Application eference umber: WO10001 Thames Water’s ......for residential purposes and contribute...

Thames Water’s Response to Local Impact Report from London Borough of Hammersmith and FulhamDoc Ref: APP30.05

Folder 149 2 December 2013DCO-DT-APP-ZZZZZ-300500

APP3

0.05

Thames Tideway Tunnel Thames Water Utilities Limited

Application for Development ConsentApplication Reference Number: WWO10001

1 Introduction

Response to London Borough of Hammersmith and Fulham Local Impact Report

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1 Response to London Borough of Hammersmith and Fulham Local Impact Report

1.1 Introduction

1.1.1 This document responds to the points raised in the Local Impact Report (LIR) submitted by the London Borough of Hammersmith and Fulham (LBHF) to the Examining Authority (the ‘ExA’) for the 4 November 2013 deadline. The response is split into 11 sections that mirror the sections in the LIR as follows:

a. Section 2: LIR Sections 1 to 4

b. Section 3: LIR Section 5 Transport

c. Section 4: LIR Section 6 Heritage

d. Section 5: LIR Section 7 Air quality

e. Section 6: LIR Section 8 Land contamination

f. Section 7: LIR Section 9 Flooding

g. Section 8: LIR Section 10 Ventilation

h. Section 9: LIR Section 11 Biodiversity

i. Section 10: LIR Section 12 Equality

j. Section 11: LIR Section 13 Hammersmith Bridge

k. Section 12: LIR Section 14 Noise, vibration, odour and dust

1.1.2 Again, mirroring the LIR, within each section matters are first addressed where they are of a general non-site-specific nature, followed by site-specific matters relating to the proposals at Acton Storm Tanks (which is outside of, but close to the boundary with LBHF), Hammersmith Pumping Station and Carnwath Road Riverside. The responses to each matter are tabulated, with the LIR comment set out on the left and Thames Water’s response on the right.

2 Sections 1 to 4 of the LIR


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2.1.1 Sections 1 to 4 of the LIR include:

a. Section 1: an introduction

b. Section 2: descriptive material relating to each site and its surroundings as well as details of the proposals, relevant planning policies and planning history and development proposals

c. Section 3: a brief introduction to how the local impact report is structured on a topic-by-topic basis

d. Section 4: material on socio-economic and community matters, including a range of socio-economic data.

2.1.2 Much of the material in Sections 1 to 4 is descriptive in nature and therefore does not require a response. Where matters are identified that we consider a response would assist LBHF and the ExA, it is provided in the tables below.

2.2 General matters

Para. ref LBHF comment Our response

4.35-4.36

“The potential impact on residents living close to the proposed site is likely to result in some residents being rehoused for at least a period of 6 years. This possibility has been recognised by Thames Water in their press announcement in October 2012 (Evening Standard 15.10.12) and in the compensation strategy.

“The loss of occupied housing due to this development is contrary to London Plan policy 3.15B and to H&F Core Strategy policy H1. Also, as much of the housing closest to the site is affordable housing, this will increase the shortage of affordable housing in London.”

We do not propose to compulsory purchase any housing units. There is therefore no loss of housing (including affordable housing), which would be contrary to London Plan 2011 or local planning policies. This is entirely separate from any potential compensation payable under the compensation strategy.

4.23 “The council is concerned that the Environmental Impact We have taken into account the sensitive receptors outlined by LBHF



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Assessment and the Planning and Site Selection Assessments have not fully assessed or taken into account the impact of the proposed tunnel sites on residents, businesses and community facilities, including schools, nurseries, parks, sports and leisure facilities in the local areas. Many of the residents within the vicinity of all three tunnel construction sites experience high levels of deprivation and are likely to have fewer resources to deal with the adverse impacts arising from the construction sites. These issues have been raised by the ExA first written questions Q15.1 to 15.8”

in para. 4.23 of the LIR within our assessment of effects presented in the Environmental Statement (the ‘ES’). ES (Doc ref: 6.2.02, Vol 2) sets out the methodology used for each environmental topic, including how sensitive receptors have been identified. In particular, we direct LBHF and the ExA to the methodologies for the assessment of noise effects and socio-economic effects. LBTH notes that these matters were raised by the ExA in the first written questions and we therefore direct LBHF and the ExA to our responses to questions 15.1 to 15.8.

Appendix B of the draft LBHF Statement of Common Ground (SoCG) submitted to the ExA on 4 November 2013 outlines the nature of the pre-application environmental engagement with LBHF.

4.87 “The cumulative effects assessment in relation to H&F is inadequate in that it did not assess the effects of all the sites that may be completed before the Thames Tunnel construction commences or will be under construction at the same time as the proposed construction”

It is important to note that the Council was twice consulted on the methodology and development schemes used in the cumulative effects assessment, in February 2012 and September 2012, but did not respond. Responses to the specific schemes which the LIR refers to are provided under the site-specific sections below, covering Acton Storm Tanks, Hammersmith Pumping Station and Carnwath Road Riverside.

2.3 Hammersmith Pumping Station


4.92 “Hammersmith Pumping Station site is within 1km of Hammersmith Town Centre and the Transport Assessment proposes that all traffic from this construction site will access the A4 via the Hammersmith Gyratory.”

Noted

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4.93 “H&F Core Strategy included Hammersmith Town Centre and Riverside as a regeneration area and Strategic Policy HTC promoted the regeneration of the town centre and riverside and included site policies for three sites. All these sites are within 1km of the Hammersmith Pumping Station and new development is progressing on these sites (Table 8). This table updates Table N1 in Vol 5 of the ES Appendix N. This table only included the Fulham Reach development and none of the other sites within Hammersmith Town Centre. Table 8 updates this information.”

As per the methodology of the environmental impact assessment (EIA) (see ES Vol 2, Section 3.8, paras. 3.8.12 to 14), on which we have consulted LBHF, we have only identified planning applications rather than plans, policies and programmes that designate, eg, regeneration areas. The reason for this is that a) limited or no information is available on the design and timescales for implementation of the policies, which is required for a robust assessment, and b) there is no guarantee that a proposal would go ahead as it is at an early stage of the planning process.

We note that the LIR provides, in Table 8, schemes for consideration and our responses are as follows:

Item 1) We already have this scheme in our development schedule, and do not believe that it is appropriate to revisit the conclusions of the ES due to the different information that the Council has now provided in terms of the phasing schedule for this development. The assessment is based on information provided by the developer in April 2012 (in a letter to LBHF).

2) This scheme was submitted for planning approval (9/9/2013) after the submission of our application, and therefore did not meet the criteria for inclusion within the cumulative effects assessment.

3) This scheme was submitted for planning approval (22/7/2013) after the submission of the application. We also note that the scheme was rejected by the Mayor of London and on the basis that our methodology excludes schemes that are rejected, should not be part of the development schedules in any case.

4) This was submitted for approval (30/10/2012) after the cut-off date of 5 October 2012 for inclusion of schemes in the cumulative assessment in the ES. Nevertheless we reviewed the scheme and consider that it would not change the findings presented in the ES.



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5) This scheme does not meet our criteria for consideration, on the basis that it is not a Mayor referral scheme and/or within 50m of a project site.

6) As per 5)

2.4 Acton Storm Tanks


4.94 “Although Acton Storm Tanks are not located in H&F the Transport Assessment shows that traffic movements will impact on roads in H&F and therefore major developments in this borough should were assessed as part of the cumulative effects assessment. Table 9 below includes developments that are likely to be completed or under construction during construction work at Acton Storm Tanks.”

Table 9

Item 1) This does not meet our criteria for consideration on the basis that it is not a Mayoral referral scheme and/or within 50m of a project site.

2) As per item 1)

3) This was submitted for planning approval (27/2/2013) after the submission of the application. It also does not meet our criteria for consideration as it is not a Mayoral referral scheme and/or within 50m of a project site.

4) This was submitted for planning approval (14/8/2013) after the submission of the application. It also does not meet our criteria for consideration as it is not a Mayoral referral scheme and/or within 50m of a project site.

