Supp Report On P2 Consultation - Chapter 3 Other Feedback

110-RG-PNC-00000-000784 | May 2012
Supplementary report on phase two consultation

Chapter 3 Other feedback
3 Other Comments
Thames Tunnel Supplementary report on phase two consultation

List of contents
Page number
Other comments ............................................................................................ 3-1 3.1 3.2 3.3 3.4 3.5 3.6 3.7 3.8 3.9 3.10 Introduction ........................................................................................... 3-1 Other supportive and neutral feedback comments ............................... 3-1 Preliminary environmental information report ....................................... 3-2 Site selection methodology paper ......................................................... 3-7 Phase two scheme development report................................................ 3-9 Code of construction practice Part A: General requirements ................ 3-9 Draft waste strategy ............................................................................ 3-11 Design development report................................................................. 3-13 Other objections, issues and concerns ............................................... 3-16 Our view of the way forward ............................................................... 3-31
3 Other Comments
List of tables Table 3.2.1 Other supportive and neutral feedback comments ............................. 3-1 Table 3.3.1 Supportive and neutral feedback comments relating to the Preliminary environmental information report ..................................... 3-2 Table 3.3.2 Objections, issues and concerns relating to the Preliminary environmental information report ........................................................ 3-3 Table 3.4.1 Objections, issues and concerns relating to the Site selection methodology paper ............................................................................. 3-8 Table 3.5.1 Supportive and neutral feedback comments relating to the Phase two scheme development report ............................................. 3-9 Table 3.6.1 Supportive and neutral feedback comments relating to the Code of construction practice Part A: general requirements .............. 3-9 Table 3.6.2 Objections, issues and concerns relating to the Code of construction practice Part A: general requirements ............ 3-10 Table 3.7.1 Supportive and neutral feedback comments relating to the Draft waste strategy.......................................................................... 3-11 Table 3.7.2 Objections, issues and concerns relating to the Draft waste strategy.......................................................................... 3-12 Table 3.8.1 Supportive and neutral feedback comments relating to the Design development report............................................................... 3-13 Table 3.8.2 Objections, issues and concerns relating to the Design development report............................................................... 3-15 Table 3.9.1 Other objections, issues and concerns ............................................. 3-16
3 Other Comments
3
3.1
3.1.1
Other comments
Introduction
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 our feedback 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 3.1.3 3.1.4
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. Our responses to the feedback comments raised by respondents are set out in the tables. 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. Where a response contains a reference to our website, go to www.thamestunnelconsultation.co.uk for 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 3.2.1 Supportive and neutral comments Welcome that the tunnel is expected to directly create over 4,000 jobs in construction and associated industries. The City of Westminster wishes to be involved in ensuring access to these jobs is made available to Westminster residents. Respondent ID LC, WCC No. 2 Our response Your support is noted and welcomed.
3.2.2
Support the new air management strategy WCC as appropriate to avoid odour from tunnel operations and to reduce the size and height of the ventilation columns. Pleased that Thames Water's approach to EA the project will consider impacts and opportunities in all phases of the project and that these will be considered on an individual site and a cumulative, project wide basis. Welcome that the number of foreshore sites with permanent structures has been EA
3.2.3
3.2.4
3-1
3 Other Comments Ref 3.2.5 3.2.6 Supportive and neutral comments reduced from eight to seven. Welcome the studies that are currently progressing with regard to flood risk. Pleased that the decision hierarchy (avoid, mitigate, compensate, enhance) is being used by the project team. Respondent ID EA EA No. 1 1 Our response
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 Ref 3.3.1 Supportive and neutral comments The Preliminary environmental information report (PEIR) appears to include all the relevant information to inform a comprehensive Environmental statement in the future. The PEIR appears to have identified all the relevant pressures and receptors associated with the project. There is a substantial amount of new and historic data and this should be sufficient to inform any subsequent Environmental statement. Welcome the consideration given to both terrestrial and aquatic wildlife in assessing the likely impacts and setting out the proposed designs for each site. Content that the assessment methodologies for aquatic and terrestrial ecology as set out in volumes 5 and 6 of the PEIR represent a robust approach to assessing and addressing the impacts of the Thames Tunnel project on biodiversity at both the site and project wide scale. Welcomes the identification of the need for particular care in respect of listed buildings and structures with regard to settlement impacts and the recognition of the need for heritage specialists to play a key role in the assessment of the potential for this type of impact on listed buildings. Overall the PEIR is clear and well structured, reflecting a good understanding of the environmental issues in the Thames estuary. Respondent ID (LR)MMO No. 1 Our response Your support is noted and welcomed.
3.3.2
LR9491
3.3.3
NE
3.3.4
EH
3.3.5
(LR)MMO
3-2
3 Other Comments Ref 3.3.6 Supportive and neutral comments Respondent ID No. 1 Our response
The methodology proposed to undertake the (LR)MMO environmental impact assessment is appropriate and in line with the IEEM Guidelines and the requirements of the 2011 EIA Regulations (Town and Country Planning Act 1999) and the 2009 EIA Regulations (Planning Act 2008), and guidance associated with both. The use of the 'ABC' method for assessing and establishing significance criteria for construction noise is acceptable. (LR)RBKC
3.3.7
Objections, issues and concerns

