Supp Report on P2 Consultation - Chapter 10 Carnwath Road Riverside

7/31/2019 Supp Report on P2 Consultation - Chapter 10 Carnwath Road Riverside

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

Supplementary reporton phase twoconsultation

Chapter 10 Carnwath Road Riverside


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10 Carnwath Road Riverside

Thames Tunnel

Supplementary report on phase two consultation

List of contents

Page number

10 Carnwath Road Riverside ........................................................................... 10-110.1 Introduction ......................................................................................... 10-110.2 Number of respondents ...................................................................... 10-210.3 Site selection ...................................................................................... 10-210.4 Alternative sites ................................................................................ 10-2210.5 Management of construction works .................................................. 10-2910.6 Permanent design and appearance .................................................. 10-9710.7 Management of operational effects ................................................ 10-11010.8 Our view of the way forward ........................................................... 10-140


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List of tables

Page numberTable 10.2.1 Number of respondents who provided feedback on Carnwath Road

Riverside ........................................................................................ 10-2Table 10.3.1 Views on whether Carnwath Road Riverside should be our preferred

site (Q2).......................................................................................... 10-3Table 10.3.2 Supportive and neutral comments feedback comments in relation to

selection of our preferred site ......................................................... 10-3

Table 10.3.3 Objections, issues and concerns in relation to selection of ourpreferred site .................................................................................. 10-8

Table 10.3.4 Supportive and neutral feedback comments in relation to shortlistedsites .............................................................................................. 10-20

Table 10.4.1 Suggested alternative sites to Carnwath Road Riverside ............. 10-22Table 10.4.2 Supportive and neutral comments in relation to the availability and

identification of alternative sites .................................................... 10-28Table 10.4.3 Objections, issues and concerns in relation to the availability and

identification of alternative sites .................................................... 10-29Table 10.5.1 Do you agree that we have identified the right key issues in the site

information paper? (Q4a) ............................................................. 10-30Table 10 5 2 Do you agree that we have identified the right way to address the key


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Table 10.5.12 Objections, issues and concerns in relation to construction site designand layout ..................................................................................... 10-45

Table 10.5.13 Objections, issues and concerns in relation to the historic environmentduring construction ....................................................................... 10-46

Table 10.5.14 Objections, issues, concerns and suggestions to address the effectson the historic environment issues during construction ................ 10-47

Table 10.5.15 Objections, issues and concerns in relation to land quality andcontamination during construction ................................................ 10-47

Table 10.5.16 Objections, issues and concerns in relation to lighting duringconstruction .................................................................................. 10-49

Table 10.5.17 Objections, issues, concerns and suggestions for addressing theeffects of lighting during construction ........................................... 10-50

Table 10.5.18 Objections, issues and concerns relating to the natural environment(aquatic) during construction ........................................................ 10-51

Table 10.5.19 Objections, issues, concerns and suggestions for addressing naturalenvironment (aquatic) issues during construction ........................ 10-51

Table 10.5.20 Supportive and neutral comments in relation to the naturalenvironment (terrestrial) ............................................................... 10-51

Table 10.5.21 Objections, issues and concerns in relation to the natural environment(terrestrial) .................................................................................... 10-52

Table 10 5 22 Objections iss es concerns and s ggestions to address effects on


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Table 10.5.33 Objections, issues and concerns in relation to socio-economic issuesduring construction ....................................................................... 10-71

Table 10.5.34 Objections, issues, concerns and suggestions for addressing socio-economic effects during construction ........................................... 10-78

Table 10.5.35 Supportive and neutral comments in relation to structures and utilitiesduring construction ....................................................................... 10-79

Table 10.5.36 Objections, issues and concerns in relation to structures and utilitiesduring construction ....................................................................... 10-79

Table 10.5.37 Objections, issues, concerns and suggestions to address themeasures proposed in relation to the effects on structures and utilitiesduring construction ....................................................................... 10-80

Table 10.5.38 Supportive and neutral comments in relation to townscape and visualissues during construction ............................................................ 10-82

Table 10.5.39 Objections, issues and concerns in relation to townscape and visualissues during construction ............................................................ 10-82

Table 10.5.40 Objections, issues, concerns and suggestions to address townscapeand visual effects during construction .......................................... 10-83

Table 10.5.41 Supportive and neutral comments in relation to transport and accessduring construction ....................................................................... 10-83

Table 10.5.42 Objections, issues and concerns in relation to transport and accessduring construction ....................................................................... 10-85


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Table 10.7.3 Supportive and neutral feedback comments relating to general keyissues during operation .............................................................. 10-111

Table 10.7.4 Objections, issues and concerns relating to general key issues duringoperation .................................................................................... 10-112

Table 10.7.5 Supportive and neutral feedback comments in relation to measures toaddress the key issues during operation .................................... 10-116

Table 10.7.6 Objections, issues and concerns in relation to measures to addressthe key issues during operation .................................................. 10-116

Table 10.7.7 Supportive and neutral feedback comments in relation to air qualityand odour issues during operation ............................................. 10-120

Table 10.7.8 Objections, issues and concerns in relation to air quality and odourissues during operation .............................................................. 10-120

Table 10.7.9 Supportive and neutral feedback comments in relation to measuresproposed to address air quality and odour issues during operation . 10-122

Table 10.7.10 Objections, issues, concerns and suggestions to address air qualityand odour issues during operation ............................................. 10-123

Table 10.7.11 Objections, issues and concerns in relation to land quality andcontamination issues during operation ....................................... 10-124

Table 10.7.12 Supportive and neutral feedback comments in relation to naturalenvironment (terrestrial) issues during operation ....................... 10-125


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Table 10.7.23 Objections, issues, concerns and suggestions to address socio-economic issues during operation .............................................. 10-132

Table 10.7.24 Objections, issues and concerns in relation to structures and utilitiesissues during operation .............................................................. 10-133

Table 10.7.25 Objections, issues, concerns and suggestions to address structuresand utilities issues during operation ........................................... 10-133

Table 10.7.26 Supportive and neutral feedback comments in relation to townscapeand visual issues during operation ............................................. 10-134

Table 10.7.27 Objections, issues and concerns in relation to townscape and visualissues during operation .............................................................. 10-134

Table 10.7.28 Objections, issues, concerns and suggestions to address townscapeand visual issues during operation ............................................. 10-134

Table 10.7.29 Supportive and neutral feedback comments in relation to transport andaccess issues during operation .................................................. 10-135

Table 10.7.30 Objections, issues and concerns in relation to transport and accessissues during operation .............................................................. 10-135

Table10.7.31 Supportive and neutral feedback comments in relation to measuresproposed to address transport and access issues during operation . 10-136

Table 10.7.32 Objections, issues, concerns and suggestions to address transportand access issues during operation ........................................... 10-137


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Supplementary report on phase two consultation 10-1


10.1 Introduction

10.1.1 This chapter covers the feedback comments received during phase two consultation regarding the our preferred site Carnwath Road Riverside. This site would be used to drive the maintunnel to Acton Storm Tanks and receive the main tunnel from Kirtling Street. Carnwath Road Riverside would also receive a long connection tunnel (the Frogmore connection tunnel),which would be driven from Dormay Street.

10.1.2 At phase one consultation, our preferred main drive site was Barn Elms. However, following reassessment of potential sites and the tunnelling strategy, Carnwath Road Riverside wasidentified as our preferred main tunnel drive site and presented at phase two consultation. Barn Elms is still our preferred site to intercept the West Putney Storm Relief CSO (see chapter6). For further information regarding the proposals at Carnwath Road Riverside at phase two consultation, refer to the Carnwath Road Riverside site information paper.

10.1.3 Sections 10.3 (site selection) and 10.4 (alternative sites) of this chapter present feedback on alternative shortlisted sites to Carnwath Road Riverside, which were identified at phase twoconsultation. These are:

Barn Elms (site 1)

Feathers Wharf (site 2)

Fulham Depot (site 3).

Structure of this chapter

10.1.4 This chapter is organised as listed below, which reflects the structure of the phase two consultation feedback form.

section 10.2 number of respondents

section 10.3 site selection section 10.4 alternative sites

section 10.5 management of construction works

section 10.6 permanent design and appearance

section 10.7 management of operational effects

section 10.8 our view of the way forward.

1.1.1 In sections 10.3 to 10.7we present details of the feedback comments raised, the types and total number of respondents, and our response to feedback comments. Where specificobjections, issues or concerns have been raised, the final column of the tables indicates whether, in response to the feedback received:

C we are considering or proposing change or additional mitigation1 to that set out in our phase two consultation material

N we do not propose to amend our proposals.

10.1.5 A full list of the phase two consultation material is set out in annex A to this report. Where a response contains reference to our website, go to www.thamestunnelconsultation.co.uk for

further information, or to access the documents referred to.10.1.6 Where more than 250 respondents have made a feedback comment the details of the respondent IDs are set out in annex C to this report.