2.5 Carnwath Road Riverside


4.88 and “The H&F Core Strategy (2011) sets out the Council’s We are not using SPDs as the basis for identifying development



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4.89 proposals to work with landowners and other partners to secure the regeneration of the South Fulham Riverside. It proposes that most development sites should be developed for residential purposes and contribute to the South Fulham Riverside target of 2,200 additional homes

“Subsequently H&F Council adopted the South Fulham Riverside SPD (adopted Jan 2013) to guide development in this area of South Fulham. Appendix 7 shows the sites that are under construction, have a planning consent or are currently being considered. In addition there are other sites that are identified as potential development sites in the South Fulham Riverside SPD”

schemes, as per the methodology of our ES (see Vol 2 Section 3.8, paras. 3.8.12 to 14), which we asked LBHF to comment on but for which no response was received. The reason for this is that a) limited or no information is available on the design and timescales for implementation of the policies, which is required for a robust assessment, and b) there is no guarantee that a proposal would go ahead as it is at an early stage of the planning process.

4.90 “4.90 Table 7 below updates the Table N1 in Vol 10 of the ES Appendix N. shows the sites that have planning permission and are under construction or have not yet started. There is significantly more development that will have completed or may be under construction at the same time as the construction of the Thames Tunnel main drive site.”

Table 7 Additional schemes

1) Not appropriate to assess this scheme, as it is within the boundary of the Carnwath Road Riverside site. While this scheme has a resolution to grant from the Council, because of our safeguarding direction, it is not appropriate to assume that this development would go ahead, and therefore affect the base case and/or cumulative effects assessment.

2) As per 1)

3) As per 1)

4) This was submitted for planning approval after the submission of the application. Nevertheless, we assessed this development in our response to first written question 14.24, specifically paras. 24.5.83 to 24.5.93. We acknowledge that there would be changes to the base case, and changes in cumulative effects.

5) This scheme does not meet our criteria for assessment on the basis that it is not a Mayoral referral scheme and/or within 50m.

6) This is in our original development schedules and has therefore



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been included in the ES.

7) This scheme is a Mayoral referral scheme, and therefore meets our criteria for inclusion in the EIA. It was omitted in error. The absence of comments from LBHF to our requests for schemes for inclusion in the base case and cumulative assessment meant that this omission was not identified sooner. Nevertheless, we have reviewed the scheme and while it would introduce new residential receptors, we do not consider that such receptors would experience significant adverse effects.

8) This is already in the development schedules and has therefore been included in the ES. LBHF has identified that it is now ‘permitted but not yet implemented’ rather than ‘submitted but not yet determined’. This is noted, but would not change the findings in the ES, as the scheme was considered, regardless of its precise status.

9) As per 7).

4.91 “4.91 A site on Imperial Road that is over 1km from the Carnwath Road site has been included in this table because the roads and key junctions servicing the site will be the same as the junctions affected by the Thames Tunnel construction, that is the Townmead Road, Carnwath Road and Wandsworth Bridge Road junction and the Kings Road, New Kings Road and Waterford Road junction”

See our response to item 9 in para. 4.90 above.

3 Transport (Response to Section 5 of the LIR)


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3 Transport (Response to Section 5 of LIR)

3.1 General matters: Transport


5.14 “The proposed project-wide disapplication of transport related legislation in the Development Consent Order (DCO) is considered to be an ineffective and potentially damaging means of carrying out works to the local and strategic highway.”

We refer to our response to first written question 6.72 and appendix APP6.72.01, which addresses all legislation set out in Schedule 19 to the Draft DCO (Doc ref: 9.20).

The approach to such legislation is to provide replacement controls on a project-specific basis through the DCO so as to ensure that the public interest objective underlying the excluded act would continue to be met, without undue interference to the effective and efficient implementation of the project.

Hence the approach and associated controls are bespoke and thus better suited to the delivery of the project from the perspective of all stakeholders.

5.15 “The council is concerned about the breadth and scope of powers presented by the applicants in the development consent order. Our concerns are broadly in line with those raised by other London boroughs and Transport for London (TfL) and include the disapplication of legislation such as the Traffic Management Act 2004.The council strongly believes that the local highway authority is best placed to exercise these powers and we do not support a scenario where key traffic management issues are not carefully considered in a consistent and effective manner against established legislation.2

We carefully considered the legislation which it seeks to exclude and limited it to those matters as appropriate. In the case of the Traffic Management Act 2004 this is limited to sections 32 to 29 relating to permit schemes.

As set out in Appendix APP 6.72.01 to the first written questions, we re of the view that the urgent need for the delivery of the project, balanced with the replacement controls secured through the DCO, would ensure that the public interest objective is met

5.16 Strategic construction traffic movement has been Transport for London (TfL) and its consultants are currently reviewing the

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modelled by the applicant using TfL’s highway assignment models and based on TfL guidelines. Despite this, TfL have found a number of inconsistencies that could invalidate the results of this modelling exercise. The council supports the representations made by TfL regarding inconsistencies in the modelling and we would welcome a review of these by the applicant.

project’s models. A meeting was held with TfL, City of Westminster, City of London Corporation and the Royal Borough of Kensington and Chelsea, on 22 November 2013 to discuss modelling issues further; it has been agreed by all parties to hold a further meeting to resolve key issues.

5.18 The council understands that it is the intention of the applicants to agree sign off of the Transport Strategy with TfL and the PLA only. The council strongly objects to this given that the transport strategy directly affects the borough’s road network and it is imperative that all effected boroughs are involved in the sign off process. As it stands the Council considers that the proposals are contrary to the Council’s Development Management Local Plan (Policy DM J6).

A summary of the draft mechanism for securing the Transport Strategy (Doc ref: 7.09) has been prepared through discussions with the Greater London Authority (GLA), TfL, the Port of London Authority (PLA) and the affected London Boroughs. This includes information on the approvals process. See the Draft Framework for the Transport Strategy Mechanism submitted in response to GLA’s LIR on 2 December 2013 (Appendix A of APP30.15).

While LBHF has been invited to two transport strategy workshops, it has attended only one. Discussions with David Gawthorpe are ongoing to finalise this mechanism, with the next transport strategy workshop scheduled for 2 December 2013. It is also our intention to meet with LBHF before this workshop to discuss the transport strategy.

LBHF states that the proposal would be contrary to Development Management Local Plan policy DM J6. The ExA has advised that policies of a general nature which cover topics already addressed in the National Policy Statement for Waste Water (the ‘NPS’) are unlikely to be important and relevant. Site allocations and site-specific designations and guidance are more likely to be important and relevant.

Notwithstanding this the policy relates to road hierarchy and states that development will not be permitted where it would prejudice the effectiveness of different strategic levels of roads within the borough. We disagree with this assertion as the proposed works at Carnwath Road Riverside would not result in any blocking up or diversions of local roads. Additional traffic would

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

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not result in any effects other than ‘minor adverse’, as outlined in the ES (Doc ref: 6.2.10, Vol 10, Table 12.10.1).

5.22 Local highway modelling has been undertaken based on TfL guidelines. Despite this TfL have found a number of inconsistencies that could invalidate the results of this modelling exercise. TfL are carrying out further work to establish the extent of inconsistencies and effect on robustness of results. Notwithstanding this the modelling indicates that there will be a maximum increase of three seconds delay to vehicles exiting Chancellors Road and this junction would still operate within capacity. The impact on Hammersmith Gyratory has not been modelled as part of this assessment which is crucial given the strategic importance Hammersmith Gyratory plays in west London and its essential continued resilience. As a minimum, the Council wants to see the impact on Hammersmith Gyratory modelled by the applicants. As it stands, the proposal is considered to run contrary to local Development Management Policies DM J1 and DM J6.

The method for the selection of junctions to test for impacts on highway capacity was discussed and agreed with TfL, and then shared with all the relevant local authorities. The method involved testing the capacity of the nearest applicable junction to the site that construction vehicles route through to accommodate demand. If this junction was found to be significantly adversely affected by our proposals, the scope of the capacity modelling would be extended to the next applicable junction away from the site.

This method led to the identification of the Chancellor’s Road/Fulham Palace Road as the first junction likely to be affected. Further information can be found in Section 10.2 and 10.5 of the Carnwath Road Riverside Transport Assessment (Doc ref: 7.10.07).

With regards to the modelling of the Hammersmith Gyratory, the low level of construction vehicle trips expected to route through the gyratory (average daily peak of four movements per hour) is well within the daily variation in traffic flows that can be expected. This level of additional construction vehicle trips would have a negligible effect on the capacity of the Hammersmith Gyratory. Modelling discussions are ongoing with TfL.