Table 3.3.2 Objections, issues and concerns relating to the Preliminary environmental information report Ref 3.3.8 Objections, issues and concerns The amount of information presented is large and lacks an appropriate summary of the main issues which would facilitate the reference to specific sections and annexes. There is no information contained within the PEIR to suggest that Thames Water has done or intends to undertake a full cost benefit analysis covering the use of river rather than land based transport to bring in equipment and subassemblies and to take out excavated material during the construction phase. Consideration does not seem to have been made of any major known construction projects that are occurring at any of the sites. Respondent ID (LR)MMO No. 1 Our response Noted, consideration will be given to the structure and presentation of the Environmental statement.
3.3.9
LR13496LO
We do not intend to undertake a full cost-benefit analysis covering use of the river because there is no agreed methodology for attributing financial costs to certain environmental assets eg heritage, ecology and townscape. We are undertaking a transport assessment which will evaluate different transport scenarios, including road, river and rail, using both quantitative and qualitative criteria that reflect social, economic and environmental objectives and policies. Our assessment methodology is in line with the Infrastructure Planning (Environmental Impact Assessment) Regulations 2009, which requires assessment 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 the GLA, consistent with Planning Inspectorate Advice note nine. Section 2 of the site volumes of our PEIR set out the details of any relevant developments that will be taken into consideration. We will continue to monitor proposed development in the local area and any relative cumulative effects would be reported in our Environmental statement that will be submitted as part of our DCO application. Our assessment methodology is in line with the Infrastructure Planning (Environmental Impact Assessment) Regulations 2009. We are therefore confident that we will be able to correctly assess the number and scale of impacts arising from the Thames Tunnel project. We are also developing a Code of Construction Practice (CoCP) which will set out how we will manage our construction sites to minimise disruption to nearby communities. During construction, we will require all
3.3.10
(LR)MMO
3.3.11
Concerned that local residents will have no recourse if the environmental impact assessment turns out to be incorrect or underestimates the damage to the local area that may be caused by the proposals.
8751
3-3
3 Other Comments Ref Objections, issues and concerns Respondent ID No. Our response contractors to be fully certified under the Considerate Contractors Scheme. These measures will allow us to identify any unforeseen effects arising from construction and put in place suitable measures to manage them. Once the tunnels are operational, we propose to undertake performance monitoring as well as regular inspection and maintenance visits which will allow us to identify any unforeseen effects and put in place suitable measures to manage them. The PEIR provides preliminary environmental information on the Thames Tunnel project. As such, it represents a snap shot in time during the environmental impact assessment process to facilitate effective consultation. Because the report is preliminary, the assessment information is not final or complete. Where appropriate, the report indicates what further work is to be undertaken. The environmental assessment process is continuing and will culminate in the production of an Environmental statement which will be submitted with our DCO application. The effect on river navigation is being considered separately as part of a Navigational Risk Assessment, which we are preparing in consultation with the Port of London Authority. Our PEIR was made available at phase two consultation. Volume 22 contains a preliminary assessment of the environmental effects associated with Chambers Wharf. We welcome the technical comments provided on the PEIR. As part of the environmental impact assessment process we will be reviewing the detailed technical comments received and continuing to engage with statutory consultees and potentially directly affected local authorities on environmental impact assessment generally as well as on the specific technical comments raised. A summary of how comments received in relation to the environmental impact assessment have been taken into account will be contained within the Consultation report with more detail contained within the Environmental statement; both documents will be submitted with our DCO application.
3.3.12
The PEIR places undue reliance on desk study, partial data and modelling. Specifically, there is insufficient environmental information to allow the respondent to assess the impact of proposals at Carnwath Road Riverside on their property.
8753
3.3.13
There is no mention of navigational risks in the PEIR. Concerned that Thames Water is not publishing details of environmental impacts at the preferred sites, specifically Chambers Wharf. Detailed technical comments were provided on the contents of volumes 1 - 6 of the PEIR including: volume 3 should strengthen the discussion of the role of sustainable urban drainage systems (SuDS) in relation to the historic environment volume 4 no reference is made to the scoping response submitted by London Borough of Southwark volume 5: o on assessment methodologies including in relation to air quality and odour, noise and vibration, socioeconomics, transport, flood risk, townscape and visual, ecology aquatic, ecology terrestrial, surface water, physical hydraulic modelling, mathematical hydraulic modelling, geotechnical modelling, scour and deposition assessment
8853
3.3.14
9085LO, 9086LO
3.3.15
CoL, EA, EH, GLA, (LR)MMO, (LR)RBKC, WCC, (LR)LBS, (LR)LBE, (LR)LBTH, 13380
3-4
3 Other Comments Ref Objections, issues and concerns o there is a requirement for study of tunnelling on flood defence settlement o do not accept any characterisation of enhancement as something over and above what might reasonably be expected as part of mitigating direct, in-direct, secondary, cumulative, incombination and compound impacts on the historic environment caused by the project volume 6 in relation to project wide effects including air quality (specifically underestimation of the effect of construction traffic on emissions) ecology aquatic, groundwater, surface water, and flood risk. A number of works methodologies or exact locations are missing, preventing the Marine Management Organisation (MMO) from being able to confirm whether works are licensable. The MMO assumes this is due to the preliminary nature of the documentation, however, the environmental impact of these works would need to be comprehensively covered within the Environmental statement to enable the MMO to carry out a thorough review. Acton Storm Tanks - detailed technical comments were provided in relation to assessment. Hammersmith Pumping Station - detailed technical comments were provided in relation to assessment. Barn Elms - detailed comments were provided in relation to assessment. Respondent ID No. Our response
3.3.16
(LR)MMO
3.3.17
GLA
3.3.18
EH, GLA
3.3.19 3.3.20
EH, GLA
2 2
Putney Bridge Foreshore - detailed technical EH, GLA comments were provided in relation to the assessment of archaeological effects for the main site and temporary slipway and in relation to the assessment on the site context, historic environment, townscape and visual, transport and water resources surface. Dormay Street - detailed technical GLA
3.3.21
3-5
3 Other Comments Ref Objections, issues and concerns comments were provided in relation to assessment. King George's Park - detailed technical comments were provided in relation to assessment. Carnwath Road Riverside - detailed technical comments were provided in relation to assessment. Falconbrook Pumping Station - detailed technical comments were provided in relation to assessment. Cremorne Wharf Depot - detailed technical comments were provided in relation to assessment. Chelsea Embankment Foreshore - the absence of an assessment of the setting of heritage assets in this volume of the PEIR presents an inaccurate impression of the appropriateness of the foreshore site for development particularly when compared to Ranelagh Gardens. Detailed technical comments were also provided in relation to assessment on: site context, historic environment, air quality and odour, noise and vibration, townscape and visual, water resources - surface water, transport, land contamination and appendix A: historic environment. Kirtling Street - detailed technical comments were provided in relation to assessment. Heathwall Pumping Station detailed technical comments were provided in relation to assessment. Albert Embankment Foreshore - detailed technical comments were provided in relation to assessment. Victoria Embankment Foreshore - detailed technical comments were provided in relation to: air quality, historic environment, noise and vibration, socio-economic, townscape and visual, transport and water resources (surface). Blackfriars Bridge Foreshore - detailed technical comments were provided in Respondent ID No. Our response
3.3.22
EH, GLA
3.3.23
EH, GLA, 9461
3.3.24
EH, GLA
3.3.25
EH, GLA, (LR)RBKC
3.3.26
EH, GLA, (LR)RBKC
3.3.27 3.3.28
EH, GLA EH, GLA
2 2
3.3.29
EH, GLA
3.3.30
EH, GLA, WCC
3.3.31
EH, GLA
3-6
3 Other Comments Ref Objections, issues and concerns relation to assessment including the phase two assessment which indicates that the impact of the proposal on road users in this area is minor adverse. This assessment clearly does not adequately reflect the nature and period of impact arising from the scheme proposals. Shad Thames Pumping Station - this should be a standalone chapter in the Environmental statement. Chambers Wharf - detailed technical comments were provided in relation to assessment. Earl Pumping Station - detailed technical comments were provided in relation to assessment. Deptford Church Street - detailed technical comments were provided in relation to assessment including in respect of: air quality, historic environment, noise and vibration, socio-economic, townscape and visual, transport, mitigation and terrestrial ecology. Greenwich Pumping Station - detailed technical comments were provided in relation to assessment including on aquatic ecology and terrestrial ecology. King Edward Memorial Park Foreshore detailed technical comments were provided in relation to assessment. Abbey Mills Pumping Station - detailed technical comments were provided in relation to assessment. Beckon Sewage Treatment Works detailed technical comments were provided in relation to assessment. Respondent ID No. Our response
3.3.32
GLA, (LR)LBS
3.3.33
EH, GLA
3.3.34
EH, GLA
3.3.35
EH, GLA, (LR)LBLew, 8937, 9065
3.3.36
EH, GLA, 9066
3.3.37
EH, GLA
3.3.38
EH, GLA
3.3.39
EH, GLA
3.4
3.4.1
Site selection methodology paper

No supportive or neutral feedback comments were received in relation to the Site selection methodology paper.
3-7
3 Other Comments

Table 3.4.1 Objections, issues and concerns relating to the Site selection methodology paper Ref 3.4.2 Objections, issues and concerns Except when a site is Thames Water's own property, it is clear that construction must, if only for the sake of cost, be at places of CSO interception and avoid extra environmental damage. Respondent ID 9488, 9395 No. 2 Our response In accordance with the Site selection methodology paper and Site selection background technical paper sites have been selected on the basis of needing to intercept existing CSOs. CSOs are in fixed locations and the site to intercept the CSO needs to on the line of, or in close proximity to, the sewer. Site selection has involved a multi-disciplinary approach and has considered environmental factors alongside planning, community, engineering and property considerations. We are satisfied that our approach takes full account of environmental issues. Ownership of a site was taken into account along with other considerations as set out in the Site selection methodology paper. However, it should be noted that the location of CSO sites is constrained by the location of the existing combined sewers, because the interception chambers have to be built on the existing sewers and therefore the search area for the CSO sites is limited to the vicinity of the existing CSO. Working within these constraints we have sought to use operational sites as far as possible. Of the sites presented at phase two consultation, seven sites are within our existing pumping stations, with a further three sites located on land we own. As part of the site selection process, whether a site is brownfield or greenfield is one of many considerations taken into account when determining whether or not a site is suitable. Given that we had a limited search area to identify a suitable CSO/main tunnel sites, we did not consider it was appropriate to exclude sites based on their use when compiling our longlist of sites. Although not related to site selection, we have been assessing the likely significant effects that may arise as a result of the works as part of an environmental impact assessment. This will set out measures necessary to mitigate any significant adverse effects that are identified. Other suggestions, which may include betterment, will be subject to further discussions with the local planning authority and may be secured through a section 106 agreement.
3.4.3
In the interests of local communities and 9063, 9067 local environments, we believe that as far as is possible works should be carried out at Thames Water's existing pumping stations.
3.4.4
Thames Water should also consider researching further solutions to avoid the potential destruction of other greenfield sites in the whole construction of the Thames Tunnel project. Even if it costs more money, this should be prioritised over effects on local residents. Thames Water appears to have adopted a strategy of targeting green space, amenities and heritage assets for its infrastructure/caustic wastes rather than taking the long term responsible option of properly appraising brownfield alternatives. Should avoid the use of green spaces. Whether or not the works affect open spaces or the Thames Path, extension or improvement of open spaces and rights of way would be welcomed as part of any final restoration of the sites.
8996, 10701
3.4.5
9055
3-8
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 Ref 3.5.1 Supportive and neutral comments Detailed technical comments were provided on Phase two scheme development for: Chelsea Embankment Foreshore, Albert Embankment Foreshore, Victoria Embankment Foreshore, Blackfriars Bridge Foreshore, Greenwich Pumping Station. English Heritage also notes that they have not been consulted on shortlisted sites at Chelsea Embankment Foreshore, Albert Embankment Foreshore, Victoria Embankment Foreshore and Blackfriars Bridge Foreshore. Respondent ID EH No. 1 Our response We welcome the technical comments provided on the Phase two scheme development report. We will take these comments into account as part of the site selection process/documenting of the site selection process. Further details will be contained within the Final report on site selection 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 Ref 3.6.1 Supportive and neutral comments Welcome the provision for heritage management plans as part of the proposed Construction environmental management plans. Pleased to see that contractors will consider using on or offsite soil remediation to deal with contaminated soils. Pleased to see that pre-demolition audits will be undertaken to identify high value reuse opportunities for materials present and that asbestos surveys will be undertaken to identify and manage any asbestos containing materials. Request the opportunity to review the community liaison plan that is to be prepared by the contractor to establish the monitoring framework for the project. Respondent ID EH No. 1 Our response Your support is noted and welcomed.
3.6.2
EA
3.6.3
EA
3.6.4
EH
The local authorities will be able to review the community liaison plan. Where relevant, other statutory consultees may also be given the opportunity to review the plan. This is under review and may be considered for inclusion in the next draft of the document.
3-9
3 Other Comments

