended transport strategy, see the Section 48: Transport Strategy. C
Mitigation suggestions 12.5.62 4 Use the river to reduce HGV movements. c a z 2 Use the river to transport more/all construction c materials and spoil. TfL requires a minimum a commitment to the level of river transport at a phase two consultation. 1 TfL C
12.5.63
PLA, TfL
218
12 Other comments
Ref 12.5.64 Comments 3 Construction hours should be 10am to 5pm 2 given the proximity to residential uses. c a y 6 Trees must be retained/ protected during c construction. h 6 Any other vegetation/habitat lost during c construction must be replaced. i 1 Total/ID number LR14117 Our response At most of our sites we plan to carry out the majority of works within standard construction industry working hours, which are 8am to 6pm weekdays, and 8am to 1pm on Saturdays. We do not therefore consider it appropriate to restrict working hours to 10am to 5pm. Our proposals for this site require the removal of seven semi-mature London plane trees to enable access. These trees are considered to have a low intrinsic biodiversity value and are unlikely to support any notable species; however, we recognise that they hold amenity and townscape value. We sought to position our site to minimise any loss of trees and our landscaping plans include replacement tree planting. All other trees on or close to the site would be subject to tree protection measures, as detailed in the draft CoCP at phase two consultation. Our contractor would implement the identified measures where practicable and in consultation with the City of Westminster tree officer. The Environmental Statement for submission with the application will include a full assessment of likely significant noise and vibration effects that will be completed in line with a methodology agreed with the City of Westminster that complies with BS5228, BS6472 and BS7385. We will develop mitigation measures to provide appropriate attenuation for any significant noise and/or vibration effects identified at a site. Our draft CoCP sets out a range of measures to minimise noise and vibration from plant and works that would be adopted by our contractor including the C N
12.5.65
TfL
12.5.66
TfL
12.5.67
1 Provide suitable mitigation to minimise the 4 impact on residential amenity. c a z
LR14117
219
12 Other comments
Ref Comments Total/ID number Our response selection of appropriate plant and equipment, siting of equipment, and use of enclosures and temporary stockpiles to provide acoustic screens. Specific measures such as acoustic suppression systems, operating equipment in a mode that minimises noise and shutting down equipment when not in use are also indicated in the draft CoCP. Our contractor would be required to comply with the CoCP, which also states that the contractor would be required to apply for Section 61 consents under the Control of Pollution Act 1974. These would set out specific working methods and measures to minimise noise and vibration as well as any appropriate monitoring measures, to be agreed with environmental health officers from the local authority. Our Settlement project information paper at phase two consultation sets out our approach to protecting against the likely significant effects of settlement associated with tunnelling. We would undertake studies to identify any potential effects of our construction work on third party structures such as buildings, bridges, tunnels and utilities. The studies may recommend particular construction methods or, in a very few cases, protection works. These measures are in line with best practice guidelines and will be detailed in the CoCP for submission with the application. We would design site accesses and operate all of our construction sites to ensure that they meet design and health and safety standards. The CoCP for submission with the application will include a requirement for a Traffic Management Plan C
12.5.68
2 Undertake protection works in relation to the 7 District, Circle and Bakerloo Line tunnels. c q
TfL
12.5.69
2 Request more information on mitigation, c including road user safety. c
TfL
220
12 Other comments
Ref Comments Total/ID number Our response to carefully control construction traffic in order to minimise any potential effects on the road network, residential amenity or access to the local area. The CoCP will also set out construction traffic routes, site access/egress points, signage and monitoring procedures. The proposals will be subject to independent external review by TfL and the local highway authority to ensure that proposed highway layouts and vehicle movement arrangements are as safe as possible. The Thames Path would be temporarily diverted via a safe alternative route along the northern footpath to Victoria Embankment. The footpath diversions would be designed to meet all appropriate design and safety standards and agreed with TfL and the City of Westminster. We will consider the demand for the existing coach parking and possible alternative locations. We will discuss any alternative provision with TfL and the City of Westminster and report our conclusions in the Transport Assessment for submission with the application. We are preparing a Transport Assessment for submission with the application, which will include a detailed analysis of potential access routes and an assessment of the likely significant effects of construction traffic on local roads, together with any necessary mitigation measures. It will also consider the cumulative effects of our works with other developments. We will work closely with TfL, the City of Westminster, local residents and other interested C
12.5.70
2 Provide a suitable, safe Thames Path diversion c with carefully designed pedestrian crossings g and diversionary signage agreed with TfL.
TfL
12.5.71
2 Provide alternative car and coach parking. c m
TfL
12.5.72
12.5.73
2 Complete a transport assessment of the c effects at Chelsea Embankment Foreshore, x Victoria Embankment Foreshore and Blackfriars Bridge Foreshore all together. 2 Other construction transport and access c mitigation suggestions included: a a. The existing capacity on A3211 Victoria z Embankment should be maintained at all times. Any lane or parking/loading capacity
TfL
TfL
221
12 Other comments
Ref Comments required should be temporary and for as short a period as possible to minimise disruption to road users. b. Further details are required in relation to the operations and logistics of the site and implications for existing river use. 12.5.74 2 Reference should be made to the procedures 2 for the Technical Approval for Highway c Structures outlined in the Design Manual for a Roads and Bridges since the low level sewer o interception chamber would affect the A3211 Victoria Embankment. 1 TfL Your comment is noted. N Total/ID number Our response groups to minimise the effects of traffic movements to and from the site. C
Chambers Wharf Supportive and neutral comments 12.5.75 1 Support for the new preferred site since phase 0 one consultation/the preferred site is more 1 suitable than the site at phase one because it b is a vacant wharf with better access. On this c basis, acquisition of the site is fully justified. The design proposals would create a new area of public/open space with interesting views of the river towards Tower Bridge. Support for the proposals because it seems that they would not impede navigation in any way. 1 Object to the use of this preferred site. 0 1 1 14119 Your support is noted and welcomed. N/A
12.5.76
14119
Your support is noted and welcomed.
N/A
12.5.77
14119
N/A
Objections, issues and concerns 12.5.78 1 14093 The sites that we consulted on were identified through an extensive site selection process (see the Site selection methodology paper on our website). N/A
222
12 Other comments
Ref a Comments Total/ID number Our response We consulted on and agreed the methodology with key stakeholders, including potentially directly affected local authorities. We used a multidisciplinary approach to assess potential main tunnel sites and drive options, having regard to engineering, planning, environmental, property and community considerations. We recognise that, given the locations in which we are seeking to construct and operate the tunnel, many of the shortlisted sites are constrained. However, based on our assessment prior to phase two consultation we consider that, on balance, Chambers Wharf is the most suitable site. This is because it is a brownfield site that has good access to the River Thames, which would enable the removal of excavated material and delivery of construction materials by barge. The site would not disrupt the Thames Path, which is already diverted around the site. Our proposals would not preclude the approved residential development on this site. We considered the feedback received at phase two consultation and we still believe that Chambers Wharf is the most suitable site. This was stated in the draft application at Section 48 publicity. For further details on the site selection process, see Appendix R of the Section 48: Report on site selection process. Following phase two consultation, we considered the feedback received along with new information and we also undertook further technical work. As a result, we still consider Chambers Wharf to be the most suitable site to drive the main tunnel to Abbey Mills Pumping Station, receive the main tunnel from C
12.5.79
1 Site selection has not incorporated comments 0 and objections at phase two consultation. 1 d
14093
N/A
223
12 Other comments
Ref Comments Total/ID number Our response Kirtling Street and receive the Greenwich connection tunnel from Greenwich Pumping Station. For further details of how we took account of phase two consultation feedback, refer to the Section 48: Report on site selection process and the Report on phase two consultation. It is not clear what major concessions is intended to mean in this context, and no specific concessions are suggested to which we can respond. In general, however, we do not accept that major concessions will be required now that Chambers Wharf has been selected as a preferred site. The Environmental Statement for submission with the application will contain an assessment of the likely significant effects of the project on a range of themes, such as noise and vibration, air quality (including dust emissions), odour, and transport, based on a methodology agreed with the London Borough of Southwark. We would develop mitigation measures in consultation with relevant stakeholders to address any likely significant effects identified, in addition to the measures set out in our draft CoCP. Landowners may have a statutory entitlement to claim compensation for any diminution in the value of property due to the construction of the tunnel. In addition to the statutory process, we have published an Exceptional hardship procedure, which sets out how we would assess claims from householders who contend that they are suffering exceptional hardship as a result of being unable to sell their property because it is potentially impacted by our currently published proposals. We also published a Guide to the Thames Tunnel compensation programme, C
12.5.80
1 Now that the project is proceeding with 0 Chambers Wharf, major concessions will be 1 required. f c
14093
N/A
224
12 Other comments
Ref Comments Total/ID number Our response which sets out details of compensation that would be available during construction for damage or loss, required protection measures or compulsory purchase. As stated in our Chambers Wharf site information paper at phase two consultation, the contractor would be required to implement noise and vibration control measures, in line with the requirements of the CoCP. The contractor would also be required to gain approval from the London Borough of Southwark prior to construction through a Section 61 application under the Control of Pollution Act, which would set out specific working methods and measures to minimise noise and vibration as well as any appropriate monitoring measures. This would ensure that noise levels are reasonable and best practice means are applied. The measures would be agreed with environmental health officers from the local authority. We would also implement best practice measures to minimise noise and vibration from plant and works including the selection of appropriate plant and equipment, siting of equipment, and use of acoustic screening enclosures. At this site the shaft would also be enclosed. Full details of the measures that would be adopted during construction will be set out in the CoCP for submission with the application. The PEIR (Volume 22, Section 9) sets out our preliminary assessment of likely significant noise and vibration effects from construction site activities, noise from construction traffic on roads outside the site, and noise and vibration from the operational site. This assessment informed the proposed C
12.5.81
12.5.82
1 Concerns regarding noise and vibration from 4 above-ground construction activity including c spoil sorting. 1 Concerns regarding noise and vibration from 4 underground tunnelling, specifically the d Greenwich connection tunnel drive.
14093
14093
225
12 Other comments
Ref Comments Total/ID number Our response mitigation measures in our draft CoCP. The PEIR assessment used Defra's London noise maps. The Environmental Statement for submission with the application will include an assessment of noise and vibration completed in line with a methodology agreed with the London Borough of Southwark that complies with BS5228, BS6472 and BS7385. In our Section 48: Transport Strategy we increased our commitment to river transport from phase two consultation and post phase two consultation. At this site, we propose to use river transport to export excavated material from the shaft and main tunnel, to import and export cofferdam fill material, and to import sand and aggregates for the main tunnel secondary lining. This use of barges would remove approximately 59,300 lorries from the road during construction. However, it is not generally practical or cost-effective to transport all materials by barge therefore some materials would still be transported by road. We intend to maximise the use of the river to transport construction materials and excavated materials throughout the construction programme. For further details on our amended transport strategy, see the Section 48: Transport Strategy. C
Mitigation suggestions 12.5.83 2 Request more information on transport c mitigation including confirmation of the c percentage of materials that would be delivered and removed by barge and the resulting reduction in traffic volume over the construction period. 2 Use the river to transport more/all construction c materials and spoil. Comments included: a a. Encourage contractors to maximise the use a of wharves at all stages of construction. b. Since barges would only be used during the set-up and completion/site restoration phases of construction, there should be no inflexible restrictions on barge traffic during these phases. 1 14093 C
12.5.84
14119
Greenwich Pumping Station Supportive and neutral comments 12.5.85 Dont know/unsure whether the right key issues associated with the operational site and 1 15000 Your comment is noted. N/A
226
12 Other comments
Ref Comments measures to address them were identified in the phase two Greenwich Pumping Station site information paper. 1 Object to the use of this preferred site. 0 1 a 1 Total/ID number Our response C
Objections, issues and concerns 12.5.86 15000 The sites that we consulted on were identified through an extensive site selection process (see the Site selection methodology paper on our website). We consulted on and agreed the methodology with key stakeholders, including potentially directly affected local authorities. We used a multidisciplinary approach to assess potential CSO and long connection tunnel sites, having regard to engineering, planning, environmental, property and community considerations. We recognise that, given the locations in which we are seeking to construct and operate the tunnel, many of the shortlisted sites are constrained. However, based on our assessment prior to phase two consultation, we consider that, on balance, Greenwich Pumping Station is the most suitable site. This is principally because Thames Water owns most of the site. Although the pumping station is a Grade II listed structure, positioning our works to the north of the pumping station site would greatly reduce any potential effect on its setting. We considered all the phase two consultation feedback received and we still believe that Greenwich Pumping Station is the most suitable site, as stated in our draft application at Section 48 publicity. For further details on the site selection process, refer to Appendix V of the Section 48: Report on site selection process. N/A
227
12 Other comments
Ref 12.5.87 Comments 1 The preferred site is currently occupied by 0 Jewson; demolition would be necessary in 1 order to proceed with the proposals. a j Use/consider an alternative site. Do not agree that the right key issues associated with the construction site and measures to address them were identified in the phase two consultation Greenwich Pumping Station site information paper. 1 Total/ID number 15000 Our response Refer to our response at para. 12.5.86. The PEIR (Volume 26, Section 10) states that two businesses located on the site would require relocation during construction. The Environmental Statement for submission with the application will assess the likely significant effects of business relocation. We will assist the directly affected businesses to find alternative premises. The purpose of the key issues in the Greenwich Pumping Station site information paper and measures proposed to address them was to provide a broad overview of likely significant effects associated with the site during construction. It is not, however, an exhaustive list. A more detailed description of likely significant effects and the methodology used to identify and assess them is provided in other technical reports, including the PEIR (Volume 26). We are carrying out an environmental impact assessment, which will include a comprehensive assessment of likely significant effects of the project and measures to address them. The findings of the assessment, together with any recommendations for mitigation, will be available in the Environmental Statement for submission with the application. The PEIR (Volume 26, Section 10) states that two businesses located on the site would require relocation during construction. The Environmental Statement for submission with the application will assess the likely significant effects of business relocation. We will assist the directly affected businesses to find alternative premises. C N/A
12.5.88 12.5.89
1 1
15000 15000
N/A N/A
12.5.90
1 Concerns regarding the detrimental effect on 6 business operations; it is unlikely that suitable e alternative premises could be found for Jewson, which would lead to loss/closure of the business. Concerns regarding the loss of local jobs
15000
12.5.91
15000
228
12 Other comments
Ref 12.5.92 Comments resulting from the extinguishment of Jewson. Do not agree that the right site-specific issues that influence the permanent design for the site were identified. 1 Total/ID number 15000 Our response Our view of the most significant site-specific issues in relation to the permanent design of the site is set out in the Greenwich Pumping Station site information paper. It is not, however, an exhaustive list, and further potential issues associated with the site are detailed in the PEIR (Volume 26) and Design development report. We are carrying out an environmental impact assessment, which will include a comprehensive assessment of likely significant effects of the project. The findings of the assessment, together with any recommendations for mitigation, will be available in the Environmental Statement for submission with the application. Your comments in relation to the design of our proposed scheme are noted. The design follows our project-wide principles and takes account of phase one consultation feedback, on-going discussions with consultees and a design review with the Design Council CABE. The Design development report at phase two consultation sets out the principles that informed our design in more detail. C N
12.5.93
2 Do not support the proposals for the 2 permanent design and appearance of the site. a
15000
King Edward Memorial Park Foreshore Objections, issues and concerns 12.5.94 1 Object to the use of this preferred site. 0 1 a 1 Engineering reasons for selecting a site should 0 2 15000, 14094 The sites that we consulted on were identified through an extensive site selection process (see the Site selection methodology paper on our website). We consulted on and agreed the methodology with key stakeholders, including potentially directly affected local authorities. We used a N/A
12.5.95
15000, 14083
N/A
229
12 Other comments
Ref Comments not override environmental and community 1 considerations. On this basis, Heckford Street f is more appropriate than King Edward b Memorial Park Foreshore. 1 Use/consider an alternative site. King Edward 0 Memorial Park is a precious resource for the 1 community that is used recreationally and i enhances residents quality of life. 1 Site selection has not incorporated comments 0 and objections at phase two consultation. 1 d Total/ID number Our response multidisciplinary approach to assess potential CSO sites, having regard to engineering, planning, environmental, property and community considerations. We recognise that, given the locations in which we are seeking to construct and operate the tunnel, many of the shortlisted sites are constrained. However, based on our assessment prior to phase two consultation, we consider that, on balance, King Edward Memorial Park Foreshore is the most suitable site. This is because the CSO can be intercepted and connected to the main tunnel at one site, which also eliminates the cumulative effects of simultaneous construction works at two sites. It would avoid direct impacts on businesses and enable the use of river transport. The tunnels would also pass under fewer buildings at this site. The majority of the worksite lies in the foreshore and we sought to minimise potential effects on the park as far as possible. We considered the feedback received at phase two consultation and we still believe that King Edward Memorial Park Foreshore is the most suitable site, as stated in our draft application at Section 48 publicity. For further details on the site selection process, refer to Appendix S of the Section 48: Report on site selection process. We re-assessed the potential sites prior to phase two consultation and reviewed the phase two consultation feedback; however we still consider that Heckford Street is less suitable than our preferred site. This is because it would require a site within King Edward Memorial Park as well as the Heckford C
12.5.96
15000, 14082
N/A
12.5.97
15000, 14094
N/A
12.5.98
1 The shortlisted Heckford Street site is more 0 suitable. 1 k
14094
N/A
230
12 Other comments
Ref Comments Total/ID number Our response Street site. The additional tunnelling works would likely take longer, cause more disruption to park users and the local community, require some 24hour construction works, and increase traffic on local roads. The two sites would also result in disruption to and potential loss of businesses, which would conflict with council planning policies to protect employment uses. It would not be possible to use the River Thames to transport construction materials. Finally, the tunnels would have to pass below many more buildings than at the preferred site and the connection tunnel would be at a much shallower depth. C
12.5.99
1 Reasons for not selecting the shortlisted 0 Heckford Street site are unjustified/incorrect/ 1 flawed. l 1 The site selection methodology is 0 incorrect/flawed/unjustified. The criteria mean 1 that the issues are weighted. q
LR15001, 14094 We consider that we have sufficiently justified the choice of our preferred site and explained why other shortlisted sites are less suitable. Refer to Appendix S of the Section 48: Report on site selection process for further details. LR15001, 14083 The sites on which we consulted were identified through an extensive site selection process (see the Site selection methodology paper on our website), having regard to environmental, planning, engineering, property and community considerations. Our methodology was agreed with key stakeholders, including potentially directly affected local authorities. The methodology does not include a quantitative scoring or weighting element, as this is not considered best practice. The methodology relies instead on increasingly detailed studies at each stage of the process, and our teams reached balanced decisions on the suitability of sites on the basis of their professional judgement.
N/A
12.5.100
N/A
231
12 Other comments
Ref 12.5.101 Comments 6 Concerns regarding the loss of trees due to d construction activities, particularly along the access route. 2 Total/ID number Our response C N
LR15001, 14083 We sought to minimise tree loss and damage as far as possible. Our draft CoCP describes how we would protect existing trees during construction. Measures such as erecting protective fencing and banning the storage of materials within the protected area would be implemented prior to the works (as specified in BS5837) where practicable and in consultation with the London Borough of Tower Hamlets tree officer. Our permanent site landscaping proposals include planting more trees than would be lost during construction.
12.6
12.6.1