5.23 In terms of highway operation, the applicant’s assessment relies heavily on the assumptions that only 10 per cent of construction vehicles occurring during the peak hours and that none of the workforce would drive. The latter represents a significant disparity between the Carnwath Road site where[Carnwath Road:] it is suggested by the applicants that there will be a significant number of

The roads around the Hammersmith Pumping Station site all lie within Controlled Parking Zones A (operating Monday to Saturday 8.30am to 6.30pm), Q (operating and T (operating Monday to Friday 9am to 5pm). As site operating hours are 8am to 6.00pm, these parking restrictions would prevent workers from parking within walking distance of the site. For this reason, the number of vehicle trips generated by the low number of workers at this site was assumed to be zero. The assessment includes construction (heavy goods vehicle – HGV) vehicle trips and other construction vehicle

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worker trips despite no parking facilities on site and controlled parking on street. If this assumption is incorrect, the network impact could be considerably worse, and given the location of the site with regards to the heavily trafficked and congested Fulham Palace Road and Hammersmith town centre highway network the impact could be exacerbated.

movements including cars and light goods vehicles associated with site operations and contractor activity only.

The roads around the Carnwath Road Riverside site all lie within Controlled Parking Zones U, Q and Z, which operate Monday to Saturday 9am to 5pm). The Carnwath Road Riverside site would have 24-hour working and thus some workers would arrive and depart outside of the hours of the parking restrictions. For this reason, some worker vehicle trips were included in the assessment.

A summary of the approach to the arrival and departure of construction traffic is included in the Strategic Modelling Methodology Report included in Appendix B of the Transport Assessment (Doc ref 7.10). The report shows that the expected number of average daily lorry movements per site in the peak month that and peak months at each site do not necessarily coincide.

It is noted that the number of lorry movements per hour would vary across the duration of the construction programme at each of the sites, depending on the nature of activities being undertaken at the time, however the Transport Assessment assessed the peak month which would not necessarily occur for the whole construction programme. The Transport Assessment is also based on the existing traffic flows in the peak hours.

Further to the above, there is a requirement to prepare traffic management plans as part of the Code of Construction Practice (CoCP), which would include measures to manage lorry movements to, from and around the sites.

Taking into consideration the number of lorry movements at the majority of sites relative to existing traffic flows, the peak months and duration, and the requirements for a traffic management plan, we consider that using ten per cent of the daily lorry movements is reasonable as a basis for identifying impacts of the highway network.

5.24 The two controls in place are a project-wide Code of Construction Practice (CoCP) which will include a

The traffic management plan includes the strategy for traffic management, such as the use of parking measures and/or site operatives (CoCP Part A

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site-specific traffic management plan and a project-wide framework travel plan, which will include a site-specific travel plan. The council consider that these documents need to include mechanisms to monitor these assumptions as well as procedures to make changes to the construction operation to ensure any adverse impact is further mitigated. This is required to ensure compliance with local policy set within the Council’s Development Management Local Plan policy DM J1.

Doc ref: 9.21, Section 5.1.5). The potential for adverse impact management is included in para. 5.1.4). It is also for local authority approval, so LBHF will have the opportunity to ensure that they are satisfied with the mechanisms included in this document.

We are currently considering including an extra bullet in para. 5.1.5 of the CoCP, which sets out what the site-specific plans must include, to cover mechanisms to monitor the assumptions within the travel plan.

5.25 The traffic modelling exercise undertaken by the applicants includes ‘the optimisation of traffic signal timings in order to minimise journey times increase in the local area’ . However, there does not seem to be any mechanism for this to be delivered (through TfL) and it does not assess the implications of changes to traffic signal timings to other road users, such as delay to pedestrians wishing to cross local roads and could impact on access to Charing Cross Hospital. This is required to ensure compliance with Development Management Local Plan policy DM J5.

Traffic signal optimisation would not apply to the Chancellor’s Road junction with Fulham Palace Road, and therefore access to the Charing Cross Hospital, because this is not a signalised junction.

The capacity testing of the Carnwath Road/Wandsworth Bridge Road/Townmead Road did include the optimisation of signal timings. However, since the construction traffic did not have a significant effect on the capacity of this junction the level of optimisation due to project traffic would be minimal. It is worth noting that this junction is proposed to be remodelled significantly as part of the borough SPD and therefore signal timings are likely to be changed.

In response to concern regarding policy Development Management Plan policy DM J5, the ExA advised that policies of a general nature which cover topics already addressed in the NPS are unlikely to be important and relevant. Site allocations and site-specific designations and guidance are more likely to be important and relevant.

Notwithstanding this, we direct LBHF to the ES (Doc ref: 6.2.05, Vol 5, Section 10), in particular Table 12.10.1, which identifies no effects beyond that of minor adverse on the different identified receptor groups. We are satisfied that there is no conflict with this policy.

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5.34 It was assumed that 90 per cent of the main tunnel excavated material is transported out by barge and 90 per cent of all main tunnel secondary lining aggregates are transported in by barge. This equates to an average four peak daily barge movements. Should river transport not be suitable, these movements would be transferred to the road and in order to assess the implications of this an ‘all by road sensitivity test’ has been carried out. The council considers that there is a need to secure 90 per cent river movements by requirements to ensure that adverse impacts on the road network do not occur.

See our response to para. 5.18 of the LIR.

5.36 In the ‘all by road’ scenario all additional movements travel to and from the north along Wandsworth Bridge Road rather than a 50:50 split in the barge scenario. This is contrary to the transport strategy that states that construction traffic will join the TLRN as soon as possible. Furthermore no detailed traffic modelling has been carried out for any of the junctions north of the site such as King’s Road and Bagley’s Lane. These junctions are operating close to and over capacity which would again suggest that these routes are contrary to the transport strategy to avoid parts of the network that already show congestion. Unless there is the correct application of the transport strategy on this matter, the Council consider that the proposal is contrary to Development Management Local Plan policy DM J6.

Construction vehicle trips were distributed according to the likely origins/destinations of the materials they would transport. The materials transported in the barge scenario resulted in a distribution of HGV trips that was approximately 50:50 north and south along Wandsworth Bridge Road. In the barge scenario, no excavation spoil road based trips were generated.

In the ‘all by road’ scenario, spoil materials would have to be transported and the most likely destination of these trips is to Denham Quarry in the north west, for which the most likely route is north along Wandsworth Bridge Road towards the A4 or A40. Since the majority of trips generated during the peak period of site activity would be excavation trips, the distribution of trips at the junction with Wandsworth Bridge Road at this time would show a greater percentage of trips routing to/from the north.

The method for the selection of junctions to test for impacts on highway capacity was discussed and agreed with TfL. The method involved testing the capacity of the nearest applicable junction to the site that construction vehicles would route through to accommodate demand. If this junction was found to be significantly adversely affected by the proposals, the scope of the



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capacity modelling was extended to the next applicable junction away from the site.

This method led to the identification of the Carnwath Road/Wandsworth Bridge Road/Townmead Road as the first junction likely to be affected.

The results of modelling this junction for the EIA (barge) scenario suggest that it would operate without additional delay in the AM and PM peaks. The largest change would be a 7 per cent increase in degree of saturation from 33 per cent to 40 per cent on the left turn/ahead movement on Carnwath Road in the AM peak. This was not deemed to be significant therefore no further junctions were assessed.

The ‘all by road’ scenario represented a sensitivity test expected to occur very infrequently and only if there were times when it was not possible to uses barges and is in line with the agreed process for derogations.

5.38 The council considers that any increase in lorry movements will have a comparable linked increase in both vehicle noise and mud deposits onto the public highway. The latter, if not effectively managed, can have a detrimental impact on the safety performance of the highway network.

The CoCP Part A, Section 7.2 mandates following the GLA Best Practice Guidance The control of dust and emissions during construction and demolition (soon to be superseded by Supplementary Planning Guidance of the same name), this states that vehicles – in particular wheels – should be washed or cleaned before leaving the site.

