1-MAIN REPORT on Phase 1 Consultation

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Thames TunnelMain Report onPhase 1 Consultation

March 2011


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Thames Tunnel

Main Report on Phase 1 Consultation

List of contents

Page number

1 Foreward......................................................................................................... 1

Section 1 Approach to consultation 3

1 Introduction.................................................................................................... 42 Our Approach................................................................................................. 83 Method .......................................................................................................... 20

Section 2 Need, solution and tunnel route 27

4 ...............................................................................The need for the tunnel 285 .......................................................................................................The route 396 Other comments .......................................................................................... 43

Section 3 Site specific issues 477 Acton Storm Tanks (site 1).......................................................................... 488 Hammersmith Pumping Station (site 2) ..................................................... 529 Barn Elms (site 3)......................................................................................... 5710 Putney Bridge Foreshore (site 4)................................................................ 6411 Bell Lane Creek (site 5) ............................................................................... 6912 King Georges Park (site 6) ......................................................................... 7213 Jews Row (site 7) ......................................................................................... 7614 Bridges Court Car Park (site 8)................................................................... 8015 Cremorne Wharf Foreshore (site 9)............................................................ 8416 Chelsea Embankment Foreshore (site 10)................................................. 8817 Tideway Walk (site 11) ................................................................................. 91

18 Albert Embankment Foreshore (site 12) .................................................... 9619 Victoria Embankment Foreshore (site 13) .............................................. 10020 Blackfriars Bridge Foreshore (site 14) ..................................................... 10321 Druid Street (site 15).................................................................................. 10722 Kings Stairs Gardens (site 16) ................................................................. 111


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23 King Edward Memorial Park Foreshore (site 17)..................................... 11624 Butcher Row (site 18) ................................................................................ 12125 Abbey Mills Pumping Station (site 19) .................................................... 12526 Earl Pumping Station (site 20) ................................................................. 12927 Borthwick Wharf Foreshore (site 21)........................................................ 13328 Greenwich Pumping Station (site 22)....................................................... 13729 Beckton Sewage Treatment Works ......................................................... 140

Section 4 The consultation process 142

30 .........................................................................Approach to consultation 143

Section 5 Conclusion 14931 ................................................................................................Conclusion . 150

Glossary ................................................................................................................ 155Appendices ........................................................................................................... 160


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List of figures

Page number

Figure 4.1 Support for alternative solutions .............................................................. 35Figure .................................................................................5.1 Feedback on routes 39

List of tables

Page number

Table .............................................................2.1 Project information papers (PiPs) 16Table ....................................................2.2 Site specific project information papers 17Table ....................................................................2.3 Other project documentation 17

Table ..................................................................................3.1. Means of feedback 20Table ....................................................................................3.2. Respondent Type 20Table ......................................................................................4.1 Feedback results 28Table ......................................................................4.2 Main issues and responses 29Table ......................................................................................4.3 Feedback results 31Table ........................................................4.4 Tunnel solution response to issues 32Table ......................................4.5 Alternative solutions main comments received 35Table 5.1 Tunnel routes ............................................ main issues and responses 40Table ......................................................................6.1 Main issues and responses 43Table .......................................................30.1 Summary of issues and responses 144Table ................................31.1 Preferred sites: principal changes and outcome ... 150


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List of abbreviations

1990 Act Town and Country Planning Act 1990

2004 Act The Planning and Compulsory Purchase Act 2004

2008 Act Planning Act 2008

APA Archaeological Priority Areas

CoL Corporation of the City of London

CSO Combined sewer overflow

CCWater Consumer Council for Water

DCLG Department of Communities and Local Government

DCO Development Consent Order

DEFRA Department of Environment, Fisheries and Rural Affairs

EA Environment Agency

EH English Heritage

EIA Environmental Impact Assessment

ES Environmental Statement

EU European Union

FAQs Frequently Asked Questions

FRA Flood Risk Assessment

GLA Greater London Authority

HPA Health Protection Agency

IPC Infrastructure Planning Commission

LA London Assembly

LBE London Borough of Ealing

LBHF London Borough of Hammersmith and Fulham

LBG London Borough of Greenwich

LBL London Borough of Lambeth

LBLew London Borough of Lewisham


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SNCI Site of Nature Conservation Importance

SOAC Shadwell Outdoor Activity Centre

SOCC Statement of Community Consultation

S.o.S Secretary of State

SSSI Site of Special Scientific Interest

STW Sewage Treatment Works

SPA Special Protection Area

SSPiPs Site Specific Project Information Papers

SuDS Sustainable Drainage Systems

TBM Tunnel Boring Machine

TA Transport Assessment

TfL Transport for London

TH Trinity House

TTSS Thames Tideway Strategic Study

UDP Unitary Development Plan

UWWTD Urban Waste Water Treatment Directive

WCC Westminster City Council

WRWA Western Riverside Waste Authority


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Foreword

The Thames Tunnel is needed to help substantially reduce the volume of untreated

sewage discharged from Londons Victorian sewers into the River Thames.

Projected population growth and increased urbanisation add to the need for urgentaction to address this problem.

Together with other improvements which are already under way, the Thames Tunnel

will enable us to capture and treat 96% of the untreated flows which currently enter

the River Thames in a typical year. This will provide a major benefit to the health of

the River Thames and increased recreational value to Londoners.

Building the Thames Tunnel will be a major construction project and it is inevitable

that it will cause some disruption to residents and the environment. However, we aredetermined to understand local views and concerns, and to do our best to minimise

any disturbance. This means looking carefully at the sites selected and the design of

our works, at the ways in which we can reduce any impacts, and at the long-term

legacy which we leave behind. The starting point in each case is extensive local

consultation, which we have tried hard to achieve for our phase one proposals.

Since the start of the consultation period we have written to over 173,000 properties

near potential sites and routes, staged 25 exhibitions and attended 60 meetings to

gather feedback on our initial proposals for the project.

We are very grateful to everybody who has taken the time to attend these events

and submit feedback, including via our website. Your input will help us ensure that

the final design is the right one, meeting the aims of the project, while providing best

value for money and keeping disruption to a minimum across the capital.

We have received feedback from 2,869 community respondents in addition to

feedback from technical consultees and landowners. This report summarises those

comments and provides our response to the issues raised.

A further consultation period on our revised plans phase two will be held in

autumn 2011.


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In the meantime we remain committed to working with everyone who is potentially

affected by this project to ensure your views are heard and that the scheme

responds, as far as possible, to your concerns. Although the next phase of formal

consultation will not begin until the autumn, do please get in touch at any time with

comments or questions and we will do our best to help.

Richard Aylard CVO Phil Stride

External Affairs & Head of the LondonSustainability Director Tideway Tunnels


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Section 1 Approach to consultation


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1 Introduction

1.1 The purpose of this report

1.1.1 This report is a record of the phase one consultation on the

Thames Tunnel proposals. The report sets out the process weundertook for carrying out our phase one consultation, provides anoverview of the feedback received, identifies the main issues andconcerns raised, and provides our responses. The supplementaryreport to this report sets out comprehensively and in detail all theissues raised, together with our responses. This report alsodescribes our next steps for the project, including furtherconsultation that will be undertaken.

1.2 The proposed project

1.2.1 The Thames Tunnel (the project) is needed to help substantially

reduce the volume of untreated storm sewage discharged fromLondons Victorian sewers into the River Thames. Projectedpopulation growth and increased urbanisation add to the need forurgent action to address the problem.

1.2.2 The Thames Tunnel will ensure that the UK complies with the EUUrban Waste Water Treatment Directive, and will also assist inmeeting the objectives of the EU Water Framework Directive.

1.2.3 We are proposing to design, build and operate the Thames Tunnelto capture untreated sewage, which can currently flow directly intothe River Thames after as little as 2mm of rainfall. The main tunnelwould be 7.2m in diameter, constructed at a depth of up to 75mbeneath London, broadly following the path of the River Thamesfrom west to east. The tunnel will capture untreated sewage thatcurrently flows directly into the River Thames from combinedsewer overflows (CSOs) along its route. The tunnel will then storethe captured sewage from the CSOs and transport it for treatment,bringing long-term benefits for the environment and people usingthe River Thames.

