application reference number: wwo10001 response to the ...... · response to the examining...

Response to the Examining Authority’s request for informationQuestion 58 - Other Matters

Doc Ref: APP168

Folder 208 3 March 2014DCO-DT-APP-ZZ100-680000

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Thames Tideway Tunnel Thames Water Utilities Limited

Application for Development ConsentApplication Reference Number: WWO10001

Responses to request for information Q58: Other Matters

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Responses to request for information Q58 Other Matters

List of contents

Page no.

1 Question: 58.1 ................................................................................................. 1

1.1 Introduction .............................................................................................. 1

1.2 Thames Water response to Assael Architecture ...................................... 1

1.3 Thames Water response to Environment Agency ................................... 5

1.4 Thames Water response to Free Trade Wharf Management Company Ltd ......................................................................................................... 19

1.5 Thames Water response to Glendola Leisure Ltd ................................. 28

1.6 Thames Water response to London Borough of Hammersmith and Fulham................................................................................................... 31

1.7 Thames Water response to London Borough of Lewisham ................... 50

1.8 Thames Water response to written submission from the London Borough of Southwark .......................................................................................... 53

1.9 Thames Water response to London Borough of Tower Hamlets ........... 61

1.10 Thames Water response to MMO .......................................................... 64

1.11 Thames Water response to Minerva (Wandsworth) Limited .................. 65

1.12 Thames Water response to National Grid.............................................. 68

1.13 Thames Water response to St James Group Ltd ................................... 69

1.14 Thames Water response to Save Your Riverside .................................. 75

1.15 Thames Water response to Thamesbank .............................................. 81

1.16 Thames Water response to Western Riverside Waste Authority ........... 85

1.17 Thames Water response to Wrayburn Residents Together ................... 90

2 Question: 58.2 ............................................................................................... 93

2.1 Our response ......................................................................................... 93

3 Question: 58.3 ............................................................................................. 105

Appendix A : Review of proposed acoustic wall .............................................. 107

Appendix B : Technical Advice Note – Hydraulic Assessment of CDM Smith 'Alternative A' drive strategy ....................................................................... 109

Appendix C : Dr New note on Separation Distances ........................................ 111

Appendix D : Waterslade letter 19 February 2014 ............................................ 113

Appendix E : Updated Figure 8.1 Chambers Wharf acoustic site accommodation diagram ............................................................................. 115


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Appendix F : Previous Thames Water representations to the ExA relating to Minerva (Wandsworth) ................................................................................. 117

Appendix G : Statement of Common Ground between Minerva (Wandsworth) Limited and Thames Water Utilities Limited .............................................. 119

Appendix H : Thames Water correspondence to Larry Broomhead of Wrayburn Residents Together, 26 February 2014 ...................................................... 121

List of tables

Page no.

Table 1.1 Core Strategy Policy H1 SFR Housing Delivery Targets .......................... 32

Table 1.2 London Plan 2011: Housing targets for LBHF ......................................... 33 Table 1.3 Draft further alterations to the London Plan (2014): Housing targets for LBHF ........................................................................................................................ 33 Table 1.4 SFR additional housing delivery up to 2022 (source SHLAA) ................... 33

Table 1.5 SFR Housing Delivery: 2022 – 2032 (source SHLAA) ............................. 34 Table 1.6 Efficiency comparison .............................................................................. 55 Table 1.7 HGV numbers at different tunnelling rates ............................................... 56 Table 1.8 LB Southwark comments regarding noise and vibration and our response ................................................................................................................................. 58 Table 1.9 LB Southwark comments regarding health and in-combination and our response ................................................................................................................... 60

List of figures

Page no.

Figure 1.1 Option 3A Whiffin Wharf Feasibility Study ............................................... 40

Figure 1.2 Whiffin Wharf Policy Design Brief ............................................................ 41


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Abbreviations

CEMP construction environment management plan

CSO combined sewer overflow

DCO development consent order

EA Environment Agency

ExA Examining Authority

HoTs Heads of Terms

LLAU limits of land to be acquired or used

NEWT not environmentally worse than

SoCG statement of common ground

SuDS sustainable urban drainage system

TAP trigger action plan

TBM tunnel boring machine

TW Thames Water


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Question: 58.1


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1 Question: 58.1

In the submissions made for the 12 February 2014 deadline a number of statutory bodies, local authorities, action groups and other Interested Parties highlight their outstanding concerns. The ExA requests that the Applicant provide a full response to these submissions with their submissions due on or before 3 March 2014.

1.1 Introduction

1.1.1 The Thames Water (TW) responses to submissions made to the Examining Authority (the „ExA‟) on 12 February 2014 are provided below.

1.2 Thames Water response to Assael Architecture

Introduction

1.2.1 Responses are given below to points raised regarding noise and vibration raised by Layton Solicitors on behalf of Assael Architecture Ltd, 50 Carnwath Road London SW6 3EG, submitted to PINS on 12 February 2014.

1. Methodology

Point 1: PINS questions 29.1 and 29.2 responses – BS 5228 methods 1 and 2

1.2.2 TW has described the methodology used for the assessment of significant noise effects and supplemented this with further explanation in response to first written question 11.1 (see Doc ref: APP11.01.01).

1.2.3 TW has set out why the BS5228 method 1, as applied in the Environmental Statement, is more appropriate than method 2 and is consistent with the NPS (Noise and Disturbance, Question 29.2, Supplementary Information, Doc ref: APP97 and Written summaries of the cases put orally at the hearings held on 20 February 2014, Doc ref: APP157).

2. Non-residential premises

Point 2: 50 Carnwath Road has not been assessed in accordance with BS5228

1.2.4 As set out in oral evidence (Doc ref: APP157), all receptors have been assessed in accordance with BS5228-1.

Point 3: Cumulative noise from on-site/road traffic/river traffic

1.2.5 The cumulative noise from the site, road traffic and river traffic has been considered cumulatively and reported in our response to second written question 29.1 (Doc ref: APP56). Adding the worst-case daytime construction noise level (74dB(A)), and the river traffic level (for the closest receptor is 60dB(A)) and road traffic level (allowing for the increase in

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Question: 58.1


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noise due to the Thames Tideway Tunnel project (the „project‟), less than 1dB), there would be no increase in the worst-case noise level at this receptor.

Point 4: Baseline is not representative as the site is being used as a lorry store

1.2.6 The application site was not being used as a lorry store at the time of the baseline noise measurements. Therefore, we consider the baseline to be robust for this location.

3. Riverside traffic noise

Point 5: River-based construction traffic effects on 50 Carnwath Road

1.2.7 This is dealt with in Point 3 (para. 1.2.5 above).

4. Cumulative impacts

Point 6: Inclusion of all construction related impacts including lorries and barges

1.2.8 This is dealt with in Point 3 (para. 1.2.5) above.

Point 7: Consideration of traffic noise only where traffic noise increases of greater than 1dB are predicted

1.2.9 Changes in traffic noise are considered negligible if less than 1dB (Table 3.1, DMRB1). Estimated increases of less than this would not contribute a perceptible change to noise level when combined with construction noise, even assuming the traffic noise increase were to occur during the same period as a potentially significant construction noise effect. The rationale for the consideration of combined direct and indirect effects is set out in the response to second written question 29.1, submitted on 13 January 2014 (Doc ref: APP 56).

5. Vibration

Point 8: PPV should be used instead of VDV for human response based upon BS5228 Part 2

1.2.10 VDV is the correct methodology for considering human response to vibration. This is clear from the relevant British Standard2.

Point 9: Concerns regarding assumptions used for vibration prediction – in particular for piling

1.2.11 The Environmental Statement, Vol 10 (Doc ref: 6.2.10), presents predicted vibration levels and associated assessment for each receptor location

1 The Highways Agency, Transport Scotland, Welsh Assembly, DRD (2011), Design Manual for Roads and

Bridges Volume 11, Section 3, Part 7,HD 213/11 – Revision 1, TSO 2 British Standards Institution (2008), BS 6472-1 Guide to evaluation of human exposure to vibration in buildings

Part 1: Vibration sources other than blasting, British Standards Institution

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Question: 58.1


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around the site, including 50 Carnwath Road. Vibration is quantitatively assessed for human disturbance, and then separately for effects on buildings. The assessment is carried out according to established methodologies using the relevant British Standards.

1.2.12 The information as to the types of construction plant that would potentially give rise to vibration are taken from the detailed schedules of construction for the works and the worst-case locations for the relevant plant (para. 9.5.76 Environmental Statement, Vol 10 (Doc ref: 6.2.10), and para, 9.5.14 of Methodology, Vol 2 to the Environmental Statement (Doc ref: 6.2.02).

5. Impact of noise combined with vibration

Point 10: Concerns regarding potential for combined noise and vibration effects

1.2.13 Vibration has been assessed as not significant as forecast levels are below the thresholds identified for offices defined in the relevant British Standards (BS6472-1). It should be noted also that, in the case of offices, the threshold of 'low probability of adverse comment' should be increased by a factor of two (from BS 6472 as referred to in Table 9.5.2 of Methodology, Vol 2 to the Environmental Statement, Doc ref: 6.2.02). Therefore, the vibration exposure would be well below this threshold for offices. Combined with the worst-case noise levels occurring for one month, this is not assessed as being a combined noise and vibration significant effect.

1.2.14 If the solution for river transport is to provide a campshed, hence requiring a cofferdam, then push piling would be employed, as set out in response to second written question 29.16, submitted to the ExA on 13 January 2014 (Doc. ref: APP 56). Alternatively, if a jetty is to be used, guide piles would be required and these would be vibro-driven; however, the assessment shows that there would be no significant vibration effect at 50 Carnwath Road.

6. Lack of assessment of intermittent noise/maximum noise levels

Point 11: Effect of maximum noise levels during construction works

1.2.15 The established prediction assessment methodologies (BS 5228) take account of the nature of variable construction noise and the potential for disturbance from longer term and short-term noise events (causing maximum noise levels). The variable character of construction noise and its effects are implicit in these well-tried assessment methods. Under BS5228-1, maximum noise levels are only considered for specific activities, such as percussive piling, and percussive piling is not required at Carnwath Road Riverside. These matters were the subject of examination at the issue specific hearing in relation to noise and vibration on 4 and 5 February 2014, and TW‟s responses are summarised in the document, Written summaries of the cases put orally at the hearings held on 4 and 5 February 2014 (Doc ref: APP115.01), submitted to the ExA on 12 February 2014.

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Question: 58.1


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Point 12: The applicant’s response to ExA questions 29.8 and 29.9

1.2.16 These matters were the subject of examination at the issue specific hearing in relation to noise and vibration on 4 and 5 February 2014, and TW's responses are summarised in the document, Written summaries of the cases put orally at the hearings held on 4 and 5 February 2014, submitted to the ExA on 12 February 2014.

7. Noise contour plans

Point 13: The applicant has not complied with the request for noise contour plans, they have provided just one month out of six years and then only taking into consideration the most frequently occurring noise, which is not the worst-case scenario at all. There is no assessment therefore of how noise levels change during the construction process at the different sites as requested.

1.2.17 TW does not believe that noise contour maps are the best way to provide information for the basis of assessment for construction noise. This is for a number of reasons, as set out in the letter provided on 28 August 2013 to the ExA (ref: 100-CO-PNC-PINSP-000006), and reiterated in the Noise Contours and Assessment Summary Plans Explanatory Note (Doc ref: 9.11.01).

1.2.18 The assessment of noise contained within the Environmental Statement as submitted considers the following:

a. the predicted noise over the lifetime of the project

b. the range and duration of noise effects

c. the variation of noise at each identified receptor, at the most affected façade.

1.2.19 The noise contour plans, produced at the request of ExA, were not intended to provide a thorough assessment of the noise levels as is provided in the Environmental Statement. However, the intention was to provide information which was helpful and informative, given the request for further information. For further information on the predicted noise level at 50 Carnwath Road over the lifetime of the project, this can be found in the Environmental Statement, Vol 10, Appendix G, Plate G.8 (Doc ref: 6.2.10).

8. Conclusion

1.2.20 TW considers that the impacts at 50 Carnwath Road have been fully and properly assessed, and that the assessment methodology criteria set out in para. 9.5.52 of the Environmental Statement methodology has been duly applied.

1.2.21 There is sufficient information to assess the cumulative impacts on 50 Carnwath Road, in accordance with the guidance within the NPS, as set out above.

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Question: 58.1


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1.3 Thames Water response to Environment Agency

Introduction

1.3.1 The following is our response to the Environment Agency (EA) submission on 12 February 2014.

Response to EA18 – comments on application documents

Development consent order

1.3.2 In its submission EA18, the EA notes that it has previously requested that the following Requirements are defined as major detailed Requirements: PW6, PW14, ACTST10, HAMPS2, HAMPS7, BAREL9, PUTEF18, CARRR12, CARRR16, DRMST6, DRMST10, KNGGP11, CREW13, CHEEF2, CHEEF17, KRTST22, HEAPS13, ALBEF18, VCTEF21, BLABF3, BLABF23, EARPS9, DEPCS10, GREPS12, KEMPF15, ABMPS83.

1.3.3 The EA notes that this had not been reflected in the 3 February 2014 revised Draft DCO (Doc ref: APP105.02). The EA has requested that these Requirements are determined within an eight-week period (proposed timescales for major Requirements) as opposed to the five-week determination period for minor Requirements.

1.3.4 TW has updated the Draft DCO to remove the distinction between major and minor Requirements so that the eight-week determination period now applies to all Requirements (see 3 March 2014 Draft DCO, Doc ref: APP177.02).

Code of Construction Practice, Part A

1.3.5 TW is pleased to note that, in its submission EA18, the EA confirms that it has reviewed the 3 February 2014 version of the CoCP Part A (Doc ref: APP104.02) and is pleased to see considerable progress being made on this matter and that, in particular, Section 4.7, River Works, now gives a more balanced representation of the licensing and permitting regimes of the EA, the Port of London Authority (PLA) and the Marine Management Organisation (MMO).

1.3.6 The EA notes that details of the particular areas of work within the river regime have been removed from Section 4.7 of the CoCP Part A, and suggests that it may be more helpful for the contractor if some of the detail is retained in the document.

1.3.7 TW notes that a subsection has been included within Section 4.7 of the CoCP Part A (Doc ref: APP178.01) which provides further detail and guidance with regards to removal of in-river piles. TW believes that Section 4.7 of the CoCP Part A provides adequate general guidance in relation to all river works and notes that further detail, including specific deliverables and timescales for approval of consents, is contained within

3 It should be noted that, in some cases, the numbering of Schedule 3 Requirements may have changed since the

12 February 2014 submission – see DCO tracker appended to the DCO drafting notes (Doc ref: APP177.01).

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Question: 58.1


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the Deemed Marine Licence and the EA and PLA protective provisions (see schedules 15 and 16 of the Draft DCO).

1.3.8 The EA also raises concerns regarding the approval process for the Construction Environment Management Plan (CEMP) and its ability to review and approve plans and method statements. However, the EA also notes that recent discussions and negotiations have led to a compromise, whereby the EA protective provisions (Schedule 16, Part 3 of the Draft DCO) would include the approval of relevant sections of the management plans forming part of the CEMP within the EA‟s remit, namely: Pollution Incident Response Plan, Emergency Preparedness Response Plan, Water Management Plans, and Ecology and Landscape Management Plan.

1.3.9 TW is pleased to confirm that the revised EA protective provisions now include provisions to address the EA‟s concerns in relation to the CEMP, and also that the EA notes that it is now satisfied that this matter is adequately secured.

Design Principles

1.3.10 In its submission EA18 of 12 February 2014, the EA confirms that it would be pleased to be named as a consultee on Requirements for „detailed design approval of river wall and foreshore structures‟, and that it looks forward to seeing this addition in the next iteration of the Draft DCO. TW confirms that the EA has been added as a consultee on these Requirements. TW also notes that the EA is satisfied that all matters within the design principles that are within its remit (with the exception of those noted below) are adequately secured, either through the Requirements or the EA protective provisions.

1.3.11 The EA has outstanding concerns regarding the site drainage principles and how these are being applied at certain sites. According to the EA, para. 3.6.1 of the Design Principles (Doc ref: APP179.01) implies that TW will not consider drainage for the whole of its sites, potentially leading to an increase in flood risk. The EA has concerns regarding this and the lack of clarity given to whether the detailed design of drainage will consider and demonstrate the increase in run-off rates and volumes, including the increased allowance for climate change, for the whole of the area within the limits of land to be acquired or used (LLAU). It is the EA‟s view that introduction of the additional site-specific design principles that relate to surface water drainage further complicate the obligations for the contractor when looking at detailed design. The EA believes there would be more clarity if para. 3.6.1 of the Design Principles was removed.

1.3.12 TW notes that the design principles would only apply to the permanent operational phase of the project, as stated in para. 1.1.1 of the Design Principles. Para. 3.6.1 of the Design Principles provides further clarification by identifying those areas within the Site works parameter plans where drainage design principles would apply. TW notes that surface water drainage for those areas within the LLAU not covered by the Design Principles (ie, areas to be used only during construction) would be managed in accordance with the CoCP Part A.

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Question: 58.1


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1.3.13 In addition, the EA remains concerned over the reference to National Standards for Sustainable Drainage Systems. While the EA accepts that these are likely to come into force prior to construction of the project, the EA believes clarity is needed as to which standards are to be followed should the National Standards be less stringent than the London Plan or not be in effect when the designs are agreed.

1.3.14 TW notes that Design Principle SDRN.01 has been amended to include reference to the London Plan as well as the National Standards. As currently drafted, Design Principle SDRN.01 states:

“Site drainage shall comply with the National Standards for Sustainable Drainage Systems under the Floods and Water Management Act 2010 and London Plan drainage policies.*

* It should be noted that the National Standards is currently a draft document that was issued for consultation by Defra in December 2011. It is anticipated that the remaining provisions of the Flood and Water Management Act, including those relating to the requirements for Sustainable Drainage Systems, provided for in Schedule 3, would be implemented by December 2014. If this is not the case, the site drainage shall comply with design principles SDRN.02, SDRN.03 or SDRNR.04 as relevant. Once the National Standards come into force, the site drainage shall comply with these as well as with the design principles SDRN.02, SDRN.03 or SDRN.04 as relevant”.

1.3.15 As indicated by the wording of SDRN.01, the contractor would have to follow both standards. TW believes both documents are likely to complement each other and that the proposed wording is consistent with the approach set out in the National Policy Statement for Waste Water, para. 4.4.10 (ie, “the decision maker should be satisfied that, where relevant:...the proposal is in line with any relevant national and local flood risk management strategy”).

1.3.16 In addition, TW believes that the footnote to SDRN.01 as currently drafted covers any eventuality (eg, National Standards not being in place by the time drainage design is approved) and should not lead to confusion as to which standards apply to either the contractor or the body approving the drainage design.

1.3.17 In its submission, the EA also raised its concern with regards to Design Principle CHAWF.07, as shown in the 3 February 2014 Design Principles (Doc ref: APP106.01). In the EA‟s view, this design principle does not allow for an interim drainage solution should the proposed residential development not follow immediately after construction of the project is completed. As it is not possible to guarantee that the residential development will definitely be built, nor that drainage is installed immediately upon acquiring the site, the EA believes an interim drainage solution is essential and should be developed by the contractor.

1.3.18 TW notes that, in addition to the rewording of Design Principle CHAWF.07 (ie, current wording of CHAWF.07 states: “If Thames Water instructs the contractor that commencement of the approved residential development for the site will proceed immediately after construction of the operational

https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/69505/pb13709-waste-water-nps.pdf

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Question: 58.1


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structures, surface water drainage shall comply with the drainage design for the approved residential scheme”), Table 4.31 of the Design Principles has also been amended so that if the approved residential development is delayed, the relevant generic drainage principles would apply to this site.

1.3.19 Also, a new surface water drainage Requirement CHAWF.12 has been included within Schedule 3 of the Draft DCO, as follows:

“(1) Construction of the permanent above-ground structures shall not commence until details of the surface water drainage system for this site (including means of pollution control, an assessment of the hydrological and hydrogeological context and how the scheme shall be maintained and managed following completion), which shall accord with the design principles for this site, are submitted to and approved by the relevant planning authority in consultation with the Environment Agency.

“(2) The authorised development shall be carried out in accordance with the approved details, unless otherwise approved by the relevant planning authority in consultation with the Environment Agency, and completed prior to use of the authorised development.”

1.3.20 Finally, the EA raised concerns with regards to the generic site information for both Greenwich Pumping Station and Abbey Mills Pumping Station which shows that no riparian and in-river structure design principles apply at these sites. The EA notes that this is a mistake as both sites are adjacent to a river and, therefore, IRVR.12, IRVR.13 and IRVR.14 should apply at these sites.

1.3.21 TW notes Table 4.39 and Table 4.41 of the Design Principles have now been reviewed and amended as a result of EA comments (see 3 March 2014 Design Principles, Doc ref: APP179.01).

Report on the implications for European sites

1.3.22 In its submission EA18 of 12 February 2014, the EA confirms that it has reviewed the Report on the Implications for European Sites (REIS) with respect to potential impacts of changes in the quality and location of discharges to water, as a consequence of the construction and operation of the project, and including significant in-combination impacts.

1.3.23 TW is pleased to note that the EA agrees that the conclusion of the RIES of no adverse impact is correct.

Draft Consents Management Plan

1.3.24 TW notes the comments provided by the EA in the submission EA18 of 12 February 2014 on the Draft Consents Management Plan (Doc ref: APP107). Where appropriate, TW will consider and address the comments provided by the EA.

Groundwater Environmental Management – Dewatering and Monitoring Strategy

1.3.25 In its submission EA18 of 12 February 2014, the EA confirms it has reviewed the draft Groundwater Environmental Management - Dewatering and Monitoring Strategy (GEMDMS), and advises that the document

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should contain a section concerning the assessment of risk along the tunnel route of the mobilisation of pre-existing contaminants and proposed remedial works.

1.3.26 This issue has been discussed and agreed between the EA and TW, and was addressed in the version of the GEMDMS submitted on 12 February 2014 (Doc ref: APP128). The agreed additional text regarding risk assessment along the tunnel route has also been retained in the final version of the GEMDMS, which is being submitted on 3 March 2014 (Doc ref: APP141).

Excavated Materials and Waste Commitments

1.3.27 TW notes that the EA has reviewed and provided comments on the 3 February 2014 version of the Excavated Material and Waste Commitments (EMWC) document (Doc ref: APP109). The EA notes that it no longer has a remit in the project-wide and site waste management plans, and hence does not wish to be consulted on changes to waste management plan templates.

1.3.28 The comments made by the EA have been addressed in the version of the EMWC document, which is being submitted on 3 March 2014 (Doc ref: APP142).

Response to EA20: Protective provisions

1.3.29 In its submission EA20 on the 12 February 2014, the EA provided a set of preferred protective provisions on the assumption that a legal agreement between TW and the river regulators (the EA, the PLA and the MMO) would be in place by the end of the examination.

1.3.30 It should be noted that the preferred EA protective provisions provided by TW on 12 February 2014 (Schedule 16, Part 3 of the Draft DCO, Doc ref: APP124.03) were submitted on the assumption that the legal agreement between TW, the EA, the PLA and the MMO would not be in place.

1.3.31 Considerable progress has been made in relation to the legal agreement with the river regulators submitted to the ExA on 13 January 2014 (Doc ref: APP74.4), and the EA protective provisions that would apply on the assumption that either the agreement is in place, or not in place, by the end of the examination. The jointly agreed EA protective provisions on the assumption that the legal agreement is in place by the end of the examination are being submitted as Appendix 1 of the 3 March 2014 revised legal agreement with the river regulators (Doc ref: APP183).

1.3.32 TW understands that the EA and TW will provide a jointly-signed update on whether the legal agreement has been executed, or not, in their submissions of 11 March 2014.

Response to EA19: Statement of Common Ground

1.3.33 The following paragraphs provide TW‟s position on the outstanding matters identified in the SoCG summary table submitted by the EA on 12 February 2014 (Doc ref: EA19).

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Question: 58.1


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2.3 Issue: Ecological compensation package inadequate and not secure

1.3.34 In its submission EA19 of 12 February 2014, the EA notes that this matter is conditionally agreed. The EA also notes that, in its role within the Habitat Compensation Working Group, it has agreed to the principle of delivery of the ecological compensation package being through the relevant local planning authorities, but that it understands that the relevant S106 agreements have not yet been concluded.

1.3.35 The EA has now had the opportunity to review the S106 agreement between TW and the London Borough (LB) of Wandsworth, and, as a result, this matter is now agreed. The jointly-signed SoCG update letter submitted to the ExA on 17 February 2014 (Doc ref: APP154) confirms that the EA and TW are now in agreement over the resolution of this issue.

5.9 Issue: Sustainable drainage

1.3.36 In its submission EA19 of 12 February 2014, the EA notes that this issue is conditionally agreed, subject to its review of TW‟s 12 February 2014 submission.

1.3.37 In the jointly-signed EA SoCG update letter submitted by TW on 17 February 2014, the EA notes that the 12 February 2014 Design Principles still make it unclear which standards should be followed with regards to drainage design (ie, National Standards for Sustainable Drainage Systems or the London Plan).

1.3.38 TW believes the matter is adequately addressed through the drainage design principles (see 3 March 2014 Design Principles) and the „surface water drainage‟ Requirements in Schedule 3 of the Draft DCO.

1.3.39 As stated in para. 1.3.14 above, drainage Design Principle SDRN.01 was amended in the 12 February 2014 version of the Design Principles to include a reference to the London Plan in response to EA comments.

1.3.40 TW understands this matter remains as not agreed (see also paras. 1.3.10 to 1.3.21, design principles, above, for a more detailed discussion of positions on this issue).

9.1 Issues: Albert Embankment Foreshore terraces

1.3.41 In its submission EA19 of 12 February 2014, the EA notes that this matter is conditionally agreed, but that the EA cannot support encroachment for non-operational use. The EA, however, recognises that the decision lies with the Secretaries of State as advised by the ExA. Should the terraces remain as per the proposed design, the EA is in agreement with TW over the use of landscaping Requirement ALBEF9.

1.3.42 The jointly-signed EA SoCG update letter, submitted by TW on 17 February 2014, observes that this matter is, in fact, not agreed, given the EA‟s inability to support any encroachment for non-operational use and that both parties recognised that the ultimate decision lies with the Secretaries of State. The letter confirms that should the design of the

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Question: 58.1


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terraces remain, the EA and TW are in agreement over the use of Requirement ALBEF9 (see Schedule 3 of the 3 March 2014 Draft DCO).

1.3.43 TW notes that, in its 2 December 2013 submission to the ExA (Doc ref: EA08), the EA requested to be a party in the „detailed design approval for river wall and terraces‟ Requirements (eg, ALBEF3). Within this submission, the EA explained that if the terraces remain on the design for Albert Embankment Foreshore, it would wish to see a Requirement enabling them to review, comment on and agree the final design and planting of the terraces to ensure that these are constructed to maximise their ecological benefit. In its 3 February 2014 submission to the ExA (Doc ref: EA15), the EA reiterated its wish to be a consultee on Requirement ALBEF3.

1.3.44 TW has amended Requirement ALBEF3 (detailed design approval river wall and terraces) in the 12 February 2014 Draft DCO (Doc ref: APP124.03) to include consultation with the EA in respect of land-based access to flood defences and potential for ecological enhancements.

1.3.45 In addition, Design Principle IRVR.01has also been amended to capture the recommendation from the Habitat Compensation Working Group to provide in-river support for fish fry migration where practicable. This principle is being secured though the definition of „ecological enhancements‟ within the EA protective provisions.

1.3.46 TW is unclear on which basis the EA objects to the terraces at Albert Embankment Foreshore, given:

a. the lack of any formal EA policy on foreshore encroachment

b. the agreement over the resolution of EA SoCG Issue 1.1, Structures in the river (ie, encroachment)

c. the clarification provided with regards to the proposed terraces design (see Comments on Relevant Representation of the Environment Agency, 4 November 2013, Doc ref: APP21)

d. the amendments to Requirements ALBEF3, ALBEF9 and Design Principle IRVR.01

e. the agreed ecological compensation measures (see TW response to R51.3, Doc ref: APP161)

f. the agreement over the protective provisions.

1.3.47 This matter is not agreed.

1.3.48 TW believes the design of the terraces as proposed is appropriate and provides a balance between the conflicting demands at this location (eg, ecology, townscape, visual amenity and heritage). Any intertidal habitat loss would be compensated for through the measures identified by the Habitat Compensation Working Group, including the proposed River Wandle restoration scheme. The EA will be given the opportunity to comment on these matters through the relevant Requirements and its protective provisions.

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Question: 58.1


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9.2 Issue: Chelsea Embankment Foreshore terraces

1.3.49 In its submission EA19 of 12 February 2014, the EA notes that this matter is conditionally agreed, but that the EA cannot support encroachment for non-operational use. The EA, however, recognises that the decision lies with the Secretaries of State as advised by the ExA. Should the terraces remain as per the proposed design, the EA is in agreement with TW over the use of landscaping Requirement CHEEF8.

1.3.50 The jointly-signed EA SoCG update letter, submitted by TW on 17 February 2014, confirms the nature of this matter but observes that it is not agreed. As with Issue 9.1 above, this is due to the EA‟s inability to support encroachment for non-operational use (ie, townscape/aesthetic reasons). The letter confirms that should the design of the terraces remain, the EA and TW are in agreement over the use of Requirement CHEEF8 (see Schedule 3 of the 3 March 2014 Draft DCO).

1.3.51 TW notes that, in its 2 December 2013 submission to the ExA , the EA requested to be a party in the „detailed design approval for river wall and terraces‟ Requirements (eg, CHEEF3). Within this submission, the EA explained that if the terraces remain on the design for Chelsea Embankment Foreshore, it would wish to see a Requirement enabling them to review, comment on and agree the final design and planting of the terraces to ensure that these are constructed to maximise their ecological benefit. In its 3 February 2014 submission to the ExA (Doc ref: EA15), the EA reiterated its wish to be a consultee on Requirement CHEEF3.

1.3.52 Design Principle CHEEF.02 was amended in the 3 February 2014 Draft DCO (Doc ref: APP105.02) to take account of the EA‟s suggested wording.

1.3.53 In addition, Requirement CHEEF3 (detailed design approval river wall and terraces) has been amended in the 12 February 2014 Draft DCO (Doc ref: APP124.03) in response to EA comments.

1.3.54 As explained in para. 1.3.45, Design Principle IRVR.01 has also been amended to capture the recommendation from the Habitat Compensation Working Group to provide in-river support for fish fry migration where practicable. This principle is being secured though the definition of „ecological enhancements‟ within the EA‟s protective provisions.

1.3.55 TW is unclear on which basis the EA objects to the terraces at Chelsea Embankment Foreshore, given:




d. the amendments to Requirements CHEEF3, CHEEF8 and design principles IRVR.01 and CHEEF.02

Question: 58.1


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e. the agreed ecological compensation measures (see TW response to R51.3, Doc ref: APP161) and



1.3.57 TW believes that the design of the terraces as proposed is appropriate and provides a balance between the conflicting demands at this location (eg, ecology, townscape, visual amenity and heritage). Any intertidal habitat loss would be compensated for through the measures identified by the Habitat Compensation Working Group, including the proposed River Wandle restoration scheme. The EA will be given the opportunity to comment on these matters through the relevant Requirements and its protective provisions.

9.3 Issue: Victoria Embankment Foreshore floodable public realm

1.3.58 In its submission EA19 of 12 February 2014, the EA notes that this matter is not agreed, and that the EA cannot support encroachment for non-operational use. The EA, however, recognises that the decision lies with the Secretaries of State as advised by the ExA.

1.3.59 The jointly-signed EA SoCG update letter, submitted by TW on 17 February 2014, confirms the nature of this matter and that it is not agreed.

1.3.60 In its written representation to the ExA (Doc ref: EA04), the EA states:

“This Issue is not yet Agreed.

“In our Relevant Representation we raised concerns regarding the proposed floodable public terraces at Victoria Embankment Foreshore and them being for non operational or engineering purposes.

“If the terraces are for non operational or engineering purposes then they represent unnecessary encroachment and loss of foreshore habitat.

“We have discussed this issue with the applicant and they have provided us with clarification on the purposes and need for the floodable public terraces. They have confirmed that the extent of the projection of the terraced area was determined by the requirement to provide adequate ship impact protection for the CSO drop shaft and other below ground infrastructure. There are two areas of the structure that sit outside of this ship impact protection zone and they have been provided to „square off‟ the projection. This symmetrical design has been proposed so the structure blends into the surrounding area with regards to townscape, visual and heritage aspects. As two areas of the structure are not for operational purposes, we are not in agreement with TWUL over this issue and maintain that there is unnecessary encroachment into the foreshore and habitat loss for non operational purposes. We maintain that Design Principle VCTEF.16 should be removed.

“Any permanent loss of foreshore habitat must be compensated for and this is being discussed by the Ecological Compensation Working Group.”

1.3.61 TW has provided justification on the proposed area for the terraces at this site (see response from TW to ExA first written question 2.15, Doc ref:


Question: 58.1


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APP02). TW considers that Design Principle VCTEF.16 should be retained. The loss of foreshore habitat at Victoria Embankment Foreshore site has been assessed as part of the overall loss of habitat arising from all of the foreshore sites. Adequate compensation would be provided for this loss and, in its role within the Habitat Compensation Working Group, the EA has agreed to the ecological compensation measures identified by the group, including the proposed River Wandle restoration scheme which is to be secured through a S106 agreement with the LB of Wandsworth.