5.42 “The South Fulham Riverside regeneration area planning framework has identified that capacity increases are required at this junction to support sustainable housing and job growth. The most recent studies and designs show that the amendments required by the site and these capacity improvements are essential. These studies and designs are at an early stage and should they develop to become incompatible with the amendments required for this site additional

The application was submitted prior to the approval of the South Fulham Riverside (SFR) SPD, therefore any amendments required as part of this document were not taken into account in the Transport Assessment.

We do not consider that we have a responsibility to deliver the junction improvements discussed in the SFR SPD. The Thames Tideway Tunnel is a major infrastructure project and is not a residential or commercial led development which the SFR SPD and Core Strategy Strategic Policy SFR seek for the site.




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mitigation might be required at the detailed design stage to ensure policy compliance.”

5.44 The submitted plans show a number of illustrative layouts of the site. There is no assessment of the implications of any of the layouts provided with regards to pedestrian and cyclist safety with two vehicle access points, reinstatement of the Thames Path through the site or its internal layout and manoeuvrability of construction vehicles

Drawing DCO-PP-06X-CARRR-09-0003 is the Access plan for the Carnwath Road Riverside worksite. The plan shows the location of the access points and the route of temporary diversions of rights of way, which would subsequently be reinstated.

Site layouts are illustrative. The final layouts would be designed to ensure construction vehicles would be able to enter and exit the site in forward gear, as required for safety reasons. Site accesses would be subject to full road safety audits and, as set out in the CoCP, site management including marshalling and signage would be provided.

3.2 Hammersmith Pumping Station: Transport


5.19 The council is concerned about the potential transport impacts at Hammersmith Pumping Station and the inadequacy of the modelling information compiled by the applicants.

See question 5.16 above.

5.27 The site further requires the extension of the single yellow line restrictions from Monday to Saturday 8.30 to 18.30 to 7.00 to 19.00, an additional 2 hours per day. Working hours are 8am – 6pm so the Council questions the need for this proposed extension.

LBHF was invited to discuss this proposal, but declined the opportunity. We have made continued attempts to engage with LBHF since August 2011, as outlined in Appendix A of the draft SoCG submitted to the ExA on 4 November 2013.

The benefits of this extension of operating hours would be to ensure that these locations are unobstructed in advance of site opening time. This measure can be discussed with LBHF.

5.28 The site requires highway amendments to the junction of Chancellors Road and Distillery Road. This will result in a

A Stage 2 road safety audit will be produced by the contractor at the detailed design stage.



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widening of the carriageway at this junction resulting in a slightly longer crossing movement for pedestrians. A stage 1 road safety audit carried out on this design does not consider this to be an issue, however the Council would require a stage 2 road safety audit to make an assessment based on the future predicted use of this crossing due to the Fulham Reach development.

Again this is required to ensure compliance with Development Management Local Plan policy DM J5.



5.19 The council is concerned about the potential transport impacts at Hammersmith Pumping Station and the inadequacy of the modeling information compiled by the applicants.

See our response 5.16 above.

5.27 The site further requires the extension of the single yellow line restrictions from Monday to Saturday 8.30 to 18.30 to 7.00 to 19.00, an additional 2 hours per day. Working hours are 8am – 6pm so the Council questions the need for this proposed extension.

LBHF was invited to discuss this proposal, but declined the opportunity. We have made continued attempts to engage with LBHF since August 2011, as outlined in Appendix A of the draft SoCG.

The benefits of this extension of operating hours would be to ensure that these locations are unobstructed before the site opens. This measure can be discussed with LBHF.

5.59 There are concerns with regard to the optimisation of traffic signal timings proposed at Acton Storm Tanks.

In the development case, the signalised junction of The Vale/Warple Way/East Acton Lane is expected to operate with a Ratio of Flow to Capacity (RFC) of 65 per cent in the AM peak and 60 per cent in the PM peak and therefore operate well within capacity.

Although the signal timings may have been optimised by the



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LinSig model, the amount of spare capacity suggests that if the optimisation had not been applied the junction would still have operated within capacity. The signal optimisation is therefore unlikely to have had a significant effect on the result of the modelling.

5.60 This site will generate a similar vehicle profile to Hammersmith PumpingStation, based on a similar nature of construction and operation. All movements associated with this site are to be carried out by road and the construction lorry route that affects Hammersmith & Fulham is The Vale, Old Oak Road, A40. No assessment has been made of the performance of any junctions in Hammersmith &Fulham with the additional construction vehicle movements. This information is required in order to assess the impact in the borough.

LBHF was invitied to discuss construction vehicle routing for Acton Storm Tanks, but was not available to attend; however, this was discussed with the London Borough of Ealing and TfL. We have made continued attempts to engage with LBHF since August 2011.

The method for the selection of junctions to test for impacts on highway capacity was discussed and agreed with TfL. The method involved testing the capacity of the nearest applicable junction to the site that construction vehicles route through to accommodate demand. If this junction was found to be significantly adversely affected by our proposals, the scope of the capacity modelling would be extended to the next applicable junction away from the site.

This method led to the identification of The Vale as the first junction likely to be affected. The results of modelling this junction for the EIA scenario suggest that it would operate without additional delay in the AM and PM peaks. The largest change is a 7 per cent increase in degree of saturation from 33 per cent to 40 per cent on the left turn/ahead movement on Carnwath Road in the AM peak. This was not deemed to be significant therefore no further junctions were assessed.



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5.29 The council is concerned about the increase of traffic movements proposed at Carnwath Road based on the capacity of the existing network and the inadequate mitigation proposed by the applicant.

Approximately 441 additional daily movements would be produced by the construction works at Carnwath Road Riverside. For further information on the vehicle split, refer to table 10.2.4 of the Carnwath Road Riverside Transport Assessment. It should be noted that close to half of these movements are attributed to worker vehicle movements which is considered to be a robust assessment. This should be viewed against the commitments made in the Draft Project Framework Travel Plan (Doc ref: 7.11) and the requirement for site-specific travel plans which would, in practice, mean it is highly unlikely that any workers would travel by car.

The Wandsworth Bridge Road (A217)/Carnwath Road/ Townmead Road junction in the construction base case would be operating over capacity during the AM peak hour and within capacity during the PM peak hour. The addition of project traffic (anticipated to be 45 construction vehicle trips (90 movements) during the peak hours) results in an overall increase in delay of two seconds per vehicle in the PM peak hour. On any one arm the maximum delay is 14 seconds per vehicle in the AM peak hour. Overall this effect would not be significant (a minor adverse effect is identified in the ES), and hence no mitigation is proposed.

5.31 In total, based on an operation relying on four barge movements a day, an additional 441 vehicle movements will be generated a day during the peak construction period. This equates to 108 vehicles in the morning two hour peak period and 68 vehicle movements in the evening peak two hour period. Construction vehicles will access the site to and from the north via Carnwath

Construction HGV routes were determined based on the most likely origin/destination of the trip taking into consideration the type of material being transported. Once the direction had been determined, vehicles were assumed to take the shortest route to the Transport for London Road Network (TLRN) or Strategic Road Network) SRN. Since a number of construction HGV trips

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Road, Wandsworth Bridge Road and New Kings Road towards the A3220, and the south via Wandsworth Bridge. The Transport Assessment indicates that the north-south split is broadly 50:50 which seems a robust prediction based on the assumptions made for origin and destination of construction vehicles. However, the transport strategy implies that the quickest route would be taken from any site to access the TLRN, which would be southbound over Wandsworth Bridge. This would remove any construction traffic passing along King’s Road which is subject to congestion and delay due to the close association of three sets of traffic lights. This conflict in assumptions undermines the reliance that can be placed on the transport assessment and the lack of assessment is contrary to Development Management Local Plan policies DM J1 and J6.

are expected to route to/from northern destinations, a proportion of trips route to TLRN/SRN roads to the north.

Construction vehicle routes from the TRLN would be determined by the contractor based on origins and destinations of material and could be subject to further consultation and highway capacity modelling if necessary.

The ExA has advised that policies of a general nature which cover topics already addressed in the NPS are unlikely to be important and relevant. Site allocations and site-specific designations and guidance are more likely to be important and relevant.

Notwithstanding this, we are satisfied that a full and proper Transport Assessment has been carried out, Vol 2 of the ES identifies the methodology which was used for the assessment.