1Mitigation here refers to a wide range of measures set out in our phase two consultation proposals including for example, the Air management planand other documents as well as those mitigation measures set out in the PEIR.
http://www.thamestunnelconsultation.co.uk/http://www.thamestunnelconsultation.co.uk/


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10.2 Number of respondents

10.2.1 A total of 3,136 respondents and two petitions provided comments on Carnwath Road Riverside, of which 41 were received after the close of our phase two consultation. Table 10.2.1 setsout the different groups who provided feedback for this site.

Table 10.2.1 Number of respondents who provided feedback on Carnwath Road Riverside

Statutory consultees Local authorities Landowners Community consultees Petitions

7 respondents

- Design Council CABE (CABE)

- Consumer Council for Water (CCW)

- English Heritage (EH)

- Environment Agency (EA)

- Greater London Authority (GLA)

- London Councils (LC)

- Port of London Authority (PLA)

3 respondents

- London Borough ofHammersmith and Fulham(LBHF)

- London Borough of RichmondUpon Thames (LBR)

- London Borough ofWandsworth (LBW)

21 respondents 3,105 respondents 2 petitions

- 291 signatories

- 4,766 signatories

10.2.2 Feedback was received in a number of forms, including: feedback forms, an alternative Carnwath Road Riverside feedback form, correspondence (emails and letters) and two petitions.

10.3 Site selection

10.3.1 A series of sites is required in order to build and operate the Thames Tunnel project. To determine our preferred scheme, a site selection process is being undertaken, using amethodology which was adopted after consultation with the relevant local authorities and statutory consultees. For further information on our methodology and the process we are

following, refer to: Site selection project information paperwhich sets out the process we followed to find and select our preferred sites

Site selection methodology paperwhich details the methodology used to select construction sites along the route of the main tunnel

Site selection background technical paperwhich provides supporting technical information to the Site selection methodology paper such as the engineering requirements for size ofconstruction sites.

10.3.2 The results of the site selection process up to phase two consultation are set in:

Site information papers which provide summary information on each of our preferred sites, including the reasons for selecting them

Phase two scheme development reportwhich describes how our proposals for the Thames Tunnel project have evolved and provides a detailed account of the site selection processfor each of the preferred sites.

10.3.3 In this section, we set out the feedback comments received in relation to the selection of Carnwath Road Riverside as our preferred site, together with our responses. Our responsesprovide relevant details of the site selection process and its findings up to phase two consultation. Where appropriate we have also identified further work tha t we have undertaken inrelation to our preferred site, such as the preparation of our Preliminary environmental information report(PEIR). As part of the project design development process, we continue to assess

how the effects arising from the proposed development can be addressed. The output of our assessment up to phase two consultation is contained in appendix G of the Designdevelopment reportand our PEIR(volume 13).

10.3.4 Where respondents commented on matters in relation to management of construction works, permanent design and appearance or the management of operational effects at CarnwathRoad Riverside, these comments are reported in sections 10.5 to 10.7.

Number of respondents

10.3.5 During the phase two consultation, respondents were asked to comment on the decision to select Carnwath Road Riverside as our preferred site to drive the main tunnel to Acton StormTanks (see question 2 of the phase two consultation feedback form, provided in Appendix M of the Main report on phase two consultation). Table 10.3.1 sets out details of the differentgroups who responded and were asked to select supportive, opposed/concerned or dont know/unsure. Tables 10.3.2 and 10.3.3 then detail the feedback comments received inrelation to this site. It should be noted that not all respondents who provided feedback comments selected supportive, opposed/concerned or dont know/unsure .


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Table 10.3.1 Views on whether Carnwath Road Riverside should be our preferred site (Q2)

Respondent type Number of respondents

Total Supportive Opposed/ concerned Dont know/ unsure

Statutory consultees 0

Local authorities 2 1

- LBR

1

- LBHF

Landowners 18 1 16 1

Community consultees 2,891 203 2,622 66

Petitions 1 1

- 291 signatories

Total 2,912 205 2,640 67

Supportive and neutral feedback comments in relation to our preferred site

Table 10.3.2 Supportive and neutral comments feedback comments in relation to selection of our preferred site

Ref Supportive and neutral comments Respondent ID No. Our response

10.3.6 Support the use of the preferred site. 7729LO, 11014, 11026, 11112, 11308,11450, 11539, 11565, 11675, 11757,11823, 11888, 12114, 12189, 12210,12282, 12435, 12565, 12588, 12590,

12609, 12720, 12742, 12777, 12951,12995, 13012, 13015, 13217, 7124, 7323,7418, 7784, 7871, 7901, 7905, 7997,8118, 8736, 9382, 9486, LR9236, LR9447

43 Your support is noted and welcomed.

10.3.7 Support the identification of a new preferredsite since phase one consultation/ thepreferred site is more suitable than the siteput forward at phase one consultation.Reasons included:

- the site has better access and local roadinfrastructure

- it would reduce the number of bargestravelling under Putney Bridge, which willreduce the risk for recreational river users

- the site is a disused brownfield siteadjacent to an industrial park

- use of a greenfield site over a brownfieldsite would be hard to justify

- use of this site would not result in the lossof green space; Barn Elms is veryvaluable recreational resource which isused by a lot of people

- there would be less conflict with

GLA, PLA, LBR, LBW, 13471, 13479,13483, 7009, 7128, 7160, 7175, 7288,7359, 7383, 7604, 7641, 7744, 7814,7860, 7873, 7878, 7887, 7891, 7901,7915, 7930, 7953, 7955, 7963, 7970,7980, 7995, 8029, 8034, 8147, 8148,8149, 8150, 8151, 8152, 8153, 8162,8163, 8164, 8165, 8166, 8167, 8168,8169, 8171, 8172, 8173, 8174, 8175,8176, 8179, 8185, 8190, 8195, 8202,8216, 8219, 8224, 8276, 8281, 8292,

8322, 8408, 8502, 8516, 8517, 8518,8520, 8522, 8523, 8524, 8526, 8535,8576, 8578, 8580, 8582, 8583, 8584,8587, 8592, 8593, 8594, 8596, 8597,8599, 8601, 8603, 8605, 8607, 8616,8618, 8619, 8620, 8623, 8637, 8638,8671, 8695, 8696, 8699, 8700, 8701,8709, 8710, 8728, 8729, 8730, 8757,8774, 8777, 8800, 8804, 8810, 8816,8822, 8825, 8860, 8871, 8880, 8905,

188


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recreational river users

- there would be less impact on theThames Path

- the site has better and more reliable riveraccess

- The environmental and recreationalimpact would be lower

- Barn Elms has a higher density ofresidences

- fewer residents would be directly affecteddownstream sites should be favouredover equivalent upstream sites as thespoil has to be taken east

- it relocates major tunnelling activities froma greenfield to a partially derelictbrownfield site and increases the viabilityof barge transport by using a currentlyvacant safeguarded wharf.

8925, 8945, 8955, 8961, 8966, 8974,8977, 8986, 9001, 9002, 9005, 9006,9009, 9010, 9020, 9033, 9042, 9055,9056, 9057, 9058, 9059, 9060, 9063,9067, 9068, 9069, 9073, 9102, 9151,9155, 9159, 9166, 9191, 9205, 9209,9239, 9240, 9245, 9248, 9262, 9281,9296, 9300, 9351, 9354, 9362, 9364,

9367, 9372, 9408, 9423, 9429, 9431,9442, LR13383, LR13385, LR13478,LR9164, LR9236, LR9276, LR9447

10.3.8 The preferred site is more suitable than anyalternative site.

7758, 7781, 8280, 8742 4

10.3.9 The preferred site is more suitable than any

of the shortlisted site(s) - specifically BarnElms (site 1).

7839, 8289 2

10.3.10 Thames Water has taken objections raisedat phase one consultation into account insite selection.

8034, 8514, 8580, 8977, 9001, 9002,9042, 9262, 9429, LR9236

10 Noted. We have considered the comments received at phase oneconsultation and where possible these have been incorporated into therevised proposals we presented at phase two consultation. Feedbackreceived at phase one consultation is one the factors that hascontributed to us changing our preferred main tunnel drive site fromBarn Elms to Carnwath Road Riverside.

10.3.11 Characteristics which make the site suitable,included:

- existing wharves and river access

- better quayside mooring facilities forbarges

- good road access

- proximity to strategic road network

- being on the inside of a river bend, tidalscouring has created a wider tidal rangeand deeper channel with capacity forlarger barges (850 tonnes rather than 350tonnes)

- the width and height of the navigationalspan of Wandsworth Bridge, is betterthan Putney Bridge.

13479, 7160, 7223, 7744, 7750, 7754,7839, 7855, 7887, 7889, 7938, 8147,8151, 8202, 8281, 8289, 8502, 8535,8592, 8619, 8637, 8638, 8671, 8708,8728, 8777, 8825, 8871, 8955, 8966,9020, 9144, 9151, 9354, 9382, 9408,

9442, LR13385, LR13478, LR9447

40 Noted.

.