Table 3.6.2 Objections, issues and concerns relating to the Code of construction practice Part A: general requirements Ref 3.6.5 Objections, issues and concerns Detailed technical comments were provided in relation to: main site layout, waste legislation references, lighting, noise and vibration, air quality, heritage, land quality and remediation, pre-demolition audits and the selection guide. Detailed technical comments were received in relation to waste legislation references. The lighting management plan will need to consider the aquatic environment as well as the terrestrial, particularly the need to avoid direct lighting of the watercourse to avoid inhibiting movements of photophobic species. Any de-watering operations for cofferdams or in-river structures will need to consider the need for a fish rescue. Requirements of the City of London Code of Practice for Construction and Demolition should be applied. Machinery and plant should meet European Emissions standards. More detail is required on river transport. The PLA expects that contractors will do more than 'reasonably practicable' to maintain clearance within the navigational channel during construction. Respondent ID EA, EH, GLA, WCC, (LR)RBKC, (LR)LBE, (LR)LBTH No. 7 Our response We welcome the technical comments provided on the draft CoCP. As part of the process of developing the CoCP we will be reviewing the detailed technical comments received and continuing to engage with statutory consultees and potentially directly affected local authorities on the CoCP generally as well as on the specific technical comments raised. A summary of how comments received have been taken into account will be contained within the Consultation report with more detail contained within the Environmental statement; both documents will be submitted with our DCO application.
3.6.6 3.6.7
EA EA
1 1
3.6.8
EA
3.6.9
CoL
Where CoCPs have been produced by the local authorities directly affected by the Thames Tunnel project, these have been taken into consideration while preparing the draft CoCP. The CoCP to be submitted with our DCO application will require machinery and plant to meet European emissions standards. It is our intention to develop this section further with input from the PLA and other relevant stakeholders, for inclusion within the next draft of the document.
3.6.10 3.6.11
(LR)LBS, (LR)LBTH PLA
1 1
3.6.12
Query whether a one size fits all approach GLA will be appropriate across the 14 local authorities for Part A of the CoCP. In particular, appendix B of Part A provides guidance on how to apply for a Section 61 agreement under the Control of Pollution Act 1974. Table B.1 assumes standard hours of work for the purposes of the Control of Pollution Act and does not give local authorities discretion. We understand that the Code of 8986 Construction Practice specific to each site will soon be coming out but, by that time, the consultation will be finished. We think that it is essential that residents who will be
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 general requirements, and has been produced to get general agreement across all 14 boroughs. Part B is site specific, and allows changes to be recognised across the boroughs. This includes detailing how working hours are defined, and allowing for variance in the boroughs methods for dealing with this.
3.6.13
The CoCP will comprise two main parts: Part A: General requirements. These measures will be applicable project wide Part B: Site specific requirements. This will document site specific
3-10
3 Other Comments affected will have the chance to have some input and to make comments. requirements. A draft of Part A of the CoCP was produced as part of the phase two consultation, which respondents had the opportunity to comment on. A draft of Part B of the CoCP will be prepared. The CoCP will be submitted as part of the DCO application, at which point members of the public will be able to make representations on the document.
3.7
Draft waste strategy

Table 3.7.1 Supportive and neutral feedback comments relating to the Draft waste strategy Ref 3.7.1 Supportive and neutral comments Welcome the inclusion of the objectives to conserve landscape and townscape and to protect heritage for the Excavated materials options assessment. Support the provision of training to site workers on recycling procedures and use of a standard site waste management plans (SWMP) template across all sites as this will provide consistency in terms of the information contained/gathered and style/layout. Welcome the commitment to finding a beneficial use for as much of the excavated material as possible, and would welcome firm proposals for the planned end use of excavated material. The shortlisted receptor sites for utilisation of the excavated materials will be included in the waste strategy once they have been finalised. We would welcome an opportunity to review these for historic environment implications when they become available. The Excavated materials options assessment outlines the environmental, socio-economic, operational and waste management policy evaluation objectives used to assess receptor site suitability. The Royal Society for the Protection of Birds has considered the objectives in relation to the Wallasea Wild Coast Project and believes that this site could meet or exceed the published objectives for the receipt of excavated material. Respondent ID EH No. 1 Our response Your support is noted and welcomed. In relation to the planned end use for excavated material, this will be set out in the Waste strategy submitted with our DCO application.
3.7.2
EA
3.7.3
LR9447
3.7.4
EH, LR9447
The shortlisted sites can be made available for review.
3.7.5
LR9447
The results of the Excavated material options assessment will be published in the Waste strategy submitted as part of the DCO application. Wallasea Wild Coast Project is one of the receptor sites considered in the assessment.
3-11
3 Other Comments

