supp report on p2 consultation - chapter 3 other feedback

7/31/2019 Supp Report on P2 Consultation - Chapter 3 Other Feedback

1/34

110-RG-PNC-00000-000784 | May 2012

Supplementary reporton phase twoconsultation

Chapter 3 Other feedback


2/34

3 Other Comments

Thames Tunnel

Supplementary report on phase two consultation

List of contents

Page number

3 Other comments ............................................................................................ 3-13.1 Introduction ........................................................................................... 3-13.2 Other supportive and neutral feedback comments ............................... 3-13.3 Preliminary environmental information report ....................................... 3-23.4 Site selection methodology paper ......................................................... 3-73.5 Phase two scheme development report................................................ 3-93.6 Code of construction practice Part A: General requirements ................ 3-93.7 Draft waste strategy ............................................................................ 3-113.8 Design development report ................................................................. 3-133 9 Other objections issues and concerns 3 16


3/34

3 Other Comments

List of tables

Table 3.2.1 Other supportive and neutral feedback comments ............................. 3-1Table 3.3.1 Supportive and neutral feedback comments relating to the

Preliminary environmental information report..................................... 3-2Table 3.3.2 Objections, issues and concerns relating to the Preliminary

environmental information report........................................................ 3-3Table 3.4.1 Objections, issues and concerns relating to the Site selection

methodology paper............................................................................. 3-8Table 3.5.1 Supportive and neutral feedback comments relating to the

Phase two scheme development report............................................. 3-9Table 3.6.1 Supportive and neutral feedback comments relating to the

Code of construction practice Part A: general requirements.............. 3-9Table 3.6.2 Objections, issues and concerns relating to the

Code of construction practice Part A: general requirements............ 3-10Table 3.7.1 Supportive and neutral feedback comments relating to the

Draft waste strategy.......................................................................... 3-11Table 3.7.2 Objections, issues and concerns relating to the

Draft waste strategy 3 12


4/34

3 Other Comments

Supplementary report on phase two consultation 3-1

3 Other comments

3.1 Introduction

3.1.1 This chapter sets out feedback comments received during the phase two consultation that relate to technical documents, reports or other matters not directly related to the questions in ourfeedback form, including:

Other supportive and neutral feedback comments

the Preliminary environmental information report the Site selection methodology paper

the Phase two scheme development report

the Code of construction practice Part A: General requirements

the Draft waste strategy

the Design development report

Other objections, issues and concerns.

3.1.2 In each of the following sections (except 3.2), the feedback comments have been grouped as being either supportive and neutral comments or objections, issues or concerns. Ourresponses to the feedback comments raised by respondents are set out in the tables.

3.1.3 The final section of this chapter sets out our initial view of the way forward and further work we are going to undertake as a result of the feedback comments received.

3.1.4 Where a response contains a reference to our website, go towww.thamestunnelconsultation.co.ukfor further information, or to access the documents referenced.

3.2 Other supportive and neutral feedback comments

Table 3.2.1 Other supportive and neutral feedback comments

Ref Supportive and neutral comments Respondent ID No. Our response

3.2.1 Welcome that the tunnel is expected todirectly create over 4,000 jobs inconstruction and associated industries. TheCity of Westminster wishes to be involved inensuring access to these jobs is madeavailable to Westminster residents.

LC, WCC 2 Your support is noted and welcomed.

3.2.2 Support the new air management strategyas appropriate to avoid odour from tunneloperations and to reduce the size and height

of the ventilation columns.

WCC 1

3.2.3 Pleased that Thames Water's approach tothe project will consider impacts andopportunities in all phases of the project andthat these will be considered on anindividual site and a cumulative, project widebasis.

EA 1

3.2.4 Welcome that the number of foreshore siteswith permanent structures has been

EA 1
http://www.thamestunnelconsultation.co.uk/http://www.thamestunnelconsultation.co.uk/http://www.thamestunnelconsultation.co.uk/http://www.thamestunnelconsultation.co.uk/


5/34

3 Other Comments



reduced from eight to seven.

3.2.5 Welcome the studies that are currentlyprogressing with regard to flood risk.

EA 1

3.2.6 Pleased that the decision hierarchy (avoid,mitigate, compensate, enhance) is beingused by the project team.

EA 1

3.3 Preliminary environmental information report

Supportive and neutral feedback comments

Table 3.3.1 Supportive and neutral feedback comments relating to the Preliminary environmental information report


3.3.1 The Preliminary environmental informationreport(PEIR) appears to include all therelevant information to inform acomprehensive Environmental statementinthe future. The PEIRappears to haveidentified all the relevant pressures andreceptors associated with the project. Thereis a substantial amount of new and historic

data and this should be sufficient to informany subsequent Environmental statement.

(LR)MMO 1 Your support is noted and welcomed.

3.3.2 Welcome the consideration given to bothterrestrial and aquatic wildlife in assessingthe likely impacts and setting out theproposed designs for each site.

LR9491 1

3.3.3 Content that the assessment methodologiesfor aquatic and terrestrial ecology as set outin volumes 5 and 6 of the PEIRrepresent arobust approach to assessing andaddressing the impacts of the ThamesTunnel project on biodiversity at both thesite and project wide scale.

NE 1

3.3.4 Welcomes the identification of the need for

particular care in respect of listed buildingsand structures with regard to settlementimpacts and the recognition of the need forheritage specialists to play a key role in theassessment of the potential for this type ofimpact on listed buildings.

EH 1

3.3.5 Overall the PEIRis clear and wellstructured, reflecting a good understandingof the environmental issues in the Thamesestuary.

(LR)MMO 1


6/34

3 Other Comments



3.3.6 The methodology proposed to undertake theenvironmental impact assessment isappropriate and in line with the IEEMGuidelines and the requirements of the 2011EIA Regulations (Town and CountryPlanning Act 1999) and the 2009 EIARegulations (Planning Act 2008), andguidance associated with both.

(LR)MMO 1

3.3.7 The use of the 'ABC' method for assessingand establishing significance criteria forconstruction noise is acceptable.

(LR)RBKC 1

Objections, issues and concerns

Table 3.3.2 Objections, issues and concerns relating to the Preliminary environmental information report

Ref Objections, issues and concerns Respondent ID No. Our response

3.3.8 The amount of information presented islarge and lacks an appropriate summary ofthe main issues which would facilitate thereference to specific sections and annexes.

(LR)MMO 1 Noted, consideration will be given to the structure and presentation ofthe Environmental statement.

3.3.9 There is no information contained within the

PEIRto suggest that Thames Water hasdone or intends to undertake a full costbenefit analysis covering the use of riverrather than land based transport to bring inequipment and subassemblies and to takeout excavated material during theconstruction phase.

LR13496LO 1 We do not intend to undertake a full cost-benefit analysis covering use

of the river because there is no agreed methodology for attributingfinancial costs to certain environmental assets eg heritage, ecology andtownscape. We are undertaking a transport assessment which willevaluate different transport scenarios, including road, river and rail,using both quantitative and qualitative criteria that reflect social,economic and environmental objectives and policies.

3.3.10 Consideration does not seem to have beenmade of any major known constructionprojects that are occurring at any of thesites.

(LR)MMO 1 Our assessment methodology is in line with the Infrastructure Planning(Environmental Impact Assessment) Regulations 2009, which requiresassessment of cumulative effects.

We have identified the schemes in the local area that will be included inthe assessment based on applications which have been referred to theGLA, consistent with Planning Inspectorate Advice note nine. Section 2of the site volumes of our PEIRset out the details of any relevantdevelopments that will be taken into consideration. We will continue to

monitor proposed development in the local area and any relativecumulative effects would be reported in our Environmental statementthat will be submitted as part of our DCO application.

3.3.11 Concerned that local residents will have norecourse if the environmental impactassessment turns out to be incorrect orunderestimates the damage to the localarea that may be caused by the proposals.

8751 1 Our assessment methodology is in line with the Infrastructure Planning(Environmental Impact Assessment) Regulations 2009. We aretherefore confident that we will be able to correctly assess the numberand scale of impacts arising from the Thames Tunnel project.