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10.3.12 The site is a cost-effective option,specifically relating to the opportunity to usethe river to transport materials and the sizeof barge that can be accommodated.

8289 1

10.3.13 The site is currently vacant/derelict/availablefor redevelopment.

11014, 13479, 7744, 7825, 7855, 8098,8118, 8148, 8149, 8150, 8152, 8153,8162, 8163, 8164, 8165, 8166, 8167,8168, 8169, 8173, 8174, 8175, 8179,8202, 8518, 8584, 8592, 8593, 8594,8596, 8597, 8599, 8603, 8605, 8607,8620, 8681, 8695, 8699, 8700, 8709,8710, 8800, 8804, 8955, 9033, 9056,9057, 9058, 9059, 9060, 9144, 9245,9354, 9364, 9382, 9423, LR13478

59

10.3.14 The site will be a catalyst forregeneration/redevelopment/improvementsto the local area.

8847 1

10.3.15 The site is currently underutilised. 7124, 7754 2

10.3.16 Site is of limited value to the localcommunity.

7762 1

10.3.17 Agree with the reasons for selecting the

preferred site, as set out in the siteinformation paper.

7251, 7275 2

10.3.18 Support the site selection because theproject needs to be undertaken.

13015, 7997, 8118 3

10.3.19 The site is a suitable size and/or hassufficient capacity to accommodate theproposals.

13483 1 Agreed.

10.3.20 It is a brownfield site. LBR, 13471, 13479, 13483, 7009, 7128,7160, 7175, 7223, 7251, 7288, 7418,7478, 7507, 7744, 7750, 7754, 7771,7814, 7825, 7839, 7873, 7878, 7889,7891, 7903, 7904, 7905, 7930, 7938,7953, 7955, 7970, 7980, 7985, 8015,8029, 8034, 8098, 8148, 8149, 8150,8151, 8152, 8153, 8162, 8163, 8164,8165, 8166, 8167, 8168, 8169, 8173,8174, 8175, 8176, 8185, 8190, 8202,8216, 8276, 8289, 8322, 8332, 8502,8518, 8522, 8523, 8524, 8535, 8578,8580, 8582, 8583, 8584, 8587, 8592,8593, 8594, 8596, 8597, 8599, 8601,8603, 8605, 8607, 8616, 8619, 8620,8623, 8637, 8638, 8671, 8695, 8699,8700, 8701, 8708, 8709, 8710, 8728,

140 Noted. The preferred site is brownfield land and was one of theconsiderations taken into account as part of our site selection process.


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8730, 8766, 8777, 8800, 8804, 8825,8871, 8880, 8955, 8961, 8966, 8974,9009, 9020, 9033, 9056, 9057, 9058,9059, 9060, 9067, 9072, 9144, 9151,9167, 9245, 9247, 9262, 9281, 9351,9354, 9364, 9367, 9408, 9429, 9442,LR13478, LR9447

10.3.21 The site is an industrial site. 13471, 7016, 7801, 7891, 7905, 7953,

8028, 8179, 8578, 9245

10 Noted. Using industrial land was one of the considerations taken into

account as part of our site selection process.

10.3.22 Proposals are compatible with existing usesin the vicinity of the site, which includesindustrial uses.

13479, 7855, 8118, 8148, 8149, 8150,8152, 8153, 8162, 8163, 8164, 8165,8166, 8167, 8168, 8169, 8173, 8174,8175, 8518, 8592, 8593, 8594, 8596,8597, 8599, 8601, 8603, 8605, 8607,8620, 8637, 8638, 8695, 8699, 8700,8701, 8708, 8709, 8710, 8800, 8804,8955, 9033, 9056, 9057, 9059, 9060,9144, 9354, 9364, 9408, 9429, LR13478

54 Noted. Compatibility between our proposals and existing uses at a site isone of the considerations taken into account as part of our site selectionprocess.

10.3.23 The site is sufficiently far away fromresidential areas/is not a residential area

7801 1 Noted. Effect on residents was one of the considerations taken intoaccount as part of our site selection process as well as the ability tomitigate likely significant effects.

10.3.24 Use of the site would have limited effects on

the local area and community.

11607, 12087, 7124, 7801, 7903, 7904,

7985, 8028, 8280

9

10.3.25 Use of the site would not result in the loss ofopen space/use of greenfield sites.

7839, 7873, 8190, 8578, 8587, 8730,8825, 9072, 9281

9 Noted. Open space is one of the considerations taken into account aspart of our site selection process.

10.3.26 Not qualified to comment on this technicalmatter.

7220 1 The purpose of consultation is to explore as fully as possible what thosewith an interest in the project think about our proposals. We will haveregard to comments received from both technical and non-technicalconsultees.

10.3.27 Other supportive comments included:

- all sites will be disruptive duringconstruction and should be acceptedgiven the long-term benefit of the project

- use of this site will minimise material riskto wildlife and the environment

- the site has already been subject to large-scale development, and will continue tobe so in the years ahead

- it is an essential project which has to berealised without delay; any delay willresult in further speculative developmentsclose to the available sites

- appreciate that there are goodengineering reasons to create a shortertunnel from a main drive site at Carnwath

7744, 7777, 7855, 7891, 7904, 7997,8118, 8401, 8541

9 Your comments are noted.


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Road.

Other comments included:

- shocked and concerned about the cynicalstirring up of concerns amongst localresidents and the knee jerk reaction fromthe council

- should not hold the project back as a

consequence of 'NIMBY' protestors- it is selfish to only consider personal

interests by opposing a project that willbenefit the whole of London.

10.3.28 Qualified support for the preferred siteincluded:

- any site is acceptable subject toappropriate mitigation

EH, 9434LO, 7777, 7975, 8098, 9253 6 Since selecting Carnwath Road Riverside as our preferred site, we havebegun assessing the likely significant effects that may arise as a resultof the works as part of an environmental impact assessment. This willset out measures necessary to mitigate any likely significant effects thatare identified. An Environmental statement, which records the findings ofthe environmental impact assessment, will accompany our DCOapplication.The initial environmental assessment work that has beencarried out on the project is contained within the PEIR(volume 13),which is available on our website. As part of the phase two consultation,we have also sought feedback on the potential likely significant effectsarising from our proposals and how the effects will be mitigated. Where

possible, we will take feedback comments into account as we developour proposals. .

- odour must be controlled Refer to paragraphs 10.5.56 and 10.7.47 for our response to thisfeedback comment.

- ventilation shafts must be incorporatedinto future development

We are currently considering our design proposals for the site and willconsider how we can take your comments into consideration.

- the river must be used to transportexcavated material and bulky goods

Refer to paragraph 10.5.353 for our response to this feedback comment.

- subject to confirmation that ThamesWater will not require any highwayimprovements and/or sufficientenvironmental information to enableothers to make this assessment

Refer to paragraph 10.5.341 in relation to highway improvement works.

With regard to provision of environmental information, we consider thatwe have undertaken a thorough and comprehensive consultationexercise. As part of this, we carefully considered the information wemade available at our phase two consultation to ensure that consultees

had sufficient information to respond to the consultation. Information ofkey likely significant environmental effects was contained in theCarnwath Road Riverside site information paperwith further detailscontained within the PEIR(volume 13) and the draft CoCP. We areconfident therefore that the information we have provided is sufficient.

- require additional information fromThames Water to demonstrate that therewill be no unacceptable noise, vibrationand socio-economic impacts.

Refer to paragraphs 10.5.141 and table 10.5.213 for our response to thisfeedback comment.


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Objections, issues and concerns

Table 10.3.3 Objections, issues and concerns in relation to selection of our preferred site

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

10.3.29 Object to the use of this preferred site. 13397LO, 7285LO, 9169LO, 9400LO,9417LO, 9481LO, 11018, 11040, 11041,11104, 11133, 11156, 11232, 11261,11316, 11330, 11341, 11410, 11411,11414, 11438, 11452, 11453, 11457,

11496, 11564, 11623, 11687, 11754,11759, 11834, 11865, 12015, 12539,12598, 12616, 12635, 12756, 12793,13061, 13099, 7007, 7015, 7035, 7120,7121, 7125, 7142, 7143, 7186, 7254,7276, 7345, 7353, 7362, 7363, 7382,7388, 7409, 7411, 7417, 7430, 7433,7435, 7440, 7461, 7470, 7482, 7495,7512, 7513, 7516, 7519, 7522, 7523,7527, 7532, 7544, 7545, 7564, 7673,7693, 7702, 7731, 7751, 7780, 7786,7856, 7892, 7931, 8020, 8096, 8103,8288, 8472, 8542, 8749, 8839, 8855,8870, 8878, 8906, 8913, 8923, 8926,9008, 9024, 9034, 9037, 9201, 9377,

9421PET

112 The sites that we consulted on at phase two consultation have beenidentified through an extensive site selection process (see our Siteselection methodology paperon our website). We consulted and agreedthe methodology prior to its use with key stakeholders includingpotentially directly affected local authorities and utilised a

multidisciplinary approach to assess potential main tunnel sites anddrive options against engineering, planning, environmental, property andcommunity considerations.

