Supp Report on P2 Consultation - Chapter 20 Chambers Wharf

7/31/2019 Supp Report on P2 Consultation - Chapter 20 Chambers Wharf

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

Supplementary reporton phase twoconsultation

Chapter 20 Chambers Wharf


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Thames Tunnel

Supplementary report on phase two consultation

List of contents

Page number

20 Chambers Wharf ......................................................................................... 20-120.1 Introduction ......................................................................................... 20-120.2 Number of respondents ...................................................................... 20-220.3 Site selection ...................................................................................... 20-220.4 Alternative sites ................................................................................ 20-1520.5 Management of construction works .................................................. 20-2120.6 Permanent design and appearance .................................................. 20-7320.7 Management of operational effects .................................................. 20-8220.8 Our view of the way forward ........................................................... 20-105


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List of tables

Page number

Table 20.2.1 Number of respondents who provided feedback on Chambers Wharf....................................................................................................... 20-2

Table 20.3.1 Views on whether Chambers Wharf should be our preferred site (Q2)....................................................................................................... 20-3

Table 20.3.2 Supportive and neutral feedback comments in relation to the selection

of our preferred site ........................................................................ 20-3Table 20.3.3 Objections, issues and concerns in relation to the selection of our

preferred site .................................................................................. 20-5Table 20.3.4 Objections, issues and concerns in relation to shortlisted sites .... 20-14Table 20.4.1 Suggested alternative sites to Chambers Wharf .......................... 20-16Table 20.4.2 Supportive and neutral comments in relation to the availability and

identification of alternative sites .................................................... 20-21Table 20.4.3 Objections, issues and concerns in relation to the availability and

identification of alternative sites .................................................... 20-21Table 20.5.1 Do you agree that we have identified the right key issues in the site

information paper? (Q4a) ............................................................. 20-22Table 20.5.2 Do you agree that we have identified the right way to address the key

issues? (Q4b) 20 22


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Table 20.5.13 Objections, issues and concerns in relation to the historic environmentduring construction ....................................................................... 20-36

Table 20.5.14 Objections, issues and concerns in relation to the measures proposedto address the effects on the historic environment during construction..................................................................................................... 20-38

Table 20.5.15 Objections, issues and concerns in relation to lighting duringconstruction .................................................................................. 20-39

Table 20.5.16 Objections, issues and concerns in relation to the measures proposed

to address the effects of lighting during construction .................... 20-39Table 20.5.17 Objections, issues and concerns in relation to the natural environment

(aquatic) during construction ........................................................ 20-40Table 20.5.18 Objections, issues and concerns in relation to the measures proposed

to address the effects on the natural environment (aquatic) duringconstruction .................................................................................. 20-41

Table 20.5.19 Supportive and neutral feedback comments in relation to the naturalenvironment (terrestrial) during construction ................................ 20-41

Table 20.5.20 Objections, issues and concerns in relation to the natural environment(terrestrial) during construction ..................................................... 20-42

Table 20.5.21 Objections, issues and concerns in relation to the measures proposedto address the effects on the natural environment (terrestrial) duringconstruction .................................................................................. 20-43

Table 20 5 22 Objections iss es and concerns in relation to noise and ibration


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Table 20.7.5 Supportive and neutral feedback comments in relation to themeasures proposed to address the key issues during operation .. 20-85

Table 20.7.6 Objections, issues and concerns in relation to the measures proposedto address the key issues during operation .................................. 20-85

Table 20.7.7 Supportive and neutral feedback comments in relation to air qualityand odour during operation .......................................................... 20-87

Table 20.7.8 Objections, issues and concerns in relation to air quality and odourduring operation ........................................................................... 20-88

Table 20.7.9 Objections, issues and concerns in relation to the measures proposedto address the effects of air quality and odour during operation ... 20-89

Table 20.7.10 Objections, issues and concerns in relation to the historic environmentduring operation ........................................................................... 20-90

Table 20.7.11 Objections, issues and concerns in relation to the measures proposedto address the effects on the historic environment during operation 20-91

Table 20.7.12 Objections, issues and concerns in relation to land quality andcontamination during operation .................................................... 20-92

Table 20.7.13 Objections, issues and concerns in relation to the natural environment(aquatic) during operation............................................................. 20-93

Table 20.7.14 Objections, issues and concerns in relation to the measures proposedto address the effects on the natural environment (aquatic) during

ti 20 93


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Table 20.7.24 Supportive and neutral feedback comments in relation to socio-economic effects during operation ................................................ 20-97

Table 20.7.25 Objections, issues and concerns in relation to socio-economic effectsduring operation ........................................................................... 20-98

Table 20.7.26 Objections, issues and concerns in relation to the measures proposedto address socio-economic effects during operation .................. 20-100

Table 20.7.27 Objections, issues and concerns in relation to structures and utilitiesduring operation ......................................................................... 20-100

Table 20.7.28 Supportive and neutral feedback comments in relation to townscapeand visual effects during operation ............................................. 20-100

Table 20.7.29 Objections, issues and concerns in relation to townscape and visualeffects during operation .............................................................. 20-100

Table 20.7.30 Objections, issues and concerns in relation to the measures proposedto address the effects on townscape and visual during operation .... 20-101

Table 20.7.31 Supportive and neutral feedback comments in relation to transportand access during operation ...................................................... 20-102

Table 20.7.32 Objections, issues and concerns in relation to transport and accessduring operation ......................................................................... 20-102

Table 20.7.33 Objections, issues and concerns in relation to the measures proposedto address the effects of transport and access during operation 20-103


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Supplementary report on phase two consultation 20-1

20 Chambers Wharf

20.1 Introduction

20.1.1 This chapter covers the feedback comments received during phase two consultation regarding our preferred site Chambers Wharf. Chambers Wharf would be used to drive the maintunnel to Abbey Mills Pumping Station and to receive the main tunnel from Kirtling Stree t; and to connect three existing local combined sewer overflows (CSOs) to the main tunnel via along connection tunnel (the Greenwich connection tunnel). The three CSOs are known as Greenwich Pumping Station CSO, Deptford Storm Relief CSO and Earl Pumping Station CSO.

20.1.2 At phase one consultation, Kings Stairs Gardens was presented as the preferred site to intercept the CSOs and receive the main tunnel from Tideway Walk and Abbey Mills Pumping

Station. However, following a review of possible sites and the tunnelling strategy and the joint acquisition of Chambers Wharf with St James, the site was identified and presented as thepreferred site at phase two consultation. For further information regarding the proposals for this site at phase two consultation, refer to the Chambers Wharf site information paper.

20.1.3 As part of our phase two consultation, we identified one shortlisted site for a main tunnel drive site. The shortlisted site is Kings Stairs Gardens. Where feedback comments were receivedon this shortlisted site, they are presented in section 20.3 (site selection) and section 20.4 (alternative sites) of this chapter.

Structure of this chapter

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

section 20.2 Number of respondents

section 20.3 Site selection

section 20.4 Alternative sites

section 20.5 Management of construction works

section 20.6 Permanent design and appearance

section 20.7 Management of operational effects

section 20.8 Our view of the way forward.

20.1.5 In sections 20.3 to 20.7 we 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.

20.1.6 A full list of the phase two consultation material is set out in Annex A to this report. Where a response contains a reference to our website, go to www.thamestunnelconsultation.co.ukfor further information, or to access the documents referenced.

20.1.7 Where over 250 responses were received, the details of the respondents are listed in annex D 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.


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20.2 Number of respondents

20.2.1 A total of 639 respondents and three petitions provided feedback comments on Chambers Wharf, of which 70 were received after the close of phase two consultation. Table 20.2.1 setsout the different groups who provided feedback for this site.