We have been clear in its approach and sees no conflict with the aims or intentions with regard to Development Management Policies DM J1 and DM J6.

5.32 Local highway modelling has been undertaken based on TfL guidelines. Despite this TfL have found a number of inconsistencies that could invalidate the results of this modelling exercise. Notwithstanding this, the modelling shows that under current conditions the junction of Wandsworth Bridge Road, Carnwath Road and Townmead Road is operating above capacity in the morning peak and within capacity in the evening peak. This is consistent with the early results of the modelling the Council has undertaken for its South Fulham riverside regeneration area (Jacobs Transport Study Report 2010). The Thames Water modelling further shows that by 2019 (and without construction traffic) the junction will operate in a similar manner however with increased delays due to background traffic

See our response 5.16 above.



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growth. When the construction vehicle movements are applied (along with the required highway adjustments, detailed below) again a similar performance is shown with the junction operating over capacity in the morning peak and within capacity in the evening peak. A maximum increase in delay of fourteen seconds results to vehicles turning right from Carnwath Road

5.33 Given the current and future performance of this junction in the morning peak, additional mitigation is required to ensure that no construction vehicle movements are carried out in the morning peak. This is in line with the projects transport strategy of avoiding parts of the network that are already showing congestion and delay. The council considers that the applicants should remodel the movements of this site based on this essential mitigation measure.

The Transport Assessment for Carnwath Road Riverside (Doc ref: 7.10.07) considers the impacts which would occur if construction traffic movements took place in the morning peak hour. At this site, the assessment also includes a proportion of workers driving to the site. There would be measures within the site-specific travel plan to discourage workers from driving to the site, but the assessment provides a robust approach which examines the impacts that might arise if workers were to drive. In practice, it is expected that the number of construction-related vehicle movements would be lower than assessed.

ES Vol 10 concludes that the impacts identified would not give rise to significant effects at this site.

We and the contractor would endeavour to minimise the number of construction vehicle movements in peak hours, where possible. If the number of movements in the morning peak hour were lower than assessed, there would still be no significant effects in relation to highway network operation at this site. Effects in other hours would be no greater than in the ES.

5.39 This site requires the suspension of twelve on street parking bays on Carnwath Road for the duration of the construction period of six years. Vehicle tracking shows that not all these bays are required to be suspended due to the presence of the road build-out on the southern side of Carnwath Road. The extent of parking suspensions should be reviewed in light of this.

The Transport Assessment assesses the worst case impact on parking, which LBHF has agreed “should not result in a loss of amenity for residents or lead to unsafe traffic conditions”. If required to remove the parking, the contractor would submit notice to cover no waiting at any time restrictions. This could be tailored to allow evening parking or cover periods where

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However, notwithstanding the above and based on the submitted parking stress data, and our own, this should not result in a loss of amenity for residents or lead to unsafe traffic conditions.

particularly large vehicles are required.

The contractor would undertake an assessment and apply to the highway authority to restrict parking in order to ensure safe access to the site. If it is proven that the level of parking restriction proposed in the Transport Assessment is not required then the number of restricted spaces could be reduced.

5.40 The proposals for this site further require the extension of the single yellow line restrictions on Carnwath Road from Monday to Saturday 9.00 to 17.00 to 7.00 to 19.00, an additional four hours per day. However the code of construction practice for this site suggests shorter times. Both sets of times do suggest a no loading restriction during this time which would restrict local businesses such as Hitchcock and King’s builders merchants that rely on this single yellow line to load and unload.

This should be reviewed and justified to ensure compliance with policy DM J6.

Certain times were omitted from the CoCP Part B in regards to the extension of the single yellow line. The updated CoCP Part B for Carnwath Road Riverside (Doc ref: 9.22.07), submitted on 23 September 2013 states the correct hours. These timings are required to minimize the impact on local road users.

5.41 The proposals for this site require a widening of one of the lanes of the Wandsworth Bridge Road, Carnwath Road, Townmead Road junction to allow for the largest lorries to access the site. The submitted plans show an illustrative arrangement however Wandsworth Bridge is a key north-south cycle route over the river and the increase in left turning lorries could increase cycle casualties. In the five year period to 2011 thirteen casualties were recorded at this junction, with three reported as serious injuries.

In the 2021 AM peak base case, it is expected that a total of 812 vehicles would make a left turn into Carnwath Road from Wandsworth Bridge Road, of which 40 are expected to be HGVs. The Carnwath Road Riverside site would generate an additional three HGV left turn movements into Carnwath Road in the AM peak hour. This increase is not significant compared to the expected number of other HGVs that already make this movement.

It is also important to note that under the current junction layout, the largest vehicles making this left turn do so by straddling the nearside and central lanes of the carriageway on Wandsworth Bridge Road before cutting across both lanes in order to avoid mounting the nearside kerb. In some cases HGVs were

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observed to mount the kerb while making this movement. The mitigation proposed in the site-specific Transport Assessment includes increasing the kerb radius on the left turn between Wandsworth Bridge Road and Carnwath Road to enable large vehicles to make the turn safely from the nearside lane and without mounting the kerb. This represents a significant improvement in safety for all road users, pedestrians and cyclists compared to the base case.

We are committed to the highest level of safety between construction vehicles and cyclists. These measures are detailed in Section 5 of the CoCP Part A.

5.43 This site requires two vehicle access and egress points on the south side of Carnwath Road during early phases of the construction and one vehicle access during later phases. These would be directly on the current diversion of the riverside walk. Furthermore the site requires a further diversion of the riverside walk whichwould continue along Carnwath Road for approximately another 100m before returning to the riverside. The site-specific code of construction practice does not offer any additional mitigation to the pedestrians and cyclists using this route during construction times. Pedestrian and cyclist safety is paramount and reflected in the requirements of policy DM J5.

The CoCP Part A, Section 5 sets out measures to be taken by contractors to ensure the safety of pedestrians and cyclists at site accesses and on diversion routes. These include ensuring that movements at site accesses are controlled, appropriate signage is provided on diversions and at accesses, routes are suitable for mobility impaired users and that advance information is given of potential closures or diversions.

The CoCP Part A states:

“The contractor would carry out the works in such a manner as to limit inconvenience to the public arising from increased traffic flows and disruptive impacts of construction traffic (para. 5.1.4)”;

“The contractor would:

a. limit the need for diversions of public rights of way, cycle routes or National Trails (including the Thames Path)

b. limit the length of any necessary diversions of the above

c. limit the length of time diversions are in place

d. place controls to ensure the safety of pedestrians and



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cyclists if they need to cross a haul route

e. provide clear signage for any diversions, and advance notice of any closures/diversions

f. ensure any diversions are fully accessible and in line with Disability Discrimination Act requirements, as far as practicable and in the context of the route that is being closed temporarily”. (para. 5.3.5)

“The design and operation of the works will take into account people with reduced mobility”. (para. 5.3.6)

It should also be noted that there are already accesses from Carnwath Road into areas of the Carnwath Road Riverside site, which pedestrians on the footways have had to cross to date.

5.55 Bus route 424 operates as a hail and ride service along Carnwath Road and continues along Peterborough Road. The requirement for a no loading restriction along this stretch of Carnwath Road will remove this service and passengers will need to use the nearest stops on sections of the route that do not have restrictive loading facilities or at the nearest stop on Townmead Road 260m away. The number of passengers affected by this change has been reported as small, however no data has been provided to substantiate this. Given the low Public Transport Accessibility level (PTransport AssessmentL) of the area and distance from a rail station to the site, bus travel is important and this impact should be fully assessed. The need for this loading restriction should be reviewed in order to restore this service and meet the local servicing needs as detailed previously.

The suspension of the hail and ride bus facility along Carnwath Road has been discussed with TfL. The conclusion was that this service is not heavily used and therefore the number of passengers its would impact on would be low. TfL explained that the nature of a hail and ride service is that a bus would stop to pick up passengers at the driver’s discretion. Therefore, a driver would not stop if unsuitable to do so for safety or congestion or any other reason. Carnwath Road is currently used by a significant number of HGVs and there may already be times when hail and ride service drivers do not stop. Given that the hail and ride service does not route past the Carnwath Road Riverside construction site, it is likely that it could continue to operate as frequently as it currently does.