We are also developing a Code of Construction Practice(CoCP) whichwill set out how we will manage our construction sites to minimisedisruption to nearby communities. During construction, we will require all


7/34

3 Other Comments



contractors to be fully certified under the Considerate ContractorsScheme. These measures will allow us to identify any unforeseeneffects arising from construction and put in place suitable measures tomanage them.

Once the tunnels are operational, we propose to undertake performancemonitoring as well as regular inspection and maintenance visits whichwill allow us to identify any unforeseen effects and put in place suitablemeasures to manage them.

3.3.12 The PEIRplaces undue reliance on deskstudy, partial data and modelling.Specifically, there is insufficientenvironmental information to allow therespondent to assess the impact ofproposals at Carnwath Road Riverside ontheir property.

8753 1 The PEIRprovides preliminary environmental information on theThames Tunnel project. As such, it represents a snap shot in time duringthe environmental impact assessment process to facilitate effectiveconsultation. Because the report is preliminary, the assessmentinformation is not final or complete. Where appropriate, the reportindicates what further work is to be undertaken. The environmentalassessment process is continuing and will culminate in the production ofan Environmental statementwhich will be submitted with our DCOapplication.

3.3.13 There is no mention of navigational risks inthe PEIR.

8853 1 The effect on river navigation is being considered separately as part of aNavigational Risk Assessment, which we are preparing in consultationwith the Port of London Authority.

3.3.14 Concerned that Thames Water is notpublishing details of environmental impactsat the preferred sites, specifically ChambersWharf.

9085LO, 9086LO 2 Our PEIRwas made available at phase two consultation. Volume 22contains a preliminary assessment of the environmental effectsassociated with Chambers Wharf.

3.3.15 Detailed technical comments were providedon the contents of volumes 1 - 6 of the PEIRincluding:

volume 3 should strengthen thediscussion of the role of sustainableurban drainage systems (SuDS) inrelation to the historic environment

volume 4 no reference is made to thescoping response submitted by LondonBorough of Southwark

volume 5:

o on assessment methodologiesincluding in relation to air quality andodour, noise and vibration, socio-economics, transport, flood risk,townscape and visual, ecologyaquatic, ecology terrestrial, surfacewater, physical hydraulic modelling,mathematical hydraulic modelling,geotechnical modelling, scour anddeposition assessment

CoL, EA, EH, GLA, (LR)MMO, (LR)RBKC,WCC, (LR)LBS, (LR)LBE, (LR)LBTH,13380

9 We welcome the technical comments provided on the PEIR. As part ofthe environmental impact assessment process we will be reviewing thedetailed technical comments received and continuing to engage withstatutory consultees and potentially directly affected local authorities onenvironmental impact assessment generally as well as on the specifictechnical comments raised. A summary of how comments received inrelation to the environmental impact assessment have been taken intoaccount will be contained within the Consultation reportwith more detailcontained within the Environmental statement; both documents will besubmitted with our DCO application.


8/34

3 Other Comments



o there is a requirement for study oftunnelling on flood defencesettlement

o do not accept any characterisation ofenhancement as something over andabove what might reasonably beexpected as part of mitigating direct,in-direct, secondary, cumulative, in-

combination and compound impactson the historic environment causedby the project

volume 6 in relation to project wideeffects including air quality (specificallyunderestimation of the effect ofconstruction traffic on emissions) ecologyaquatic, groundwater, surface water, andflood risk.

3.3.16 A number of works methodologies or exactlocations are missing, preventing the MarineManagement Organisation (MMO) frombeing able to confirm whether works arelicensable. The MMO assumes this is due to

the preliminary nature of the documentation,however, the environmental impact of theseworks would need to be comprehensivelycovered within the Environmental statementto enable the MMO to carry out a thoroughreview.

(LR)MMO 1

3.3.17 Acton Storm Tanks - detailed technicalcomments were provided in relation toassessment.

GLA 1

3.3.18 Hammersmith Pumping Station - detailedtechnical comments were provided inrelation to assessment.

EH, GLA 2

3.3.19 Barn Elms - detailed comments wereprovided in relation to assessment.

EH, GLA 2

3.3.20 Putney Bridge Foreshore - detailed technicalcomments were provided in relation to theassessment of archaeological effects for themain site and temporary slipway and inrelation to the assessment on the sitecontext, historic environment, townscapeand visual, transport and water resources -surface.

EH, GLA 2

3.3.21 Dormay Street - detailed technical GLA


9/34

3 Other Comments



comments were provided in relation toassessment.

3.3.22 King George's Park - detailed technicalcomments were provided in relation toassessment.

EH, GLA 2

3.3.23 Carnwath Road Riverside - detailedtechnical comments were provided in

relation to assessment.

EH, GLA, 9461 3

3.3.24 Falconbrook Pumping Station - detailedtechnical comments were provided inrelation to assessment.

EH, GLA 2

3.3.25 Cremorne Wharf Depot - detailed technicalcomments were provided in relation toassessment.

EH, GLA, (LR)RBKC 2

3.3.26 Chelsea Embankment Foreshore - theabsence of an assessment of the setting ofheritage assets in this volume of the PEIRpresents an inaccurate impression of theappropriateness of the foreshore site fordevelopment particularly when compared toRanelagh Gardens.

Detailed technical comments were alsoprovided in relation to assessment on: sitecontext, historic environment, air quality andodour, noise and vibration, townscape andvisual, water resources - surface water,transport, land contamination and appendixA: historic environment.

EH, GLA, (LR)RBKC 3

3.3.27 Kirtling Street - detailed technical commentswere provided in relation to assessment.

EH, GLA 2

3.3.28 Heathwall Pumping Station detailedtechnical comments were provided inrelation to assessment.

EH, GLA 2

3.3.29 Albert Embankment Foreshore - detailed

technical comments were provided inrelation to assessment.

EH, GLA 2

3.3.30 Victoria Embankment Foreshore - detailedtechnical comments were provided inrelation to: air quality, historic environment,noise and vibration, socio-economic,townscape and visual, transport and waterresources (surface).

EH, GLA, WCC 3

3.3.31 Blackfriars Bridge Foreshore - detailedtechnical comments were provided in

EH, GLA 2


10/34

3 Other Comments



relation to assessment including the phasetwo assessment which indicates that theimpact of the proposal on road users in thisarea is minor adverse. This assessmentclearly does not adequately reflect thenature and period of impact arising from thescheme proposals.

3.3.32 Shad Thames Pumping Station - this shouldbe a standalone chapter in theEnvironmental statement.

GLA, (LR)LBS 2

3.3.33 Chambers Wharf - detailed technicalcomments were provided in relation toassessment.

EH, GLA 2

3.3.34 Earl Pumping Station - detailed technicalcomments were provided in relation toassessment.

EH, GLA 2

3.3.35 Deptford Church Street - detailed technicalcomments were provided in relation toassessment including in respect of: airquality, historic environment, noise andvibration, socio-economic, townscape and

visual, transport, mitigation and terrestrialecology.

EH, GLA, (LR)LBLew, 8937, 9065 4

3.3.36 Greenwich Pumping Station - detailedtechnical comments were provided inrelation to assessment including on aquaticecology and terrestrial ecology.

EH, GLA, 9066 3

3.3.37 King Edward Memorial Park Foreshore -detailed technical comments were providedin relation to assessment.

EH, GLA 2

3.3.38 Abbey Mills Pumping Station - detailedtechnical comments were provided inrelation to assessment.

EH, GLA 2

3.3.39 Beckon Sewage Treatment Worksdetailed technical comments were providedin relation to assessment.

EH, GLA 2

3.4 Site selection methodology paper


3.4.1 No supportive or neutral feedback comments were received in relation to the Site selection methodology paper.


11/34

3 Other Comments



Table 3.4.1 Objections, issues and concerns relating to the Site selection methodology paper


3.4.2 Except when a site is Thames Water's ownproperty, it is clear that construction must, ifonly for the sake of cost, be at places ofCSO interception and avoid extraenvironmental damage.

9488, 9395 2 In accordance with the Site selection methodology paperand Siteselection background technical papersites have been selected on thebasis of needing to intercept existing CSOs. CSOs are in fixed locationsand the site to intercept the CSO needs to on the line of, or in closeproximity to, the sewer.