Table 3.7.2 Objections, issues and concerns relating to the Draft waste strategy Ref 3.7.6 3.7.7 Objections, issues and concerns A sustainable process/end location is required for the disposal of tunnel arisings. The Waste Framework Directive mandates that the waste hierarchy be followed, rather than just placing greater emphasis on it. Should include a stronger commitment towards recycling by contractors and sub contractors. Contractors should be mandated to recycle welfare waste. Require confirmation that the excavated materials from the tunnelling sites will be dealt with in a sustainable manner. The Excavated Materials Options Assessment sets a suitable framework, although the environmental objectives should include enhancement alongside protection. Details of the options selected should form part of the final proposals. Any proposed recovery should offer genuine environmental, social and economic benefits. Excavated material should be taken to Maplin by rail via Shoeburyness to firm the fill for reclaiming the co-ordinated Thames Estuary development. Further consideration is required to identify the most beneficial use for the excavated material and whether it is suitable for a positive use such as aggregate material. In particular it would be beneficial to examine whether any of the early shaft excavation material or excavation material from other projects, notably Crossrail or National Grid Tunnelling, could be used as infill material for the cofferdam sites in the River Thames. The landfill diversion target of 90 per cent is appropriate to begin with, however it is suggested that a reuse and recycling target of 95 per cent should be implemented by 2020 at the latest for the project as a whole. Welcome the use of the Waste Hierarchy as a guide for this strategy. More emphasis Respondent ID LBN EA, LR9447 No. 1 2 Our response One of the main purposes of the Excavated material options assessment is to identify the most sustainable disposal option for excavated material. It is integral to the Waste strategy that the waste hierarchy is followed. The Waste strategy objectives are being revised to reflect this. Noted this will be included in the next draft of the Waste strategy.
3.7.8
EA
3.7.9
CoL
Noted.
3.7.10
LR9447
3.7.11
LR9459
Approximately 250 options have been considered in the Excavated material options assessment. Maplin will be considered if potentially viable. Options to source recycled aggregates for cofferdam fill are being considered. Due to the length of the planning horizon clarity on this is not always possible at this point. But it will be included in the Waste Strategy.
3.7.12
GLA
3.7.13
GLA
We are yet to set a target for recycling; however, once set this target will be reviewed in order to maximise landfill diversion.
3.7.14
GLA
Noted.
3-12
3 Other Comments Ref Objections, issues and concerns should be placed on waste reduction and over the course of the project ambitious targets should be set for limiting the amount of waste generated in the first place. Respondent ID No. Our response
3.7.15
Further detail on how the Waste Hierarchy GLA will inform the pre-construction stages of the overall project and the individual site projects eg the planning and design, through to material specification and procurement stages, is needed. The target for the use of reused and recycled materials should be set from the outset in order to drive the work of the various contractors. Detailed technical comments were provided on the Draft waste strategy. GLA
This will be included in the Waste strategy.
3.7.16
A target will be included in the Waste strategy, which will be submitted as part of the Development Control Order.
3.7.17
GLA
We welcome the technical comments provided on the Draft waste strategy. As part of the developing our waste strategy we will be reviewing the detailed technical comments received and continuing to engage with statutory consultees and potentially directly affected local authorities. A summary of how comments received in relation to the waste strategy have been taken into account will be contained within the Consultation report with more detail contained within the Environmental statement; 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 Ref 3.8.1 Supportive and neutral comments Respondent ID No. 1 Our response Your support is noted and welcomed.
Support the that the project is being EH developed in the Victorian civic infrastructure tradition and aims to build on Bazalgettes legacy of high quality designs and the aspiration for the project to provide a modern benchmark for infrastructure projects. Also, English Heritage welcomes the recognition of the heritage and townscape issues that relate to the design of the river walls. The principles guiding the design approach should be tied to an overarching design vision to underpin the site-specific design briefs. Such a vision should be based on a clear grasp of the diverse character of the River Thames, reflecting the particular conditions at those points where (LR)CABE
3.8.2
The overarching statement of architectural and landscape design is contained in the Design project information paper. In developing our designs for phase two consultation, we have taken into account: - local context of each site, including specific opportunities and constraints - feedback received at phase one consultation
3-13
3 Other Comments Ref Supportive and neutral comments interventions are proposed. Respondent ID No. Our response - 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 report explains further how we have sought to include common design themes across London while responding to the local context. We note your comments and although we have not specifically grouped our sites into these categories we believe our designs have responded positively to their local surroundings and the technical requirements to intercept the existing flows which differ along the route. The overarching statement of architectural and landscape design is contained in the Design project information paper and is supported by further detail in the Design development report which sets out how we have approached design across the route and at each site. Your comment is noted. The Design development report sets out how we have approached design across the route and at each site.
3.8.3
Sites fall into two categories: 'Central foreshore/monument' and 'Neighbourhood' interventions. While there will be a common thread that ties all sites together, grouping them in this way could prove a useful mechanism.
(LR)CABE
3.8.4
Designs should be celebratory when the 4 occasion demands and discreet when not but in all cases they should adopt a confident, rather than apologetic, relationship with their surroundings.
(LR)CABE
3.8.5
The following areas could be further (LR)CABE explored: promoting the special character of the River Thames and enjoyment of the riverside through opening up new views and vistas as well as preserving those that exist improving accessibility through identifying opportunities to address conflicts between road traffic and people and focussing on priorities for movement using the buildings and landscape as a way to promote learning about both Bazalgettes works and the modern achievement of the Thames Tunnel project maximising the opportunity to enhance plant and animal life across the sites bringing beneficial use to redundant listed buildings as well as promoting a better appreciation of the River Thames improving local amenity including allowing the community to have a say in shaping these projects to increase buy-in,
We note your comments and our designs at phase two have sort to address 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 where it is appropriate and practicable to do so in order to provide information on the project and the surrounding area how we have engaged with the local community is set out in our Statement of community consultation and also recorded in this report on Phase two consultation. Where practicable we have sort to utilise existing buildings for our works in order to reduce the projects footprint for example locating our equipment with Lots Road Pumping station and Beam Engine House at Greenwich Pumping Station. We will consider temporary uses of our sites where it is practicable to do so.
3-14
3 Other Comments Ref Supportive and neutral comments instil civic pride and a sense of ownership considering opportunities for temporary use of sites for use by the community so as not to blight the neighbourhoods affected. Developing common design components such as ventilation columns and manhole covers could lend the project as a whole a strong identity that unifies the above ground works along the length of the tunnel. Proposals at Blackfriars Bridge Foreshore could inform the development of an access language of steps, ramps and lifts for the whole Thames Tunnel project. Respondent ID No. Our response
3.8.6
(LR)CABE
Your support is noted and welcomed. As noted in our Design development report we consulted at phase two consultation on a number of common design principles which included ventilation columns, access covers and design of new river walls. Your comment is noted. The Design development report sets out how we have approached design across the route and at each site. We would note that the designs at each site need to take account of the local context but, we have sort to have some commonality in our designs and are seeking to develop a signature that recognises the common importance of the sites and the project to the river. We note your comment and will consider whether lighting can be used to enhance the design of our ventilation columns. We would note that generally no new operational lighting is proposed as part of the Thames Tunnel project except where we are providing or extending areas of public realm which will be accessible to the public at night.
3.8.7
(LR)CABE
3.8.8
There is an opportunity to promote the Thames Tunnel project through a consistent approach to the expression and lighting of ventilation structures.
(LR)CABE

Table 3.8.2 Objections, issues and concerns relating to the Design development report Ref 3.8.9 Objections, issues and concerns Detailed technical comments were provided in relation to Putney Bridge Foreshore, Carnwath Road Riverside, Chelsea Embankment Foreshore, Heathwall Pumping Station, A(LR)LBErt Embankment Foreshore, Abbey Mills Pumping Station, Beckton Sewage Treatment Works, Victoria Embankment Foreshore, Blackfriars Bridge Foreshore and Deptford Church Street. Support the notion of a structural signature across the project and consider that the design for the ventilation columns could achieve this effectively. However, at Acton Storm Tanks, Barn Elms, King Georges Park, Hammersmith Pumping Station and Carnwath Road Riverside this signature is not used. Recommend that thought is given to which elements are common to all sites and how these might be designed to provide an appropriate signature for the projects. Respondent ID EH No. 1 Our response We welcome the technical comments provided on our proposed designs. As part of the design development process we will be reviewing the detailed technical comments received. A summary of how comments received in relation to the design have been taken into account will be contained in the Consultation report with more detail contained within the Design and access statement; both documents will be submitted with our DCO application.
3.8.10
EH
3-15
3 Other Comments Ref Objections, issues and concerns Keen to ensure that there is an element of interpretation of the project; the heritage at each location may provide a useful opportunity to develop a signature element as well. Consider that elements of design at Albert Embankment Foreshore, Victoria Embankment Foreshore and King Edward Memorial Park Foreshore are considered on a project-wide basis as part of an interpretation strategy or signature element for the project as a whole. Thames Water should work with the Mayor, boroughs and local interests to design and deliver these improvements in line with local priorities, the principles of the Mayor's manifesto for improving public spaces, London's Great Outdoors and the All London Green grid. This should include the introduction of the Legible London wayfinding scheme and consultation with Transport for London. Respondent ID No. Our response
3.8.11
GLA
We welcome the comments provided on our proposed designs. We will be reviewing and considering these comments as we refine our design proposals. The design follows our scheme-wide principles and takes into account comments made at phase one consultation, on-going discussions with stakeholders including the 14 directly affected London local authorities, GLA, Environment Agency, English Heritage, PLA, local community groups and affected land owners as well as a design review with CABE. Our Design development report available as part of our phase two consultations sets out the principles that have informed our design in more detail. We are continuing to develop our design proposals in light of feedback to phase two consultation and will continue to engage with our stakeholders as we develop our designs. We welcome the comments provided on our proposed designs. We will be reviewing and considering these comments as we refine our design proposals.
3.8.12
The re-instatement works should incorporate cycling infrastructure, for example secure parking and Barclays Cycle Hire docking stations wherever possible, and appropriate, within the legacy public realm strategy.
GLA
3.9
Other objections, issues and concerns