5.56 The Transport Assessment indicates that there will be no worker parking on site which is essential. The Site Suitability Report for

ES Vol 10, para. 12.5.40 states that “parking for 15 essential construction site operations and contractor activity operation



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Carnwath Road (Doc Ref.9.10.01) para.7.2.3 recognises that parking could be allocated within the site boundary or workforce transport may need to be provided. This has not been addressed in the Transport Assessment. It only indicates that there will be parking for essential maintenance vehicles on site. While this is recognised as a requirement, it does not indicate how many spaces this will be. There is a predicted daily ‘other construction vehicle’ movement figure of 134 which would suggest a significant number of on-site parking spaces. The council would need to be assured that the spaces are not used for workforce parking, outside the periods the spaces are used for maintenance vehicles.

vehicles would be provided on-site”. In determining the number of on-site parking spaces required to accommodate these ‘other construction vehicles’, we considered the number of these vehicles along with their likely on-site dwell time. The number of movements quoted for ‘other construction vehicles’ includes allowance for journeys made by workforce transport minibuses or similar vehicles to support site-specific travel plan initatives to reduce the potential for workers to drive to site. The level of parking provision identified on-site includes provision for contractors’ operational vehicles and workforce transport vehicles, among others. The use of these spaces would be carefully controlled and therefore the number of spaces identified is expected to be sufficient to accommodate demand.

Construction workers would not be permitted access to the site for parking. Furthermore, as described in ES Vol 10, Section 12, measures would be taken at this site to discourage workers from travelling by car, including promoting the use of public transport, walking or cycling. These measures are included in the Draft Project Framework Travel Plan (Doc ref: 7.11) and CoCP and would be reflected in the site-specific travel plan.

5.58 The project-wide transport assessment identifies that seventeen hazardous loads will be generated per week and this includes one at the Carnwath Road site. However, there is no reference to this in the site-specific information. The council considers that the impact of this on the Carnwath Road area should be addressed.

ES Vol 10, para. 12.5.58 states: “It is assessed that potentially one hazardous load per week would be generated by this site and this equates to a medium adverse impact in accordance with the criteria set out in Vol 2.”



4 Heritage (Response to Section 6 of LIR


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4 Heritage (Response to Section 6 of LIR)

4.1 General matters: Heritage


6.6 “The council is concerned that the potential impacts of the proposal on heritage during and after construction are impossible to assess with any certainty because of the indicative nature of the site layouts and illustrative plans within the DCO application.”

The assessment of effects for each environmental topic in the ES is based on the ‘worst case’ layout in terms of the construction site and the location of permanent structures within the zones shown on Site works parameter plans. This is a robust approach, which predicts the maximum extent (or ‘worst case’) of likely significant effects, while maintaining a degree of flexibility in the final design, within the parameters imposed through DCO Requirements relating to the design of above-ground structures and landscaping, and the design principles. Therefore, in terms of the assessment of effects on the historic character and setting of above-ground heritage assets, the most prominent location for above-ground structures within the setting of listed buildings or within conservation areas was assumed.



6.8 “The council is concerned that the proposed construction and Brutalist style of architecture planned at Hammersmith Pumping Station may not be in keeping with the character of the Fulham Reach Conservation Area and Thames Policy Area and would run contrary to policy.”

As detailed in the assessment of effects on the historic environment (ES Vol 5, Section 7), we consider that with the design principles in place for the works at Hammersmith Pumping Station the operational phase would largely be screened from most of the Fulham Reach Conservation Area by



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the surrounding walls, mature vegetation and intervening buildings. The design would marginally enhance the site by improving its appearance, giving rise to a low beneficial change to the character of the asset.

6.9 “The proposal is extensively underground with the main tunnel shaft not apparent at ground level apart from access hatches, however some above ground infrastructure is proposed. The electrical and control equipment would be housed within the existing pumping station building and therefore would not be visible from the public domain. Other modifications are also required within the pumping station building. A 1.5m high penstock control panel would be mounted on the external wall of the building. The council accepts that accommodating these works within the existing building will help to reduce the visual impact on the Fulham Reach Conservation Area. However, the existing screen house building will potentially be demolished to be replaced with a similar structure, the height and footprint of which remain unconfirmed. It is of concern that only indicative proposals are provided and therefore it is not possible to fully assess the impact on the Fulham Reach Conservation Area or the Thames Policy Area.”

See our response to para. 6.6. We undertook a robust assessment of effects based on ‘worst case’ layouts and heights within the zones shown on the Site works parameter plan. Design principle HAMPS.07 controls the height and footprint of the Screen House, as follows: “If the Screen House is removed, then it shall be replaced with a structure(s) that shall not exceed the height and footprint of the existing Screen House building”. As detailed in the ES, minor beneficial effects are predicted on the Fulham Reach Conservation Area. The operational phase would largely be screened from most of the area by the surrounding walls, mature vegetation and intervening buildings. The associated design would marginally enhance the site by improving its appearance, giving rise to a low beneficial change to the character of the asset.

6.12 “Six ventilation columns of between 8.5 and 9m in height are proposed to be placed adjacent to the south east façade of the existing pumping station. As they are likely to be visible it will be necessary to access the impact on the Fulham Reach Conservation Area and the Thames Policy Area, but this is not possible at this stage as only indicative plans have been submitted. The council considers that as indicated the ventilation columns in tandem with the pumping station and its concrete wall are likely to have a negative impact on the Conservation

See our response to para. 6.6 above. We undertook a robust assessment of effects based on ‘worst case’ layouts and heights within the zones shown on the Site works parameter plan (see ES Vol 5, Section 7). As noted in response to para. 6.9, overall minor beneficial effects on the Fulham Reach CA are predicted from the proposed site design and layout. The effects are also discussed in the Heritage Statement (Doc ref: 5.3, Appendix A), which concludes that the proposals would cause no harm to the significance of the conservation area as a whole.

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Area and the Thames Policy Area and are likely to run contrary to Policy. For example, Development Management Local Plan Policy DM F2 (The design and appearance of development within the Thames Policy Area) will not permit development within the Thames Policy Area unless it is of a high standard of accessible and inclusive design and maintains or enhances the quality of the built and natural environment. In this case the proposed columns, together with the concrete wall and pumping station building would not, as currently proposed, maintain or improve the quality of the built environment in this designated Thames Policy Area. The council considers that further work is needed to improve the design of the proposed buildings and columns.”

6.13 “A ventilation structure of 4.5m would be placed at the south western end of the pumping station building. It appears that an existing structure (Venturi building) will be demolished in a similar location. The building would be constructed of precast concrete; it seems to match the Brutalist style of the pumping station building, but again an opportunity has been missed to design a structure that is more sympathetic to the character of the area. A zone for the building is indicated, rather than precise proposals and therefore, it is not possible to adequately assess the impact on the Fulham Reach Conservation Area or the Thames Policy Area.”

See our response to para. 6.6. We undertook a robust assessment of effects based on ‘worst case’ layouts and heights within the zones shown on the Site works parameter plan. As noted in response to para. 6.9, overall minor beneficial effects on the conservation area are predicted from the proposed site design and layout.



6.25 “The council is concerned that the indicative and illustrative See our response to para. 6.6.



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plans put forward for Acton Storm Tanks do not allow adequate assessment to be made.”

6.26 “The most significant visual impact of the proposal at Acton Storm tanks is the 15m high ventilation column and although this is indicatively proposed to be set away from the borough boundary it is still likely to be visible to residents immediately adjacent to the development site. Other buildings proposed on site together with landscaping will also be noticible from flats in the borough which overlook the site. The council acknowledges that on the Warple Road side of the site the lining of mid rise buildings will provide a certain amount of screening out of the ventilation column from the wider borough and the conservation area to the west. Our colleagues in Ealing will be able to fully assess the impact of the proposed buildings and ventilation column when final designs are put forward for approval. At present the indicative and illustrative plans do not provide enough certainty to help the authorities assess their potential impact. Even if an assessment is made the plans could subsequently change.”

See our response to para. 6.6 above.

We direct LBHF to Part 1 the Design and Access Statement (Doc ref: 7.04), which provides further details of the ventilation column and how the design was set out in order to minimize impacts.

As shown in Section 8 of the draft SoCG with the London Borough of Ealing, within which Acton Storm Tanks is located, design, landscape and visual issues are all agreed.