Site selection has involved a multi-disciplinary approach and hasconsidered environmental factors alongside planning, community,engineering and property considerations. We are satisfied that ourapproach takes full account of environmental issues.

3.4.3 In the interests of local communities andlocal environments, we believe that as far asis possible works should be carried out atThames Water's existing pumping stations.

9063, 9067 1 Ownership of a site was taken into account along with otherconsiderations as set out in the Site selection methodology paper.However, it should be noted that the location of CSO sites is constrainedby the location of the existing combined sewers, because theinterception chambers have to be built on the existing sewers andtherefore the search area for the CSO sites is limited to the vicinity of theexisting CSO. Working within these constraints we have sought to useoperational sites as far as possible.

Of the sites presented at phase two consultation, seven sites are withinour existing pumping stations, with a further three sites located on land

we own.3.4.4 Thames Water should also consider

researching further solutions to avoid thepotential destruction of other greenfield sitesin the whole construction of the ThamesTunnel project. Even if it costs more money,this should be prioritised over effects onlocal residents.

Thames Water appears to have adopted astrategy of targeting green space, amenitiesand heritage assets for itsinfrastructure/caustic wastes rather thantaking the long term responsible option ofproperly appraising brownfield alternatives.

8996, 10701 1 As part of the site selection process, whether a site is brownfield orgreenfield is one of many considerations taken into account whendetermining whether or not a site is suitable. Given that we had a limitedsearch area to identify a suitable CSO/main tunnel sites, we did notconsider it was appropriate to exclude sites based on their use whencompiling our longlist of sites.Although not related to site selection, we have been assessing the likelysignificant effects that may arise as a result of the works as part of anenvironmental impact assessment. This will set out measuresnecessary to mitigate any significant adverse effects that are identified.Other suggestions, which may include betterment, will be subject tofurther discussions with the local planning authority and may be securedthrough a section 106 agreement.

3.4.5 Should avoid the use of green spaces.Whether or not the works affect openspaces or the Thames Path, extension orimprovement of open spaces and rights ofway would be welcomed as part of any finalrestoration of the sites.

9055 1


12/34

3 Other Comments


3.5 Phase two scheme development report


Table 3.5.1 Supportive and neutral feedback comments relating to the Phase two scheme development report


3.5.1 Detailed technical comments were providedon Phase two scheme development for:Chelsea Embankment Foreshore, Albert

Embankment Foreshore, VictoriaEmbankment Foreshore, Blackfriars BridgeForeshore, Greenwich Pumping Station.English Heritage also notes that they havenot been consulted on shortlisted sites atChelsea Embankment Foreshore, AlbertEmbankment Foreshore, VictoriaEmbankment Foreshore and BlackfriarsBridge Foreshore.

EH 1 We welcome the technical comments provided on the Phase twoscheme development report. We will take these comments into accountas part of the site selection process/documenting of the site selection

process. Further details will be contained within the Final report on siteselection process.


3.5.2 No objections, issues or concerns were received in relation to the Phase two scheme development report.

3.6 Code of construction practice Part A: General requirements


Table 3.6.1 Supportive and neutral feedback comments relating to the Code of construction practice Part A: general requirements


3.6.1 Welcome the provision for heritagemanagement plans as part of the proposedConstruction environmental managementplans.

EH 1 Your support is noted and welcomed.

3.6.2 Pleased to see that contractors will considerusing on or offsite soil remediation to dealwith contaminated soils.

EA 1

3.6.3 Pleased to see that pre-demolition auditswill be undertaken to identify high valuereuse opportunities for materials presentand that asbestos surveys will beundertaken to identify and manage anyasbestos containing materials.

EA 1

3.6.4 Request the opportunity to review thecommunity liaison plan that is to beprepared by the contractor to establish themonitoring framework for the project.

EH 1 The local authorities will be able to review the community liaison plan.Where relevant, other statutory consultees may also be given theopportunity to review the plan. This is under review and may beconsidered for inclusion in the next draft of the document.


13/34

3 Other Comments



Table 3.6.2 Objections, issues and concerns relating to the Code of construction practice Part A: general requirements


3.6.5 Detailed technical comments were providedin relation to: main site layout, wastelegislation references, lighting, noise andvibration, air quality, heritage, land qualityand remediation, pre-demolition audits and

the selection guide.

EA, EH, GLA, WCC, (LR)RBKC, (LR)LBE,(LR)LBTH

7 We welcome the technical comments provided on the draft CoCP. Aspart of the process of developing the CoCPwe will be reviewing thedetailed technical comments received and continuing to engage withstatutory consultees and potentially directly affected local authorities onthe CoCPgenerally as well as on the specific technical comments

raised. A summary of how comments received have been taken intoaccount will be contained within the Consultation reportwith more detailcontained within the Environmental statement; both documents will besubmitted with our DCO application.

3.6.6 Detailed technical comments were receivedin relation to waste legislation references.

EA 1

3.6.7 The lighting management plan will need toconsider the aquatic environment as well asthe terrestrial, particularly the need to avoiddirect lighting of the watercourse to avoidinhibiting movements of photophobicspecies.

EA 1

3.6.8 Any de-watering operations for cofferdamsor in-river structures will need to considerthe need for a fish rescue.

EA 1

3.6.9 Requirements of the City of London Code of

Practice for Construction and Demolitionshould be applied.

CoL 1 Where CoCPshave been produced by the local authorities directly

affected by the Thames Tunnel project, these have been taken intoconsideration while preparing the draft CoCP.

3.6.10 Machinery and plant should meet EuropeanEmissions standards.

(LR)LBS, (LR)LBTH 1 The CoCPto be submitted with our DCO application will requiremachinery and plant to meet European emissions standards.

3.6.11 More detail is required on river transport.The PLA expects that contractors will domore than 'reasonably practicable' tomaintain clearance within the navigationalchannel during construction.

PLA 1 It is our intention to develop this section further with input from the PLAand other relevant stakeholders, for inclusion within the next draft of thedocument.

3.6.12 Query whether a one size fits all approachwill be appropriate across the 14 localauthorities for Part A of the CoCP. Inparticular, appendix B of Part A providesguidance on how to apply for a Section 61

agreement under the Control of Pollution Act1974. Table B.1 assumes standard hours ofwork for the purposes of the Control ofPollution Act and does not give localauthorities discretion.

GLA 1 It is acknowledged that a one size fits all brief does not fit our project.This is why the project has adopted a two-part CoCP. Part A is generalrequirements, and has been produced to get general agreement acrossall 14 boroughs. Part B is site specific, and allows changes to berecognised across the boroughs. This includes detailing how working

hours are defined, and allowing for variance in the boroughs methods fordealing with this.

3.6.13 We understand that the Code ofConstruction Practice specific to each sitewill soon be coming out but, by that time, theconsultation will be finished. We think that itis essential that residents who will be

8986 1 The CoCPwill comprise two main parts:

Part A: General requirements. These measures will be applicable projectwide

Part B: Site specific requirements. This will document site specific


14/34

3 Other Comments


affected will have the chance to have someinput and to make comments.

requirements.

A draft of Part A of the CoCPwas produced as part of the phase twoconsultation, which respondents had the opportunity to comment on.

A draft of Part B of the CoCPwill be prepared. The CoCP will besubmitted as part of the DCO application, at which point members of thepublic will be able to make representations on the document.

3.7 Draft waste strategy

Supportive and neutral feedback commentsTable 3.7.1 Supportive and neutral feedback comments relating to the Draft waste strategy


3.7.1 Welcome the inclusion of the objectives toconserve landscape and townscape and toprotect heritage for the Excavated materialsoptions assessment.

EH 1 Your support is noted and welcomed. In relation to the planned end usefor excavated material, this will be set out in the Waste strategysubmitted with our DCO application.

3.7.2 Support the provision of training to siteworkers on recycling procedures and use ofa standard site waste management plans(SWMP) template across all sites as this willprovide consistency in terms of theinformation contained/gathered and

style/layout.

EA 1

3.7.3 Welcome the commitment to finding abeneficial use for as much of the excavatedmaterial as possible, and would welcomefirm proposals for the planned end use ofexcavated material.

LR9447 1

3.7.4 The shortlisted receptor sites for utilisationof the excavated materials will be includedin the waste strategy once they have beenfinalised. We would welcome an opportunityto review these for historic environmentimplications when they become available.