1.3.62 TW is unclear on which basis the EA objects to the terraces at Victoria Embankment Foreshore, given:




d. the amendments to Requirements VCTEF6 and Design Principle IRVR.01

e. the agreed ecological compensation measures (see TW response to R51.3, Doc ref: APP161) and



1.3.64 TW considers that the floodable public terraces proposed are appropriate to balance the conflicting demands at this location (eg, ecology, townscape, visual amenity and heritage). Any intertidal habitat loss would be compensated for through the measures identified by the Habitat Compensation Working Group, including the proposed River Wandle restoration scheme. The EA will be given the opportunity to comment on these matters through the relevant Requirements and its protective provisions.

9.11 Issue: Flood defence access at Barn Elms

1.3.65 In its submission EA19 of 12 February 2014, the EA notes that this matter is conditionally agreed, subject to the agreement of the Heads of Terms between LB Wandsworth and TW, which the EA had not had the opportunity to review at that point. The EA also notes that this matter will be resolved once that agreement is in place, which will secure EA access to its asset.

1.3.66 The jointly-signed EA SoCG update letter, submitted by TW on 17 February 2014, confirms the nature of this matter and observes that it is not agreed, as the Heads of Terms between LB Wandsworth and TW were as yet unavailable for EA review.

1.3.67 TW agrees that, during the construction period of the authorised works, TW will make provision for access by the EA to the Ashlone Wharf tidal barrier at any time, to enable the EA to carry out scheduled and

Question: 58.1


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unscheduled maintenance in accordance with its statutory duties. The Heads of Terms (HoTs) for an access agreement at Beverly Brook Tidal Barrier (Ashlone Wharf, Barn Elms) have been agreed between the EA and TW.

1.3.68 TW is also in discussion with the London Borough of Wandsworth over the wording of a land agreement, which would allow the EA access to the Ashlone Wharf tidal barrier during the construction phase. TW understands that this agreement has been acknowledged as acceptable in principle by the LB of Wandsworth, although as yet it remains unsigned. Written confirmation from the LB of Wandsworth regarding the following wording included in the Heads of Terms of the access agreement was provided to the EA on 26 February 2014:

“The tenant will allow the Environment Agency or its contractor with or without plant and machinery or other attendant equipment to use the works access for the purposes of gaining vehicular access to the Beverly Brook Tidal Barrier (Ashlone Wharf) to carry out its flood defence obligations.”

1.3.69 In the absence of a response from the EA on this written confirmation, however, the issue remains not agreed. TW and the EA will provide an update on this matter in the 11 March 2014 final written submissions.

10.6 Issue: CHAWF.07 drainage

1.3.70 In its submission EA19 of 12 February 2014, the EA notes that the matter is not agreed, and that the EA remains unsatisfied that adequate drainage will be provided on Chambers Wharf, either for the long-term or temporary scenario post-construction.

1.3.71 The jointly-signed EA SoCG update letter, submitted on 17 February 2014, confirms the nature of this matter and that it is not agreed.

1.3.72 As set out in para. 1.3.17, the EA believes the drainage Design Principle CHAWF.07 (as amended for the 3 February 2014 version of the Design Principles, Doc ref: APP106.01) does not allow for an interim drainage solution should the proposed residential development not follow immediately after construction of the project is completed. As it is not possible to guarantee that the residential development will definitely be built, nor that drainage is installed immediately upon acquiring the site, the EA believes that an interim drainage solution is essential and should be developed by the contractor.

1.3.73 TW believes this matter was adequately addressed through the amendments to Table 4.31 and Design Principle CHAWF.07 as proposed in the 3 February 2014 version of the Design Principles (see para. 1.3.18 above), as well as the site restoration Requirement CHAWF10 (see Schedule 3 of the 3 March 2014 Draft DCO, Doc ref: APP177.02).

1.3.74 TW considers that the detailed design of the permanent surface water drainage at this site should be the responsibility of the residential developer. This development has commenced (on an adjacent site) and there is no reason to believe that it will not be completed. It would be wasteful and unnecessary for the contractor to design and implement a

Question: 58.1


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temporary drainage scheme for Chambers Wharf, as this would only need to be destroyed shortly thereafter to allow for the residential development. Temporary drainage provision at this site would, therefore, be secured by Requirement CHAWF10. This Requirement, in turn, refers to the CoCP Part B, Section 4, Site Operation which states “On completion of the works the site shall be left in a safe condition, with secure hoardings, a level ground surface which does not increase flood risk in the surrounding area and no open stockpiles”.

1.3.75 Notwithstanding the above and given EA‟s ongoing concerns, a new surface water drainage Requirement (CHAMW12) is being included in Schedule 3 of the 3 March 2014 Draft DCO, with wording as follows:

“(1) Construction of the permanent above-ground structures shall not commence until details of the surface water drainage system for this site (including means of pollution control, an assessment of the hydrological and hydrogeological context and how the scheme shall be maintained and managed following completion), which shall accord with the design principles for this site, are submitted to and approved by the relevant planning authority in consultation with the Environment Agency.

“(2) The authorised development shall be carried out in accordance with the approved details, unless otherwise approved by the relevant planning authority in consultation with the Environment Agency, and completed prior to use of the authorised development.”

1.3.76 The inclusion of a new surface water drainage Requirement for Chambers Wharf has been discussed with the EA. TW and the EA will provide an update on whether this issue has now been resolved in the 11 March 2014 final written submissions.

10.8 Issue: Design Principle KEMPF.08 for King Edward Memorial Park Foreshore

1.3.77 In its submission EA19 of 12 February 2014, the EA notes that this matter is conditionally agreed, although the EA cannot support encroachment for non-operational use. The EA, however, recognises that the decision lies with the Secretaries of State as advised by the ExA and that should the overhang remain in the design at this site, the EA understands TW‟s intention to cite the EA in Requirement KEMPF5.


1.3.79 In its written representation, the EA states:

“This design principle [KEMPF.08] requires the design of the river walls not to compromise the safety of recreational boat users and shall not incorporate overhangs unless they are adequately fendered.

“We have been in discussion with TWUL over this issue and currently have not come to an agreement on this matter.

“We remain concerned that the proposed overhang is not for operational purposes and should not be part of the Design Principles. TWUL has confirmed that this structure is to enable visual integration of the foreshore

Question: 58.1


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site. The mitigation hierarchy within the ES prioritises avoiding impacts ahead of reducing them, and we believe this principle should be applied here.”

1.3.80 TW believes that the proposed illustrative design is the very least required to effectively integrate the structure into the park, and the best alternative to additional encroachment. The overhangs have been reduced to the very minimum that TW is comfortable with, given the illustrative nature of the design.

1.3.81 TW‟s amended Requirement KEMPF5 (detailed design approval river wall and terraces) in the 12 February 2014 Draft DCO (Doc ref: APP124.03) is to include consultation with the EA as requested.


1.3.83 TW believes that the proposed overhang is appropriate and provides a balance between the conflicting demands at this location (eg, ecology, townscape, visual, amenity use and heritage). The EA will be given the opportunity to comment on these matters through the Requirements and its protective provisions.

Issue 10.12: Site Drainage Principles

1.3.84 In its submission EA19 of 12 February 2014, the EA notes that this issue is conditionally agreed, subject to its review of TW‟s 12 February 2014 submission.

1.3.85 As stated in para. 1.3.14 above, drainage Design Principle SDRN.01 was amended in the 12 February 2014 Design Principles to include a reference to the London Plan in response to EA comments.

1.3.86 In the jointly-singed EA SoCG update letter, submitted by TW on 17 February 2014, the EA notes that Design Principle SDRN.01, as included in the 12 February 2014 Design Principles, still make it unclear which standards should be followed with regards to drainage design (ie, National Standards for Sustainable Drainage Systems or the London Plan).

1.3.87 TW believes that Design Principle SDRN.01, as currently drafted, adequately addresses this matter.

1.3.88 TW understands this matter remains as not agreed (see also the section on Design Principles, above, for a more detailed discussion of positions on this issue).

Issue 10.14: ALBEF.05 foreshore structure ‘bedding’

1.3.89 In its submission EA19 of 12 February 2014, the EA notes that this matter is not agreed and that the EA cannot support the „bedding in‟ and consequent loss of habitat for visual purposes. The EA, however, recognises that the decision lies with the Secretaries of State as advised by the ExA.


Question: 58.1


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1.3.91 In its 31 January 2014 comments on the 13 January 2014 Design Principles (Doc ref: APP76.01), the EA states the following with regards to Design Principle ALBEF.05:

“The EA still disagree with the inclusion of this design principle as covered in Table 5 Section 10 of our Written Representation. It is our understanding that this „bedding in‟ is proposed for visual purposes only, and the EA would not support this for visual purposes alone.”

1.3.92 Design principle ALBEF.05 was subsequently amended in the 3 February 2014 Design Principles (Doc ref: APP106.01) to clarify the purpose of the proposed use of rocks and boulders in the foreshore. As currently drafted, Design Principle ALBEF.05 states:

“The interception structure and terraces shall be „bedded‟ into the foreshore by rocks and boulders to soften the transition between the terraces and the foreshore....”

1.3.93 As set out in TW‟s Comments on Relevant Representation of the Environment Agency (Doc ref: APP21), the very base of the terraced structure at the Albert Embankment Foreshore site would be tied into the foreshore with boulders. The structure as a whole is designed to be visually integrated into the foreshore environment and to mediate between the terrestrial and riverine environment. The surface of the existing riverbed is broken up in nature and consists of sediments, rubble, cobbles and small boulders. The proposed use of boulders is therefore visually consistent with the setting and serves to integrate (bed) the foreshore structure into its environment. Boulders would be used sparingly in areas where required to blur the transition between the new structure and the foreshore. As the ground levels in the foreshore vary greatly, boulders would be used to soften the junction of the terraced structure with the riverbed and river walls, without the use of additional terraces to mediate the level change where the foreshore levels dip away. This anchors the foreshore structure into the foreshore in a more natural way.

1.3.94 TW notes that the use of boulders is a key component of the design strategy at this site in order to visually integrate the interception structure into the foreshore environment. The proposed approach and indicative design at this site is fully supported by key stakeholders, including the Historic Buildings and Monuments Commission for England (HBMCE) and the London Borough of Lambeth.


1.3.96 TW believes that the proposed use of rocks and boulders is appropriate and provides a balance between the conflicting demands at this location (eg, ecology, townscape, visual, amenity use and heritage). On this basis, TW believes that Design Principle ALBEF.05 should be retained. The EA will be given the opportunity to comment on these matters through the relevant Requirements and its protective provisions.

Question: 58.1


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1.4 Thames Water response to Free Trade Wharf Management Company Ltd

Introduction

1.4.1 Free Trade Wharf Management Company Limited (FTWMCL) has provided additional representations on 3 February 2014 and 12 February 2014. This document provides a response to the main issues raised in these representations. Where TW has already responded to matters in its response to the ExA‟s questions or at the examination hearings, the response is not repeated in this document.

Air quality

1.4.2 FTWMCL, at Section 3 of its 3 February 2014 submission, has made a number of comments relating to air quality and TW‟s responses to the ExA‟s questions on this subject. A series of extracts from FTWMCL representation are provided below, followed in each case by TW‟s response:

“TW have previously suggested that there will be no odour effects at KEMPF during the operational phase. In their answer to question 20.3 TW confirm that the ventilation stacks at KEMPF need to be 1m higher than at any other site as the expected hydrogen sulphide level during a 15yr storm would be 238μg/m3 which exceeds the EA‟s recommended maximum of 150μg/m3”

1.4.3 As explained in TW‟s response to second written question 20.3 in January 2014 (Doc ref: APP47), it is prudent to raise the ventilation columns at KEMPF by 1m to a minimum height of 5m to ensure compliance with the Environment Assessment Level for the hourly concentration of hydrogen sulphide under the 1 in 15-year storm event. The hydrogen sulphide level with the 5m ventilation columns is 107μg/m3. The ventilation columns at one other site need to be raised to a minimum height of 6m, hence KEMPF is not unique in this respect.

“FTW is immediately adjacent to the proposed ventilation stacks and stands considerably taller than the vents which will be 4m, 5m or 8m. There are predicted to be 8 hours when odour will be above 1.5ouE/m3 (European Odour Units per cubic metre) at ground level (see table 2.1 in response to question 20.2) yet odour is detected by 50% of people at 1ouE/m.

“FTWMCL believes there is a risk of devaluing FTWMC and residents‟ property interests due to odour or the perception of odour. Even in the winter and during storms, it is not uncommon for residents to leave windows ajar. There is also a ventilation system in the window frames that cannot be shut off.

“If the effects of discharging these gasses at ground level are considered unacceptable, FTWMCL does not consider it is appropriate to discharge them immediately adjacent to residential properties.”

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1.4.4 The plan is for two ventilation columns with a minimum height of 5m. The definition of 1ouE/m3 is the level of odour detected by half the panel of trained assessors under laboratory conditions. This means that the general public would not detect this level of odour in the open air.

1.4.5 The zone where the odour level is predicted to exceed 1.5ouE/m3 for eight individual hours during the typical year is within 25m from the ventilation columns at ground level, and 15m from the ventilation columns at a height of 4m. The highest values occur at the ventilation columns with a rapid diminishing of values to 1.5ouE/m3. For example, within 5m of the ventilation columns, the values have reduced by about 75 per cent. Heights higher than 4m are in a zone for odour where values are less than 1.5ouE/m3. This is because dispersion, and therefore dilution of odours, increases with height. This means that the Free Trade Wharf properties, the nearest point of which is 65m from the ventilation columns, will not be affected by odour. In fact, the maximum odour level predicted at 65m from the ventilation columns is less than 0.1ouE/m3, both at ground level and at a height of 4m. Therefore, there is no risk of odours being a factor in the value of Free Trade Wharf properties. The odours released presently when the combined sewer overflow (CSO) discharges frequently are of a much higher concentration than the treated air releases which would emanate from the ventilation columns during operations.

1.4.6 We believe our approach for avoiding nuisance odours has a fourfold protection to the neighbourhood: This is by the operation of the system which draws in air at this site and infrequent air releases; conservative values for the production of odour from sewage; air releases are treated, and enhanced dispersion by using ventilation columns.

Noise and vibration

1.4.7 FTWMCL has made a number of comments relating to noise and vibration. A summary of the relevant points in the FTWMCL representations is provided below in italics, followed in each case by TW‟s response.

National Policy Statement and noise

1.4.8 FTWMCL questions Thames Water‟s assertion that a „significant adverse impact‟, as identified in the Environmental Statement, is not the same as the „significant adverse impact‟ identified in the National Policy Statement for Waste Water (the „NPS‟) which, according to FTWMCL, leaves the ExA and affected parties in the dark as to whether a particular impact is a significant adverse effect according to the NPS.

1.4.9 TW‟s understanding of the NPS noise policy and how the Environmental Statement assessment should be considered in terms of the policy has been responded to in oral evidence (Appendix B to APP102.03 and Appendix A of APP157).

Mitigation in the park

1.4.10 FTWMCL considers the environmental impact of the proposed 5-6m acoustic barrier has not been considered. Thames Water is yet to confirm

Question: 58.1


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whether the barrier can be provided within the limits of land acquired or used, or whether they will be dependent on obtaining separate permissions and agreements to be able to provide this measure.

1.4.11 TW‟s response is that this matter has been responded to in oral evidence during the issue specific hearing relating to noise and vibration (Appendix B of APP115.01).

General comments

1.4.12 FTWMCL has raised concerns regarding the trigger action plans (TAPs), specifically that the proposed TAPs are also not the subject of DCO Requirements and, as such, FTWMCL does not consider the commitments within them to be adequately secured and, given the project‟s long gestation, TAPs could have commenced earlier in the process to enable compliance with them to be included as a Requirement in the DCO and their terms to be before the ExA.

1.4.13 TW‟s response is that over the course of the process the project has committed to additional specific on-site mitigation at KEMPF (CoCP Part B, Doc ref: APP178.37) and to the „not environmentally worse than‟ (NEWT) requirement in section 2.1 of the CoCP Part A (Doc ref: APP178.01) that is set in terms of Environmental Statement update report (Doc refs: APP184.01 and APP184.01.27). These measures provide substantial additional protection for FTW.

1.4.14 The project has committed to provide off-site noise mitigation at FTW in advance of construction, without waiting for noise levels to be confirmed for the contractors detailed construction method (Doc ref: APP181 and 182).

1.4.15 The off-site mitigation will avoid a significant observed adverse noise effect on FTW (south) and will minimise any residual adverse noise effect as far as practicable (Doc ref: APP186). This is to be secured by the legal agreement and associated S106 unilateral undertaking (Doc ref: APP181 and 182).

1.4.16 The performance of the mitigation to be provided is secured by internal noise levels now defined in the Draft DCO project-wide Requirement PW17 that are to be met in accordance with the Non-statutory Off-site Mitigation and Compensation Policy (Doc ref: APP186) and the legal agreement and associated S106 unilateral undertaking (Doc ref: APP181 and 182).

1.4.17 TW believes that the foregoing provide the security and certainty required to enable the ExA to give full weight to this mitigation that meets, in full, the three aims of NPS 4.9.9, the third aim being met by the legacy benefit of the off-site mitigation that will reduce the FTW‟s exposure to existing noise, particularly from the Highway.

1.4.18 As has been set out in TW‟s oral submissions to the hearings, TW has, and continues to actively engage, with the FTWMCL to develop and agree the TAP which will define the detail of the mitigation to be provided (Doc ref: APP102.04).

http://infrastructure.planningportal.gov.uk/wp-content/ipc/uploads/projects/WW010001/2.%20Post-Submission/Hearings/Issue%20Specific%20Hearing%20-%2023-01-2014%20-%201030%20-%20Glaziers%20Hall/APP102.04%20Written%20summaries%20of%20the%20cases%20put%20orally%20at%20the%20hearings%20held%20on%2023%20Janua

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Noise and socio-economic impacts at Heckford Street with mitigation measures in place

1.4.19 FTWMCL questioned the basis on which TW has assessed the noise impact in Schoolhouse Lane.

1.4.20 This was responded to in TW‟s oral submissions to the hearings held on 23 January 2014 (Doc ref: APP102.04).

Thames Water’s response to ExA question 29.2: Request for method 2 assessment to be provided

1.4.21 The requested information was provided in Doc ref: APP97 that also explained why no weight should be given to the information.

1.4.22 We have also set out why Method 1, as applied in the Environmental Statement, is preferred to Method 2 in oral evidence to the issue specific hearing relating to noise and vibration (Doc ref: APP157).

Thames Water’s response to ExA question 29.3: Clarification of the areas of FTW which are considered to middle and south

1.4.23 FTW south is specifically defined in the schedule of TAPs which it provided at Appendix 1 to the Legal Agreement for Securing Noise Mitigation and Compensation Policies (Doc ref: APP182).

Thames Water’s response to ExA question 29.4: Considers that the effects on the eastern wing of FTW blocks A and B are closer than Trafalgar Court

1.4.24 It is agreed that the eastern façade of blocks A and B are a similar distance to Trafalgar Court (part of Prospect Wharf as assessed in the Environmental Statement). However, the works which result in the adverse impact at this receptor is due to works within King Edward Memorial Park, which would be screened to blocks A and B and therefore, blocks A and B will not be subject to a significant adverse impact from construction noise.

Thames Water’s response to ExA question 29.11: Thames Water’s response declining the submission of maximum noise levels

1.4.25 This information has been provided within Doc ref: APP150.

Thames Water’s response to ExA question 29.13: Ventilator provided is ineffective at reducing heat and the running costs are to be borne by the residents

1.4.26 The function of the ventilation supplied as part of noise insulation is to provide the equivalent ventilation and cooling that would be achieved by opening the window. The detail of ventilation to be provided as part of the mitigation will be defined and agreed with the owner/occupiers as part of TAPs.

http://infrastructure.planningportal.gov.uk/wp-content/ipc/uploads/projects/WW010001/2.%20Post-Submission/Representations/ExA%20Questions/13-01-2014%20-%20Responses%20to%20Exa%20Questions%20Round%202/140124_WW010001_Thames%20Water_APP97_Noise%20+%20Disturbance_ExA%202nd%20WQ%2029.2%20sup

Question: 58.1


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Concern regarding the averaging period of 10 hours and the contractor could work at usual levels for 9 hours, then reduce the level for 1 hour to avoid the requirement for mitigation, and short duration noisier activities

1.4.27 The trigger values for off-site mitigation are in terms of the equivalent continuous noise level (LAeq). This indicator is not an average level and is weighted towards shorter duration, higher noise levels as has been confirmed in evidence by both interested parties and the applicant (Doc ref: APP115.01,section 5.3). If the contractor were to create a noise for 9 hours and then reduce the level for 1 hour, the maximum possible reduction in the 10 hour LAeq value is less than 0.5 dB.

1.4.28 The project has made the commitment to provide off-site mitigation at FTW south before the start of construction (Doc ref: APP182, Appendix 1) without waiting for confirmation of noise levels based on the contractor‟s detailed construction method. The „not environmentally worse than‟ (NEWT) commitment will ensure that no significant noise effect can occur on any other part of FTW (Doc ref: APP178.02).,

Monitoring should be undertaken at FTW to be agreed by LB Tower Hamlets and, in addition to a semi-permanent monitoring station, the contractor shall undertake hand-held monitoring on site

1.4.29 Noise and vibration monitoring requirements have been refined in the CoCP Part A (section 6.6) and the details of noise and vibration monitoring arrangements at FTW will be agreed with LB Tower Hamlets in advance of construction as part of the Noise and Vibration Management Plan (Doc ref: APP178.02, section 6.1). The CoCP is secured by project wide requirement PW06 in schedule 3 of the DCO (Doc ref: APP177.02).

Construction matters

Programme

1.4.30 FTWMCL, at paragraphs 4.3 and 4.4 of its 3 February 2014 submission, has made a number of comments relating to prohibiting work on Saturdays and the implications this would have for the overall programme.

1.4.31 It is not possible to assess the true effect of a reduced working week on the construction programme until a contractor has been appointed and the detailed construction method is known. It is very unlikely, however, that the omission of Saturday morning working would not be reflected in an increase in the overall construction programme.

Piling

1.4.32 FTWMCL, at paragraphs 11.1 and 11.2 of its 3 February 2014 submission, has made a number of comments relating to piling methods and contingency techniques.

1.4.33 TW proposes to use press/push in pilling techniques for construction of the foreshore cofferdam. A commitment to this method can now be found in Section 6 of the updated CoCP Part B.

Question: 58.1


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1.4.34 Section 6 of the updated CoCP Part B for the King Edward Memorial Park Foreshore site now contains the following clarification regarding contingency measures if the proposed method is determined to be impossible:

“Where push piling is determined to be impossible, this shall be demonstrated by the contractor, who shall make an application to the local authority to use an alternative piling method through the Section 61 dispensation process (see Appendix A, Section A.1 in the CoCP Part A) or through contingency measures and arrangements if included in the original Section 61 consent.”

1.4.35 As stated in TW‟s response to second written question 29.17, the ground conditions at this site are deemed suitable for the use of press/push piling techniques. This has been confirmed in discussions between TW and contractors experienced in using this method in similar ground conditions.

1.4.36 In the very unlikely event that an obstruction within the riverbed makes it impossible to drive a sheet pile to the required level, three possible mitigation measures were set out in second written question 29.17 as follows:

a. Remove the obstruction using a long-reach excavator

b. Leave the pile short of its final design level, cut the pile off and strengthen the temporary works using local bracing

c. Break up the obstruction using drill or auger.

1.4.37 Based on the known geology at this site, TW does not foresee a situation where the use of percussive piling techniques would be necessary for cofferdam construction.

1.4.38 FTWMCL, at paragraphs 12.1 and 12.2 of its 3 February 2014 submission, has commented on the inclusion of the press piling technique in the CoCP Part B for KEMPF.

1.4.39 TW confirms that Section 6 of the updated CoCP Part B for the KEMPF site now contains the following confirmation regarding the use of press/push piling techniques:

“Except for the anchor piles, the contractor shall construct the cofferdam using push piling unless this is determined to be impossible. The first anchor piles shall be installed at a location away from the closest sensitive receptors, including Free Trade Wharf South.”

Daylight and sunlight implications of proposed acoustic wall

1.4.40 Included at Appendix A to this response is a paper reviewing the daylight and sunlight implications of the proposed 5-6m high acoustic wall at the site perimeter adjacent to FTW. It confirms that there will be no material impact on the daylight or sunlight amenity to this property.

The Heckford Street and Park option

1.4.41 FTWMCL, at paragraph 14.5 of its 3 February 2014 submission, has commented on the mitigation proposed for the KEMPF proposals as

Question: 58.1


25

compared to that developed for the Heckford Street and Park option. In particular, FTWMCL has queried why the 5-6m high acoustic barrier proposed for KEMPF has not been proposed for the park site under the Heckford Street and Park option. In addition, FTWMCL has queried the approach to providing acoustic structures at Heckford Street.

1.4.42 TW would clarify that the 5-6m acoustic barrier will be implemented as specific noise mitigation for the southern end of Free Trade Wharf during shaft constriction works under the KEMPF proposals. A similar mitigation was not required for the park site under the Heckford Street and Park option as noise effects from this site were not assessed as significant.

1.4.43 The construction activities at the Heckford Street site which have potential for noise effects are assessed as being:

a. demolition works

b. site clearance and set-up

c. diaphragm wall construction

d. shaft excavation

e. connection tunnel construction

f. interception chamber construction

g. fit-out and completion.

1.4.44 While many activities would be the same for both options, the Heckford Street and Park option would require additional works related to demolition of existing structures on the proposed worksite and tunnelling works to connect the CSO drop shaft at the Heckford Street site, with the proposed interception site in the north of King Edward Memorial Park.

1.4.45 The Heckford Street site is far closer to sensitive receptors than the KEMPF site. A series of five- and six-storey residential properties would be within 25m of the proposed CSO drop shaft and would also be located on the construction access route to the site. This limits the available options for mitigating noise effects at the site.

1.4.46 For assessment, it was assumed that the same package of embedded mitigation measures, where applicable, would be in place for the Heckford Street scheme, which would include use of a 3.6m high hoarding, screening off of static items of plant, reduced movements of plant at night during periods of 24-hour working, low vibration construction methods, etc.

1.4.47 Despite these measures, a large number of significant noise effects were assessed as being likely. These included:

a. Cable Street – Night-time noise during tunnelling works assessed as being significant

b. Schoolhouse Lane – Daytime, evening and night-time noise significant for all flats due to construction activity during all phases of work

c. Schoolhouse Lane – Daytime noise significant due to construction traffic accessing site

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d. Shadwell Basin Outdoor Activity Centre and Pier Head Preparatory School – Noise effects would be significant during site set-up and shaft construction works.

1.4.48 Many of these significant effects are a result of the proximity and number of sensitive receptors which have direct views over the site.

1.4.49 Three additional mitigation measures were assessed at the Heckford Street site:

a. An enclosure around the diaphragm wall slurry treatment plant

b. A three-sided enclosure with a roof around the materials handling area

c. An acoustic shed over the shaft during tunnelling works.

1.4.50 With these mitigations in place, the following significant effects would remain:

a. Schoolhouse Lane – Noise would remain significant for all flats due to construction activity during all phases of work.

b. Schoolhouse Lane – Daytime noise would remain significant due to construction traffic accessing site.

c. Pier Head Preparatory School – Noise effects would remain significant during site set-up and shaft construction works.

1.4.51 In addition to this, the duration of works on-site would be extended by approximately four months to allow for the construction and subsequent removal of these large enclosure structures. There would unquestionably be significant noise effects associated with these additional works, the result of which would be the mitigation of approximately three months of noise effects associated with tunnelling works. While technically possible, these mitigation measures were considered to be disproportionate, offering no net benefit.

1.4.52 The Heckford Street and Park option is not the scheme for the subject of the application for the project and, as such, the scheme will clearly not be as developed as the scheme applied for at King Edward Memorial Park Foreshore. However, at the request of the ExA, TW has made considerable efforts to assess the construction methods, associated environmental effects and possible mitigation measures for the Heckford Street and Park option. The mitigation measures proposed are extensive and are suited to a site of this type, where sensitive receptors are in close proximity to the works and are located on all sides. TW considers that there are no additional physical mitigation measures that could reduce the noise effects resulting from demolition works and from HGVs accessing the worksite.

Non-statutory off-site mitigation and compensation policy

1.4.53 FTWMCL, at Section 9 of its 3 February 2014 submission, makes a number of comments relating to the Non-statutory Off-site Mitigation and Compensation Policy.

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1.4.54 TW would like to refer stakeholders to the revised version of the policy that will be submitted on 3 March 2014 (Doc ref: APP186).

1.4.55 FTWMCL refer to a meeting at which TW agreed it would be willing to create a TAP for the whole of FTW. This is not the case. Only part of Free Trade Wharf South will be subject to a TAP. This is shown on a drawing (Plan 19) within the policy.

1.4.56 A number of FTWMCL comments related to how the proposed TAPs will be secured. TW can confirm that the policy, and therefore the TAPs, are secured by way of a legal agreement (in advance of the DCO being made) and by a Section 106 unilateral undertaking with the London boroughs (post-DCO) (Doc ref: APP181). In addition, a project-wide Requirement has been drafted for inclusion in the 3 March 2014 submission that makes the trigger values previously in the policy a DCO Requirement.

DCO drafting and Requirements

1.4.57 FTWMCL, at paragraph 18.2 of its 3 February 2014 submission, proposes an additional site-specific Requirement for KEMPF, in connection with alternatives.

1.4.58 TW considers the proposed Requirement to be procedurally unacceptable. The imposition of such a Requirement would have the effect of approving a scheme that is materially different to that which is the subject of the application for development consent, which has been subject to consultation and EIA.

1.4.59 TW has made representations throughout the examination process on the consideration of alternatives and its position remains unchanged.

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1.5 Thames Water response to Glendola Leisure Ltd

Introduction

1.5.1 The following response to Glendola Leisure Ltd (owners of the Star & Garter public house in Putney) addresses the questions raised in their representation to PINS on 18 February 2014 (which is a repeat of the letter submitted to PINS on 28 January 2014). TW met with representatives acting on behalf of Glendola Leisure on 10 January 2014 to respond to issues raised in their letter to PINS of 31 October 2013 and subsequently responded to by TW in Doc ref: APP 31.19, which was submitted to PINS on 2 December 2013. TW provided minutes of the meeting to representatives of Glendola Leisure on 30 January 2014 and again on 24 February 2014.

Response

1.5.2 Glendola Leisure comments principally relate to the Non-statutory Off-site Mitigation and Compensation Policy (Doc ref: APP 68), which was issued on 13 January 2014. We shall respond to each point in the order shown in the representation.

Paragraph 2.3.2

1.5.3 Glendola Leisure comment: “The ICP should include accountant/business consultants so as to ensure impartial advice on loss of profits etc.”

1.5.4 TW response: We have now added „Accountants and Business Advisers‟ to the list of expertise that will be available to the Independent Compensation Panel within the Non-statutory Off-site Mitigation and Compensation Policy submitted to PINS on 3 March 2014 (Doc ref: APP 186).

Paragraph 5.1.10

1.5.5 Glendola Leisure comment: “This paragraph specifies that only permanent dwelling accommodation is acceptable for compensation in the event of a trigger being implemented. The applicant appreciates that the works put impact on the living and sleeping accommodation provided for staff on the upper floors of the Star and Garter property and we look forward to receiving confirmation that such accommodation does fall within the permanent dwelling accommodation category and therefore benefits from the site mitigation and compensation packages.”

1.5.6 TW response: In the latest Non-statutory Off-site Mitigation and Compensation Policy (Doc ref: APP133) published on 12 February 2014, Appendix A, which is the schedule of TAPs, includes at Putney Embankment Foreshore, „Star & Garter Public House staff accommodation (façade facing the embankment)‟. It is therefore confirmed that the Star & Garter Public House staff accommodation is covered by the policy.

http://infrastructure.planningportal.gov.uk/wp-content/ipc/uploads/projects/WW010001/2.%20Post-Submission/Representations/Comments/Written%20Representations/131202_WW010001_Thames%20Water%20response%20to%20written%20representations.pdf

http://infrastructure.planningportal.gov.uk/wp-content/ipc/uploads/projects/WW010001/2.%20Post-Submission/Representations/ExA%20Questions/13-01-2014%20-%20Responses%20to%20Exa%20Questions%20Round%202/APP68%20Non%20Statutory%20Off-site%20Mitigation%20and%20Compensation%20Policy%20(DRAFT).pdf

http://infrastructure.planningportal.gov.uk/wp-content/ipc/uploads/projects/WW010001/2.%20Post-Submission/Representations/ExA%20Questions/13-01-2014%20-%20Responses%20to%20Exa%20Questions%20Round%202/APP68%20Non%20Statutory%20Off-site%20Mitigation%20and%20Compensation%20Policy%20(DRAFT).pdf

http://infrastructure.planningportal.gov.uk/wp-content/ipc/uploads/projects/WW010001/2.%20Post-Submission/Representations/12-02-2014%20-%20TWUL%20Submission%20of%2012%20Feb%202014%20inc.%20draft%20DCO/APP133%20Non-statutory%20Off-site%20Mitigation%20and%20Compensation%20Policy.pdf

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Paragraph 6.2.1

1.5.7 Glendola Leisure comment: “We note that in the event of double glazing or other insulation measures being required then the owner of the building is required to obtain three quotations with a fourth being obtained by the Authority. We look forward to receiving confirmation that all costs arising out of this activity and the professional advice that is needed will be covered under the compensation package.”