We received a range of feedback that did not relate to the direct scope of post phase two consultation. In accordance with the requirements of the 2008 Act, we considered all of the feedback received. While some comments did lead us to consider changes to our proposals, the majority of these changes were under already consideration in response to phase two consultation and further technical work.
12.7
12.7.1 12.7.2 12.7.3
Feedback in relation to our approach to consultation

The supportive and neutral comments and objections, issues and concerns in relation to our approach to post phase two consultation are set out in Table 12.6. The feedback is grouped by theme, as denoted by the sub-headings shaded in blue, and the orange sub-headings categorise the feedback as supportive and neutral comments or objections, issues and concerns. Two community consultees confirmed that they had previously taken part in project consultation activities and one confirmed submitting feedback to phase two consultation. Two community consultees also confirmed that they had attended an exhibition and spoken to a member of the project team (one of the consultees specifically noted an exhibition on 25 June).
232
12 Other comments Table 12.6 Feedback in relation to our approach to consultation

Ref Consultation materials Objections, issues and concerns 12.7.4 6 Information and materials provided at 6 consultation were inaccurate. There was a p disconnect between the information on the website and the latest proposed changes. 1 14099 It was imperative to provide a balanced analysis in our consultation material and we do not agree that the material was inaccurate. We carefully considered the information we made available at post phase two consultation and believe that the information was sufficient to explain the proposed changes to the project following phase two consultation. The information available at post phase two consultation was clearly identified as such on our website. Comments Total/ID number Our response
Consultation strategy Supportive and neutral comments 12.7.5 Thames Water has taken on board and responded to feedback at previous phases of consultation. No further comments to make on the consultation process. a More people should have been directly informed a about post phase two consultation. Comments included: 1 14115 Your support is noted and welcomed.
12.7.6
15000
Your comment is noted.
Objections, issues and concerns 12.7.7 7 14052LO, 14104LO, 14089, 14097, MD14102, 14096PET, 14099 As stated in Section 3.4 and 3.5, we notified statutory consultees, local authorities, landowners and community consultees in accordance with the requirements of the 2008 Act. We also publicised our proposals in accordance with our published SOCC, as stated in Section 3. We also provided information on our proposals in this year's customer bill leaflet. See Section 2 of the Main report on phase two consultation for further details of the publicity we carried out. We consider that the area to which we
233
12 Other comments
Ref Comments a. Thames Water has not consulted with local residents in respect of either the proposed increase in the scale of the tunnel or rerouting it away from the River Thames to pass directly under properties on the north side of Lillian Road. Total/ID number Our response distributed consultation letters was appropriate. At phase two consultation we proposed to increase the scale and adjust the alignment of the main tunnel between Barn Elms and Acton Storm Tanks. We sent letters to Lillian Road residents in November 2011 to inform them of the start of phase two consultation and explain how they could provide feedback on our proposals. On 4 November 2011, we published our SOCC, which sets out our approach to consultation, in the London Evening Standard. The SOCC stated that it may be necessary to amend our proposals following phase two consultation. We would then consider on a site-by-site basis whether the changes were relevant to the comments received at phase two consultation and, where appropriate, undertake targeted consultation. In accordance with this approach, we did not consider it necessary to notify Lillian Road residents of targeted consultation since the alignment in this area had not changed between phase two consultation and targeted consultation. In fact, the proposed limit of deviation for this section of the main tunnel is now smaller than at phase two consultation, which would reduce potential effects on properties at Lillian Road. We agreed our approach to notifying community consultees of our proposals with the potentially directly affected local authorities prior to phase two consultation. We conducted an extensive land referencing exercise to identify landowners that might be directly affected by our proposals. Sections 3.4 and 3.5 clearly set out whom we notified and the reasons why. Based on our approach for notifying landowners of changes to the tunnel alignments we did not consider it necessary to
b. Not all parties potentially affected by the proposals were notified of the proposed changes and consultation, therefore the project failed to comply with the requirements of the 2008 Act and its own consultation strategies. In order to remedy this, the project should extend the consultation deadline for the school.
234
12 Other comments
Ref Comments Total/ID number Our response notify St Pauls School. The proposed limit of deviation for this section of the main tunnel is now smaller than at phase two consultation, which would reduce potential effects on the school. We promoted the exhibitions in local newspapers (see Section 3.4) and in the letters posted prior to targeted consultation (see Section 3.4). We consulted potentially directly affected local authorities on how we proposed to publicise and undertake targeted consultation, before publishing our SOCC on 4 November 2011. We did not receive any adverse feedback in relation to our approach. We used a range of methods to publicise post phase two consultation (see Section 3.4 and 3.5) all of which complied with the statutory requirements and government guidance on pre-application consultation. Therefore we do not agree that the project and consultation activities were kept lowkey. An integral part of the pre-application process is the legal requirement to consult with the communities and stakeholders along the tunnel route on the sites we propose to use to construct and operate the project and to have regard to all feedback received. We must also comply with guidance issued by the DCLG in respect of pre-application consultation. The process is intended to be open and transparent and to ensure that project promoters give careful consideration to consultation responses and, where appropriate, adjust their proposals accordingly. We are committed to this approach. In accordance with the legal requirements, we considered all the feedback received at each stage of consultation. We
12.7.8
12.7.9
6 The exhibitions were badly publicised; some 7 respondents only learnt about the event at the f Wetlands Centre by chance and information was not delivered directly to local residents. 6 Thames Water is deliberately keeping the 7 project and consultation low-key. In particular, it is a informing residents of the effects of the not e project.
LR15001
14084
12.7.10
12.7.11
6 Thames Water has not taken account of 7 feedback from phase two consultation. There is a no information on the project website to confirm h that it considered previous representations. 6 There is a lack of transparency regarding the 7 project, consultation and the decisions that have a been made, particularly in relation to Carnwath k Road Riverside and alternative solutions to the tunnel.
14118LO, 14120LO, 14122 14084, 14094
235
12 Other comments
Ref Comments Total/ID number Our response published reports setting out the details of the feedback received and our responses following phase one consultation, interim engagement, phase two consultation and now post phase two consultation. The reports are publicly available on our website or on CD on request. Our Report on phase two consultation responded to feedback received in relation to Carnwath Road Riverside and alternative solutions to the tunnel. Our DCO application must be accompanied by a consultation report explaining how we responded to public consultation, including explanations of instances in which feedback did not lead to any changes. The process is intended to be open and transparent to ensure that project promoters carefully consider consultation responses and, where necessary, adjust their proposals accordingly. We do not agree that the targeted consultation and Section 42 modifications to site boundaries and the tunnel alignment consultation feedback form was constricting. Questions 1 and 2 sought respondents details and the capacity in which they responded, in accordance with the requirements of the 2008 Act. The remainder of the feedback form comprised open questions requesting views on our revised proposals and was formatted to be as flexible as possible. All the comments received, however they were submitted, were considered and included in this report. We note that the respondent did not raise any particular failings regarding our alleged failure to comply with statutory requirements. We devised and implemented our consultation strategy to meet the requirements of the 2008 Act and had regard to the DCLGs guidance on pre-application consultation and
12.7.12
6 The targeted consultation and Section 42 7 modifications to site boundaries and the tunnel a alignment consultation feedback form didn't ask q the right questions; it was constricting.
LR14130
12.7.13
6 Phase two consultation, including the Report on 7 phase two consultation, has not fulfilled the prea application consultation requirements of the a 2008 Act. d
14093
236
12 Other comments
Ref Comments Total/ID number Our response relevant Planning Inspectorate advice notes. It is a requirement of the 2008 Act to consult with potentially directly affected local authorities on the SOCC prior to commencing consultation. In June and July 2011 we reconsulted on our SOCC with potentially directly affected local authorities and secured a broad agreement on our proposed approach. Our approach to producing material was to make information available to members of the community in an accessible form and to provide more detailed technical information to technical consultees, in accordance with DCLG guidance on pre-application consultation. Our Report on phase two consultation is not the consultation report required by Section 37(3) (c) of the 2008 Act, nonetheless we had regard to advice published by the Planning Inspectorate and the DCLG on the content of the consultation report. Specifically, we had regard to paras. 94 to 102 of the DCLGs Guidance on preapplication consultation (September 2009) and the Planning Inspectorates Advice note fourteen (April 2012). We believe that our phase two consultation complied with the relevant statutory requirements. For further details on compliance with statutory guidance, refer to Section 3 of our Main report on phase two consultation. We therefore do not agree that we did not fulfil the preapplication consultation requirements of the 2008 Act. We clearly stated that feedback would also be accepted via letters and email. This is demonstrated by the fact that at phase two consultation we accepted 4,217 responses in the form of alternative questionnaires, emails, letters and petitions. We followed the same approach at post phase two consultation.
12.7.14
6 Not clear whether any consideration was given to7 feedback submitted by any means other than a the feedback forms at phase two consultation. a e
14094
237
12 Other comments
Ref 12.7.15 Comments 6 The telephone number on feedback form is a 7 generic rather than a dedicated line for the a project. a f 1 Total/ID number MD14102 Our response The telephone number on the feedback form (0800 0721 086) directs callers to our Customer Centre, which handles all calls in relation to the project alongside other enquiries to Thames Water. Callers have the option to press 1 to discuss the project. Any callers who wish to speak to a member of the project team during working hours are transferred by the Customer Centre. Outside of working hours, callers are contacted the next working day. The proposals have undergone several revisions in response to feedback from phase one and phase two consultation. Feedback received at post phase two consultation was considered prior to publicising our proposed application at Section 48 publicity. Our Settlement project information paper provides information on our approach to controlling and limiting ground movement, which can cause settlement, associated with construction of the tunnel. We acknowledge that construction of the tunnel would cause some small movements in the ground, the size of which would depend on a range of factors including the size and depth of construction works and the existing ground conditions. The use of modern tunnelling methods and the depth of our tunnels, which are generally much deeper than most other tunnels under London, minimises the likelihood of ground movement. We are carrying out an assessment of the potential effects of ground movement in advance of the works. Where necessary, we would carry out protective measures. We would monitor actual ground movement during and after tunnelling to check that the ground is reacting as predicted. We would also carry out a defects survey on buildings located over, or close to, our tunnels and worksites where
12.7.16
6 The project should fully consult with local 7 residents on its proposals. a a h 6 Request further information on pre- and post7 tunnelling house surveys and compensation for a any blight on houses due to tunnelling or a possible reductions in house prices. z
14052LO, 14099, 14096PET LR15001
12.7.17
238
12 Other comments
Ref Comments Total/ID number Our response necessary. The method we used to assess settlement is similar to that used for the Channel Tunnel Rail Link, the Jubilee Line Extension, and Crossrail. Further details on our compensation programme are provided in A guide to the Thames Tunnel compensation programme (available on our website).
239
13 Conclusions and next steps
13
13.1
13.1.1
Conclusions and next steps