EH, LR9447 2 The shortlisted sites can be made available for review.

3.7.5 The Excavated materials optionsassessmentoutlines the environmental,

socio-economic, operational and wastemanagement policy evaluation objectivesused to assess receptor site suitability. TheRoyal Society for the Protection of Birds hasconsidered the objectives in relation to theWallasea Wild Coast Project and believesthat this site could meet or exceed thepublished objectives for the receipt ofexcavated material.

LR9447 1 The results of the Excavated material options assessmentwill bepublished in the Waste strategysubmitted as part of the DCO

application. Wallasea Wild Coast Project is one of the receptor sitesconsidered in the assessment.


15/34

3 Other Comments



Table 3.7.2 Objections, issues and concerns relating to the Draft waste strategy


3.7.6 A sustainable process/end location isrequired for the disposal of tunnel arisings.

LBN 1 One of the main purposes of the Excavated material options assessmentis to identify the most sustainable disposal option for excavated material.

3.7.7 The Waste Framework Directive mandatesthat the waste hierarchy be followed, ratherthan just placing greater emphasis on it.

EA, LR9447 2 It is integral to the Waste strategythat the waste hierarchy is followed.The Waste strategyobjectives are being revised to reflect this.

3.7.8 Should include a stronger commitmenttowards recycling by contractors and subcontractors. Contractors should bemandated to recycle welfare waste.

EA 1 Noted this will be included in the next draft of the Waste strategy.

3.7.9 Require confirmation that the excavatedmaterials from the tunnelling sites will bedealt with in a sustainable manner. TheExcavated Materials Options Assessmentsets a suitable framework, although theenvironmental objectives should includeenhancement alongside protection. Detailsof the options selected should form part ofthe final proposals.

CoL 1 Noted.

3.7.10 Any proposed recovery should offer genuineenvironmental, social and economicbenefits.

LR9447 1

3.7.11 Excavated material should be taken toMaplin by rail via Shoeburyness to firm thefill for reclaiming the co-ordinated ThamesEstuary development.

LR9459 1 Approximately 250 options have been considered in the Excavatedmaterial options assessment. Maplin will be considered if potentiallyviable.

3.7.12 Further consideration is required to identifythe most beneficial use for the excavatedmaterial and whether it is suitable for apositive use such as aggregate material. Inparticular it would be beneficial to examinewhether any of the early shaft excavationmaterial or excavation material from other

projects, notably Crossrail or National GridTunnelling, could be used as infill materialfor the cofferdam sites in the River Thames.

GLA 1 Options to source recycled aggregates for cofferdam fill are beingconsidered. Due to the length of the planning horizon clarity on this isnot always possible at this point. But it will be included in the WasteStrategy.

3.7.13 The landfill diversion target of 90 per cent isappropriate to begin with, however it issuggested that a reuse and recycling targetof 95 per cent should be implemented by2020 at the latest for the project as a whole.

GLA 1 We are yet to set a target for recycling; however, once set this target willbe reviewed in order to maximise landfill diversion.

3.7.14 Welcome the use of the Waste Hierarchy asa guide for this strategy. More emphasis

GLA 1 Noted.


16/34

3 Other Comments



should be placed on waste reduction andover the course of the project ambitioustargets should be set for limiting the amountof waste generated in the first place.

3.7.15 Further detail on how the Waste Hierarchywill inform the pre-construction stages of theoverall project and the individual siteprojects eg the planning and design, through

to material specification and procurementstages, is needed.

GLA 1 This will be included in the Waste strategy.

3.7.16 The target for the use of reused andrecycled materials should be set from theoutset in order to drive the work of thevarious contractors.

GLA 1 A target will be included in the Waste strategy, which will be submittedas part of the Development Control Order.

3.7.17 Detailed technical comments were providedon the Draft waste strategy.

GLA 1 We welcome the technical comments provided on the Draftwastestrategy. As part of the developing our waste strategy we will bereviewing the detailed technical comments received and continuing toengage with statutory consultees and potentially directly affected localauthorities. A summary of how comments received in relation to thewaste strategy have been taken into account will be contained within theConsultation reportwith more detail contained within the Environmentalstatement; both documents will be submitted with our DCO application.

3.8 Design development report


Table 3.8.1 Supportive and neutral feedback comments relating to the Design development report


3.8.1 Support the that the project is beingdeveloped in the Victorian civicinfrastructure tradition and aims to build onBazalgettes legacy of high quality designsand the aspiration for the project to providea modern benchmark for infrastructureprojects. Also, English Heritage welcomes

the recognition of the heritage andtownscape issues that relate to the design ofthe river walls.

EH 1 Your support is noted and welcomed.

3.8.2 The principles guiding the design approachshould be tied to an overarching designvision to underpin the site-specific designbriefs. Such a vision should be based on aclear grasp of the diverse character of theRiver Thames, reflecting the particularconditions at those points where

(LR)CABE 1 The overarching statement of architectural and landscape design iscontained in the Design project information paper.

In developing our designs for phase two consultation, we have takeninto account:

- local context of each site, including specific opportunities andconstraints

- feedback received at phase one consultation


17/34

3 Other Comments



interventions are proposed. - planning policy set out at national, London and local levels- comments received as part of our ongoing engagement- with technical consultees, including local authorities- on-going technical work, including assessment of possible

environmental effects.

The Design development reportexplains further how we have sought toinclude common design themes across London while responding to thelocal context.

3.8.3 Sites fall into two categories: 'Centralforeshore/monument' and 'Neighbourhood'interventions. While there will be a commonthread that ties all sites together, groupingthem in this way could prove a usefulmechanism.

(LR)CABE 1 We note your comments and although we have not specifically groupedour sites into these categories we believe our designs have respondedpositively to their local surroundings and the technical requirements tointercept the existing flows which differ along the route.

The overarching statement of architectural and landscape design iscontained in the Design project information paperand is supported byfurther detail in the Design development reportwhich sets out how wehave approached design across the route and at each site.

3.8.4 Designs should be celebratory when theoccasion demands and discreet when notbut in all cases they should adopt aconfident, rather than apologetic,relationship with their surroundings.

(LR)CABE 1 Your comment is noted. The Design development reportsets out howwe have approached design across the route and at each site.

3.8.5 The following areas could be furtherexplored:

promoting the special character of theRiver Thames and enjoyment of theriverside through opening up new viewsand vistas as well as preserving thosethat exist

improving accessibility through identifyingopportunities to address conflictsbetween road traffic and people andfocussing on priorities for movement

using the buildings and landscape as away to promote learning about bothBazalgettes works and the modernachievement of the Thames Tunnel

project maximising the opportunity to enhance

plant and animal life across the sites

bringing beneficial use to redundant listedbuildings as well as promoting a betterappreciation of the River Thames

improving local amenity includingallowing the community to have a say inshaping these projects to increase buy-in,

(LR)CABE 1 We note your comments and our designs at phase two have sort toaddress these issue where they are relevant including:

our foreshore sites have sort to promote views of and over the river,

public realm design ensure they are accessible for all,

we are seeking to include educational information at our sites whereit is appropriate and practicable to do so in order to provideinformation on the project and the surrounding area

how we have engaged with the local community is set out in ourStatement of community consultationand also recorded in this reporton Phase two consultation.

Where practicable we have sort to utilise existing buildings for ourworks in order to reduce the projects footprint for example locatingour equipment with Lots Road Pumping station and Beam EngineHouse at Greenwich Pumping Station.

We will consider temporary uses of our sites where it is practicable to do

so.


18/34

3 Other Comments



instil civic pride and a sense of ownership

considering opportunities for temporaryuse of sites for use by the community soas not to blight the neighbourhoodsaffected.

3.8.6 Developing common design componentssuch as ventilation columns and manholecovers could lend the project as a whole astrong identity that unifies the above groundworks along the length of the tunnel.

(LR)CABE 1 Your support is noted and welcomed. As noted in our Designdevelopment reportwe consulted at phase two consultation on anumber of common design principles which included ventilationcolumns, access covers and design of new river walls.

3.8.7 Proposals at Blackfriars Bridge Foreshorecould inform the development of an accesslanguage of steps, ramps and lifts for thewhole Thames Tunnel project.