1.2.4 In broad terms, the project will be designed to ensure that the worstpolluting CSOs in the tidal reach of the River Thames will no longer

frequently discharge into the river following rainfall and that, in atypical year, they would only overflow four times on average,compared with the present average of more than 50 times a year.

1.2.5 The project comprises two main elements:

works to control and intercept untreated sewage from the worstpolluting CSOs and transfer it into the main tunnel

works to build and operate the main tunnel that will provide themajority of the storage capacity and enable transfer ofuntreated sewage to Beckton Sewage Treatment Works in east

London.


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1.2.6 Connection tunnels will also be required to connect interceptedCSOs to the main tunnel. Based on the scheme presented atphase 1 these would be at the following preferred sites: ActonStorm Tanks, Bell Lane Creek, King Georges Park, Druid Street,Earl Pumping Station, Borthwick Wharf and Greenwich Pumping

Station. Other sites that are closer to the line of the main tunnelwould also have shorter connection tunnels. Other minor works arealso required to the existing sewage infrastructure, includingBeckton Sewage Treatment Works. A diagram of the preferredsites and three tunnel routes is included at Appendix A.

1.2.7 Sites are required to undertake the works to intercept the CSOs, toconstruct the tunnel and subsequently to operate the project. Wehave identified five preferred main tunnel drive/reception sites(required to operate the tunnel boring machines) together withpreferred CSO sites for works to enable 21 CSOs to be intercepted

by the tunnel. Where possible, the CSO and drive/reception siteworks have been combined with a total of 2 preferred shaft siteshave been identified.

1.3 Phase one consultation

1.3.1 Before starting our phase one consultation, we consulted with localauthorities and other technical consultees about our strategy for theconsultation. We then formalised our strategy in a Statement ofcommunity consultation, which we published in the EveningStandardon 9 September 2010.

1.3.2 We launched our phase one consultation on 13 September 2010for a period of 14 weeks to 20 December 2010. The decision wassubsequently made to extend this to a total of 18 weeks, and theconsultation closed on 14 January 2011.

1.3.3 The overriding aim of our public consultation was to ensure that allconsultees had a chance to understand and influence ourproposals at an early stage.

1.4 Structure of this report

1.4.1 This report is arranged in six sections, as follows:

1.4.2 Section 1 Approach to consultation Chapter 2 sets out our approach to phase one consultation in

more detail. It contains:

o how approval for the scheme will be sought and theplanning context in which our application is currently beingprepared

o how we have sought to meet the requirements of thePlanning Act 2008 (2008 Act), statutory guidance andpolicy in the development and implementation of phaseone consultation


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o a description of the publicity that was undertaken to spreadawareness of the consultation process and the informationavailable

o the methods of engagement, such as the schedule ofexhibitions and community briefing.

Chapter 3 provides a summary of our method for analysingresponses to the public consultation. It describes:

o how we have analysed the feedback received andresponding to the relevant issues raised

o how we have responded to feedback

o how the method of analysis and structure of this reportreflects the requirements of the 2008 Act and relevantstatutory guidance.

1.4.3 Section 2 Need, solution and tunnel route

Chapters 4 and 5 provide a summary of the feedback receivedon the need for the Thames Tunnel, the proposed solution androute, and identify how the feedback is being taken intoaccount in the development of our proposals.

Chapter 6 provides a summary of the feedback received onother issues raised by respondents which are not covered inany of the other chapters.

1.4.4 Section 3 Site specific issues

Chapters 728 provide a summary of the feedback received oneach of the preferred sites. This sets out information on whoprovided feedback on the preferred and shortlisted sites,summarises the comments made on our preferred sites, andsets out our initial view on the way forward. The chapters alsodescribe in more detail the main issues raised for our preferredsites and our responses to these issues.

Chapter 29 adopts the same format as chapters 7-28 andaddresses the works proposed at Beckton Sewage TreatmentWorks.

1.4.5 Section 4 The consultation process

Chapter 30 provides a summary of comments received inrelation to the phase one consultation process. Findings fromthis process will be used to update ourCommunityConsultation Strategyand the Statement of CommunityConsultation (SOCC). The lessons learnt will be taken forwardto the next phase of consultation.

1.4.6 Section 5 Conclusion

Chapter 31 sets out our conclusions following completion of

phase one consultation. It sets out key findings, changes beingconsidered and further investigations/assessments that will be


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taken forward as a result of the phase one consultation. Thischapter also provides a summary of our next steps, andidentifies lessons learnt for future consultation to beundertaken.

1.4.7 Supplementary report and appendices

Each chapter that contains a summary of the feedbackreceived (chapters 4-30) has a corresponding chapter in thesupplementary report which sets out comprehensively, and indetail, all the feedback received and our response to the issuesraised.

Appendices to this report provide detailed informationregarding the consultation process undertaken.


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2 Approach to consultation

2.1 Objective

2.1.1 As set out in DCLGs Guidance on pre -application consultationdated September 2009 effective public consultation is an importantaspect of the development of major projects prior to the submissionfor planning approval. The early involvement of local communities,local authorities and statutory consultees at this stage can bringabout significant benefits for all parties, such as:

allowing members of the public to influence the way projectsare developed by providing feedback on potential options, andproviding them with an opportunity to shape the way in whichtheir community develops

helping local people better understand what a particular project

means for them, so that concerns resulting frommisunderstandings are resolved early

obtaining important information about the economic, social andenvironmental impacts of a scheme from consultees, thushelping promoters identify project options which are unsuitableand not worth developing further

enabling potential mitigation measures to be considered and, insome cases, built into the project before an application issubmitted

identifying ways in which the project could reasonably assist insupporting wider strategic or local objectives.

2.1.2 Overall, effective pre-application consultation will lead toapplications which are better developed, and in which the importantissues have been articulated and considered as far as possible inadvance of submission to the consent-granting bodies1

2.1.3 We have set out to undertake the public consultation on theThames Tunnel on this basis.

.

2.1.4 The design of the project is engineering-led and driven by arequirement to intercept CSOs to feed into the tunnel at fixed

locations. This means that the selection of the route and the sites ismore constrained than might be the case for other types ofinfrastructure projects.

2.1.5 The overriding aim of our pre-application consultation for thisproject is to ensure that both community and technical consulteeshave a chance to be informed, and to influence the proposals forthe Thames Tunnel. This means that:

the local and strategic impacts and benefits of the projectrelating to river water quality and system capacity are

1Planning Act 2008, Guidance on pre-application consultation, September 2009, DCLG


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explained, in order for all parties to form a clear view of theneed for the Thames Tunnel

members of the public, across the route as a whole and in thevicinity of the sites, are consulted in good time during theevolution of the project, enabling them to have a meaningfulsay and where possible - to influence its development.

2.1.6 All parties, ranging from statutory interests through to business,local communities, harder to reach groups and individual residents,should have good access to high-quality information on the project,communicated at all stages of the planning process and beyond.

2.2 How approval for the scheme will be sought

2.2.1 On 7 September 2010, the Secretary of State for Environment,Food and Rural Affairs made an announcement confirming theGovernments continued support for our plans for a tunnel to

reduce the amount of untreated sewage discharged into the RiverThames. In relation to the planning framework for the project, shenoted:

I am also minded that development consent for the project shouldbe dealt with under the regime for nationally significantinfrastructure projects established by the Planning Act 2008. Iconsider that this project, with its unique scale and complexity, is ofnational significance, and therefore appropriate for this regime. Iwill be considering the appropriate mechanism under the 2008 Actto ensure the Thames Tunnel project is considered under thisnational level regime and intend to include consideration of theThames Tunnel in the draft National Policy Statement for wastewater.

2.2.2 In a further ministerial statement to Parliament on 16 November2010 the Secretary of State said: I intend to bring the tunnel withinthe direct scope of the Planning Act 2008 by amending thethresholds in s.14(3), Part 3 of the Act 2008. I plan to consult onthe draft order early in 2011.