Targeted consultation
We received a range of comments on the proposed changes to our sites at targeted consultation. We took all the feedback received into account in accordance with the requirements of the 2008 Act.
Barn Elms
13.1.2 Having considered the feedback received, we still believe that the revised access route is the most suitable. This conclusion is reflected in the material produced for Section 48 publicity.
Putney Embankment Foreshore

13.1.3 No new information that might change the conclusions of our site selection process was brought to light at targeted consultation. Putney Embankment Foreshore therefore remains our preferred site to connect the Putney Bridge CSO to the main tunnel. Having considered the feedback received, we still believe that our targeted consultation proposals appropriately address the local context and that it is not necessary to revise our proposed approach for the application.
13.1.4
Albert Embankment Foreshore

13.1.5 The alternative construction access between Camelford House and Tintagel House presented at targeted consultation raised objections from stakeholders. This is an exceptional combination of circumstances and we therefore intend to submit both access options in the application. The access route will be considered and decided as part of the examination of the application. We also propose to include measures to manage the current emergency access requirements during construction in the CoCP Part B for submission with the application. We will also discuss the arrangement of our works with the management of the buildings in order to maintain ongoing access for maintenance and cleaning purposes during the works. Full details of these changes will be set out in the application for development consent.
13.1.6
13.1.7
Victoria Embankment Foreshore

13.1.8 As illustrated in the Section 48 publicity material, we have amended the layout and shape of the permanent design in response to targeted consultation feedback. The revised layout is more formal and symmetrical than at phase two consultation and targeted consultation, and does not project as far into the river. We had regard to comments from English Heritage and the Design Council CABE in the design development process. The revised design was influenced by the historic environment of Victoria Embankment and seeks to emulate the more formal layout of the townscape in this area.
240
13 Conclusions and next steps 13.1.9 Our preferred option remains to relocate the Tattershall Castle to a temporary mooring to the south of our site during construction and then to move her back north, as close to her existing location as possible, once the works are complete. We are considering permanently removing the Hispaniola and putting the Tattershall Castle in the Hispaniolas place. Discussions with the owners, the City of Westminster and the PLA are ongoing.
13.2
13.2.1
Section 42 consultation
Modifications to site boundaries
We received a number of comments on the proposed modifications to site boundaries that we consulted on at Section 42 consultation. We received project-wide and non-site-specific feedback as well as specific comments in respect of Cremorne Wharf Depot and Chelsea Embankment Foreshore. No feedback was received that would lead us to change the proposed site boundaries. Therefore, our draft application at Section 48 publicity includes the site boundaries illustrated at Section 42 consultation.
13.2.2
Modifications to the tunnel alignment

13.2.3 We received a range of objections, issues and concerns in respect of the proposed modification to the preferred tunnel alignment at Section 42 consultation. The majority of the feedback received related to the Lillian Road/St Pauls School area, No feedback was received that would lead us to change the preferred tunnel alignment. Therefore, our draft application at Section 48 publicity includes the preferred tunnel alignment presented at Section 42 consultation.
13.2.4
Ground water abstraction

13.2.5 The feedback in respect of ground water abstraction included comments on the effects of ground water abstraction and responses to the project-wide questions that we consulted on at phase two consultation. In response to comments on the effects of ground water abstraction, we are considering site-specific mitigation measures that would be incorporated in our Environmental Statement for submission with the application. In response to the project-wide comments, we do not believe that any new information or issues were raised that would lead us to change our proposals. Our proposals set out in the draft application at Section 48 publicity was not revised as a result of this feedback.
13.2.6
13.2.7
241
13 Conclusions and next steps
13.3
13.3.1
Next steps
On 16 July 2012 we published our draft application in accordance with the requirements of Section 48 of the 2008 Act. Before publishing the draft application, we reviewed all of the feedback received in order to determine whether any changes to our preferred scheme were required. The feedback received at post phase two consultation will be reported in the Consultation Report for submission with the application.
13.3.2
242
Appendices
Appendices
List of tables
Page number
Table A.1 List of statutory consultees ..................................................................... 244 Table A.2 List of local authorities ............................................................................ 248 Table B.1 List of newspaper advertisements .......................................................... 250 Table C.1 Means of invitation ................................................................................. 251 Table E.1 List of town halls and libraries where post phase two consultation information was available ............................................................................... 254 Table F.1 List of targeted consultation exhibitions .................................................. 257 Table H.1 Modifications to site boundaries ............................................................. 260
243
Appendices
Appendix A:Statutory consultees, local authorities and the GLA

Table A.1 List of statutory consultees
Statutory consultees Greater London Authority (GLA) The Health and Safety Executive NHS London Natural England English Heritage London Fire Brigade/London Fire and Emergency Planning Authority Metropolitan Police Authority The Environment Agency Commission for Architecture and the Built Environment London Development Agency The Equality and Human Rights Commission The Commission for Sustainable Development The Homes and Communities Agency The Joint Nature Conservation Committee The Marine and Fisheries Agency The Civil Aviation Authority The Highways Agency Integrated Transport Authorities and Passenger Transport Executives Department for Transport Relevant Highways Authority Transport for London and London Boroughs The Rail Passengers Council The Disabled Persons Transport Advisory Committee The Office of Rail Regulation and approved operators The Gas and Electricity Markets Authority The Water Services Regulation Authority (Ofwat) Waste Regulation Authorities City of London Corporation Waste Authority City of Westminster Waste Authority London Borough of Greenwich Waste Authority
244
Appendices
Statutory consultees London Borough of Lewisham Waste Authority London Borough of Southwark Waste Authority London Borough of Tower Hamlets Waste Authority East London Waste Regulation Authority North London Waste Regulation Authority West London Waste Regulation Authority Western Riverside Waste Regulation Authority British Waterways Trinity House The Health Protection Agency London Regional Resilience Forum Communications and Media 186K AboveNet Communications UK BT Cable and Wireless City of London Telecommunications (COLT) Comsol ConocoPhillips (UK) Ltd Easynet Telecom Fibernet FibreSpan Gamma Telecommunications GEO Networks Ltd Global Crossing (UK) Telecomms Ltd GO Mobile (UK) Ltd H20 Networks Ltd Hutchinson 3G UK Ltd Interoute Communications Ltd J.C Decaux (UK) Ltd Kingston Communications Group KPN Telecom UK Ltd Level (3) Communications MCI/Worldcom Ltd
245
Appendices
Statutory consultees More Group UK O2 (UK) Ltd Orange Telecom Spectrum Interactive TATA group TeliaSonera Thus plc T-Mobile (UK) Ltd Urband Ltd Verizon Business Virgin Media Rail Crossrail Docklands Light Railway (DLR) London Rail London Underground Ltd (LUL) Network Rail Water Transport Port of London Authority Marine Management Organisation Postal Services Royal Mail Utilities Dalkia Utilities services plc E.ON EDF Energy Gas Transportation Company National Grid Scottish & Southern Energy plc Serco Gulf Engineering LTD Shell Gas Direct Southern Gas Network Thames Water Total Fina Elf Pipelines
246
Appendices
Statutory consultees The Crown Estate Commissioners Secretary of State for Transport Defra Department for Trade and Industry Sport England Theatres Trust
247
Appendices Table A.2 List of local authorities

Local authorities City of London Corporation City of Westminster London Borough of Ealing Royal Borough of Greenwich London Borough of Hammersmith & Fulham London Borough of Lambeth London Borough of Newham London Borough of Richmond upon Thames London Borough of Southwark London Borough of Tower Hamlets London Borough of Wandsworth Royal Borough of Kensington & Chelsea Royal Borough of Kingston Upon Thames Brentwood Borough Council Broxbourne Borough Council Buckinghamshire County Council Dartford Borough Council Elmbridge Borough Council Enfield Council Epping Forest District Council Epsom & Ewell Borough Council Essex County Council Hertfordshire County Council Hertsmere Borough Council Kent County Council London Borough of Barking and Dagenham London Borough of Barnet London Borough of Bexley London Borough of Brent London Borough of Brent London Borough of Bromley London Borough of Camden
248
Appendices
Local authorities London Borough of Croydon London Borough of Hackney London Borough of Haringey London Borough of Harrow London Borough of Havering London Borough of Hillingdon London Borough of Hounslow London Borough of Islington London Borough of Lewisham London Borough of Merton London Borough of Newham London Borough of Redbridge London Borough of Sutton London Borough of Waltham Forest London Thames Gateway Development Corporation ODA Planning Decisions Team Sevenoaks District Council Slough Borough Council South Bucks District Council Spelthorne Borough Council Surrey County Council Tandridge District Council Three Rivers District Council Thurrock Borough Council Welwyn Hatfield District Council
249
Appendices
Appendix B: List of newspaper advertisements

Table B.1 List of newspaper advertisements
Site name Barn Elms Putney Embankment Foreshore Victoria Embankment Foreshore Newspaper/s Richmond & Twickenham Times Wandsworth Guardian Series West End Extra Camden New Journal Lambeth Post South London Press Space Quarter page Quarter page Quarter page Quarter page Quarter page Quarter page Size (mm) 160 x 143 160 x 143 Insertion date 18/05/2012 17/05/2012
170 x 146 170 x 146 170 x 130 170 x 130
17/05/2012 18/05/2012 17/05/2012 18/05/2012
250
Appendices
Appendix C: Means of invitation and copies of invitation letters