We recognise that, given the locations where we are seeking toconstruct and operate the tunnel, many of the shortlisted sites areconstrained. However, based on our assessment we consider that, onbalance, Carnwath Road Riverside is the most suitable site. Generally,this is because it is a brownfield site and the presence of wharves at thissite, combined with the width of the River Thames at this point, wouldallow the use of larger barges to remove material excavated duringconstruction of the main tunnel. There would be much less conflict withrecreational users of the River Thames than at Barn Elms.

For more detailed response to the specific alternative site suggestionsreceived, refer to:

- specifically one in a less densely populated or residential areaparagraph 10.3.47

- several south of the River Thames paragraph 10.4.27- Wandsworth Park paragraph 10.4.16- between Putney and Hammersmith Bridge paragraphs 10.4.25 and

10.4.28.- Battersea Power Station paragraph 10.4.8- industrial sites paragraph 10.3.45- less costly options paragraph 10.3.57- other unpopulated sites paragraph 10.4.33.

For further details on the results of the site selection process includingour assessment of shortlisted sites, refer to appendix G of the Phasetwo scheme development report.

10.3.30 Disagree with the selection of this preferredsite.

9417LO, 9481LO, 7341, 7424, 7434, 7439,7466, 7544, 7657, 7794, 8030, 8037, 9303

13

10.3.31 This preferred site is generally unsuitable. LBHF, 8082LO, 11018, 11065, 11100,11135, 11260, 11274, 11280, 11373,11435, 11464, 11469, 11470, 11497,11500, 11608, 11625, 11660, 11706,11707, 11716, 11755, 11799, 11802,11807, 11862, 11874, 11902, 11952,11958, 11967, 11983, 12173, 12343,12446, 12449, 12451, 12452, 12456,12529, 12533, 12543, 12596, 12603,12666, 12689, 12703, 12707, 12743,12779, 12796, 12829, 12839, 12910,12973, 12982, 12990, 12992, 13004,13006, 13033, 13067, 13094, 13104,13112, 13138, 13150, 13191, 13204,13230, 13233, 7005, 7125, 7135, 7156,7168, 7177, 7178, 7197, 7217, 7228,7235, 7259, 7276, 7335, 7336, 7342,7343, 7345, 7394, 7464, 7472, 7478,7480, 7486, 7499, 7504, 7507, 7523,7526, 7527, 7532, 7544, 7553, 7565,7633, 7671, 7675, 7691, 7702, 7751,7794, 7836, 7894, 7922, 7932, 7934,

136


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7949, 8011, 8112, 8124, 8313, 8550,8636, 8678, 8727, 8736, 8820, 8839,8888, 8891, 9441, 9460, LR13422,LR9418

10.3.32 Do not support the specific location of thesite.

7359 1

10.3.33 Should use/consider an alternative site -

specifically one in a less densely populatedor residential area.

See annex C of this report 395

10.3.34 There are other more suitable alternativesites available in the local area, includingseveral south of the River Thames,Wandsworth Park, between Putney andHammersmith Bridge, Battersea PowerStation, industrial sites, less costly options,and other unpopulated sites.

9131LO, 11015, 11099, 11368, 11467,11669, 11878, 12234, 12417, 13014,13091, 13099, 7104, 7135, 7177, 7180,7197, 7201, 7220, 7221, 7241, 7269,7341, 7396, 7408, 7532, 7538, 7544,7575, 7663, 7671, 7673, 7728, 7824,8100, 8313, 8683, 8838, 8878, 9461,9421PET

41

10.3.35 Alternative sites have not been properlyconsidered.

11058, 11504, 11702, 12097, 12107,12111, 12117, 12306, 12326, 12367,12405, 12407, 12480, 12768, 12769,12789, 12885, 12927, 12945, 12980,12991, 13003, 13040, 13152, 7201, 7847,8581, 8693

28

10.3.36 Site selection has not incorporatedcomments and objections from phase oneconsultation or interim engagement.

7127, 7378, 9377 3 Following phase one consultation, we considered the comments fromphase one consultation, along with feedback from on-goingengagement, new information and undertook further technical work. Thistriggered a review of all potential main tunnel sites betweenHammersmith Bridge and Albert Bridge. The result of this review andassessment (which was based on our agreed site selectionmethodology) was that we changed our preferred main tunnel drive sitefrom Barn Elms to Carnwath Road Riverside. Therefore, it is difficult tomaintain that we did not consider feedback to phase one consultationbecause this resulted in a number of changes to sites, use of sites andour drive strategy in the western end of the main tunnel.

For further details of how we have taken account of the feedbackreceived at phase one consultation and interim engagement refer to our

Report on phase one consultationand Interim engagement report.

10.3.37 The preferred site put forward at phase oneconsultation, Barn Elms, is more suitablebecause:

- the scale and type of impact is moreacceptable

- it would have less impact on residentialamenity and the local community

- less impact on business

See annex C of this report 1,319 We considered the comments from phase one consultation, along withfeedback from on-going engagement, new information and undertookfurther technical work. As set out in appendix G of the Phase twoscheme development report, the following reasons triggered ourdecision to review whether Barn Elms remained the most suitable maintunnel drive site. These were:

- We were aware that LBHF had changed the planning policydesignation at the Hammersmith Pumping Stati on site from mixed use


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- it will not hold back wider regeneration

- the site is less physically constrained interms of river access, contamination andsize

- it is a cheaper option

- recreational impacts can be satisfactorilymitigated

- the site can be easily restored followingcompletion of construction

- local road infrastructure is more suitableand traffic disruption would be minimised

- combined sewer overflow (CSO)interception and main tunnel drive sitesshould be combined

- there is no reasonable reason why thissite cannot be used.

to residential. As a result of this, at the time of our review a newplanning application for a residential development on the part of thesite which excluded Hammersmith Pumping Station had beensubmitted. This planning application has now been approved andconstruction works have commenced.

- because of strategic design developments, the long connection tunnelbetween Hammersmith Pumping Station and Acton Storm Tanks,which needed to be the same width at the main tunnel, and therefore

the main tunnel needed to be extended to Acton Storm Tanks.- review of tunnelling strategy for the western part of the main tunnel.

- further technical work on barge movements at Barn Elms confirmedthat only 350 tonne barges could be used to transport materials byriver. Due to the short tidal window, this limited the amount of materialwhich could be transported by river. The reduced width of the RiverThames at this location also increases the potential for conflictbetween barge operators and recreational users of the River Thames.

- comments from phase one consultation on the effects of using BarnElms as a main tunnel drive site.

- changes in the engineering site size assumptions which underpin thesearch for suitable sites.

As a result of a review of possible sites, Barn Elms and Carnwath RoadRiverside emerged as the two most suitable sites. We consider that

Carnwath Road Riverside is more suitable than Barn Elms because:- Carnwath Road Riverside is a brownfield site while Barn Elms is a

greenfield site.

- Carnwath Road Riverside includes a safeguarded wharf and hasmuch better river access for transportation of construction materials,using significantly larger barges (800 1000 tonne rather than 350tonne) than can reach Barn Elms.

- at Carnwath Road Riverside, there would be less conflict withrecreational users of the River Thames than at Barn Elms.

- Carnwath Road Riverside has better direct access to the public roadnetwork and links to the strategic road network. In contrast, at BarnElms there would be a need to construct lengthy temporary accessroads across the Barn Elms playing fields to local roads.

- use of Carnwath Road Riverside is less disruption to the Thames

Path than at Barn Elms. The Thames Path is already diverted aroundthe site at Carnwath Road Riverside.

- use of this site will have less impact on the natural and builtenvironment in terms of planning policies and designations whereasusing Barn Elms as a main tunnel drive site would affect MOL, thesite is adjacent to a SSSI (Wetlands Centre), would affect Barn ElmsPlaying Fields and would necessitate need to demolish localcommunity boating facility etc.