2.2.3 The draft National Policy Statement for Waste Water(NPS), which

the Department for Environment, Food and Rural Affairs (Defra)published in autumn 2010, identifies the need for the ThamesTunnel.

2.2.4 Although the Thames Tunnel has not yet been brought within thedirect scope of the 2008 Planning Act, the phase one consultationprocess has been designed to meet the requirements of the 2008Act and local and central government policy and guidance,including local authorities statements of community involvement(SCIs). This approach is outlined in ourCommunity ConsultationStrategyand SOCC. Our approach to consultation is thereforesufficient to support either a development consent order application

to the Infrastructure Planning Commission (IPC) or its successor,or a series of planning applications submitted to the relevant local


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planning authorities under the Town and Country Planning Act1990.

2.2.5 The 2008 Act introduced duties to consult, which apply where aperson proposes to make an application for a development consentorder (s.42 and s.47). The legislation provides for guidance to beissued relating to this consultation process.

2.2.6 In anticipation that the project will be designated as a nationallysignificant infrastructure project within the 2008 Act, we have setout to consult as if the 2008 Act requirements applied. Ourapproach is consistent with the guidance on pre-applicationconsultation issued in September 2009 by the Department forCommunities and Local Government (DCLG) and the IPCGuidance Note 1 on pre-application stages (March 2010). We areensuring that the approach to consultation responds to theguidance set out at paragraph 8 of the IPCs Guidance Note as

follows:

the overriding intention of the legislation is to ensure that detailedmatters are consulted upon and solutions or mitigation negotiatedwith the local community, landowners, statutory consultees andlocal authorities before submission of the application fordevelopment consent to the IPC.

2.2.7 If our application is dealt with under the 2008 Act, the IPC or itssuccessor as examining authority will be responsible for examiningthe proposals and will either determine the application itself ormake recommendations to the Secretary of State as to how it

should be determined.

2.3 Report on consultation

2.3.1 Section 37(3)(c) of the 2008 Act states that an application fordevelopment consent must be accompanied by a consultationreport.

2.3.2 Guidance provided by the IPC states that the report should drawtogether2

an account of the statutory consultation, publicity, deadlinesset, and community consultation activities undertaken by theapplicant at the pre-application stage

:

a summary of the relevant responses to the separate strands ofconsultation

the account taken of responses in developing the applicationfrom proposed to final form.

2.3.3 This report on phase one consultation is intended to form anappendix to the full consultation report which will accompany our

2IPC (2009), IPC Guidance Note 2 on Preparation of Planning Documents under S37 of the

Planning Act 2008


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planning applications or development consent order application forthe Thames Tunnel in due course.

2.4 Our strategy for undertaking consultation

2.4.1 In developing ourCommunity Consultation Strategy, we took into

account the requirements of the 2008 Act, relevant subordinatelegislation3

2.4.2 Consultation is also an important element of our site selection

methodology

and guidance including the above mentioned IPC andDCLG guidance and Planning Policy Statement 12(PPS12). Ourapproach to consultation is informed by our experience of previouspublic and stakeholder engagement programmes for majordevelopment projects, our knowledge of and discussions with thevarious London local authorities likely to be affected by thedevelopment of the proposed Thames Tunnel, and by legalrequirements and best practice.

4

2.4.3 The Community Consultation Strategy

, which sets out how we have made decisions aboutwhich sites we consider are appropriate, taking into account arange of engineering, planning, environmental, community andproperty considerations. As part of the site selection methodology,any feedback received on the sites and other matters which wehave consulted on will be considered and, where appropriate,having regard to technical considerations, will help to decide onthose sites we select for the project.

5

2.4.4 We have adopted a multistage consultation process. This reportsets out the feedback received and our responses to the first stage.Our proposals will be the subject of further consultation, prior to theapplication(s) being submitted during 2012.

and SOCC set out theintended consultation approach and strategy. The SOCC (includedat Appendix B) was published on 9 September 2010, consistentwith s.47 (7) of the 2008 Act. The preparation of this documentfollowed the development of a community strategy alongside oursite selection methodology. We undertook two rounds ofconsultation with stakeholders (September 2008 and April 2009)before the Community Consultation Strategywas adopted andmade available on our website from May 2009.

2.5 What we consulted on

2.5.1 During phase one, we have consulted on:

the need for the Thames Tunnel to reduce the amount ofuntreated sewage overflowing into the River Thames fromLondons Victorian sewers

the alternatives to a tunnel solution

3Infrastructure Planning (Applications: Prescribed Forms and Procedure) Regulations 2009

and the Infrastructure Planning (Environmental Impact Assessment) Regulations 20094Thames Water (2009) Site Selection Methodology Paper

5Thames Tunnel Community Consultation Strategy (100-RG-PNC-00000-900032)


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the conclusions of our work so far to establish our preferredscheme, consisting of a series of sites (the preferred sites), aroute (the preferred route) and also the other shortlisted sitesand routes considered

engineering, environmental, community, planning and propertyissues that were identified and considered during our siteselection work for the preferred sites and preferred routepresented at phase one

our initial ideas on the permanent structures and use of eachpreferred site after construction work is complete.

2.6 Who we consulted

2.6.1 We consulted:

Community consultees, including the general public, local

property owners/occupiers, local businesses, communityrepresentatives and groups, including hard-to-reach groups.

Technical consultees, including local authorities, other statutoryconsultees, utilities and pan-London strategic stakeholders.

Landowners including property owners and lessees of the shortlisted sites, and occupiers of properties above and adjacent tothe potential tunnel routes.

Community consultees

2.6.2 We have defined community consultees so as to include the ward

councillors, the local MP and MEPs and other communityrepresentatives, individuals or organisations that formally orinformally represent local interests including, but not exclusively:

individuals, owners/occupiers, businesses and groups based,or living, in the vicinity of (but not on) each site

individuals, owners/occupiers, businesses and groups who liveor work further away, but have, or represent, an interest in agiven site

local people living nearby, using or overlooking a given site

local environmental groups

voluntary organisations (including residents associations andblack and minority ethnic support groups);

faith communities

schools and colleges in the immediate vicinity

local hospitals, care homes and private healthcareorganisations in the immediate vicinity.

2.6.3 We carried out community audits prior to the commencement of our

phase one consultation to identify all those groups noted abovewith a potential interest in a site. The audits were carried out in


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liaison with local authorities to identify local community and hard toreach groups.

2.6.4 To define the area within which we would notify people that phaseone consultation was being undertaken we used a minimumdistance of approximately 250m from the boundary of eachpreferred and shortlisted site and a broad corridor of the potentialtunnel routes as a benchmark. We consulted with local authoritieswhen developing our SOCC to seek agreement that the boundarieswere appropriate. The boundary was applied flexibly according tothe scale and nature of the proposed works and taking into accountthe characteristics of the surrounding area. The publicity methodsused are set out in more detail in Section 2.7.

Technical consultees

2.6.5 In addition to the community, we targeted the technical consultees,

defined as local authorities, the GLA and other statutory consulteesas listed in Appendix C.

Landowners

2.6.6 In parallel to our community consultation, we also consultedlandowners including property owners, lessees, tenants and thosewith a property interest in the land subject to our proposals,together with occupiers of properties above and adjacent to thepotential tunnel routes. These parties are referred to aslandowners for the purpose of this report. These landowners wereidentified from a land registry search of the sites concerned. We

have adopted a practical approach to landowners, directlyconsulting those owners of preferred and shortlisted sites on thepreferred route. We have not notified all those with an interest inthe land under the three tunnel routes at this stage, as the tunnelalignment is still at the early options stage. We will, however,directly consult all landowners under the preferred tunnel routeduring future consultation.

2.7 How we undertook the consultation

2.7.1 Pre-briefing of local authorities and other stakeholders took place

prior to our formal launch. The formal phase one consultation wasundertaken between 13 September 2010 and 14 January 2011.The deadline for feedback was extended by four weeks from theoriginal date to maximise the opportunity for everybody to let usknow their views.