We also direct LBHF to Requirement ACTST2, which detail permanent above-ground structures to be submitted to and approved by the local authority.



6.15 “The council is concerned that the proposed construction at Carnwath Road is not in keeping with the character of the Sands End Conservation Area and Thames Policy Area and would severely restrict any future regeneration of this part of the South Fulham Riverside Regeneration Area (as designated in the Core Strategy 2011).”

As detailed in ES Vol 10 Section 7, we consider that the proposed development would enhance the quality of design along the riverside at a scale appropriate to the character of the Sands End Conservation Area. An assessment of effects on townscape character and visual amenity was also undertaken (ES Vol 10 Section 11), which similarly concludes that there

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would be beneficial effects overall due to the creation of a riverside public open space alongside a high quality building to house air management plant, equipment and the ventilation column.

It is also important to acknowledge that the Sands End Conservation Area was designated because “of the importance of protecting the riverside from unsympathetic development and to encourage the preservation and enhancement of the riverside itself, ensuring that new development is of a good and appropriate design”. The Sands End Conservation Area appraisal recognizes that the appearance of the designation is somewhat transitional, with older industry contrasting with newer build properties. It states “the main feature within the conservation area, and the principal elements in defining its character, are the river itself, the river bank and views along and across the Thames”, which Thames Water would maintain in legacy and as far as practicable during construction.

6.18 “The ventilation building and ventilation column provide the visual markers of the tunnel’s presence on the site. The ventilation column is positioned close to the riverside at the back edge of the proposed extension of the Thames Path. The council considers that the column will be highly visible and will have a visual impact on the townscape within the Sands End Conservation Area and Thames Policy Area.”


6.19 “The council’s South Fulham Riverside Policy (Strategic Policy SFR) set within the Core Strategy requires that on the riverside especially, a very high standard of urban design will be necessary, together with linkages to the river and riverside walk. The provision of an open space accords with the Core Strategy Policy and would accord with the Key Urban Design principles of

The Carnwath Road Residential Feasibility Study (Doc ref: APP.31.01) shows active frontages at ground floor level on the principal frontages of Riverside Walk and Carnwath Road. The shape of the developable space of the site would mean that a traditional outward looking perimeter block would not be possible, ie, there is no ‘block’.



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the Council’s Fulham Riverside Supplementary Planning Document 2013 (SPD). However, the Council considers that the location of the open space and its layout could restrict development on the remainder of Whiffin Wharf. The key urban design principles within the South Fulham Riverside SPD states a preference for fine grain development with active edges at ground floor level. The most appropriate built form is outward looking perimeter blocks.”

Open space is provided in accordance with guidelines set out in the SFR SPD, Core Strategy policy H3 and the Mayor’s Supplementary Planning Guidance (2012), standard 4.10.1.

6.20 “The position of the open space is not supported as it has not been demonstrated whether its size and location will enable the remainder of Whiffin Wharf to be developed in a way which satisfies the key urban design principles in the South Fulham Riverside SPD and Core Strategy Policy SFR. It is also unclear from the proposals whether the remaining undeveloped Section of Whiffin Wharf will be of sufficient size that it could integrate well in the future with existing neighbouring residential development on Petrofina Wharf. To have a large stretch of this designated regeneration area occupied for 7 years and then to render it undevelopable land as a legacy is considered to be extremely irresponsible planning and could significantly impede the regeneration of South Fulham, which in turn could impact negatively on the delivery of housing in the borough and across London.”

As per para. 6.19, we undertook a pre-feasibility study which provides three options for development on Whiffin Wharf. The existing application for 78 residential units on the site has been recommended for approval. Our feasibility study showed between 36 and 53 residential units under development on the site.

The Urban Design Strategy, Chapter 9, in the SFR SPD proposes that west of Wandsworth Bridge building heights would generally be appropriate at four to seven storeys (with reduced massing at upper levels). Additional height could be accommodated in specific places but not above ten storeys. However, in the Core Strategy (2011) strategic policy for the South Fulham Riverside Area states that in some locations higher buildings may be considered, if it can be demonstrated that a taller building would be a key design element in a master plan for regeneration and that it would have a positive relationship to the riverside (see SFR SPD Section 9.6). Building height can be increased towards the riverfront where buildings need to be of a scale to give appropriate definition and presence to the riverside.

The Whiffin Wharf scheme building is part four, part five storeys on the eastern boundary and Carnwath Road; part five, part six,



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part seven storeys on the eastern boundary; and part four, part six on the River Thames.

Our options for feasibility offer a range of storey heights and set-backs to reflect different massing options. Generally they are low on the north and west of the site rising towards the riverside.

See our response to first written question 14.24 (paras. 24.5.40 to 24.5.51) in relation to the impact of the project on the future regeneration of the SFR regeneration area.

6.21 “The Council considers that the ventilation column does not necessarily need to be a free standing structure but could be incorporated within future development of the site in an integrated manner. There has been no consideration of how the structure could be integrated into a perimeter block form of development in a way that optimises development of the site. The Council does not accept that there is a need for a visual marker of the tunnel on the site.”

The height of the ventilation column was designed to ensure suitable dispersion of treated air from the main tunnel. It was designed as a free standing structure to represent a feature on the permissive public realm which would surround the shaft, hydraulic and ventilation chambers and other project infrastructure. We note that the Council does not accept that there is a need for a visual marker of the tunnel on the site.

6.22 “Regarding the indicative position of the ventilation building and the buffer wall along the entire length of the boundary with Hurlingham Wharf, there is concern that these could prevent integration with future development on Hurlingham Wharf. In combination they form an impenetrable barrier that extends from Carnwath Road to the riverside wall. It has been designed specifically to be a buffer to wharf type/industrial uses on Hurlingham Wharf given its protected status in the London Plan. The Council does not wish to preclude the potential for residential and mixed use development on Hurlingham Wharf following completion of the works. As such our preference would be for an open edge along this eastern boundary of the open space, similar to the indicated layout for the western side where a footpath runs along the whole length linking Carnwath Road to

The Design and Access Statement Part 2, Section 12, paras. 12.4.17 to 12.4.20 describes the protective buffer to Hurlingham Wharf that is proposed within the design and its rationale.

Hurlingham Wharf is a safeguarded wharf and we have received no indication from the GLA that this status is likely to change in the near future. As such, the inclusion of a buffer zone between Hurlingham Wharf and potential development on Whiffin Wharf is a sensible design precaution. The ventilation column is set back from the river wall in order to facilitate a continuous riverside walkway.

Please also see response to para. 6.20 above.



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the riverside. The Council contends that an open edge would provide flexibility for the form of future development on Hurlingham Wharf and would facilitate more easily a perimeter block form of development with active edges and permeability between the new open space and Hurlingham Wharf. The continuous wall also precludes the provision of a continuous Thames Walk along the entire length of the works site.”

6.23 “The indicative position of the ventilation building and the ventilation column are not supported due to their impact on the future development of Hurlingham Wharf, however the Council recognises that the parameter plans allow their position to be changed. It is appreciated that Thames Water wishes to make a signature structure of the 15m ventilation column, but the Council considers that it is not possible to fully assess the impact on the heritage assets against policies in the Core Strategy and Development Management Local Plan as there is a lack of clarity in the proposals and only parameter plans and indicative plans have been provided.”

See our response to para. 6.6 and 6.21 above. We undertook a robust assessment of effects based on ‘worst case’ layouts and heights within the zones shown on the Site works parameter plan.

6.24 “The Council finds the approach to Archaeological investigation to be acceptable however, it is concerned that no reference has been made to where the results of the study will be published. The study should be deposited with the Council when completed and made available to interested parties such as local amenity groups.”