Further information including responses to the detailed points raised iscontained within appendix G of the Phase two scheme development

10.3.38 Reasons for changing the preferred sitesince phase one consultation areunclear/unjustified/unsatisfactory. Inparticular:

- too much weight has been given to the

'greenfield' and Metropolitan Open Land(MOL) status of the site

- local planning policies have beenmisapplied

- the temporary impact on a greenfieldsite/MOL is acceptable, as acknowledgedby Thames Water

- the scale of impact on the localcommunity resulting from the use ofCarnwath Road is unacceptable, vsenvironmental/recreational impacts atBarn Elms

- the issues relating to site constraints suchas foreshore depth apply to both sites

- the scale of impact associated with usingCarnwath Road and its feasibility as amain drive site has not been fullyidentified/ assessed

LBHF, 13397LO, 8843LO, 9131LO,9261LO, 9392LO, 9481LO, 11011, 11022,11038, 11042, 11043, 11044, 11045,11046, 11058, 11182, 11191, 11192,11193, 11194, 11233, 11243, 11307,

11361, 11448, 11456, 11502, 11509,11577, 11607, 11772, 11781, 12042,12085, 12087, 12112, 12301, 12477,12544, 12678, 12685, 12788, 12797,12821, 12837, 12968, 12979, 12986,12987, 12988, 12989, 12990, 12994,13000, 13002, 13004, 13005, 13006,13007, 13020, 13021, 13025, 13028,13032, 13033, 13034, 13035, 13036,13037, 13042, 13053, 13056, 13063,13064, 13066, 13068, 13079, 13082,13083, 13084, 13085, 13093, 13111,13114, 13123, 13136, 13139, 13141,13146, 13160, 13171, 13174, 13175,13179, 13180, 13184, 13192, 13195,13198, 13200, 13201, 13206, 13208,13228, 13229, 13238, 7015, 7127, 7173,7177, 7192, 7193, 7196, 7250, 7371,7377, 7427, 7428, 7434, 7483, 7485,7507, 7514, 7561, 7601, 7610, 7628,7633, 7675, 7692, 7694, 7741, 7794,7824, 7833, 7848, 7873, 7877, 7922,7958, 7971, 8007, 8022, 8027, 8108,8196, 8199, 8209, 8211, 8241, 8413,8505, 8537, 8586, 8629, 8743, 8749,

175


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8865, 8867, 8891, 9061, 9124, 9303,9384, 9441, 9443, 9460, 9461, 9474,LR13428, LR13429, LR13441, LR13444,LR9418

report.

- the criteria and reasons for rejecting BarnElms need to be made public

The criteria and reasons for rejecting Barn Elms have been made public.Refer to paragraphs 10.3.1 and 10.3.2 for further details.

- the reasons for changing the preferredsite (brownfield site, opportunities for rivertransport and reduced impact onrecreation) are not sufficient to justify the

change of site

We disagree. These are important considerations and cannot bedismissed as being irrelevant.

- Thames Water has admitted that the useof Carnwath Road would be more costlyand disruptive

See paragraph 103.3.57 for our response to these feedback comments.

- the increased cost of using CarnwathRoad cannot be justified

- Thames Water has breached theprinciples of lawful consultation

This is not a matter for site selection. However, in devising and carryingout our consultation strategy, we met the requirements of the PlanningAct 2008 and have had regard to the Department for Communities andLocal Government guidance on pre-application consultation. We do notconsider therefore that we have breached the principles of lawfulconsultation.

- Carnwath Road Riverside was explicitlyidentified and rejected at phase one

consultation.

At phase one consultation we identified two main tunnel intermediatesites that covered Carnwath Road Riverside. At this point, from a

technical perspective we said that a main tunnel drive site needed to beat least 20,000m2. We listened to concerns raised at phase one

consultation and re-checked our engineering assumptions. We foundthat where we were constructing in clay, we could use smaller sizes thatpreviously identified. As a result, we reviewed and re-assessed all sitesbetween Hammersmith Bridge and Albert Bridge; we found CarnwathRoad Riverside to be suitable in this main tunnel zone. We then re-checked our drive options for the western section of the main tunnel.When we compared the different drive options using Barn Elms andCarnwath Road Riverside, we found Carnwath Road Riverside to be themost suitable site.For further details, refer to chapter 6 and appendix G of our Phase twoscheme development report.

10.3.39 One of the shortlisted sites is more suitable.Specifically, Feathers Wharf (site 2) is close

to a rail line and next to waste transfer sitewith existing barge facilities. The ventilationcolumn could be easily accommodated, andthe River Wandle could accommodate apiled deck platform over the river as atemporary raised structure to provideadditional space. The site already suffersfrom odour associated with the wastetransfer station.

12539, 13395, 7673, 7968, 9461 5 Our re-assessment of sites prior to phase two consultation and ourreview of phase two consultation comments do not support the use of

Feathers Wharf as our preferred site. Feathers Wharf is less suitablethan our preferred site because it is too small to accommodate all theworks and no viable partner site could be identified.

Refer to appendix G of the Phase two scheme developmentfor furtherdetails of our assessment.

10.3.40 The site selection methodology is 9400LO, 11056, 12371, 13020, 13133, 18 The sites on which we have consulted were identified through an


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incorrect/flawed/unjustified. In particular:

- further in-depth impact analysis isrequired before Thames Water can makean informed decision

- the relative merits of different sites needto be quantified

- factors should not be equally weighted

- site selection is a subjective ThamesWater decision

7364, 7377, 7427, 7428, 7483, 7485,7618, 7977, 8288, 8318, 8413, 8505, 8891

extensive site selection process as set out in the Site selectionmethodology paperthat is available on our website. This methodologywas agreed with key stakeholders, including potentially directly affectedlocal authorities, prior to its use. The paper explains how environmental,planning, engineering, property and community considerations weretaken into account in the site selection process.

The site selection methodology does not include a quantitative scoringor weighting element. Such an approach is not considered best

practice, and this was agreed with stakeholders when consulting on thedraft methodology. Instead the methodology relies on increasinglydetailed study at each stage of the process, utilising professional

judgement to reach balanced decisions about the suitability of sites.

- the overriding factor should be theimpact on businesses and quality of life


- profit and cost is the overriding factor. Refer to paragraph 10.3.57 for our response to this feedback comment.

10.3.41 Site selection should use / prioritisebrownfield sites.

11189, 12579, 13094 3 Whether a site is brownfield or greenfield/open space was taken intoaccount along with other considerations as set out in the Site selectionmethodology paper.

10.3.42 Site selection should avoid greenfield sitesand open space.

11189, 9029 2

10.3.43 Site selection should not use sites within theRiver Thames foreshore.

11629, 13118 3 In general, main tunnel sites will be located on land due to a range ofengineering constraints and requirements. Only where it has proveddifficult to identify suitable land-based sites, have we explored thepotential for siting main tunnel sites wholly or partially within or on theforeshore of the River Thames. Further information can be found withinthe Site selection background technical paper, which is available on ourwebsite.

We can confirm that apart from the construction of a campshed tofacilitate use of barges at this site, we are not proposing to constructwithin the foreshore. The campshed design and construction willmitigate any likely significant environmental effects.

10.3.44 Site selection should avoid sites that havebeen allocated for, are known to beawaiting, or have planning permission forredevelopment. Specifically:

- this site has been identified for mixed usedevelopment

LBHF, 13365LO, 9417LO, 9481LO, 11800,12138, 7824, 8537, 8838, 8839, 8926,9428, 9460, LR9418

14 The planning status of a site was taken into account along with otherconsiderations as set out in the Site selection methodology paper. Aprofessional judgement was then made in relation to the impact on theplanning status of that site and this was balanced against other

considerations identified in the Site selection methodology paper. Itshould be noted that even if sites have been allocated or have secured aplanning permission, that does not preclude the use of the site. Otherfactors such as whether the planning permission will be implementedneed to be considered Even then, it may be possible for constructionwork to be phased so that both the approved development and theThames Tunnel project can be constructed.

Sites located within designated regeneration areas do not necessarypreclude the use of the site as our proposed use in many cases can becomplementary or beneficial to some of the regeneration aims.


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- a large proportion of the plots identifiedas having potential for redevelopmentwithin the next zero to ten years wouldessentially be sterilised by the works

We are aware of the allocation within the adopted Core strategy forresidential development on both Whiffin Wharf and the Carnwath RoadIndustrial Estate and of Hurlingham Wharfs safeguarded wharf status. Consequently, we have organised the layout of our proposedpermanent works such that there will be no effect on the CarnwathRoad Industrial Estate, however, some of Whiffin Wharf will be occupiedby our main tunnel shaft and several above ground structurespermanently, which may prevent the use of the entire site for future

development. In addition, we are providing for a significant area ofpermanent public open space west of our permanent works and for anarea for future development. We therefore believe that the areasterilised by our proposed works is minimised and following completionof our temporary works the development aspirations for this area canproceed.

- permanent structures will severely limitthe sites development potential

We are currently considering our design proposals for the site and willconsider how we can take your comments into consideration.

- potential impact Hurlingham Retail Parksite redevelopment proposals.

We have considered the effect on local area and businesses as part ofthe site selection process, the results of which concluded that CarnwathRoad Riverside is the most suitable site.

10.3.45 Site selection should prioritise use ofindustrial sites; should use an industrial sitethat is not in a vibrant family neighbourhood.

7400 1 Carnwath Road Riverside is an industrial site. We recognise that ourpreferred site is within close proximity to residential housing. As part ofthe project design development process, we continue to assess how the

likely significant effects arising from the proposed development can beaddressed. The output of our assessment up to phase two consultationis contained within appendix G of the Design development reportandour PEIR(volume 13).