Publicity

2.7.2 We publicised the phase one consultation through a range ofmedia and public awareness initiatives.

2.7.3 TheSOCC was published in the Evening Standard on 9 September2010. Advertisements were also placed in local newspapers


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regarding specific exhibition dates. The publications andadvertisement dates are set out in full at Appendix D.

2.7.4 Consultation letters and information totalling 162,926 in numberwere posted by Royal Mail on 10 September 2010 to members ofthe public, providing information about the project and invitingattendance at public exhibitions. Three hundred and eighty-oneletters were also sent to landowners with 437 letters issued totechnical consultees. Additional letters were sent to residents andinterested parties to advise of an additional exhibition in relation toBarn Elms (9,932) on 3 December 2010 and to the residents of theWorlds End estate (2,938) on 7 January 2011.

2.7.5 This written information consisted of two items:

a letter giving details of the public exhibitions to be held in thevicinity of each of the preferred sites

a more detailed leaflet, providing background information onthe project as a whole, to give additional context for theproposed construction work.

2.7.6 Both the invitation and leaflet provided details of the helpline andwebsite which the public could use to access further informationand provide feedback.

2.7.7 Appendix E contains a table setting out the ways we invited ourconsultees to take part in the process and a copy of the letters sentto the different respondent groups.

2.7.8 We worked with personnel at the London local authorities and othertechnical consultees to ensure information on the consultationwould be available in the local publications and on their websites.We also sent the consultation material to libraries and localauthority offices.

2.7.9 Following a number of reports that our letters had not beenreceived, an investigation was carried out. This revealed an error inthe correct identification of relevant post code data, which we verymuch regret. We corrected this and ensured that all residents had aproper opportunity to participate fully in our consultation, which wecontinued to promote through various activities until it closed. This

included sending out additional letters (9,652) to everyone who wasidentified as having been omitted the first time around.

2.7.10 The following sections set out the different methods we used toundertake phase one consultation.

Consultation website

2.7.11 At the start of phase one consultation, we launched a dedicatedconsultation website (www.thamestunnelconsultation.co.uk) whichprovided information on the project and formed a dedicated pointfor comments and feedback. Paper feedback forms were also

available for those that needed them.
http://www.thamestunnelconsultation.co.uk/http://www.thamestunnelconsultation.co.uk/


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2.7.12 The website presents information on the preferred tunnel route andeach of the preferred sites, as well as the alternative tunnel routesand shortlisted sites previously considered. It includes aninteractive map, designed to help members of the public identifythe sites of most interest to them.

2.7.13 Our website seeks to meet best practice standards in terms ofaccessibility and usability. Pages are devoted to the pre-applicationprocess, exhibition dates, information on the preferred sites and theproject timetable. All information available at the exhibitions is alsoavailable online.

2.7.14 A frequently asked questions section was added to the website asquestions were raised, also a latest news section, detailing theprogress of the consultation, the events and exhibitions. Thewebsite remains a live resource and will be updated as theconsultation process moves to the next phase.

2.7.15 Unfortunately, we experienced a temporary technical issue with ourwebsite, (16:30 on 12/01/2011 until 09:00 on 13/01/2011) whichwas rectified. We contacted all those known to be affected (63respondents) and worked with them to ensure their consultationfeedback was successfully submitted.

Community briefings

2.7.16 For each of the preferred construction sites, we consulted localauthorities on our initial draft of the community audits, sought theirinput and developed the audits further before consultation

commenced. The methodology for undertaking the audits and thegroups identified are listed at Appendix F. We used the communityaudits to identify the individuals who will be invited to the briefingsessions, together with input from the relevant local authorityofficers.

2.7.17 We combined the community briefings with a private view of thepublic exhibitions prior to them opening to the wider public. The aimof these briefings was to ensure that community representatives,both formal and informal, understood our proposals and had asuitable level of information on the project to enable them to pass

on factual information to interested members of the localcommunity, and help to ensure they were accurately informed. Thebriefings were also aimed at explaining the project to communityrepresentatives at an early stage, in recognition that they mayreceive a number of enquiries about the project from localresidents.

2.7.18 We also responded to requests to attend meetings with localorganisations and community groups. A list of meetings weattended can be found in Appendix G.

Provision of written information

2.7.19 We provided a range of written information in the form of generalbriefing notes to support the consultation, which were available at


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the public exhibitions, online and at local libraries and town halls.Refer to Appendix H for a full list of locations.

2.7.20 We produced general project information papers (PiPs), whichcovered the following topics:

Table 2.1 Project information papers (PiPs)

PiP topic PiP content

Build How we will build the Thames Tunnel andwhat sort of worksites we will need.

Construction sites How we chose our sites.

Depth How deep the tunnel will be and settlementeffects.

Environment This paper sets out all the environmentalstudies we have to carry out.

Funding How much the Thames Tunnel will cost,who will pay and the impact on bills.

Land How we plan to restore and protect the landwe use.

Managingconstruction

How we will manage the construction toreduce disruption.

Odour How we will make sure the tunnel will notsmell.

Options The other options we considered to reduce

sewage overflowing into the River Thames.Overflow Why the sewers overflow to the River

Thames.

Regulatoryframework

The other organisations that have a role inthe need and delivery of the ThamesTunnel.

Routes The different route options for the ThamesTunnel.

Timing Current timetable for the completion of theproject.

Transport How we plan to use barges on the riverwhere feasible.

Views Why we are consulting and how important itis that consultees provide feedback.

2.7.21 Site specific project information papers (SSPiPs) on each preferredsite included:

the significance of the site in relation to the preferred andalternative tunnel routes, and the preferred method for

constructing the tunnel


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provisional justification for initially selecting a site in preferenceto any other potential local sites, and an overview of the outlineproposals for the site

maps and plans to put the sites and their operation in contextwith the local area

images based on architects drawings of potentialabove-ground structures and use of sites after construction ofthe tunnel

drawings showing the potential shaft location, site access andthe operational areas.

2.7.22 The table below lists the sites for which specific briefing informationwas produced:

Table 2.2 Site specific project information papers

(SSPiPs)Abbey Mills Pumping Station Earl Pumping Station

Acton Storm Tanks Greenwich Pumping Station

Albert Embankment Hammersmith Pumping Station

Barn Elms Jews Row

Beckton Sewage TreatmentWorks

King Edward Memorial ParkForeshore

Bell Lane Creek King Georges Park

Blackfriars Bridge Kings Stairs GardensBorthwick Wharf Putney Bridge

Bridges Court Car Park Tideway Walk

Butcher Row Victoria Embankment

Chelsea Embankment Other shortlisted sites

Cremorne Wharf Other works

Druid Street

2.7.23 Other project documents were also available to the public at theexhibitions and via the website.

Table 2.3 Other project documentation

Other project documentation

Site Selection Background Technical Paper

Site Selection Methodology Paper

Statement of Community Consultation and CommunityConsultation Strategy

Needs Report, including appendices

Project Overview


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Programme of public exhibitions

2.7.24 We held public exhibitions in the vicinity of the potentialconstruction sites and these were advertised locally in advance.They were open for up to three consecutive days in each location,

during the day and into the evening. Members of the project team(including representatives from the planning, environment,community, property and engineering disciplines) were available toanswer questions, assist with interpreting materials or completingfeedback forms, and to encourage people to give their views.Additional exhibitions were held from those originally planned at 11venues over 13 days. See Appendix I for the list of exhibitions heldand the numbers in attendance at each exhibition.

2.7.25 We displayed information at each exhibition to inform visitors aboutthe project and the local construction site(s). The information wasthe same as that used for the project and site specific information

papers, and on the consultation website.

2.7.26 Members of the public were encouraged to use our consultationwebsite to register their comments. A paper feedback form wasalso available at the exhibitions and on request. Where requested,respondents were given support to fill in the questionnaire.