Table 20.2.1 Number of respondents who provided feedback on Chambers Wharf

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)

1 respondent

- London Borough of Southwark(LBS)

50 respondents 578 respondents 3 respondents

- 7,602 signatories- 1,388 signatories, of which 485

were received after 4 November2011

- 592 signatories

20.2.2 Feedback on this site was received in a number of forms including feedback forms, standard Chambers Wharf letters, correspondence (emails and letters) and petitions.

20.3 Site selection

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

Site selection project information paper, which sets out the process we followed to find and select our preferred sites

Site selection methodology paper, which details the methodology used to select construction sites along the route of the main tunnel

Site selection background technical paper, which provides supporting technical information to the Site selection methodology papersuch as the engineering requirements for the sizeof construction sites.

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

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

Phase two scheme development report, which 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.

20.3.3 In this section, we set out the feedback comments received in relation to the selection of Chambers Wharf as our preferred site, together with our responses. Our responses providerelevant details of the site selection process and its findings up to phase two consultation. Where appropriate, we have also identified further work that we have undertaken in relation toour 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 theeffects arising from the proposed development can be addressed. The output of our assessment up to phase two consultation is contained in appendix R of the Design development

reportand our PEIR(volume 22).

20.3.4 Where respondents commented on matters relating to management of construction works, permanent design and appearance or the management of operational effects at ChambersWharf, these comments are reported in sections 20.5 to 20.7.

Number of respondents

20.3.5 During phase two consultation, respondents were asked to comment on the decision to select Chambers Wharf as our preferred site to drive the main tunnel to Abbey Mills PumpingStation and receive it from Kirtling Street and connect the Greenwich Pumping Station, Deptford Church Street and Earl Pumping Station CSOs via the Greenwich connection tunnel (seequestion 2 of the phase two consultation feedback form, provided in appendix M of the Main report on phase two consultation). Table 20.3.1 sets out details of the different groups whoresponded and were asked to select supportive, opposed/concerned or dont know/unsure. Tables 20.3.2 and 20.3.3 then detail the feedback comments received in relation 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 20.3.1 Views on whether Chambers Wharf should be our preferred site (Q2)

Respondent type Number of respondents

Total Supportive Opposed/concerned Dont know/unsure

Statutory consultees 0

Local authorities 1 1

- LBS

Landowners 48 47 1

Community consultees 522 47 472 3

Petitions 2 2

- 1,388 signatories,of which 485received after 4November 2011

- 592 signatories

Total 573 47 522 4

Supportive and neutral feedback comments in relation to our preferred site

Table 20.3.2 Supportive and neutral feedback comments in relation to the selection of our preferred site

Ref Supportive and neutral feedbackcomments

Respondent ID No. Our response

20.3.6 Support the use of the preferred site. GLA, 7189, 7590, 7592, 7625, 9063,LR13417, LR9447

8 Your support is noted and welcomed.

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

- good road infrastructure and river access

- Kings Stairs Gardens need to beprotected as an open space andcommunity facility

- reduced impact on residential amenity

- lower environmental impact

- it is a brownfield site that can beredeveloped following completion of theworks; the site was going to beredeveloped anyway.

PLA, 7101, 7111, 7157, 7160, 7189, 7270,7585, 7624, 7625, 7726, 7800, 7804,8099, 8119, 8198, 8306, 8323, 8606,8610, 8765, 8791, 8827, 8876, 8886,8933, 8936, 8943, 9055, 9063, 9145,9298, 9442, LR9491

33

20.3.8 The preferred site is more suitable than anyalternative site.

8119, 8886 2

20.3.9 The preferred site is more suitable than the 7451, 7804, 7926, 7939, 7966 5


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shortlisted site Kings Stairs Gardens (site1).

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

8323, 8907, 9063, LR8975, LR9315 5 Noted. We have considered the feedback comments received at phaseone consultation and, where possible, have incorporated them into therevised proposals we presented at phase two consultation.

20.3.11 The physical characteristics of the site make

it suitable, including:- good road and river access

- no removal of trees

7101, 7155, 7587, 7592, 7800, 7925,

8078, 8188, 8323, 9442

10 Your support is noted.

20.3.12 The site is currently vacant/derelict/available for redevelopment.

7038, 7157, 7160, 7536, 7925, 8099,8119, 8188, 8323, 8606, 8765, 8886, 8943

13

20.3.13 The site is currently under-utilised. 7155 1

20.3.14 Possible effects associated with theselection of the site are manageable/can besatisfactorily addressed. In particular, largescale construction on this site was alreadyplanned and consented.

8323 1

20.3.15 Support site selection because the projectneeds to be undertaken.

8078, 8323 2

20.3.16 There will be no/minimal negative long-termeffects on the local area.

7925, 7926 2

20.3.17 Other supportive feedback commentsincluded:

- site is already allocated for developmentand can be redeveloped afterwards

- objections are due to a NIMBY attitudeamongst local residents

- project will bring wider public benefits.

7189, 7211, 7592, 8078, 8099, 8186 6

20.3.18 The site will be a catalyst for regeneration/redevelopment/improvements to the localarea.

8188 1

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

8099 1 Agreed.

20.3.20 The site is already owned by ThamesWater.

7189 1

20.3.21 It is a brownfield site. 7038, 7101, 7111, 7155, 7160, 7211,7451, 7579, 7585, 7586, 7587, 7592,7624, 7625, 7800, 7804, 7925, 7926,7939, 7966, 8119, 8186, 8188, 8306,8323, 8491, 8606, 8610, 8827, 8876,

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


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Ref Objections issues and concerns Respondent ID No. Our response

20.3.33 Objection to the change of preferred site/introduction of a new site since phase oneconsultation. Specifically, concerned thatThames Water has acted in a manner thatappears biased and that the consultationappears pre-determined.

13490LO 1 technical work. Based on our assessment we consider that, on balance,Chambers Wharf is the most suitable site. This is because it is abrownfield site and has good access to the River Thames, which wouldallow the removal of excavated material and delivery of constructionmaterials to site via barge. The site would not cause disruption to theThames Path because it is already diverted around the site, so nodiversion works would be required. Our proposal would not prevent thecompletion of the approved residential development on this site.

Our consultation has been undertaken in line with the Statement ofcommunity consultationand Community consultation strategythat setout how we would consult to meet best practice and the relevantlegislative requirements. These documents were consulted on with thepotentially directly affected local authorities and statutory consulteesbefore being published prior to both our phases of consultation.

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

- not clear why the Chambers Wharf site isneeded

- site has been selected because it is aneasier option than undertaking additionaltunnelling

- further explanation is required as to whyChambers Wharf is the only solution.

LR9271LO, 8566, 9023, LR13381, LR9279 5 As set out in the Site selection background technical paper, we need twotypes of site to construct and operate the project. These are:

- CSO sites to intercept the CSO and, if needed, drive the connectiontunnel to the main tunnel

- main tunnel sites to either drive or receive the tunnel boring machineused to construct the main tunnel.

We stated in our consultation material, including the Chambers Wharfsite information paper, that the sites to build the main tunnel need to be

located where the geology that the tunnel would go through changes. Atthis location the geology changes from clays, sands and gravels tochalk. To meet health and safety requirements and construct the tunnelwith acceptable risk of major failure, we consider it necessary to usedifferent tunnelling machines for different geological conditions. Inaddition we would need to connect the three existing local CSOs, at EarlPumping Station, Deptford Church Street and Greenwich PumpingStation, to the main tunnel so that the discharges could be conveyed toBeckton Sewage Treatment Works, via Abbey Mills Pumping Station, fortreatment.

We believe that our assessments, which have been carried out inaccordance with the Site selection methodology paper, arecomprehensively explained in appendix R of the Phase two schemedevelopment report. Based on our assessment we consider that onbalance, Chambers Wharf is the most suitable site. This is because it is

a brownfield site and has good access to the River Thames, whichwould allow the removal of excavated material and delivery ofconstruction materials to the site via barge. The site would not causedisruption to the Thames Path because it is already diverted around thesite, therefore no diversion works would be required. Our proposal wouldnot prevent the completion of the approved residential development onthis site. We also consider that some of the likely significant effectsarising from the development at this site can be addressed throughdesign development and/or mitigation measures. More information canbe found in the Design development reportand PEIR.