(LR)CABE 1 Your comment is noted. The Design development reportsets out howwe have approached design across the route and at each site. Wewould note that the designs at each site need to take account of thelocal context but, we have sort to have some commonality in our designsand are seeking to develop a signature that recognises the commonimportance of the sites and the project to the river.

3.8.8 There is an opportunity to promote theThames Tunnel project through a consistentapproach to the expression and lighting ofventilation structures.

(LR)CABE 1 We note your comment and will consider whether lighting can be used toenhance the design of our ventilation columns. We would note thatgenerally no new operational lighting is proposed as part of the ThamesTunnel project except where we are providing or extending areas ofpublic realm which will be accessible to the public at night.


Table 3.8.2 Objections, issues and concerns relating to the Design development report


3.8.9 Detailed technical comments were providedin relation to Putney Bridge Foreshore,Carnwath Road Riverside, ChelseaEmbankment Foreshore, HeathwallPumping Station, A(LR)LBErt EmbankmentForeshore, Abbey Mills Pumping Station,Beckton Sewage Treatment Works, VictoriaEmbankment Foreshore, Blackfriars BridgeForeshore and Deptford Church Street.

EH 1 We welcome the technical comments provided on our proposeddesigns. As part of the design development process we will be reviewingthe detailed technical comments received. A summary of how commentsreceived in relation to the design have been taken into account will becontained in the Consultation reportwith more detail contained withinthe Design and access statement; both documents will be submittedwith our DCO application.

3.8.10 Support the notion of a structural signature

across the project and consider that thedesign for the ventilation columns couldachieve this effectively. However, at ActonStorm Tanks, Barn Elms, King GeorgesPark, Hammersmith Pumping Station andCarnwath Road Riverside this signature isnot used. Recommend that thought is givento which elements are common to all sitesand how these might be designed to providean appropriate signature for the projects.

EH 1


19/34

3 Other Comments



Keen to ensure that there is an element ofinterpretation of the project; the heritage ateach location may provide a usefulopportunity to develop a signature elementas well.Consider that elements of design at AlbertEmbankment Foreshore, VictoriaEmbankment Foreshore and King Edward

Memorial Park Foreshore are considered ona project-wide basis as part of aninterpretation strategy or signature elementfor the project as a whole.

3.8.11 Thames Water should work with the Mayor,boroughs and local interests to design anddeliver these improvements in line with localpriorities, the principles of the Mayor'smanifesto for improving public spaces,London's Great Outdoors and the AllLondon Green grid. This should include theintroduction of the Legible Londonwayfinding scheme and consultation withTransport for London.

GLA 1 We welcome the comments provided on our proposed designs. We willbe reviewing and considering these comments as we refine our designproposals.

The design follows our scheme-wide principles and takes into accountcomments made at phase one consultation, on-going discussions withstakeholders including the 14 directly affected London local authorities,GLA, Environment Agency, English Heritage, PLA, local communitygroups and affected land owners as well as a design review with CABE.Our Design development reportavailable as part of our phase twoconsultations sets out the principles that have informed our design inmore detail. We are continuing to develop our design proposals in light

of feedback to phase two consultation and will continue to engage withour stakeholders as we develop our designs.

3.8.12 The re-instatement works shouldincorporate cycling infrastructure, forexample secure parking and Barclays CycleHire docking stations wherever possible,and appropriate, within the legacy publicrealm strategy.

GLA 1 We welcome the comments provided on our proposed designs. We willbe reviewing and considering these comments as we refine our designproposals.

3.9 Other objections, issues and concerns

Table 3.9.1 Other objections, issues and concerns


Approach to environmental assessment3.9.1 The overall scheme appraisal should include

the wider social and environmental impactsat a local level and for London and ensurethat Thames Water does all that itreasonably can to mitigate the adverseimpacts on local communities.

(LR)CCW 1 We set out our preliminary assessment of the likely significantenvironmental effects at site specific and project-wide level in our PEIRthat was published with our phase two consultation material. Thisincluded an assessment of socio-economic effects and effects on a widerange of environmental topics. We will develop this further and in moredetail in our Environmental statementwhich we will be submitting withour DCO application. Our Environmental statementwill describemeasures to mitigate any significant adverse effects on localcommunities and other receptors. The methodology for our


20/34

3 Other Comments



Environmental statementwas consulted on with all relevant stakeholdersprior to our phase two consultation. Our Code of Construction Practicewill also contain measures to mitigate local effects.

3.9.2 Thames Water should continue inter-borough groups to address issues such asair quality, noise, vibration, wastemanagement, land quality and transport.

GLA 1 We intend to continue the inter-borough group (the Thames TunnelForum). These are high level meetings which are not really theappropriate forum in which to address detailed environmental issues. Inaddition, we hold regular pre-application meetings with local authorityofficers and other key stakeholders such as the Environment Agency,

PLA and GLA at which we discuss more detailed matters such as airquality, noise and other environmental, design and planning matters.

3.9.3 The footprint of disturbance in the channeland on the foreshore (land take) must beminimised in both the construction andoperational phases unless this results in netenvironmental improvement such asremediation of contaminated land at the site.Only essential infrastructure should be sitedin the foreshore and associated worksshould be sited on land if possible. TheEnvironmental statementwill need to justifyand make an exceptional case for placingfacilities in the river channel.

EA 1 We have developed our design to take account of the feedbackcomments made previously regarding the footprint of our temporary andpermanent foreshore structures being kept to a minimum. Our Environmental statementwill identify any likely significant effectsresulting from the works in the foreshore and will include appropriatemitigation measures for any significant adverse effects identified. We willalso provide flood risk and navigational risk assessments with our DCOapplication which we will continue to discuss with the EnvironmentAgency, PLA and other relevant stakeholders.

3.9.4 The Environmental statementshouldhighlight more of the benefits the ThamesTunnel project will bring to localcommunities. There is a widespreadrecreational use of some of the stretches ofthe River Thames and the improvementsthat will be made to the River Thames andfor the users of it should be highlighted.

EA 1 Our Environmental statementwill include an assessment of theconstruction and operational phases of our proposals on recreationalusers and will identify the social, environmental and economic benefitsthe Thames Tunnel project will bring to the river, local communities andrecreational users.

3.9.5 Comments on detailed technical mattersshould be taken into account in theEnvironmental statement.

EA 1 We welcome the technical comments provided on the content of theEnvironmental statement. As part of the environmental impactassessment process we will be reviewing the detailed technicalcomments received and continuing to engage with statutory consulteesand potentially directly affected local authorities on environmental impactassessment generally as well as on the specific technical commentsraised. A summary of how comments received in relation to the

environmental impact assessment have been taken into account will becontained within the Consultation reportwith more detail containedwithin the Environmental statement; both documents will be submittedwith our DCO application.

3.9.6 Detailed technical comments were alsoprovided on aquatic ecology, noise andvibration assessment requirements in

Environmental statement.

(LR)MMO 1

3.9.7 The requirement for and impact of anydredging activity required for theconstruction and operational phase shouldbe fully assessed by the Environmental

EA 1 We are carrying out fluvial modelling of the temporary and permanentforeshore works to establish the effects of the development on the river,and will discuss the findings with the Port of London Authority and theEnvironment Agency.


21/34

3 Other Comments



statement. We are also undertaking scour modelling. Our design would incorporatemitigation measures to manage the temporary and permanent effects ofour construction on the river. If appropriate, as part of our designdevelopment we will consider whether there are alternative options toavoid temporary structures in the river. Where significant scour ispredicted, we would carry out preventative measures (such as placingrip-rap on the river bed), and in all locations the riverbed would bemonitored and remedial works carried out if/as required.

The requirement for and the effect of any dredging activity will bereported in the Environmental statement.

3.9.8 Further work needs to be embedded in theenvironmental impact assessment todemonstrate a commitment to ensuring thatecological and other environmental impactsare robustly mitigated for in line with existinglegislation and guidance and that, forexample, net gains to biodiversity aresecured not just after completion of theproject, but during the constructionprogramme as best possible.