Responding to information requests

2.7.27 Where queries were raised in either correspondence or onfeedback forms, we provided individual responses in cases wherewe considered that it would assist the respondents to be able to

respond to phase one consultation. Throughout phase oneconsultation, we responded to over 700 queries. These queriesinformed the content of the FAQs section of the website.

Access for all

2.7.28 We sought to ensure that responding to our consultation wasequally possible for everyone and offered a range of solutions forpeople requiring additional assistance. For example, consultationinformation was available in large print, Braille or audio format uponrequest. Our Customer Centre offered a telephone servicetranslating consultation materials to any language on request. Thisservice was not requested by any customers.

2.7.29 Customers within the consultation area who were identified fromthe Customer Centre database as requiring special services weresent the consultation letter and project leaflet in the appropriateformat: Audio (2 customers), Braille (5 customers) or large print (42customers).

2.7.30 A health and safety audit was carried out on the potential exhibitionvenues to ensure that a suitable balance was struck betweenaccess to the buildings and proximity to the residents wishing to

attend. Staff were in attendance to facilitate access and assist thepublic.


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How feedback could be provided

2.7.31 Feedback was primarily provided through the use of feedbackforms, which were available online and in hard copy (included atAppendix J). In addition, written correspondence was received and

processed on the same basis as the feedback forms such that,where possible, the comments raised were allocated to thequestions in the feedback forms to allow analysis in the same way.


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3 Method for analysis of feedback and developing ourresponse

3.1 Consultation feedback received

3.1.1 We received a total of 2,869 unique responses to phase oneconsultation. Of this total, 408 consultation responses werereceived after the close of the consultation period, although theselate responses have also been considered and analysed.

3.1.2 Tables 3.1 and 3.2 provide a breakdown of feedback receivedduring the consultation period. A detailed explanation of the meansused and type of respondent is set out below.

Table 3.1. Means of feedback

Means of feedbackNumber of unique

respondents

Feedback form (online andpaper)

2,389

Correspondence 480

Petitions 5

- Kings Stairs Garden ActionGroup (5,274 signatories)

- Cremorne Gardens (251signatories)

- Stop the Shaft Putney &Barnes (5,013 signatories)

- Millennium QuaysResidents Association (104signatories)

- Cheyne Walk Trust (683signatories)

Table 3.2. Respondent Type

Respondent typeNumber of unique

respondents

Community 2,815

Technical consultees 30

Landowners 24

3.2 How consultation feedback has been analysed

Feedback forms

3.2.1 Feedback forms have been received online, via our dedicated

consultation website, and in hard copy. Responses received online


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and via hard copy have been analysed together, using an identicalmethod.

3.2.2 The design of the phase one feedback form provides theopportunity for both qualitative and quantitative analysis ofresponses, with responses saved in a single database. Eachfeedback form has been logged and given a unique reference.

3.2.3 In terms of the qualitative analysis of data, each feedback form hasbeen analysed to identify key issues and themes, drawing out awide range of comments relating to issues such as the need for theproject, the proposed solution, site selection process, site specificissues and potential impacts the proposed solution may have,including both positive and negative comments. In order to identifykey themes emerging from the qualitative analysis, three distinctsections of the database were developed, relating to the followingparts of the feedback form:

Part 1: Need, solution and route

Part 2: Site-specific issues

Part 3: Consultation process.

3.2.4 Each individual relevant issue has been recorded, with a uniquereference of the respondent recorded against the issue raised.Where similar issues were raised by multiple respondents, relevantissues were consolidated, with each of the unique referencesrecorded against the consolidated issue. This approach hasallowed us to systematically identify the issues raised by

respondents and the volume of feedback against each issue.

3.2.5 Each chapter of this report that contains a summary of thefeedback received (chapters 4-30) has a corresponding chapterwithin the supplementary report which sets out comprehensively,and in detail, all the feedback received and our response to theissues raised. The chapters within the supplementary report showwhere issues were grouped and consolidated for each of the threeparts of the database set out above. A count of respondents perissue is also provided.

3.2.6 The online feedback form allowed respondents to update and

submit their feedback form as many times as they wished, whilemaintaining the same unique ID. To ensure our analysis was notskewed by multiple submissions from a single respondent, anyadditional feedback received from the same respondent wasallocated the same ID. Our analysis is therefore based on thenumber of unique respondents rather than the amount of feedbacksubmitted.

3.2.7 The feedback form encouraged respondents to provide detailedcomments and statements that are of significant value to thepre-application stage and the process of design evolution. Our

analysis therefore has concentrated on the qualitative aspects ofthe responses. Quantitative analysis can, however, provide an


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indication of the strength of feeling on particular elements of theproposals that can be placed in the context of other considerations,including the views of technical consultees.

3.2.8 Appendix K identifies the feedback form questions that have beenquantified, the reason for their selection and the categories ofresponse used. The outcome of this process is described in therelevant site specific chapters in sections 2 and 3 of this report.

Correspondence

3.2.9 In addition to use of the feedback forms, feedback was alsoreceived via general correspondence by email or post. On receiptof feedback via this method, responses were sorted and thoserelated to the project were logged with a unique reference number.Responses were sorted according to the respondent type by thefollowing categories:

Community

Technical consultees

Landowners

Petitions.

3.2.10 Correspondence was analysed as being from a landowner, wherethat landowner or their representative confirmed that they wereresponding in that capacity, or where research indicated that theywere landowners. It was less clear from the feedback forms if therespondent was a landowner since the form was rarely annotatedwith any information on status. Where the feedback form wasannotated or research indicated the respondent was a landowner,the feedback forms were analysed as such. In cases where it wasunclear whether the respondent was a landowner and this couldnot be verified by further research, they were analysed ascommunity.

3.2.11 We analysed correspondence from the community against thefeedback form questions. This approach ensured continuity whencomparing feedback received, and enabled efficient analysis ofissues. The analysis of community feedback has resulted in

consolidating common responses made to questions, and ourresponses were developed accordingly.

3.2.12 In relation to feedback received from technical consultees andlandowners, which were more technical in nature, an alternativemethod was developed. Rather than analysing technical feedbackagainst the specific questions in the feedback form, we identifiedthe themes and issues raised by the respondent to allow in-depthanalysis of technical issues. Additional comments outside theseissues were also collated and analysed. Quantitative analysis wasnot undertaken.

3.2.13 At a number of sites, standard letters were utilised by residents soa number of shared points were submitted. As these were posted


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as individual letters and, in many cases, substantially customised,they have all been regarded as community correspondence andrecorded and analysed on this basis.

Petitions

3.2.14 A number of signed petitions have been sent to us, expressingviews on our proposals. We have identified the key issues raisedby each petition and, along with the number of signatories; theseissues are reported in the relevant section of this report andsupplementary report chapter. In most instances, signed petitionsare site specific, and these are therefore presented in the relevantsite chapter and supplementary report chapter.

3.3 Developing our responses

3.3.1 This report includes our responses to the issues raised by

respondents during phase one consultation. In Section 3.2 of thischapter, we identify how community responses have beenanalysed, with common themes consolidated. We also explain theprocess for analysing and identifying key themes arising fromtechnical consultees and landowners. Following the identification ofthese key themes and issues, we have undertaken further analysisto identify how these might influence the development of theproposed scheme. This has involved the five disciplines engineering, planning, environment, property and community reviewing the key themes and issues, and evaluating their impacton our proposals and how they could respond to them.

3.3.2 Taking each of the issues into account, this report and thesupplementary report set out how we are looking at ways in whichwe can reduce the effects identified or, where our proposals remainas originally presented, justification for this outcome.

3.3.3 We have always recognised the importance of introducingmeasures to reduce the effects of our proposals, and the feedbackreceived will help guide this further work. For the purposes of thisreport, mitigation/reducing the effects of our works is treated asincluding measures for design development, further environmentalassessments or amendments to the approach which change the

nature or extent of the works.3.3.4 Where changes or mitigation are proposed, design work will

continue following publication of this report. Phase two ofconsultation in autumn 2011 will contain the output from ourcontinued design work, including our proposed mitigationmeasures.