Table C.1 Means of invitation
Consultee Abstraction borehole owners Local authorities and statutory consultees Community groups (not area specific) New landowners Barn Elms Putney Embankment Foreshore Albert Embankment Foreshore Victoria Embankment Foreshore Other sites New maybe affected by a site Barn Elms Putney Embankment Foreshore Albert Embankment Foreshore Victoria Embankment Foreshore Other sites New may acquire your subsoil New maybe affected by a site and we may acquire subsoil General notification Barn Elms Albert Embankment Foreshore Victoria Embankment Foreshore Other sites Site Letter reference 100-CO-CMNMULTI-000035 100-CO-CMNMULTI-000036 100-CO-CMNMULTI-000037 100-CO-CMNMULTI-000031 100-CO-CMNMULTI-000043 100-CO-CMNMULTI-000049 100-CO-CMNMULTI-000045 100-CO-CMNMULTI-000038 100-CO-CMNMULTI-000032 100-CO-CMNMULTI-000042 100-CO-CMNMULTI-000028 100-CO-CMNMULTI-000046 100-CO-CMNMULTI-000039 100-CO-CMNMULTI-000040 100-CO-CMNMULTI-000033 100-CO-CMNMULTI-000029 100-CO-CMNMULTI-000047 100-CO-CMN06/06/2012 06/06/2012 06/06/2012 Date sent 06/06/2012 06/06/2012 06/06/2012 06/06/2012
251
Appendices
Consultee Everyone within 250m of 4 sites, excluding those in areas who received Letters 12 to 15 Site Barn Elms Putney Embankment Foreshore Albert Embankment Foreshore Victoria Embankment Foreshore Letter reference MULTI-000041 100-CO-CMNMULTI-000034 100-CO-CMNMULTI-000030 100-CO-CMNMULTI-000048 Date sent 06/06/2012
252
Title; First Name; Surname Position Organisation Address 1 Address 2 Address 3 Address 4; Address 5
Thames Tunnel - June 2012

Phone Email Our ref Land Parcel 0800 0721 086 thames.tunnel@thameswater.co.uk 100-CO-CMN-MULTI-000028 INSERT FIELD
Dear [Title; Surname]
Thames Tunnel Albert Embankment Foreshore

I am writing to let you know about some important proposed changes to the Thames Tunnel project. In February 2012, we completed our phase two consultation on the proposed Thames Tunnel, a major new sewer urgently needed to help tackle the problem of sewage overflows from Londons Victorian sewerage system into the River Thames. Since then, we have made some further changes to our plans in response to comments which we have received, and as these changes affect local communities we are carrying out a targeted consultation in your area. We are consulting on a potential alternative access arrangement and are seeking views on a construction access route from Albert Embankment via a temporary road between Tintagel House and Camelford House. We do not need to acquire your property for our project, but you may be affected by the construction and possibly the future operation of the Thames Tunnel. More detailed information on the changes we are proposing since our phase two consultation is available on our website www.thamestunnelconsultation.co.uk, and at our exhibitions. If you would like to speak to a member of the team to find out more please call 0800 0721 086. The consultation will last for 28 days, and will start on 6 June 2012 and close on 4 July 2012 at 5pm. We must receive all your comments by the closing date. It is your chance to make your views on our revised proposals known so that we can take them into account before we finalise the design and publicise it prior to formally submitting our application for consent to construct the Thames Tunnel in early 2013. If approved, main construction would start in 2016. Thank you for your time and I look forward to receiving your comments on our revised proposals. Yours sincerely,
Phil Stride Head of London Tideway Tunnels Thames Water
Details overleaf
Page 1 of 2
If you have any questions please call us on 0800 0721 086 You can give us your feedback by contacting us in a number of ways
Online complete our online form at www.thamestunnelconsultation.co.uk Paper copy please call 0800 0721 086 and we can send you a form. Exhibitions visit us to find out more. Paper copies of our forms will be available. Email thamestunnel@thameswater.co.uk Write to us Thames Tunnel Consultation, Thames Water Utilities, Freepost SCE 9923, PO Box 522, Swindon SN2 8LA
Visit our public exhibitions

13 and 14 June 2012, 2pm 8pm
WWT London Wetland Centre, Queen Elizabeths Walk, SW13 9WT 8 Northumberland Avenue, London, WC2N 5BY
18 and 19 June 2012, 2pm 8pm

Park Plaza Riverbank London, 18 Albert Embankment, SE1 7TJ
20 and 21 June 2012, 2pm 8pm

London Rowing Club, Embankment, Putney, SW15 1LB
Thames Tunnel Consultation, Freepost SCE9923, PO Box 522, Swindon, SN2 8LA www.thamestunnelconsultation.co.uk
Registered in England and Wales No. 2366661 Registered office Clearwater Court, Vastern Road, Reading, Berkshire, RG1 8DB
Page 2
Thames Tunnel June 2012


I am writing to let you know about some important proposed changes to the Thames Tunnel project. In February 2012, we completed our phase two consultation on the proposed Thames Tunnel, a major new sewer urgently needed to help tackle the problem of sewage overflows from Londons Victorian sewerage system into the River Thames. Since then, we have made some further changes to our plans in response to comments which we have received, and as these changes affect local communities we are carrying out a targeted consultation in your area. We are consulting on a potential alternative access arrangement and are seeking views on a construction access route from Albert Embankment via a temporary road between Tintagel House and Camelford House. You may be affected by the construction and possibly the future operation of the tunnel. In addition, in order to build the tunnel we may also need to acquire subsoil rights below your property. More detailed information on the changes we are proposing since our phase two consultation is available on our website www.thamestunnelconsultation.co.uk, and at our exhibitions. If you would like to speak to a member of the team to find out more please call 0800 0721 086. The consultation will last for 28 days, and will start on 6 June 2012 and close on 4 July 2012 at 5pm. We must receive all your comments by the closing date. It is your chance to make your views on our revised proposals known so that we can take them into account before we finalise the design and publicise it prior to formally submitting our application for consent to construct the Thames Tunnel in early 2013. If approved, main construction would start in 2016. Thank you for your time and I look forward to receiving your comments on our revised proposals. Yours sincerely
Details Overleaf
Page 1 of 2

13 and 14 June 2012, 2pm 8pm
18 and 19 June 2012, 2pm 8pm

20 and 21 June 2012, 2pm 8pm

Page 2


I am writing to let you know about some important proposed changes to the Thames Tunnel project. In February 2012, we completed our phase two consultation on the proposed Thames Tunnel, a major new sewer urgently needed to help tackle the problem of sewage overflows from Londons Victorian sewerage system into the River Thames. Since then, we have made some further changes to our plans in response to comments which we have received, and as these changes affect local communities we are carrying out a targeted consultation in your area. We are consulting on a potential alternative access arrangement and are seeking views on a construction access route from Albert Embankment via a temporary road between Tintagel House and Camelford House. More detailed information on the changes we are proposing since our phase two consultation is available on our website www.thamestunnelconsultation.co.uk, and at our exhibitions. If you would like to speak to a member of the team to find out more please call 0800 0721 086. The consultation will last for 28 days, and will start on 6 June 2012 and close on 4 July 2012 at 5pm. We must receive all your comments by the closing date. It is your chance to make your views on our revised proposals known so that we can take them into account before we finalise the design and publicise it prior to formally submitting our application for consent to construct the Thames Tunnel in early 2013. If approved, main construction would start in 2016. Thank you for your time and I look forward to receiving your comments on our revised proposals. Yours sincerely,
Details overleaf
Page 1 of 2

13 and 14 June 2012, 2pm 8pm
18 and 19 June 2012, 2pm 8pm

20 and 21 June 2012, 2pm 8pm

Page 2

Phone Email Our ref Land Parcel 0800 0721 086 thames.tunnel@thameswater.co.uk 100-CO-CMN-MULTI-000031 INSERT FIELDS
Thames Tunnel - Barn Elms

I am writing to let you know about some important proposed changes to the Thames Tunnel project. In February 2012, we completed our phase two consultation on the proposed Thames Tunnel, a major new sewer urgently needed to help tackle the problem of sewage overflows from Londons Victorian sewerage system into the River Thames. Since then, we have made some further changes to our plans in response to comments which we have received, and as these changes affect local communities we are carrying out a targeted consultation in your area. We are proposing to change the access arrangements for the site at Barn Elms. Instead of building an access route alongside the Beverley Brook to Rocks Lane we are now proposing to access the site from the north, via Queen Elizabeth Walk. We need to acquire a number of sites that will be used in the construction and subsequent operation of the Thames Tunnel. We believe that you may have an interest in land which we may now need to acquire or use. More detailed information on the changes we are proposing since our phase two consultation is available on our website www.thamestunnelconsultation.co.uk, and at our exhibitions. If you would like to speak to a member of the team to find out more please call 0800 0721 086. The consultation will last for 28 days, and will start on 6 June 2012 and close on 4 July 2012 at 5pm. We must receive all your comments by the closing date. It is your chance to make your views on our revised proposals known so that we can take them into account before we finalise the design and publicise it prior to formally submitting our application for consent to construct the Thames Tunnel in early 2013. If approved, main construction would start in 2016. Thank you for your time and I look forward to receiving your comments on our revised proposals. Yours sincerely,
Details overleaf
Page 1 of 2

13 and 14 June 2012, 2pm 8pm
18 and 19 June 2012, 2pm 8pm

20 and 21 June 2012, 2pm 8pm

Page 2

Thames Tunnel Barn Elms

I am writing to let you know about some important proposed changes to the Thames Tunnel project. In February 2012, we completed our phase two consultation on the proposed Thames Tunnel, a major new sewer urgently needed to help tackle the problem of sewage overflows from Londons Victorian sewerage system into the River Thames. Since then, we have made some further changes to our plans in response to comments which we have received, and as these changes affect local communities we are carrying out a targeted consultation in your area. We are proposing to change the access arrangements for the site at Barn Elms. Instead of building an access route alongside the Beverley Brook to Rocks Lane we are now proposing to access the site from the north, via Queen Elizabeth Walk. We do not need to acquire your property for our project, but you may be affected by the construction and possibly the future operation of the Thames Tunnel. More detailed information on the changes we are proposing since our phase two consultation is available on our website www.thamestunnelconsultation.co.uk, and at our exhibitions. If you would like to speak to a member of the team to find out more please call 0800 0721 086. The consultation will last for 28 days, and will start on 6 June 2012 and close on 4 July 2012 at 5pm. We must receive all your comments by the closing date. It is your chance to make your views on our revised proposals known so that we can take them into account before we finalise the design and publicise it prior to formally submitting our application for consent to construct the Thames Tunnel in early 2013. If approved, main construction would start in 2016. Thank you for your time and I look forward to receiving your comments on our revised proposals. Yours sincerely,
Details overleaf
Page 1 of 2

13 and 14 June 2012, 2pm 8pm
18 and 19 June 2012, 2pm 8pm

20 and 21 June 2012, 2pm 8pm

Page 2

Thames Tunnel Barn Elms

I am writing to let you know about some important proposed changes to the Thames Tunnel project. In February 2012, we completed our phase two consultation on the proposed Thames Tunnel, a major new sewer urgently needed to help tackle the problem of sewage overflows from Londons Victorian sewerage system into the River Thames. Since then, we have made some further changes to our plans in response to comments which we have received, and as these changes affect local communities we are carrying out a targeted consultation in your area. We are proposing to change the access arrangements for the site at Barn Elms. Instead of building an access route alongside the Beverley Brook to Rocks Lane we are now proposing to access the site from the north, via Queen Elizabeth Walk. You may be affected by the construction and possibly the future operation of the tunnel. In addition, in order to build the tunnel we may also need to acquire subsoil rights below your property. More detailed information on the changes we are proposing since our phase two consultation is available on our website www.thamestunnelconsultation.co.uk, and at our exhibitions. If you would like to speak to a member of the team to find out more please call 0800 0721 086. The consultation will last for 28 days, and will start on 6 June 2012 and close on 4 July 2012 at 5pm. We must receive all your comments by the closing date. It is your chance to make your views on our revised proposals known so that we can take them into account before we finalise the design and publicise it prior to formally submitting our application for consent to construct the Thames Tunnel in early 2013. If approved, main construction would start in 2016. Thank you for your time and I look forward to receiving your comments on our revised proposals. Yours sincerely
Details Overleaf
Page 1 of 2

13 and 14 June 2012, 2pm 8pm
18 and 19 June 2012, 2pm 8pm

20 and 21 June 2012, 2pm 8pm

Page 2

Thames Tunnel Putney Embankment Foreshore and Barn Elms

I am writing to let you know about some important proposed changes to the Thames Tunnel project. In February 2012, we completed our phase two consultation on the proposed Thames Tunnel, a major new sewer urgently needed to help tackle the problem of sewage overflows from Londons Victorian sewerage system into the River Thames. Since then, we have made some further changes to our plans in response to comments which we have received, and as these changes affect local communities we are carrying out a targeted consultation in your area. Putney Embankment Foreshore - we are proposing a modified site location which is situated further away from Putney Bridge and the existing draw dock. Barn Elms - we are also proposing to change the access arrangements for the site at Barn Elms. Instead of building an access route alongside the Beverley Brook to Rocks Lane we are now proposing to access the site from the north, via Queen Elizabeth Walk. More detailed information on the changes we are proposing since our phase two consultation is available on our website www.thamestunnelconsultation.co.uk, and at our exhibitions. If you would like to speak to a member of the team to find out more please call 0800 0721 086. The consultation will last for 28 days, and will start on 6 June 2012 and close on 4 July 2012 at 5pm. We must receive all your comments by the closing date. It is your chance to make your views on our revised proposals known so that we can take them into account before we finalise the design and publicise it prior to formally submitting our application for consent to construct the Thames Tunnel in early 2013. If approved, main construction would start in 2016. Thank you for your time and I look forward to receiving your comments on our revised proposals. Yours sincerely,
Details overleaf
Page 1 of 2