Table 3.9.1 Other objections, issues and concerns Ref 3.9.1 Objections, issues and concerns Respondent ID No. 1 Our response We set out our preliminary assessment of the likely significant environmental effects at site specific and project-wide level in our PEIR that was published with our phase two consultation material. This included an assessment of socio-economic effects and effects on a wide range of environmental topics. We will develop this further and in more detail in our Environmental statement which we will be submitting with our DCO application. Our Environmental statement will describe measures to mitigate any significant adverse effects on local communities and other receptors. The methodology for our
Approach to environmental assessment The overall scheme appraisal should include (LR)CCW the wider social and environmental impacts at a local level and for London and ensure that Thames Water does all that it reasonably can to mitigate the adverse impacts on local communities.
3-16
3 Other Comments Ref Objections, issues and concerns Respondent ID No. Our response Environmental statement was consulted on with all relevant stakeholders prior to our phase two consultation. Our Code of Construction Practice will also contain measures to mitigate local effects. We intend to continue the inter-borough group (the Thames Tunnel Forum). These are high level meetings which are not really the appropriate forum in which to address detailed environmental issues. In addition, we hold regular pre-application meetings with local authority officers and other key stakeholders such as the Environment Agency, PLA and GLA at which we discuss more detailed matters such as air quality, noise and other environmental, design and planning matters. We have developed our design to take account of the feedback comments made previously regarding the footprint of our temporary and permanent foreshore structures being kept to a minimum. Our Environmental statement will identify any likely significant effects resulting from the works in the foreshore and will include appropriate mitigation measures for any significant adverse effects identified. We will also provide flood risk and navigational risk assessments with our DCO application which we will continue to discuss with the Environment Agency, PLA and other relevant stakeholders.
3.9.2
Thames Water should continue interborough groups to address issues such as air quality, noise, vibration, waste management, land quality and transport.
GLA
3.9.3
The footprint of disturbance in the channel and on the foreshore (land take) must be minimised in both the construction and operational phases unless this results in net environmental improvement such as remediation of contaminated land at the site. Only essential infrastructure should be sited in the foreshore and associated works should be sited on land if possible. The Environmental statement will need to justify and make an exceptional case for placing facilities in the river channel. The Environmental statement should highlight more of the benefits the Thames Tunnel project will bring to local communities. There is a widespread recreational use of some of the stretches of the River Thames and the improvements that will be made to the River Thames and for the users of it should be highlighted. Comments on detailed technical matters should be taken into account in the Environmental statement. Detailed technical comments were also provided on aquatic ecology, noise and vibration assessment requirements in Environmental statement.
EA
3.9.4
EA
Our Environmental statement will include an assessment of the construction and operational phases of our proposals on recreational users and will identify the social, environmental and economic benefits the Thames Tunnel project will bring to the river, local communities and recreational users.
3.9.5
EA
3.9.6
(LR)MMO
We welcome the technical comments provided on the content of the Environmental statement. As part of the environmental impact assessment process we will be reviewing the detailed technical comments received and continuing to engage with statutory consultees and potentially directly affected local authorities on environmental impact assessment generally as well as on the specific technical comments raised. A summary of how comments received in relation to the environmental impact assessment have been taken into account will be contained within the Consultation report with more detail contained within the Environmental statement; both documents will be submitted with our DCO application. We are carrying out fluvial modelling of the temporary and permanent foreshore works to establish the effects of the development on the river, and will discuss the findings with the Port of London Authority and the Environment Agency.
3.9.7
The requirement for and impact of any dredging activity required for the construction and operational phase should be fully assessed by the Environmental
EA
3-17
3 Other Comments Ref Objections, issues and concerns statement. Respondent ID No. Our response We are also undertaking scour modelling. Our design would incorporate mitigation measures to manage the temporary and permanent effects of our construction on the river. If appropriate, as part of our design development we will consider whether there are alternative options to avoid temporary structures in the river. Where significant scour is predicted, we would carry out preventative measures (such as placing rip-rap on the river bed), and in all locations the riverbed would be monitored and remedial works carried out if/as required. The requirement for and the effect of any dredging activity will be reported in the Environmental statement. Our Environmental statement will describe any mitigation measures required to address likely significant environmental effects identified in accordance with the relevant EIA regulations and guidance. This will include measures for ecology and biodiversity effects and cover both the construction and operational phases of the Thames Tunnel project.
3.9.8
Further work needs to be embedded in the environmental impact assessment to demonstrate a commitment to ensuring that ecological and other environmental impacts are robustly mitigated for in line with existing legislation and guidance and that, for example, net gains to biodiversity are secured not just after completion of the project, but during the construction programme as best possible. More detailed proposals for ensuring longterm biodiversity gains along the whole route in addition to water quality should be set out in the environmental impact assessment.
LR9491
3.9.9
LR9491
3.9.10
The environmental impact assessment LR9491 should take account of the needs of the species identified in the PEIR in construction and operation, and inform the design of the operational structure. It is not clear in the phase two consultation (LR)MMO documentation where the impacts of the construction and operation of the main tunnel will be assessed. The Marine Management Organisation would suggest that this is covered in the project-wide effects section of the Environmental statement as the effects are not site specific due to the nature of the main tunnel and that its route passes under a number of different sites. Expect a navigational risk assessment to be included in the Environmental statement either for the whole project or for each relevant site. (LR)MMO
Our Environmental statement will identify any significant effects on species identified, as well as any necessary mitigation measures required for ecology and biodiversity. Our environmental specialists have worked closely with our designers and environmental measures have been integrated into the design as it has evolved. Our preliminary assessment of the likely significant effects of the construction phase of the main tunnel is set out in the project-wide volume of our PEIR (volume 6). The project-wide part of our Environmental statement will include the full assessment of the effects of main tunnel construction, including noise and vibration and settlement effects on historic structures.
3.9.11
3.9.12
We are preparing a Navigational risk assessment as part of our application for a Development Consent Order (DCO), the approach to which is being discussed with the PLA.
3-18
3 Other Comments Ref 3.9.13 Objections, issues and concerns Respondent ID No. 1 Our response We confirm that any effect on National Grid assets will be considered and assessed and that we will continue to engage with National Grid on our proposals.
National Grid Gas Distribution owns and NGG plc operates the local gas distribution network in the area of the proposed works. Gas distribution assets are located within or in close proximity to the proposed site of the project. As part of the environmental impact assessment process, the potential impact of the proposed project on National Grid's existing and planned assets should be considered. The location of our existing and planned assets should also be taken into account at any future design stages and National Grid should be consulted at the earliest opportunity on the proposed route of the Thames Tunnel project. National Grid high voltage electricity underground cables/cable tunnels lie in or within close proximity to the proposed Thames Tunnel route/associated development, these lines form an essential part of the electricity transmission network in England and Wales. As part of the environmental impact assessment process, the potential impact of the proposed project on National Grid's existing and planned assets should be considered. The location of our existing and planned assets should also be taken into account at any future design stages and National Grid should be consulted at the earliest opportunity on the proposed route of the Thames Tunnel. Query whether Thames Water will submit an environmental impact assessment before applying for permission. Thames Water should establish a specific biodiversity action plan for the Thames Tunnel project. This should identify what measures can be implemented in advance of construction at any particular site (or elsewhere along the route), as well as during, and after construction of infrastructure. Methodological and procedural matters remain to be resolved including: NG
3.9.14
We confirm that any effect on National Grid assets will be considered and assessed and that we will continue to engage with National Grid on our proposals.
3.9.15
9069, 9068, LR13477
We can confirm that an Environmental statement reporting the environmental impact assessment will be submitted with our DCO application. Our Environmental statement has been prepared in accordance with the EIA regulations and relevant guidance and we have had regard to the councils and GLA biodiversity action plans in our assessment. We are also considering advance planting works where our assessment indicates it is necessary and where we can reach agreement with landowners. Other mitigation works will be implemented as soon as possible The matters referred to were all still evolving during our phase two consultation because we are still at the pre-application phase. We will have regard to all feedback to phase two consultation and continue
3.9.16
LR9491
3.9.17
EH
3-19
3 Other Comments Ref Objections, issues and concerns identifying the limits of deviation establishing a strategy for on-going maintenance, care and, in some cases, use of the operational sites completing assessment of the construction and operational impacts of the project on archaeology and the setting of heritage assets assessing secondary, cumulative, and compound impacts of the project on the historic environment confirming the suitability of signature features and interpretation at each site English Heritage would also welcome the opportunity to review the assessment of cumulative and compound minor impacts on the historic environment when it becomes available. 3.9.18 Compensation should be offered where impacts cannot be fully mitigated against. Query when residents will be able to apply for compensation; they need to plan in advance to allow time to make adjustments to their properties, eg installing double glazing Should mitigate imaginatively for the sites that it does end up using. EA, 8944 2 Respondent ID No. Our response discussions with all our key stakeholders such as Environment Agency, English Heritage and local authorities as we move forward to DCO submission and further develop our proposals.
Our Environmental statement will include any mitigation measures required for potential significant environmental impacts identified in accordance with the relevant EIA regulations and other relevant legislation. A guide to the Thames Tunnel compensation programme is available on our website.
3.9.19
9067
Our Environmental statement will describe any mitigation measures required to address likely significant environmental effects identified in accordance with the relevant EIA regulations and guidance. As indicated in the preliminary assessment (the PEIR), which was published as part of our phase two consultation material, the Environmental statement will include a full assessment of the likely significant effects of the construction and operational phases of the project. At each site, the ventilation column(s) have been designed to meet functional and health and safety requirements and need to be the size that we have identified to ensure that the tunnel can operate efficiently. Across the project, our approach to the design of the ventilation column(s) has been to use the height to make a positive feature or local landmark. The Thames Tunnel project is proud to sit in the tradition of great London infrastructure and we are proud that we will be materially improving the quality of the tidal River Thames for users. It is anticipated that we will need to have some flexibility in the level of detail we submit for approval and this is consistent with Planning Inspectorate advice note nine. We will continue to discuss our approach with all our key stakeholders and our application for a DCO will be prepared in accordance with the Planning Act 2008 (the 2008 Act) and
3.9.20
Should ensure that the visual and environmental impact of permanent structures is minimised.
LR9154
3.9.21
Request that Thames Water explain the level of detail that will be assessed, the potential need to provide for some flexibility on detailed design, and how this will be assessed.
GLA
3-20