3.4 Presentation of findings

3.4.1 This report provides a summary of the main issues arising from ouranalysis of phase one feedback. The structure of this report and

the method of presenting findings have been developed byreference to guidance prepared by the IPC and DCLG relating to


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the content of the consultation report required by section 37(3)(c)of the 2008 Act.

3.4.2 Paragraph 13 of the IPC Guidance Note 2 on Preparation ofApplication Documents under S.37 of the Planning Act 2008, inparticular, provides guidance on how feedback received should bepresented in the consultation report. Paragraph 13 recommendsthat consultation responses should be listed by statutoryconsultees (under s42 and Sch 1 of the APFP), local authorities,landowners and then local community consultation responses.

3.4.3 At the start of each chapter contained within sections 24 of thisreport, the source of the feedback and number of respondents isidentified by the groups described above. We considered that itwas more appropriate to present feedback from the differentrespondent groups thematically (for example, by each of thepreferred sites or by need for the tunnel) rather than cover each of

these topics under each respondent group separately.

3.4.4 Chapters 4 and 5 provide an overview of the main issues raised inrelation to the need for the project, the tunnel as an appropriatesolution, other solutions considered, and the tunnel route and ourresponse to these issues. It also sets out which [technology and]route we propose to take forward to the next stage.

3.4.5 Chapter 6 sets out the main issues that have been raised inresponse to Question 6 of Part 1 of the feedback form and also anyother issues that have been raised by technical consultees andlandowners. Our response to these issues is also provided.

3.4.6 The site chapters (7-29) set out the main issues raised for thepreferred sites only, the feedback for the shortlisted sites iscovered in the related chapter in the supplementary report.

3.4.7 We set out our initial view of the way forward, which addresses ourintentions for the preferred site, including how the design of the siteis to be taken forward, in the light of comments received duringPhase 1 consultation. In some cases, this includes the investigationof alternative sites and, where possible, alternative technicalsolutions.

3.4.8 A summary of the main issues received in relation to the site arealso presented. These are divided into two sections, as follows:

i Future work to address the issues that you raised

ii Issues which have not led to a change in our proposals

3.4.9 Within each of these two sections, feedback is divided betweenthose that relate to the site selection and construction phase, andthose that relate to the completed works in operation. The issuescontained within these two sections are a summary of the moredetailed issues and responses provided in the supplementaryreport.


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3.4.10 The approach adopted is adapted from the approachrecommended in IPC guidance for the consultation report, whichsuggests issues are divided between those that directly result in achange, those that result in mitigation and those that result in nochange. The two part structure adopted more accurately reflects

the multistage consultation process and the stage that has beenreached in the design process. The section entitled our initial viewof the way forward identifies any changes that are being explored,which are as a result of all the feedback received rather than aparticular issue raised. The section entitled future work to addressthe issues that you raised addresses any issues where we arelooking at ways in which we can reduce the effects identified whichinclude those issues which have influenced any changes we areconsidering.

3.4.11 Chapter 30 summarises the feedback which has been received in

relation to the consultation process undertaken for phase one, ourresponse to the issues raised and, where appropriate, how weintend to amend ourCommunity Consultation Strategyand SOCCin light of the comments received.

3.4.12 A full record of the feedback received and our response is set outin the supplementary report. Within the supplementary report,separate chapters are provided for issues raised relating to theneed for the project, alternative solutions and the consultationprocess generally. The chapters within the supplementary reportwhich relate to the sites (7-29) also set out the feedback receivedfor preferred and shortlisted sites. A chapter is also provided for

feedback received on other shortlisted sites and other works.

3.4.13 The format of the site chapters within the supplementary report areas follows. The feedback from the different respondent groups ispresented in a table format. The tables also show how issues havebeen grouped together to form consolidated issues. The number ofrespondents who have raised the issue is also set out and aresponse to the issue is provided.

3.4.14 For each site, the issues that have been identified are dividedbetween those that relate to site selection and construction phaseand after use and operation. Under each heading, the commentsreceived are divided between supportive and general commentsand issues. The issues under the site selection and constructionphase heading have been grouped into themes as follows:

Open space and recreation

Natural environment

Built environment

Transport and access

Heritage

Property values


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Other.

3.4.15 The issues raised under after use and operation have beengrouped into themes as follows:

After use proposals

Design of operational buildings

Operational impacts.

3.4.16 Each site chapter concludes with the details of alternative siteswhich have been suggested.

3.4.17 Consultation feedback has also been categorised based on ourresponse to the issue raised. A column in the table entitledoutcome confirms whether, as a result of the issue:

i Future work to address the issues that you raised (M)

ii Issues which have not led to a change in our proposals (N)


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Section 2 Need, solution and tunnel route


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4 The need for the tunnel

4.1 The need to significantly reduce the amount ofsewage entering the River Thames

Your views

4.1.1 Feedback from the community, technical consultees andlandowners indicated that the majority of respondents weresupportive of the need for the project. Nearly a quarter ofrespondents were unclear or opposed/concerned.

Table 4.1 Feedback results

SupportiveOpposed/concerned

Unclear/no view

expressed

Number ofcommunityrespondents

1,661 plus two petitions(104 and 683 signatories)

70 450

Number oflandownerrespondents

Nine landowners None None

Technicalconsultees

London Councils (LC),London Assembly (LA),Environment Agency (EA),

English Heritage (EH),Consumer Council forWater (CC Water), Port ofLondon Authority (PLA),Greater London Authority(GLA), Corporation of Cityof London (CoL),LB of Newham (LBN),LB of Lewisham (LBLew),LB of Tower Hamlets(LBTH), LB Southwark

(LBS)

RoyalBorough ofKensington

and Chelsea(RBKC)

LondonBorough ofWandsworth

(LBW )

4.1.2 The main comments received in support of the project included thefollowing:

London needs to reduce the amount of untreated sewagedischarged into the River Thames because it is polluting andunacceptable; the reduction is needed to improve quality of lifeand Londons image, and to support the local economy. Theconstruction of the tunnel should be undertaken as soon aspossible.


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Investment in the infrastructure is essential because Londonssewer system is outdated and a new system is needed forpresent and future generations.

There are environmental and recreation benefits associatedwith reducing the amounts of untreated sewage.

4.1.3 The main concerns raised about the need for the project included:

the need for the project requires further explanation and it isunclear whether the project is essential

further clarity is needed on whether the project is a priority andwhether by prioritising other infrastructure works, the sameobjectives for reducing the amount of sewage entering theRiver Thames could be achieved

although there was support in principle for the project, there

were a number of concerns with the proposed solution relatingto cost, scale, duration of construction works, impacts on theenvironment and impacts on the amenity of residents.

Response to the issues that you raised

4.1.4 We received a number of comments concerning the need for theproject. The main issues raised and our responses are summarisedin the table below. A full list of the comments and issues received,and our detailed response, are provided in table format at ChapterA-2 of the supplementary report.

Table 4.2 Main issues and responses

Issue Our response

a. The need for the project requiresfurther explanation. Is the projectessential or just a wish list project?(community)

The project is needed to reduce theamount of sewage entering the RiverThames and to comply with the UrbanWaste Water Treatment Directive(UWWTD) and the Water FrameworkDirective (WFD). We believe that theneed for the project has been clearlydemonstrated in the phase oneconsultation material, particularly the

Needs Report.The Government hasalso indicated its support for this projectand has proposed that it should bedesignated a Nationally SignificantInfrastructure Project (NSIP). The draftWaste Water National Policy Statementpublished in November 2010 sets outGovernment policy (in draft form) forthe provision of major waste waterinfrastructure, and assumes the futuredesignation of the Thames Tunnel as aNSIP.