13 and 14 June 2012, 2pm 8pm
18 and 19 June 2012, 2pm 8pm

20 and 21 June 2012, 2pm 8pm

Page 2

Dear [Title; Surname] Proposed Thames Tunnel, private water abstraction and ground source heat pumps The proposed Thames Tunnel is a major new sewer, urgently needed to help tackle the problem of sewage overflows from Londons Victorian sewerage system into the River Thames. You may have already received a letter from us last October. We contacted those who we believe may be affected by our proposals and we were establishing data to help inform the tunnels design. Following further technical design work we now believe that the dewatering required to ensure safe construction of the proposed Thames Tunnel may have an effect on your ability to abstract water or operate your ground source heat pump which your property may benefit from. More detailed information on the project as a whole and the changes we are proposing since our phase two consultation is available on our website www.thamestunnelconsultation.co.uk, and at our exhibitions. If you would like to speak to a member of the team to find out more please call 0800 0721 086. The consultation will last for 28 days, and will start on 6 June 2012 and close on 4 July 2012 at 5pm. We must receive all your comments by the closing date. It is your chance to make your views on our revised proposals known so that we can take them into account before we finalise the design and publicise it prior to formally submitting our application for consent to construct the Thames Tunnel in early 2013. If approved, main construction would start in 2016. Given the nature of our proposals and possible impacts on you, we would be very happy to arrange to meet you to discuss how our works could affect you and any temporary measures that we could put in place during construction of the tunnel. Once we have finished our works we would fully expect groundwater levels to return to normal and your ability to abstract water or operate your ground source heat pump to be restored. If a meeting would be helpful please contact Barney Forrest on 0203 429 1123 or email barney.forrest@tidewaytunnels.co.uk We look forward to hearing from you. Yours sincerely Phil Stride Head of London Tideway Tunnels Thames Water
If you have any questions please call us on 0800 0721 086

Details Overleaf
Page 1 of 2
You can give us your feedback by contacting us in a number of ways


13 and 14 June 2012, 2pm 8pm
18 and 19 June 2012, 2pm 8pm

20 and 21 June 2012, 2pm 8pm

Page 2

Phone Email Our ref 0800 0721 086 thames.tunnel@thameswater.co.uk 100-CO-CMN-MULTI-000036
Thames Tunnel
Firstly I would like to thank you and your teams for working with us throughout our consultations on the project. You may recall that in our Statement of Community Consultation, published on 4 November 2011, we indicated that we may need to amend our scheme following phase two consultation. We undertook to consider, on a site by site basis, whether our changes would affect the nature of the comments received from the public at phase two consultation. Where appropriate, we explained that we would undertake further targeted consultation. Since the close of our phase two consultation in February 2012, we have made some further changes to our proposed plans. We would like your views on the proposals as outlined below. Putney Embankment Foreshore - a proposed modified site location which is situated further away from Putney Bridge and the existing draw dock; Barn Elms - a proposed new access route which would use Queen Elizabeth Walk instead of the previously proposed temporary route alongside the Beverley Brook; Victoria Embankment Foreshore - a proposed new design for the permanent works Albert Embankment Foreshore potential alternative construction access route Tunnel alignment and other sites - Minor changes to our proposed tunnel alignment and to the land that we may have to acquire to construct and operate the Thames Tunnel.
More detailed information is available on our website www.thamestunnelconsultation.co.uk and at our exhibitions. If you would like to speak to a member of the team to find out more please call 0800 0721086. The consultation will last for 28 days, and will start on 6 June 2012 and close on 4 July 2012 at 5pm. We must receive all your comments by the closing date. It is your chance to make your views on our revised proposals known so that we can take them into account before we finalise the design and publicise it prior to formally submitting our application for consent to construct the Thames Tunnel in early 2013. If approved, main construction would start in 2016. We appreciate that many stakeholders will not have an interest in these specific changes, however we are required to consult all statutory consultees to comply with section 42 of the Planning Act 2008. Thank you for your time and I look forward to receiving your comments on our revised proposals. Yours sincerely Phil Stride, Head of London Tideway Tunnels Thames Water
Details overleaf
Page 1 of 2
You can give us your feedback by contacting us in a number of ways


13 and 14 June 2012, 2pm 8pm
18 and 19 June 2012, 2pm 8pm

20 and 21 June 2012, 2pm 8pm

Page 2

Phone Email Our ref 0800 0721 086 thames.tunnel@thameswater.co.uk 100-CO-CMN-MULTI-000037
Thames Tunnel
In February 2012, we completed our phase two consultation on the proposed Thames Tunnel, a major new sewer urgently needed to help tackle the problem of sewage overflows from Londons Victorian sewerage system into the River Thames. Since then, we have made some further changes to our plans in response to comments which we have received, and as these changes affect local communities we are carrying out targeted consultation in the following areas. Putney Embankment Foreshore - a proposed modified site location which is situated further away from Putney Bridge and the existing draw dock; Barn Elms - a proposed new access route which would use Queen Elizabeth Walk instead of the previously proposed temporary route alongside the Beverley Brook; Victoria Embankment Foreshore - a proposed new design for the permanent works Albert Embankment potential alternative construction access route Tunnel alignment and other sites - Minor changes to our proposed tunnel alignment and to the land that we may have to acquire to construct and operate the Thames Tunnel.
More detailed information on the changes we are proposing since our phase two consultation is available on our website www.thamestunnelconsultation.co.uk and at our exhibitions. If you would like to speak to a member of the team to find out more please call 0800 0721 086. The consultation will last for 28 days, and will start on 6 June 2012 and close on 4 July 2012 at 5pm. We must receive all your comments by the closing date. It is your chance to make your views on our revised proposals known so that we can take them into account before we finalise the design and publicise it prior to formally submitting our application for consent to construct the Thames Tunnel in early 2013. If approved, main construction would start in 2016. Once again thank you for your time and I look forward to receiving your comments on our revised proposals. Yours sincerely
Phil Stride, Head of London Tideway Tunnels Thames Water
Details overleaf
Page 1 of 2

13 and 14 June 2012, 2pm 8pm
18 and 19 June 2012, 2pm 8pm

20 and 21 June 2012, 2pm 8pm

Page 2

Thames Tunnel
I am writing to let you know about some important proposed changes to the Thames Tunnel project. In February 2012, we completed our phase two consultation on the proposed Thames Tunnel, a major new sewer urgently needed to help tackle the problem of sewage overflows from Londons Victorian sewerage system into the River Thames. Since then, we have made some further changes to our plans in response to comments which we have received. We need to acquire a number of sites that will be used in the construction and subsequent operation of the Thames Tunnel. We believe that you may have an interest in land which we may now need to acquire or use. More detailed information on the changes we are proposing since our phase two consultation is available on our website www.thamestunnelconsultation.co.uk, and at our exhibitions. If you would like to speak to a member of the team to find out more please call 0800 0721 086. The consultation will last for 28 days, and will start on 6 June 2012 and close on 4 July 2012 at 5pm. We must receive all your comments by the closing date. It is your chance to make your views on our revised proposals known so that we can take them into account before we finalise the design and publicise it prior to formally submitting our application for consent to construct the Thames Tunnel in early 2013. If approved, main construction would start in 2016. Thank you for your time and I look forward to receiving your comments on our revised proposals. Yours sincerely,
Details overleaf
Page 1 of 2

13 and 14 June 2012, 2pm 8pm
18 and 19 June 2012, 2pm 8pm

20 and 21 June 2012, 2pm 8pm

Page 2

Thames Tunnel
I am writing to let you know about some important proposed changes to the Thames Tunnel project. In February 2012, we completed our phase two consultation on the proposed Thames Tunnel, a major new sewer urgently needed to help tackle the problem of sewage overflows from Londons Victorian sewerage system into the River Thames. Since then, we have made some further changes to our plans in response to comments which we have received. We do not need to acquire your property for our project, but you may be affected by the construction and possibly the future operation of the Thames Tunnel. More detailed information on the project as a whole and the changes we are proposing since our phase two consultation is available on our website www.thamestunnelconsultation.co.uk, and at our exhibitions. If you would like to speak to a member of the team to find out more please call 0800 0721 086. The consultation will last for 28 days, and will start on 6 June 2012 and close on 4 July 2012 at 5pm. We must receive all your comments by the closing date. It is your chance to make your views on our revised proposals known so that we can take them into account before we finalise the design and publicise it prior to formally submitting our application for consent to construct the Thames Tunnel in early 2013. If approved, main construction would start in 2016. Thank you for your time and I look forward to receiving your comments on our revised proposals. Yours sincerely,
Details overleaf
Page 1 of 2

13 and 14 June 2012, 2pm 8pm
18 and 19 June 2012, 2pm 8pm

20 and 21 June 2012, 2pm 8pm

Page 2

Thames Tunnel
I am writing to let you know about some important proposed changes to the Thames Tunnel project. In February 2012, we completed our phase two consultation on the proposed Thames Tunnel, a major new sewer urgently needed to help tackle the problem of sewage overflows from Londons Victorian sewerage system into the River Thames. Since then, we have made some further changes to our plans in response to comments which we have received. We have had to make some important modifications to the route of the tunnel and we may now need to acquire subsoil rights below your property. It is important to note that due to the depth of the tunnel, your property should not be affected by its construction or subsequent operation. More detailed information on the changes we are proposing since our phase two consultation is available on our website www.thamestunnelconsultation.co.uk, and at our exhibitions. If you would like to speak to a member of the team to find out more please call 0800 0721 086. The consultation will last for 28 days, and will start on 6 June 2012 and close on 4 July 2012 at 5pm. We must receive all your comments by the closing date. It is your chance to make your views on our revised proposals known so that we can take them into account before we finalise the design and publicise it prior to formally submitting our application for consent to construct the Thames Tunnel in early 2013. If approved, main construction would start in 2016. Thank you for your time and I look forward to receiving your comments on our revised proposals. Yours sincerely,
Details Overleaf
Page 1 of 2

13 and 14 June 2012, 2pm 8pm
18 and 19 June 2012, 2pm 8pm

20 and 21 June 2012, 2pm 8pm

Page 2

Thames Tunnel
I am writing to let you know about some important proposed changes to the Thames Tunnel project. In February 2012, we completed our phase two consultation on the proposed Thames Tunnel, a major new sewer urgently needed to help tackle the problem of sewage overflows from Londons Victorian sewerage system into the River Thames. Since then, we have made some further changes to our plans in response to comments which we have received. You may be affected by the construction and possibly the future operation of the tunnel. In addition, in order to build the tunnel we may also need to acquire subsoil rights below your property. More detailed information on the changes we are proposing since our phase two consultation is available on our website www.thamestunnelconsultation.co.uk, and at our exhibitions. If you would like to speak to a member of the team to find out more please call 0800 0721 086. The consultation will last for 28 days, and will start on 6 June 2012 and close on 4 July 2012 at 5pm. We must receive all your comments by the closing date. It is your chance to make your views on our revised proposals known so that we can take them into account before we finalise the design and publicise it prior to formally submitting our application for consent to construct the Thames Tunnel in early 2013. If approved, main construction would start in 2016. Thank you for your time and I look forward to receiving your comments on our revised proposals. Yours sincerely
Details Overleaf
Page 1 of 2

13 and 14 June 2012, 2pm 8pm
18 and 19 June 2012, 2pm 8pm

20 and 21 June 2012, 2pm 8pm

Page 2

Thames Tunnel Putney Embankment Foreshore

I am writing to let you know about some important proposed changes to the Thames Tunnel project. In February 2012, we completed our phase two consultation on the proposed Thames Tunnel, a major new sewer urgently needed to help tackle the problem of sewage overflows from Londons Victorian sewerage system into the River Thames. Since then, we have made some further changes to our plans in response to comments which we have received, and as these changes affect local communities we are carrying out a targeted consultation in your area. We are proposing a modified site location which is situated further away from Putney Bridge and the existing draw dock. We do not need to acquire your property for our project, but you may be affected by the construction and possibly the future operation of the Thames Tunnel. More detailed information on the changes we are proposing since our phase two consultation is available on our website www.thamestunnelconsultation.co.uk, and at our exhibitions. If you would like to speak to a member of the team to find out more please call 0800 0721 086. The consultation will last for 28 days, and will start on 6 June 2012 and close on 4 July 2012 at 5pm. We must receive all your comments by the closing date. It is your chance to make your views on our revised proposals known so that we can take them into account before we finalise the design and publicise it prior to formally submitting our application for consent to construct the Thames Tunnel in early 2013. If approved, main construction would start in 2016. Thank you for your time and I look forward to receiving your comments on our revised proposals. Yours sincerely,
Details overleaf
Page 1 of 2

13 and 14 June 2012, 2pm 8pm
18 and 19 June 2012, 2pm 8pm

20 and 21 June 2012, 2pm 8pm

Page 2

Thames Tunnel Putney Embankment Foreshore

I am writing to let you know about some important proposed changes to the Thames Tunnel project. In February 2012, we completed our phase two consultation on the proposed Thames Tunnel, a major new sewer urgently needed to help tackle the problem of sewage overflows from Londons Victorian sewerage system into the River Thames. Since then, we have made some further changes to our plans in response to comments which we have received, and as these changes affect local communities we are carrying out a targeted consultation in your area. We are proposing a modified site location which is situated further away from Putney Bridge and the existing draw dock. We need to acquire a number of sites that will be used in the construction and subsequent operation of the Thames Tunnel. We believe that you may have an interest in land which we may now need to acquire or use. More detailed information on the changes we are proposing since our phase two consultation is available on our website www.thamestunnelconsultation.co.uk, and at our exhibitions. If you would like to speak to a member of the team to find out more please call 0800 0721 086. The consultation will last for 28 days, and will start on 6 June 2012 and close on 4 July 2012 at 5pm. We must receive all your comments by the closing date. It is your chance to make your views on our revised proposals known so that we can take them into account before we finalise the design and publicise it prior to formally submitting our application for consent to construct the Thames Tunnel in early 2013. If approved, main construction would start in 2016. Thank you for your time and I look forward to receiving your comments on our revised proposals. Yours sincerely,
Details overleaf
Page 1 of 2