1.5.8 TW response: Please refer to paragraph 5.3.4 in the Non-statutory Off-site Mitigation and Compensation Policy (Doc ref: APP133) which states: “The Undertaker shall reimburse reasonable fees and costs incurred by the applicant to obtain the three quotations in para 5.2.1b. This will be due with payment of any discretionary grant or when the undertaker requests a contractor to implement the work.” Therefore, it is confirmed that the costs outlined in para. 1.5.7, above, are covered.

Paragraphs 8.2 and 8.3

1.5.9 Glendola Leisure comment: “Confirmation is required that staff residential accommodation is covered by this policy.”

1.5.10 TW response: We can confirm that, as per para. 1.5.6, above, the Star & Garter Public House staff accommodation is covered by the policy.

Paragraph 9.2

1.5.11 Glendola Leisure comment: “The extent of damage which may be caused to my client‟s property due to vibration needs to be established such that any claim made under the policy can be verified. We suggest that this will require a survey of existing condition in the form of a written schedule and photographic record which can be checked upon completion of the works and any damage clearly established.”

1.5.12 TW response: The detail in terms of a schedule of condition and photographic records can be set out and agreed in the TAP prior to the commencement of works. In the event the parties do not agree such methodology for survey, the matter will be referred to the ICP.

Appendix A

1.5.13 Glendola Leisure comment: “This schedule does not include the Star and Garter building. We assume that the building needs to be included to fall within the special mitigation and compensation policies.”

1.5.14 TW response: The updated version of the policy submitted on 12 February 2014 to PINS (Doc ref: APP133) confirms the Star & Garter Public House staff accommodation is covered.

Appendix B

1.5.15 Glendola Leisure comment: “This appendix states that non-residential buildings are excluded and again we need to clarify that staff accommodation within a residential building is accepted.”

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1.5.16 TW response: As per para. 1.5.14, above, the Star & Garter Public House staff accommodation is now included in the updated version of the Non-statutory Off-site Mitigation and Compensation Policy (Doc ref: APP133).

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1.6 Thames Water response to London Borough of Hammersmith and Fulham

Response to London Borough of Hammersmith and Fulham (LBHF) submissions of 3 and 12 February 2014 and ExA written question 56.1

1.6.1 This document provides a response to LBHF‟s submissions to the ExA on 3 and 12 February 2014, as well as the ExA‟s written question 56.1(b), which states:

“The ExA understands that the LB Hammersmith and Fulham does not consider the Applicant‟s illustrative proposals to provide 53 dwellings at Whiffin Wharf to be feasible in planning terms.

“b) Can the Applicant provide a further assessment of the future housing capacity of the site having regard to the comments made by the LB Hammersmith and Fulham?”

1.6.2 A response to written question 56.1 is also included separately in the 3 March submission to ExA under Doc ref: APP 166.

Impact on housing sites in LBHF

1.6.3 In its submission on 3 February 2014, at para. 1.2, LBHF states the following:

“The Further Alterations to the London Plan published on 15 January propose that H&F‟s housing target is increased from 615 additional dwellings pa to 1031dwellings pa. and a minimum 10 year target of 10,312 additional dwellings between 2015 to 2025.

“Thames Tunnel construction sites will significantly impact on housing sites in H&F during this ten year period.”

1.6.4 Para. 1.11 of the LBHF submission contains a table outlining the delay in housing delivery on sites which LBHF anticipates as a result of the proposed project works. TW has already responded with regards to impacts of development at Whiffin Wharf, Hurlingham Wharf and Carnwath Road Industrial Estate in response to first written question 14.24, within our response to LBHF‟s written representations of 4 November 2013 (Doc ref: APP31.01, submitted 2 December 2013) and in Section 2.4 of our written summary of the issue specific hearing held on 22 January 2014 (Doc ref: APP102.03). This response supplements those earlier responses.

1.6.5 This response uses a number of LBHF published documents to evidence Thames Water‟s position on the matters raised. The three key documents used are:

a. Strategic Housing Land Availability Assessment (SHLAA), published October 2010 (covering the period 2012 to 2032)

b. Five Year Housing Supply (2012/13 to 2016/17), published August 2012 (covering the period 2012/13 to 2016/17)

http://infrastructure.planningportal.gov.uk/wp-content/ipc/uploads/projects/WW010001/2.%20Post-Submission/Representations/Comments/Other%20Comments/APP31.01%20TW%20Response%20to%20issue%20specific%20hearing%20and%20written%20representations%20Part%201.pdf


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c. Annual Monitoring Report 2011/12, published January 2013 (covering the financial year 2011/2012 although includes housing trajectory up to 2032).

1.6.6 Each document covers a different time period (as identified above), therefore, it has been necessary to use them together in order to provide an overall view of housing supply and demand within the borough.

Short-term housing supply

1.6.7 Core Strategy policy H1 states that, borough-wide, LBHF will seek to deliver at least 615 additional dwellings per year up to 2021 and will continue to seek at least 615 additional dwellings per year in the period up to 2032. Policy H1 sets the following indicative housing targets for the South Fulham Riverside (SFR) regeneration area.

Table 1.1 Core Strategy Policy H1 SFR Housing Delivery Targets

2012/17 2017/22 Total 10

years 2022/27 2027/32

Total 20 years

SFR 800 800 1,600 400 200 2,200

1.6.8 Hammersmith and Fulham published their Five Year Housing Supply (2012/13 to 2016/17) paper in August 2012. The paper states, at para. 3.1, that there is “demonstrable five-year housing supply in Hammersmith and Fulham with a minimum of 5,830 new build dwellings expected to be delivered over the 2012-17 period”. It goes on to state, at para. 3.2, that “this is equivalent to a minimum annual average of 1,166 dwellings per annum, well above the 615 annual average required by the London plan”.

1.6.9 Table 2 (on page 4) of the Five Year Housing Supply document identifies the „Five-year housing supply, list of all sites‟. Carnwath Road Business Centre (as it is known in the SHLAA), Hurlingham Wharf and Whiffin Wharf are not identified within this document as sites that will come through within this period. However, the plan still shows the borough comfortably exceeding the 615 additional new homes target set by the GLA (as set out in Table 1 of the document).

1.6.10 Table 1 in the Five Year Housing Supply document identifies that, within the SFR regeneration area, the minimum expected supply up to 2016/17 is 1,352 additional homes and the maximum is 1,517. This suggests that the ten-year target (up to 2022) of 1,600 additional homes (as set by policy H1 of the Core Strategy) within the SFR regeneration area will be comfortably met.

1.6.11 Tables 1.2 and 1.3 below summarise data from the Five Year Housing Supply Report and compare these with the London Plan housing targets, including the revised targets set out in the draft Further Alterations to the London Plan. These confirm that there is suitable housing supply coming forward without the need for the sites associated with the project.

Question: 58.1


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Table 1.2 London Plan 2011: Housing targets for LBHF

12/13 13/14 14/15 15/16 16/17 Total

London Plan 2011 615 615 615 615 615 3075

Five Year Housing Supply 1,235 997 1,728 1,462 1,324 6746

Surplus/Deficit +620 +382 +1113 +847 +709 +3671

Table 1.3 Draft further alterations to the London Plan (2014): Housing targets for LBHF

12/13 13/14 14/15 15/16 16/17 Total

London Plan 2014

1,031 1,031 1,031 1,031 1,031 5155

Five Year Housing Supply

1,235 997 1,728 1,462 1,324 6746

Surplus/Deficit +204 -34 +697 +431 +293 +1591

1.6.12 Moreover, the list of sites within the South Fulham Riverside (SFR) regeneration area in the Five Year Housing Supply document does not include a number of development sites identified in the SHLAA (Figure 2, page 18) as coming forward before 2022 (we have not included the sites relating to Carnwath Road Riverside or safeguarded wharves in this table as it is anticipated they would be delivered post-2022). All remaining sites are identified below, alongside the number of units they may provide (figures from the SHLAA).

Table 1.4 SFR additional housing delivery up to 2022 (source SHLAA)

Site Period coming forward Number of units

Townmead Road electricity substation

2017-22 48

Townmead Road Business Centre

2017-22 59

Currys and PC World 2017-22 65

Enterprise Centre and Hurlingham Business Park

2017-22 50

74-86 Carnwath Road 2017-22 40

Imperial Wharf (less units identified in Five Year Housing Supply)

2012-22 884

Albert Wharf 2017-22 50

Total 1,196

Question: 58.1


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1.6.13 The SHLAA is therefore clear that there is ample supply to deliver the 1,600 units required in the first ten years of the Core Strategy period. Indeed, if all the units in the table above were delivered and the Five Year Housing Supply is accurate, by 2022, in excess of 2,200 additional homes will have been delivered in SFR alone without any of the sites required by the project coming forward.

1.6.14 In terms of recent data, the Annual Monitoring Report (AMR) (at page 33) states that: “overall, 511 additional homes were built in 2011/12. This compared to 446 in 2010/11 and 871 in 2009/10.” In addition: “5,741 homes were permitted in 2011/12 a significant increase compared to last year‟s figure of 520 additional homes and to the average of 745 homes approved over the last five years.”

1.6.15 Based on the analysis set out above, there is no evidence to suggest that the project will have, or has had, any impact on short-term housing supply. On the contrary, current supply comfortably exceeds forecast demand.

Longer term housing supply

1.6.16 The AMR, published in March 2013, states that forthcoming land for housing appears to be in good supply. The AMR states that (at page 33) “between 2011/12 and 2020/21, the sites identified could provide 11,033 additional dwellings. This compares to the 5,640 dwellings target from the LP [London Plan] over the same period. This also meets the NPPF‟s requirement looking to identify an additional buffer of 5% [as set out at para. 47].”

1.6.17 The AMR provides the housing trajectory for the borough up to 2032 at Table 9 of the document. This shows the borough comfortably exceeding 1,000 additional dwellings per year up to 2022/23, when the supply is expected to drop to 962 new dwellings per year until 2026/27. The trajectory shows a supply of 697 new dwellings per year 2027/28 to 2031/32. These figures do not include the uplifted expected housing delivery for the Earls Court and West Kensington Opportunity Area as included in the updated London Plan.

Table 1.5 SFR Housing Delivery: 2022 – 2032 (source SHLAA)

Site Period coming forward Number of units

National Grid Land, Imperial Road

2022/27 500

National Grid Land, Imperial Road

2027-32 500

Sullivan Enterprise Centre and Hurlingham Business Park

2022/27 50

Bagley‟s Depot and Adjoining Land

2022/27 290

Total 1,340

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1.6.18 The table above indicates the sites identified in the SHLAA as coming forward between 2022 and 2032. The table does not include Currys and PC World (as this is now expected to be delivered by 2017), nor does it include the sites delayed as a result of project works at Carnwath Road Riverside. The Core Strategy indicative housing delivery target for the SFR regeneration area from 2022 to 2032 is 600 additional homes (as set out in Policy H1). The SHLAA clearly suggests that more than double the target figure identified in policy H1 may be delivered within the SFR regeneration area, even without the use of the sites delayed by Carnwath Road Riverside. TW considers, therefore, that there are no implications in terms of housing delivery against the indicative targets set in policy H1 of the Core Strategy either before, during or after construction of the project.

Further Alterations to the London Plan

1.6.19 The Further Alterations to the London Plan, published on 15 January 2014, propose that LBHF‟s housing target is increased from 615 additional dwellings per annum to 1,031 dwellings per annum, and a minimum ten-year target of 10,312 additional dwellings between 2015 and 2025. However, whereas previously the Earls Court and West Kensington opportunity area had not been included in the housing target of 615 dwellings per annum (Table 3.1 of the London Plan 2011), the note has now been removed from the updated Table 3.1 and therefore the housing provision in the opportunity area may now be included in the overall housing target for LBHF, which significantly increases the total housing delivery.

1.6.20 Annex 1 to the updated draft London Plan 2014 identifies that 7,500 new homes is the minimum delivery target for the Earls Court and West Kensington opportunity area. This has been raised from 4,000 in the London Plan 2011. Hammersmith and Fulham was allocated 2,900 homes within the opportunity area in 2011 (Policy H1 of the Core Strategy), which is 72.5 per cent of the total allocation. If this percentage is applied to the total number of dwellings to be delivered under the London Plan 2014 allocation, this would equate to 5,437 additional dwellings within LBHF.

1.6.21 The additional housing provision required in the draft further alterations to the London Plan (2014) is entirely accounted for by the inclusion of the updated Earls Court and West Kensington Opportunity Area. This is unrelated to any housing supply or demand issues related to SFR in a different part of the borough and therefore any delays to housing delivery arising from the project are not relevant.

Affordable Housing

1.6.22 In its submission of 3 February 2014, at para. 1.9, LBHF states that:

“In addition to the loss of up to 70 dwellings, there will be a significant delay in the completion of 541 dwellings, including 97 affordable dwellings at Carnwath Road Riverside and a further 92 dwellings including 27 affordable dwellings at the Hammersmith Pumping Station site.”

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1.6.23 Policy H2 of the Core Strategy seeks to ensure 40 per cent of all additional dwellings built between 2011 and 2021 will be affordable on sites with the capacity for ten or more self-contained dwellings. The AMR advises that LBHF is not meeting the current proposed targets and that, in 2010/11, 19 per cent of approved homes on sites of more than ten units were affordable. Indeed, the percentage of affordable homes calculated by LBHF for the Carnwath Road Riverside site is less than half of the 40 per cent target (18 per cent) set out in the Core Strategy. If the safeguarded Hurlingham Wharf site is removed from the total number of dwellings, the percentage of affordable housing to be delivered across the remainder of the site drops to just over 14 per cent.

1.6.24 Looking at the borough-wide picture, policy H1 of the Core Strategy targets 9,000 new homes to be delivered by 2022. If the 40 per cent target of affordable housing is met across the borough, that would result in 3,600 affordable homes being delivered by 2022. The delay of the sites at Carnwath Road Riverside (not including the safeguarded Hurlingham wharf) therefore account for just over 1.5 per cent of the total number of affordable dwellings across the borough up to 2022.

1.6.25 TW acknowledges the delay in bringing forward the dwellings which have been recommended for approval across the Carnwath Road Riverside site. However, while the delay to the delivery of affordable housing is regrettable, it amounts to only a very small percentage of the overall target supply for the borough. Furthermore, as demonstrated above, there is sufficient land expected to come forward to meet the Core Strategy housing delivery targets, both within the SFR regeneration area and borough-wide, and it is not unreasonable to expect other housing developments coming forward across the borough, in advance of those delayed by reason of the project works, to deliver affordable housing in line with the requirements of policy H2.

Delivery of housing on Sullivan Road/Carnwath Road

1.6.26 In terms of the delays to the St James site at 26 Sullivan Road and 92-116 Carnwath Road, TW considers there is no justification for LBHF to attribute this delay to the construction of the project. Indeed, no evidence to support this has been presented other than a LBHF Select Committee report from January 2013, which states: “Planning permission and S106 agreement on the Baltic Sawmills site, 92-116 Carnwath Rd and 26 Sulivan Rd agreed the payment of £5 million as the physical and social infrastructure contribution for a development of 149 dwellings. 13 dwellings are under construction and that has triggered the payment of £1 million. The remaining £4million contribution is delayed until after a decision is made on TTT and/or its completion. Most of this £4 m was to be allocated to transport improvements.”

1.6.27 The site in question lies over 60 metres away from the western boundary of the project site (to the eastern boundary of the Baltic Sawmills site). Project vehicles would not pass the site and the Environmental Statement does not recognise any significant noise impacts at the site. TW believes that there is no evidence to any delay of implementation at this site due to the construction of the project.

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1.6.28 With regards to Hammersmith Pumping Station, TW has engaged with the developer (St George Central London Ltd) and the interface of the phasing of the Fulham Reach site and TW works has been agreed between the two parties, as in the signed confidential agreement between TW and St George Central London Ltd. However, TW maintains that there is sufficient housing delivery elsewhere in the borough to meet required targets and, therefore, this is an unjustified criticism of the project.

Delivery of housing on safeguarded Hurlingham Wharf

1.6.29 Para. 1.10 of the LBHF rep states:

“TW maintain that there is no capacity for additional dwellings on Hurlingham Wharf because it is designated a safeguarded wharf. H&F in their consideration of the planning application for Hurlingham Wharf demonstrated that this wharf is no longer viable or capable of being made viable for waterborne freight handling, apart from its use as Thames Tunnel construction site (Response to Inspectors Question 9.4) and section below. Therefore the Thames Tunnel proposals are delaying the regeneration and the completion of housing on Hurlingham Wharf.”

1.6.30 LBHF reiterates this position in its submission to the ExA dated 12 February 2014.

1.6.31 TW‟s position is consistent with current London Plan policy 7.26 (Increasing the use of the Blue Ribbon Network for Freight Transport) and the GLA safeguarded wharves review recommendation to the Secretary of State, in which the safeguarding status is recommended to be retained. In addition, Kevin Reid of the GLA noted, in the issue specific hearing relating to the „rationale for the selection of work sites and drive strategies matters‟ on 11 November 2013, that there was a deficit of capacity against the future projections for the amount to cargo anticipated to be transported by river over the next 20 years in the west of London and that the GLA could not see legitimate scope for the proposed consolidation put forward by LBHF. TW therefore maintains that LBHF‟s position in this regard is unfounded.

Conclusions on housing delivery

1.6.32 There is no evidence to suggest that the project will have, or has had, any impact on short-term housing supply. On the contrary, current supply comfortably exceeds forecast demand.

1.6.33 The AMR confirms that forthcoming land for longer term housing needs is in good supply. Between 2011/12 and 2020/21, the sites identified could provide 11,033 additional dwellings across the borough, compared to the 5,640 dwellings target from the London Plan.

1.6.34 The housing trajectory for the borough up to 2032 shows the borough comfortably exceeding 1,000 additional dwellings per year up to 2022/23, when the supply is expected to drop to 962 new dwellings per year until 2026/27, not including the uplifted expected housing delivery for the Earls Court and West Kensington Opportunity Area included in the updated London Plan.

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1.6.35 There is no evidence to support assertions of delay to the delivery of housing on Sullivan Road/Carnwath Road or Hurlingham Wharf. These sites are either unconnected to the project or unsuitable for housing.

1.6.36 TW acknowledges there would be a delay in bringing forward affordable housing at Carnwath Road, which is regrettable. However, it would amount to only a very small percentage (1.5 per cent) of the overall target supply for the borough. Furthermore, there is sufficient land expected to come forward to meet the Core Strategy housing delivery targets, both within the SFR regeneration area and borough-wide, and it is not unreasonable to expect these to deliver affordable housing in line with the requirements of policy H2.

Whiffin Wharf feasibility

1.6.37 In its submission of 3 February 2014, at para. 1.2, LBHF makes a number of comments relating to the TW feasibility study (submitted as Appendix 1 to our submission on 4 December, Doc ref: 31.01). These comments are recognised by the ExA and noted in the explanatory text for question 56.1 where it states: “The ExA understands that the LB Hammersmith and Fulham does not consider the Applicant‟s illustrative proposals to provide 53 dwellings at Whiffin Wharf to be feasible in planning terms. The ExA then asks (question 56.1 (b)): “Can the Applicant provide a further assessment of the future housing capacity of the site having regard to the comments made by the LB Hammersmith and Fulham?”.

1.6.38 In response to written question 56.1 (b), we have revised our Option 3 proposals, taking into account LBHF‟s comments. This has resulted in Option 3A, which is included in Figure 1.1 Option 3A Whiffin Wharf Feasibility Study below, with the updated policy design brief table for Whiffin Wharf included at Figure 1.2 Whiffin Wharf Policy Design BriefError! Reference source not found.. Please note that a response to written question 56.1 (b) is also included separately in the 3 March submission to the ExA (Doc ref: APP 166).

1.6.39 The proposed units at ground floor are 21m away from 81-87 Carnwath Road and 6m from 89-101 Carnwath Road. Option 3A shows the western elevation of the proposed block stepping back above third-floor level by between 3m on the river frontage and 9m on Carnwath Road.

1.6.40 The height of the building increases towards the river frontage and the eastern edge of the site, in accordance with guidance outlined Chapter 9 of the SFR SPD (see paras. 1.6.47 and 1.6.48 below).

1.6.41 We have also reconfigured the units in the northern wing to ensure that there are no north-facing single aspect flats in accordance with Standard 5.2.1 of the London Plan Interim Design Guide. This was achieved by using a scissor section to flats in this wing.

1.6.42 These amendments to Option 3 were made with the loss of two residential units (from 53 to 51), and show that there is flexibility in the site to develop alternative arrangements and respond to LBHF comments. Therefore, TW remains confident that it is technically feasible to comfortably exceed the number of dwellings identified as being deliverable on the site in the LBHF


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SHLAA (33 dwellings). The SHLAA figure then informed the housing supply targets for the SFR regeneration area.

The TW response to LBHF‟s more detailed comments is outlined in the following section.

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Figure 1.1 Option 3A Whiffin Wharf Feasibility Study

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Figure 1.2 Whiffin Wharf Policy Design Brief

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Two-storey basement and impact on commercial viability

1.6.43 While the commercial viability of the two-storey basement would be subject to more detailed analysis, TW considers it a fair assumption that riverside properties such as those proposed here are highly desirable in the current market, particularly when associated with a high-quality design and ample amenity space. The market value of the most desirable units is considered, at this early stage, to be able to offset the costs associated with the basement car park and affordable housing provision. Therefore, we do not agree that the viability of the site will be completely blighted by the proposed shaft and associated structures.

1.6.44 Thames Water note that the two-storey basement structures shown in our study options would be only marginally deeper than the one shown in the 2912/02047/FUL scheme, which is 1.5 storeys deep to incorporate a „Lower Ground Floor‟, for which LBHF has recommended approval. Further, parking provision in the TW feasibility study is based on the more onerous requirements stated in the London Plan (see para. 1.6.45 below), rather than emulating what is provided in the 2912/02047/FUL scheme (0.61 spaces per unit).

1.6.45 The London Plan parking standards referred to above are as follows:

a. Four or more bedrooms: 1.5 to 2 car park spaces per unit

b. Three bedrooms: 1 to 1.5 car spaces per unit

c. One to two bedrooms: Less than one car park space per unit.

1.6.46 The extent of the basement may be reduced if we could agree a similar level of provision with the local authority.

Building height

1.6.47 As regards the storey height to the north and west of the site, we would note once again that, because the lowest storey in the 2012/02047/FUL scheme is an „Upper Ground Floor‟, this would in fact be 4.5 storeys tall, not the four storeys stated in paragraph 1.4. TW‟s designs shown in the feasibility study are fully compatible with the urban design guidance outlined Chapter 9 of the SFR SPD. It states that: “West of Wandsworth Bridge, building heights would generally be appropriate at 4 to 7 storeys. Additional height could be accommodated in specific places, but should not exceed 10 storeys”. The guidance goes on to advise that, with regards to Carnwath Road: “All new developments should respect the residential scale of buildings to the north of the framework area with a “stepped massing” to building heights, which have the potential to increase as they move away from the domestic scale of the existing housing towards the riverfront where the buildings would need to be of a scale which gives appropriate definition and presence to the riverside.”

1.6.48 Options 1 and 2 already set back on the northern edge at four storeys to mediate the change in building height to the lower buildings here and the taller buildings anticipated to the east. Further setbacks could be included in the whole western edge without great loss to the number of units and without compromising with amenity of adjacent property. For example, in

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Option 2, a setback along the entire western edge could be achieved with the omission of just two residential units.

Distance from ventilation column

1.6.49 As regards the distance of the development from the ventilation column, we assume that the 30m figure stated in para. 1.6 is derived from the Environmental Statement in relation to odour and the proximity of the ventilation column to existing dwellings. This figure relates to the parameters that were assessed; it does not represent the required offset of the column from residential properties. As regards the extent of the required offset, TW‟s own guidance (which exceeds the standards required by Part H of the building regulations) states that naturally convective sewer ventilation columns should be: “sited no closer than 6m from openable windows or air intakes to buildings. Furthermore such vent columns should terminate at least 1.8m above any windows within 12m.” This represents the worst case as the active ventilation plant at Carnwath Road Riverside will generally disperse exhausted air more effectively than a naturally convective vent. The windows of the all the proposed options show the building between 23m and 24m from the proposed ventilation column and would therefore sit well outside the required 12m zone stipulated by guidance. It is important to recognise the level of detail provided in the feasibility study and acknowledge the limitations that come with such a high-level study of a site. All of the matters raised above would normally be subject to detailed and constructive discussions between the local planning authority and the developer, as it is frequently possible, with exemplary design and appropriate S106 contributions, to develop proposals that balance the needs of the development with the constraints of the site.

Outstanding issues – noise and vibration

1.6.50 Responses are given below to points where questions are raised by LBHF in Section 3 of its 3 February submission to the ExA.

Point 3.5 Night-time noise affecting residents at Carnwath Road

1.6.51 LBHF notes that noise will be noticeable to residents at Carnwath Road during the night, even if it is not assessed as significant. As part of the embedded mitigation, all practicable measures have been assumed to minimise noise. At receptors other than 89-101 Carnwath Road and 5 Carnwath Road, the construction noise levels would be below the ambient noise. TW has committed (Doc refs: APP111 and APP186) to provide off-site mitigation for 89-101 Carnwath Road and 5 Carnwath Road and that this mitigation will take full account of the vulnerable persons identified by the housing association responsible for 89-101 Carnwath Road. The Legal Agreement for Securing Noise Mitigation and Compensation Policies will be secured (Doc ref: APP182) contains an obligation to include in the TAP for that property provision of acrylic acoustic screens on the river wall outside in order to reduce the effect of night-time barging noise. Provision of the acrylic acoustic screens will be subject to obtaining necessary statutory and other consents. The precise

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details of the mitigation will be determined and agreed with the property occupiers under the TAP. TW will consult with LB Hammersmith and Fulham in preparing the TAP (Doc ref: APP186).

Point 3.6 Significant effects due to piling at Lancaster House, Barn Elms

1.6.52 LBHF has questioned whether push piling methods have been considered to minimise noise effects at Lancaster House.

1.6.53 This was considered. In this case, it is not possible to adopt sheet piling for these works (as recorded in the Environmental Statement update report (Doc ref: APP. 184.01) and push piling methods are not applicable therefore in this case. For the purpose of the assessment, a worst-case assumption of vibratory piling was therefore made.

1.6.54 The significant effects at Lancaster House due to piling are therefore reported in the Environmental Statement update report.

Point 3.8a Traffic movements for drive site – necessity for night-time movements

1.6.55 Although there are no night-time traffic movements associated with the CSO scheme proposed for Barn Elms, it is necessary to operate 24-hour traffic movements for the drive site scenario.

1.6.56 As a drive site, Barn Elms would cause significant noise effects due to construction river traffic at Stockhurst Close and due to construction road traffic at Queen Elizabeth Walk. This is described in Appendix B of Doc ref: APP31.01 and as confirmed in oral submissions (Doc ref: APP102.03).

Point 3.8b River traffic noise at Stockhurst Close, Barn Elms (drive site) as compared with effects at Carnwath Road

1.6.57 At Carnwath Road, it was possible to reduce noise impacts from river traffic by proposals to erect screening on the river wall (subject to planning permission and landowner agreement). These properties (5 and 89-101 Carnwath Road) are relatively close to the river. Given the distance of the properties on Stockhurst Close from the river and the resulting screening attenuation possible, significant effects would still arise. It was therefore not considered that there would be a worthwhile benefit from screening to reduce the significant noise effects.

1.6.58 We have looked at the possibility of attaching a screen to the river wall at Barn Elms; however, we can confirm that it is not practicable to avoid the significant effect outlined in in para. 1.6.56, above.

Point 3.9 Combined construction and indirect effects from road/river traffic at Barn Elms

1.6.59 As noted in the response to ExA question 29.01, the combination of the road or river traffic noise increase and calculated construction noise have been analysed for worst-case periods of construction noise and periods of peak construction traffic flows. In the response to question 29.01 (Doc ref: APP56), those sites where worst-case construction noise and traffic noise



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would coincide are identified, as were those sites where they were not coincident for peak construction noise and peak traffic noise. The periods of worst-case construction noise were not generally found to coincide with the period of peak traffic flows.

1.6.60 In the case of the consideration of combined direct and indirect effects for Barn Elms, the worst-case construction noise and traffic noise are not coincident, and hence our response to question 29.01 (Doc ref: APP56). It was assessed that there is no potential for traffic noise to combine with construction noise.

Point 3.10 Number of noise sensitive properties at on Queen Elizabeth Walk

1.6.61 The six households identified in the response to ExA question 32.27 (Doc ref: APP59) is correct.

Thames Water’s response to CDM Smith’s memorandum dated 3 February 2014

1.6.62 CDM Smith‟s memorandum responds to TW‟s Written summary of cases put orally at the hearings held on 22 January 2014 (Doc ref: APP102.03). We made ten points against CDM Smith‟s Alternative A, and CDM Smith has responded using six headings in its memorandum dated 3 February 2014. We do not agree with CDM Smith‟s conclusion, for reasons given previously, and respond to the six points raised in the latest memorandum as follows.

Vertical tunnel profile (CDM Smith point A)

1.6.63 TW‟s vertical tunnel profile includes a step in the invert level of the tunnel within the Carnwath Road Riverside shaft to provide what we consider to be the minimum acceptable clearance to existing and planned tunnels, while ensuring our hydraulic design criteria are fulfilled.

1.6.64 Alternative A would reduce the clearance to these other tunnels, below that agreed with the respective asset owners, and would not meet our hydraulic design criteria.

Hydraulic design

1.6.65 TW has provided the London Borough of Hammersmith and Fulham with a Technical Advice Note, Doc ref: 100-TN-XXX-CARRR-000001-AA, Hydraulic Assessment of the CDM Smith „Alternative A‟ proposal, to explain why the CDM Smith Alternative A does not meet our basic hydraulic design criteria. A copy of that Technical Advice Note is included in Appendix B.

Clearance to other tunnels

1.6.66 With respect to the clearance to other tunnels, CDM Smith suggests that the separation should be reduced and cites three examples of other crossings in London to give precedents for their alternative.

1.6.67 One of these is the Crossrail crossing of the Ham sewer, which had a separation of 0.5m. We do not consider this to be a relevant comparison,

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primarily because the two water tunnels that the project will cross are operational pressurised water tunnels, while the Ham sewer is not pressurised. Furthermore, both the TW ring main and the Lee Raw Water Tunnel are critical pieces of infrastructure required in delivering water to large proportions of London. Any unplanned interruption to either of these two assets may have significant ramifications for meeting the water supply demands of the capital.

1.6.68 In order to check that our assertions about tunnel separation are valid, we have asked Dr Barry New, from the Geotechnical Consulting Group, to independently review the proposed crossings and to compare these to the crossing of the Ham sewer. Dr New‟s report is provided in Appendix C. Dr New concludes that the Ham sewer crossing is not a relevant precedent for the Thames Tideway Tunnel. In his report, Dr New mentions the fact that the existing tunnels will be operational and pressurised when the main tunnel passes over the top. The following statement from TW explains the critical nature of the existing tunnels, the restrictions on access and why we cannot assume that the existing tunnels will be depressurised:

“The Lee Valley Raw Water Tunnel and the Thames Water Ring Main are major strategic water supply assets, whose operation is critical to Thames Water‟s ability to meet its regulatory duty to supply potable water to its customers. The tunnels are only taken out of service about once every ten years for inspection and maintenance/ repair, except in emergencies. The tunnels cannot be taken out of service unless adequate alternative measures are in place to ensure uninterrupted water service to customers. In the case of the Lee Valley Raw Water Tunnel, this means that it can only be taken out of service when fluvial flows in the River Lea are adequate in quantity and quality, which only occurs October to December, the Lea Valley reservoirs are adequately full and there are no other major assets out of service or under maintenance. In the case of the Thames Water Ring Main, an outage can only occur at one location at a time (so that all abstraction shafts can be supplied without interruption). Outages of major assets such as these tunnels is planned well in advance to take into account planned maintenance, other work throughout the water network, and prospective high demands (such as the Olympics), and can be cancelled at very short notice should operational contingencies (such as droughts, surface water pollution incidents, emergency works being needed on related assets, or equipment faults) arise. Strengthening works are not emergency works, and so can only be undertaken during tunnel outages for planned maintenance.”

Tunnelling volume loss

1.6.69 CDM Smith suggests that we have used an unnecessarily conservative volume loss assumption when predicting the potential impacts of other assets and says that is it is not unusual to specify tighter tolerances.

1.6.70 We do not agree that our assumption for prediction of impacts is inappropriate at this stage of project design, although we do accept it would be possible to specify a lower target for construction purposes.

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Specifying a lower ground loss volume than that used to predict impacts is sometimes used to introduce an additional factor of safety.