10.3.46 Site selection should prioritise use of vacantsites.

7225 1 Carnwath Road Riverside is a partially vacant site.

10.3.47 Site selection should avoid sites inresidential and/or densely populated areas.

See annex C of this report 557 In identifying our preferred sites, we have followed the methodology setout in the Site selection methodology paper. Having considered theissue raised, we are confident that the basis on which we identified thesite as a preferred site is consistent with our site selection methodology.

The main tunnel search area and tunnel alignment generally follows theRiver Thames. This is an efficient route to connect CSOs on the northand south side of the river, minimises going under buildings and allowsuse of river transport during construction. In addition to the locational

constraints for main tunnel sites, the sites need to fulfil other engineeringrequirements and planning, environment, planning and communityconsiderations. Given that we are searching for sites within complexbuilt up areas of central London and given the requirements that thesites need to fulfil, we did not consider it appropriate to exclude sitesbased on their use when compiling our longlist of sites.

Proximity to residential areas and the likely significant effect of theproposals on residential amenity was taken into account along with otherconsiderations as set out in the Site selection methodology paper.

10.3.48 Impact on residential amenity should beconsidered as part of the site selectionprocess.

LBHF, 13397LO, 9392LO, 8318, 8923,9461, LR9418, 9421PET

8

10.3.49 Site selection needs to be reconsidered andshould focus on less residential areas.

11566, 11732, 12373, 12539, 7050, 7388,7513, 7534, 7663, 7958, 7968

11


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We recognise that our preferred site is within close proximity toresidential housing. As part of the project design development process,we continue to assess how the likely significant effects arising from theproposed development can be addressed. The output of ourassessment up to phase two consultation is contained within appendix Gof the Design development reportand our PEIR(volume 13).

10.3.50 Site selection should avoid sites close tosensitive receptors, including:

- schools and nurseries; there are 17schools and four nurseries within 1,500metres of the site

- sheltered housing.

LBHF, 8082LO, 8843LO, 9495LO, 11008,11055, 11058, 11068, 11069, 11102,

11104, 11149, 11185, 11228, 11243,11277, 11301, 11303, 11326, 11361,11362, 11400, 11402, 11409, 11411,11414, 11500, 11588, 11612, 11664,11699, 11741, 11746, 11748, 11768,11802, 11806, 11816, 11979, 11992,11993, 11994, 12006, 12018, 12026,12037, 12236, 12241, 12242, 12279,12281, 12352, 12360, 12376, 12379,12383, 12408, 12496, 12539, 12579,12586, 12611, 12635, 12662, 12677,12689, 12693, 12707, 12728, 12734,12737, 12785, 12860, 12900, 12904,12942, 12969, 13033, 13046, 13091,13094, 13126, 13150, 13363, 13395,

7007, 7012, 7031, 7110, 7117, 7118,7125, 7133, 7142, 7164, 7168, 7173,7177, 7186, 7187, 7202, 7217, 7226,7228, 7239, 7241, 7341, 7345, 7394,7396, 7408, 7411, 7412, 7472, 7476,7478, 7481, 7483, 7491, 7500, 7502,7507, 7513, 7518, 7526, 7527, 7535,7545, 7549, 7628, 7654, 7702, 7704,7705, 7738, 7752, 7753, 7759, 7764,7765, 7766, 7783, 7786, 7809, 7833,7836, 7847, 7856, 7870, 7892, 7933,7949, 7958, 7968, 8022, 8030, 8075,8081, 8085, 8096, 8103, 8109, 8117,8121, 8139, 8192, 8209, 8210, 8211,8302, 8411, 8457, 8629, 8636, 8652,

8656, 8691, 8727, 8747, 8749, 8755,8820, 8830, 8838, 8855, 8865, 8867,8870, 8884, 8898, 8906, 8926, 9008,9377, 9461, 9466, LR13446, 9421PET

198 Proximity to sensitive receptors including schools and nurseries wastaken into account along with other considerations as set out in the Site

selection methodology paper. We recognise that Thomass FulhamSchool in particular is within close proximity to our preferred site.However, as set out in appendix G of the Phase two schemedevelopment report, we consider that Carnwath Road Riverside is themost suitable site and that likely significant effects on communityfacilities can be mitigated.

10.3.51 The drive strategy and associated use ofthis site needs to be reconsidered. Inparticular, the Kirtling Street site could beexpanded and the tunnel driven from thereto Acton Storm Tanks.

11456, 11584, 11674, 12373, 12378,12668, 8926, 9155

8 Refer to paragraph 2.5.18 for our response to this feedback comment.


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10.3.52 Socio-economic effects arising fromselecting a particular site should takeprecedence over environmental / greenconsiderations.

7012, 7020, 7035, 7142, 7173, 7177,7397, 7438, 7512, 7513, 7527, 7537,7628, 7671, 7693, 7763, 7795

17 Community (which includes socio-economic issues) and environmentalconsiderations have both been examined (alongside engineering,planning and property considerations) as part of our site selectionprocess. No one issue takes precedence over another, however allrelevant factors are examined by the project team and a judgementmade as to the suitability of a site, taking into account all relevantconsiderations.

10.3.53 Selection of this preferred site has beenpoorly justified/inadequately explained. Inparticular:

- the benefits of site selection do notoutweigh the nuisance that it will cause

7331LO, 11559, 12019, 12684, 12696,12821, 12824, 7121, 7193, 7244, 7250,7346, 7396, 7427, 7432, 7439, 7541,7833, 7856, 7869, 7876, 8037, 8096,8413, 8528, 9303

26 We believe that our assessments, which have been carried out inaccordance with the Site selection methodology paper, arecomprehensively explained in appendix G of the Phase two schemedevelopment report.

- no explanation of why a residential areais considered suitable


- the site will be more costly and disruptiveto local residents

- use of this site would result inunnecessary cost


- would like further information regardingthe relative costs and benefits associatedwith using this site

- site selection has been poorly thoughtthrough


- unclear why the site now meets the sitesize criteria when previously it was toosmall

Refer to paragraphs 10.3.38 and 10.3.58 for our response to thisfeedback comment.

- reasons why the site was unsuitable atphase one consultation.

10.3.54 Reasons for selecting the site areflawed/questionable.

-

LBHF, 13397LO, 8807LO, 8843LO,9400LO, 9417LO, 9481LO, 11013, 11100,11121, 11236, 11263, 11284, 11332,11361, 11509, 12005, 12281, 12407,12440, 12529, 12530, 12556, 12715,12725, 12744, 12765, 12849, 12980,

13011, 13094, 13136, 13205, 13233,7156, 7196, 7201, 7242, 7364, 7396,7427, 7428, 7491, 7513, 7532, 7618,7628, 7694, 7700, 7752, 7753, 7759,7764, 7765, 7766, 7783, 7786, 7794,7809, 7824, 7847, 7892, 7958, 8011,8021, 8027, 8111, 8209, 8218, 8294,8404, 8629, 8727, 8884, 9346, 9443,9460, LR9418

78 Refer to paragraph 10.3.53 for our general response to this feedbackcomment. In relation to the specific points raised, refer to our responsesbelow.

In particular:

- it is not necessary to use this site

We do not agree. The reasons why this site is needed are set out inchapter 6 and appendix G of Phase two scheme developmentwhich is

supported by our Engineering options reportand Site selectionbackground technical paper.

- the site is not a 'brownfield' site Carnwath Road Riverside is a previously developed site. The NationalPlanning Policy Framework defines previously developed land as landwhich is or was occupied by a permanent structure, including thecurtilage of the developed land (although it should not be assumed thatthe whole curtilage should be developed) and any associated fixedsurface infrastructure. This excludes: .... land in built-up areas such asprivate residential gardens, parks, recreation grounds and allotments;and land that was previously-developed but where the remains of the


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permanent structure or fixed surface structure have blended into thelandscape in the process of time. Previously developed land iscommonly referred to as brownfield.

- the feasibility of barge access is unprovenand good access to the Transport forLondon Route Network has not beentested

Refer to paragraphs 10.5.300 and 10.5.327 for our response to thisfeedback comment.

- it is wrongly stated Carnwath RoadRiverside benefits from rail access

It is not clear where this alleged reference is made. As part of the siteselection process we have not assumed that rail access would provide aviable mechanism for transporting material.

- Thames Water has misapplied or ignoredits own methodology and principals inselecting Carnwath Road Riverside as apreferred site


- the development value of the site(100mln) has not been taken intoaccount


- Whiffen Wharf is not safeguarded andthe long-term safeguarded status ofHurlingham Wharf is currently under

review


- not all planning policies have been takeninto account


- full impact assessments have not beenundertaken

Refer to paragraph 10.5.7 for our response to these feedbackcomments.

- mitigation proposed is unsatisfactory/poorly developed

- there are hidden political and financialagendas.