20.3.35 Reasons for selecting this preferred site areflawed/questionable. In particular:

- Chambers Wharf is not a 'brownfield site'

- would require a (greenfield) extensioninto the river

- justification of the need for the site isweak

- use of the site would be more expensive

- development offers no long-term benefitfor the community

- site selection has been driven purely by

opportunity- profit should not be a factor

- impacts on the environment andcommunity have not been properlyconsidered

- selection is contrary to the site selectionmethodology (eg proximity to sensitivereceptors)

- lack of explanation of how various factors

7274LO, 7996LO, 8410LO, 8561LO,8571LO, 8803LO, 8887LO, 9083LO,9084LO, 9107LO, 9147LO, LR9271LO,LR9272LO, 13484, 7215, 7402, 7580,7621, 7767, 8416, 8486, 8712, 8750,8834, 8849, 8890, 8938, 9007, 9249,9387, 9395, 9488, LR13413, LR8975,LR9136, LR9315, LR9341

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have been weighted. Responses to the detailed points raised can be found in appendix R ofthe Phase two scheme development report.

20.3.36 The preferred site put forward at phase oneconsultation is more suitable. Abbey MillsPumping Station should be used as themain drive site because:

- it has better road infrastructure

- use of the River Lee would reduce roadtransport

- the site has capacity to store spoil andmaterials

- lower impact on residential amenity

- higher construction costs are justified bylower community impact.

9086LO, 9147LO, 7496, 7621, 7804, 8306,8430, 8486, 8568, 8673, 9023, 9149,9387, 9488, 9496, 9497, LR13498

17 Following phase one consultation, we considered the feedbackcomments from phase one consultation, along with feedback from on-going engagement and new information. We also undertook furthertechnical work.

As part of this work, we reviewed the drive strategy for this section of themain tunnel. As a result of the review, we concluded that Abbey MillsPumping Station was less suitable than Chambers Wharf for thefollowing reasons:

- further technical work and discussions with the Thames Tunnelproject team and Olympic Delivery Authority on their experience forthe Olympic Park has shown that transporting materials to and fromAbbey Mills Pumping Station via the River Lee is highly undesirablewhen material needs to be transported daily over a two- to three-yearperiod. The same level of barge movements would be required if thesite were used as main tunnel drive site, given the volume ofexcavated material that would be produced

- at Abbey Mills Pumping Station there are more constraints in usingBow Creek to remove excavated material due to the fact that onlysmall 350 tonne barges could be used during a short tidal window,while at Chambers Wharf, 1,500 tonne or potentially larger barges

could be used on the River Thames to remove excavated materialproduced by a main tunnel drive site

- use of Chambers Wharf as the main tunnel drive site avoids the needto work in Channelsea River, which would avoid the potential healthand safety risks associated with the contaminated materials in theChannelsea River. It also means a lesser impact on the foreshoreecology and water resources at Abbey Mills Pumping Station

- it has been determined that work to construct campsheds and wharffacilities in the Channelsea River would introduce high health andsafety risks, including the handling of contaminated materials. Thisrisk does not exist at Chambers Wharf.

Although we recognise that the works at Chambers Wharf have thepotential to effect local residents, it is considered that appropriatemitigation measures could be put in place to address them, such as theconstruction shed to minimise noise during periods of 24-hour

construction.

In relation to Kings Stairs Gardens, we assessed both sites and, basedon our professional judgement, we consider Chambers Wharf moresuitable. Appendix R of the Phase two scheme development reportcomprehensively sets out why we consider Chambers Wharf moresuitable.

20.3.37 Reasons for changing the preferred sitesince phase one consultation are unclear/unjustified/unsatisfactory. With regards toAbbey Mills Pumping Station:

- feasibility of using the River Lee totransport materials needs to beinvestigated further

- use of the River Lee would reduce roadtransport

- higher construction costs are justified bythe lower community impact

- the site has better infrastructure

- argument that the change in ecologicalconditions in Southwark means theselection of Chambers Wharf is notconvincing.

With regards to Kings Stairs Gardens:

- the preferred site has simply beenrepositioned from other areas due tolocal protests

- Thames Water has purchased Chambers

Wharf and now has to justify thatdecision; its purchase has alsopredetermined its use

- Thames Water has not dealt with factorsthat gave rise to the identification ofKings Stairs Gardens as the preferredsite

- Kings Stairs Gardens is twice the size ofChambers Wharf

8410LO, 13490LO, 8226, 8649, 8712,9387

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- criteria used as justification for preferringChambers Wharf are inconsistent withthe published criteria for phase one.

20.3.38 The shortlisted site Kings Stairs Gardens(site 1) is more suitable because:

- it is cheaper

- it has better road access

- it is not located in a dense residentialarea or close to schools

- there are alternative local open spaces

- open space can be reinstated andimproved following construction

- would allow Chambers Wharf to beredeveloped immediately.

7262LO 1 Our re-assessment of sites prior to phase two consultation and ourreview of phase two consultation feedback comments does not supportthe use of King's Stairs Gardens as our preferred site. King's StairsGardens is less suitable than our preferred site because it would involvethe temporary loss of public open space and the diversion of the

Thames Path. The site also has relatively poor river access. KingsStairs Gardens does not have any existing jetty and wharf facilities,therefore these would need to be constructed.

Refer to chapter 6 and appendix R of the Phase two schemedevelopment reportfor further details on why we consider ChambersWharf more suitable.

20.3.39 Insufficient information has been providedon shortlisted sites. Specifically, theconsultation process and surveysundertaken for Kings Stairs Gardens areflawed. A particular report did not mentionthe school, community centre and churchright on the doorstep of Kings Stairs

Gardens. When open space surveys wereundertaken, the people who carried themout purposefully stood away from the centreof the gardens and did not take into accountthe children or dog walkers using thefacilities in the garden.

8626 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 our shortlisted sites are described and illustrated throughoutthe phase two consultation material, including the site informationpapers which provide an overview of the detail in the Phase two scheme

development report. We are confident, therefore, that the information wehave provided is sufficient.

20.3.40 The site selection methodology is incorrect/flawed/unjustified. In particular:

- it fails to take account of the effect onquality of life and human health

- insufficient weight is given to the impacton local communities

- it is biased towards the successfulimplementation of the project

- engineering preferences should notdictate the sites; availability of acceptablesites should dictate engineering solutions

- inconsistency in site selection reportsand application of criteria.

LR9272LO, 8649, 8890, 9007, 9385, 9395,9475, LR9341

8 The sites on which we have consulted were identified through anextensive 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.

20.3.41 Site selection should use/prioritisebrownfield sites.

7582 1 Whether a site is brownfield or greenfield/open space was taken intoaccount along with other considerations, as set out in the Site selectionmethodology paper.

20.3.42 Site selection should not use sites in the 8899 1 In general, main tunnel sites would be located on land due to a range of


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River Thames foreshore. engineering 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 in or on theforeshore of the River Thames. Further information can be found in theSite selection background technical paper, which is available on ourwebsite. At Chambers Wharf, where we would extend into the foreshore,one of the benefits is that barge movements would not be tideconstrained, which provides more flexibility during construction. It should

also be noted that the area of the construction site shown in ourdrawings is the maximum area tha t the site would extend into theforeshore and it is possible that the contractors may choose to re-configure the site in a way that minimises the part of the site in theforeshore.

20.3.43 Do not support the specific location/extent ofthe site. Specifically it would be easier if theconstruction site is entirely located on land.

LR9272LO, 8899 2

20.3.44 Site selection should avoid sites that havebeen allocated for/are known to be awaiting,or have planning permission forredevelopment.