1.6.71 We do not think that it is appropriate, or indeed normal, to base the prediction of impacts on lower volume losses than we have at this stage of project design and planning before the contractors have been appointed and final construction methods have been selected. We believe our approach meets normal industry standards.

Tunnel secondary lining (CDM Smith point B)

1.6.72 For reasons previously explained in Doc ref: APP102.3, we strongly maintain that the secondary lining is required to satisfy the main tunnel operating conditions, including cyclic hydraulic loading, over a design life of 120 years. We maintain that the omission of the secondary lining would not be a sensible solution and would not meet the structural integrity, permeability or durability requirements over the 120-year period.

1.6.73 We do not expect the primary and secondary linings to be structurally connected but if the future detailed designer were to propose a mechanism for connecting the two linings, that would have to be explained and justified at the time.

Spacing of access points (CDM Smith point C)

1.6.74 We have explained our approach to the provision of safe access during maintenance of the tunnels within Doc ref: APP31.01, Response to issue specific hearing and written representations to CRR, Alternative Drive Strategy and Putney Embankment Foreshore, Section 5 Alternative Drive Strategy, Doc ref: APP59, Rationale for the Selection of Works Sites and Drive Strategies, response to Question 32.1, and Doc ref: APP102.03, Written summaries of the cases put orally at the hearing dated 22 January 2014. These documents also explain why the offline CSO shafts would not provide acceptable safe access.

Tunnelling risks (CDM Smith point D)

1.6.75 CDM Smith‟s case for the long tunnel drive necessary for Alternative A seems to be that the risk of tunnel boring machine (TBM) failure is „very low‟ and that TBM main bearings are designed to last for more than enough time to complete the long drive from Kirtling Street to Acton Storm Tanks.

1.6.76 By comparison, we have sought to recognise and manage the risks that exist, including the probability of TBM failures including main bearing failures. We maintain the probability of failure increases as the tunnel length increases.

1.6.77 Both during examination hearings and in written representations, CDM Smith cited the Brightwater CSO Tunnel project as an example and states in its evidence that TBM failure risk has „a low probability of occurrence today‟. We note that this project experienced major technical problems during tunnelling due to the realisation of this „low risk‟ and required the launch of a rescue TBM.

http://infrastructure.planningportal.gov.uk/wp-content/ipc/uploads/projects/WW010001/2.%20Post-Submission/Representations/Comments/Local%20Impact%20Report/APP30.01%20Thames%20Water%20Response%20to%20London%20Borough%20of%20Hounslow%20Local%20Impact%20Report.pdf

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1.6.78 A further example of a tunnelling project where major technical issues occurred, namely a TBM main bearing failure, is that of the new highway tunnel in Seattle, America. Although we recognise that the Washington State Department of Transportation (WSDOT) highway tunnel in Seattle is significantly larger than those proposed for the main tunnel, that project does provide a timely reminder of the fact that TBM main bearings on modern machines do fail and that it is sometimes necessary to excavate a new shaft to fix the problem. The following is an extract from a news report posted by TunnelTalk on 11 February 20144:

“TBM Bertha has damage that will delay for "months" delivery of the 2.6km double-deck highway tunnel in Seattle, while repairs are carried out. Washington State Department of Transportation (WSDOT) has finally admitted its worst nightmare has come true - the seals that protect the main bearing of the world record 17.48m diameter Hitachi Zosen EPBM have been compromised. The announcement is made just days after the machine was restarted, advanced 2ft to complete the setting of a new ring of segmental lining, and then had to be shut down after the same high temperature sensor readings that caused the initial shutdown decision on December 6 were recorded again. In a four paragraph statement issued at 8.49pm yesterday (February 10), it is admitted that whichever of two solutions to gain access to the TBM's main bearing sealing system is attempted - either via an access shaft excavated from the surface, or through the back of the machine from inside - the net result will be the same. As WSDOT put it tersely: "Either way this process will take months.”

1.6.79 On the 14 February 2014, the Washington State Department of Transportation posted this note on its website5:

“Seattle Tunnel Partners (STP) informed WSDOT today that they expect to receive a plan on potential repairs to the SR 99 tunnelling machine from the machine‟s manufacturer Hitachi Zosen by the end of this month. This will include a schedule for how long the repair work would take. Earlier this week, STP told us the plan may be completed by the end of the week, but said today more time is needed for the Hitachi to prepare it. It appears likely that repairs will be made by digging a shaft from the surface so the machine can be entered from the front. Entering the back of the machine would require removal of more equipment and likely take longer. STP will begin work next week on the design of the shaft so if that option is selected, some of the necessary work will already be underway. We will post additional information as we receive it from STP.”

1.6.80 We maintain that the drive strategy of the project, and the inclusion of a drive shaft at Carnwath Road Riverside, reduces the risk of major TBM component failure.

4 http://tunneltalk.com/Seattle-11Feb2014-TBM-Bertha-main-bearing-seal-damaged.php 5 http://www.wsdot.wa.gov/Projects/Viaduct/

http://tunneltalk.com/Seattle-11Feb2014-TBM-Bertha-main-bearing-seal-damaged.php

http://www.wsdot.wa.gov/Projects/Viaduct/

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Risks, programme and impacts at Kirtling Street (CDM Smith points E and F)

1.6.81 We have said that Alternative A would increase the extent of work and impacts at Kirtling Street, and change the balance of procurement risks.

1.6.82 We have said that if the construction contract packaging were not amended, then the contract for building the central package would increase in value and would negatively affect our chosen procurement strategy. Even unchanged, we believe the central contract, with an estimated value of between £600 and £950 million, would be the biggest tunnelling project ever undertaken in the UK‟s water industry.

1.6.83 CDM Smith says it has looked at our published shortlist of contractors and concluded, without any access to the detailed pre-qualification submissions that these contractors have made, that many of them would „be able to handle‟ a much bigger job resulting from the addition of 7km of tunnelling.

1.6.84 We accept that some of the contractors on the shortlist are very big organisations and have historically completed large projects, but we are following a rigorous prequalification and tender process and need to be confident the successful contractors are capable of delivering this project. We have packaged the works contracts to help mitigate the delivery risks and we have shortlisted contractors with the right expertise and experience to complete the work.

Conclusions

1.6.85 We maintain that the Alternative A drive strategy proposed by CDM Smith is inferior to that we have proposed in our application for the following reasons:

a. The proposal reduces the clearance to existing tunnel infrastructure which is critical to maintaining London‟s water supply needs.

b. In the case of the National Grid Cable tunnel, it reduces the clearance to levels below that require by the asset owner.

c. It does not meet our criteria for an acceptable hydraulic solution and would lead to changes in the air management proposals.

d. It exceeds the required spacing of operational access shafts and increases the levels of risk for maintenance personnel.

e. It increases the levels of construction risk due to the longer tunnel drive length between Kirtling Street and Acton Storm Tanks.

f. It would lead to increased works at other locations, including Kirtling Street, Dormay Street and King George‟s Park.

g. It would change and adversely affect our procurement strategy.

Question: 58.1


50

1.7 Thames Water response to London Borough of Lewisham

Introduction

1.7.1 This section addresses the matters LB Lewisham raised in its 12 February submission in response to the TW submission on 13 January 2014. This is in response to the ExA‟s request for further information, question 58.1.

Code of Construction Practice

Signage to open business premises

Para 2.3 LBL therefore considers that TW should install and maintain suitable signage directing pedestrians that access to Deptford High Street remains in place and that there is „business as usual‟.

Para 2.4 LBL has raised this issue with TW but a revision to the CoCP to achieve this has not been forthcoming.

Secured through project-wide Requirement PW11 (Signage for temporary footpath diversions)

Inclusion of the school in the proposed community liaison group

2.5 The CoCP Part B for the Deptford Church Street site (APP72.21) currently identifies St Paul's Church as a member of the community liaison group. LBL considers that St Joseph‟s RC Primary School, which is also adjacent to the worksite, should also be included in this group.

CoCP Part B for Deptford states that:

3.1.1 The contractor shall liaise with St Paul‟s Church to coordinate traffic movements to and from the site including:

a. limiting vehicle movements during funeral arrivals and departures

b. facilitating horse delivery lorries for horse-drawn hearses

c. completing Saturday works and traffic movements before 13:00.

3.1.2 The contractor shall provide a full-time community liaison person dedicated to the Deptford Church Street site. The liaison person shall provide a monthly report to the employer on all liaison activities.

3.1.3 In addition, there shall be a dedicated Project Officer specifically to maintain and enhance the ongoing and future spiritual and commercial use of the

Grade I listed St. Paul‟s Church. The role will commence approximately Deptford Church Street three months in advance of construction works beginning at this site, continuing throughout the construction works and for six months post completion.

We do not identify St Paul‟s Church as a member of the Community Liaison Group but the particulars of the Liaison Groups are identified in CoCP Part A, Section 3.1.6:

The participants, frequency and chair of the

Question: 58.1


51

meetings will be determined in liaison with the employer and the local authority.

Noise Monitoring

2.6 Real-time noise monitoring should be undertaken by TW at both Deptford Church Street and Earl Pumping Station at locations to be agreed with LBL. LBL has a web-based facility for accessing noise monitoring for major construction sites. Real-time noise monitoring at the sites selected should be compatible with this system.

2.7 In addition, LBL wishes the output of the monitoring to be compatible with its web based facility for presenting real-time noise data. This includes texting and emailing alerts where trigger values are exceeded.

2.8 In addition LBL requires that the CoCP stipulates that the contractor will also have an additional hand-held monitor available for routine noise surveys/checks around the site throughout the construction process.

2.9 LBL notes that similar measures have been included in the CoCP Part B for Cremone Wharf Depot and invite TW to apply this measure more broadly across the project.

Provisions for real-time noise monitoring are to be made through the Noise and Vibration Management Plan which is for the relevant planning authority‟s approval. The content of the Noise and Vibration Management Plan is detailed in CoCP Part A, Section 6.1.10 as such:

A minimum of three months before the commencement of relevant works a Noise and Vibration Management Plan shall be submitted for approval by the relevant planning authority. The noise and vibration management plan will be developed and implemented for each worksite and shall include:

a. an inventory and timetable of activities which may give rise to noise and vibration

b. alert system to be used (including notification process)

c. how and when information about noise and vibration will be communicated to local stakeholder‟s by cross-reference to the Community Liaison Plan

d. details of control measures to be included in Section 61 applications and draft timetable of applications (using the guidance at Appendix A of the CoCP)

e. details of noise and vibration monitoring arrangements, including the location of sensitive receptors, monitoring locations, monitoring durations, and monitoring equipment to be used

f. details of the noise and vibration reporting requirements

g. details of off-site mitigation to be brought forward (compliant with the Non statutory off-site mitigation and compensation policy)

Off-site mitigation

The indicative timetable for the TAPs to be in place set out in APP67 is concerning. This timetable indicates that TW does not expect TAPs to be completed until the end of August 2014. As this will be outside of the examination period LBL notes that the ExA will not have an opportunity to consider these important documents or take account of their contents in its recommendation to the Secretary of State.

The development of the TAPs requires engagement with the relevant property owners and occupiers, detailed surveys on site and design of potential options for consideration and agreement with the relevant owners. Given the work required for this purpose, it is impractical to complete the TAPs within the examination period.

Question: 58.1


52

Draft agreement with local authorities

1.7.2 LB Lewisham, in its submission, set out a number of comments on TW‟s draft legal agreement with the local authorities to secure the non-statutory mitigation and compensation policies.

1.7.3 The legal agreement was updated and reissued with the 3 March 2014 submission deliverables. Refer to document submission number APP182 for the updated version which reflects LB Lewisham‟s comments.

Question: 58.1


53

1.8 Thames Water response to written submission from the London Borough of Southwark

Introduction

1.8.1 This document provides a response to the written submission from the London Borough of Southwark (LB Southwark) submitted to the ExA on 3 February 2014. LB Southwark‟s 12 February 2014 submission is addressed in the Update to the Statement of Common Ground submitted on 3 March 2014.

1.8.2 This document responds to comments made by LB Southwark in relation to TW‟s responses to the second written questions and the summary of oral representations made at the DCO issue specific hearings. A response is provided where we believe it is necessary to provide further clarity or correct inaccuracies.

Response

Question 25 Development Consent Order drafting and related matters

1.8.3 LB Southwark provided comments on the responses to the second written questions relating to drafting of the Draft DCO and Code of Construction Practice. A response is provided below where an update is required.

a. Question 25.2 (Minor/Major Requirements): We further reviewed this and deleted the distinction between major and minor requirements. This change has been incorporated in the current drafting of the Draft DCO submitted with associated drafting notes on 3 March 2014 (Doc ref: APP177)

b. Question 25.4 (Code of Construction Practice – Practically Impossible): The term „impossible‟ is defined in the Code of Construction Practice glossary. The Code of Construction Practice Part B Chambers Wharf states that the anchor piles would be installed as far away from the closest residential receptor as practicable. Our position remains as detailed in our response to Q25.4.

c. Question 25.7 (Community liaison working group): The role of the community liaison working group is defined in the Section 106 unilateral undertaking dated 12 February 2014 which also includes agreeing projects for the Community Enhancement Fund also included in the Section 106.

d. Question 25.9 (Approval of Documents): We provided detailed comments in regards to approval of documents and details in the Update to Statement of Common Ground (Doc ref: APP159.05).

Question 32 Rationale for the selection of worksites and drive strategies

1.8.4 LB Southwark made a number of comments regarding our response to second written question 32.22. Further comments were provided in its summary of oral representations from the issue specific hearing held on

Question: 58.1


54

23 January 2014. The following sections seek to address these comments and provide clarification on identified issues.

Question 32.22 Abbey Mills Pumping Station as a drive site and Inefficiency of barging at Abbey Mills Pumping Station (Doc ref: APP59.22.03)

Efficiency comparison

1.8.5 We agree with the arithmetical error highlighted in LB Southwark‟s representation relating to the amount of material removed by road for the 200m/week tunnelling rate (see Doc ref: APP59.22.03, Figure A.1). This has, however, highlighted a further issue in the version submitted in the response (Doc ref: APP59.22.03) as the table reflected the resources required for a single Abbey Mills Pumping Station tug only. This underestimated the amount of resources required to operate a barge operation.

1.8.6 The marine operation to remove excavated material from Abbey Mills Pumping Station during the tunnelling phase would require a tug to operate for 14 shifts per week between the mouth of Bow Creek and Abbey Mills Pumping Station. The mainstream tug would operate five shifts in a week to remove six barges from the Bow Creek mouth area. In total there would be 14 x 4, plus a spare crew per tug. Therefore a single tug servicing Abbey Mills Pumping Station would require 60 man shifts. The mainstream tug requires 5 x 4 plus a spare crew equating to 24 man shifts. This totals 144 man shifts.

1.8.7 Table 1.6 below provides the updated figures and includes LB Southwark‟s assessment in red text and brackets. It should be clarified that the resources required relates to man shifts.

Qu

estion

: 5

8.1

Responses t

o r

equest fo

r in

form

ation

Q

58:

Oth

er

Matt

ers

55

Ta

ble

1.6

E

ffic

ien

cy c

om

pa

ris

on

Sit

e

Ma

teri

al

pro

du

cti

on

p

er

we

ek

Am

ou

nt

rem

ove

d b

y

rive

r

Am

ou

nt

rem

ove

d b

y

roa

d

Re

so

urc

e

req

uir

ed

HG

Vs

req

uir

ed

/ w

ee

k

HG

V d

rive

rs

To

tal

tra

nsp

ort

re

so

urc

e

t/m

an

sh

ift

80m

/we

ek

Ab

be

y M

ills

Pu

mp

ing

Sta

tion

9730t

8330t

1400t

84 1

44

(64)

88

29

113 1

73

(93)

86 5

6

(104

)

Ch

am

bers

W

harf

8757t

973t

30

61

20

50

194

200

m/w

eek

Ab

be

y M

ills

Pu

mp

ing

Sta

tion

24330t

8330t

18080

16000t

84 1

44

(64)

1130

1000

377

334

461 4

78

(398

)

58 5

1

(61)

Ch

am

bers

W

harf

21896

t 2433t

80

152

51

131

186

Note

: T

he r

ed f

igure

s in b

rackets

rela

te to L

B S

outh

wark

‟s a

ssessm

ent.

Question: 58.1


56

Heavy goods vehicle numbers at different tunnelling rates

1.8.8 In LB Southwark‟s summary of oral representations made at the Issue specific hearing (23 January 2014), the table on p. 21, sets out the council‟s view on the difference in numbers of heavy goods vehicles (HGVs) for the different tunnelling rates. The table contains errors and misunderstandings with regards to the HGV numbers quoted. There was also a numerical error in Doc ref: APP59.22.03 regarding the tonnage of excavated material moved by road which translated into an error in the number of HGVs at the peak rate.

1.8.9 Table 1.7 corrects the figures referenced within LB Southwark‟s submission and updates the figure in Doc ref: APP59.22.03. A brief explanation is provided regarding what each number represents, which is further defined in the following sections.

Table 1.7 HGV numbers at different tunnelling rates

Our response reference

Para. 22.2.12 Para. 22.2.14 Doc ref:

APP59.22.03

HGVs required per day 80m/week tunnelling rate

48 56 48 (1) 18

HGVs required per day 200m/week tunnelling rate

152 266 (1) 266 152 (1) 226 200 (2)

Description of figures

HGV numbers associated with tunnelling works – all materials

HGV numbers associated with tunnelling works – all materials.

The figure of 152 HGVs represents the average tunnelling rate for the all-by-road scenario, not the peak rate as stated in the LB Southwark representation.

HGV numbers associated with tunnelling works – excavated material only

1) Incorrect reference made in LB Southwark‟s written representation.

2) Correction for numerical error in Doc ref: APP59.22.03.

1.8.10 The figures provided in para. 22.2.12 and Doc ref: APP59.22.03 are based on the same data and are indicated graphically in Doc ref: APP59.22.02. The figures set out in para. 22.2.12 represent the number of all HGVs associated with tunnel construction. This includes estimated HGV numbers associated with the transportation to site of tunnel lining segments, tunnel boring machine consumables such as track and slurry pipe, construction plant, grout and other general site supplies as well as HGVs associated with the removal of excavated material.

Question: 58.1


57

Doc ref: APP59.22.03 specifically addressed the number of barges and HGVs associated with excavated material removal only.

1.8.11 The figures stated in para. 22.2.14 represent the number of HGVs required for tunnelling at the average drive rate only. The lower figure of 48 HGVs represents the „road and river‟ scenario and is consistent with the figures in para. 22.2.12. The higher figure of 152 represents the „all-by-road‟ scenario and is therefore not directly comparable with the figures provided in para. 22.2.12.

Transhipment

1.8.12 LB Southwark considers that transhipment would be required but could be manageable. It considers that a transhipment site is certainly necessary to tranship materials from the Kirtling Street and Carnwath Road Riverside drive sites and other foreshore CSO sites irrespective of whether the eastern section of the main tunnel is driven from Abbey Mills Pumping Station.

1.8.13 The requirement for transhipment for sites upstream of Tower Bridge is due to the physical limitations of the river that prevent larger sea-going vessels navigating up to the main drive sites. It is likely that there is no alternative but to use a transhipment site to transfer material to a sea-going vessel, although sites with direct river access may be available in future.

1.8.14 The lithological nature of the materials (predominantly clays, sands and gravels) produced at Carnwath Road Riverside and Kirtling Street, together with the construction methodology, makes them suitable for the transhipment. However, we have consistently stated that the double handling of processed Chalk (mainly arising at the eastern drive sites) should be avoided due to the deterioration in the physical consistency of the processed Chalk.

Assessment of impact on cyclists

1.8.15 LB Southwark states that: “the council would welcome a full impact assessment of the impact on cycling for both sites – something lacking to date”.

1.8.16 The Transport Assessment and Environmental Statement volumes for Chambers Wharf and Abbey Mills Pumping Station include accident analyses and an assessment of impacts on cyclists. For both sites, the conclusion was that there would be a minor impact on cyclists which suggests that, according to the methodology applied in those document, there is no need for a further study.

Question 32.26 (feasibility of pumping slurry)

1.8.17 LB Southwark has requested further information on the feasibility of pumping slurry from Abbey Mills Pumping Station either along the route of the Northern Outfall Sewer or down Bow Creek to another site on the River Thames. This detail is provided in our response to Save Your Riverside‟s 3 February 2014 submission (Doc ref: APP168).

Question: 58.1


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Question 33 Socio-economic effects

Questions 33.8 to 33.10 Daylight/sunlight

1.8.18 LB Southwark has raised concerns regarding the Daylight/Sunlight Assessment (Doc ref: 7.24). A response to the concerns raised is provided in Appendix D in which Waterslade, the specialists who carried out the assessment, clarify the approach to the assessment. Appendix D also contains the calculation tables for the post-mitigation scenario, which shows all windows are fully compliant with the Building Research Establishment guidelines in daylight and sunlight.

1.8.19 In addition, the errata document (Doc ref: APP123) submitted on 12 February 2014 noted an error in the given scale in Figure 8.1: the Chambers Wharf acoustic site accommodation diagram provided in our response to second written question 33.8. LB Southwark was informed of this minor error and provided the replacement figure by email on 20 January 2014. The amended figure is provided in Appendix E.

Noise impacts

1.8.20 Responses are given below to the points raised regarding noise and vibration. LB Southwark notes that many items at the stage of submission were deferred to discussion at the issue specific hearing on 4 February 2014.

Table 1.8 LB Southwark comments regarding noise and vibration and our response

LB Southwark comment Our response

Section 2, Point 3a

“issues which have arisen on [other major civil engineering projects] and have been satisfactorily addressed, cannot be addressed here”

As has been noted at the hearings, Appendix C of Doc ref: APP31.02 and Appendix A of Doc ref: APP102.04 describe and illustrate other major infrastructure construction projects comparable with the proposed works at Chambers Wharf, where potential noise and vibration effects have been satisfactorily addressed.

Section 2, Point 3b:

“Difference between the threshold at which significant effects are identified and the threshold for noise insulation”

See our response to Q57.13 of the request for further information.

Section 2, Point 4:

“The outstanding feature of this site is the very large number of single-aspect dwellings extremely close to the site, e.g. 31 in Axis Court and Luna House and 47 in the Chambers Street development under construction which means that significant effects begin at thresholds much more difficult to deal with other than by noise insulation and other extreme approaches.”

Appendix A of the summary of evidence for the hearing on 23 January (Doc ref: APP102.04) demonstrated that the number of single aspect dwellings in the locality of the Chambers Wharf site is not materially different from the number around comparable benchmark construction site on other major London infrastructure projects.

Noise insulation has proved successful in mitigating residual significant observed adverse effects at a number of these benchmark projects.

http://infrastructure.planningportal.gov.uk/wp-content/ipc/uploads/projects/WW010001/2.%20Post-Submission/Application%20Documents/Other%20Documents/7.24_Daylight_Sunlight_Assessment.pdf

http://infrastructure.planningportal.gov.uk/wp-content/ipc/uploads/projects/WW010001/2.%20Post-Submission/Application%20Documents/Other%20Documents/7.24_Daylight_Sunlight_Assessment.pdf

Question: 58.1


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Section 2, Point 5:

“background noise may go down in Chambers Street which is currently affected by noise from Jamaica Road, and when the new buildings are completed that will be reduced so that there may be a significant effect which is not found at present. How will NEWT work in a case such as that?”

It is considered that the baseline ambient noise levels assumed for the assessment are adequately representative of the area immediately prior to the proposed start of the construction work. The site is some 250m from Jamaica Road with high-rise buildings between Jamaica Road and the site. Although there is potentially a distant contribution from this highway, it cannot be assumed to be the dominating noise at the assessed receptors. The addition of the new buildings on Chambers Street, of similar height to the existing intervening buildings will not result in reduced ambient noise levels by providing any further screening to Jamaica Road.

Given that the new buildings on Chambers Street are not expected to reduce ambient noise, additional significant effects are not expected and hence the „not environmentally worse than‟ (NEWT) requirement will be met.

Section 2, Point 6:

“The contractor will inevitably have different proposals from those assumed in the preparation of the ES and may dispose plant about the site in a different way and noise will be differently dispersed across the site. Will the contractor not be allowed to cause a significant effect in Chambers Street and be allowed to cause a significant effect at Axis Court and Luna House?”

The contractor will be bound by the NEWT commitment (Doc ref: APP177.02) which is to “ensure that no significant adverse effects arise that are worse than those reported in the Environmental Statement.” So the new development on Chambers Street that is identified in the Environmental Statement Update (Doc ref: APP184.01.26) as being not significantly affected cannot become significantly affected after development consent is granted.

Section 2, Point 7:

“Sections 60 & 61 of the Control of Pollution Act 1974 will apply, but it is of course subject to the use of „Best Practicable Means‟”.

As noted above, there may be best practical means constraints as to how far noise can be minimised, but the NEWT commitment ensures noise exposure cannot exceed that assessed in the Environmental Statement (secured by DCO Requirement PW6).

Question: 58.1


60

Health and in-combination impacts

Table 1.9 LB Southwark comments regarding health and in-combination and our response


Section 4, Point 5:

“Noise remains a particular issue for the whole community at Chambers Wharf despite the intention to offer mitigation to some of the sensitive receptors. From a public health perspective, everyone living and working in the area needs to be regarded as a potentially sensitive receptor (although there are variations in individual vulnerability) as there is robust evidence13 for an exposure-response relationship between noise and adverse health and psycho-social impacts.”

The Health Impact Assessment (Doc ref: 7.12, Table 5.1) considers health and well-being in relation to noise (and other environmental factors). The assessment considered:

the existing noise conditions

residential density and the demographic of the population

the current status of health indicators

the nature, magnitude and duration of noise impacts.

The Chambers Wharf site assessment summary is contained in Section 9.18 of the Health Impact Assessment and includes noise and vibration as an in-combination effect amongst: access to open space, physical activity, air quality, quality of life and personal safety and security. The noise and vibration section of the Environmental Statement (Doc ref: 6.2.02) was also referred to in developing the Health Impact Assessment by considering the noise impacts and the types of receptors affected. Taking account of the embedded mitigation, the residual health impact effects are assessed as negligible to minor adverse.

http://infrastructure.planningportal.gov.uk/wp-content/ipc/uploads/projects/WW010001/2.%20Post-Submission/Application%20Documents/Other%20Documents/7.12_Health_Impact_Assessment_Main_Report.pdf

Question: 58.1


61

1.9 Thames Water response to London Borough of Tower Hamlets

Introduction

1.9.1 London Borough of Tower Hamlets (LBTH) has provided additional representations on 3 February 2014 and 12 February 2014. This section provides a response to the main issues raised in these representations. Where TW has already responded to matters in its response to the ExA‟s questions or at the examination hearings, the response is not repeated in this document.

Development Consent Order

1.9.2 Thames Water has already responded to LBTH‟s comments on the DCO in earlier submissions, Response to issue specific hearing and written representations relating to King Edward Memorial Park Foreshore (Doc ref: APP31.04, Section 8).

Requirements

1.9.3 Many of LBTH‟s comments on the project-wide Requirements are supportive of changes that have been made. There are, however, two comments and updates that TW would like to make.

1.9.4 With regard to PW4, we have reviewed the proposed two-month notice period included in the Draft DCO submitted to the ExA on 12 February 2014 and are not proposing any changes. It would not be possible for any major complex infrastructure project to be able to provide accurate information in advance of two months. This is considered to be an appropriate and reasonable period of notice.

1.9.5 With regards to PW16, TW notes the concerns regarding the NPS review. At the DCO hearing on 21 February 2014, submissions were made by TW in response to questions from the ExA and other parties on the NPS review. As promised at the hearing, we have reviewed the proposals and the NPS review process has been removed from the River Transport Strategy.

1.9.6 LBTH has also made a number of comments on the site-specific Requirements. Its comments on KEMPF3, 4 and 5 relate to the inclusion of explicit references to the historic character, materials and appearance of the park. These considerations will need to be addressed in order to be in accordance with the design principles for the site, and are therefore already covered by Requirements KEMPF3 and 5.



Question: 58.1


62

Code of Construction Practice

1.9.7 We have given full consideration to the Joint Boroughs‟ comments on the CoCP Part A and a number of changes were included in the revised version submitted on 12 February 2014. TW would like to make the following comments in response to the council‟s recent submission:

a. The council‟s comments on Chapter 1 of the CoCP Part A (Doc ref: APP125.01) have been responded to in the 12 February 2014 submission.

b. The council‟s comments about our commitment to „best practice‟ in paragraph 1.1.9 of the CoCP Part A have been responded to in the 3 March 2014 submission (Doc ref: APP178.01).

c. TW does not agree with the council‟s comments on the CEMP relating to site layout and operations, for reasons already explained in the various hearings and in response to LB Southwark‟s submissions, as summarised within the final version of the Statement of Common Ground to be submitted on 3 March 2014 (Doc ref: APP159.02). The final version of the CEMP will be made available to the local planning authority at least four weeks before commencement of construction, and a template for this is included in the 12 February 2014 submission (Doc ref: APP125.01, Appendix B).

d. The Non-statutory Off-site Mitigation and Compensation Policy (Doc ref: APP186) submitted to the ExA on 3 March 2014 includes provision for the appointment of an Independent Complaints Commissioner.

e. As defined in paragraph 1.1.6 of the CoCP Part A, the term „construction‟ includes all physical works carried out to implement the project including utility works. These are required to be carried out in accordance with the CoCP under Requirement PW6 and relevant site-specific requirements in Schedule 3 to the DCO.

f. The council‟s comments on Section 6 of the CoCP Part A relating to noise and vibration are responded to in the Non-statutory Off-site Mitigation and Compensation Policy, the revised version of which will be submitted on 3 March 2014 (Doc ref: APP186).

g. As a relevant stakeholder, the council will be consulted on with regards to the Ecology and Landscape Management Plan – see paragraph 11.2.1 of the CoCP Part A (Doc ref: APP178.01).

h. In response to the council‟s comments on Article 53 and Schedule 17 of the Draft DCO relating to the discharge of Requirements, TW can confirm that the distinction between major and minor Requirements has been removed so that the eight-week determination period will apply to all Requirements.

1.9.8 We have also reviewed the council‟s comments on the CoCP Part B for KEMPF. TW would like to make the following comments in response to the council‟s recent submission:

a. As already stated in response to ExA‟s questions, it is not considered appropriate to prohibit weekend working as this would have

http://infrastructure.planningportal.gov.uk/wp-content/ipc/uploads/projects/WW010001/2.%20Post-Submission/Representations/12-02-2014%20-%20TWUL%20Submission%20of%2012%20Feb%202014%20inc.%20draft%20DCO/APP125.01%20Code%20of%20Construction%20Practice%20Part%20A%20General%20Requirements%20-%20Revised%2012%20February%202014.pdf

Question: 58.1


63

unacceptable implications for the overall programme of works at this site.

1.9.9 All of the other suggested edits provided by the council were not included as it was considered they did not add any necessary or appropriate detail or clarity to the text.

Question: 58.1


64

1.10 Thames Water response to MMO

Introduction

1.10.1 This is TW‟s response to the letter submitted to the ExA by the Marine Management Organisation (MMO) on 12 February 2014, reference DC9221.

Response

1.10.2 TW confirms that matters raised in the MMO submission of 12 February 2014 have been addressed in the 3 March 2014 update to the SoCG, including:

a. Schedule 15 Deemed Marine Licence (DML) is now in agreed final form

b. matters relating to transfer of benefit of the order are now agreed and included in the agreed DML

c. the four-way Legal Agreement is now in agreed final form.

1.10.3 TW notes MMO‟s clarification to the ExA regarding excavated material disposal and refers also to TW‟s response to question 62.2. TW would also reiterate that no disposal at sea is proposed.

Question: 58.1


65

1.11 Thames Water response to Minerva (Wandsworth) Limited

Introduction

1.11.1 This is a response to a letter from Herbert Smith Freehills on behalf of Minerva (Wandsworth) Limited dated 12 February 2014 (ref: 2129/4269/30939775).

1.11.2 TW has previously made representations to the ExA relating to Minerva (Wandsworth) Limited and a list of previous representations is provided in Appendix F.

Response

1.11.3 As stated by Herbert Smith Freehills, the parties are hopeful of reaching a point of agreement by 3 March 2014, through an agreement relating to the Ram Brewery site which, if concluded, would lead to a withdrawal of the objection made by Minerva (Wandsworth) Limited.

1.11.4 In working towards an agreement, the parties have held the following meetings:

a. 5 September 2012 (discussed our planning application recommendation)

b. 8 November 2012 (discussed sharing of data, technical assessment and the preparation of an agreement)

c. 4 February 2013 (technical engineering meeting)

d. 25 September 2013 (technical and agreement matters)

e. 7 November 2013 (technical engineering meeting)

f. 3 February 2014 (detailed discussion of draft agreement).

1.11.5 A draft Agreement was originally forwarded to Minerva from TW on 24 January 2014. An amended version of the draft Agreement responding to Minerva‟s comments of 28 January 2014 was issued by TW to Minerva on 30 January 2014. The parties held discussions on a draft Agreement at a meeting on 3 February 2014. A further amended version of the draft Agreement was forwarded to Minerva from TW on 12 February 2014. Further discussions on the draft Agreement have been held between 25 and 27 February 2014.