13 and 14 June 2012, 2pm 8pm
18 and 19 June 2012, 2pm 8pm

20 and 21 June 2012, 2pm 8pm

Page 2

Thames Tunnel Victoria Embankment Foreshore

I am writing to let you know about some important proposed changes to the Thames Tunnel project. In February 2012, we completed our phase two consultation on the proposed Thames Tunnel, a major new sewer urgently needed to help tackle the problem of sewage overflows from Londons Victorian sewerage system into the River Thames. Since then, we have made some further changes to our plans in response to comments which we have received, and as these changes affect local communities we are carrying out a targeted consultation in your area. We are proposing to change the design of the permanent works at the Victoria Embankment Foreshore site. We need to acquire a number of sites that will be used in the construction and subsequent operation of the Thames Tunnel. We believe that you may have an interest in land which we may now need to acquire or use. More detailed information on the changes we are proposing since our phase two consultation is available on our website www.thamestunnelconsultation.co.uk, and at our exhibitions. If you would like to speak to a member of the team to find out more please call 0800 0721 086. The consultation will last for 28 days, and will start on 6 June 2012 and close on 4 July 2012 at 5pm. We must receive all your comments by the closing date. It is your chance to make your views on our revised proposals known so that we can take them into account before we finalise the design and publicise it prior to formally submitting our application for consent to construct the Thames Tunnel in early 2013. If approved, main construction would start in 2016. Thank you for your time and I look forward to receiving your comments on our revised proposals. Yours sincerely,
Details overleaf
Page 1 of 2

13 and 14 June 2012, 2pm 8pm
18 and 19 June 2012, 2pm 8pm

20 and 21 June 2012, 2pm 8pm

Page 2


I am writing to let you know about some important proposed changes to the Thames Tunnel project. In February 2012, we completed our phase two consultation on the proposed Thames Tunnel, a major new sewer urgently needed to help tackle the problem of sewage overflows from Londons Victorian sewerage system into the River Thames. Since then, we have made some further changes to our plans in response to comments which we have received, and as these changes affect local communities we are carrying out a targeted consultation in your area. We are proposing to change the design of the permanent works at the Victoria Embankment Foreshore site. We do not need to acquire your property for our project, but you may be affected by the construction and possibly the future operation of the Thames Tunnel. More detailed information on the changes we are proposing since our phase two consultation is available on our website www.thamestunnelconsultation.co.uk, and at our exhibitions. If you would like to speak to a member of the team to find out more please call 0800 0721 086. The consultation will last for 28 days, and will start on 6 June 2012 and close on 4 July 2012 at 5pm. We must receive all your comments by the closing date. It is your chance to make your views on our revised proposals known so that we can take them into account before we finalise the design and publicise it prior to formally submitting our application for consent to construct the Thames Tunnel in early 2013. If approved, main construction would start in 2016. Thank you for your time and I look forward to receiving your comments on our revised proposals. Yours sincerely,
Details overleaf
Page 1 of 2

13 and 14 June 2012, 2pm 8pm
18 and 19 June 2012, 2pm 8pm

20 and 21 June 2012, 2pm 8pm

Page 2


I am writing to let you know about some important proposed changes to the Thames Tunnel project. In February 2012, we completed our phase two consultation on the proposed Thames Tunnel, a major new sewer urgently needed to help tackle the problem of sewage overflows from Londons Victorian sewerage system into the River Thames. Since then, we have made some further changes to our plans in response to comments which we have received, and as these changes affect local communities we are carrying out a targeted consultation in your area. We are proposing to change the design of the permanent works at the Victoria Embankment Foreshore site. You may be affected by the construction and possibly the future operation of the tunnel. In addition, in order to build the tunnel we may also need to acquire subsoil rights below your property.. More detailed information on the changes we are proposing since our phase two consultation is available on our website www.thamestunnelconsultation.co.uk, and at our exhibitions. If you would like to speak to a member of the team to find out more please call 0800 0721 086. The consultation will last for 28 days, and will start on 6 June 2012 and close on 4 July 2012 at 5pm. We must receive all your comments by the closing date. It is your chance to make your views on our revised proposals known so that we can take them into account before we finalise the design and publicise it prior to formally submitting our application for consent to construct the Thames Tunnel in early 2013. If approved, main construction would start in 2016. Thank you for your time and I look forward to receiving your comments on our revised proposals. Yours sincerely
Details Overleaf
Page 1 of 2

13 and 14 June 2012, 2pm 8pm
18 and 19 June 2012, 2pm 8pm

20 and 21 June 2012, 2pm 8pm

Page 2


I am writing to let you know about some important proposed changes to the Thames Tunnel project. In February 2012, we completed our phase two consultation on the proposed Thames Tunnel, a major new sewer urgently needed to help tackle the problem of sewage overflows from Londons Victorian sewerage system into the River Thames. Since then, we have made some further changes to our plans in response to comments which we have received, and as these changes affect local communities we are carrying out a targeted consultation in your area. We are proposing to change the design of the permanent works at the Victoria Embankment Foreshore site. More detailed information on the changes we are proposing since our phase two consultation is available on our website www.thamestunnelconsultation.co.uk, and at our exhibitions. If you would like to speak to a member of the team to find out more please call 0800 0721 086. The consultation will last for 28 days, and will start on 6 June 2012 and close on 4 July 2012 at 5pm. We must receive all your comments by the closing date. It is your chance to make your views on our revised proposals known so that we can take them into account before we finalise the design and publicise it prior to formally submitting our application for consent to construct the Thames Tunnel in early 2013. If approved, main construction would start in 2016. Thank you for your time and I look forward to receiving your comments on our revised proposals. Yours sincerely,
Details overleaf
Page 1 of 2

13 and 14 June 2012, 2pm 8pm
18 and 19 June 2012, 2pm 8pm

20 and 21 June 2012, 2pm 8pm

Page 2

Phone Email Our ref Land Parcel 0800 0721 086 thames.tunnel@thameswater.co.uk
100-CO-CMN-MULTI-000049
INSERT FIELD

I am writing to let you know about some important proposed changes to the Thames Tunnel project. In February 2012, we completed our phase two consultation on the proposed Thames Tunnel, a major new sewer urgently needed to help tackle the problem of sewage overflows from Londons Victorian sewerage system into the River Thames. Since then, we have made some further changes to our plans in response to comments which we have received, and as these changes affect local communities we are carrying out a targeted consultation in your area. We are consulting on a potential alternative access arrangement and are seeking views on a construction access route from Albert Embankment via a temporary road between Tintagel House and Camelford House. We need to acquire a number of sites that will be used in the construction and subsequent operation of the Thames Tunnel. We believe that you may have an interest in land which we may now need to acquire or use. More detailed information on the changes we are proposing since our phase two consultation is available on our website www.thamestunnelconsultation.co.uk, and at our exhibitions. If you would like to speak to a member of the team to find out more please call 0800 0721 086. The consultation will last for 28 days, and will start on 6 June 2012 and close on 4 July 2012 at 5pm. We must receive all your comments by the closing date. It is your chance to make your views on our revised proposals known so that we can take them into account before we finalise the design and publicise it prior to formally submitting our application for consent to construct the Thames Tunnel in early 2013. If approved, main construction would start in 2016. Thank you for your time and I look forward to receiving your comments on our revised proposals. Yours sincerely,
Details overleaf
Page 1 of 2

13 and 14 June 2012, 2pm 8pm
18 and 19 June 2012, 2pm 8pm

20 and 21 June 2012, 2pm 8pm

Page 2
C4 envelope.indd 1
28-May-12 2:16:28 PM
If undelivered please return to: Thames Water, Customer Services, PO Box 508, Swindon SN38 9TU
For more information go to: www.thamestunnelconsultation.co.uk
C4 envelope.indd 2
28-May-12 2:16:28 PM
&
FI D
EN
TI AL
AF T
Area of main map
WORK IN PROGRESS
Legend
Limits of Land to be Acquired or Used for Section 48 2012 250m Buffer
PRD2X
General Notification Zone
0 30 60 120 Metres 180 240
Mapping reproduced by permission of Ordnance Survey on behalf of HMSO. Crown copyright and database right 2012. All rights reserved. Ordnance Survey Licence number 100019345 CH2M HILL accept no responsibility for any circumstances, which arise from the reproduction of this map after alteration, amendment or abbreviation or if it is issued in part or issued incomplete in any way.
Map Ref : ............................ Map Ref XXX Date : .................................. 2012/04/23 Projection : .......................... British National Grid
PWH12
Thames Water Utilities
The Point, 7th Floor, 37 North Wharf Road, Paddington, London W2 1AF
Title:
This is an indicative working draft plan which has been produced for the purpose of confidential discussions only. Accordingly, the draft plan must not be copied, distributed or shown to any third party without the express written permission of Thames Water Utilities Limited. It provides an indication of sites that, following discussions with local authorities and other stakeholders, may be confirmed as being on the shortlist of construction sites for the proposed Thames Tunnel. Inclusion of a site on this draft plan should not be taken to mean that such site will be selected as a construction site to form part of the Thames Tunnel scheme.
Barn Elms
&
FI D
EN
TI AL
AF T
PRD2X
Area of main map
WORK IN PROGRESS
Legend
Limits of Land to be Acquired or Used for Section 48 2012 250m Buffer General Notification Zone
PWH12
0 25 50 100 Metres 150 200
Title:
&
FI D
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TI AL
AF T
Area of main map
WORK IN PROGRESS
Legend
Limits of Land to be Acquired or Used for Section 48 2012 250m Buffer General Notification Zone
PWR1X
0 20 40 80 Metres 120 160
Title:
Appendices
Appendix D:Site notices
253
Thames Tunnel targeted consultation

6 June 2012 - 4 July 2012
Proposed changes to our plans at Barn Elms

The Thames Tunnel is a major new sewer, urgently needed to significantly reduce the amount of untreated sewage which currently overflows into the River Thames. As little as 2mm of rain can cause a discharge from Londons overloaded sewerage system.
Following our second phase of consultation, which ended on 10 February 2012, we are considering some changes to our plans on which we are asking for your views. We are proposing to modify the temporary access route, taking account of comments received during phase two consultation. The key proposed change is: At phase two consultation, we proposed that construction vehicles would use a newly constructed temporary access route alongside the Beverley Brook. We are now considering a revised access route via Queen Elizabeth Walk for both construction and operational vehicles. The revised new vehicle access route would be constructed along the northern and eastern perimeters of the Barn Elms Schools Playing Fields. For more information please visit www. thamestunnelconsultation.co.uk where further details will be available from 6 June 2012, or attend one of our drop-in sessions.
13 and 14 June 2012 (2pm 8pm) WWT London Wetland Centre, Queen Elizabeths Walk, SW13 9WT
The deadline for comments is 4 July 2012.
If you need a telephone language interpreter, please call us on 0800 0721 086. We are open 24 hours a day.
0800 0721 086
0800 0721 086
Somaali Haddii aad u baahan tahay tarjume luuqadeed oo khadka telefoonka ah, fadlan naga soo wac halkan 0800 0721 086. Waxaanu furanahay 24 saac maalintii.
Thames Tunnel

6 June 2012 - 4 July 2012
Proposed changes to our plans at Barn Elms

Following our second phase of consultation, which ended on 10 February 2012, we are considering some changes to our plans on which we are asking for your views. We are proposing to modify the temporary access route, taking account of comments received during phase two consultation. The key proposed changes are: At phase two consultation, we were proposing that construction vehicles would use a newly constructed temporary access route alongside the Beverley Brook. We are considering a revised access route via Queen Elizabeth Walk for both construction and operational vehicles. The revised new vehicle access route would be constructed along the northern and eastern perimeters of the Barn Elms Schools Playing Fields. For more information please visit www. thamestunnelconsultation.co.uk where further details will be available from 6 June 2012, or attend one of our drop-in sessions.
13 and 14 June 2012 (2pm 8pm) WWT London Wetland Centre Queen Elizabeths Walk, SW13 9WT
If you need a telephone language interpreter, please call us on 0800 0721 086. We are open 24 hours a day. Polski Jesli potrzebujesz tlumaczenia ustnego przez telefon, zadzwon pod numer 0800 0721 086. Pracujemy 24 godziny na dobe. Somaali Haddii aad u baahan tahay tarjume luuqadeed oo khadka telefoonka ah, fadlan naga soo wac halkan 0800 0721 086. Waxaanu furanahay 24 saac maalintii.
0800 0721 086
B E Wand
Thames Tunnel