In identifying our preferred sites, we have followed the methodology setout in the Site selection methodology paper. Political pressure has notplayed any part in our site selection process and we have no hiddenfinancial agenda.

10.3.55 Site selection appears unsustainable/not

environmentally friendly.

11379, 12675 2 Site selection has involved a multidisciplinary approach and has

considered community (including socio-economic) and environmentalfactors alongside planning (including policies on sustainabledevelopment), engineering and property considerations. We aresatisfied that our approach takes full account, at a strategic level, ofenvironmental issues.

Refer to paragraph 2.3.60 for further information regarding why weconsider the Thames Tunnel project to be more generally sustainable.

10.3.56 Previous uses of the site presentdevelopment constraints.

9461 1 The previous uses of a site were taken into account along with otherconsiderations as set out in the Site selection methodology paper. We


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do not consider that the previous uses of the site present developmentconstraints.

10.3.57 The cost of using the site is too high/notcost-effective. Specifically, the cost of usingthis site is higher than using Barn Elms.Thames Water has a duty to minimise costssince they will be passed on to ThamesWater customers.

9392LO, 11689, 11946, 12030, 12491,12675, 13064, 13124, 13131, 13186,7127, 7193, 7201, 7217, 7263, 7343,7397, 7422, 7435, 7438, 7439, 7519,7523, 7562, 7564, 7567, 7669, 7751,7769, 7833, 7949, 8142, 8313, 8543, 9461

35 Cost is one of the considerations that inform site assessments, but it isnot an overriding factor that outweighs all other engineering, planning,environmental, community, property and wider economic considerations.High acquisition costs alone would not outweigh positive considerationssuch as use of brownfield land, conformity with planning policy, and theability to construct/operate the proposed works on the site. Equally, a

low value site would not result in a site becoming our preferred site, ifthere were significant planning, engineering, environmental orcommunity concerns associated with its use. In determining ourpreferred site, we made a balanced judgement taking planning,environment, engineering, property and community considerations intoaccount.

10.3.58 The site is too small and does not havesufficient capacity to accommodate theproposals. Specifically:

- in order to accommodate the constructionworks, an industrial estate would need tobe demolished

- the site would be 50 per cent too smallwithout two compulsory purchases.

13397LO, 9417LO, 9481LO, 11055,12990, 12992, 13094, 13112, 7112, 7117,7156, 7252, 7390, 7526, 7527, 7535,7657, 7701, 7705, 7741, 7752, 7753,7759, 7764, 7765, 7766, 7824, 7848,7949, 8075, 8085, 8103, 8121, 8209,8636, 8785, 8874

37 The Site selection background technical paper, which accompanies theSite selection methodology paper, specifies the sizes for CSO and maintunnel sites. We have used these criteria to select our preferred sites.Carnwath Road Riverside is therefore an appropriate size toaccommodate our proposals.

We note that following selection of Carnwath Road Riverside as ourpreferred site, the Secretary of State has issued an Article 25 Directionthat prevents the determination of all planning applications that affect

this site. We believe that this direction reinforces the conclusions of oursite selection process.

Refer toSite selection background technical paperfor further details onappropriate site sizes for main tunnel sites.

10.3.59 The scale of effects on the local area andcommunity resulting from the selection ofthis site is unacceptable/ has not beenproperly considered.

See annex C of this report 277 Our site selection process has had regard to possible likely significanteffects on the local area and community, and the environmental impactassessment process will undertake further assessment and recommendany necessary mitigation measures.

The environment and community assessments undertaken as part ofsite selection considered the number and nature of sensitive receptorsas well as possible likely significant effects from traffic and constructionworks including noise, air quality and visual impact. We also consideredlikely significant effects on employment uses and possible conflict withplanning policy that seeks to protect local amenity. Accordingly, weconsider that the scale of possible likely significant effects on the localarea and community has been adequately considered.

For further details on the results of the site selection process, refer toappendix G of the Phase two scheme development report.

10.3.60 Site selection has been influenced bypressure from politicians, celebrities andNon-Governmental Organisations. ThamesWater is effectively placing a higher valueon what is in fact a very small area of greenspace than on the quality of life of at least

9392LO, 9400LO, 11502, 11607, 12045,12079, 12100, 12103, 12283, 12375,12721, 13017, 13020, 13090, 13150,13161, 13224, 13237, 7015, 7121, 7127,7129, 7137, 7147, 7196, 7202, 7217,7241, 7371, 7486, 7513, 7527, 7538,

39 In identifying our preferred sites, we have followed the methodology setout in the Site selection methodology paper. Political pressure has notplayed any part in our site selection process.


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1,200 people. 7554, 7575, 7833, 8027, 8209, 9461

10.3.61 Insufficient information has been providedon alternative sites.

7413 1 We consider that we have undertaken a thorough and comprehensiveconsultation exercise. As part of this, we carefully considered theinformation we made available at our phase two consultation to ensurethat consultees had sufficient information to respond to the consultation.Details of sites considered as part of the site selection process aredescribed and illustrated throughout the phase two consultation materialincluding the site information papers which provide an overview with the

detail in appendix G Phase two scheme development report. We areconfident therefore that the information we have provided is sufficient.

10.3.62 Site selection should avoid commerciallyestablished areas; in this particular instanceestablished businesses would need to berelocated which would have significantimpacts on current occupiers of the site.Furthermore, proposals may have anadverse impact on the Hurlingham RetailPark.

13365LO, 8807LO, 9417LO, 9481LO,9495LO, 11303, 11305, 11409, 11446,11699, 11741, 11806, 11816, 11864,12130, 12785, 13105, 13218, 13363,7020, 7164, 7217, 7342, 7507, 7702,7752, 7764, 7765, 7766, 7809, 7833,7949, 7958, 8030, 8075, 8108, 8121,8537, 8838, 8884, 8926, 9428, 9466,LR9418

44 The main tunnel search area and tunnel alignment generally follows theRiver Thames. This is an efficient route to connect CSOs on the northand south side of the river, minimises going under buildings and allowsuse of river transport during construction. In addition to the locationalconstraints for main tunnel sites, the sites need to fulfil other engineeringrequirements and planning, environment, property and communityconsiderations. Given that we are searching for sites within centralLondon and given the requirements that the sites need to fulfil, we didnot consider it appropriate to exclude sites based on their use whencompiling our longlist of sites.In relation to Carnwath Road Riverside, as set out in appendix G o f thePhase two scheme development report, while we recognise that ourproposals may have a potentially adverse effect on businesses

operating out of the eastern part of the site, the other benefits of this siteoutweigh this consideration in this case. Any existing businesses wouldbe assisted with relocation in line with our published A guide to theThames Tunnel compensation programme. We consider there will be nolikely significant effect on Hurlingham Retail Park.

10.3.63 Proposals will bring no long-term benefit(legacy) to the local area.

7118, 7254, 7545, 7847 4 As set out in the Needs report, the Thames Tunnel project will addressthe water quality, ecological, aesthetic and health issues identified assupporting the need for the project. The Thames Tunnel project will alsoprovide additional benefits for the sewer system, in terms of improvingthe operation and maintenance of the sewer network, and providinggreater robustness and flexibility for the future impacts of populationgrowth and changes in the pattern of rainfall due to climate change.

10.3.64 The site should be developed for other uses,including residential, shops, employment,

leisure and/or uses that would benefit thelocal community.

9495LO, 11800, 7504, 7535, 7547, 8022,8139, 8684

8 Using a site for the Thames Tunnel project does not preclude the sitebeing used for other uses once construction of the project is complete.

The footprint of the permanent works required for the operation of theThames Tunnel project is significantly smaller than the space requiredduring its construction. The area not permanently required could beused for other uses that obtain planning permission.

10.3.65 Disagree with/not commenting on siteselection due to wider objections to theproposed solution and/or the need for theproject. It is understood that it is notnecessary to use a site in this area as thereare no CSOs to intercept in this location.

LBHF, 13397LO, 9110LO, 9392LO, 11020,11072, 11073, 11123, 11124, 11128,11133, 11253, 11254, 11284, 11372,11407, 11590, 11644, 11690, 11709,11740, 11754, 11811, 11821, 11830,11836, 11988, 12062, 12107, 12151,

117 Refer to paragraph 2.2.32 for our response to feedback commentsrelated to need and solution.

It is incorrect that sites to construct the main tunnel have to be located atsites to intercept CSOs. We need to identify both types of site.


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prove that the previous choice was not aviable option

- given the significant changes that haveoccurred between phase one and phasetwo consultation, concerned that ThamesWater have yet to identify the mostoptimal solution

As set out in the Carnwath Road Riverside site information paperandappendix G of the Phase two scheme development report, we considerthat Carnwath Road Riverside is the most appropriate site because it isa brownfield site. The presence of wharves at this site combined with thewidth of the River Thames at this point would allow the use of largerbarges to remove material excavated during construction of the main

tunnel. There would be much less conflict with recreational users of theRiver Thames than at Barn Elms.