(LR)LBS, 8303LO, 8768LO, LR9272LO,13490LO, 8753, 8890, 9395, 9476, 9488,9496, 9497, 9450PET

13 As part of the site selection process, we considered the planning statusof a site in our assessment and a professional judgement was made asto whether or not our proposed use would have an impact. It should benoted that even if sites have been allocated or have secured a planningpermission, it does not preclude the use of the site. Other factors suchas whether the planning permission would be implemented need to beconsidered. Even then it may be possible for construction work to bephased so that both the approved development and the Thames Tunnelproject could be constructed. Designated regeneration areas do notnecessary preclude the use of a site as our proposed use may in many

cases be complementary or beneficial to some of the regeneration aims.In relation to the approved residential development on this site, we willcontinue to work with St James, the residential developer, to ensure ourproposed works are compatible with the approved development and donot result in any unnecessary delays for construction of the approvedflats, associated facilities and landscaping. As with any development ofthis nature, the completion of the residential development would dependon the market conditions, which is one reason why this site becameavailable.

20.3.45 Site selection should prioritise use ofindustrial sites.

7215 1 The main tunnel search area and tunnel alignment generally follows theRiver Thames. This is because it is an efficient route to connect CSOson the north and south side of the river, it minimises going underbuildings and allows the use of river transport during construction. Theproposed site is a disused industrial site, which was a factor when

proposing this as our preferred site to construct the main tunnel. Inaddition to the locational constraints for main tunnel sites, the sites needto fulfil other engineering requirements and planning, environment,property and community considerations must be taken into account.Given that we are searching for sites in central London and given therequirements that the sites need to fulfil, we did not consider itappropriate to exclude industrial sites when compiling our longlist ofsites. We considered the use of the land, including any designations, aspart of the assessment.

20.3.46 Site selection should avoid sites in See annex D of this report 432 The main tunnel search area and tunnel alignment generally follows the


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20.3.49 Impact on residential amenity should beconsidered as part of the site selectionprocess, specifically proximity to the localpark.

13379LO, 9475 2 Proximity to residential areas and amenity areas such as local parks andthe potential effect of our proposals on residential amenity was takeninto account along with other considerations, as set out in our Siteselection methodology paper.

20.3.50 Existing uses on the site presentdevelopment constraints.

8356 1 Chambers Wharf is currently a disused industrial site that has beenpartially cleared for redevelopment, which means there are no currentuses that would be affected by our proposals on this site. We have,however, taken into account the approval for a residential developmenton this site in our site selection process, as set out in appendix R of ourPhase two scheme development report. Due to the phasing of theresidential development at the Chambers Wharf site, it is possible for theThames Tunnel project works to be undertaken.

20.3.51 The cost of using the site is too high/notcost-effective.

7262LO, 7261, 8890, 8899, 9074, 9347,9395, 9475, 9476, LR9341

10 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, alow value site would not become our preferred site if there weresignificant planning, environmental or community concerns associatedwith its use. In determining our preferred site, we made a balanced

judgement taking planning, environment, engineering, property and

community considerations into account.20.3.52 The site is too small and does not have

sufficient capacity to accommodate theproposals; the site would need to beextended 50m into the River Thames inorder to accommodate the proposals.

7262LO, 7452, 7460LO, 8303LO, 8562LO,8571LO, 9093LO, 9105LO, 9147LO,LR9271LO, 7621, 7709, 7761, 8456, 8557,8558, 8649, 8653, 8753, 8803LO, 8899,8938, 9074, 9198, 9251, LR8975, LR9112

27 The Site selection background technical paper, which accompanies theSite selection methodology paper, specifies the site sizes required forCSO and main tunnel sites. We have used these criteria to select ourpreferred sites. Chambers Wharf is therefore an appropriate size toaccommodate our proposals.

20.3.53 The scale of effects on the local area andcommunity resulting from the selection ofthis site is unacceptable/has not beenproperly considered. In particular, ThamesWater has not adequately considered theenvironmental, health and safety impact ofbuilding the tunnel from this site.

See annex D of this report 404 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 receptors,as well as the possible likely significant effects from traffic andconstruction works including noise, air quality and visual impact. We

also considered likely significant effects on employment uses andpossible conflict with planning policy that seeks to protect local amenity.Accordingly, we consider that the scale of possible likely significanteffects on the local area and community has been adequatelyconsidered.

In addition, health and safety effects of our proposals have beenconsidered. We also have obligations under The Construction (Designand Management) Regulations 2007 (CDM) as far as reasonablypracticable to avoid foreseeable risks to the health and safety of anyperson carrying out construction work. The designer must eliminate


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hazards where possible and reduce risks from any remaining hazards.We have been undertaking hazard identification and risk assessmentsas part of our on-going design development work. As a result of thiswork, we are confident that any risks could be managed.

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

20.3.54 Site selection should be reconsidered,taking into account opportunity and socialcosts and a comparison with the cost of atunnel boring machine (TBM) breaking downoccasionally, or the cost of a link to BecktonSewage Treatment Works or Limehouse.

8801LO, 8989, 9488 3 Refer to paragraph 2.5.18 for our response to this feedback comment.

20.3.55 Site selection should avoid sites on theriverside.

7402, 9475 2 The main tunnel search area and tunnel alignment generally follows theRiver Thames. This is because it is an efficient route to connect CSOson the north and south side of the river, it minimises going underbuildings and allows the use of river transport during construction. Inaddition to the locational constraints for main tunnel sites, the sites needto fulfil other engineering requirements and planning, environment,property and community considerations must be taken into account.Given that we are searching for sites in central London and given therequirements that the sites need to fulfil, we did not consider itappropriate to exclude riverside sites when compiling our longlist ofsites. We considered the use of the land, including any designations, aspart of the assessment.

20.3.56 The site should be developed for otheruses, specifically residential use.

8444 1 Using a site for the Thames Tunnel project does not preclude the sitefrom other uses once construction is complete. The footprint of thepermanent works required for the operation of the project is significantlysmaller than the space required during construction. The area notpermanently required could be used for other uses, including thosespecified.

20.3.57 Disagree with site selection due to widerobjections to the proposed solution,specifically:

- not necessary to use a site in Southwarkas there are no CSOs to intercept

- Thames Water could construct the tunnelwithout using this site.

7996LO, 8303LO, 8410LO, 8560LO,8561LO, 8562LO, 8563LO, 8569LO,8571LO, 8795LO, 8802LO, 8887LO,9083LO, 9084LO, 9086LO, 9092LO,9107LO, 9254LO, 9380LO, LR9272LO,LR9274LO, LR9379LO, LR9386LO,10829, 10830, 10832, 10833, 10837,

10838, 10839, 10840, 10841, 10842,10843, 10844, 10845, 10846, 10847,10848, 10849, 10850, 10851, 10852,10853, 10854, 10855, 10856, 10857,10858, 10860, 10861, 10862, 10863,10864, 10865, 10866, 10867, 10868,10870, 10871, 10872, 10873, 10876,10885, 10890, 10928, 10951, 10953,10954, 10955, 10956, 10957, 10959,10968, 10969, 11002, 11003, 11004,

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

In addition to sites to intercept the CSOs we also need sites to constructthe main tunnel to transfer the sewage to Beckton Sewage TreatmentWorks for treatment. Preventing the current regular discharges into theriver would have benefits not just for areas closest to CSOs but also forother riverside communities, such as the area around Chambers Wharf.

While no CSO needs to be intercepted at this site, Southwark does havea CSO (at Shad Thames Pumping Station to the west of ChambersWharf) that requires works to prevent the current discharges to the RiverThames. We propose to manage this CSO by utilising the existing sewersystem in this area and modifying the pumping station. However, thiswould not be possible if we did not intercept the other CSOs to the eastof Southwark, particularly Earl Pumping Station on the Lewisham/Southwark border, which would deal with additional flows from the west,including those that originate in Southwark.