3 Other Comments Ref Objections, issues and concerns Respondent ID No. Our response all the relevant associated legislation, regulations, guidance and advice. The Environmental statement will assess likely significant effects of the project within the parameters contained in the application, in accordance with Planning Inspectorate advice note nine. The National Policy Statement (NPS) for Waste Water does not preempt 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 statutory definition. The NPS for Waste Water does not seek to define what is or is not an NSIP for the purposes of the 2008 Act. Moreover, an NPS may set out the type or size of the specified description of development that is appropriate nationally or for a specified area. In establishing that the Thames Tunnel project is an appropriate project for the London catchment and articulating why it is needed and that the need for the project has been demonstrated, the NPS is properly performing its role. The NPS for Waste Water also does not seek to pre-empt or fetter the future decision that will be taken on an application for development consent under the 2008 Act. That decision will be made in accordance with the NPS unless certain specified exceptions apply, and the NPS properly sets out the criteria that should be taken into account by the decision maker. The IPC was created to implement a streamlined process for deciding nationally significant infrastructure projects. The previous system was seen as cumbersome and overly-complex, requiring developers to apply for consents under as many as eight separate, yet overlapping regimes for a single infrastructure project. One of the main benefits of this more streamlined process is the time taken to make a decision; on average it should take less than a year. This process includes a significant level of involvement of local authorities at various stages of the process including the pre-application stage that this project is currently undertaking. We have consulted with authorities and other statutory bodies on how we intended to consult at the pre-application stage as required by the 2008 Act and comments made prior to our consultation were taken into account in our published SOCC and CCS. Following submission of our application to the Planning inspectorate there will be further opportunities for the local authorities to be involved in the process. Since April this year the IPC has been abolished and replaced by the Planning inspectorate which will first consider whether to accept our application and then examine our submission and all relevant representations including the local authorities Local Impact Reports and any representations the local authorities may make during the Examination process before making its recommendations to the relevant Secretary of State. The 2008 Act established a streamlined process for deciding nationally significant infrastructure projects. This process includes a significant level of involvement of local authorities at various stages of the process including the pre-application stage, which we are currently undertaking.
Process for examining and consenting the Thames Tunnel project 3.9.22 The Waste Water National Policy Statement should not pre-empt the role of the planning process to determine whether the project is a nationally significant infrastructure project (NSIP). (LR)LBS 1
3.9.23
The proposed use of the Infrastructure Planning Commission is a deliberate attempt to circumvent the detailed consideration that a local planning authority can give to a project such as this. If this were to become an NSIP, a full public inquiry would be almost inevitable, with the associated delays.
9427
3.9.24
London's local authorities will continue to push for a strong role in the process to ensure that local issues are taken into account. Boroughs want reassurance that
LC
3-21
3 Other Comments Ref Objections, issues and concerns sufficient weight will be given to their local impacts reports to reflect the significant site specific and cumulative impacts this scheme will have on residents and businesses in affected areas. Respondent ID No. Our response We have consulted with local authorities and other statutory consultees on how we intended to consult at the pre-application stage as required by the 2008 Act and feedback made prior to our consultations were taken into account in our published Statement of community consultee and Community consultation strategy. Following submission of our DCO application to the Planning inspectorate there will be further opportunities for the local authorities to be involved in the process. Since April 2012, the IPC has been abolished and replaced by a new directorate in the Planning inspectorate which will first consider whether to accept our application and then examine our submission and all relevant representations including the local authorities local impact reports and any representations the local authorities may make during the examination process before making its recommendations to the relevant Secretary of State. We have not commenced negotiations with any local authority on planning requirements or obligations since our design is not yet fixed. We will enter into these discussions shortly and will ensure that our proposed requirements and any obligations, where relevant, comply with the legal requirements and relevant guidance.
3.9.25
Thames Water should secure commitments by conditions or requirements: London Borough of Southwark requests obligations to address mitigation associated with heritage, open space, community facilities, residential and visual amenity, transport and sustainability, employment and local procurement, public realm, other community impacts and costs of Section 106 administration London Borough of Tower Hamlets also requires Section 278 Highways Agreement or equivalent provision in the DCO and appropriate liaison regarding site hoardings etc, prior to construction. The council also requires provisions in the DCO to make good any damage to roads. London Borough of Ealing requests conditions on the removal of storm tanks when the Thames Tunnel project is complete, tree protection, unloading/loading on highways, and wheel washing to avoid mud Section106 obligation may also be required to ensure that Thames Water pays for any damage to roads from construction traffic. The Mayor expects to see adequate safeguards included in the DCO to protect
(LR)LBS, (LR)LBTH, (LR)LBE
3.9.26
GLA
We will continue our pre-application discussions with all our key stakeholders including TfL and will be discussing any relevant matters
3-22
3 Other Comments Ref Objections, issues and concerns the apparatus of a public transport undertaker from the effects of the proposed scheme. The DCO should also explain the inter-relationship with the requirements of other consents and licenses. It does not appear that an equality analysis assessment has been undertaken as part of the phase two consultation. The council considers that one should be undertaken for this project. Concerns about the timing for the project given the number of significant project-wide and site specific issues that are still to be resolved and given the need for consultation on sustainability and energy statements, cumulative impacts, and detailed phasing of construction. Respondent ID No. Our response such as provisions in our DCO that would relate to TfL. Our DCO is likely to include a number of other, non-planning, consents and an explanatory memorandum as required in line with the 2008 Act.
3.9.27
(LR)LBLew
We can confirm that we are undertaking an equalities impact assessment, the output of which will be submitted with our DCO application.
3.9.28
WCC
We are undertaking our consultation exercise in accordance with relevant statutory requirements and having regard to government guidance and policy. We carefully considered the information we made available at our phase two consultation to ensure that consultees had sufficient information to respond to the consultation. The level of information to be made available at phase two consultation was also agreed with potentially directly affected local authorities prior to consultation commencing. Our assessment methodology is in line with the Infrastructure Planning (Environmental Impact Assessment) Regulations 2008, which requires assessment 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 the GLA, consistent with Planning Inspectorate Advice note nine. Section 2 of the site volumes of our PEIR set out the details of any relevant developments that will be taken into consideration. We will continue to monitor proposed development in the local area and any relative cumulative effects would be reported in our Environmental statement that will be submitted as part of our DCO application. An Energy statement and Sustainability appraisal will be submitted as part of our DCO application. There is no requirement under the 2008 Act for consultation to be undertaken on drafts of these documents. Information on construction phasing was also contained in the site information papers and site volumes of the PEIR. Further details will be available as part of our DCO application. It is our intention, in line with relevant guidance on land acquisition, to negotiate with the relevant land owners, and we will therefore continue our discussions on these matters with the GLA/TfL.
3.9.29
The Greater London Authority/Transport for London will expect any occupation of its property by Thames Water to be on the basis of agreement as opposed to by exercise of powers. In relation to licences required under Part 4 of the Marine and Coastal Access Act 2009, the following is advised: the construction of the whole of the main tunnel is a licensable activity. It may be more appropriate to include tunnelling
GLA
3.9.30
(LR)MMO
Noted, we are continuing our discussions on these matters with the MMO.
3-23
3 Other Comments Ref Objections, issues and concerns Respondent ID works at sites associated with the construction of the tunnel in the marine licence for main tunnel there are no marine licensable activities and therefore no marine license is required at Acton Storm Tanks or Falconbrook Pumping Station the following sites should be considered as part of main tunnel license but do not require separate site marine licenses: Hammersmith Pumping Station and Barn Elms for the short connection tunnel licensable activities are being undertaken at: Putney Bridge Foreshore, Dormay Street, Carnwath Road Riverside, Cremorne Wharf Deport, Chelsea Embankment Foreshore, Kirtling Street, Heathwall Pumping Station, Albert Embankment Foreshore, Victoria Embankment Foreshore, Blackfriars Bridge Foreshore, Chambers Wharf, King Edward Memorial Park Foreshore and Greenwich Pumping Station no licensable activities at King Georges Park, Earl Pumping Station, Deptford Church Street, Abbey Mills Pumping Station and Beckton Sewage Treatment Works site assessment figures show that in most of the sites the draft limit of land to be acquired includes an extra area of foreshore and river adjacent to the proposed works. If any further works are to go ahead within this area in the future, a marine licence may be required. possible dredging has been mentioned at a number of sites. Should the dredged material be disposed of at sea this will also require a marine licence and the sediment would need to be sampled and analysed in line with Convention for the Protection of the Marine Environment (Ospar) guidelines to ensure compliance with Ospar. in relation to marine historic environment, any site investigation works, such as grab samples or borehole surveys, required No. Our response
3-24
3 Other Comments Ref Objections, issues and concerns below mean high water springs, would require a marine licence. Where necessary, suitable notices to mariners will also need to be issued. This requirement would need to be captured on the relevant marine licences for monitoring and enforcement purposes. The impact of the project on transport assets has not yet been fully assessed. Query to what degree the requirement for secondary lining has been included in traffic modelling figures and for each sites duration programme and other additional impacts. Respondent ID No. Our response
3.9.31
(LR)MMO
Approach to transport assessment 3.9.32 GLA 1 As part of our PEIR we have assessed the construction transport effects of the proposed development on pedestrian and cycle routes and highway layout, operation and capacity. As part of the assessment we have considered the effects of lorry and (where applicable) barge transport, based on a methodology that has been discussed and agreed with the local authority and TfL. The PEIR was available as part of our phase two consultation. We acknowledge that this is a preliminary assessment; we are preparing a full Transport assessment for submission within the Environmental statement as part of our DCO application. For the purposes of all these assessments we have assumed there will be secondary lining required for the tunnel and main connection tunnels and all drop shafts so all the data used includes the relevant traffic movements etc associated with these activities. We are examining options for increasing the use of the river for the transport 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 information in our DCO application materials.
3.9.33
Greater use can and should be made of the river, and possibly rail. Cost-saving opportunities can be realised as well as the general reduction in impacts, noise, safety risks and emissions. A nominal figure of a 70m increase in project costs has been identified to account for the use of barges. Transport for London has not seen the evidence or breakdown of this cost and therefore cannot comment on whether it is a reasonable estimate or to what extent other impact costs (such as air quality, congestion and safety) can be averted. The installation of permanent facilities such as transhipment points and new rail heads may have a value for other uses after completion of the tunnel. The identification and appraisal of these facilities should be explicitly considered and opportunities for use explored and identified within expected social cost benefit analyses. The use of rail opportunities also needs to be further explored. Full use should be made of the river for the
GLA
3.9.34
LR9154
It is our intention to use the river to transport 90 per cent of excavated
3-25
3 Other Comments Ref Objections, issues and concerns movement of excavated material and delivery of materials to minimise the wider environmental impact of the Thames Tunnel project. River transport should be maximised for delivery and removal of excavated materials from worksites. The consultation material leaves too much flexibility over transport management. Confirmation requested that: all excavated material from the main tunnel and where possible from the CSO connection tunnels will be transported by barge it will be a requirement for the contracts that the tunnel segments and materials for the lining arrive by water the cost of the disruption that would be caused by bringing materials by road does not appear to have been considered, as it should have been, against the possible saving to Thames Waters own contracts by doing so. Respondent ID No. Our response material from main tunnel drive sites. However, it is not generally practical and cost-effective to transport all materials by barge so we would still need to transport some materials by road.
3.9.35
9155
We are examining options for increasing the use of the river for the transport 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 information in our DCO application materials.
3.9.36
Thames Water should promote a logistics GLA plan that: maximises the use of river and rail transportation minimises the impact on the strategic and local highway network minimises overall and local environmental impacts is cost-effective considering all direct and indirect costs and benefits consistent with established government guidance on transport investment. The cost of any identified mitigation measures to Transport for Londons highway network, assets or services would need to be met by the project promoter. There is a need to address the access to construction sites, the impact on local roads arising from movement of excavated material, residential car parking and local business continuity. GLA