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Issue Our response

Given the legal requirements and theenvironmental benefits of the project,we consider that it is essential and nota wish list project. We consider that

the objective of improving river waterquality can only be met cost-effectivelythrough improvements to sewagetreatment works (where work is alreadyunderway) and through the provision ofthe Thames Tunnel.

b. Is the project needed, given thatthere are already improvements inriver quality and it is not evident thatthere is a pollution problem? The

frequency of overflows and volumeof sewage released into the river islow (community)

The frequency of discharge can beonce a week and the annual volumecan is around 39 million cubic metres inthe Beckton and Crossness

catchments. Although river quality hasimproved as a result of previousinvestment, there is still a need toreduce the discharge of untreatedsewage to allow for furtherimprovements to river quality and tocomply with legislation.

c. Leakage and flooding, sewerimprovements and upgrades shouldbe a higher priority. There is a riskthat the cost of the tunnel could be

at the expense of otherimprovement works (community)

We give high priority to leakage ofclean water and preventing rainwaterflooding e.g. Victoria Mains programmeand sewage treatment works

extensions. The existing sewers inLondon are generally in good physicalcondition but their capacity isinadequate. There is no risk that thatthe cost of the tunnel would be at theexpense of other improvement works.

d. Some respondents agree inprinciple with the aim to reduce theamount of untreated sewage,although have a number ofconcerns with the proposed solution

relating to cost, scale, duration ofconstruction works, impacts on theenvironment and impacts on theamenity of residents (community)

We recognise that there will be somedisruption as a result of construction.However, this has to be balancedagainst the considerable overallbenefits that will arise from a cleaner

River Thames and the need to reducethe amount of sewage discharged intothe River Thames to ensurecompliance with the UWWTD. We willbe working closely with the localboroughs and the community tominimise any disruption caused duringconstruction.


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4.2 The tunnel as the right solution

Your views

4.2.1 We also sought views on what is the most appropriate solution forreducing the amount of sewage entering the River Thames. We

presented four possible solutions: Sustainable urban drainagesystem, separation of the sewage system, use of bubblers andskimmers and a storage and transfer tunnel (our preferredsolution).

4.2.2 The table below sets out the feedback received on the tunnel asthe right solution.

Table 4.3 Feedback results

Agree DisasgreeUnclear/no view

expressedNumber ofcommunityrespondents

922 plus two petition (104and 683 signatories)

248 736

Number oflandownerrespondents

Seven landowners None None

Technicalconsultees

London Councils (LC),London Assembly (LA),Environment Agency (EA),English Heritage (EH), Portof London Authority (PLA),Greater London Authority(GLA), Corporation of Cityof London (CoL), LB ofTower Hamlets (LBTH), LBof Newham (LBN), LB ofLewisham (LBLew),

RoyalBorough ofKensingtonand Chelsea(RBKC)

ConsumerCouncil forWater (CCWater)

4.2.3 The main supportive and general comments received in relation towhether the tunnel was the right solution included:

a tunnel is the most practical, sound and reasonable solution

a tunnel is less disruptive than installing a separate sewagesystem across London

a tunnel is the most cost-effective solution

a tunnel is the best solution from an aesthetic point of view,since it is least intrusive

agree in principle with a tunnel as the right solution for theneed, subject to caveats including use of open andconstruction impacts should be minimised.


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4.2.4 The main concerns raised in relation to whether the tunnel was theright solution included:

the cost of the project is considered excessive and-costeffectiveness has not been demonstrated

there will be adverse environmental and amenity effects duringthe construction of the project.

Response to the issues that you raised

4.2.5 We received a number of comments concerning the tunnel as asolution. The main issues raised and our responses aresummarised in the table below. A full list of the comments andissues received, and our detailed response, are provided in tableformat at Chapter A-2 of the supplementary report.

Table 4.4 Tunnel solution response to issues

Issue Our responsea. The cost of the project is

excessive and there areconcerns about cost overruns.Could the cost be reduced(community, CC water, LC,LBW)

OurNeeds Reportshows that the costof the tunnel is the lowest cost optionrelative to alternatives of separatesewers and SuDS. It has beenconfirmed by the Secretary of State thatthe Tunnel is the cheapest solution byfar. We will explore ways to minimisethe cost of the project to offer value toour customers through the design,construction and operation of thetunnel.

b. The cost of the project fallsunfairly on the customer andsome customers cannot affordhigher bills (community, RBKC,LC, LA, LBW, CC water)

We estimate the total cost of buildingthe tunnel to be 3.6 billion and thatthis will require average bills to rise byslightly more than 1 a week by 2018.This means that the bills of ourcustomers, which have for many yearsbeen among the lowest in the country,would rise to around the nationalaverage. The Thames Water Trust

Fund is able to help customers infinancial difficulty or hardship.

c. The balance of the cost andbenefits of the project has notbeen adequately demonstratedand further details of the costsand benefits should have beenprovided. Other options for thetunnel have not been properlytested (community, CCwater,RBKC)

A comprehensive cost-benefit analysishas been undertaken which shows thata storage and transfer tunnel option,combined with improvements tosewage treatment works, has thehighest net benefit. This work wastaken into account in preparing theMinisterial Statement of March 2007,where we were requested to develop

the tunnel solution. Our work has beenclosely scrutinised by our industry


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Issue Our response

regulator (Ofwat) and by Defra. Wehave examined the cost of alternativetunnel routes and alternative solutionswithin the Needs Reportand this

confirms that the Abbey Mills tunneloption is the most cost-effectivesolution.

d. The design of the project shouldbe revised, reappraised orexplained further, for example,with respect to ensuring it isfuture proofed (to meet thedemands of climate change),permanent proposals are ofsufficient build quality, it

minimises the number ofshafts/above ground structuresand is a sustainable solution(minimising energy demand)(community, GLA, LBW)

Population growth and climate changehave been taken into account in thedesign of the tunnel. There is moredetailed design work to be completedon our permanent design proposals,which will be presented as part of ourphase two consultation. We will beexamining options for reducing the

number of above ground structuresrequired (for example, throughalternative ventilation strategies) andwill be undertaking further work toexamine ways of reducing carbon (forexample, by using recycled materials inthe construction of the tunnel). We arecarrying out further work in relation tothe sustainability of our proposals.

e. Ensure the protection of and

minimise the impact on heritagefeatures and ecological habitatsthrough high-quality design andappropriate mitigation solutions(EH, NE)

High-quality sympathetic design

solutions are being developed inconsultation with local authorities andother stakeholders, such as EH and theEA. Opportunities to enhance ecologythrough design of structures are beingexplored and we are taking intoaccount heritage considerations andprotected views across London.

f. The construction phase of theproject should be revised,reappraised or explained further.

Concerns raised about thelength of the construction periodand potential impacts, such assubsidence and traffic(community, GLA, LBW, LBN,LBTH)

The length of the construction periodset out in the consultation documents isa maximum period and it is possible

that in many cases it will be shorter; forinstance, there will be periods when noactivity is taking place within sites.Further studies are to be carried out aspart of the development of detaileddesigns, including an assessment ofthe potential for subsidence. We willalso be carrying out an assessment, aspart of the Environmental ImpactAssessment and TransportAssessment, of the effects of the

project on the environment, includingtraffic related effects, and will develop


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Issue Our response

measures to minimise any effects inconjunction with local authorities andother stakeholders.

g. Use of river for transport of

construction materials must bemaximised (community, PLA,GLA, LC, LBN, LBW)

It is our intention to use the river for the

removal of excavated materials asmuch as possible and where practicaland cost-effective to do so.

h. There is no justification for thedetrimental effects of the projecton the environment and onamenity. The balance betweencost and damage to theenvironment is not correct(community, GLA, EA, CCwater)

There will be significant environmentaland amenity benefits from a cleanerRiver Thames once the project iscompleted. Nevertheless, we recognisethat there will be some impacts, whichwill largely be temporary, on theenvironment and amenity duringconstruction. The potentialenvironmental impacts of the projectare to be fully assessed alongside thepreparation of a detailed design and wewill identify measures to ensure thatany impacts on the environment and onpeople living near to the constructionsites are minimised.

i. The project will have an impacton property values (community)

Thames Water is preparing proposalsfor addressing compensation and thiswill be subject to consultation during

2011, before its introduction in 2012. j. The project will impact on thewildlife of the foreshore andfishery interests, and couldaffect the water and sedimentpatterns in the Thames Estuary.Navigation could also beaffected during construction (EA,NE, MMO, GLA)

Where possible, we have aimed tolocate proposed construction sites onland and avoid locating sites within theRiver Thames. In a small number ofcases, it was not feasible to identify asuitable land-based site in proximity tothe existing sewer network. Whereworks are required on the foreshore,we have sought to minimise the amountof land taken from the foreshore. A

comprehensive assessment of aquaticecology will be carried out to considerthe potential for impacts on fish,invertebrates, algae, mammals andriver dependent habitats, and we willalso examine the effects of scour andsediment. We will consult with therelevant stakeholders on ways to avoid,minimise or reduce impacts on theRiver Thames and its habitats, andwork with the PLA on navigational

safety issues.