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11005, 11006, 11007, 13484, 7261, 7496,7578, 7582, 7761, 8062, 8194, 8251,8252, 8253, 8255, 8256, 8258, 8259,8260, 8266, 8268, 8270, 8271, 8272,8273, 8297, 8298, 8299, 8300, 8386,8393, 8394, 8415, 8416, 8417, 8418,8419, 8420, 8423, 8426, 8428, 8431,8432, 8456, 8557, 8558, 8567, 8572,

8624, 8647, 8673, 8712, 8738, 8751,8753, 8890, 8927, 8943, 8953, 9007,9074, 9082, 9129, 9149, 9198, 9251,9308, 9316, 9317, 9334, 9353, 9357,9381, 9395, 9475, 9488, 9496, 9497,LR10970, LR10972, LR10975, LR10981,LR10996, LR11000, LR13404, LR13405,LR13406, LR13407, LR13408, LR13411,LR13413, LR13416, LR8422, LR9136,LR9280, LR9289, LR9341, LR9343,LR9352, LR9360

20.3.58 Site selection should avoid sites adjacent toor containing heritage assets; ChambersWharf is very close to Tower Bridge WorldHeritage Site (WHS), sits partially in the

Protected London Panorama View:Greenwich Park to Central London and hassignificant archaeological potential.

EH, 8410LO, 8561LO, 8803LO,LR9272LO, 8299, 8300, 8649, 8712, 8836,8890, 9168, 9206, 9288, 9395, 9476,LR9341

17 The main tunnel search area and tunnel alignment generally follows theRiver Thames. This is because it is an efficient route to connect CSOson the north and south side of the river, it minimises going underbuildings and allows the use of river transport during construction. In

addition to the locational constraints for main tunnel sites, the sites needto fulfil other engineering requirements and planning, environment,property and community considerations must be taken into account. Asset out in the Site selection methodology paper, sites in Londons WHSshave not been identified in recognition of the historic importance of thesesites. Given that we are searching for sites in central London and giventhe requirements that the sites need to fulfil, we did not consider itappropriate to exclude sites included or adjacent to other designatedheritage assets when compiling our longlist of sites. We considered theeffect of our proposals of heritage designations as part of theassessment. We concluded that effects on built heritage and townscapewould not be significant and therefore the site was considered suitable.

20.3.59 Site selection appears unsustainable/notenvironmentally friendly.

9160 1 Site selection has involved a multidisciplinary approach and hasconsidered community (including socio-economic) and environmentalfactors alongside planning (including policies on sustainable

development), engineering and property considerations. We aresatisfied that our approach takes full account of environmental issuesand the requirement for sustainable development.

20.3.60 Other concerns, issues and objectionsinclude:

- site is too close to a major tourist area

LR9271LO, 7589, 7987, 8938, 9036,LR13498, LR8975

7 We do not consider that undertaking construction works at ChambersWharf would negatively affect the area around Tower Bridge.

- the fact that Thames Water has changedthe site once suggests it can be doneagain

Based on the sites we have identified through the site selectionmethodology, we consider that Chambers Wharf to be most suitable.


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- none of the sites proposed appear toadequately address the issues

- it is a lazy solution simply because thesite became available

- continued extension of the proposeddates for commencement of the projectoffers the opportunity to ensure that

proposals are representative of thevarious options that may not have existedat the time the project was initiallyproposed

Alternative solutions to constructing a tunnel have been considered indetail over a number of years however no suitable or practicablealternative has been identified, which has recently been confirmed in the

government's National Policy Statement for Waste Water, that waspublished in March this year.

- area is up and coming and would bedamaged by the proposals.

We do not expect that construction of the tunnel in this location wouldcompromise the wider regeneration of the area or future redevelopmentof the site.

Supportive and neutral feedback comments in relation to shortlisted sites

20.3.61 No supportive or neutral feedback comments were received in relation to the shortlisted sites.

Objections, issues and concerns in relation to shortlisted sites

Table 20.3.4 Objections, issues and concerns in relation to shortlisted sites

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

Shortlisted site Kings Stairs Gardens (site1) is unsuitable for the proposed use(s)because:

- it is a greenfield site, open space, greencorridor and designated village green

- the site is a valuable recreational andcommunity resource in a sociallydeprived area

- there are few other open spaces in thelocal area and use of the site would resultin the permanent loss of some openspace

- proximity to residential dwellings andimpact on residential amenity

- the site is located in an ArchaeologicalPriority Area, Kings Stairs Gardens,Southwark Park Conservation Area andneighbours the Moated Manor House ofEdward III Scheduled Monument andother historic sites

- heritage value of the site itself

- impact on views of local landmarks andriver events

EH, (LR)LBS, 8787LO, LR9274LO,7582,7624, 7625, 7725, 7804, 7939, 7966,8054, 8186, 8188, 8323, 8475, 8477,8483, 8488, 8491, 8604, 8606, 8610,8626, 8673, 8692, 8765, 8775, 8776,8780, 8793, 8857, 8876, 8907, 8933,8936, 8940, 8941, 8942, 8943, 8964,8967, 8972, 8973, 8980, 8988, 8996,8997, 9026, 9028, 9029, 9063, 9067,9243, 9259, 9298, 9339, 9347, 9383,9385, 9389, 9488, 9494, LR9158,13377PET

65 Based on our assessment, we consider that Kings Stairs Gardens maypotentially be suitable as a main tunnel site, however, in comparison toour preferred site it is less suitable because it would involve thetemporary loss of public open space and the diversion of the ThamesPath. The site also has relatively poor river access. Kings StairsGardens does not have any existing jetty and wharf facilities, thereforethese would need to be constructed.

For further details on the results of the site selection process, includingresponses to the detailed points raised, refer to chapter 6 and appendixR of the Phase two scheme development report.


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- local road infrastructure and site accessis unsuitable

- the site has a high ecological value,including Site of Importance for NatureConservation (SINC) designation

- the site is a prime tourist attraction

- use of the site would have a negativeeconomic impact on the local area

- the site is part of the Thames Path,Jubilee Greenway and National CycleNetwork

- impact on planned developments in thelocal area

- greenfield sites should be protected asthey help to reduce surface runoff

- phase one consultation site selectionmethodology was flawed and informationcontained in the Chambers Wharf siteinformation papercontradicts letters sentto Save Kings Stairs Gardens ActionGroup regarding site suitability.

Objection to the inclusion or referencing ofKings Stairs Gardens (site 1) as a possiblealternative to the preferred site.

(LR)LBS, 8787LO, 9133LO, 7101, 7111,7189, 7270, 7582, 7585, 7586, 7624,7625, 7719, 7725, 7800, 7804, 7966,8054, 8186, 8194, 8465, 8475, 8477,8488, 8491, 8572, 8604, 8606, 8610,8625, 8626, 8673, 8692, 8738, 8775,8776, 8780, 8793, 8857, 8907, 8933,8935, 8936, 8940, 8941, 8942, 8943,8964, 8965, 8967, 8972, 8973, 8980,8988, 8996, 8997, 9028, 9029, 9043,9063, 9067, 9156, 9243, 9259, 9298,9339, 9347, 9383, 9385, 9389, 9494,LR9158, LR9315, 9450PET

74

Shortlisted sites

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

20.4 Alternative sites

20.4.1 During the phase two consultation, respondents were invited to suggest alternative sites that they thought should be used to drive the main tunnel to Abbey Mills Pumping Station andreceive it from Kirtling Street and connect the Greenwich Pumping Station, Deptford Church Street and Earl Pumping Station CSOs via the Greenwich connection tunnel instead ofChambers Wharf (see question 3 of the phase two consultation feedback form, provided in appendix M of the Main report on phase two consultation). The following sites were put forwardas possible alternatives:


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Table 20.4.1 Suggested alternative sites to Chambers Wharf

Ref Alternative site suggestions Reasons Respondent ID No. Our response

Preferred site

20.4.2 Chambers Wharf. It is a brownfield site which is derelictand has been cleared. The site alsohas good access by road and river.This site is also preferred over KingsStairs Gardens.