3.9.37
We have not commenced negotiations on planning requirements or obligations since our design is not yet fixed. We will enter into these discussions shortly and will ensure that our proposed requirements and any obligations, where relevant, comply with the legal requirements and relevant guidance We are reviewing the proposed routes that construction traffic would use as part of our Transport assessment. If the Transport assessment identifies any likely significant effects arising from congestion we will develop mitigation measures to minimise the effects of any disruption. We are also developing a CoCP (a draft was provided as part of our phase two consultation), which will include requirements for a Traffic
3.9.38
LR9154
3-26
3 Other Comments Ref Objections, issues and concerns Respondent ID No. Our response management plan to ensure that construction traffic is carefully controlled to minimise any potential effects on the road network including access to the local area, setting out construction traffic routes, site access/egress points, signage and monitoring procedures. We have discussed the use of the river for transporting materials with the PLA, the body which is responsible for regulating the use of the River Thames. We are preparing a Navigational risk assessment for submission as part of our DCO application, the approach to which is being discussed with the PLA. We are will continue to discuss our proposals to minimise risk to river navigation by commercial or leisure river users. We will also complete a survey of river usage, the findings of which will be reported in our DCO application and will inform further discussions with the PLA.
3.9.39
During the construction phase there will be a LR13477 considerable increase in the volume of river traffic. While projected barge movements associated with each individual construction site have been provided, a full assessment of the in-combination impact of these barge movements cannot be made until a holistic navigational risk assessment has been conducted for the project in its entirety. Objection to the size and number of proposed barge movements on the River Thames. Without any detail available on scheduling, this could lead to bottlenecks occurring, particularly at river bridges and at key tide times. Where lorries are absolutely necessary they should be retrofitted with technology that reduces their carbon emissions. WRWA
3.9.40
Construction of the project 3.9.41 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 the opportunities to utilise environmentally friendly vehicles during construction. The transport and environmental assessments are considering the combined effects of construction activities at the various sites. Throughout the design process we have sought to minimise the effects of the project. Noted. We have not yet developed our proposals to manage construction logistic activities but are aware that other major construction projects including Crossrail have followed this approach.
3.9.42
Thames Water should look carefully at the LC, 9131LO phasing of the sites throughout London. This should also be shared with boroughs to try to minimise the projects impacts. Thames Water will need to establish a resource or team to centrally coordinate and manage all construction logistics activity across the project. One of its remits will be the need to provide the adequate enforcement of agreed routes by any construction traffic to the satisfaction of Transport for London. Due to the increased heavy goods vehicle movements that will result from project, confirmation should be provided that all contractors will be mandated to fit their vehicles with specialist sensors and mirrors to protect vulnerable road users such as cyclists. GLA
3.9.43
3.9.44
9429
Our contractors will be required to meet industry best practice in relation to measures to protect vulnerable road users. These will be set out in our CoCP.
3-27
3 Other Comments Ref 3.9.45 Objections, issues and concerns Thames Water should put in place a programme to train and employ Londoners, especially those seeking work, to undertake as many of these jobs as possible. No discussion on the opportunities for local people to become engaged with the project in a positive way and potential employment opportunities. London boroughs will be looking for a clear strategy for maximising the employment of Londoners in the construction of the Thames Tunnel project. Ambitious targets should be set. Invites Thames Water to work with the Port of London Authority (PLA), the operators and others to secure a lasting legacy for the River Thames through the development and training of the skilled marine workforce required to deliver this project. Construction operations for the Thames Tunnel project could potentially impact on navigation on the River Thames and may require marking by aids to navigation. Consultation will be required with the PLA in the first instance as the responsible authority for the River Thames. Trinity House will also be able to advise the PLA or the developer on aids to navigation matters as required in due course. Thames Water should establish a clear structure/mechanism for community feedback during construction periods to enable local issues to be discussed and resolved. Respondent ID GLA No. 1 Our response We estimate that the tunnel would directly employ about 4,250 people in construction and related sectors, as well as providing further secondary employment. We actively support the Crossrail Tunnelling and Underground Construction Academy, which is currently training and gaining employment for 70 apprentices a year. As set out in our publication Why Does Londons Economy Need the Thames Tunnel, the Thames Tunnel procurement process will aim to deliver business opportunities for small and medium sized enterprises as well as utilising local products, services and labour through the supply chain where possible. Any such targets will be subject to market sounding to ensure their commercial viability and compliance with EU regulations. We aim to meet a target on employing in excess of 20 per cent local labour.
3.9.46
LR13381
3.9.47
LC
3.9.48
PLA
3.9.49
TH
We are already working closely with the PLA and others to examine the feasibility of increasing the use of the river for the transport of materials, subject to cost, environmental and other constraints. We are aware that increased use of the river would require the development and training of the marine workforce, and this is one of the constraints which we are examining. We have discussed the use of the river for transporting materials with the PLA, the body which is responsible for regulating the use of the River Thames. We are preparing a Navigational risk assessment for submission as part of our DCO application, the approach to which is being discussed with the PLA. We are will continue to discuss our proposals to minimise risk to river navigation by commercial or leisure river users. We will also complete a survey of river usage, the findings of which will be reported in our DCO application and will inform further discussions with the PLA. Chapter 8 of our Community consultation strategy sets out our initial proposals in relation to communication with consultees once construction commences. As we draw closer to the start of construction work, we will be providing more detail on our communication proposals and will take into account the suggestions received. Further details may also be contained within part B of CoCP and our Consultation report which will be submitted with our DCO application. This comment does not relate to the DCO, but is noted. It is our intention that the CoCP will be part of tender documents as has been discussed at our recent meetings with local authorities.
3.9.50
GLA
3.9.51 3.9.52
Thames Water should make river transport a requirement of their tender process. Tender documents should stipulate the requirements of the CoCP so that each bidder is evaluated against the same criteria. Tender documents should contain specifications with specific requirements to
LBW LBW
1 1
3.9.53
LR13477,
Noted and agreed.
3-28
3 Other Comments Ref Objections, issues and concerns ensure that each company bids on the same basis. Thames Water has promised to pay for independent experts hired by the foreshore group at Putney Bridge Foreshore; not clear whether any experts have been engaged yet. Technical experts should provide advice on the specifications to allow informed decisions on the viability. With regards to vessels associated with the project passing through the district, the Kent and Essex Inshore Fisheries and Conservation Authority would wish to see Notice to Mariners issued in a timely fashion through appropriate channels and would expect vessels to display lights and shapes in accordance with Rule 27 of the International Regulations for Preventing Collisions at Sea, where appropriate. There should be a principle of using native species, including rich native grass mixes, during reinstatement works as this will contribute to the overall enhancement of biodiversity outside of ecological management plans. In relation to Thames Waters compensation scheme: no details have been provided on compensation measures for hardship or temporary disruption respondents cannot imagine anyone meeting the criteria for compensation scheme. The scheme only applies to loss or damage over and above that normally to be expected from a major construction site. This is a very high test which will be hard for residents to meet. It is also not clear what needs to be submitted to provide Thames Water with acceptable proof and evidence of the harm suffered from the construction works. Request for information on the level of financial compensation Thames Water will be bound to pay in the event of wastewater Respondent ID No. Our response
3.9.54
LR13383, 8944
Your feedback comment is noted.
3.9.55
9030
Noted. We will comply with all relevant laws and regulations.
Other comments 3.9.56 EA 1 We have not fully worked up our landscape proposals as the site layouts and locations are still being finalised. We will discuss the details of planting with our stakeholders when we are much closer to project implementation and fully expect to use native species wherever this is considered appropriate. Landowners may have a statutory entitlement to claim compensation for the diminution on 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 will 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 the currently published Thames Tunnel project 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 arising from damage or loss, for required protection measures, and for compulsory purchase.
3.9.57
8751, LR13381
3.9.58
9409
3-29
3 Other Comments Ref Objections, issues and concerns flooding to the owners of affected buildings which lie in (or close to) the alignment of the Thames Tunnel. Regarding exceptional circumstances, the statement that Our guarantees do not apply when events beyond our control prevent us from meeting our specified standards appears to give Thames Water immense wiggle-room for contesting virtually any claim. A full business process management evaluation based on the function of the tunnel and its impact on society and the environment should be undertaken. Respondent ID No. Our response
3.9.59
LR9398
The methodology for our Environmental statement was consulted on with stakeholders prior to our phase two consultation and has been undertaken in accordance with the EIA regulations and other relevant legislation. The Environmental statement includes a full assessment of all significant social, economic and environmental effects. A public inquiry will not be held for the Thames Tunnel project. It is anticipated that the project will be designated as a nationally significant infrastructure project. This means that the application for development consent will be submitted to Planning Inspectorate, which will examine the application before making a recommendation to the Secretary of State. As part of this process the effect on residents will be considered. Once the DCO application has been submitted, there are opportunities for those with an interest in the project to make representations; this may include oral hearings. For further details of the process once the DCO application has been submitted, refer to the Planning Inspectorate's website: http://infrastructure.planningportal.gov.uk/ Noted. Detailed comments on design and environment will be reviewed and taken into account. If other sites are required outside of the DCO application process these will need to be the subject of separate planning applications, which would need to include appropriate assessment of any environmental effects.
3.9.60
Query when a public inquiry will take place 9399, 7780 and in what form. Also consider that an independent inquiry should be undertaken to ensure effect on residents is assessed.
3.9.61
English Heritage also provided detailed comments on: the Design and Environment project information papers that it recognises that the potential transfer station in the eastern reaches of the River Thames will need its own planning application. English Heritage advises that this is likely to have implications for the historic environment, particularly the archaeology of the River Thames the reporting of the response in the Report on phase one consultation. In the past, the Emlyn Gardens allotments have been flooded by sewage. Measures must be taken to ensure that the manhole cover in those allotments will not be forced off in future.
EH
3.9.62
9197
Noted.
3-30
3 Other Comments Ref 3.9.63 Objections, issues and concerns Thames Water has indicated that design work on permanent structures has not yet taken place and that the visualisations shown in the consultation leaflets do not represent the final designs. Thames Water should ensure that the designers consult with the Sailing Clubs on the design and location of all structures, plant, excavated material heaps etc, because of the effect on the wind as well as the more obvious visual aspects. Every opportunity should be taken to improve river access and to provide short term moorings or slipways with adjacent parking wherever possible. The Royal Yachting Association Thames Valley & London Region wishes to be consulted on the detailed design of all legacy structures constructed on the foreshore or adjacent to the river bank. Respondent ID 9042 No. 1 Our response In our phase two consultation material we included our proposed designs for the permanent foreshore structures and these are being developed further taking into account the more detailed assessments currently being undertaken for our ES and consideration of comments received from our consultation to date. We intend to publicise our proposed application in the summer and it is intended that this will include plans showing our developed design. There will be a further opportunity for comments to be made at that stage.
3.10
3.10.1 3.10.2
Our view of the way forward