6 June 2012 - 4 July 2012
Proposed changes to our plans at Putney Embankment Foreshore

Following our second phase of consultation, which ended on 10 February 2012, we are considering some changes to our plans on which we are asking for your views. We are proposing to modify the location and layout of the temporary works and our permanent design, taking account of comments received during phase two consultation. The key proposed changes are: We propose to relocate the permanent hardstanding area approximately 30m to the west, in response to comments on the permanent design of the works and its relationship with the public slipway. The configuration of the temporary replacement slipway has been changed to respond to comments. We are now proposing that it will be a prefabricated steel structure, which will be predominantly delivered by river and then assembled on site. A new construction traffic route will be used to access the temporary slipway site. The route
will be westwards along Lower Richmond Road, turning right into Glendarvon Street and right onto the Embankment. Vehicles will exit from the Embankment via Thames Place and onto Lower Richmond Road. As the size of the temporary construction site would be extended by 30m (due to relocation or our permanent hardstanding), we also now need to move an existing houseboat during the construction period. For more information please visit www.thamestunnelconsultation.co.uk where further details will be available from 6 June 2012, or attend one of our drop-in sessions.
20 and 21 June 2012 (2pm 8pm) London Rowing Club Embankment, Putney, SW15 1LB
If you need a telephone language interpreter, please call us on 0800 0721 086. We are open 24 hours a day. Polski Jesli potrzebujesz tlumaczenia ustnego przez telefon, zadzwon pod numer 0800 0721 086. Pracujemy 24 godziny na dobe. Somaali Haddii aad u baahan tahay tarjume luuqadeed oo khadka telefoonka ah, fadlan naga soo wac halkan 0800 0721 086. Waxaanu furanahay 24 saac maalintii.
0800 0721 086
Thames Tunnel

6 June 2012 - 4 July 2012
Proposed changes to our plans at Albert Embankment

Following our second phase of consultation, which ended on 10 February 2012, we are considering some changes to our plans on which we are asking for your views. We are proposing a revised design for our construction works, taking account of comments received during phase two consultation. The key proposed alternative we are considering is: The access route for construction vehicles between Camelford and Tintagel Houses.
For more information please visit www. thamestunnelconsultation.co.uk where further details will be available from 6 June 2012, or attend one of our drop-in sessions.
18 and 19 June 2012 (2pm 8pm) Park Plaza Riverbank London, 18 Albert Embankment, SE1 7TJ
If you need a telephone language interpreter, please call us on 0800 0721 086. We are open 24 hours a day. Portugus Se necessitar de um intrprete numa chamada telefnica, ligue para o nmero 0800 0721 086. Estamos disponveis 24 horas por dia. Yoruba B o b nl olgbif telifonu, jw p w n 0800 0721 086. A w n ss n wkt 24 ljm.
Thames Tunnel
Thames Tunnel phase two consultation

6 June 2012 - 4 July 2012
Proposed changes to our plans at Victoria Embankment

Following our second phase of consultation, which ended on 10 February 2012, we are considering some changes to our plans on which we are asking for your views. We are proposing a revised design for our permanent works in the foreshore, taking account of comments received during phase two consultation. The key proposed changes are: The top of the shaft would form an island in the River Thames, which would be a publicly accessible viewing platform, linked by footbridges to the embankment. The footprint of the revised design of the permanent structure would be much reduced as a result of the shaft being disconnected from the embankment. For more information please visit www. thamestunnelconsultation.co.uk where further details will be available from 6 June 2012, or attend one of our drop-in sessions.
13 and 14 June 2012 (2pm 8pm) 8 Northumberland Avenue London, WC2N 5BY
If you need a telephone language interpreter, please call us on 0800 0721 086. We are open 24 hours a day.
0800 0721 086
0800 0721 086
Somaali Haddii aad u baahan tahay tarjume luuqadeed oo khadka telefoonka ah, fadlan naga soo wac halkan 0800 0721 086. Waxaanu furanahay 24 saac maalintii.
Thames Tunnel
Appendices
Appendix E: List of town halls and libraries where post phase two consultation information was available
Table E.1 List of town halls and libraries where post phase two consultation information was available
Venue Address 1 Address 2 City Postcode
Ealing Town Hall Hounslow Civic Centre Hammersmith & Fulham Town Hall Wandsworth Town Hall Kensington & Chelsea Town Hall Westminster City Hall Lambeth Council City of London Corporation Southwark Council Lewisham Town Hall London Borough of Tower Hamlets London Borough of Greenwich
Perceval House Lampton Road King Street Wandsworth High Street Hornton Street 64 Victoria Street Phoenix House, St George Wharf Department of Planning & Transportation 160 Tooley Street 5th Floor, Laurence House 5th Floor, Anchorage House Town Hall
14-16 Uxbridge Road Hammersmith
London Hounslow London London London London
W5 2HL TW3 4DN W6 9JU SW18 2PU W8 7NX SW1E 6QP SW8 2LL EC2P 2EJ SE1 2QH SE6 4RU E14 2BE SE18 6PW
Wandsworth Road PO Box 270, Guildhall
London London London
Catford Road 5 Clove Crescent Wellington Street
London London London
254
Appendices
Newham Town Hall Richmond Upon Thames Civic Centre London Thames Gateway Development Corporation Ealing Central Library Acton Library Hounslow Library Chiswick Library Hammersmith Library Fulham Library Sands End Library Wandsworth Town Library Putney Library York Gardens Library Battersea Park Library Chelsea Library Kensington Central Library Victoria Library
1000 Dockside Road 44 York Street 9th Floor, South Quay Plaza 3 103 Ealing Broadway Centre High Street Centre Space Duke's Avenue Shepherds Bush Road 598 Fulham Road The Community Centre, 59 Broughton Road 11 Garratt Lane 5/7 Disraeli Road 34 Lavender Road 309 Battersea Park Road Chelsea Old Town Hall 12 Phillimore Walk 160 Buckingham Palace Road King's Road Kensington Hammersmith Fulham Fulham 189 Marsh Wall The Broadway Acton Treaty Centre, High Street
London Twickenham London London London Hounslow London London London London London London London London London London London
E16 2QU TW1 3BZ E14 9SH W5 5JY W3 6NA TW3 1ES W4 2AB W6 7AT SW6 5NX SW6 2LE SW18 4AQ SW15 2DR SW11 2UG SW11 4NF SW3 5EZ W8 7SA SW1W 9UD
255
Appendices
Pimlico Library South Lambeth Library Guildhall Library John Harvard Library Canada Water Library Lewisham Library Pepys Resource Centre West Greenwich Library East Greenwich Library Stratford Library Castelnau Library Richmond Information Centre Tower Hamlets Idea Store Tower Hamlets Idea Store Shoe Lane library
Rampayne Street 180 South Lambeth Road 5 Aldermanbury 211 Borough High Street 21 Surrey Quays Road 199-201 Lewisham High Street Old Library 146 Greenwich High Road 203-207 Woolwich Road 3 The Grove 75 Castelnau Old Town Hall Gladstone Place Churchill Place Hill House Whittaker Avenue Bow Canary Wharf Little New Street Stratford Deptford Strand Surrey Quays
London London London London London London London London London London London London London London London
SW1V 2PU SW8 1QP EC2V 7HH SE1 1JA SE16 7AR SE13 6LG SE8 3BA SE10 8NN SE10 0RL E15 1EL SW13 9RT TW9 1TP E3 5ES E14 5RB EC4A 3JR
256
Appendices
Appendix F:Targeted consultation exhibitions

Table F.1 List of targeted consultation exhibitions
Venue Barn Elms, WWT London Wetland Centre, Queen Elizabeths Walk, Barnes, London, SW13 9WT Victoria Embankment Foreshore, 8 Northumberland, 8 Northumberland Avenue, London, WC2N 5BY Albert Embankment Foreshore, Park Plaza Riverbank London, 18 Albert Embankment, SE1 7TJ Putney Embankment Foreshore, London Rowing Club, Embankment, Putney, London, SW15 1LB Date 13/06/2012 14/06/2012 Time 2-5pm Visitors 35 attendees
5-8pm 2-5pm 35 attendees 5-8pm Total 70 attendees 2-5pm 5-8pm 2-5pm 5-8pm 2-5pm 5-8pm 2-5pm 5-8pm 10 attendees 4 attendees
13/06/2012 14/06/2012
Total 14 attendees 18/06/2012 19/06/2012 12 attendees 19 attendees
20/06/2012 21/06/2012
Total 31 attendees 2-5pm 82 attendees 5-8pm 2-5pm 52 attendees 5-8pm Total 249 attendees
257
Appendices
Appendix G: Feedback forms

G.1
Targeted consultation and Section 42 modifications to site boundaries and the tunnel alignment feedback form
258
You can contact us about any of our other activities online or by telephone: Call Billing or account enquiries: 0845 9200 888
Lines are open weekdays from 8am-8pm and on Saturday from 8am1pm (Minicom or Typetalk: 0845 7200 899) Lines are open 24 hours a day (Minicom or Typetalk: 0845 7200 898)
Water or wastewater enquiries: 0845 9200 800
We need your comments

Targeted consultation feedback form
As a result of the feedback we received during phase two consultation, we are considering making changes to our proposals at Barn Elms, Putney Embankment Foreshore, Victoria Embankment Foreshore and Albert Embankment Foreshore. We are now consulting on these proposed changes and are seeking peoples views. In addition to the proposed changes at these sites, we have made some modifications to the proposed boundaries for all our sites and the tunnel alignment. We have written to those who are potentially affected notifying them of these changes and informing them of this consultation.
Visit
www.thameswater.co.uk
This targeted consultation closes at 5pm on 4 July 2012. For more information about our proposals, or if you require any help filling out this form: Call 0800 0721 086 Visit www.thamestunnelconsultation.co.uk Email thames.tunnel@thameswater.co.uk
If there is not enough space on this sheet for all your comments, continue on to another piece of paper and attach it securely. Please send your completed form by 5pm on 4 July 2012 to: Freepost RSSB-HYRU-EGUT, Thames Tunnel, 35 King Street, BRISTOL, BS1 4DZ Call 0800 0721 086 Email thames.tunnel@thameswater.co.uk Visit www.thamestunnelconsultation.co.uk
Thames Tunnel
110-PU-PNC-00000-000776
1.
Your details
Putney Embankment Foreshore Are you: Supportive Opposed Dont know/unsure
Giving us this information means that we can contact you after the consultation with a summary of the consultation comments and how we have responded. We will publish your response anonymously and keep your personal details confidential. Name ........................................................................................................................................................................................................................................................ Address .................................................................................................................................................................................................................................................... ..................................................................................................................................................................................................................................................................... ........................................................................................................................................Postcode.......................................................................................................... Email address ......................................................................................................................................................................................................................................... Telephone number ...............................................................................................................................................................................................................................
................................................................................................................................................................................................................................................................ ................................................................................................................................................................................................................................................................ ................................................................................................................................................................................................................................................................ ................................................................................................................................................................................................................................................................ ................................................................................................................................................................................................................................................................ Victoria Embankment Foreshore Are you: Supportive Opposed Dont know/unsure
................................................................................................................................................................................................................................................................ All the comments you provide on this form should only relate to the changes proposed in this targeted consultation. ................................................................................................................................................................................................................................................................ ................................................................................................................................................................................................................................................................ ................................................................................................................................................................................................................................................................ ................................................................................................................................................................................................................................................................ Albert Embankment Foreshore Are you: Supportive Opposed Dont know/unsure
2. Please state in what capacity you are providing comments on the Thames Tunnel.
A local resident An organisation e.g. community or residents group, or business, or other (please provide details below) Landowners1/Significantly affected persons2 as defined by s.44 of the 2008 Planning Act or agent acting on their behalf (please provide details below) Statutory consultee (excluding local authority). Please only select this option if you have specifically been contacted by Thames Water in this capacity in connection with the Thames Tunnel (please provide details below) Local authority (please provide details below) Other ......................................................................................................................................................................................................................................... Please provide details ................................................................................................................................................................................................................... ................................................................................................................................................................................................................................................................ ................................................................................................................................................................................................................................................................
1. Landowners means owners and others with a legal interest in land which may be acquired for the project. 2. Significantly Affected Persons means those who, as a result of having a legal interest in land, may be able to claim compensation arising out of the construction and/or operation of the project, even though their land would not be acquired. For example, for interference with a right of way, or because their property may be affected by noise or vibration.
................................................................................................................................................................................................................................................................ ................................................................................................................................................................................................................................................................ ................................................................................................................................................................................................................................................................ ................................................................................................................................................................................................................................................................ ................................................................................................................................................................................................................................................................ Modifications to site boundaries please state which site/s you are commenting on: ................................................................................................................................................................................................................................................................ Are you: Supportive Opposed Dont know/unsure
................................................................................................................................................................................................................................................................ ................................................................................................................................................................................................................................................................
3. What aspect of our proposed changes are you commenting on? (Please tick and provide any comments)
In order to answer the following questions, you may find it useful to look at our supplementary site information papers. These are available on our website or by calling our Customer Centre.
................................................................................................................................................................................................................................................................ ................................................................................................................................................................................................................................................................ ................................................................................................................................................................................................................................................................ Modifications to tunnel alignment Are you: Supportive Opposed Dont know/unsure
Barn Elms Are you: Supportive Opposed Dont know/unsure
................................................................................................................................................................................................................................................................ ................................................................................................................................................................................................................................................................ ................................................................................................................................................................................................................................................................ ................................................................................................................................................................................................................................................................ ................................................................................................................................................................................................................................................................ ................................................................................................................................................................................................................................................................ ................................................................................................................................................................................................................................................................
................................................................................................................................................................................................................................................................ ................................................................................................................................................................................................................................................................ ................................................................................................................................................................................................................................................................ ................................................................................................................................................................................................................................................................ ................................................................................................................................................................................................................................................................ ................................................................................................................................................................................................................................................................
Appendices
G.2
Section 42 groundwater abstraction consultation feedback form
259
We need your comments