7536, 7966,8119

3 As set out in the Chambers Wharf site information paper, this is ourpreferred site.

Shortlisted sites

20.4.3 King's Stairs Gardens. It is a larger site, less expensive andwould not delay residentialdevelopment proceeding atChambers Wharf. It is large enough toaccommodate both drive points and areceptor point, therefore reducing thetunnelling impact on Greenwich. Itwould also not require constructionworks in the foreshore of the RiverThames. It has not been sufficientlyevaluated by Thames Water, and nosufficient reason has been given as towhy it was rejected at phase two.

The site is also further from schoolsand residential areas, which wouldmean less disruption for localresidents. The site also benefits fromgood road access and would causeless traffic congestion than atChambers Wharf. It has direct riveraccess and the addition of a small

jetty would enable the removal ofexcavated material via the river.

After construction works, the sitecould be re-landscaped. Duringconstruction Southwark Park can beused as an alternative green space.

8768LO,13490LO,7709, 7262,8680, 8899,8653,

7 We did identify and consider this site. It is a shortlisted site and isconsidered less suitable than our preferred site (Chambers Wharf)because it would involve the temporary loss of public open space andthe diversion of the Thames Path. The site also has relatively poor riveraccess. It does not have any existing jetty and wharf facilities, thereforethese would need to be constructed. While we recognise that the sitemay be further away from residential properties and local amenities, weconsider that at Chambers Wharf these effects could be adequatelymitigated.


Other sites

20.4.4 Abbey Mills Pumping Station. It is a brownfield site, with sufficientland to house and undertake theconstruction works. The site is furtheraway from residential areas andcheaper than Chambers Wharf.However, any additional cost anddifficulty associated with using thissite is far outweighed by the effects ofthe construction works on local

7460LO,8560LO,

8571LO,8632LO,

8803LO,9083LO,

9085LO,9086LO,9092LO,

52 Following phase one consultation, we considered the comments fromphase one consultation, along with feedback from on-going engagementand new information. We also undertook further technical work.

As part of this work, we reviewed the drive strategy for this section of themain tunnel. As a result of the review, we concluded that Abbey MillsPumping Station was less suitable than Chambers Wharf for thefollowing reasons:

- further technical work and discussions with the Lee Tunnel projectteam and Olympic Delivery Authority on their experience for the


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residents at Chambers Wharf. Thetunnel should be built from AbbeyMills Pumping Station using thetechnology outlined by the 'Save YourRiverside' campaign, namely hybridTBMs.

It was the preferred site at phase oneconsultation and is a Thames Water

operational site. Thames Watershould provide detailed reasons as towhy it is not possible, especially sincethe site is already set up for majorconstruction works due to worksassociated with the Lee Tunnel.

The site has better road and riveraccess allowing use of the River Leeto transport materials (asdemonstrated by the Lee Tunnel).The site would also not affect theThames Path or riverside views. Therisk of subsidence is also lower atAbbey Mills Pumping Station.

If you amend the drive strategy for the

main tunnel and the Greenwichconnection tunnel, it would bepossible to obviate the need for a siteat Chambers Wharf. Therefore use ofAbbey Mills Pumping Station wouldbe most appropriate.

9093LO,9105LO,9147LO,

9254LO,LR9271LO,LR9272LO,LR9274LO,9146LO, 7452,

7496, 7621,7695, 7767,8041, 8260,8268, 8299,8430, 8558,8568, 8572,8673, 8753,8781, 8791,8890, 8953,9007, 9063,LR9112, 9149,9161, LR9280,LR9341,LR9343, 9347,9357, 9387,

9395, 9475,9496, 9497,LR13413,

Olympic Park have shown that transporting materials to and fromAbbey Mills Pumping Station by the River Lee is highly undesirablewhen material needs to be transported daily over a two- to three-yearperiod. The same level of barge movements would be required if thesite were used as main tunnel drive site, given the volume ofexcavated material that would be produced

- at Abbey Mills Pumping Station there are more constraints in usingBow Creek to remove excavated material due to the fact that only

small 350 tonne barges could be used during a short tidal window,while at Chambers Wharf, 1,500 tonne or potentially larger bargescould be used on the River Thames to remove excavated materialproduced by a main tunnel drive site

- use of Chambers Wharf as the main tunnel drive site avoids the needto work in the Channelsea River, which would avoid the potentialhealth and safety risks associated with the contaminated materials inthe Channelsea River. It would also mean a lesser impact on theforeshore ecology and water resources at Abbey Mills PumpingStation

- we have determined that work to construct campsheds and wharffacilities in the Channelsea River would introduce high health andsafety risks, including the handling of contaminated materials. Thisrisk does not exist at Chambers Wharf.

Although we recognise that the works at Chambers Wharf have thepotential to effect local residents, we consider that appropriate mitigationmeasures could be put in place to address them, such as theconstruction shed to minimise noise during periods of 24-hourconstruction.

For further details on the results of the site selection process, refer toappendix R of the Phase two scheme development report. In addition tothe response provided here, you may also find the response atparagraph 2.5.18 of interest.

20.4.5 Southwark Park. It is a large site which is further awayfrom residential areas and localschools. The site also has good roadaccess and is near the river, whichwould facilitate barge use.

8303LO 1 We did identify and consider this site although it did not progress beyondthe draft shortlist stage of the site selection process. This site wasappraised as only suitable as a main tunnel reception site. It wasconsidered less suitable than Chambers Wharf since the site has nodirect access to the River Thames, it would impact on large number ofplanning designations, including development on Metropolitan Open

Land, Historic Park and Garden etc and would result in temporary loss ofthe park, which would impact on park users and other sensitivereceptors. This site would also require the main tunnel to be diverted farinland which means that it would pass under more properties and haveother hydraulic consequences.


20.4.6 Greenwich Pumping Station. There should not be a site inSouthwark since no CSO is being

9083LO,9084LO, 8573,

4 Since phase one consultation, we decided that we would change oureastern main tunnel site from Kings Sta irs Gardens to Chambers Wharf.


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intercepted; drive Greenwichconnection tunnel from GreenwichPumping Station to Abbey MillsPumping Station thereby avoidingChambers Wharf. Suggested site isfurther from residential properties.

9347 Chambers Wharf is constrained by site size and programme limitations,which mean that this site can only support one tunnel drive. Furtherinvestigation also found that it would be difficult to drive the main tunnelfrom Abbey Mills Pumping Station. Therefore, we decided to useChambers Wharf to drive the main tunnel to Abbey Mills PumpingStation. We also need a long connection tunnel drive site to connect thethree CSOs being intercepted at Earl Pumping Station, Deptford ChurchStreet and Greenwich Pumping Station. Due to the limitations identified

at Chambers Wharf, we needed to investigate the option of driving theconnection tunnel from Greenwich Pumping Station or an alternativesite. We considered sites in the vicinity of Deptford Church Street andGreenwich Pumping Station as alternative long connection tunnel drivesites and not as alternatives to Chambers Wharf.

As well as needing to intercept CSOs, we also need sites to constructthe main tunnel at certain locations where the geology that the tunnelwould go through changes, such as the area around Chambers Wharf.Greenwich Pumping Station or Deptford Church Street are too far awayfrom where this geological change occurs and therefore are not suitablefor this purpose. We do, however, need to intercept the CSOs at both thesuggested sites and transfer the sewage flow to the main tunnel so it canbe treated at Beckton Sewage Treatment Works. Our preferred site tomake this connection is Chambers Wharf, for the reasons set out inappendix V of our Phase two scheme development report.