LR9491 1 Our Environmental statementwill describe any mitigation measuresrequired to address likely significant environmental effects identified inaccordance with the relevant EIA regulations and guidance. This willinclude measures for ecology and biodiversity effects and cover both theconstruction and operational phases of the Thames Tunnel project.

3.9.9 More detailed proposals for ensuring long-term biodiversity gains along the whole

route in addition to water quality should beset out in the environmental impactassessment.

LR9491 1

3.9.10 The environmental impact assessmentshould take account of the needs of thespecies identified in the PEIRin constructionand operation, and inform the design of theoperational structure.

LR9491 1 Our Environmental statementwill identify any significant effects onspecies identified, as well as any necessary mitigation measuresrequired for ecology and biodiversity. Our environmental specialists haveworked closely with our designers and environmental measures havebeen integrated into the design as it has evolved.

3.9.11 It is not clear in the phase two consultationdocumentation where the impacts of theconstruction and operation of the maintunnel will be assessed. The MarineManagement Organisation would suggestthat this is covered in the project-wideeffects section of the Environmentalstatementas the effects are not site specificdue to the nature of the main tunnel and thatits route passes under a number of differentsites.

(LR)MMO 1 Our preliminary assessment of the likely significant effects of theconstruction phase of the main tunnel is set out in the project-widevolume of our PEIR(volume 6). The project-wide part of ourEnvironmental statementwill include the full assessment of the effects ofmain tunnel construction, including noise and vibration and settlementeffects on historic structures.

3.9.12 Expect a navigational risk assessment to beincluded in the Environmental statementeither for the whole project or for eachrelevant site.

(LR)MMO 1 We are preparing a Navigational risk assessmentas part of ourapplication for a Development Consent Order (DCO), the approach towhich is being discussed with the PLA.


22/34

3 Other Comments



3.9.13 National Grid Gas Distribution owns andoperates the local gas distribution network inthe area of the proposed works. Gasdistribution assets are located within or inclose proximity to the proposed site of theproject.As part of the environmental impactassessment process, the potential impact of

the proposed project on National Grid'sexisting and planned assets should beconsidered. The location of our existing andplanned assets should also be taken intoaccount at any future design stages andNational Grid should be consulted at theearliest opportunity on the proposed route ofthe Thames Tunnel project.

NGG plc 1 We confirm that any effect on National Grid assets will be consideredand assessed and that we will continue to engage with National Grid onour proposals.

3.9.14 National Grid high voltage electricityunderground cables/cable tunnels lie in orwithin close proximity to the proposedThames Tunnel route/associateddevelopment, these lines form an essentialpart of the electricity transmission network inEngland and Wales.

As part of the environmental impactassessment process, the potential impact ofthe proposed project on National Grid'sexisting and planned assets should beconsidered. The location of our existing andplanned assets should also be taken intoaccount at any future design stages andNational Grid should be consulted at theearliest opportunity on the proposed route ofthe Thames Tunnel.

NG 1 We confirm that any effect on National Grid assets will be consideredand assessed and that we will continue to engage with National Grid onour proposals.

3.9.15 Query whether Thames Water will submit anenvironmental impact assessment beforeapplying for permission.

9069, 9068, LR13477 3 We can confirm that an Environmental statementreporting theenvironmental impact assessment will be submitted with our DCOapplication.

3.9.16 Thames Water should establish a specific

biodiversity action plan for the ThamesTunnel project. This should identify whatmeasures can be implemented in advanceof construction at any particular site (orelsewhere along the route), as well asduring, and after construction ofinfrastructure.

LR9491 1 Our Environmental statementhas been prepared in accordance with the

EIA regulations and relevant guidance and we have had regard to thecouncils and GLA biodiversity action plans in our assessment. We arealso considering advance planting works where our assessmentindicates it is necessary and where we can reach agreement withlandowners. Other mitigation works will be implemented as soon aspossible

3.9.17 Methodological and procedural mattersremain to be resolved including:

EH 1 The matters referred to were all still evolving during our phase twoconsultation because we are still at the pre-application phase. We willhave regard to all feedback to phase two consultation and continue


23/34

3 Other Comments



identifying the limits of deviation

establishing a strategy for on-goingmaintenance, care and, in some cases,use of the operational sitescompleting assessment of theconstruction and operational impacts ofthe project on archaeology and thesetting of heritage assets

assessing secondary, cumulative, andcompound impacts of the project on thehistoric environment

confirming the suitability of signaturefeatures and interpretation at each site

English Heritage would also welcome theopportunity to review the assessment ofcumulative and compound minor impactson the historic environment when itbecomes available.

discussions with all our key stakeholders such as Environment Agency,English Heritage and local authorities as we move forward to DCOsubmission and further develop our proposals.

3.9.18 Compensation should be offered whereimpacts cannot be fully mitigated against.

Query when residents will be able to applyfor compensation; they need to plan inadvance to allow time to make adjustmentsto their properties, eg installing doubleglazing

EA, 8944 2 Our Environmental statementwill include any mitigation measuresrequired for potential significant environmental impacts identified inaccordance with the relevant EIA regulations and other relevantlegislation. A guide to the Thames Tunnel compensation programme is

available on our website.

3.9.19 Should mitigate imaginatively for the sitesthat it does end up using.

9067 1 Our Environmental statementwill describe any mitigation measuresrequired to address likely significant environmental effects identified inaccordance with the relevant EIA regulations and guidance. As indicatedin the preliminary assessment (the PEIR), which was published as partof our phase two consultation material, the Environmental statementwillinclude a full assessment of the likely significant effects of theconstruction and operational phases of the project.

3.9.20 Should ensure that the visual andenvironmental impact of permanentstructures is minimised.

LR9154 1 At each site, the ventilation column(s) have been designed to meetfunctional and health and safety requirements and need to be the sizethat we have identified to ensure that the tunnel can operate efficiently.

Across the project, our approach to the design of the ventilationcolumn(s) has been to use the height to make a positive feature or locallandmark. The Thames Tunnel project is proud to sit in the tradition ofgreat London infrastructure and we are proud that we will be materiallyimproving the quality of the tidal River Thames for users.

3.9.21 Request that Thames Water explain thelevel of detail that will be assessed, thepotential need to provide for some flexibilityon detailed design, and how this will beassessed.

GLA 1 It is anticipated that we will need to have some flexibility in the level ofdetail we submit for approval and this is consistent with PlanningInspectorate advice note nine. We will continue to discuss our approachwith all our key stakeholders and our application for a DCO will beprepared in accordance with the Planning Act 2008 (the 2008 Act) and


24/34

3 Other Comments



all the relevant associated legislation, regulations, guidance and advice.The Environmental statementwill assess likely significant effects of theproject within the parameters contained in the application, in accordancewith Planning Inspectorate advice note nine.

Process for examining and consenting the Thames Tunnel project

3.9.22 The Waste Water National Policy Statementshould not pre-empt the role of the planning

process to determine whether the project isa nationally significant infrastructure project(NSIP).

(LR)LBS 1 The National Policy Statement (NPS) for Waste Water does not pre-empt the question of whether the project is an NSIP. The question of

whether or not a particular project is an NSIP is simply one of statutorydefinition. The NPS for Waste Water does not seek to define what is oris not an NSIP for the purposes of the 2008 Act. Moreover, an NPS mayset out the type or size of the specified description of development thatis appropriate nationally or for a specified area. In establishing that theThames Tunnel project is an appropriate project for the Londoncatchment and articulating why it is needed and that the need for theproject has been demonstrated, the NPS is properly performing its role.The NPS for Waste Water also does not seek to pre-empt or fetter thefuture decision that will be taken on an application for developmentconsent under the 2008 Act. That decision will be made in accordancewith the NPS unless certain specified exceptions apply, and the NPSproperly sets out the criteria that should be taken into account by thedecision maker.

3.9.23 The proposed use of the Infrastructure

Planning Commission is a deliberateattempt to circumvent the detailedconsideration that a local planning authoritycan give to a project such as this. If thiswere to become an NSIP, a full publicinquiry would be almost inevitable, with theassociated delays.