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4.3 Alternative solutions to a tunnel

4.3.1 The pie chart below illustrates the number of communityrespondents who supported each of the alternative solutions to thetunnel.

Figure 4.1 Support for alternative solutions

4.3.2 The table below provides a summary of the main commentsreceived in relation to the alternative solutions. A full list of thecomments and issues received, and our detailed response, areprovided in table format at Chapter A-2 of the supplementaryreport.

Table 4.5 Alternative solutions main comments received

Technology Comments

Sustainable urbandrainage systems

(SUDS)

Respondents thought SUDS would bebeneficial:

as an alternative to the project in combination with the project

in combination with a separatesewage system.

Separate sewagesystem

Comments received in support ofseparate sewers included:

it is the preferred solution because itaddresses the problem at source

it should be used in combinationwith SUDS

built in parts, each element would

operate as soon as part of it wasbuilt, unlike the tunnel, which only

83

75

17

SuDS

Seperate Sewers

Bubblers and Skimmers


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Technology Comments

makes an impact once the wholeproject is complete

although this solution would cost

much more, the Government shouldassist in funding this option ratherthan relying entirely on ThamesWater customers.

Bubblers and skimmers Appears to have been dismissed byThames Water and yet wouldprovide a workable and cheapersolution, compared with disruptionand cost of a tunnel

There is a continuing need toremove flotsam and jetsam from the

river.A range of measuresshould be employed tomeet the water qualityobjective, rather thanrelying on the tunnelalone

Reasons for this approach included:

use the suggested alternatives incombination as appropriate

look at a wider range than thesuggested alternatives, including:

o a pipe laid on the bed of theRiver Thames

o greener solutions, eg, fittingflats with biogas/biowaste

disposal unitso reduce the waste at source

rather than dealing with itseffects.

Complementarymeasures should beimplemented for widerenvironmental gains

Measures suggested included:

planning controls on the extent anddesign of development in London,with consequential impacts onadditional runoff

education on the use of sewers andthe need to reduce waste

wider recycling of grey water andthe use of composting WCs.

4.3.3 We have considered the appropriateness of using SuDs, separatesewers and bubblers and skimmers as set out in the Needs Report.None of the three solutions are considered feasible alternatives toa storage and transfer tunnel. Reasons include because:

SuDs and bubblers and skimmers will not achieve compliancewith the UWWTD

SuDs and separate sewers would cost more than our preferredsolution and cause more disruption to build


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bubblers and skimmers do not limit flows into the River Thamesand therefore are not a long-term viable solution.

4.3.4 A combination of measures including the tunnel would be moreexpensive than the tunnel alone and is not considered costeffective. A combination of measures not including the tunnel,such as SuDS and separate sewers would not address the driversfor the project and will fail to deliver a solution by the target date of2020.

4.3.5 In terms of complementary measures we are working with the EA,the GLA and other stakeholders on many of the complementarymeasures indentified including pressing for planning policies thatreduce water use and encourage the development of SuDS andeducation campaigns such as the bin it, dont block it campaign toencourage customers to reduce waste flushed down toilets andcooking far poured down sinks.

4.4 Our initial view of the way forward

4.4.1 We recognise that a minority of respondents have concerns aboutthe need for the project and that some respondents were eitherunclear or not convinced that a tunnel is the most appropriatesolution. We have given careful consideration to these commentsand reviewed the detailed evidence contained in the Needs Report.Having done so, we still believe that it is essential to reduce theamount of sewage entering the River Thames and that a tunnelrepresents the best way to achieve this.

4.4.2 Some of the concerns raised included detailed comments on thedesign and construction of the tunnel. These will, so far aspossible, be taken into account as the design for the tunnelprogresses.


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5 The route

5.1 Your views

5.1.1 We consulted on three possible routes for the tunnel: Abbey Mills,

Rotherhithe and River Thames. Our preference is for the AbbeyMills route, which is significantly less expensive and achieves thenecessary improvements in water quality. The routes were alsoassessed in relation to five disciplines: engineering, planning,property, environment and community, with the conclusion that theAbbey Mills route is the most appropriate because on balance it isconsidered to have the least impacts. The pie chart below indicatesthat, of the three routes, Abbey Mills received the most supportfrom community respondents. In addition, nine technical consulteesand seven landowners supported the Abbey Mills route.

Figure 5.1 Feedback on routes

5.1.2 The main concerns raised about the Abbey Mills route (ourpreferred route) included:

further information is required on the impacts on residentialamenity caused by the Abbey Mills route compared with theRotherhithe route

is the Lee Tunnel adequately sized to take the Abbey Millsroute loads

if we are going to spend so much money and complete sucha large project, it should capture as many of the sewageoverflows as possible

5.1.3 Detailed comments were also received regarding the impact of thetunnel on existing infrastructure, such as roads, tube lines and

bridges.


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5.2 Our initial view of the way forward

5.2.1 Of the three routes, Abbey Mills received the most supportcompared with the other two routes. We recognise that somerespondents have concerns about our preferred tunnel route

(Abbey Mills) and prefer alternative routes. Having considered thecomments that have been received, we still consider that AbbeyMills is the most appropriate route and therefore intend to pursuethis option because it is significantly less expensive, achieves thenecessary improvements in water quality and is likely to have theleast impacts. As the design for the tunnel progresses, we willundertake assessments of third-party infrastructure potentiallyaffected by the project in order to avoid any adverse impact. Wewill be discussing this further with relevant organisations.

5.2.2 A full list of the comments and issues received, and our detailedresponse, are provided in table format at Chapter A-3 of the

supplementary report.

5.3 Response to the issues that you raised5.3.1 We received a number of comments about the tunnel routes. The

main issues raised and our responses are summarised below.

Table 5.1 Tunnel routes main issues and responses

Issue Our response

Abbey Mills route (our preferred route)

a. Further clarification sought on the

details of the route, includingimpacts on residential amenity, whyit is aligned to the south of the riverand whether it is the shortest andcheapest route option (community)

We took into account a range of factors in

assessing the route options, including thepotential for each route to cause loss ofresidential amenity. The balance ofresidential amenity for the Abbey Millsroute and Rotherhithe route were almostthe same and did not significantly influencethe choice of route. There are major CSOson the south side of the River Thames thatneed to be connected to the tunnel. Thelocation of these CSOs influence thealignment of the tunnel. Some additional

sites on the north side were explored butwere rejected because they are locatedfurther east than our chosen site(s) andcarry additional tunnelling risks because ofa major change in geology from ThanetSand to Chalk at tunnel depth. The AbbeyMills route is the shortest and leastexpensive option.

b. Whether the Lee Tunnel isadequately sized (community)

The design and sizing of the Lee Tunnel issuch that it can fully cope with theadditional flow from the Thames Tunnel.

c. The route that should be followedshould allow the tunnel to capture

The project we are proposing interceptsthe highest priority CSOs as identified by


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Issue Our response

as many of the CSOs as possible(community)

the EA. It would not be cost-effective tointercept all the CSOs.

d. The impacts on DLR railwayinfrastructure, London Overground

structures and LondonUnderground need to beconsidered, and potential impactswhere Crossrail and the ThamesTunnel alignments cross should beassessed (GLA)

We will be engaging with all infrastructureowners to assess the potential impact of

our works and will be considering, amongother things, the potenti

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