It would not be possible to drive a tunnel directly to Abbey Mills PumpingStation and intercept the three CSOs on this side of the river fromGreenwich Pumping Station without a connection to the main tunnelsomewhere in the Limehouse area. We have not identified any suitablesites to make this connection.

Deptford Church Street would not be large enough to construct the mainor long connection tunnels and it is too far away from the River Thames,which means that it would not be possible to transport materials by river.Both sites, like most sites in London, have residential areas close tothem.

For further details on our assessment of long connection tunnel drivesites refer to appendix V of the Phase two scheme development report.

20.4.7 Deptford Church Street. There should not be a site inSouthwark since no CSO is being

intercepted.

8573, 9347 2

20.4.8 Kirtling Street. The main tunnel should be drivenfrom Kirtling Street and Abbey Mills

Pumping Station. There is no reasonto do any work in Southwark andusing this site would have less impacton local communities.

8558 1 Refer to paragraph 2.5.18 for our response to this feedback comment.

20.4.9 Blackfriars Bridge Foreshore. It could be used as an emergency exitas there is no need to drive fromChambers Wharf.

LR9272LO 1 The site suggested has been identified through the site selection processas being suitable as a CSO interception site. We need a smaller site forCSO interception and therefore the suggested sites are not large enoughto accommodate works associated with a main tunnel site. If we used thesuggested sites we would still need to intercept the CSO, which wouldrequire a larger site than if we used the site solely to build the main


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on the local community/quality of lifeand will be further away from localschools. It will also have less impacton the local ecology.

LR9386LO,8225, 8412,8649, 8750,8751, 8776,8786, LR9111,LR9116, 9269,LR9279

connections. A main tunnel site cannot therefore be selected in isolation.

Prior to identifying the precise location of the main tunnel sites, weestablished the broad areas in which they would be needed. Theseextended 500m from the edge of the River Thames. Sites need to bewithin this distance of the River Thames to maximise the potential to useriver transport and minimise how much of the main tunnel would beconstructed under existing buildings.

As part of the site selection process, we considered all potential sites in

each zone. Based on our assessment, sites in non-residential areaswere considered not suitable. For further information, refer to appendix Rof the Phase two scheme development report.

No sites owned by Thames Water in this part of London met our searchparameters and therefore it is not possible to utilise a Thames Watersite. Chapter 6 of the Phase two scheme development reportprovidesmore information on our approach to selecting tunnelling sites andchapter 6 and appendix W explain why Abbey Mills Pumping Station isconsidered less suitable as a main tunnel site.

20.4.18 Another of Thames Water's

sites.

Thames Water owns or has access to

at least one other site in an industrialarea; the use of these sites should beprioritised.

7756, 8486 2

20.4.19 Brownfield site(s)

- further from residential areas

- near railway tracks

- further downstream

- further from the river.

There are a number further south ofthe river which would be further fromresidential areas and schools.

8569LO,9392LO, 7490,7966, 9383

5 Our preferred site, Chambers Wharf, is a brownfield site. As part of thesite selection process, we have considered all sites that fall within oursearch parameters (set out in our Site selection methodology paper).Prior to identifying the precise location of the main tunnel sites, weestablished the broad areas in which they would be needed. Theseextended 500m from the edge of the River Thames. Sites need to bewithin this distance of the River Thames to maximise the potential to useriver transport and minimise how much of the main tunnel would beconstructed under existing buildings.

All other brownfield sites assessed in the search area were consideredunsuitable. Further details are contained in appendix R of the Phase twoscheme development report.

20.4.20 Any site outside of London. It should not be in London directlyadjoining residents.

8764 1 The current situation that this project is preparing to address is the CSOsin London that regularly discharge into the River Thames. Since this iswhere the CSOs are located we need to construct our tunnel andinterceptions of these CSOs on sites in London.

Due to the nature of the project, it is necessary to select a package ofmain tunnel sites and have regard to how they would work incombination and in relation to the tunnel alignment and CSOconnections. A main tunnel site cannot therefore be selected in isolation.

Prior to identifying the precise location of the main tunnel sites, weestablished the broad areas in which they would be needed. Theseextended 500m from the edge of the River Thames. Sites need to bewithin this distance of the River Thames to maximise the potential to useriver transport and minimise how much of the main tunnel would beconstructed under existing buildings.

The suggested site is outside of this area and therefore is not consideredto be a suitable main tunnel drive site.


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20.4.21 Respondents also made the following feedback comments in relation to the availability and identification of alternative sites:

Supportive and neutral feedback comments

Table 20.4.2 Supportive and neutral comments in relation to the availability and identification of alternative sites



20.4.22 No alternative site is available; ThamesWater has done its best to survey alternativesites.

7404 1 Your support is noted and welcomed.

Objections, issues and concerns

Table 20.4.3 Objections, issues and concerns in relation to the availability and identification of alternative sites


20.4.23 It is the responsibility of Thames Water toidentify sites, should be non-residential, withaccess by river only.

8298, 8614 2 We have undertaken an extensive site selection process, the results ofwhich are contained in our phase two consultation material. The purposeof phase two consultation was to seek feedback on the work we haveundertaken. Refer to appendix R of our Phase two scheme developmentreportfor further details.

20.4.24 Unable to comment; none of the proposedsites adequately address the issues.

8305LO, 8783 2 As set out in our phase two consultation material, we consider thatChambers Wharf is the most suitable site.

20.4.25 There are no suitable sites inBermondsey/Southwark. It is a dense

residential area and there are major touristattractions along the river which form animportant source of income for the localarea.

7996LO, 7165, 7166 3

20.4.26 Not an expert/not qualified/do not have theknowledge to comment.

8552LO 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 feedback comments received from both technical and non-technical consultees.

20.5 Management of construction works

20.5.1 This section sets out feedback comments received during the phase two consultation in relation to the management of construction works at Chambers Wharf. This includes theidentification of site specific issues arising from construction activities and proposals for addressing these issues.

20.5.2 During the phase two consultation, respondents were asked whether the site information paper had identified the right key issues associated with Chambers Wharf during construction andthe ways to address these issues (see questions 4a and 4b o f the phase two consultation feedback form, provided in appendix M of the Main report on phase two consultation). The firstpart of question 4a and 4b asked respondents to select agree, disagree or dont know/unsure. Where respondents completed this part of the question, the results are set out in tables20.5.1 and 20.5.2. Tables 20.5.3 to 20.5.41 detail the feedback comments received in relation to this site. It should be noted that not all respondents who provided feedback commentsconfirmed whether the right issues and the ways to address those issues had been identified.


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General feedback comments on the identified key issues

Supportive and neutral feedback comments in relation to the identified key issues

Table 20.5.3 Supportive and neutral feedback comments in relation to key issues during construction

Ref Supportive and neutral comments Respondent ID No. Our response

20.5.4 The correct key issues have been identified. 7996LO 1 Your comment is noted and welcomed.

Objections, issues and concerns in relation to the identified key issues

Table 20.5.4 Objections, issues and concerns in relation to key issues during construction

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

20.5.5 The wrong/none of the key issues havebeen identified.

8653 1 The key issues set out in the Chambers Wharf siteinformation paperare intended to provide a broad overviewof potential effects and key issues associated with the siteduring construction. It is not, however, an exhaustive list. Amore detailed description of possible likely significant effectsand the methodology through which they have beenidentified is provided in other technical reports, including thePEIR(volume 22), Design development report, Phase twoscheme development report,Site selection methodologypaperand Site selection background technical paper. Weare undertaking an environmental impact assessment, whichwill include a comprehensive assessment of likely significanteffects arising from the proposals. The findings of the

assessment, together with any recommendations formitigation, will be available as part of the Environmentalstatementthat will be submitted with our DCO appli cation.

N

20.5.6 The scale of potential effects has not beenproperly assessed and/or underestimated.

8653, 8751, 8849, 9129, LR9136 5 N

20.5.7 More fundamental issues regarding thesite's selection, its suitability and alternativesites have not been addressed/recognised.