1.11.6 The key technical points that are being included within the Agreement are:

a. limitation on the Frogmore connection tunnel horizontal alignment adjustment allowance and protection zone as the tunnel passes the Ram Brewery site to a maximum of 10 metres in an eastward direction from the centre line, shown on the Works Plan and Section DCO-WP-000-ZZZZZ-010016

b. sharing and coordination of construction details and timing of construction works

Question: 58.1


66

c. liability in respect of loss or damage

d. recovery of costs

e. recovery of professional fees incurred.

1.11.7 TW has also prepared a SoCG to assist the parties in coming to an agreement. A draft SoCG was forwarded to Minerva from TW on 4 February 2014. The SoCG was largely agreed and an amended version of the draft SoCG was submitted to the ExA and TW by Minerva on 12 February 2014. The changes were minor and relate to commercial matters.

1.11.8 It is agreed by both parties that the Agreement addresses the main concerns, being:

a. a restriction of the alignment for the Frogmore connection tunnel as it passes the Ram Brewery development site to no more than 10 metres from the centre line

b. an agreed mechanism and procedure for dealing with the timing for notification and agreement of route alignment, design and construction programmes, including protocol for the sequence of development between both schemes

c. a method for dealing with the submission of and approval by TW of details under condition 25 of the Ram Brewery Planning Permission; and

d. details of costs are to be supplied by Minerva, reviewed by TW and mutual agreement reached or resolved by way of dispute resolution.

1.11.9 There are protections in the Agreement whereby Minerva can enforce TW‟s obligations.

1.11.10 There are no matters not agreed in principle, subject to the owners' lawyers' sign-off of the draft Agreement. Once the negotiations have been satisfactorily completed and the Agreement has been exchanged, the representations will be withdrawn. The parties are working in a constructive manner and hope to conclude the Agreement by 7 March 2014.

1.11.11 The signed SoCG is included in Appendix G of this response.

1.11.12 TW notes the slight amendments within the 12 February 2014 Minerva letter to the draft Requirement proposed by Minerva for inclusion within the DCO. A Requirement by the project is submitted as an alternative in the unlikely event that an Agreement is not concluded by 7 March 2014. The Requirement is as follows:

(1) Subject to (2), paragraphs (3), (4) and (5) of this requirement shall only have effect in respect of the construction of the mixed use development proposed to be carried out by Minerva (Wandsworth) Limited at the Ram Brewery Site in the London Borough of Wandsworth in accordance with:

a. the planning permission for that mixed use development granted on 6 December 2013 under reference 2012/5286;

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b. the listed building consent granted on 6 December 2013 under reference 2012/5290;

c. conservation area consent granted on 6 December 2013 under reference 2012/5287; and

d. the details submitted and approved by the relevant planning authority in consultation with Thames Water Utilities Limited further to condition 25 of planning permission 2012/5286.

(2) This requirement shall continue to have effect, notwithstanding any variations or amendments to consents referred to in (1), but only to the extent that:

a. the undertaker confirms that those variations or amendments do not result in a greater impact on the construction, maintenance or operation of Work No.7; and

b. the development carried out by Minerva (Wandsworth) Limited on the Ram Brewery Site does not extend any further westwards than as authorised further to the consents referred to in (1) as originally granted.

(3) Thames Water shall, no later than 18 months prior to the commencement of construction of Work No.7 (the Frogmore Connection Tunnel) notify the relevant planning authority and the owners of the Ram Brewery Site of the proposed detailed alignment of the Frogmore Connection Tunnel.

(4) In respect of Work No. 7 between approximate chainage 240m to approximate chainage 380m the horizontal limit of deviation in an eastward direction shall be limited to a maximum of 10 metres from the centre line of Work No. 7 as illustrated on Drawing No. DCO-WP-000-ZZZZZ-010016.

(5) The authorised development shall be carried out in accordance with these details unless otherwise agreed with the relevant planning authority in consultation with the owners of the Ram Brewery Site.

(6) “Ram Brewery Site” means the land known as Ram Brewery, Duval Works, Capital Studios, Wandsworth High Street and 1-9 Church Row.

1.11.13 It should be noted that this Requirement is submitted at the request of the ExA in the event that an Agreement between the parties is not achieved before the end of the examination. It is hoped that the Agreement will be signed by both parties and, if this is achieved, Minerva will remove its existing objection and confirm to the ExA before the end of the examination.

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1.12 Thames Water response to National Grid

Introduction

1.12.1 This is TW‟s response to the letter dated 12 February 2014, submitted to the ExA by National Grid Gas plc and National Grid Electricity Transmission, together with National Grid.

Response

1.12.2 TW confirms that the version of the protective provisions that are in the Draft DCO (Doc ref: APP177.02), submitted for the 3 March 2014 deadline, are the agreed version previously attached to the Statement of Common Ground (SoCG) between National Grid and TW, submitted on 12 February 2014.

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1.13 Thames Water response to St James Group Ltd

Introduction

1.13.1 This is a response to St James Group Limited‟s Comments on the Applicant‟s Response to the Second Round of Questions, dated 3 February 2014 (ref: LR16386 49913643.1), and St James Group Limited‟s Summary of Case put forward at the noise and Vibration Issue Specific Hearing and Comments on the Revised DCO and CoCP (3 Feb 2014), dated 12 February 2014 (ref LR16386 50166252.1).

1.13.2 TW is hopeful of reaching a point of agreement with St James Group Limited by 3 March 2014, through the signing of Heads of Terms (HoTs) relating to the Riverlight site which, if concluded, would lead to a withdrawal of the objection made by St James Group Limited.

1.13.3 Draft HoTs were forwarded by St James Group Limited to TW on 9 December 2013. TW forwarded amended HoTs to St James Group Limited on 23 January 2014. St James Group Limited forwarded amended HoTs to TW on 14 February 2014. Following a meeting between the parties on 26 February 2014, TW has now drafted and sent revised HoTs to St James Group Limited, which it is hoped can be agreed shortly.

1.13.4 The key points that are being included within the HoTs are:

a. noise mitigation

b. noise monitoring

c. resident‟s liaison and complaints handling

d. construction traffic access

e. provision of a green wall.

1.13.5 Within its representations, St James Group Limited makes specific comments relating to noise and construction traffic which are being considered as part of a revised drafting of the HoTs. Responses to the comments are provided below.

1.13.6 St James Group Limited also makes specific comments relating to the draft CoCP (revised 3 Feb 2014) and Design Principles (revised 3 Feb 2014, Doc ref: APP106.01). These have been considered as part of the submission of revised documents, and responses to the comments are also provided below.

Noise

1.13.7 This section responds to paragraphs 1 to 2.8 of the St James Group Limited representation entitled, Summary of Case Put Forward at the Noise and Vibration Issue Specific Hearing and Comments on the Revised DCO and CoCP (3 Feb 2014), dated 12 February 2014 (ref LR16386 50166252.1), and paragraphs 1 to 1.16 of the St James representation entitled, Comments on the representation Applicant‟s Responses to the Second Written Questions, dated 3 February 2014 (ref LR16386 49913643.1).

http://infrastructure.planningportal.gov.uk/wp-content/ipc/uploads/projects/WW010001/2.%20Post-Submission/Representations/Comments/Responses%20to%20ExA%20Questions/03-02-2014%20-%20Comments%20on%20Responses%20to%20the%202nd%20Round%20of%20Questions/WW010001_140203_St%20James%20Group%20Ltd.pdf

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1.13.8 In its submissions of 3 and 12 February 2014, St James Group Limited:

a. raises a number of matters relating to the application of the project‟s Non-Statutory Off-site Mitigation and Compensation Policy to the Riverlight development, and

b. seeks to secure noise limits to control noise impact on the Riverlight development.

1.13.9 TW‟s response to St James Group Limited‟s submissions was provided at the noise hearings (Doc ref: APP115.01, paragraph 2.1.14 and sequence).

1.13.10 TW‟s position with regards to noise limits is set out in a written submission to the ExA (Noise Limits Paper – Update 3 March 2014, Doc ref: APP188).

1.13.11 The ongoing engagement with St James Group Limited and its advisors has confirmed the high level of sound insulation provided by the design specification of the Riverlight development. Taking this and the increased on-site mitigation into account, as defined in the Kirtling Street CoCP Part B (Doc ref: APP178.23), the Environmental Statement update report (Doc refs: APP184.01 and APP184.01.17) confirms that the construction noise effects at the Riverlight development are likely to be not significant.

1.13.12 The „NEWT‟ requirement set out in Section 2.1 of the CoCP Part A (Doc ref: APP178.01) ensures that the contractor‟s proposals cannot result in the Riverlight development becoming significantly affected by noise. This provides an equivalent level of protection as the imposition of noise limits, where the limits are set in line with the Environmental Statement update report.

1.13.13 TW does not accept St James‟s request to approve a noise monitoring scheme prior to the commencement of construction work. This is because Section 6 of the CoCP Part A (Doc ref: APP178.01):

a. defines detailed requirements for noise monitoring to be undertaken and reported by the contractor. This includes the requirement to undertake monitoring at the assessment locations identified in the Environmental Statement (that include a number of locations on the Riverlight development)

b. requires the contractor to agree the noise monitoring scheme with the local authority before construction works commence as part of the Noise and Vibration Management Plan

c. requires the contractor to undertake monitoring to ensure and demonstrate compliance with all noise commitments

d. requires the results of monitoring to be issued to the local authority on a weekly or, as otherwise agreed, basis.

1.13.14 The CoCP is secured by Schedule 3 of the Draft DCO, Requirement PW6 (Doc ref: APP177.02).

Construction traffic/traffic and transport

1.13.15 This section responds to paragraphs 2 to 2.15 of the St James Group Limited representation entitled, Comments on the representation


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Applicant‟s Responses to the Second Written Questions, dated 3 February 2014 (ref: LR16386 49913643.1).

Revised CoCP

Cringle Street/Nine Elms Lane Junction

1.13.16 Project construction traffic will be subject to a one-way system on Kirtling Street and Cringle Street.

1.13.17 If the project was to use the Kirtling St/Battersea Park Road junction for both access and egress, this would add to risk by potentially doubling movements in that area and increase the amount of HGVs travelling in opposite directions in the area. Splitting access and egress spreads the flow, thus reducing traffic at any one location, and maintains a one-way construction traffic flow.

1.13.18 In addition, left turning HGVs (no right turning) from Cringle Street onto Nine Elms Lane and only using this junction for egress reduces the risk at this junction.

1.13.19 The alternative route proposals put forward by St James Group Limited are responded to below under the heading, Alternative route.

Conflicts between construction traffic and other road users

1.13.20 The CoCP Part A (Doc ref: APP178.01), Section 5.2, sets out provisions for lorry management and control, including commitments to use „active‟ cycle safety measures on construction lorries, signage and appropriate lorry driving training. In addition to this, a Phase 2 Road Safety Audit will be undertaken on the final detail design of the project and, where necessary and where recommended, further control measures can be applied.

1.13.21 The alternative route proposals put forward by St James Group Limited are responded to below under the heading, Alternative route.

Alternative route

1.13.22 St James Group Limited has proposed an „alternative route‟ to avoid the use of Kirtling Street by project construction traffic adjacent to the Riverlight development. The alternative route requires an internal haulage route within the project‟s Kirtling Street construction site, noting that the illustrative Construction phase plans for phases 1, 3 and 4 show a haul route within the construction site.

1.13.23 TW has provided illustrative plans (Construction phases plans, Book of Plans – Section 15, phases 1, 3 and 4), which indicate a haul route. This, however, is only one scenario of many for the area and is not intended to provide a through traffic haul route at all times but to provide an idea of where a haul route might be required for some time during the construction phase. Haul routes can be, by nature, a risk to safety and must be carefully planned to meet the changing circumstances of the activities on site. Flexibility has to be maintained to manage all site related movements. During the continuing process of site development, this flexibility has been shown to be of vital importance in providing alternatives

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and options, for instance, with the CEMEX relocation, and temporary as well as permanent power supply solutions.

1.13.24 Committing to a constant through route within the project construction site at any time is not considered an ideal solution because of safety risks and TW‟s need to maintain flexibility. However, further discussions are required with adjacent stakeholders to coordinate the most appropriate haul routes for the area.

Question 34.10

1.13.25 The commitment is to transport 100 per cent of the specified materials by river, subject to approved derogations (in accordance with the process set out in the River Transport Strategy (Doc ref: APP180.02)). However, following derogations, the objective is to transport at least 90 per cent of the specified materials by river. Table 10.1 of the response to second written question 34.10 (Doc ref: APP61) sets out the quantities in line with the objective in the River Transport Strategy.

1.13.26 The Transport Assessment is based on the objective to transport 90 per cent of the specified materials (in accordance with the River Transport Strategy) by river. At Kirtling Street, for the purposes of the assessment, the materials which have been assessed as transported by road include shaft excavated material, other excavated material and 90 per cent of the main tunnel excavated material (to allow for operational derogations within the assessment). These material tonnages have been translated into the number of lorry movements required across the construction period and assessed as part of the Transport Assessment and Environmental Impact Assessment. The number of vehicles associated with these materials takes into consideration the total tonnages, capacity of the site/loading equipment and the construction programme.

Questions 34.12 and 34.13

1.13.27 The implementation of river transport is controlled by processes which are set out in the River Transport Strategy, such as contingency planning. The aims of these processes are to ensure that an event which could potentially give rise to an operational derogation is sufficiently mitigated to reduce the need for, or extent of, any operational derogation. It also ensures that the use of HGVs for an operational derogation is only implemented where necessary. This means that only when all mitigation and alternative options have been considered and adopted as appropriate, as a last resort, some of the specified materials may have to be transported by road instead of river for a short period. The River Transport Strategy cannot result in an exceedance of the worst case assessment of effects set out in the Environmental Statement.

Comments on the draft Code of Construction Practice (Revised 3 Feb 2014)

1.13.28 This section responds to paragraphs 3 to 4.2 of the St James Group Limited representation entitled, Summary of Case Put Forward at the

http://infrastructure.planningportal.gov.uk/wp-content/ipc/uploads/projects/WW010001/2.%20Post-Submission/Representations/ExA%20Questions/13-01-2014%20-%20Responses%20to%20Exa%20Questions%20Round%202/APP61%20Thames%20Water%20Traffic%20Travel%20and%20Transportation.pdf

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Noise and Vibration Issue Specific Hearing, dated 12 February 2014 (ref LR16386 50166252.1).

CoCP Part B for Kirtling Street

Section 4 (site operation)

1.13.29 A sentence has been added to the CoCP Part B: Site Specific Requirements Kirtling Street (Doc ref: APP178.23) to clarify that office and welfare facilities positioned along the eastern boundary of the construction site are not restricted to the 3.6m height of the hoarding at this location and may exceed this height to assist screening.

1.13.30 The sound insulation performance suggested by St James Group Limited may not be sufficient to assure that the level of noise reduction provided by the „green wall‟ or other site hoardings/barriers are fit for purpose. Section 6 of the CoCP Part A (Doc ref: APP178.01) requires the contractor to seek prior consent for its construction method and best practicable means steps to minimise noise under Section 61 of the Control of Pollution Act 1974. The relevant applications and consents will ensure that the detailed design of the perimeter hoardings, „green walls‟ or other noise barriers is fit for purpose with regards to delivering the agree noise reduction at Riverlight.

Section 5 (public access, highway and river transport)

1.13.31 The alternative route proposals put forward by St James Group Limited are responded to above under the heading, Alternative route.

Section 6 (noise and vibration)

1.13.32 Comments relating to the management of noise, noise limits and monitoring are responded to above, under the heading, Noise.

1.13.33 With regards to control measures relating to ventilation fans, the CoCP Part A (Doc ref: APP178.01), para. 6.6.4c, requires that all tunnel ventilation plant with connections to the atmosphere in any noise-sensitive location will be subject to mitigation measures appropriate to the local environment, including enclosures or screening.

1.13.34 The assurance that modifications to control measures should not reduce the level of control over noise is provided in the commitment to be „not environmentally worse than‟ the effects identified in the Environmental Statement update in Section 2.1 of the CoCP Part A (Doc ref: APP178.01). Further, no change is possible to the CoCP Part A after the DCO is granted and any change to the CoCP Part B must be approved by the local authority.

CoCP Part B for Heathwall Pumping Station

Section 6 (noise and vibration)

1.13.35 Comments relating to the management of noise, noise limits and monitoring are responded to above, under the heading, Noise.

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1.13.36 A sentence has been added to the CoCP Part B: Site Specific Requirements Heathwall Pumping Station (Doc Ref APP178.25) to require that all static plant shall be screened or enclosed and that movement of vehicles on-site shall be restricted outside of standard hours.

1.13.37 The use of electrically powered plant cannot be required, due to the short-term nature of the activities and the lack of an available, suitable main power source.

Comments on Design Principles (revised 3 Feb 2014)

1.13.38 Requirement KRTST 5 requires that details of the landscaping, which shall accord with the indicative Proposed landscape plan (Drawing no. DCO-PP-13X-KRTST-150008) and the design principles for this site, are submitted to and approved by the relevant planning authority in consultation with the Mayor of London.

1.13.39 Design Principle KRTST.06 specifies that the materials and design of any reinstatement works outside of Kirtling Wharf shall be consistent with the Riverlight development in order to support a coherent public realm in the area.

1.13.40 Paragraph 4.11.2 of the Design Principles (Doc ref: APP126.01) acknowledges that streetscape improvement works may be provided by others, for instance, as part of the redevelopment of the Battersea Power Station. In any case, street surfacing, lighting and details of restoration required under Requirement KRTST 5 will all be for approval by the local authority.

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1.14 Thames Water response to Save Your Riverside

Introduction

1.14.1 This section provides a response to the written submissions from Save Your Riverside (SYR) submitted to the ExA on 3 and 12 February 2014. A response is provided to points where clarification is required or to signpost where matters are addressed elsewhere.

Response: 3 February 2014 submission

APP 75 series – further DCO drafting notes and updated DCO

1.14.2 The issue regarding acceptance period (para. 13) was discussed at the issue specific hearing on 21 February 2014. The written summary of the issue specific hearing provides further detail (Doc ref: APP158). We have sought to address this issue in the updated Draft DCO which will be submitted to the ExA on 3 March 2014 (Doc ref: APP177.02).

1.14.3 In relation to the comments regarding Article 7 (para. 14), please see the following written summaries:

a. Written summary of issue specific hearing held on 26 November 2013 (Doc ref: APP34, pp. 2 to 3)

b. Written summary of issue specific hearing held on 20 January 2014 (Doc ref: APP102.1, pp. 6 to 8)

c. Written summary of issue specific hearing held on 6 February 2014 (Doc ref: APP115.02, p. 6).

APP59 Rationale for the selection of work sites and drive strategies

Q32.22 (AM as drive site with 3 [now 4] barge scenario)

1.14.4 Paragraph 30 of the SYR written submission states: “TW has accepted [that theoretical high tunnelling rates, if sustained, would lead to systems for dealing with spoil becoming overwhelmed] would also be the case at CW even with its river access for larger barges.”

1.14.5 This represents a clear misunderstanding of the figures presented by TW in comparing tunnel drives from Chambers Wharf and Abbey Mills Pumping Station.

1.14.6 The chart submitted as Doc ref: APP59.22.02, Effect at AM of Variable Drive Rates, depicts the number of HGVs and barges required to sustain tunnelling activities for drive rates from 1-200m per week. This is not intended to be misleading, as stated by SYR, but rather it is intended to demonstrate the sharp increase in HGV movements that would be observed at Abbey Mills Pumping Station during periods of sustained high output tunnel drive rates.

1.14.7 In contrast, a similar chart for Chambers Wharf would show a proportional increase in HGV and barge numbers with increased drive rates up to a maximum of 58 HGVs predicted at the 200m per week rate, 208 HGVs or

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416 movements per day fewer than predicted at Abbey Mills Pumping Station for the same drive rate and with fully utilised use of the river. At the high output rate of 200m per week, an average of just under three 1,500t barges would be required per day to manage tunnel excavated material, which is well within the assessed capacity of the Chambers Wharf site for processing barges even with the restrictions placed on loading operating periods.

1.14.8 The reference made by SYR to para. 13.2.32 of Doc ref: APP61 in response to second written question 34.13 relates to the assessed capacity of the worksite for processing HGVs under the 'all by road' scenario, whereby an unplanned disruption to river transportation requires that all materials are transported by road. The mitigation measures which would be put in place in this situation are discussed in response to second written question 34.11. However, it should be reiterated that TW believes the likelihood of an event occurring whereby HGVs would be needed to remove all tunnel excavated material from Chambers Wharf would be highly unlikely.

1.14.9 To respond to the point about tunnelling rates in paragraph 31 of the SYR submission, we make reference to our 2 December 2013 submission (Doc ref: APP31.02) and principally to Section 3.5. Within this, and through our detailed response to first written questions 14.25 and 14.29, we have stressed health and safety as our primary concern when addressing risk and, importantly, the risk to surface structures and buildings from settlement due to ground movement created by the tunnelling process. In finalising the direction of the tunnel drive, we have taken in to account the geological profile along the route, which has identified low cover of competent chalk in places and the risk of encountering geological faults which are known to exist in this location. We have, of course, chosen slurry TBM technology as the tried and tested mode of dealing with these challenging ground conditions.

1.14.10 Section 3.5.13 highlights reference to the British Tunnelling Society Closed Face Ground Stability Document (September 2005), and the statement therein that the "rate of tunnel advance has a direct influence on ground stability and the control of settlement". Experience from recent projects has demonstrated that the faster the progress, the less the settlement. For this reason, it is accepted that tunnelling is a 24 hours per day „continuous‟ operation.

1.14.11 By continuous, it is not our contention that the TBM cannot be stopped at any time. Indeed, the TBM will stop on occasions to facilitate routine inspections and maintenance. These stoppages, however, will be planned „interventions‟, and located only where ground conditions are assessed as suitable and represent the lowest risk to the TBM, the tunnel, and to settlement at the surface. It is the unplanned stoppages to the tunnelling operation that pose a higher risk.

1.14.12 A detailed, bespoke specification for the design and operation of the TBM that we will instruct our contractors to follow will help ensure that unplanned stoppages for essential maintenance are essentially eliminated. In the event that an unplanned stoppage of a lengthy duration for

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maintenance is required, the contractor will assess the nature of the ground before stopping the TBM. Its greater concern will be stoppages enforced by the inability to remove excavated material.

1.14.13 Section 3.5.14 highlights the risk of the contractor not being able to revert to road transport at short notice, and the subsequent risk of the TBM being at a location where a stoppage would incur additional ground movement and increased surface settlement. As stated in Section 3.6.16, Chambers Wharf offers considerably better access for river-based transport of materials, with a significantly reduced risk of derogations from river- to road-based transport.

1.14.14 With regard to the existence of Shaft G at Abbey Mills Pumping Station giving us a head start on tunnelling, we would accept that this would change the programme of works but we would still need approximately 15 months for TBM design, manufacture and delivery, which is the duration allowed for in the programme, and that this is likely to become the critical path. We would also have extensive works to carry out for the river operation, piling, dredging, etc, before we could start tunnelling from Abbey Mills Pumping Station.

Q32.26 (slurry pipeline issue)

1.14.15 Question 32.26 specifically referred to the option of a slurry pipeline located within the Lee Tunnel and therefore our response provided our view on this option.

1.14.16 We do not consider that the option of installing twin slurry pipelines along the Greenway is feasible for a number of reasons, including:

a. The option would involve a long and intrusive interface with the public over a distance of about 6km; the pipelines would be enclosed within hoarding to a height of 2.4m for safety and security reasons and pumping stations, possibly with generators, would be required at 1km to 1.5km intervals.

b. Slurry pipe bridges would be required to maintain safe public access across the Greenway and, where vehicle access is required, these would need to be raised to a minimum height of 5 metres. The pipelines would also need to cross the A13 at its junction with the Greenway and the A117, which is a major road intersection. As stated in our previous answer, ongoing maintenance of the slurry pipelines, including repairing leaks, would be necessary due to the abrasive nature of the flints carried in chalk slurry. If the slurry pipelines were to cross over these roads, then traffic management, including lane closures, would be required to carry out this maintenance. Alternatively, the pipelines could cross below the roads but they would need to be installed within separate tunnels adequately sized to allow access to and maintenance of the pipelines.

c. As these works would fall outside of the LLAU, planning permission would be required from the London Borough of Newham and the London Legacy Development Corporation, as the Greenway is an area of Metropolitan Open Land and there is a risk that the planning

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application would be rejected. Without planning permission, we would not be able to demonstrate that the works in the application for development consent are deliverable.

d. The five TW strategic brick arch northern outfall sewers are located beneath the Greenway. Access along the Greenway for construction, operation and maintenance of the slurry pipeline system is restricted by an imposed weight limit and the very shallow ground cover to these Victorian sewers, which would provide constrains on the design of below-ground foundations for temporary structures required to support power generators, pumps and pipe bridges.

e. Leakage from slurry pipes could cause hazards and potentially damage to the Greenway embankment, to other services located within the embankment (including HV cables and high-pressure gas mains) and impact on buildings at the base of the embankment.

f. The option of pumping slurry along the route of Bow Creek to another site on the tidal Thames has also been considered. However, this option is not considered feasible for the following additional reasons, including the following:

i The most obvious site for processing the slurry would be the existing Crossrail Limmo tunnel site near the mouth of Bow Creek. The availability of this site is a key issue due to the programming of the Crossrail works at the site (due to finish two years after the project begins) and the risk that the site will be promptly developed as it is designated as a Strategic Site by London Borough of Newham.

ii The slurry pipelines from Abbey Mills Pumping Station would need to cross a number of roads and footways, London Underground and mainline railway lines, as well as the Channelsea Creek and Bow Creek. Where the pipelines cross these features, access for maintenance would be restricted and there would be safety and environmental risks should the pipelines leak.

APP80 River Transport Strategy

1.14.17 TW considered SYR's comments in the preparation of the revised draft River Transport Strategy (Doc ref: APP130) which was submitted on 12 February 2014. Changes following SYR comments included further clarification on the composition of the Relevant Authority, such as the details around appointment of the Chairperson and of the Relevant Authority Coordinator, and amendments to the wording of the objective to refer to 'at least' 90 per cent of the specified materials.

1.14.18 A key outstanding concern raised by SYR in its submissions is related to the NPS review. At the DCO hearing on 21 February 2014, submissions were made by TW in response to questions from the ExA and other parties on the NPS review. As promised at the hearing, TW has reviewed the proposals and the NPS review process has been removed from the River Transport Strategy.

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Response: 12 February 2014 submission

Mitigation and compensation policy

1.14.19 In respect of the comments provided by SYR, TW would like to thanks Ms Rita Cruise O‟Brien for organising the recent visits and also representatives from the properties that have allowed access to their homes in order for TW to complete surveys.

1.14.20 We will continue to work with residents to establish TAPs and the team are in conversation with resident representatives in regard to the extent of these for the Chambers Wharf site. The next revision of the Non-statutory Off-site Mitigation and Compensation Policy (Doc ref: APP186) will set out in detail which properties, façades and dwellings (apartments) will be subject to TAPs at Luna House, Axis Court, and 8-14 Fountain Green Square. TAPs are not required for other residential property, as other properties are not identified in the Environmental Statement update report (Doc ref: APP184) as being significantly affected, and the NEWT commitment at Section 2.1 of the CoCP ensures that these properties cannot become significantly affected. This includes the new development in Chambers Street.

1.14.21 We note the reservations made in regard to the compensation process, and we trust that further detail provided in the Unilateral Undertaking will reinforce the independent nature of the Independent Advisory Service (IAS), the Independent Compensation Panel (ICP) and the Independent Complaints Commissioner (ICC). We have provided an extract of their responsibilities below, with further information available in the Non-statutory Off-site Mitigation and Compensation Policy (Doc ref: APP186).

1.14.22 The IAS team are not project employees; they are part of a company called Chainbow. They are providing advice based on their knowledge of the project and their expertise in property management and consultancy. They are aware of the mitigation and compensation policies being provided and are able to advise on the remedies available to address compensation issues that could arise from our proposed construction. The project team is not responsible for any advice given by the IAS.

1.14.23 The ICP shall be independent from the Undertaker and will run throughout construction. The Undertaker will not be responsible for any advice given or decisions made by the ICP.

1.14.24 The Undertaker shall appoint an ICC, whose role will be to ensure that the correct process has been followed where an applicant is not satisfied with the response of the ICP. In such circumstances, an applicant can raise the matter formally with the Commissioner, who will then evaluate the ICP‟s decision-making process in that case. Should the commissioner find that due process has not been followed, then the claim will be resubmitted to the ICP.

1.14.25 The mechanism for the valuation and assessment of an offer for properties to be acquired is contained in the revised version of the Exceptional

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Hardship Procedure (Doc ref: APP189) submitted to the ExA on 3 March 2014.

1.14.26 TW notes the point regarding the trigger levels and further details on these will be included in the final version of the Non-statutory Off-site Mitigation and Compensation Policy (Doc ref: APP186) and the associated new project-wide Requirement (PW17).

Question: 58.1


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1.15 Thames Water response to Thamesbank

Introduction

1.15.1 Submissions by Thamesbank over the examination period have prompted questions from the ExA which we have addressed in previous responses. This note discusses additional submissions made by Thamesbank for the 12 February 2014 deadline and the attached notes from professors Ashley, Binnie and Green to the submissions.

Response

1.15.2 Professor Ashley‟s note on Green Infrastructure (GI) includes recommendation for additional research and study and is not a rebuttal of the work previously produced by the Pennine Group. Although a number of parties have ascribed views to Professor Ashley during the examination, we believe that this is the first time that a document authored by him has been submitted. We note that, despite assertions by others that he has withdrawn the Pennine Water Group report that forms Appendix E of the Needs Report (Doc ref: 8.3), he has not in fact done so.

1.15.3 In his note, Professor Ashley has been selective in his quote on sustainable drainage systems (SuDS) being „technically feasible‟ as the full statement lacks an important continuation of the statement which points out that SuDS did not adequately control CSO discharges. Here is the full statement:

“Overall it is concluded in the present study that it is technically feasible to retrofit stormwater disconnection methods using SUDS which could potentially be effective at reducing the CSO spills into the River Thames. However, spill frequencies are likely to remain above 10 events per typical year even in the areas where the strategy is most practical.” (Page 2 of the Executive Summary of the SuDS report by the Pennine Group: Doc ref: 8.3)

1.15.4 The Executive Summary goes on to say the following which is also reiterated by Professor Ashley as his opening statement of his note:

“There are significant logistical, legal and regulatory impediments to the utilisation of SUDS as proposed, in the short and medium term.”

1.15.5 We agree with this conclusion and Professor Ashley correctly leads with this problem in his note, stating: "Only in London, of the major world cities, is water managed by so many organizations that integration of approaches is fraught with problems."

1.15.6 Implementation of effective Green Infrastructure in London is dependent on having the right institutions in place to do so. Currently, this is uncertain and difficult, and considerable time would be involved in developing a system for implementation, developing mechanisms for paying for the work and, importantly, consulting with the public on the impacts of Green Infrastructure on their properties, streets, parking and open spaces.

http://infrastructure.planningportal.gov.uk/wp-content/ipc/uploads/projects/WW010001/2.%20Post-Submission/Application%20Documents/Other%20Documents/8.3_Needs_Report_Appendix_E_Potential_Source_Control_and_SuDS_Application.pdf



Question: 58.1


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1.15.7 Thamesbank and Professor Ashley suggest methods applied in places such as Philadelphia are transferable to London. The benefits for Philadelphia are highlighted as benefits not realised by the Thames Tideway Tunnel without fully explaining how such benefits, such as avoided asthma attacks, avoidance of deaths from excessive heat and recreational days created, can be transferred to London and particularly how property value increases due to GI can be transferred between boroughs.

1.15.8 An effective (CSO) area-wide GI programme would consider more GI in some boroughs because they could affect rainfall run-off more effectively than GI in more difficult locations in other boroughs. Therefore, the benefits derived, for example, property value increases, would be limited to one borough, whereas the control of CSO is a system-wide problem. The transference of the social benefits gained in one borough across to all boroughs would be problematic.

1.15.9 The many subjective benefits of GI may be socially worthwhile for London but even if the Philadelphia proposals are fully investigated, the Philadelphia plan fails in controlling CSOs to the number and volume of spills to meet the minimum CSO control requirements set by the US Environmental Protection Agency6. The Philadelphia plan (see page 17 of The City of Philadelphia‟s Program for Combined Sewer Overflow Control: A long term Control Plan Update: Summary Report, September 2009) mentions 5 to 8 billion gallons of CSO are removed but the Philadelphia CSO problem amounts to 10 to 16 billion gallons (Philadelphia‟s June 2011 Consent Order and Agreement). Control of 50 per cent of the problem implies some significant additional work will be required. As experienced in Portland, Oregon, GI took care of around 35 per cent of the CSO problem and was deficient in meeting the regulatory requirements for controlling CSOs and a tunnel system was also built.

1.15.10 Professor Green‟s note brings to light (probably for the first time by Thamesbank) the potential costs for implementing even limited GI (roof disconnections and water harvesting for selective uses). He estimates a surcharge of around £75 per year on water bills would be needed to implement this limited GI programme. His suggestion only removes selective roofs from the system and acknowledges the problems with road drainage in central London. His proposal therefore leaves streets, parking lots and other areas connected to the sewerage system. As in Philadelphia and Portland, his proposal would only address a proportion of the CSO problem and would leave an unacceptable level of CSO discharges. However, this would still cost the average customer £75 per year. As in Philadelphia and Portland, Professor Green has pushed the cost of implementing Green Infrastructure onto the property owner/water bill payer.