9427 1 The IPC was created to implement a streamlined process for deciding

nationally significant infrastructure projects. The previous system wasseen as cumbersome and overly-complex, requiring developers to applyfor consents under as many as eight separate, yet overlapping regimesfor a single infrastructure project. One of the main benefits of this morestreamlined process is the time taken to make a decision; on average itshould take less than a year. This process includes a significant level ofinvolvement of local authorities at various stages of the processincluding the pre-application stage that this project is currentlyundertaking. We have consulted with authorities and other statutorybodies on how we intended to consult at the pre-application stage asrequired by the 2008 Act and comments made prior to our consultationwere taken into account in our published SOCCand CCS. Foll owingsubmission of our application to the Planning inspectorate there will befurther opportunities for the local authorities to be involved in theprocess. Since April this year the IPC has been abolished and replacedby the Planning inspectorate which will first consider whether to acceptour application and then examine our submission and all relevantrepresentations including the local authorities Local Impact Reports andany representations the local authorities may make during theExamination process before making its recommendations to the relevantSecretary of State.

3.9.24 London's local authorities will continue topush for a strong role in the process toensure that local issues are taken intoaccount. Boroughs want reassurance that

LC 1 The 2008 Act established a streamlined process for deciding nationallysignificant infrastructure projects. This process includes a significantlevel of involvement of local authorities at various stages of the processincluding the pre-application stage, which we are currently undertaking.


25/34

3 Other Comments



sufficient weight will be given to their localimpacts reports to reflect the significant sitespecific and cumulative impacts this schemewill have on residents and businesses inaffected areas.

We have consulted with local authorities and other statutory consulteeson how we intended to consult at the pre-application stage as requiredby the 2008 Act and feedback made prior to our consultations weretaken into account in our published Statement of community consulteeand Community consultation strategy.

Following submission of our DCO application to the Planninginspectorate there will be further opportunities for the local authorities tobe involved in the process. Since April 2012, the IPC has been

abolished and replaced by a new directorate in the Planninginspectorate which will first consider whether to accept our applicationand then examine our submission and all relevant representationsincluding the local authorities local impact reports and anyrepresentations the local authorities may make during the examinationprocess before making its recommendations to the relevant Secretary ofState.

3.9.25 Thames Water should secure commitmentsby conditions or requirements:

London Borough of Southwark requestsobligations to address mitigationassociated with heritage, open space,community facilities, residential andvisual amenity, transport andsustainability, employment and localprocurement, public realm, othercommunity impacts and costs of Section106 administration

London Borough of Tower Hamlets alsorequires Section 278 HighwaysAgreement or equivalent provision in theDCO and appropriate liaison regardingsite hoardings etc, prior to construction.The council also requires provisions inthe DCO to make good any damage toroads.

London Borough of Ealing requestsconditions on the removal of storm tankswhen the Thames Tunnel project is

complete, tree protection,unloading/loading on highways, andwheel washing to avoid mud

Section106 obligation may also berequired to ensure that Thames Waterpays for any damage to roads fromconstruction traffic.

(LR)LBS, (LR)LBTH, (LR)LBE 3 We have not commenced negotiations with any local authority onplanning requirements or obligations since our design is not yet fixed.We will enter into these discussions shortly and will ensure that ourproposed requirements and any obligations, where relevant, comply withthe legal requirements and relevant guidance.

3.9.26 The Mayor expects to see adequatesafeguards included in the DCO to protect

GLA 1 We will continue our pre-application discussions with all our keystakeholders including TfL and will be discussing any relevant matters


26/34

3 Other Comments



the apparatus of a public transportundertaker from the effects of the proposedscheme. The DCO should also explain theinter-relationship with the requirements ofother consents and licenses.

such as provisions in our DCO that would relate to TfL. Our DCO is likelyto include a number of other, non-planning, consents and an explanatorymemorandum as required in line with the 2008 Act.

3.9.27 It does not appear that an equality analysisassessment has been undertaken as part ofthe phase two consultation. The council

considers that one should be undertaken forthis project.

(LR)LBLew 1 We can confirm that we are undertaking an equalities impactassessment, the output of which will be submitted with our DCOapplication.

3.9.28 Concerns about the timing for the projectgiven the number of significant project-wideand site specific issues that are still to beresolved and given the need for consultationon sustainability and energy statements,cumulative impacts, and detailed phasing ofconstruction.

WCC 1 We are undertaking our consultation exercise in accordance withrelevant statutory requirements and having regard to governmentguidance and policy. We carefully considered the information we madeavailable at our phase two consultation to ensure that consultees hadsufficient information to respond to the consultation. The level ofinformation to be made available at phase two consultation was alsoagreed with potentially directly affected local authorities prior toconsultation commencing.

Our assessment methodology is in line with the Infrastructure Planning(Environmental Impact Assessment) Regulations 2008, which requiresassessment of cumulative effects.

We have identified the schemes in the local area that will be included in

the assessment based on applications which have been referred to theGLA, consistent with Planning Inspectorate Advice note nine. Section 2of the site volumes of our PEIRset out the details of any relevantdevelopments that will be taken into consideration. We will continue tomonitor proposed development in the local area and any relativecumulative effects would be reported in our Environmental statementthat will be submitted as part of our DCO application.

An Energy statementand Sustainability appraisalwill be submitted aspart of our DCO application. There is no requirement under the 2008 Actfor consultation to be undertaken on drafts of these documents.

Information on construction phasing was also contained in the siteinformation papers and site volumes of the PEIR. Further details will beavailable as part of our DCO application.

3.9.29 The Greater London Authority/Transport for

London will expect any occupation of itsproperty by Thames Water to be on thebasis of agreement as opposed to byexercise of powers.

GLA 1 It is our intention, in line with relevant guidance on land acquisition, to

negotiate with the relevant land owners, and we will therefore continueour discussions on these matters with the GLA/TfL.

3.9.30 In relation to licences required under Part 4of the Marine and Coastal Access Act 2009,the following is advised:

the construction of the whole of the maintunnel is a licensable activity. It may bemore appropriate to include tunnelling

(LR)MMO 1 Noted, we are continuing our discussions on these matters with theMMO.


27/34

3 Other Comments



works at sites associated with theconstruction of the tunnel in the marinelicence for main tunnel

there are no marine licensable activitiesand therefore no marine license isrequired at Acton Storm Tanks orFalconbrook Pumping Station

the following sites should be considered

as part of main tunnel license but do notrequire separate site marine licenses:Hammersmith Pumping Station and BarnElms for the short connection tunnel

licensable activities are being undertakenat: Putney Bridge Foreshore, DormayStreet, Carnwath Road Riverside,Cremorne Wharf Deport, ChelseaEmbankment Foreshore, Kirtling Street,Heathwall Pumping Station, AlbertEmbankment Foreshore, VictoriaEmbankment Foreshore, BlackfriarsBridge Foreshore, Chambers Wharf, KingEdward Memorial Park Foreshore andGreenwich Pumping Station

no licensable activities at King GeorgesPark, Earl Pumping Station, DeptfordChurch Street, Abbey Mills PumpingStation and Beckton Sewage TreatmentWorks

site assessment figures show that in mostof the sites the draft limit of land to beacquired includes an extra area offoreshore and river adjacent to theproposed works. If any further works areto go ahead within this area in the future,a marine licence may be required.

possible dredging has been mentioned ata number of sites. Should the dredged

material be disposed of at sea this willalso require a marine licence and thesediment would need to be sampled andanalysed in line with Convention for theProtection of the Marine Environment(Ospar) guidelines to ensure compliancewith Ospar.

in relation to marine historic environment,any site investigation works, such as grabsamples or borehole surveys, required


28/34

3 Other Comments



below mean high water springs, wouldrequire a marine licence.

3.9.31 Where necessary, suitable notices tomariners will also need to be issued. Thisrequirement would need to be captured onthe relevant marine licences for monitoringand enforcement purposes.

(LR)MMO 1

Approach to transport assessment

3.9.32 The impact of the project on transportassets has not yet been fully assessed.Query to what degree the requirement forsecondary lining has been included in trafficmodelling figures and for each sitesduration programme and other additionalimpacts.