7465 1 Please refer to our response at paragraph 20.3.26 above. N

20.5.8 There are more key issues than thoseidentified in the site information paper.

8768LO 1 The consultation provides the opportunity for us to respondto any additional issues raised. The key issues set out in theChambers Wharf site information paperare intended toprovide a broad overview of potential effects and key issuesassociated with the site during construction. It is not,however, an exhaustive list. A more detailed description ofpossible likely significant effects and the methodologythrough which they have been identified and assessed is

provided in other technical reports, including the PEIR(volume 22), Design development report, Phase two schemedevelopment report, Site selection methodology paperandSite selection background technical paper. We areundertaking an environmental impact assessment, which willinclude a comprehensive assessment of likely significanteffects arising from the proposals. The findings of theassessment, together with any recommendations formitigation, will be available as part of the Environmentalstatementthat will be submitted with our DCO appli cation.

N


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the PEIR(volume 22).

- would welcome more positive statementsin connection with the identification andmitigation of issues.

We have sought to avoid or eliminate potential likelysignificant effects wherever possible, both by developingrobust technical solutions to potential issues such as odour,and through our proposals for the construction andoperational site design and layout. We believe that themeasures set out in the site information paper and draftCOCPwould address and/or reduce the potential effects

satisfactorily. Measures proposed to address potentialeffects are being further developed and considered as partof the environmental impact assessment. The findings of theassessment, together with any recommendations formitigation, will be available as part of the Environmentalstatementthat will be submitted with our DCO appli cation.

N

- the issues focus on the removal of tunnelwaste and how this will be moved; therewill be significant other works insupporting this operation and these arenot considered as issues.

Our draft Waste management strategyprovides furtherdetails of how we propose to deal with construction waste.

N

General feedback comments on measures to address the key issues

Supportive and neutral feedback comments in relation to the measures proposed to address the key issues

20.5.14 No supportive or neutral feedback comments were received in relation to general comments on the measures proposed to address the key issues during construction.

Objections, issues and concerns in relation to the measures proposed to address the key issues

Table 20.5.5 Objections, issues and concerns in relation to the measures proposed to address the key issues during construction


20.5.15 Measures to address potential issues areunsatisfactory/unconvincing.

9105LO, 9107LO, 7490, 7709, 7756, 8647,8653, 8751, 8776, 8783, 8899, 9129,LR9279, LR9280

14 The measures set out in the Chambers Wharf siteinformation paperare intended to provide a broad overviewof how we intend to address potential issues associated withthe site. Further information can be found in the draft CoCPand PEIR(volume 22). Measures proposed to addresslikely significant effects are being further developed andconsidered as part of the environmental impact assessment.The findings of the assessment, together with anyrecommendations for mitigation, will be available as part of

the Environmental statementthat will be submitted with ourDCO application.

N

20.5.16 Measures to address potential effects areunsatisfactory/irrelevant as the wrong sitehas been identified/alternatives have notbeen properly considered.

8647, 8776 2 Please see our response at paragraph 20.3.26 above. N

20.5.17 Measures to address potential effects areunsatisfactory because the wrong/not all theissues have been identified.

8569LO 1 The key issues set out in the site information paper areintended to provide a broad overview of potential effects andkey issues associated with the site during construction. It is

N

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20.5.18 Measures to address potential effects areunsatisfactory because the scale and/orsignificance of the issues has beenunderestimated/not properly assessed.

8751 1 not, however, an exhaustive list. Further potential issuesassociated with the site and measures to address these areset out in the PEIR(volume 22).

We are undertaking an environmental impact assessment,which will include a comprehensive assessment of likelysignificant effects arising from the proposals. The findings ofthe assessment, together with any recommendations formitigation will be available as part of the Environmental

statementthat will be submitted with our DCO appli cation.

N

20.5.19 Thames Water cannot guarantee thatpotential effects will be satisfactorilyaddressed and/or reduced

8768LO, 7166, 8899 3 We believe that the measures set out in the site informationpaper would address and/or reduce the potential effectssatisfactorily. We are developing a CoCPthat will set outhow we would manage our construction sites to minimisedisruption to nearby communities.

Measures proposed to address potential likely significanteffects are being further developed and considered as partof the environmental impact assessment. The findings of theassessment, together with any recommendations formitigation, will be available as part of the Environmentalstatementthat will be submitted with our DCO application.

N

20.5.20 Measures proposed to address potentialeffects may minimise or manage them, but

they cannot be eliminated/prevented.

8569LO 1 We have sought to avoid or eliminate potential likelysignificant effects wherever possible, both through

construction site design and layout and by adopting suitablemeasures to manage construction activities.

Measures proposed to address potential likely significanteffects are being further developed and considered as partof the environmental impact assessment. The findings of theassessment, together with any recommendations formitigation, will be available as part of the Environmentalstatementthat will be submitted with our DCO appli cation.

N

20.5.21 Measures to address potential effects do notaddress the real concerns of local residents.

9269 1 We have sought to understand the concerns of residentsthrough our consultation process. The proposals presentedat phase two consultation reflect the issues raised by localresidents during previous consultation activities. Thepurpose of phase two consultation was to further explore theissues and concerns of local residents to ensure that, wherepossible, their principal concerns are taken into account.

This Report on phase two consultationsets out our view onhow we intend to respond to the feedback received duringthis phase of consultation. Our DCO application must beaccompanied by a Consultation reportthat explains how wehave responded to public consultation, includingexplanations of instances where we have not proposed anychange to the design in response to consultation comments.The process is intended to be open and transparent and toensure that project promoters give careful consideration to

N

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consultation responses and, where necessary, adjust theirproposals accordingly.

20.5.22 Consultation feedback does not appear tohave been taken into account by ThamesWater.

7166 1 An integral part of the pre-application process is the legalrequirement that we consult with the communities andstakeholders in the vicinity of the tunnel route and the siteswe intend to use to construct and operate the project. Wemust take account of all the comments received in responseto consultation. We also need to comply with advice issued

by the Planning Inspectorate and guidance from theSecretary of State in respect of pre-application consultationrequirements. The process is intended to be open andtransparent and ensure that project promoters give carefulconsideration to consultation responses and, wherenecessary, adjust their proposals accordingly. We arecommitted to this approach.

At phase one consultation, we consulted on need to reducethe amount of sewage entering the River Thames, the optionof a storage and transfer tunnel to address CSO discharges,the route of the tunnel, and our preferred construction sites.We also sought views our initial design proposals for thesites. Consistent with the legal requirement, the scheme weare consulting on at phase two consultation takes account ofthe responses we received at phase one consultation and

further engineering design refinements identified by theproject team.

This Report on phase two consultationsets out our view onhow we intend to respond to the feedback received duringthis phase of consultation. When we submit our DCOapplication for determination, a Consultation reportwillaccompany it. The Consultation reportwill set out how wehave taken into account the feedback received across allphases of consultation.

N

20.5.23 Identified issues can/should be avoided/addressed by changing the preferred site.

8795LO, 7756, LR9112 3 Please see our response at paragraph 20.3.26 above.

20.5.24 Responses to key issues provide noguarantee that effects will be managed,controlled and/or avoided.

7996LO, 8887LO, 7709 3 If a Development Consent Order is granted we anticipate aseries of requirements (similar to planning conditions) thatwould control the development. We expect that the

mitigation measures set out in the Environmental statementthat will besubmitted with the application would be includedin these requirements.

N

20.5.25 Other issues and comments relating tomeasures to address construction issuesincluded:

- construction impacts must be minimised atevery stage of construction

GLA, 8560LO, 8849 3 We have sought to avoid or eliminate potential likelysignificant effects wherever possible, both by developingrobust technical solutions to potential issues such as odour,and through our proposals for the permanent site designand layout.

N

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Supp Report on P2 Consultation - Chapter 20 Chambers Wharf

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