1.15.11 Professor Green‟s paper focuses on roofs and suggests a cost of £200 per m2 of roof (or £8,000 for the average 40m2 roof -- his numbers). We are not convinced that plumbing a London building for flushing toilets and

6 US EPA CSO control requires a minimum 85 per cent volume capture or no more than four events on average

in a year. Individual states can set higher control requirements.

Question: 58.1


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laundry can be done for £8,000. In addition, water harvested for laundry we suggest would need treatment. His paper is mainly on how such a programme could be financed by starting a new billing method based on an impermeable area charge. The more area a property owner has, the more his bill would be, with the perception that, by paying for controlling flows, the owner can reduce its water bill. This is a similar approach used in Portland where „stormwater‟ charges are a significant portion of property owners‟ water bills. This method of charging has already been implemented in some areas in this country for non-household customers.

1.15.12 Professor Green‟s paper is primarily a costing paper and it does not clearly state what CSO control can be achieved -- he does mention a number of 510,000m3 of runoff is removed from the sewers -- but simply says the target for CSO control is achieved in six years by doing work on roofs. We appreciate his attempt of highlighting the likely costs for implementing a partial programme of rainwater harvesting but believe this analysis is limited for numerous reasons, including insufficient knowledge of the full extent of the CSO problem, the institutional barriers in setting a stormwater charge for London, gaining public acceptance of using captured roof drainage for internal uses, and would only provide a partial solution that would not materially change the need for the project.

1.15.13 To illustrate this, we have worked back through his logic and believe the implication is that the run-off from 425,000 roofs is removed from the sewerage system. The volume of rainfall run-off removed he estimates at 510,000m3 (at 1.2m3 removal per 40m2 roof). This run-off volume is less than a third of the tunnel storage that is filled during a 30mm storm over the catchment. During such a storm, tunnel storage is filled to capacity and then discharges to the tidal Thames would occur (estimated at over 2 million m3 for this single large event). This large event would fill the Thames Tideway Tunnel and the Lee Tunnel and residual discharges would occur. The two tunnels have about 1.5 million m3 of storage, 1.2 million m3 of which is storage within the Thames Tideway Tunnel, and the full storage capacity of the tunnels is utilised during the event. With the roof disconnection proposed, it is implied that there is no Thames Tideway Tunnel: If this is true then an additional 1 milliom m3 of discharge would occur (based on 1.5 million m3 of tunnel storage not present, less the 510,000 milliom m3 of run-off controlled by the proposed roof disconnection).

1.15.14 Thamesbank, in its 12 February 2014 submission (point 37 of its submission), reiterates Professor Binnie‟s suggestion that a reduction in sewer flows is likely rather than an increase in flows due to population increase, and that this increase in flow is a contributing factor for the need for the Thames Tideway Tunnel. We do not agree with this as the problem of discharges is with today‟s system and existing population and, even if sewer flows could be decreased, CSO discharges would continue to be unacceptable.

1.15.15 The discussion on water use and sewage flows have, in the past, been discussed with Professor Binnie in earlier versions of his report, which is attached to the Thamesbank submission (see Costs and benefits analysis

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with addenda 1,2,3,4,5,6,and 7: Chris Binnie, 11 February 2014). In these discussions, we have noted that it is when it rains, the system overflows and adjustments to the foul flow rates per capita have very limited effect on CSO frequency, durations and volumes. We have presented to Professor Binnie sensitivity analysis of the effects of reduction in dry weather foul sewage flow to show that CSOs during the typical year are reduced but are still large, and continue to show the need for the Thames Tideway Tunnel. We demonstrated to Professor Binnie that if the overall dry weather foul sewage flow per capita is reduced by 26 per cent (from an average of 180 l/person/day to 130 l/person/day) and the total catchment infiltration base flow halved from 9m3/s to 4.5m3/s, the total typical year CSO discharge from the system is changed from 18 million m3 to about 13 million m3, with over 52 discharge events occurring in a typical year. These values assume that the Beckton and Crossness works improvements and Lee Tunnel are fully operational, otherwise the reduction in CSO discharges would be less significant. This radical, and totally unrealistic, reduction in base foul flow is insufficient to comply with the Urban Waste Water Treatment Directive.

Question: 58.1


85

1.16 Thames Water response to Western Riverside Waste Authority

Introduction

1.16.1 This is a response to a representation submitted by Western Riverside Waste Authority (WRWA) dated 11 February 2014 including the appended relevant representation (Representation no. 743) dated 25 May 2013.

Response

1.16.2 TW discussed the concerns identified in WRWA‟s relevant representation (Representation No. 743) with WRWA at the meeting of the 15 July 2013. A full detailed response to the representation is now provided below and the meeting minutes are now being forwarded to WRWA.

1.16.3 Regarding the 8 October 2013 WRWA response, WRWA has clarified that this was actually a representation to the Northern Line Extension project.

1.16.4 TW has been in liaison and discussions with Cory Environmental Limited as WRWA‟s waste management contractor since January 2011. Cory had provided detailed written submissions to the project at all stages of pre-application from the phase one consultation, and made further submissions to the Planning Inspectorate.

1.16.5 The intention of the Statement of Common Ground (SoCG) with Cory Environmental Ltd is to assist the ExA with a summary of the issues for the examination. TW provided the initial draft of a SoCG on 29 August 2013 but this has not been finalised.

1.16.6 The ExA requested a specific SoCG between Thames Water and Cory on the issues around navigation around the Blackfriars Bridge Foreshore site. This was submitted on 13 January 2014.

1.16.7 Following the meeting with WRWA on 15 July 2013, as no further written representation to the Planning Inspectorate had been sent by WRWA to the ExA, it was assumed that the concerns of WRWA had been clarified.

1.16.8 We apologise for the oversight and TW would welcome a meeting with WRWA to discuss any outstanding issues that are not resolved in our response below.

Relevant Representation (Representation no. 743)

1.16.9 This section is a response to the concerns identified in the relevant representation (Representation no. 743) appended to the representation submitted by Western Riverside Waste Authority to the ExA dated 11 February 2014.

Overloading of road network in the Kirtling Street area

1.16.10 A detailed and robust assessment was carried out and the findings were presented in the project‟s Transport Assessment and the Environmental Statement included within the application for development consent (see

Question: 58.1


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Doc refs: 7.10.11 and 6.2.14 which cover the Kirtling Street site). This includes a description of the likely significant effects of the development on the environment, which includes a minor adverse effect on highway users at the Kirtling Street site. The approach to determining future traffic levels arising from planned developments, and in sensitivity testing which considers effects if barge movements are restricted, are described below.

Highway network

1.16.11 The approach, used in the Transport Assessment, in modelling the highway network at a strategic level has been based on the use of Transport for London‟s Highway Assignment Models (HAMs). These models are used by TfL to predict future highway network conditions and have been developed using GLA employment and population forecasts, which are based on the employment and housing projections set out in the London Plan.

1.16.12 Additionally, for the assessment of the project worksite at Kirtling Street, in agreement with TfL and LB Wandsworth, specific account has been taken of development proposals in the Nine Elms Opportunity Area and surroundings. This has been done to ensure that the modelling of the local highway network and demands around those sites is reasonably representative of future conditions. See paras. 14.3.15 to 14.3.24 of the Kirtling Street Transport Assessment (Doc ref: 7.10.11).

Sensitivity testing

1.16.13 The Transport Assessment presents the assessment of the transport effects of the project‟s Transport Strategy (Doc ref: 7.09). For those 11 sites, including Kirtling Street, where the Transport Strategy assumes a certain level of transport by river, the assessment has also tested an „all by road‟ scenario to examine the effects of the project, in the event that disruption to river transport at one or more worksites would mean that additional road transport for construction materials is necessary for a given period of time. This may be due to events such as planned closures or restrictions on the river (eg, maintenance of Thames Barrier), incidents from river transport, shortage of vessels or trained crew, local issues preventing river access to a site (eg,. equipment failure), etc. However, if any such issue arises, it is likely that this would be a short-term occurrence. Furthermore, these issues are unlikely to affect river transport at all relevant worksites at the same time or in the same way.

1.16.14 The sensitivity testing of traffic flows was based on a scenario whereby „all by road‟ traffic figures are assumed for one month. This represents a short to medium term loss of river transport at all worksites, with the construction lorry movements represented by the Transport Strategy occurring over the remaining 11 months of the year. The „all by road‟ sensitivity test therefore represents the highest 11 months of the Transport Strategy, plus the highest month of the „all by road‟ scenario, to make it as robust as possible.

1.16.15 The assessment indicates that, in this worst-case test, the main junctions with Nine Elms Lane and local network continue to operate within capacity, albeit with some additional delay.

http://infrastructure.planningportal.gov.uk/wp-content/ipc/uploads/projects/WW010001/2.%20Post-Submission/Application%20Documents/Other%20Documents/7.10.11_Transport_Assessment_Kirtling_Street.pdf

http://infrastructure.planningportal.gov.uk/wp-content/ipc/uploads/projects/WW010001/2.%20Post-Submission/Application%20Documents/Environmental%20Statement/6.2.14_Environmental_Statement_Volume_14_Kirtling_Street_Site_Assessment_Sections_1_to_15.pdf

http://infrastructure.planningportal.gov.uk/wp-content/ipc/uploads/projects/WW010001/2.%20Post-Submission/Application%20Documents/Other%20Documents/7.10.11_Transport_Assessment_Kirtling_Street.pdf

http://infrastructure.planningportal.gov.uk/wp-content/ipc/uploads/projects/WW010001/2.%20Post-Submission/Application%20Documents/Other%20Documents/7.09_Transport_Strategy.pdf

Question: 58.1


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1.16.16 The implementation of the river transport is controlled by processes which are set out in the River Transport Strategy (update 3 March, Doc ref: APP180.2), such as contingency planning. The aims of these processes are to ensure that an event which could potentially give rise to an operational derogation is sufficiently mitigated to reduce the need for, or extent of, any operational derogation. It also ensures that the use of HGVs for an operational derogation is only implemented where necessary. This means that only when all mitigation and alternative options have been considered and adopted as appropriate, as a last resort, some of the specified materials may have to be transported by road instead of river for a short period. The River Transport Strategy cannot result in an exceedance of the worst-case assessment of effects set out in the Environmental Statement.

Impediment to river access to the WRWA’s Cringle Dock Transfer Station

1.16.17 This has been reviewed and assessed in the Navigational Issues and Preliminary Risk Assessment for Kirtling Street and Heathwall Pumping Station sites. These documents have been included in the application for development consent (Section 7.20.04 for Kirtling Street and Section 7.20.08 for Heathwall Pumping Station).

1.16.18 The work undertaken includes an assessment of the Cory Environmental Limited existing operations at Kirtling Street, Smugglers Way and Walbrook Wharf, and also details the consultations undertaken on the jetty design and location.

1.16.19 The LLAU at this location has been amended to take into account the Cory Environmental representation during phase two consultation.

1.16.20 In summary, the site layout and restrictions on working areas within the foreshore have been determined to eliminate any potential impact on the operation of Cringle Dock.

Impingement on the authority’s lighterage operations

1.16.21 The project has modelled the increased vessel movements along the river using the PLA vessel model. The assessment has included potential growth in existing commercial and passenger vessels, predicted river traffic from Battersea Power Station development and the Northern Line Extension. The results show that the additional river traffic can be safely accommodated. The assessment has been reviewed with the PLA.

1.16.22 We intend to agree with Cory Environmental Limited protocols for communicating and coordination of the river operations, both at specific sites, such as Kirtling Street, and across the project.

1.16.23 Where the works extend into the navigational channels, the impacts have been assessed and are included in the site-specific Navigational Issues and Preliminary Risk Assessments, Section 7.20.05 of the Draft DCO. The PLA has been consulted during the development of these assessments.

http://infrastructure.planningportal.gov.uk/wp-content/ipc/uploads/projects/WW010001/2.%20Post-Submission/Application%20Documents/Other%20Documents/7.20.04_Navigational_Issues_and_Preliminary_Risk_Assessment_Kirtling_Street_Main_Report_and_Appendices.pdf

http://infrastructure.planningportal.gov.uk/wp-content/ipc/uploads/projects/WW010001/2.%20Post-Submission/Application%20Documents/Other%20Documents/7.20.08_Navigational_Issues_and_Preliminary_Risk_Assessment_Heathwall_Pumping_Station_Main_Report_and_Append

Question: 58.1


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1.16.24 At Carnwath Road Riverside, the assessment covers the option for campsheds and jetties and, in doing so, addresses the worst case for navigation.

1.16.25 Determining the most appropriate delivery strategy with respect to selection of tugs, barges and motorised vessels is best undertaken by the appointed contractor and river transport suppliers. As stated above, the potential impact on existing river operations has been assessed.

1.16.26 See response on the assessment of the „all by road‟ case in paras. 1.16.13 to 1.16.16 above.

Road deliveries to and from the Smugglers Way transfer station

1.16.27 The assessment for the worksite at Carnwath Road Riverside indicates that approximately 441 additional daily movements would be produced by the construction works. It should be noted that close to a half of these are attributed to worker vehicle movements. These worker vehicle movements are very unlikely to materialise to this extent (Doc ref: 7.10.07) as the project has Requirements for worker travel plans and arrangements to access the site as Schedule 3 of the Draft DCO, Requirement CARRR9 requires that a construction force travel plan is submitted to and approved by the council, prior to development commencing.

1.16.28 The Wandsworth Bridge Road (A217)/Carnwath Road/Townmead Road junction in the construction base case (future scenario without the scheme) would be operating over capacity during the AM peak hour and within capacity during the PM peak hour. The addition of project construction traffic (anticipated to be 45 construction vehicle trips [90 movements] during the peak hours) results in an overall increase in delay of two seconds per vehicle in the PM peak hour. On any one arm, the maximum delay is fourteen seconds per vehicle in the AM peak hour. The project-wide assessment (see Doc ref: 7.10) indicates that this will not give rise to significant delays on the wider strategic network in the vicinity of Smugglers Way Transfer Station.

Scale of permanent above-ground structures at Kirtling Street

1.16.29 The proposed permanent structures at Kirtling Street are a combined ventilation column and electrical and control kiosk (with a maximum height of 4m) and a concrete batching plant (with a maximum height of 30m). The parameters for the proposed permanent structures are defined on the Site works parameter plan (Book of Plans – Section 15 DCO-PP-13X-KRTST-150005-Rev1 January 2014).

1.16.30 The parameters for the permanent structures have been designed to maintain the viability of Kirtling Wharf as a safeguarded wharf and to minimise impacts on surrounding developments, while maintaining operational requirements.

1.16.31 The Environmental Statement, Volume 14, Kirtling Street site assessment (Doc ref: 6.2.14) assesses the permanent townscape and visual impacts of the proposed works at Kirtling Street as negligible or minor beneficial.

http://infrastructure.planningportal.gov.uk/wp-content/ipc/uploads/projects/WW010001/2.%20Post-Submission/Application%20Documents/Other%20Documents/7.10.07_Transport_Assessment_Carnwath_Road_Riverside.pdf

http://infrastructure.planningportal.gov.uk/wp-content/ipc/uploads/projects/WW010001/2.%20Post-Submission/Application%20Documents/Other%20Documents/7.10.07_Transport_Assessment_Carnwath_Road_Riverside.pdf

http://infrastructure.planningportal.gov.uk/wp-content/ipc/uploads/projects/WW010001/2.%20Post-Submission/Application%20Documents/Other%20Documents/7.10_Transport_Assessment_Main_Report.pdf

http://infrastructure.planningportal.gov.uk/wp-content/ipc/uploads/projects/WW010001/2.%20Post-Submission/Application%20Documents/Environmental%20Statement/6.2.14_Environmental_Statement_Volume_14_Kirtling_Street_Site_Assessment_Sections_1_to_15.pdf

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1.16.32 In addition, a planning application (ref: 2013/4545) has been submitted to the London Borough of Wandsworth for the construction of the concrete batching plant as early work, prior to the commencement of the main works sought as part of the application for development consent.

1.16.33 The planning application was reported to the council‟s Planning Committee on 20 January 2014 and the Committee resolved to grant planning permission, subject to a legal agreement and the 21 conditions recommended in the case officer‟s committee report and addendum.

1.16.34 The council considered that: “the design, townscape and visual impacts of the new facility are considered to be acceptable, in accordance with CS policy IS3, and DMPD policies DMS1 & DMO6.

“It is not considered that the proposal would have a significantly detrimental impact on the future development of surrounding sites, including with regard to the safeguarded wharf status of the site.” (paras 11.2 and 11.3 of the Committee Report).

1.16.35 The Committee Report also makes clear that: “the, current policy, including the London Plan, are clear in defining that development next to or opposite a safeguarded wharf should be designed to minimise the potential conflicts of use and disturbance, and that any new development should ensure it does not prejudice the operation of the safeguarded wharves. The recent Safeguarded Wharves Review (2013) has confirmed the safeguarded status of Kirtling Wharf and Cringle Dock, and confirms that these Nine Elms wharves will continue to be safeguarded. In terms of development around a safeguarded wharf; the onus is clearly on the developers of the surrounding land to incorporate appropriate mitigation within their development while ensuring their development does not prejudice the operation of the safeguarded wharf” (para. 4.5).

https://planning.wandsworth.gov.uk/WAM/doc/Committee%20Report-2619872.pdf?extension=.pdf&id=2619872&location=VOLUME8&contentType=application/pdf&pageCount=1

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90

1.17 Thames Water response to Wrayburn Residents Together

Overview

1.17.1 This document provides a response to the written submission to the ExA by Larry Broomhead of Wrayburn Residents Together (WRT).

1.17.2 TW met with Mr Broomhead and the London Borough of Southwark (LB Southwark) at his home on 17 January 2014 to discuss concerns relating to the proposed construction works, and to explain the proposed on-site mitigation proposals at Chambers Wharf and the project-wide policy on compensation. Following the meeting, Mr Broomhead sent a letter to Phil Stride, along with a summary of the meeting. This letter and the summary of the meeting are attached to the WRT submission. It should be noted that the summary of the meeting has not been agreed by TW as an accurate record of the meeting.

1.17.3 In addition, TW received an email from the LB Southwark on 22 January 2014, further to Mr Broomhead‟s request that should the respective noise thresholds be triggered, TW funds the financial difference between a lower and higher specification of double-glazing proposed to be installed at Wrayburn House by the LB Southwark as freeholders of Wrayburn House. TW provided a response in Appendix D to the Statement of Common Ground (Doc ref: APP144) with LB Southwark, submitted to the ExA on 12 February 2014. TW also sent a letter of response to Mr Broomhead on 26 February 2014, which was copied to the LB Southwark. The letter is attached to this submission for information (see Appendix H).

Response

1.17.4 This response does not repeat material published elsewhere, or in the response letter to Mr Broomhead dated 26 February 2014, but provides a response to any new matters raised.

Validity of traffic survey data

1.17.5 The WRT submission states:

“Following a recent closure of a local „rat-run‟ we are of the opinion that the data is not accurate and recommend that a new traffic survey (of current vehicles using Bevington Street) be conducted by Thames Water”.

1.17.6 The traffic flow measured along Bevington Street and reported in the Transport Assessment (TA) (Doc ref: 7.10.17) and Environmental Statement (ES) (Doc ref: 6.2.10) was around 100 vehicles exiting and 170 entering Bevington Street at the Jamaica Road junction in the AM peak hour period. In the PM period, this was approximately 80 exiting and 150 entering in the peak hour period. Of this traffic, approximately 50 vehicles in each direction (in both the AM and PM peak periods) were surveyed at the Bevington Street/Chambers Street junction, indicating that the majority of vehicles use Scott Lidgett Crescent and do not continue along Bevington Street.

http://infrastructure.planningportal.gov.uk/wp-content/ipc/uploads/projects/WW010001/2.%20Post-Submission/Representations/Comments/Responses%20to%20ExA%20Questions/03-02-2014%20-%20Comments%20on%20Responses%20to%20the%202nd%20Round%20of%20Questions/APP144%20Statement%20of%20Common%20Ground%20w

http://infrastructure.planningportal.gov.uk/wp-content/ipc/uploads/projects/WW010001/2.%20Post-Submission/Representations/Comments/Responses%20to%20ExA%20Questions/03-02-2014%20-%20Comments%20on%20Responses%20to%20the%202nd%20Round%20of%20Questions/APP144%20Statement%20of%20Common%20Ground%20w

http://infrastructure.planningportal.gov.uk/wp-content/ipc/uploads/projects/WW010001/2.%20Post-Submission/Application%20Documents/Other%20Documents/7.10.17_Transport_Assessment_Chambers_Wharf.pdf

http://infrastructure.planningportal.gov.uk/wp-content/ipc/uploads/projects/WW010001/2.%20Post-Submission/Application%20Documents/Environmental%20Statement/6.2.20_Environmental_Statement_Volume_20_Chambers_Wharf_Site_Assessment_Sections_1_to_15.pdf

http://infrastructure.planningportal.gov.uk/wp-content/ipc/uploads/projects/WW010001/2.%20Post-Submission/Application%20Documents/Environmental%20Statement/6.2.20_Environmental_Statement_Volume_20_Chambers_Wharf_Site_Assessment_Sections_1_to_15.pdf

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1.17.7 During preparation of the TA and ES, we were not made aware of any road closures that have been or were due to be implemented, or of a specific rat-running issue along Bevington Street during consultation with the LB Southwark transport officers.

1.17.8 The WRT also states:

“We are also unsure where the figure of 1,375 vehicles a day using Bevington Street has come from and would like clarification on the survey methodology”.

1.17.9 The TA and transport section of the ES used hourly flows on the minor roads for assessment purposes rather than daily volumes, as detailed in the answer to the first part of the question. It is therefore not known where the 1,375 figure quoted has been taken from.

1.17.10 A survey period of 7am to 7pm was used as it is the recognised practice and is sufficient to capture the peak movements (of both vehicles and pedestrians) through a junction and provide a robust enough snapshot of the volume, composition and direction with which to make an assessment of performance. We extended the survey periods deliberately for this project to cover out-of-hours working periods (from 7pm to 12am), just in case these were needed at a later date for assessment. We count the peak periods 7am to 10am and 4pm to 7pm as they are typically the busy periods. The other time periods have been recorded but not used as they represent lower movement volumes compared to the peak hours.

1.17.11 The traffic flows taken from the surveys and used in the assessment are peak hour flows; for example, the AM peak hour is 8am to 9am. Accordingly, the total flows counted in this hour are used in the models. The figures refer to actual measured movements and are not an average calculated from the total flow over the day (or anything similar).

Vulnerable residents

1.17.12 The WRT submission states that there is a high number of „vulnerable‟ residents living at Wrayburn House who will be affected by the project works. As highlighted in our letter of 26 February 2014 to Mr Broomhead, the Environmental Statement, Chambers Wharf, Vol 20 (Doc ref: 6.2.20) does not identify significant effects on the residents of Wrayburn House as a result of the proposed works at Chambers Wharf.

1.17.13 An update to the Environmental Statement (Doc ref: APP184) was issued to the ExA on 3 March 2014, which takes into account all changes to the scheme compensation policy and the additional mitigation proposed at Chambers Wharf since submission of the application for development consent. Refer to Appendix H for further detail.

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Question: 58.2


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2 Question: 58.2

We refer to the Applicant‟s response to the ExA's second written question Q23.1 in which the Applicant set out in the document entitled "Annex 1 responses" the position with regard to all the objections made to the request for compulsory acquisition powers.

Can the Applicant provide an update of the document in relation only to compulsory acquisition objections ie those made by Affected Persons. Where an objection is withdrawn written evidence from the objector to this effect must also be provided. This information is to be provided on or before 3 March 2014.

2.1 Our response

2.1.1 We have followed the same approach that we used to complete the Annex 1 responses schedule, submitted on 13 January 14. The updated schedule has been filtered to show only those affected by compulsory acquisition and we have provided updated comments in the „3 March written response‟ column.

Question: 58.2


94


Question: 58.2


95

No. Borough Name/Organisation Link to representation 3 March written response Compulsory acquisition

1 General/Cross Canal and River Trust http://infrastructure.planningportal.gov.uk/projects/london/thames-tideway-tunnel/?ipcsection=relreps&relrep=474

Heads of Terms are agreed and a property agreement and asset protection agreement are now in the advanced stages of progress. These documents are unlikely to be completed before the close of the examination.

The Heads of Terms addresses the information set out in the draft s127 Schedule already submitted to the ExA and provides confirmation that the details from the Book of Reference are accurate.

Yes

2 General/Cross Environment Agency http://infrastructure.planningportal.gov.uk/projects/london/thames-tideway-tunnel/?ipcsection=relreps&relrep=713

We are still in discussions. Heads of Terms are agreed in principle. Formal agreement from LB Wandsworth to access at Barn Elms awaited and is the only outstanding issue.

Yes

3 General/Cross National Grid http://infrastructure.planningportal.gov.uk/projects/london/thames-tideway-tunnel/?ipcsection=relreps&relrep=1160

Since the attendance by National Grid at the CA hearings during w/c 14 January we have been in dialogue to agree the information recorded in the Book of Reference. This exercise has now been completed and we have agreement as to the accuracy of the s127 and s138 schedules. This will necessitate a number of changes from those draft versions previously submitted to the ExA and the updated schedules will be submitted for 3 March 2014.

Yes

4 General/Cross Network Rail http://infrastructure.planningportal.gov.uk/projects/london/thames-tideway-tunnel/?ipcsection=relreps&relrep=710

Further meeting with Network Rail Property on 6 February 2014, agreement in principle on property interface and on basis of acquisition. Draft Head of Terms prepared and under review. The withdrawal of the representations is dependent on the asset protection agreement, protected provisions and interface agreement being agreed.

Yes

5 General/Cross Port of London Authority http://infrastructure.planningportal.gov.uk/projects/london/thames-tideway-tunnel/?ipcsection=relreps&relrep=1088

Our negotiations with representatives of the PLA have been continuing but save for the areas of agreement set out in the Statement of Common Ground there has been little progress towards the intended property agreement. This is due primarily to a point of principle as to the appropriate basis for the assessment of compensation. Some weeks ago both parties recognised that this point was unlikely to be resolved within the timescale of the Examination and discussions have continued on the basis that third party determination will be relied upon if no consensus emerges within the next few months. In all other respects we are still working towards agreement with the PLA and do not envisage the lack of a property agreement at this stage holding up the ability to proceed with the project.

The SoCG confirms that the PLA has no objection to the compulsory acquisition of its land for the project but we have yet to obtain confirmation that the s127 schedule is an accurate record of the PLA ownership interests within the LLAU.

Yes

6 General/Cross Transport for London http://infrastructure.planningportal.gov.uk/projects/london/thames-tideway-tunnel/?ipcsection=relreps&relrep=709

We are working with Transport for London to agree the Overarching Framework Agreement. The Property Heads of Terms are agreed in principle and the Property team are progressing s127/138 schedules.

Yes

7 Ealing Martin C Grierson http://infrastructure.planningportal.gov.uk/projects/london/thames-tideway-tunnel/?ipcsection=relreps&relrep=36

Position remains as advised in our January 2014 submission. No further contact has been made by the project. Yes

8 Richmond upon Thames

Susan Antell/Sue Antell http://infrastructure.planningportal.gov.uk/projects/london/thames-tideway-tunnel/?ipcsection=relreps&relrep=679

The correspondent was contacted on 31 January 2014 by letter with further information on the project based upon their representation. No further correspondence has been received by the project.

Yes


Michael Bainbridge http://infrastructure.planningportal.gov.uk/projects/london/thames-tideway-tunnel/?ipcsection=relreps&relrep=895


Yes


Tony Barry http://infrastructure.planningportal.gov.uk/projects/london/thames-tideway-tunnel/?ipcsection=relreps&relrep=597


Yes


Peter Borgers http://infrastructure.planningportal.gov.uk/projects/london/thames-tideway-tunnel/?ipcsection=relreps&relrep=591


Yes


John Hugh Darnton http://infrastructure.planningportal.gov.uk/projects/london/thames-tideway-tunnel/?ipcsection=relreps&relrep=620


Yes

Question: 58.2


96



Katie DeAlberqueque http://infrastructure.planningportal.gov.uk/projects/london/thames-tideway-tunnel/?ipcsection=relreps&relrep=614


Yes


Judith Enright http://infrastructure.planningportal.gov.uk/projects/london/thames-tideway-tunnel/?ipcsection=relreps&relrep=585


Yes


Malcolm Hamer http://infrastructure.planningportal.gov.uk/projects/london/thames-tideway-tunnel/?ipcsection=relreps&relrep=783


Yes


The Mercers Company http://infrastructure.planningportal.gov.uk/wp-content/ipc/uploads/projects/WW010001/2.%20Post-Submission/Representations/Written%20Representations/131104_WW010001_WR_The%20Mercers%20Company.pdf


Yes


Christopher Owen http://infrastructure.planningportal.gov.uk/projects/london/thames-tideway-tunnel/?ipcsection=relreps&relrep=581


Yes


Heather Parkinson http://infrastructure.planningportal.gov.uk/projects/london/thames-tideway-tunnel/?ipcsection=relreps&relrep=929


Yes


Cllr Christine Percival http://infrastructure.planningportal.gov.uk/projects/london/thames-tideway-tunnel/?ipcsection=relreps&relrep=459


Yes


Charles Nicolas Robertson http://infrastructure.planningportal.gov.uk/projects/london/thames-tideway-tunnel/?ipcsection=relreps&relrep=603


Yes


Ann Rothwell http://infrastructure.planningportal.gov.uk/projects/london/thames-tideway-tunnel/?ipcsection=relreps&relrep=85


Yes


Josephine Talbot http://infrastructure.planningportal.gov.uk/projects/london/thames-tideway-tunnel/?ipcsection=relreps&relrep=608


Yes


Wimbledon Putney Commons Conservators

http://infrastructure.planningportal.gov.uk/wp-content/ipc/uploads/projects/WW010001/2.%20Post-Submission/Representations/Written%20Representations/131024_WW010001_WR_Wimbledon_Putney_Commons_Conservatives.pdf


Yes

24 Hounslow Karen Brown http://infrastructure.planningportal.gov.uk/projects/london/thames-tideway-tunnel/?ipcsection=relreps&relrep=1023

The correspondent was contacted on 31 January 2014 by letter with further information on the project based upon their representation. A settlement deed has been sent to Ms Brown for completion. No further correspondence has been received by the project.

Yes

25 Hounslow Gavin Charles Alexander Campbell

http://infrastructure.planningportal.gov.uk/projects/london/thames-tideway-tunnel/?ipcsection=relreps&relrep=694

The correspondent was contacted on 31 January 2014 by letter with further information on the project based upon their representation. A settlement deed has been requested and has been sent to the correspondent. No further correspondence has been received by the project.

Yes

Question: 58.2


97


26 Hounslow Liz Campbell http://infrastructure.planningportal.gov.uk/projects/london/thames-tideway-tunnel/?ipcsection=relreps&relrep=693

The correspondent was contacted on 31 January 2014 by letter with further information on the project based upon their representation. A settlement deed has been sent to the correspondent. No further correspondence has been received by the project.

Yes

27 Hounslow M E Landy http://infrastructure.planningportal.gov.uk/projects/london/thames-tideway-tunnel/?ipcsection=relreps&relrep=808

The correspondent was contacted on 31 January 2014 by letter with further information on the project based upon their representation. A settlement deed has been sent to Mrs Landy for completion. No further correspondence has been received by the project.

Yes

28 Hounslow John Lee http://infrastructure.planningportal.gov.uk/projects/london/thames-tideway-tunnel/?ipcsection=relreps&relrep=793

The correspondent was contacted on 31 January 2014 by letter with further information on the project based upon their representation. A Settlement Deed has been sent to Mr Lee. No further correspondence has been received by the project.

Yes

29 Hounslow Angus Margerison http://infrastructure.planningportal.gov.uk/projects/london/thames-tideway-tunnel/?ipcsection=relreps&relrep=1155


Yes

30 Hounslow Chiara Visioni http://infrastructure.planningportal.gov.uk/projects/london/thames-tideway-tunnel/?ipcsection=relreps&relrep=353

The correspondent was contacted on 31 January 2014 by letter with further information on the project based upon their representation. A settlement deed has been entered into with Ms Visioni.

Yes

31 Hounslow Josephine Elsie Winstanley http://infrastructure.planningportal.gov.uk/projects/london/thames-tideway-tunnel/?ipcsection=relreps&relrep=550


Yes

32 Hounslow Robert James Winstanley http://infrastructure.planningportal.gov.uk/projects/london/thames-tideway-tunnel/?ipcsection=relreps&relrep=549


Yes

33 Hammersmith and Fulham

London Borough of Hammersmith and Fulham


Heads of Term agreed and legal due diligence progressing. Contract documentation is still awaited, with exchange now anticipated in April/May 2014. The representations will therefore not be withdrawn.

Yes


Victor Lunn-Rockliffe http://infrastructure.planningportal.gov.uk/projects/london/thames-tideway-tunnel/?ipcsection=relreps&relrep=938


Yes


Nortrust Nominees Limited


Legal due diligence at an advanced stage with contracts awaited to facilitate an anticipated exchange of contracts in April/May 2014. The representations will therefore not be withdrawn.