GLA 1 As part of our PEIRwe have assessed the construction transport effectsof the proposed development on pedestrian and cycle routes andhighway layout, operation and capacity. As part of the assessment wehave considered the effects of lorry and (where applicable) bargetransport, based on a methodology that has been discussed and agreedwith the local authority and TfL. The PEIRwas available as part of ourphase two consultation. We acknowledge that this is a preliminaryassessment; we are preparing a full Transport assessmentforsubmission within the Environmental statementas part of our DCOapplication.For the purposes of all these assessments we have assumed there willbe secondary lining required for the tunnel and main connection tunnelsand all drop shafts so all the data used includes the relevant trafficmovements etc associated with these activities.

3.9.33 Greater use can and should be made of theriver, and possibly rail. Cost-savingopportunities can be realised as well as thegeneral reduction in impacts, noise, safetyrisks and emissions.

A nominal figure of a 70m increase inproject costs has been identified to accountfor the use of barges. Transport for Londonhas not seen the evidence or breakdown ofthis cost and therefore cannot comment onwhether it is a reasonable estimate or towhat extent other impact costs (such as airquality, congestion and safety) can beaverted. The installation of permanentfacilities such as transhipment points andnew rail heads may have a value for otheruses after completion of the tunnel. Theidentification and appraisal of these facilitiesshould be explicitly considered andopportunities for use explored and identifiedwithin expected social cost benefit analyses.The use of rail opportunities also needs tobe further explored.

GLA 1 We are examining options for increasing the use of the river for thetransport of materials with the PLA, TfL/GLA and other stakeholders,and are examining the feasibility of these options using social,environmental and economic criteria. We will summarise this informationin our DCO application materials.

3.9.34 Full use should be made of the river for the LR9154 1 It is our intention to use the river to transport 90 per cent of excavated


29/34

3 Other Comments



movement of excavated material anddelivery of materials to minimise the widerenvironmental impact of the Thames Tunnelproject. River transport should bemaximised for delivery and removal ofexcavated materials from worksites. Theconsultation material leaves too muchflexibility over transport management.

material from main tunnel drive sites. However, it is not generallypractical and cost-effective to transport all materials by barge so wewould still need to transport some materials by road.

3.9.35 Confirmation requested that: all excavated material from the main

tunnel and where possible from the CSOconnection tunnels will be transported bybarge

it will be a requirement for the contractsthat the tunnel segments and materialsfor the lining arrive by water

the cost of the disruption that would becaused by bringing materials by roaddoes not appear to have beenconsidered, as it should have been,against the possible saving to ThamesWaters own contracts by doing so.

9155 1 We are examining options for increasing the use of the river for thetransport of materials with the PLA, TfL/GLA and other stakeholders,and are examining the feasibility of these options using social,environmental and economic criteria. We will summarise this informationin our DCO application materials.

3.9.36 Thames Water should promote a logisticsplan that:

maximises the use of river and railtransportation

minimises the impact on the strategic andlocal highway network

minimises overall and local environmentalimpacts

is cost-effective considering all direct andindirect costs and benefits consistent withestablished government guidance ontransport investment.

GLA 1

3.9.37 The cost of any identified mitigation

measures to Transport for Londonshighway network, assets or services wouldneed to be met by the project promoter.

GLA 1 We have not commenced negotiations on planning requirements or

obligations since our design is not yet fixed. We will enter into thesediscussions shortly and will ensure that our proposed requirements andany obligations, where relevant, comply with the legal requirements andrelevant guidance

3.9.38 There is a need to address the access toconstruction sites, the impact on local roadsarising from movement of excavatedmaterial, residential car parking and localbusiness continuity.

LR9154 1 We are reviewing the proposed routes that construction traffic would useas part of our Transport assessment. If the Transport assessmentidentifies any likely significant effects arising from congestion we willdevelop mitigation measures to minimise the effects of any disruption.

We are also developing a CoCP(a draft was provided as part of ourphase two consultation), which will include requirements for a Traffic


30/34

3 Other Comments



management planto ensure that construction traffic is carefullycontrolled to minimise any potential effects on the road network includingaccess to the local area, setting out construction traffic routes, siteaccess/egress points, signage and monitoring procedures.

3.9.39 During the construction phase there will be aconsiderable increase in the volume of rivertraffic. While projected barge movementsassociated with each individual construction

site have been provided, a full assessmentof the in-combination impact of these bargemovements cannot be made until a holisticnavigational risk assessment has beenconducted for the project in its entirety.

LR13477 1 We have discussed the use of the river for transporting materials withthe PLA, the body which is responsible for regulating the use of theRiver Thames. We are preparing a Navigational risk assessmentforsubmission as part of our DCO application, the approach to which is

being discussed with the PLA. We are will continue to discuss ourproposals to minimise risk to river navigation by commercial or leisureriver users. We will also complete a survey of river usage, the findings ofwhich will be reported in our DCO application and will inform furtherdiscussions with the PLA.

3.9.40 Objection to the size and number ofproposed barge movements on the RiverThames. Without any detail available onscheduling, this could lead to bottlenecksoccurring, particularly at river bridges and atkey tide times.

WRWA 1

Construction of the project

3.9.41 Where lorries are absolutely necessary theyshould be retrofitted with technology that

reduces their carbon emissions.

9423 1 Currently, environmentally vehicles are not a mainstream technology.However, we recognise that the project is not expected to begin for

several years and that it will take a number of years to complete.Therefore we will encourage our contractor to investigate theopportunities to utilise environmentally friendly vehicles duringconstruction.

3.9.42 Thames Water should look carefully at thephasing of the sites throughout London. Thisshould also be shared with boroughs to tryto minimise the project s impacts.

LC, 9131LO 2 The transport and environmental assessments are considering thecombined effects of construction activities at the various sites.Throughout the design process we have sought to minimise the effectsof the project.

3.9.43 Thames Water will need to establish aresource or team to centrally coordinate andmanage all construction logistics activityacross the project. One of its remits will bethe need to provide the adequateenforcement of agreed routes by any

construction traffic to the satisfaction ofTransport for London.

GLA 1 Noted. We have not yet developed our proposals to manageconstruction logistic activities but are aware that other major constructionprojects including Crossrail have followed this approach.

3.9.44 Due to the increased heavy goods vehiclemovements that will result from project,confirmation should be provided that allcontractors will be mandated to fit theirvehicles with specialist sensors and mirrorsto protect vulnerable road users such ascyclists.

9429 1 Our contractors will be required to meet industry best practice in relationto measures to protect vulnerable road users. These will be set out inour CoCP.


31/34

3 Other Comments



3.9.45 Thames Water should put in place aprogramme to train and employ Londoners,especially those seeking work, to undertakeas many of these jobs as possible.

GLA 1 We estimate that the tunnel would directly employ about 4,250 people inconstruction and related sectors, as well as providing further secondaryemployment. We actively support the Crossrail Tunnelling andUnderground Construction Academy, which is currently training andgaining employment for 70 apprentices a year. As set out in ourpublicationWhy Does Londons Economy Need the Thames Tunnel, theThames Tunnel procurement process will aim to deliver businessopportunities for small and medium sized enterprises as well as utilisinglocal products, services and labour through the supply chain wherepossible. Any such targets will be subject to market sounding to ensuretheir commercial viability and compliance with EU regulations. We aimto meet a target on employing in excess of 20 per cent local labour.

3.9.46 No discussion on the opportunities for localpeople to become engaged with the projectin a positive way and potential employmentopportunities.

LR13381 1

3.9.47 London boroughs will be looking for a clearstrategy for maximising the employment ofLondoners in the construction of theThames Tunnel project. Ambitious targetsshould be set.

LC 1

3.9.48 Invites Thames Water to work with the Portof London Authority (PLA), the operatorsand others to secure a lasting legacy for theRiver Thames through the development andtraining of the skilled marine workforcerequired to deliver this project.

PLA 1 We are already working closely with the PLA and others to examine thefeasibility of increasing the use of the river for the transport of materials,subject to cost, environmental and other constraints. We are aware thatincreased use of the river would require the development and training ofthe marine workforce, and this is one of the constraints which we areexamining.

3.9.49 Construction operations for the ThamesTunnel project could potentially impact onnavigation on the River Thames and mayrequire marking by aids to navigation.Consultation will be required with the PLA inthe first instance as the responsibleauthority for the River Thames. TrinityHouse will also be able to advise the PLA orthe developer on aids to navigation mattersas required in due course.

supp report on p2 consultation - chapter 3 other feedback

Documents