- Thames Water should confirm that allthree other shortlist sites are still underactive consideration and consideredviable replacements to the preferred site

Following the feedback from phase two consultation, we haveconsidered the alternative sites suggested (see section 10.3 of thischapter) and the comments received in relation to site selection. As aresult of this process, we still consider that Carnwath Road Riverside isthe most appropriate site.

- even at this stage, the proposals arehaving a negative effect on the local area

Construction of the tunnel in this location is not expected to compromisethe wider regeneration of the area or future redevelopment of the site.

- if Carnwath Road Riverside is selected,only the more privileged people will leavethe area; the people who will remain willbe those who can't afford to move house.

Landowners may have a statutory entitlement to claim compensation forthe diminution on the value of their property due to the construction ofthe tunnel. Landowners include the council or local housing associationsthat own social housing in the area. In addition to the statutory process,we have published an Exceptional hardship procedurewhich sets out

how we will assess claims from householders who contend that they aresuffering exceptional hardship as a result of being unable to sell theirproperty because it is potentially impacted by the currently publishedThames Tunnel project proposals. We have also published A guide tothe Thames Tunnel compensation programmewhich sets out details ofcompensation that would be available arising from damage or lossduring construction, for required protection measures, and forcompulsory purchase.

Supportive and neutral feedback comments in relation to shortlisted sites

Table 10.3.4Supportive and neutral feedback comments in relation to shortlisted sites


10.3.69 Any shortlisted site acceptable subject toappropriate mitigation.

EH 1 Based on our assessment we consider that, on balance, Carnwath RoadRiverside is the most suitable. Refer to paragraph 10.3.29 for ourreasons why.

For further details on the results of the site selection process, refer toappendix G of the Phase two scheme development report.


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consequently will not be available. 8180, 8202, 8292, 8514, 8516, 8518,8520, 8524, 8546, 8578, 8584, 8592,8593, 8594, 8596, 8597, 8599, 8601,8603, 8605, 8607, 8620, 8672, 8673,8674, 8694, 8695, 8696, 8699, 8700,8701, 8709, 8710, 8729, 8800, 8905,8947, 8958, 8966, 8974, 9001, 9005,9006, 9009, 9033, 9057, 9058, 9059,9060, 9063, 9067, 9072, 9125, 9159,9178, 9209, 9239, 9240, 9245, 9247,9266, 9281, 9300, 9346, 9351, 9354,9362, 9364, 9365, 9366, 9367, 9372,9423, LR9276

10.3.72 Comments stating 'Why I love Barn Elms'that relate to open space and/or recreationalvalue.

13345LO, 13346LO, 13347LO, 13313,13314, 13315, 13316, 13317, 13318,13319, 13320, 13321, 13322, 13323,13324, 13325, 13326, 13327, 13328,13329, 13330, 13331, 13332, 13333,13334, 13335, 13336, 13337, 13338,13339, 13340, 13341, 13342, 13343,13344, 13348, 13349, 13350, 13351,13352, 13353, 13354, 13355, 13356,13357, 13358, 13359, 13360, 13361,

13362, 13479, 8800, 9218, 9219, 9225,9228, 9346, 9348, 9362, 9364, 9365,9366, 9367, 9368, 9370

65

Shortlisted sites

10.3.73 No feedback comments were received in relation to the shortlisted sites.

10.4 Alternative sites

10.4.1 During the phase two consultation, respondents were invited to suggest alternative sites that they thought should be used to drive the main tunnel to Acton Storm Tanks and receive themain tunnel from Kirtling Street and Frogmore connection tunnel from Dormay Street instead of Carnwath Road Riverside (see question 3 of the phase two feedback form, provided inappendix J of the Main report on phase two consultation). The following sites were put forward as possible alternatives:

Table 10.4.1 Suggested alternative sites to Carnwath Road Riverside

Ref Alternative site suggestions Reasons Respondent ID No. Our response

Preferred site

10.4.2 Carnwath Road Riverside. It is a brownfield site next to anindustrial area which has beenderelict for many years and hasadequate space to undertake theconstruction works.

The site offers lower constructioncosts, existing energy supply, andhigher resale value and is considered

13494LO, 7128,7160, 7302,7744, 7754,7825, 7832,7835, 7839,7884, 7885,7887, 7888,7891, 7895,

59 This is our preferred site as set out in the Carnwath Road Riverside siteinformation paper andappendix G of our Phase two schemedevelopment report.


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a better engineering solution.

The core of the site is a safeguardedwharf and therefore provides goodopportunities for use of the river totransport excavated material, whichwill reduce effects on local roads. Theopportunities for barge use are lessconstrained than at Barn Elms.

The site also has direct road accessto major arterial routes.

The site is earmarked forregeneration in a less residential areaand it is considered that it will causeless disruption.

It would not result in loss ofrecreational space and would createless disruption for recreational riverusers and the regular rowing races.

There would be no impact on theThames Path since it is alreadydiverted and the site would haveminimal impact on the environment.

Permanent structures/landscapingcould improve the site.

7903, 7904,7907, 7910,7915, 7953,7955, 7956,7967, 7979,7995, 8015,8016, 8017,8029, 8114,8185, 8281,8286, 8322,8332, 8396,8401, 8404,8459, 8502,8541, 8546,8559, 8728,8733, 8766,8789, 8800,8816, 8825,8871, 8880,9102, 9144,9346, 9348,9354

Shortlisted sites

10.4.3 Barn Elms. The site is open space/greenfieldwhich is preferable to a brownfieldsite. Respondents also query therobustness of conclusions regardingplanning policy and undertakingtemporary construction works onMetropolitan Open Land.

It allows the CSO interception andmain tunnel site to be combined,which is supported in ThamesWater's site selection methodology.

The impact on the naturalenvironment does not outweigh theimpact on local residents at CarnwathRoad Riverside.

The move away from Barn Elms ispolitically motivated.

There would be reduced impact onlocal residents, since they are locatedfurther away from the site. This sitewould also have less impact on local

See annex C ofthis report

253 We consider that Barn Elms is a less suitable site than our preferredsite, Carnwath Road Riverside. Our reasons for this conclusion are setout in paragraph 10.3.29 and appendix G of the Phase two schemedevelopment report.


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businesses, schools and vulnerablecommunities.

It is a larger size which will makeconstruction easier, and would meanlower construction-related costs andrequire a shorter period ofconstruction works.

Despite the loss of open space,

recreational use of the Barn ElmsPlaying Fields would not be affected.

There is better road access/less localroad congestion. Do not consider thatriver access is much reduced incomparison to Carnwath RoadRiverside. Any restrictions that doexist can be overcome.

It will be easier to restore the siteonce construction works are completeand the London Wetland Centreprovides interim mitigation.

It will be easier to mitigate the impacton recreational users.

Any permanent structures would havereduced visual impact in comparisonto Carnwath Road Riverside.

10.4.4 Feathers Wharf. It is next to a waste transfer site andindustrial estates. The River Wandlecould easily accommodate a pileddeck platform over the river as atemporary raised structure in anindustrial site to give additionalspace. The site has existing riveraccess and is close to a rail line, bothof which would reduce the need touse road. Any permanent structureswould have less of a visual impact.

7673, 7741,8124

3 Feathers Wharf is only big enough to be used as a main tunnelreception site. We have explored whether it would be possible to expandthe size of the site so that it could be used as a main tunnel drive site.To do this, decking would need to be constructed over the River Wandlewhich would have significant effects on this water body. The site doesnot have barge access and therefore it would not be possible to removeexcavated material by water. Use of barges is an importantconsideration when identifying suitable main tunnel drive sites due to thelarge amount of material that needs to be removed. The site access isalso constrained and there is high density residential housing adjacentto the site. This means that, based on our preferred drive strategy (ie,drive the tunnel from Carnwath Road Riverside to Acton Storm Tanks)

the site cannot be considered as an alternative to Carnwath RoadRiverside since it is not a suitable size. For further details refer toappendix G of the Phase two scheme development report.

10.4.5 One of the shortlisted sitesalready identified.

These sites are less residential andless frequented by traffic.

7050 1 We have identified other shortlisted sites. Based on our assessment ofthese sites, we consider that they are less suitable. Appendix G of thePhase two scheme development reportsets out in detail the other sitesconsidered and the reasons why we consider the sites less suitable.

Other sites

C h R d Ri id


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10.4.6 Acton Storm Tanks. Would reduce the number of sitesand could minimise the impacts.

8725 1 We do not consider that Acton Storm Tanks is appropriate as a maintunnel drive site. This is because large volumes of excavated materialare produced at main tunnel sites and there are no viable river or railoptions for transport of excavated material in the vicinity of this site. Thiswould therefore require large number of heavy goods vehicle (HGV)movements which we do not consider appropriate due to theenvironment effects that would arise.

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Supp Report on P2 Consultation - Chapter 10 Carnwath Road Riverside

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