Yes


Royal London Mutual Insurance Society Limited


We can confirm that agreement with the Royal London Mutual Insurance Society Limited is at an agreed Heads of Terms stage, with formal legal agreement being expected to be completed at the end of March 2014.

Yes

37 Wandsworth Mark Barrett http://infrastructure.planningportal.gov.uk/projects/london/thames-tideway-tunnel/?ipcsection=relreps&relrep=1147

We wrote to Mr Barrett on 30 January 2014 providing details of our updated mitigation and compensation policies and the Independent Advisory Service. Noise surveys were undertaken on Nine Elms Pier by Arup in January 2014 which will input into Trigger Action Plans. We have arranged a further meeting with the Directors of Nine Elms Pier Ltd on 25 March 14.

Yes

38 Wandsworth The Battersea Barge http://infrastructure.planningportal.gov.uk/projects/london/thames-tideway-tunnel/?ipcsection=relreps&relrep=562

Meetings were held in spring/summer 2013 with Battersea Barge and St James (who control access to the vessel) to discuss the relocation of the barge 7m to the west. Battersea Barge understood the requirement for them to move and indicated that they would like this to happen as late as possible prior to the start of our construction works. St James stated that they would prefer the move to take place as soon as possible so as to coincide with their re-landscaping of the riverbank. Any move prior to the start of our construction works would need agreement between St James and Battersea Barge and require a separate planning permission to be submitted to London Borough Wandsworth. We will continue to actively engage with both parties to establish a mutually agreeable solution.

Yes

Question: 58.2


98


39 Wandsworth Battersea Project Land Company Limited


We are in detailed dialogue with the Battersea Project Land Company. Heads of Terms for acquisition of the four affected Battersea Project Land Company land parcels are agreed and legal contracts are being progressed. Completion of the legal agreement for the occupational rights and the subsequent permanent rights required for the tunnel is expected in April 2014.

Yes

40 Wandsworth Cemex UK Operations Limited


Contracts for the lease of the CEMEX site and provision of the concrete replacement plant progressing to finalisation. Completion expected April 2014.

Yes

41 Wandsworth Cory Environmental Holdings Limited


The Statements of Common Grounds (SoCG) for all matters general (Cory/TWUL) , and the multiparty SoCG (PLA/Cory/TWUL) for Blackfriars only have not been signed by Cory due to outstanding issues in the Heads of Terms, we are continuing to negotiate on the Heads of Terms.

The multiparty SoCG on Blackfriars has been submitted to PINS with signatures from the PLA and ourselves.

Yes

42 Wandsworth Jamie Darke on behalf of Nine Elms Pier Ltd

http://infrastructure.planningportal.gov.uk/wp-content/ipc/uploads/projects/WW010001/2.%20Post-Submission/Representations/Written%20Representations/131104_WW010001_WR_Nine%20Elms%20Pier%20Ltd.pdf

We wrote to Mr Darke on 30 January 2014 providing details of our updated mitigation and compensation policies and the Independent Advisory Service. We have arranged a further meeting with the Directors of Nine Elms Pier Ltd on 25 March 14.

Yes

43 Wandsworth Michael Davies http://infrastructure.planningportal.gov.uk/projects/london/thames-tideway-tunnel/?ipcsection=relreps&relrep=15

It has been confirmed that since our 13 January 2014 response Mr Davies has passed away. We have had no communication from his family and his houseboat remains on the mooring subject to the lease from Chris Livett.

Yes

44 Wandsworth Bill Dunster http://infrastructure.planningportal.gov.uk/projects/london/thames-tideway-tunnel/?ipcsection=relreps&relrep=1118

We wrote to Mr Dunster, a Director of Nine Elms Pier Ltd, on 30 January 2014 providing details of our updated mitigation and compensation policies and the Independent Advisory Service. Noise surveys were undertaken on Nine Elms Pier by Arup in January 2014 which will input into Trigger Action Plans. We have arranged a further meeting with the Directors of Nine Elms Pier Ltd on 25 March 14.

Yes

45 Wandsworth Sue Dunster http://infrastructure.planningportal.gov.uk/projects/london/thames-tideway-tunnel/?ipcsection=relreps&relrep=1123

Please see response to Bill Dunster (above). Yes

46 Wandsworth Mark Hale http://infrastructure.planningportal.gov.uk/projects/london/thames-tideway-tunnel/?ipcsection=relreps&relrep=1122

We wrote to Mr Hale on 30 January 2014 providing details of our updated mitigation and compensation policies and the Independent Advisory Service. Noise surveys were undertaken on Nine Elms Pier by Arup in January 2014 which will input into Trigger Action Plans. We have arranged a further meeting with the Directors of Nine Elms Pier Ltd on 25 March 14.

Yes

47 Wandsworth May Hale http://infrastructure.planningportal.gov.uk/projects/london/thames-tideway-tunnel/?ipcsection=relreps&relrep=1132

Please see response in respect of above re Mark Hale. Yes

48 Wandsworth Malcolm Hollis LLP http://infrastructure.planningportal.gov.uk/projects/london/thames-tideway-tunnel/?ipcsection=relreps&relrep=1051

Following frequent attempts to contact those representing the occupiers of these business units an email was received on 24 February 2014 providing us with details of a newly appointed agent with whom we have been asked to engage.

There has yet to be a meeting arranged and there will be no prospect of agreement to report before the close of the Examination. The representations will therefore not be withdrawn.

Yes

49 Wandsworth Ian Mowbray Gildart Jackson


We have been in email contact with Mr Jackson to arrange a meeting to discuss an agreement for the relocation of his vessel. We are hopeful that this will take place as soon as possible. Noise surveys were undertaken on Nine Elms Pier by Arup in January 2014 which will input into Trigger Action Plans.

Yes

Question: 58.2


99


50 Wandsworth Taus Larsen http://infrastructure.planningportal.gov.uk/projects/london/thames-tideway-tunnel/?ipcsection=relreps&relrep=1146

We wrote to Taus Larsen on 30 January 2014 providing details of our updated mitigation and compensation policies and the Independent Advisory Service. Noise surveys were undertaken on Nine Elms Pier by Arup in January 2014 which will input into Trigger Action Plans. We provided contact details for the project team should they require further information. No further correspondence has been received by the project.

Yes

51 Wandsworth Guy Lindsay-Watson http://infrastructure.planningportal.gov.uk/projects/london/thames-tideway-tunnel/?ipcsection=relreps&relrep=8

We wrote to Mr Lindsay-Watson, a Director of Nine Elms Pier Ltd, on 30 January 2014 providing details of our updated mitigation and compensation policies and the Independent Advisory Service. We have arranged a further meeting with the Directors of Nine Elms Pier Ltd on 25 March 14.

Yes

52 Wandsworth Livett’s Launches Ltd http://infrastructure.planningportal.gov.uk/projects/london/thames-tideway-tunnel/?ipcsection=relreps&relrep=137

Since the 13 January 2014 there have been few exchanges with Chris Livetts. There was an offer to put together a Statement of Common Ground but the conditions attached to this were not acceptable to Thames Water and would have required commitments in respect of matters outside the LLAU. These issues are well documented in the written representations already submitted to the ExA and as explained at the hearings we now anticipate the representations from Chris Livett will remain with no prospect of withdrawal prior to the close of the Examination.

Yes

53 Wandsworth Lookers Motor Group Limited


We wrote to Lookers Motor Group on 27 January 2014 with our proposals and again on 27 February 2014 to provide further clarification to queries we received from them.

Yes

54 Wandsworth Manifest, MMK Enterprises, Kirtling Properties Ltd, John Woodman, Ian Thompson, Pequod BVI Inc


Following frequent attempts to contact those representing the owners of these business units an email was received on 24 February 2014 providing us with details of a newly appointed agent with whom we have been asked to engage.

There has yet to be a meeting arranged and there will be no prospect of agreement to report before the close of the Examination. The representations will therefore not be withdrawn.

Yes

55 Wandsworth Roderic Mac Clancy http://infrastructure.planningportal.gov.uk/projects/london/thames-tideway-tunnel/?ipcsection=relreps&relrep=487

An inspection and valuation of Mr Mac Clancy's houseboat was undertaken on 11 February 2014 by Crispin Marine Ltd, we are awaiting the valuation report. Noise surveys were undertaken on Nine Elms Pier by Arup in January 2014 which will input into Trigger Action Plans. We remain in regular contact with Mr Mac Clancy and anticipate and agreement will be reached in March 2014.

Yes

56 Wandsworth Metro Nominees (Wandsworth) No.1 & Metro Nominees (Wandsworth) No.2 Ltd



Yes

57 Wandsworth Minerva (Wandsworth) Ltd


Minerva has exchanged contracts for the sale of the property with Greenland Group (agreement not yet completed). We are currently continuing negotiations with Minerva. A meeting has been arranged for 27 February 2014 and we expect agreement on 28 February 2014.

Yes

58 Wandsworth Reverend Ailsa Newby http://infrastructure.planningportal.gov.uk/projects/london/thames-tideway-tunnel/?ipcsection=relreps&relrep=535

Further to Thames Water’s response dated 13 January 2014, we have prepared a brief update of the current discussions with St Marys Church.

A further meeting was held on 25 January 2014 with the Reverend Alisa Newby, Mr Berni Griffiths (verger and premises manager) and Mr Richard Bull. During the meeting the following issues were discussed:

1. Location of the ventilation column serving the interception chamber, together with possible alignments for the ventilation pipework through the vaults currently occupied by the church, to minimise any adverse impact - Provisional agreement reached with the church subject to detailed design, site investigation and agreement with LB Wandsworth and HBMCE (Historic Buildings and Monuments Commission for England).

2. Construction access into the vaults - Provisional agreement reached with regard to access route, subject to preparation of a detailed access plan illustrating route, alignment of fencing etc.

3. Provision of alternative community facilities whilst construction activities occur within the vaults – A number of possible alternatives identified by St Marys Church and discussed.

4. Provision of alternative storage facilities for church items currently located within vaults - Possible alternatives to be identified and discussed further with St Marys Church.

It is anticipated that a revised agreement to include a detailed access plan, will be sent to St Marys Church which

Yes

Question: 58.2


100


will endeavour to reflect the issues discussed at the meeting. It is anticipated that following this extremely constructive meeting that agreement can be reached with St Mary’s by 11 March 2014.

59 Wandsworth Nine Elms Pier Limited http://infrastructure.planningportal.gov.uk/projects/london/thames-tideway-tunnel/?ipcsection=relreps&relrep=1137

Noise surveys were undertaken on Nine Elms Pier by Arup in January which will input into Trigger Action Plans. We are in regular contact with Directors of Nine Elms Pier Ltd and are arranging a further meeting to take place as soon as possible.

Yes

60 Wandsworth Reverend Gregory Prior http://infrastructure.planningportal.gov.uk/projects/london/thames-tideway-tunnel/?ipcsection=relreps&relrep=570


Yes

61 Wandsworth D Spring http://infrastructure.planningportal.gov.uk/projects/london/thames-tideway-tunnel/?ipcsection=relreps&relrep=502

We wrote to Mr Spring on 30 January 2014 providing details of our updated mitigation and compensation policies and the Independent Advisory Service. We provided contact details for the project team should he require further information. No further correspondence has been received by the project.

Yes

62 Wandsworth Robert Tipping http://infrastructure.planningportal.gov.uk/projects/london/thames-tideway-tunnel/?ipcsection=relreps&relrep=1253

We met with Mr Tipping, a Director of Nine Elms Pier Ltd, on 29 January 2014 to discuss a potential agreement with him regarding the relocation of his houseboat and potential compensation. An inspection and valuation of his houseboat was undertaken on 11 February 2014 by Crispin Marine Ltd, we are awaiting the valuation report. We remain in regular contact with Mr Tipping and anticipate an agreement will be reached in March 2014. Noise surveys were undertaken on Nine Elms Pier by Arup in January 2014 which will input into Trigger Action Plans. We have arranged a further meeting with the Directors of Nine Elms Pier Ltd on 25 March 14.

Yes

63 Wandsworth Zoe Vanderwolk http://infrastructure.planningportal.gov.uk/projects/london/thames-tideway-tunnel/?ipcsection=relreps&relrep=11

We wrote to Ms Vanderwolk on 30 January 2014 providing details of our updated mitigation and compensation policies and the Independent Advisory Service. We provided contact details for the project team should she require further information. Noise surveys were undertaken on Nine Elms Pier by Arup in January 2014 which will input into Trigger Action Plans. No further correspondence has been received by the project.

Yes

64 Royal Borough of Kensington and Chelsea

Circadian Limited http://infrastructure.planningportal.gov.uk/projects/london/thames-tideway-tunnel/?ipcsection=relreps&relrep=719

There has been no further contact from Circadian. None was expected as they have made clear from previous discussions that they will not withdraw their objection. The single significant outstanding issue is the location of the vent pipe. We are flexible about the location. Circadian want it located away from the river front so that it is not near their development. However RBKC want it located on the river front as shown on the DCO plans.

Yes

65 Royal Borough of Kensington and Chelsea

Royal Hospital Chelsea http://infrastructure.planningportal.gov.uk/projects/london/thames-tideway-tunnel/?ipcsection=relreps&relrep=652

Further discussions have been held with Royal Hospital Chelsea and it is anticipated that the Heads of Terms should be agreed and ready for signing by 3 March 2014.

Yes

66 Lambeth CGIS Ltd http://infrastructure.planningportal.gov.uk/projects/london/thames-tideway-tunnel/?ipcsection=relreps&relrep=1053

Confirmation of withdrawal attached below. Yes

67 Lambeth London Duck Tours Limited


SoCG between TWUL/LDT/PLA signed. Draft Head of Terms for property/compensation agreement issued to London Duck Tours on 31 January 2014. Comments received from London Duck Tours 11 February 2014. Discussions ongoing, but basis of commercial terms not agreed.

Yes

68 City of Westminster

City of Westminster http://infrastructure.planningportal.gov.uk/wp-content/ipc/uploads/projects/WW010001/2.%20Post-Submission/Representations/Written%20Representations/131105_WW010001_WR_%20City%20of%20Westminster%20.pdf

Refer to 13 January 2014 written response. Subject to internal governance procedures by both parties, property Heads of Terms are now provisionally agreed and are awaiting signature. Within 14 days of signature, it is an obligation within those Heads of Terms that a draft lease template and transfer documents will be sent to Westminster for progression to formal documentation of agreed property matters.

Yes

69 City of London City of London Corporation


Refer to 13 January 2014 written response and SoCG. Revised Heads of Terms were sent to the City of London Corporation (CoL) on 24 February 2014. We continue to have a regular and constructive relationship with CoL’s property and legal team over reaching an agreement for the temporary use and acquisition of their land interests at the Blackfriars Bridge Foreshore site. An agreement to capture land and property matters is at an advanced stage and it is envisaged that Heads of Terms will be signed with a fully signed property agreement completed by September 2014. Revised land plans are currently being produced by the CoL for cross reference in the agreement.

Yes

Question: 58.2


101


70 City of London Thames Clippers http://infrastructure.planningportal.gov.uk/projects/london/thames-tideway-tunnel/?ipcsection=relreps&relrep=598

Thames Clippers representation is focussed on the suitability of a replacement pier. We have had a number of liaison meetings in developing the Navigational Issues and Preliminary Risk Assessment work.

Thames Clippers attended a number of meetings with stakeholders on Blackfriars Pier design development (PLA,TFL, CoL, etc).

We clarified by email on 22 October 2013 that we had amended the design of the pier to remove the monopole.

Following our meeting on 9 December 2013 we are currently incorporating the outcomes of this meeting into the reference design with respect to user requirements for the design of the pier, as well as design criteria surrounding accessibility from the landside, etc.

Our Early Works team is currently liaising with them regarding construction preparation works.

Yes

71 City of London National Small-bore Rifle Association


We have still had no response to our correspondence and we continue to work with the City of London on the basis that these premises are delivered with vacant possession on the date required.

Yes

72 Southwark London Borough of Southwark


There are no property commitments. Section 106 agreement (APP119.14) submitted on 12 February 2014. Yes

73 Southwark Ian Hudson http://infrastructure.planningportal.gov.uk/wp-content/ipc/uploads/projects/WW010001/2.%20Post-Submission/Representations/Written%20Representations/131021_WW010001_WR_Ian_Hudson.pdf

Email response received from Dr Hudson, on 4 February 2014, in which he continues to question the need for temporary use of his parking space. He acknowledges our proposal for alternative provision would be logical if he was convinced of the need for use of his space.

Yes

74 Southwark Surrey Quays Limited http://infrastructure.planningportal.gov.uk/projects/london/thames-tideway-tunnel/?ipcsection=relreps&relrep=1041

SoGC submitted 12 February 2014. Awaiting further correspondence from British Land/Surrey Quays Limited representative to resolve outstanding matters.

Yes

75 Tower Hamlets London Borough of Tower Hamlets


There has been no progress on terms for the property agreement, although further progress has been made on the s106 agreement.

Yes

76 Tower Hamlets Free Trade Wharf Management Company Ltd


A meeting was held with the company on 10 January 2014. The scope and extent of an Asset Protection Agreement had been agreed and a legal agreement is being progressed. This will include the Newcastle Jetty, in which the company has a leasehold interest from which a deep subsoil interest is required for the main tunnel alignment.

Yes

77 Tower Hamlets Higgins Homes plc http://infrastructure.planningportal.gov.uk/projects/london/thames-tideway-tunnel/?ipcsection=relreps&relrep=653

Position remains as advised in our January submission. No further contact has been made by the project. Yes

78 Tower Hamlets Old Sun Wharf Freehold Management Limited


Position remains as advised in our January submission. No further contact has been made by the project. Yes

79 Lewisham London Borough of Lewisham


There has been no progress on terms for the property agreement, although further progress has been made on the s106 agreement.

Yes

80 Lewisham Father Paul Butler http://infrastructure.planningportal.gov.uk/projects/london/thames-tideway-tunnel/?ipcsection=relreps&relrep=133

An Asset Protection Agreement for St Paul’s Church is scheduled to be signed on the 28 February 2014. Richard Bull of Winkworth Sherwood will write on behalf of Father Butler to withdraw his objections upon completion.

Yes

81 Lewisham Cannon Wharf LLP http://infrastructure.planningportal.gov.uk/projects/london/thames-tideway-tunnel/?ipcsection=relreps&relrep=1111

Heads of Terms are being drafted for an agreement. Completion of the agreement will include withdrawal of the two representations made on behalf of this party which should occur before the end of March.

Yes

http://infrastructure.planningportal.gov.uk/wp-content/ipc/uploads/projects/WW010001/2.%20Post-Submission/Representations/12-02-2014%20-%20TWUL%20Submission%20of%2012%20Feb%202014%20inc.%20draft%20DCO/APP119.14%20Section%20106%20Agreement%20-%20London%20Borough%20of%20Southwark.pdf

Question: 58.2


102


82 Lewisham Cannon Wharf London LLP http://infrastructure.planningportal.gov.uk/projects/london/thames-tideway-tunnel/?ipcsection=relreps&relrep=138

Heads of Terms are being drafted for an agreement. Completion of the agreement will include withdrawal of the two representations made on behalf of this party which should occur before the end of March.

Yes

83 Lewisham Stuart Conney http://infrastructure.planningportal.gov.uk/projects/london/thames-tideway-tunnel/?ipcsection=relreps&relrep=44

Mr Conney’s objection is to the Deptford Church Street site rather than his specific property. No further correspondence has been received by the project.

Yes

84 Lewisham Suk Goh http://infrastructure.planningportal.gov.uk/projects/london/thames-tideway-tunnel/?ipcsection=relreps&relrep=152


Yes

85 Lewisham Nerita Properties Limited http://infrastructure.planningportal.gov.uk/wp-content/ipc/uploads/projects/WW010001/2.%20Post-Submission/Representations/Written%20Representations/131029_WW010001_WR_Nerita%20Properties%20Limited.pdf

An agreement with Nerita has been completed and their objection relating to settlement has been withdrawn. Their objection to construction impact still remains and will not be withdrawn prior to the close of the Examination.

Yes

86 Lewisham Martin Saunders http://infrastructure.planningportal.gov.uk/projects/london/thames-tideway-tunnel/?ipcsection=relreps&relrep=424


Yes

87 Lewisham Nick Williams http://infrastructure.planningportal.gov.uk/projects/london/thames-tideway-tunnel/?ipcsection=relreps&relrep=1057

A further meeting was held with Nick Williams on the 21 January 2014 to discuss the correspondent's concerns. Engagement is ongoing with “Don't Dump on Deptford's Heart”.

Yes

88 Royal Borough of Greenwich

Graham Group Limited and Jewson Limited


Discussions with Jewsons Limited are ongoing. The project accepts that compensation for business disturbance will be payable as displacement from the property will be, in effect, permanent, taking account of the landowners’ aspirations to redevelop the site.

Yes

Question: 58.2


103

Question: 58.2


104


Question: 58.3


105

3 Question: 58.3

Can the Applicant check the wording, grammar and all references in all final documentation carefully for consistency, clarity and accuracy and ensure that all documentation referenced but still not provided to date is provided on or before the 3 March 2014.

3.1.1 We have remained focused on seeking to complete the required documentation to meet the original deadline. We will do this to the highest standard possible in the timeline available.

Question: 58.3


106


Question 58: Appendices


107

Appendix A: Review of proposed acoustic wall



108


Paul Fletcher MSc Waterslade Ltd, registered in England no. 2782750, VAT No. 596422511 Martin Howarth MA DPhil (Oxon), Malcolm Macpherson MA DPhil (Oxon)

Derek Arnold Thames Tideway Tunnel 3rd Floor 55 North Wharf Road Paddington London W2 1LA 26th February 2014 Dear Mr. Arnold, RE: Thames Tunnel – Impact on Daylight & Sunlight You have informed us that, in order to further reduce noise impacts at King Edward Memorial Foreshore, Chambers Wharf, Earl Pumping Station and Carnwath Road Riverside, there are proposed changes to the hoardings surrounding the sites. You have asked us to comment on whether these proposed changes will have an impact on the daylight and sunlight amenity to the properties surrounding each site. For each site, we have assumed that the methodology set out in the 2011 Building Research Establishment (BRE) Report 'Site layout planning for daylight and sunlight - A guide to good practice' by Paul Littlefair has been adopted in the relevant UDP. Even in boroughs where it has not been explicitly adopted, there is no better means of determining any impact. A brief assessment of each site follows – KING EDWARD MEMORIAL FORESHORE – An additional 5-6 metre high acoustic wall is proposed at the site perimeter adjacent to Free Trade Wharf. The BRE Report states that “If any part of a new building or extension, measured in a vertical section perpendicular to a main window wall of an existing building, from the centre of the lowest window, subtends and angle of more than 25 degrees to the horizontal, then the daylighting to the existing building may be adversely affected.” It also provides the same guideline for sunlighting. With reference to attached drawing 742/PL1-KEMP/01, the ground floor of this property is raised above ground level. Section AA shows that the acoustic wall will subtend an angle of less than 25 degrees from the centre of the lowest potentially impacted window. There will therefore not be a material impact on the daylight or sunlight amenity to this property. CHAMBERS WHARF – 3.6 metre high acrylic sheeting is proposed along the river wall adjacent to 8-14 Fountain Green Square. This will be approximately 5 metres from the nearest window, and will therefore not subtend an angle of more than 25 degrees from the window centre. There will not be a material impact on daylight or sunlight.

EARL PUMPING STATION – Increasing the hoarding height from 2.4m to 3.6m will not have a material impact on the daylight and sunlight amenity to any of the properties surrounding the site. CARNWATH ROAD RIVERSIDE – 3.6 metre high acrylic sheeting is proposed along the river wall adjacent to 89-101 Carnwath Road and 5 Carnwath Road. This will be in excess of 10 metres away from all the windows, and will therefore not subtend an angle of more than 25 degrees from the nearest window centre. It will not materially impact on the daylight or sunlight amenity to either property. Subsequent to us undertaking our October 2012 assessment, a 7.5 metre high barrier is proposed to the east of the site. This could potentially impact windows in 5 Carnwath Road. We previously found that 5m high massing adjacent to this property resulted in a material impact to two ground floor windows. We suggested how the footprint of the massing could be altered to remedy the issue (see drawing 742/PL1-CAR/09). With reference to attached drawing 742/PL1-CAR/10, we understand that the 7.5 barrier will run along the previously suggested building line. We have assessed the massing shown in relation to the windows in 5 Carnwath Road. The attached tables of results show the VSC and APSH figures. VSC is a measure of the skylight reaching a point from an overcast sky. For Existing buildings, the BRE guideline is based on the loss of VSC at a point at the centre of a window, on the outer plane of the wall. The BRE guidelines state that if the VSC at the centre of a window is less than 27%, and it is less than 0.8 times its former value, then the diffuse daylighting of the existing building may be adversely affected. In relation to sunlight, the BRE recommends that the Annual Probable Sunlight Hours (APSH) received at a given window in the proposed case should be at least 25% of the total available including at least 5% in winter. Where the proposed values fall short of these, and the absolute loss is greater than 4%, then the proposed values should not be less than 0.8 times their previous value in each period. The figures show that all of the windows comfortably achieve the BRE VSC and APSH criteria. The 7.5m barrier will therefore not have a material impact on the daylight and sunlight amenity to 5 Carnwath Road. SUMMARY – None of the proposed alterations will have a material impact on the daylight and sunlight amenity to the properties surrounding the sites. I hope all the above is clear; please contact me if I can be of further assistance. Yours sincerely, Tom Bevan Waterslade Ltd

Project Title:

Title:

Figure No.

Date:

742/PL1-KEMP/01 VariesScale:

SECTION THROUGH ACOUSTIC

WALL AT KEMP SITE

FEB 2014

THAMES TIDEWAY TUNNEL

t: 01865 881882 f: 01865 881891 @: www.waterslade.com

5 Thames Street, Eynsham, Oxford, OX29 4HF

A

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PLAN SCALE 1:200

SECTION AA SCALE 1:100

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ALL DIMENSIONS ARE APPROXIMATE

Project Title:

Title:

Figure No.

Date:

742/PL1-CAR/10 NTSScale:

PLAN & 3D VIEW - 7.5m BARRIER

LOCATED AT EASTERN END OF

CARNWATH ROAD SITE

FEB 2014

THAMES TIDEWAY TUNNEL

t: 01865 881882 f: 01865 881891 @: www.waterslade.com

5 Thames Street, Eynsham, Oxford, OX29 4HF

ALL HEIGHTS IN mm AOD

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FEB 2014THAMES TUNNEL DAYLIGHT ANALYSIS CARNWATH ROADCONSTRUCTION PHASE 2

ACARNWATH_Construction_210214.xls 26/02/2014 1

EXISTING PROPOSED LOSS REDUCTIONRoom Window VSC (EX) VSC (PR) VSC FACTOR (PR/EX)

5 CARNWATH ROAD

R1/30 W1/30 26.72 22.86 3.86 0.86

R2/30 W2/30 14.72 14.13 0.59 0.96

R3/30 W3/30 18.89 17.98 0.91 0.95R3/30 W4/30 32.73 31.22 1.51 0.95R3/30 W5/30 33.32 32.06 1.26 0.96

R1/31 W1/31 29.84 27.34 2.50 0.92

R2/31 W2/31 24.82 23.83 0.99 0.96

R3/31 W3/31 28.96 27.58 1.38 0.95R3/31 W4/31 37.69 36.93 0.76 0.98R3/31 W5/31 37.51 36.91 0.60 0.98

FEB 2014THAMES TUNNEL SUNLIGHT ANALYSIS CARNWATH ROADCONSTRUCTION PHASE 2

SCARNWATH_Construction_210214.xls 26/02/2014 1

EXISTING PROPOSED LOSS REDUCTION FACTORRoom Window Summer Winter Total Summer Winter Total Total Winter Total

5 CARNWATH ROAD

R2/30 W2/30 21 11 32 21 11 32 0 1.00 1.00R3/30 W3/30 26 14 40 24 13 37 3 0.93 0.93R3/30 W4/30 48 22 70 48 20 68 2 0.91 0.97R3/30 W5/30 47 22 69 46 21 67 2 0.95 0.97

R2/31 W2/31 30 16 46 30 15 45 1 0.94 0.98R3/31 W3/31 35 19 54 35 18 53 1 0.95 0.98R3/31 W4/31 50 26 76 50 25 75 1 0.96 0.99R3/31 W5/31 50 27 77 50 26 76 1 0.96 0.99



109

Appendix B: Technical Advice Note – Hydraulic Assessment of CDM Smith 'Alternative A' drive strategy



110


Thames Water response to London Borough of Hammersmith and Fulham


Appendix B

Technical Advice Note

Hydraulic Assessment of the CDM Smith ‘Alternative A’ Drive Strategy

Subject: Hydraulic Assessment of the CDM Smith „Alternative A‟ proposal

Date: 19 February 2014

Doc ref no: 100-TN-XXX-CARRR-000001-AA

From: Thames Water – Thames Tideway Tunnel

To: London Borough of Hammersmith and Fulham

Copy:

1.1.1 This is a Technical Advice Note to summarise the hydraulic considerations associated with the CDM Smith „Alternative A‟ drive strategy, as submitted to the Planning Inspectorate by the London Borough of Hammersmith and Fulham in their written representations dated 4th November 2013 and 2nd December 2013.

1.1.2 Thames Waters full response to the Alternative A drive strategy is contained within Doc ref: App31.01 Response to issue specific hearing and written representations to CRR, Alternative Driver Strategy and Putney Embankment Foreshore, Section 5 Alternative Drive Strategy, as submitted to the Planning Inspectorate on 2 December 2013, Doc ref: APP59 Rationale for the Selection of Works Sites and Drive Strategies, response to Question 32.1, as submitted on 13 January 2014 and APP102.03 Written summaries of the cases put orally at the hearing dated 22 January 2014.

1.1.3 During the hearing on 22 January Thames Water‟s representative confirmed that the hydraulic performance of Alternative A had been tested and this was briefly written up in Doc ref: APP102.03. This TAN has been prepared based upon the earlier testing to provide a more detailed explanation about the hydraulic assessment of Alternative A.

2.1 General

2.1.1 The current proposals within the application for development consent for the western section of the Thames Tideway Tunnel, between Kirtling Street and Acton Storm Tanks, would comprise two tunnel sections. A tunnel approximately 5km in length between Kirtling Street and Carnwath Road Riverside of 7.2m internal diameter, constructed at a constant gradient of 1 in 789, and a second tunnel of approximately 7km in length between Carnwath Road Riverside and Acton Storm Tanks of 6.5m



Appendix B

internal diameter tunnel at a constant gradient of 1 in 690. There would be a profile step within the Carnwath Road Riverside shaft.

2.1.2 Further detail of the Thames Tideway Tunnel is included within Doc ref: 2.01 Works Plans and Sections, as submitted by Thames Water to the Planning Inspectorate in February 2013.

2.1.3 The CDM Smith alternative drive strategy, known as „Alternative A‟, is for a revised configuration of the western section of the Thames Tideway Tunnel. Alternative A would comprise a single tunnel drive from Kirtling Street to Acton Storm Tanks, with no intermediate shafts and implying no shaft or air management facilities at Carnwath Road Riverside.

2.1.4 Alternative A‟ would be approximately 12km in length with an internal diameter tunnel of 6.8m and with a change of gradient approximately mid way along the tunnel. The change in gradient is to minimise conflict with existing below ground infrastructure.

2.1.5 The western section of the Alternative A tunnel would be approximately 7km in length and be constructed at a constant gradient of 1 in 610, and the eastern section would be approximately 5km in length at a constant gradient of 1 in 770.

2.1.6 An extract from the CDM Smith report, illustrating the „Alternative A‟ tunnel section is shown below. The graphic is an extract of drawing no:100759/TTWT/001 Thames Tideway Tunnel Long section Tunnel Crossing.

2.1.7 This section shows the two tunnel reaches with no intermediate shafts, no indication of where connection tunnels would join this tunnel and limited information about the critical infrastructure that the tunnel passes under and over during the drive.

Figure 1 – extract of drawing no:100759/TTWT/001 Thames Tideway Tunnel Long section Tunnel Crossing.



Appendix B

3.1 General

3.1.1 The CDM-Smith Alternative A lacks important details and fails to consider where and how connections are made from CSOs that need to be intercepted between Kirtling Street and Acton Storm Tanks. For example, how the two Frogmore CSOs are connected to this tunnel is not identified.

3.1.2 This lack of information makes detailed hydraulic simulations of Alternative A impossible to perform but basic tests were applied to identify any serious hydraulic shortcomings. The process followed included basic hydraulic tests that if marginally failed might possibly be mitigated with further detailed study. These basic tests, if passed, would lead to evaluation of other considerations for Alternative A, such as the single drive length as reported in our full response on this suggestion, Doc ref: App31.01 Response to issue specific hearing and written representations to CRR, Alternative Driver Strategy and Putney Embankment Foreshore, Section 5 Alternative Drive Strategy, APP59 Rationale for the Selection of Works Sites and Drive Strategies, response to Question 32.1, and APP102.03 Written summaries of the cases put orally at the hearing dated 22 January 2014.

3.1.3 The basic hydraulic tests were:

storage volume developed for CSO control,

flows rates for the capacity of the suggested tunnel diameter,

inflow into the system - slope of the tunnel and vertical alignment and,

potential for adverse pneumatics and transients.