Your details
Name Address
Water abstraction consultation feedback form
(Giving us this information means that we can contact you after the consultation with a summary of the consultation comments and how we have responded).
Postcode Email address Telephone number
We will publish your response anonymously and keep your personal detailsconfidential. You only need to complete the questions on this form that are of interest to you. If you require any help filling out this form, please contact our customer centre on 0800 0721 086. You can find more information about the Thames Tunnel on our website at www.thamestunnelconsultation.co.uk. Please only submit your feedback when you are completely happy with yourresponse. All the comments you provide on this form should only relate to this consultationon the Thames Tunnel. You can contact us about any other Thames Water activity using theinformation on the back of this form. If there is not enough space on this sheet for all your comments, please continue on to another piece of paper and attach it securely. Please send your completed form by 5pm on 4 July 2012 to: Freepost RSSB-HYRU-EGUT, Thames Tunnel, 35 King Street, BRISTOL, BS1 4DZ
A.
Please state in what capacity you are providing comments on the Thames Tunnel. the owner, lessee or occupier of premises (land and/or buildings) which enjoy the benefit of water abstraction for whatever purpose this may be put (for example: ground source heat pumps). As indicated in the accompanying letter we have identified the possibility that your ability to abstract water may be affected by construction of the Thames Tunnel project someone who uses these premises or is otherwise interested in them an agent acting on behalf of anyone in the above categories
Please provide details:
B.
Do you have any comments to make about the Thames Tunnel project in the context of its potential to affect water abstraction during the construction period? If you have any more general comments about the Thames Tunnel scheme, please feel free to complete any relevant questions in Parts 1-2.
Part one
Our preferred sites
In order to answer the following questions, you may find it useful to look at our phase two consultation site information papers, which are available on our website or by contacting our customer centre.
1.
Which of our preferred sites are you commenting on?
If you wish to comment on more than one site, please attach an additional feedback form for each site. Acton Storm Tanks Hammersmith Pumping Station Barn Elms* Putney Embankment Foreshore* Dormay Street King Georges Park Carnwath Road Riverside Falconbrook Pumping Station Kirtling Street Heathwall Pumping Station Cremorne Wharf Depot Chelsea Embankment Foreshore Albert Embankment Foreshore* Blackfriars Bridge Foreshore Victoria Embankment Foreshore* King Edward Memorial Park Foreshore Earl Pumping Station Deptford Church Street Greenwich Pumping Station Chambers Wharf Abbey Mills Pumping Station Beckton Sewage Treatment Works Shad Thames Pumping Station Bekesbourne Street Jews Row (please go to question 8) Other works (please go to question 8)
*There is updated information about these sites in our targeted consultation section.
2.
Given the requirements for the construction and operation of the tunnel in this location, please give us your view on whether you consider this should be our preferred site. Are you: supportive opposed dont know/unsure
Please give your reasons why:
3.
Site:
If you think an alternative site should be used to perform the function set out in the site information paper, please tell us which one and why:
Management of construction works
4.
Section 2 of the site information paper identifies what we consider to be the key issues associated with this site during construction, and how we currently intend to address them. (Other evironmental issues associated with this site are also identified in the Preliminary environmental information report (PEIR) and targeted consultation PEIR addendums). yes no dont know/unsure
a) Do you agree that we have identified the right key issues in the site information paper?
If there are other key issues that you think we should identify, please state them below, with your reasons why:
b) Do you agree that we have identified the right way to address the key issues? yes no dont know/unsure If you do not agree that we have identified the right way to address the key issues, please state the issue below, and your reasons why:
Design
5.
Section 3 of the site information paper sets out a number of site specific issues which have influenced our permanent design for this site. Do you agree that we have identified the right issues? (This question does not apply to Bekesbourne Street, please go to question 7). yes no dont know/unsure
If you do not agree that we have identified the right site specific issues, please state below what you think are the right issues, with your reasons why:
6.
Section 3 of the site information paper sets out our proposals for the permanent design and appearance of this site. Please give us your views. Are you: supportive opposed dont know/unsure
Management of operational effects
7.
a)
Section 3 of the site information paper identifies what we consider to be the key issues associated with this site once it is operational, and how we currently intend to address them. (Other environmental issues associated with this site are also identified in the PEIR and targeted consultation PEIR addendums). Do you agree that we have identified the right key issues in the site information paper? yes no dont know/unsure
If there are other key issues that you think we should identify, please state them below, with your reasons why:
b) Do you agree that we have identified the right way to address the key issues? yes no dont know/unsure If you do not agree that we have identified the right way to address any of the key issues, please state the issue below, and your reasons why:
8.
If you have any comments about our proposals for Jews Row or Other works, please provide them below. Otherwise, please go to question 9.
a) Jews Row
b) Other works
Tunnel route and alignment
9.
We presented three possible routes for the tunnel to follow, and identified the Abbey Mills route as our preferred route. Having reviewed the feedback from phase one and phase two consultation, the Abbey Mills route is still our preferred route. Do you have any further comments about our preference for the Abbey Mills route? I have no comments I have comments, as follows:
10.
Do you have any comments on the proposed alignment of the Abbey Mills route? I have no comments I have comments, as follows:
Part two
Consultation process
We are interested in your views on how we ran the consultation process.
11.
Have you previously taken part in consultation activities for this project? yes, go to question 12 no, go to question 13
12.
If yes, did you fill in a feedback form, attend an exhibition or meeting where we were present to answer questions, or provide comments in another way? attended an exhibition and spoke to a member of the Thames Tunnel team attended an exhibition, but did not speak to a member of the Thames Tunnel team filled in a feedback form (online or paper feedback form) attended drop in sessions or other meeting where a member of the Thames Tunnel team was present other (please provide details below)
Please tick all that are appropriate:
13.
Do you think you have been provided with enough information about the project and consultation material to enable you to comment? yes no
Please provide your comments here:
14.
Do you have any other comments on the Thames Tunnel consultation process? yes no
Please provide your comments here:
15.
Do you want to receive updates about the Thames Tunnel? yes, by e-mail yes, by post no
If yes, please fill in your details on the front page of this form.
For more information about the Thames Tunnel, please visit our website at www.thamestunnelconsultation.co.uk
Thank you
You can contact us about any of our other activities: Online www.thameswater.co.uk By telephone Billing or accountenquiries call 08459200 888 Lines are open weekdays from 8am - 8pm and on Saturday from 8am - 1pm (Minicom or Typetalk: 0845 7200 899). Water or wastewater enquiries call 0845 9200 800 Lines are open 24 hours a day (Minicom or Typetalk: 0845 7200 898).
All the comments you provide on this form should only relate to this consultation on the Thames Tunnel. Please submit your completed form by 5pm on 4 July 2012 to:
Freepost RSSB-HYRU-EGUT, Thames Tunnel, 35 King Street, BRISTOL, BS1 4DZ
110-PU-PNC-00000-000777
Appendices
Appendix H:Modifications to site boundaries

Table H.1 Modifications to site boundaries
Preferred site Acton Storm Tanks Proposed boundary modifications Minor boundary changes to reflect design modifications and to reflect the need for adequate adjacent construction space to the west. Boundary extended into Chancellors Road to enable the rising main to be connected with the existing sewer; boundary extended into Distillery Road to create access and accommodate kerb realignment; minor boundary changes to the west to off-set the area lost due to the required set back along Distillery Road. Boundary changes to reflect new construction and operational access road proposals and consequential minor junction improvements. See Supplementary site information paper for more information. Permanent works boundary extended to accommodate relocation of the permanent platform; need for scour protection to Putney Pier; potential to accommodate re-located residential mooring during construction and to accommodate necessary construction space and scour protection under and around Putney Bridge. Temporary Slipway boundary extended to accommodate river access for construction, potential temporary construction effects on existing moorings and to accommodate construction parking and access along the Embankment. See Supplementary site information paper for more information. Boundary extended into Armoury Way and the Causeway to provide junction and highway improvements for construction access and along the Causeway to provide construction access for light vehicles. Boundary extended southwards in Dormay Street to provide construction access to/from Dormay Street. Boundary extended into Bell Lane Creek to facilitate construction works and river wall strengthening within the creek and crane oversailing of the creek, if required. Boundary extended southwards into the council depot to enable removal of a flap valve within an existing chamber. Boundary extended into Neville Gill Close for construction access and highway and junction improvements; boundary extended near the existing park entrance to facilitate amended landscaping proposals. Minor boundary changes to reflect design modifications to enable works to the existing Thames Path and off-site junction improvements for construction access. Boundary extended to provide off-site highway works in York Road for potential bus stop relocation; minor boundary changes
Hammersmith Pumping Station
Barn Elms
Dormay Street
King Georges Park
Carnwath Road Riverside Falconbrook Pumping Station
260
Appendices
Preferred site Cremorne Wharf Depot Proposed boundary modifications to reflect design modifications. Boundary extended into Lots Road to provide junction improvements; boundary extended into the River Thames to facilitate river transport. Boundary extended to the east to include the connection between Low Level Sewer No. 1 and the foreshore site; boundary extended into the River Thames to facilitate scour protection works. Boundary extended into the River Thames to provide more flexibility for river transport and to enable the potential use of Cringle Street during construction. Boundary extended to the west to facilitate the temporary relocation of Battersea Barge and to accommodate the realignment and enlargement of the permanent foreshore structure; boundary extended to the east to facilitate access for construction equipment and for any necessary ground treatment works and to facilitate access to the South West Storm Relief connection culvert. Boundary extended to the east to include an alternative access option; boundary extended into the River Thames to facilitate scour protection works; boundary extended to include the area in front of Vauxhall Cross building to allow for utility works, construction and maintenance access; boundary extended to Albert Embankment for junction improvements. See Supplementary site information paper for more information. Boundary extended in the River Thames to facilitate options for the relocation of the Tattershall Castle and facilitate scour protection works; minor boundary changes to reflect design modifications to both the temporary and permanent layout. See Supplementary site information paper for more information. Boundary extended in the River Thames to the west to facilitate the relocation of the President boat; boundary extended in the River Thames to the east for flexibility for the relocation of Millennium Pier; boundary extended into the River Thames to facilitate scour protection works. Minor boundary changes to reflect design modifications and access requirements. Boundary extended into the highway for junction improvements and utility diversions; boundary extended around the playground in order to create a larger usable space during construction and to provide a new relocated playground; minor boundary realignments. Boundary extended into the highway for utility diversion works; boundary extended into Bevington Street for off-site highway works.
Chelsea Embankment Foreshore
Kirtling Street
Heathwall Pumping Station
Blackfriars Bridge Foreshore
Shad Thames Pumping Station King Edward Memorial Park Foreshore
Chambers Wharf
261
Appendices
Preferred site Earl Pumping Station Deptford Church Street Proposed boundary modifications Minor boundary changes within Croft Street and Chilton Grove to reflect design modifications and utility diversions. Boundary extended in the highway to facilitate highway works relating to site access and bus stop and pedestrian crossing relocation; boundary extended to the west to provide a relocated fire assembly point for St Josephs School. Boundary extended to include the pumping station and to facilitate minor highway works; minor boundary realignments to the south of the site. Boundary extended up to the public highway for access; boundary extended into Prescott Channel to facilitate potential use of river transport and the associated pedestrian footpath diversion; minor boundary changes to reflect design modifications. N/A Boundary extended into the highway to connect the two sites, to facilitate design changes and for utility diversions.
Greenwich Pumping Station Abbey Mills Pumping Station
Beckton Sewage Treatment Works Bekesbourne Street
262

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Thames Tideway Tunnel Report on post phase two consultation

Targeted consultation: Putney Embankment Foreshore ............................ 41 6.1 6.2

Report on post phase two consultation

Targeted consultation: Albert Embankment Foreshore ............................. 91

Targeted consultation: Victoria Embankment Foreshore ........................ 103

Section 42 consultation: Modifications to site boundaries ...................... 120

Section 42 consultation: Modifications to the tunnel alignment ............. 129

Section 42 consultation: Ground water abstraction ................................. 139

Report on post phase two consultation

Other comments........................................................................................... 168

Conclusions and next steps........................................................................ 240

Report on post phase two consultation

Report on post phase two consultation

Report on post phase two consultation

Report on post phase two consultation

Report on post phase two consultation

Phil Stride Head of the Thames Tideway Tunnel project

Richard Aylard External Affairs and Sustainability Director

Report on post phase two consultation

Report on post phase two consultation

The proposed project

The proposed solution

Report on post phase two consultation

Pre-application consultation and engagement to date

Report on post phase two consultation

Structure of this report

Report on post phase two consultation

Report on post phase two consultation

3 Our approach to post phase two consultation

Our approach to post phase two consultation

DCLG (2009) Planning Act 2008, Guidance on pre-application consultation

Report on post phase two consultation

Our consultation strategy

Report on post phase two consultation

Report on post phase two consultation

Report on post phase two consultation

How we undertook the consultation

Report on post phase two consultation

Report on post phase two consultation

Report on post phase two consultation

Report on post phase two consultation

How we undertook the consultation

Report on post phase two consultation

Responding to requests for information

Access for all

Means of providing feedback

Report on post phase two consultation

4 Method of analysis of feedback and development of our responses

Method of analysis of feedback and development of our responses

Table 4.2 Number of respondents by respondent group

Report on post phase two consultation

4 Method of analysis of feedback and development of our responses

Report on post phase two consultation

Report on post phase two consultation

Report on post phase two consultation

4 Method of analysis of feedback and development of our responses

Presentation of our findings

Report on post phase two consultation

Report on post phase two consultation

5 Targeted consultation: Barn Elms

Targeted consultation: Barn Elms

Structure of this section