We will take into account the detailed comments that have been received as the project develops. We will review the comments received on the PEIR and related documents as part of the environmental impact assessment process to ensure that, where appropriate, they are taken fully into account in the preparation of the Environmental statement. We will continue to work with our stakeholders in relation to the permanent design and appearance of our sites as part of our design development. The ideas, views and information received during our phase two consultation will help to ensure the final design is the optimum solution for each of our sites and best meets the needs of our local communities
3-31

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Supplementary report on phase two consultation

Thames Tunnel Supplementary report on phase two consultation

3.1.2 3.1.3 3.1.4

Other supportive and neutral feedback comments

Supplementary report on phase two consultation

Preliminary environmental information report

Supplementary report on phase two consultation

Objections, issues and concerns

Supplementary report on phase two consultation

Supplementary report on phase two consultation

Supplementary report on phase two consultation

EH, GLA, 9461

EH, GLA, (LR)RBKC

EH, GLA, (LR)RBKC

EH, GLA EH, GLA

EH, GLA, WCC

Supplementary report on phase two consultation

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

EH, GLA, 9066

Site selection methodology paper

Supplementary report on phase two consultation

Objections, issues and concerns

Supplementary report on phase two consultation

Phase two scheme development report

Objections, issues and concerns

Code of construction practice Part A: General requirements

Supplementary report on phase two consultation

Objections, issues and concerns

(LR)LBS, (LR)LBTH PLA

Supplementary report on phase two consultation

Draft waste strategy

The shortlisted sites can be made available for review.

Supplementary report on phase two consultation

Objections, issues and concerns

Supplementary report on phase two consultation

This will be included in the Waste strategy.

Design development report

Supplementary report on phase two consultation

Supplementary report on phase two consultation

Objections, issues and concerns

Supplementary report on phase two consultation

Other objections, issues and concerns

Supplementary report on phase two consultation

Supplementary report on phase two consultation

Supplementary report on phase two consultation

9069, 9068, LR13477

Supplementary report on phase two consultation

Supplementary report on phase two consultation

Supplementary report on phase two consultation

(LR)LBS, (LR)LBTH, (LR)LBE

Supplementary report on phase two consultation

Supplementary report on phase two consultation

Supplementary report on phase two consultation

It is our intention to use the river to transport 90 per cent of excavated

Supplementary report on phase two consultation

Supplementary report on phase two consultation

Supplementary report on phase two consultation

Noted and agreed.

Supplementary report on phase two consultation

Your feedback comment is noted.

Noted. We will comply with all relevant laws and regulations.

Supplementary report on phase two consultation