3.2 Storage volume

3.2.1 The first test is for storage volume equivalency between the Thames Tideway Tunnel and Alternative A to determine if CSO control would be similar. We had to assume that the length of the tunnel was comparable with the Thames Tideway Tunnel and the only difference is the tunnel diameter.

3.2.2 CDM Smith conducted this simple geometric arithmetic exercise correctly as the storage volume provided by Alternative A is equivalent.

3.2.3 The calculations are summarised in Table 3.1 below.



Appendix B

Table 3.1 - Storage volume balance

3.3 Flow rates

3.3.1 The Alternative A proposal would have a gradient change along the length of the main tunnel between Acton Storm Tanks to Kirtling Street.

3.3.2 Hydraulic calculation was conducted to determine the flow capacity of the tunnel for each tunnel section, or reach, in the „Alternative A‟ proposal, namely:

Western reach – Tunnel at 1 in 610 gradient – flow capacity of 133 m3/s

Eastern reach – Tunnel at 1 in 770 gradient – flow capacity of 119 m3/s

3.3.3 The following Tables 2 and 3 are screen captures of a portion of spreadsheets that calculates the depth-flow relationships and full pipe capacity of a circular pipe given diameter, slope and roughness.



Appendix B

Table 3.2 - CDM-Smith western 1:610 reach

Colebrooke White Equation for Full Bore and Partial Full Circular Pipe

Diameter 6.8 m

Slope 1 in 770

Roughness ks 3 mm

0.003 m

Friction Slope Sf 0.0012987 m/m

1 in 770 m

Kinematic

Viscocsity ν 1.141E-06 m2/s

Gravity acc g 9.81 m2/s

Uses Butler - Pinkerton charts / equation

Velocity Flow

(m/s) (m3/s)ψ = (ѳ - sin ѳ) /ѳ

= (4 * Hr)/D -2 x √(2gSfψD) ks /*3.7ψD+

2.51* ν */ [ψD *

√(2gSfψD)]

1 -0.8325 1.19E-04 1.01E-06 3.263 119

Maximum 3.679 126.4

Table 3.3 - CDM-Smith eastern 1:770 reach

3.4 Inflow to the system

3.4.1 The design storm for the system is a 15-year, 120-minute rainfall over the whole catchment.



Appendix B

3.4.2 The peak flow of the CSOs intercepted between Kirtling Street and Acton Storm Tanks is 125 m3/s

3.4.3 This result is given in the Table 4 below are for inflow volumes and peak inflows from the CSOs intercepted between Kirtling Street and Acton Storm Tanks.

Table 3.4 – Inflows (Acton Storm Relief to Ranelagh)

3.4.4 The peak flow for the western (steeper) reach of the CDM Smith

Alternative A would have a capacity of approximately 133m3/s and the eastern (shallower) reach a capacity of approximately 119m3/s.

3.4.5 The design flow of 125m3/s would therefore exceed the eastern reach‟s capacity and would not fulfil the required hydraulic criteria that capacity exceed predicted flow.

3.5 Pneumatics and Transients

3.5.1 The Engineering Design Statement (Doc ref 7.18) at 3.4.16 explains the

consequences of adverse flow conditions in large sewers. We have conducted a full pneumatic and transient analysis for our scheme proposal but would not do this complex and expensive work for any alternative that did not meet the basic hydraulic tests described above or other non-hydraulic considerations – refer to documents listed in 1.1.2 above .

3.5.2 In our professional opinion a basic test for long CSO tunnels transporting large flows is that they should not change gradient between shafts because this increases the risk of adverse pneumatic and transient conditions and should therefore be avoided.

http://infrastructure.planningportal.gov.uk/wp-content/ipc/uploads/projects/WW010001/2.%20Post-Submission/Application%20Documents/Other%20Documents/7.18_Engineering_Design_Statement.pdf



Appendix B

3.5.3 The suggested Alternative A alignment with a change in gradient fails this basic hydraulic test.

3.5.4 Additionally the capacity of the eastern reach of the Alternative A would prematurely surcharge during design storm conditions. This would create a filling bore that would move upstream and because of the lack of intermediate shafts that reduce bore effects, the bore would continue travelling upstream and inhibit the flow from the various connection tunnels.

3.5.5 Due to the magnitude of the flow in these connection tunnels, the main tunnel bore would cause a backwater into the connection tunnels, which would reduce the flow capacity and in turn cause another bore to travel upstream in these connection tunnels. Because of the relative small size of these connection tunnels, the bore effects would be significant and air/water mixtures could cause explosive release at the drop shafts at the end of these connection tunnels. As a minimum, the size of CSO drop shafts would have to be evaluated and it is likely they would need to be made larger to control such releases and transient effects.

3.5.6 CDM Smith has not considered this important but basic hydraulic issue.

3.6 Conclusion

3.6.1 The Alternative A drive strategy proposed by CDM Smith provides an equivalent storage volume to that contained within Thames Waters submission and therefore would provide equivalent CSO control performance.

3.6.2 The project design flow exceeds the capacity of the eastern reach of the alternative and therefore Alternative A fails design requirements for the upper reaches of the tunnel system.

3.6.3 It is our opinion that Alternative A would require measures such as those mentioned above to mitigate for the risk of adverse hydraulic, pneumatic and transients forming within the main tunnel reach and also in connection tunnels. CDM Smith did not consider this matter or provide sufficient alternative detail to fully assess this risk or mitigation measures required.

3.6.4 As recognised by CDM Smith, much more design development and hydraulic analysis would be required before the suggested tunnel could be demonstrated to be hydraulically acceptable; currently Alternative A would not meet our some of our basic criteria for an acceptable hydraulic solution.

3.6.5 When considered with other factors such as drive length and TBM failure risks (refer to documents cited in 1.1.2 above) we have decided that the hydraulic performance and testing of Alternative A should not be taken any further.



Appendix B




111

Appendix C: Dr New note on Separation Distances



112




Appendix C

A note on Separation Distances between TBM drives and Existing

Infrastructure.

The TTT Crossing of the Thames Water Ring Main (TWRM) and the Thames – Lee Raw Water Tunnel (TLRW)

Dr Barry New (Geotechnical Consulting Group)

INTRODUCTION 1 In support of their submissions to the ExA the London Borough of

Hammersmith and Fulham (LBHF) have argued that the TTT might be driven closer to three other tunnels. Two of these tunnels (the TWRM and the TLRW) are owned by Thames Water and form a critical part of London‟s water distribution network.

2 This note addresses the LBHF response to the TW written submissions put

orally at Hearings held on January 22nd 2014 and should be read together with the TW responses Doc ref: APP102.3 at 2.1.6 (Point 1) and 2.1.7 (Point 2). On page 3 of the LBHF responses the issue of tunnel separation distances is discussed and examples of close proximity crossings by Crossrail are given.

THE PRECEDENTS CITED BY LBHF 3 Unfortunately none of the examples given by LBHF relate to pressurised water

tunnels and the design and construction requirements for such crossings are necessarily very different to the more usual unpressurised situations.

4 In their Final Report for LBHF dated November 2013 (TTT – Benchmarking

and Risk Assessment of Alternative Drive Strategies) CDM Smith consider issues relating to „insufficient clearances‟ in several parts of their report (e.g. 3.3.2, 5.2.2, 5.4.2 and 6.2.5). It is remarkable that a principle design constraint that of high pressurisation in the existing Thames Water tunnels is not mentioned in their report: Neither is the requirement to accommodate high cyclic internal pressurisation (up to 4 bar) of the TTT during it operational life.

5 Whilst these requirements have been fully considered by TWUL the

construction and operation of the TTT depends on maintaining a safe distance between the tunnels.

6 The Crossrail crossing of the HAM sewer is discussed in LBHF responses at

page 3 and Table 1 is presented in support of close separation distances during Crossrail works. Given below are a number of reasons why such comparisons are inappropriate in respect of the TTT crossings of the two pressurised water tunnels.




Appendix C

7 The HAM sewer is at a depth of about 10m below the ground surface with an immediately adjacent construction shaft available for real time monitoring and repair if necessary. The TWUL water tunnels are at a depth of about 30m beneath the River Thames and at a considerable distance from any access shaft.

8 During the construction of the Crossrail tunnels there will be very little or no

internal pressure in the HAM sewer. During the construction of the TTT the design requires that both TWUL tunnels will be at operational and possibly surge pressures of almost 4 bar and 6 bar respectively.

9 For much of the time the HAM sewer carries only a dry weather flow and

diversionary arrangements (by over-pumping) have been made for use during construction works. A robust emergency preparedness plan has been prepared to deal with unforeseen circumstances during the works. No such arrangements can be made for un-programmed outages of the TWRM or the TLRW.

SAFETY DURING CONSTRUCTION AND OPERATION 10 All construction works involve a measure of risk. The TTT design team have

regarded the safety of the construction workers and the operatives as paramount in their design process and the proximity of the tunnel crossings has been an important consideration throughout.

11 The existing TW tunnels must be safe when the TTT is pressurised to its full

extent (104.5m head ATD). If the tunnels become closer together the design becomes more difficult and the safety less certain: The closer the tunnels the greater and more localised tunnel loadings both during construction and pressurised operation.

12 Maintaining a safe gap of at least 3m retains a layer of London Clay which has

a very low permeability and this assists in preventing any significant hydraulic connectivity between the tunnels.

13 Because the actual timing of the tunnel crossings cannot be accurately

programmed the designs needed to assume that both tunnels must remain capable of full operation during the works. The inner lining design for the existing tunnels also had to take into account the safety of the tunnelling operatives necessarily in the TTT during its construction. If the tunnels were closer together then the risk of inundation of the TTT works is clearly increased. The consequences of inundation are apparent to all and the risk must therefore be maintained as negligible.



Appendix C

CONCLUSION 14 I am not aware of any pressurised tunnel crossings in soils anywhere in the

UK, or for that matter anywhere in the world, that have been built in closer proximity than those currently proposed by the TTT project.

15 The existing separation has already been reduced to a minimum consistent

with safe construction and operation of the TTT and the safe and ongoing operation of the existing TW tunnels which are critical in the supply of water to London.

16 The Crossrail cases cited by LBHF are not relevant here because they do not

relate to the interaction between pressurised tunnels or tunnel crossings at depth beneath the river. These critical factors appear to have been overlooked by LBHF and their engineering advisors.

17 Safety both during tunnel construction and operation is paramount. Preserving

an adequate separation between the tunnels is of significant assistance in preventing high localised lining loads and preventing hydraulic connectivity between the tunnels.

BMN 20/2/2014



Appendix C


A.1.1



113

Appendix D: Waterslade letter 19 February 2014



114


Paul Fletcher MSc Waterslade Ltd, registered in England no. 2782750, VAT No. 596422511 Martin Howarth MA DPhil (Oxon), Malcolm Macpherson MA DPhil (Oxon)

Derek Arnold Thames Tideway Tunnel 3rd Floor 55 North Wharf Road Paddington London W2 1LA 19th February 2014 Dear Mr. Arnold, RE: Chambers Wharf – Daylight Impact on Axis Court I write in response to the concerns raised by Southwark Council regarding the impact that the proposed temporary office building will have on the ground and first floors of Axis Court. With regard to the methodology used for our assessment, we have applied the guidelines set out in the 2011 Building Research Establishment (BRE) Report 'Site layout planning for daylight and sunlight - A guide to good practice' by Paul Littlefair. This is the document most widely adopted by planning authorities to assess the acceptability of a scheme. The principle measure of daylight provided by the BRE for assessing the impact of a development on neighbouring properties is Vertical Sky Component (VSC). The guidelines explicitly state that the use of ADF as a criterion for assessing loss of light to existing buildings is not generally recommended. The BRE provides a formula for calculating the ADF value within a room. Taking into account the size of the windows, the nature of the glazing, the size of the room and its internal finishes, the ADF value is in fact derived from the VSC values at the windows serving the room. This implies that if a reduction in VSC is deemed acceptable, then so should the associated reduction in ADF. Our assessment concluded that the proposed temporary structure would result in a material impact to the ground and first floor floors windows of Axis Court and we suggested massing reductions to remedy the issue (ref. our drawings 742/PL1-CHA/11A & 13). You have adopted these, as shown by the stacked office profiles in figure 8.1 in your response to Question 33.8. The baseline position for the calculations took into account the buildings previously on the site. While we understand that these were demolished in 2008, Axis Court was built in around 2002, six years prior to this. It would be unreasonable to assume that the site should remain permanently vacant and therefore using the demolished building as the baseline position is appropriate. The massing reductions were in fact primarily driven to mitigate sunlight losses. Assuming they are implemented, with regard to daylight, the ground floor windows tested would all achieve proposed VSC values in excess of 0.9 times their baseline values, significantly in excess of the 0.8 times recommend by the BRE guidelines. All the first floor windows would in fact experience significant improvements in daylight amenity.

We note that a planning permission (Southwark Council application number: 07/AP/1262) comprising of a number of residential blocks has been granted for the site. ‘Block A’ that runs parallel to Axis Court at a distance of approximately 17 metres, varies in height from 6 to 9 stories. This would have a significantly greater impact on both the daylight and sunlight amenity to Axis Court than the proposed stacked office profiles. I hope all the above is clear; please contact me if I can be of further assistance. Yours sincerely, Tom Bevan Waterslade Ltd

THAMES TUNNEL SUNLIGHT ANALYSIS CHAMBERS WHARFCONSTRUCTION PHASE 3

WITH VSC AND APSH MASSING REDUCTIONS

NOV 2012

SCHAMBERS_Construction_7m_CB1.xls 19/02/2014 1


1-59 AXIS COURT

R3/50 W3/50 19 9 28 21 5 26 2 0.56 0.93R3/50 W4/50 19 10 29 21 6 27 2 0.60 0.93R4/50 W5/50 19 9 28 21 6 27 1 0.67 0.96

R2/51 W2/51 0 0 0 1 0 1 -1 - -R2/51 W3/51 16 2 18 22 1 23 -5 0.50 1.28R3/51 W4/51 23 6 29 29 5 34 -5 0.83 1.17R4/51 W5/51 28 9 37 34 9 43 -6 1.00 1.16R4/51 W6/51 30 10 40 35 10 45 -5 1.00 1.13R5/51 W7/51 30 9 39 36 10 46 -7 1.11 1.18R5/51 W8/51 31 9 40 37 11 48 -8 1.22 1.20R6/51 W9/51 30 9 39 38 12 50 -11 1.33 1.28R7/51 W10/51 30 12 42 38 16 54 -12 1.33 1.29R8/51 W11/51 29 13 42 39 17 56 -14 1.31 1.33R8/51 W12/51 8 0 8 15 2 17 -9 - 2.13R9/51 W13/51 10 0 10 18 4 22 -12 - 2.20

R2/52 W2/52 0 0 0 7 2 9 -9 - -R2/52 W3/52 20 3 23 28 5 33 -10 1.67 1.43R3/52 W4/52 26 7 33 35 9 44 -11 1.29 1.33R4/52 W5/52 30 10 40 39 13 52 -12 1.30 1.30R4/52 W6/52 32 11 43 40 14 54 -11 1.27 1.26R5/52 W7/52 32 10 42 40 15 55 -13 1.50 1.31R5/52 W8/52 32 10 42 40 15 55 -13 1.50 1.31R6/52 W9/52 32 11 43 40 16 56 -13 1.45 1.30R7/52 W10/52 32 14 46 40 19 59 -13 1.36 1.28R8/52 W11/52 31 14 45 40 19 59 -14 1.36 1.31R8/52 W12/52 9 1 10 15 4 19 -9 4.00 1.90R9/52 W13/52 11 1 12 18 6 24 -12 6.00 2.00

1-47 LUNA HOUSE

R1/61 W1/61 26 8 34 28 13 41 -7 1.63 1.21R1/61 W2/61 26 10 36 20 15 35 1 1.50 0.97R2/61 W3/61 13 12 25 15 7 22 3 0.58 0.88R3/61 W4/61 11 11 22 15 7 22 0 0.64 1.00R4/61 W5/61 9 10 19 15 7 22 -3 0.70 1.16R5/61 W6/61 9 10 19 15 7 22 -3 0.70 1.16R6/61 W7/61 19 6 25 15 7 22 3 1.17 0.88R6/61 W8/61 14 0 14 6 0 6 8 - 0.43

R1/62 W1/62 28 9 37 28 15 43 -6 1.67 1.16



NOV 2012



R1/62 W2/62 28 13 41 40 19 59 -18 1.46 1.44R2/62 W3/62 14 12 26 40 20 60 -34 1.67 2.31R3/62 W4/62 11 11 22 40 20 60 -38 1.82 2.73R4/62 W5/62 9 10 19 40 20 60 -41 2.00 3.16R5/62 W6/62 9 10 19 40 20 60 -41 2.00 3.16R6/62 W7/62 21 6 27 40 20 60 -33 3.33 2.22R6/62 W8/62 14 0 14 14 0 14 0 - 1.00

THAMES TUNNEL DAYLIGHT ANALYSIS CHAMBERS WHARFCONSTRUCTION PHASE 3


NOV 2012

ACHAMBERS_Construction_7m_CB1.xls 19/02/2014 1


12-14 FOUNTAIN GREEN SQUARE

R1/10 W1/10 35.92 30.66 5.26 0.85R1/10 W2/10 35.74 30.17 5.57 0.84R1/10 W3/10 35.77 30.74 5.03 0.86

R2/10 W4/10 35.60 30.82 4.78 0.87

R1/11 W1/11 36.01 32.94 3.07 0.91

R2/11 W2/11 35.82 32.97 2.85 0.92

R1/12 W1/12 24.75 23.25 1.50 0.94

R2/12 W2/12 24.68 23.34 1.34 0.95

11 FOUNTAIN GREEN SQUARE

R3/10 W5/10 35.36 30.90 4.46 0.87R3/10 W6/10 35.23 30.48 4.75 0.87

R4/10 W7/10 35.11 31.02 4.09 0.88

R3/11 W3/11 35.64 33.09 2.55 0.93

R4/11 W4/11 35.46 33.13 2.33 0.93

R3/12 W3/12 24.54 23.53 1.01 0.96


R5/10 W8/10 34.89 31.09 3.80 0.89

R6/10 W9/10 34.59 30.73 3.86 0.89R6/10 W10/10 34.57 31.16 3.41 0.90

R5/11 W5/11 35.31 33.16 2.15 0.94

R6/11 W6/11 35.11 33.15 1.96 0.94

R4/12 W4/12 24.35 23.63 0.72 0.97



NOV 2012



1-59 AXIS COURT

R3/50 W3/50 19 9 28 21 5 26 2 0.56 0.93R3/50 W4/50 19 10 29 21 6 27 2 0.60 0.93R4/50 W5/50 19 9 28 21 6 27 1 0.67 0.96

R2/51 W2/51 0 0 0 1 0 1 -1 - -R2/51 W3/51 16 2 18 22 1 23 -5 0.50 1.28R3/51 W4/51 23 6 29 29 5 34 -5 0.83 1.17R4/51 W5/51 28 9 37 34 9 43 -6 1.00 1.16R4/51 W6/51 30 10 40 35 10 45 -5 1.00 1.13R5/51 W7/51 30 9 39 36 10 46 -7 1.11 1.18R5/51 W8/51 31 9 40 37 11 48 -8 1.22 1.20R6/51 W9/51 30 9 39 38 12 50 -11 1.33 1.28R7/51 W10/51 30 12 42 38 16 54 -12 1.33 1.29R8/51 W11/51 29 13 42 39 17 56 -14 1.31 1.33R8/51 W12/51 8 0 8 15 2 17 -9 - 2.13R9/51 W13/51 10 0 10 18 4 22 -12 - 2.20

R2/52 W2/52 0 0 0 7 2 9 -9 - -R2/52 W3/52 20 3 23 28 5 33 -10 1.67 1.43R3/52 W4/52 26 7 33 35 9 44 -11 1.29 1.33R4/52 W5/52 30 10 40 39 13 52 -12 1.30 1.30R4/52 W6/52 32 11 43 40 14 54 -11 1.27 1.26R5/52 W7/52 32 10 42 40 15 55 -13 1.50 1.31R5/52 W8/52 32 10 42 40 15 55 -13 1.50 1.31R6/52 W9/52 32 11 43 40 16 56 -13 1.45 1.30R7/52 W10/52 32 14 46 40 19 59 -13 1.36 1.28R8/52 W11/52 31 14 45 40 19 59 -14 1.36 1.31R8/52 W12/52 9 1 10 15 4 19 -9 4.00 1.90R9/52 W13/52 11 1 12 18 6 24 -12 6.00 2.00

1-47 LUNA HOUSE

R1/61 W1/61 26 8 34 28 13 41 -7 1.63 1.21R1/61 W2/61 26 10 36 20 15 35 1 1.50 0.97R2/61 W3/61 13 12 25 15 7 22 3 0.58 0.88R3/61 W4/61 11 11 22 15 7 22 0 0.64 1.00R4/61 W5/61 9 10 19 15 7 22 -3 0.70 1.16R5/61 W6/61 9 10 19 15 7 22 -3 0.70 1.16R6/61 W7/61 19 6 25 15 7 22 3 1.17 0.88R6/61 W8/61 14 0 14 6 0 6 8 - 0.43

R1/62 W1/62 28 9 37 28 15 43 -6 1.67 1.16



NOV 2012



R1/62 W2/62 28 13 41 40 19 59 -18 1.46 1.44R2/62 W3/62 14 12 26 40 20 60 -34 1.67 2.31R3/62 W4/62 11 11 22 40 20 60 -38 1.82 2.73R4/62 W5/62 9 10 19 40 20 60 -41 2.00 3.16R5/62 W6/62 9 10 19 40 20 60 -41 2.00 3.16R6/62 W7/62 21 6 27 40 20 60 -33 3.33 2.22R6/62 W8/62 14 0 14 14 0 14 0 - 1.00



NOV 2012



12-14 FOUNTAIN GREEN SQUARE

R1/10 W1/10 35.92 30.66 5.26 0.85R1/10 W2/10 35.74 30.17 5.57 0.84R1/10 W3/10 35.77 30.74 5.03 0.86

R2/10 W4/10 35.60 30.82 4.78 0.87

R1/11 W1/11 36.01 32.94 3.07 0.91

R2/11 W2/11 35.82 32.97 2.85 0.92

R1/12 W1/12 24.75 23.25 1.50 0.94

R2/12 W2/12 24.68 23.34 1.34 0.95


R3/10 W5/10 35.36 30.90 4.46 0.87R3/10 W6/10 35.23 30.48 4.75 0.87

R4/10 W7/10 35.11 31.02 4.09 0.88

R3/11 W3/11 35.64 33.09 2.55 0.93

R4/11 W4/11 35.46 33.13 2.33 0.93

R3/12 W3/12 24.54 23.53 1.01 0.96


R5/10 W8/10 34.89 31.09 3.80 0.89

R6/10 W9/10 34.59 30.73 3.86 0.89R6/10 W10/10 34.57 31.16 3.41 0.90

R5/11 W5/11 35.31 33.16 2.15 0.94

R6/11 W6/11 35.11 33.15 1.96 0.94

R4/12 W4/12 24.35 23.63 0.72 0.97



NOV 2012




R7/10 W11/10 34.43 31.08 3.35 0.90R7/10 W12/10 34.17 30.60 3.57 0.90

R8/10 W13/10 33.96 30.74 3.22 0.91

R7/11 W7/11 34.92 33.09 1.83 0.95

R8/11 W8/11 34.66 32.93 1.73 0.95

R5/12 W5/12 24.13 23.71 0.42 0.98


R9/10 W14/10 33.54 30.39 3.15 0.91

R10/10 W15/10 32.79 29.44 3.35 0.90R10/10 W16/10 32.72 29.67 3.05 0.91

R9/11 W9/11 34.42 32.73 1.69 0.95

R10/11 W10/11 34.12 32.40 1.72 0.95

R6/12 W6/12 23.87 23.59 0.28 0.99

212 BERMONDSEY WALL EAST

R1/20 W1/20 27.43 25.20 2.23 0.92

R1/21 W1/21 32.99 29.35 3.64 0.89

R1/22 W1/22 28.10 26.45 1.65 0.94

10-28 CHAMBERS STREET

R1/30 W1/30 10.73 12.60 -1.87 1.17R1/30 W2/30 7.99 9.68 -1.69 1.21

R2/30 W3/30 8.29 9.83 -1.54 1.19

R1/31 W1/31 18.42 21.47 -3.05 1.17R1/31 W2/31 17.44 20.13 -2.69 1.15

R2/31 W3/31 16.51 18.89 -2.38 1.14



NOV 2012



R2/31 W4/31 16.30 18.58 -2.28 1.14R2/31 W5/31 16.10 18.27 -2.17 1.13

R1/32 W1/32 21.18 25.13 -3.95 1.19R1/32 W2/32 19.95 23.20 -3.25 1.16

R2/32 W3/32 19.06 21.81 -2.75 1.14

1-59 AXIS COURT

R3/50 W3/50 18.87 17.39 1.48 0.92R3/50 W4/50 18.62 17.96 0.66 0.96

R4/50 W5/50 18.29 18.49 -0.20 1.01

R1/51 W1/51 10.09 13.74 -3.65 1.36

R2/51 W2/51 3.24 6.28 -3.04 1.94R2/51 W3/51 20.81 23.58 -2.77 1.13

R3/51 W4/51 23.58 26.70 -3.12 1.13

R4/51 W5/51 24.40 29.08 -4.68 1.19R4/51 W6/51 24.34 29.75 -5.41 1.22

R5/51 W7/51 24.08 30.41 -6.33 1.26R5/51 W8/51 23.88 30.91 -7.03 1.29

R6/51 W9/51 23.40 31.49 -8.09 1.35

R7/51 W10/51 22.38 32.20 -9.82 1.44

R8/51 W11/51 21.36 34.13 -12.77 1.60R8/51 W12/51 3.36 9.28 -5.92 2.76

R9/51 W13/51 3.76 13.01 -9.25 3.46

R1/52 W1/52 11.14 16.38 -5.24 1.47

R2/52 W2/52 3.89 10.79 -6.90 2.77R2/52 W3/52 22.58 30.77 -8.19 1.36

R3/52 W4/52 25.42 34.13 -8.71 1.34



NOV 2012



R4/52 W5/52 26.27 36.01 -9.74 1.37R4/52 W6/52 26.22 36.43 -10.21 1.39

R5/52 W7/52 25.97 36.74 -10.77 1.41R5/52 W8/52 25.77 36.97 -11.20 1.43

R6/52 W9/52 25.30 37.19 -11.89 1.47

R7/52 W10/52 24.30 37.68 -13.38 1.55

R8/52 W11/52 23.28 38.30 -15.02 1.65R8/52 W12/52 4.42 11.54 -7.12 2.61

R9/52 W13/52 4.92 16.37 -11.45 3.33

1-47 LUNA HOUSE

R1/61 W1/61 14.42 15.44 -1.02 1.07R1/61 W2/61 16.13 20.16 -4.03 1.25

R2/61 W3/61 10.97 13.97 -3.00 1.27

R3/61 W4/61 10.15 13.91 -3.76 1.37

R4/61 W5/61 10.36 13.88 -3.52 1.34

R5/61 W6/61 11.89 13.84 -1.95 1.16

R6/61 W7/61 21.81 13.77 8.04 0.63R6/61 W8/61 39.61 35.32 4.29 0.89

R1/62 W1/62 15.47 17.57 -2.10 1.14R1/62 W2/62 17.61 38.44 -20.83 2.18

R2/62 W3/62 12.54 38.50 -25.96 3.07

R3/62 W4/62 11.23 38.54 -27.31 3.43

R4/62 W5/62 11.17 38.55 -27.38 3.45

R5/62 W6/62 12.63 38.54 -25.91 3.05

R6/62 W7/62 22.46 38.56 -16.10 1.72R6/62 W8/62 39.61 39.53 0.08 1.00



115

Appendix E: Updated Figure 8.1 Chambers Wharf acoustic site accommodation diagram



116




117

Appendix F: Previous Thames Water representations to the ExA relating to Minerva (Wandsworth)

F.1.1 Thames Water has previously made representations to the ExA relating to Minerva (Wandsworth):

a. 4 November 2013. Examining Authority's First Written Questions and Requests for Information Response from Thames Water 11. Noise and Disturbance (Doc ref: APP11) (Question 11.38)

b. 2 December 2013. Thames Water's Response to Written Representation from Minerva (Wandsworth) Limited (Doc ref: APP31.30)

c. 23 December 2013. Written summaries of the cases put orally at the hearings held on 5 December 2013 (Doc ref: APP42.5) (questions 2.1 and 12.2)

d. 3 February 2014. Thames Water's response to Minerva Wandsworth Limited (Doc ref: APP103.05)

e. 3 February 2014. Written summaries of the cases put orally at the hearings held on 27 January 2014 (Doc ref: APP102.06)

f. 3 February 2014. Written summaries of the cases put orally at the hearings held on 28 January 2014 (Doc ref: APP102.07)



118




119

Appendix G: Statement of Common Ground between Minerva (Wandsworth) Limited and Thames Water Utilities Limited



120




121

Appendix H: Thames Water correspondence to Larry Broomhead of Wrayburn Residents Together, 26 February 2014



122


Thames Tideway Tunnel The Point 37 North Wharf Road Paddington, London W2 1AF

Tel: Fax: Web:

020 3147 7700 020 3147 7701 www.thamestidewaytunnel.co.uk

Registered in England and Wales No. 2366661 Registered office: Clearwater Court, Vastern Road Reading, Berkshire, RG1 8DB

Larry Broomhead Ref: 100-CO-CMN-OWNER-000714

By Email -

26 February 2014

Dear Larry, Wrayburn House Firstly it was good to have the opportunity to catch up with you at the recent hearing at Glaziers Hall. Thank you for your letter and your draft summary of the meeting which we note has been submitted to the Planning Inspectorate. We would like to thank you for taking the time to meet with us and organise the visit and we are grateful for the opportunity to further understand the issues you describe and to take into account the factors discussed on the visit, such as proximity. Please accept our apologies for not commenting on the summary when issued to us, while we understand your concerns as expressed in this summary we believe these do not accurately represent the views expressed by the members of the team at the meeting. I would like to assure you that we are absolutely committed to ensuring we do all we can to reduce the effects of our work on residents, businesses, the community and the environment. We are already dedicated to using construction techniques and equipment at our sites which will seek to minimise disruption; and, once construction begins, we will be monitoring our work, liaising closely with the local authority and local community, such that we are able to address impacts should they arise. Although every care will be taken to ensure that all of our sites cause minimum disruption to the local community and environment, inevitably some noise, dust and vibration will be emitted during each site’s operational hours. We will be monitoring this throughout the construction phase to ensure that any disturbance is kept to a reasonable level. We have issued to the Examining Authority, on the 12 February 2014, a section 106 unilateral undertaking that secures Thames Water’s commitment to implementing the Non Statutory Off-Site Mitigation and Compensation policy. I would point out that the section 106 undertaking is for the whole project and not with LB Southwark as it relates to the project wide and voluntary non-statutory policy. Any funds, or works, relating to this policy that may be made available to those eligible would not be through the section 106 deed with LB Southwark, as was explained at the meeting with you. The Non Statutory Off-site Mitigation and Compensation Policy includes the noise insulation policy, submitted to the Examining Authority and also available on our website. This policy describes who we would prepare a Trigger Action Plan for and why. By adopting this approach, we are providing a clear, transparent and equitable basis on which to engage all stakeholders around our sites. We are also providing further information about our extensive on-site mitigation.

On 14 February 2014 we also issued to the Examining Authority an update to the Environmental Statement, this update takes into account all changes to the scheme since submission of the application for development consent last year and sets out the likely significant environmental effects of the scheme at each of our worksites. You may have seen from this document that Wrayburn House is not identified as being significantly affected. Further to your emails, we would be grateful if you could provide further details of the refurbishment for Wrayburn House as proposed by LB Southwark. Once we have further information regarding this we will undertake an assessment taking into account the proposed changes to the building. In addition with regard to your offer to undertake a survey of residents, we would be pleased to receive such a survey and would also feed this into a future assessment of the forecast impacts for Wrayburn House. Thank you for your time and working with us to enable a greater understanding of Wrayburn House and its residents, although this is not a letter of intent as I know you would prefer, it is a request for further information to feed into our decision making process. I know that you have Belinda’s contact details, so please continue to send Belinda information and if you have any questions we can arrange for a member of the project team to contact you directly. Yours sincerely,

Phil Stride Head of Thames Tideway Tunnel

Copyright notice

All rights reserved. Any plans, drawings, designs and materials (materials) submitted by Thames Water Utilities Limited (Thames Water) as part of this application for Development Consent to the Planning Inspectorate are protected by copyright. You may only use this material (including making copies of it) in order to (a) inspect those plans, drawings, designs and materials at a more convenient time or place; or (b) to facilitate the exercise of a right to participate in the pre-examination or examination stages of the application which is available under the Planning Act 2008 and related regulations. Use for any other purpose is prohibited and further copies must not be made without the prior written consent of Thames Water. Thames Water Utilities LimitedClearwater Court, Vastern Road, Reading RG1 8DB The Thames Water logo and Thames Tideway Tunnel logo are © Thames Water Utilities Limited. All rights reserved.

Copyright © Thames Water Utilities Limited March 2014.