Noted. The process detailed in the Overarching Archaeological Written Scheme of Investigation (Doc ref: 7.13) would be adhered to as per Requirement CARRR5, with site-specific details agreed through site-specific written schemes of investigation, to be submitted to the local authority for approval in consultation with the Greater London Archaeological advisory service.

http://infrastructure.planningportal.gov.uk/wp-content/ipc/uploads/projects/WW010001/2.%20Post-Submission/Application%20Documents/Other%20Documents/7.13_Overarching_Archeological_Written_Scheme_of_Investigation.pdf

http://infrastructure.planningportal.gov.uk/wp-content/ipc/uploads/projects/WW010001/2.%20Post-Submission/Application%20Documents/Other%20Documents/7.13_Overarching_Archeological_Written_Scheme_of_Investigation.pdf

5 Air quality (Response to Section 7 of LIR


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5 Air quality (Response to Section 7 of LIR)

5.1 General matters: Air quality


7.6 The Code of Construction Practice (Part A – General Requirements) is unclear, inconsistent and does not contain adequate information to effectively assess the construction phase impact of the Thames Tideway Tunnel on Air Quality. The council also considers that the currently proposed CEMP approval process and mitigation measures are not effective or appropriate.

An air quality assessment was completed that considered the air quality effects associated with construction works at the Carnwath Road Riverside worksite. Emissions from construction vehicles, construction plant and river transport were considered in the local air quality assessment. A construction dust assessment was also carried out. The assessment findings are contained in ES Vol 10 Section 4.

The CoCP outlines the management of construction impacts at each project site, including gaseous and particulate emissions from construction plant onsite.

LBHF (along with all other local authorities) as invited, at various points throughout the development of the CoCP, to contribute to the development of the document (see our response to first written question 6.74). Engagement included the offer of one to one sessions to discuss the CoCP, as well as forums and opportunities to provide written feedback. LBHF chose not to engage at these points; however we would be happy to discuss the CoCP with the Council and implement specific measures where appropriate.

7.8 The council considers that the term “work package” in relation to the planned construction phases is not clearly defined. Without a clear definition it means that there could be a very large number of CEMPs being produced for assessment which will put a lot of pressure on council resources. (The CEMP will

The project would be delivered in three main contracts (east, west and central). A construction environmental management plan (CEMP) would be produced by the contractor for packages. Therefore there would be three CEMPs for approval. Each CEMP would include site-specific measures.



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be the overarching environmental management plan covering general site operations and overall management of the construction works. An air quality management plan will form part of the Construction Environmental Management Plan).

7.9 In addition the Council notes that the Employer (Thames Water) is to approve the CEMPs “in consultation with” the Council. The council does not consider that this is appropriate as it is essential that the local authority has the final say on whether or not CEMPs are adequate enough to comply with planning policy requirements and be approved for implementation. This is particularly important as the Council is best placed to assess the need for and condition the submission of CEMPs for each site.

The approval process was clarified in our response to first written question 6.75. This includes provision for local authorities to approve the air quality management plan (in addition to the other plans which are already for their approval).

7.11 The council objects to the proposal that CEMPs that have been submitted to the Council for approval can be updated without further formal consideration and consultation with other statutory consultees. There is reference to presenting of alterations to “relevant stakeholders” which presumably includes the Council, but as above, there is an implication that it is Thames Water as the employer that has the final say in approving these documents. We consider that it is or should be the Council as the planning authority that has final sign off.

As above, our response to first written question 6.75 addresses this point. This sets out how local authorities would be consulted on amendments to the CEMP.

7.13 As a minimum the Council considers that specific conditions requiring these commitments are implemented should be included in the CoCP and/ or the DCO and that evidence is submitted to the Council for approval.

As this is part of the CEMP, this would be submitted to the local authority for consultation. The CEMP is a requirement of the CoCP, so equally is a DCO Requirement already.

The air quality management plan is for approval by the local authority; this amendment will be included in the next version of the CoCP Part A.

7.15 As a minimum the CoCP and/or the DCO should include a A new para. 2.4.2 was included in the revised CoCP Part A, which



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specific condition requiring the submission of monitoring and auditing information to prove that the conditions set and commitments given to minimise environmental impacts during construction are being complied with.

ties the enforcement more clearly to DCO Requirement PW6 (which covers implementation of the CoCP).

The individual topic sections of the CoCP detail where monitoring data must be provided to the local authorities.

The air quality management plans would be approved by the local authority and include details of auditing and minimum requirements, so the local authority would have the opportunity to stipulate their requirements.

7.16 Of significant concern to the Council is that if, as necessary, further conditions are placed on Thames Water and or their contractors to supply information for approval both prior to the start of construction and during construction (over the course of several years) then we could need significant additional resources to cover all of the additional work required to check, assess and approve or revise and update the various environmental policies and procedures being implemented at the 3 construction sites. Officers may also need to regularly attend the sites to carry out inspections and additional monitoring. The cost implications of such necessary conditions should be considered as a major impact of the scheme and factored into the cost of the overall proposal.

We are satisfied that the fees set out in Draft DCO Schedule 17, Section 3 is sufficient for the local authorities to discharge their obligations. We also advise that Schedule 17 is to be aligned with the processes as accepted by the Secretary of State as part of the Hinkley Point C approved DCO. This will provide for longer time periods in relation to requests for information. LBHF stated in its response to first written question 6.69 that the fees proposed appear consistent with current fee levels and presumably will be increased in line with any across the board changes. We agree in principle to assist local authorities to cover agreed, reasonable and proportionate costs/resources relating to pre-application discussions for discharging requirements.

7.18 The council considers that regardless of this mitigation measure, all sites should have wheel washing facilities installed to ensure that mud is not tracked out onto the road [note –this is referred to in Section 5.4 Road Cleanliness]. This can be a major source of local dust/PM10 emissions. The definition of “storage sites” is unclear and should be defined as loosely described they could include areas where materials are stored. Depending on the type of materials stored and the nature of the storage, this could give rise to dust/PM10

The CoCP (Part A, Section 7.2) sets out a commitment to following the GLA Best Practice Guidance The control of dust and emissions during construction and demolition. The guidance states that vehicles – in particular wheels – should be washed or cleaned before leaving the site. CoCP para. 5.4.2 states: “vehicle wash-down points to clean vehicle wheels at each exit point from the site”



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emissions. Specialist material handling equipment could also be a source of PM10 and NOx emissions with potential for impacts on receptors close to the sites. As a minimum the Council considers that plans should be provided to show where material storage areas will be located for prior approval by the Council. If plant/equipment is to be stationed in a permanent location, this should also be indicated on a plan to show that it has been sited to minimise impacts on any nearby receptors.

7.20 The FORS scheme has 3 levels – Bronze, Silver and Gold. Bronze just requires operators to follow best practice. The council considers that this is not adequate and a higher standard should be attained or it should be required that progression is made to the higher standards as the project progresses. For example, we consider that a minimum FORS status of Silver should be attained at the start of the project progressing to Gold within 2 years. At these more advanced levels a fuel and emissions champion has to be appointed who implements measures to improve environmental impacts by reducing overall fuel costs, CO2 and other emissions from the vehicle fleet. Euro 6 is a very good emissions standard, but this standard is only specified for “lorries” in the application. The main vehicle type in use at the construction sites is not just those classified as lorries and there appears to be no commitment to meeting a minimum level of emissions standard for other vehicles or plant/equipment. As part of Thames Water’s commitment to implementing best practice measures at the construction site, the Council would expect firmer commitments in this respect. As a minimum the Council considers that supporting information should be provided to show that vehicles being used on the sites meet the required

We have committed to complying with the GLA Best Practice Guidance on The control of dust and emissions during construction and demolition. The SPG has more stringent controls on non-road mobile machinery. We will follow this SPG (as stated in the CoCP).

We will consider the request to amend text in para. 5.2.1 of the CoCP Part A relating to the Freight Operator Recognition Scheme, moving from silver at the start of construction, progressing to gold within two years.



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level of performance in terms of emissions.

7.21 Paras 5.2.4 to 5.2.6 details arrival, parking and despatch arrangements for lorries. The council considers that as a minimum there should be an explicit commitment that no vehicles will be allowed to park on the highway or site with their engines running unnecessarily, in order to minimise emissions.

This measure is contained in the CoCP Part A para 5.2.4: There will be no parking of lorries on the highway in the vicinity of any worksite for lorries waiting to deliver or remove materials from the site, except in specified areas identified in the applicable travel management plan.

Para. 5.2.1 states that: “Measures to be considered for limiting emissions and avoiding nuisance will include the following:

a. ensuring that the engines of all vehicles and plant onsite are not left running unnecessarily”

7.22 The council considers that there is a significant omission in the application with regard to future proofing and best practice measures going forward. Given the prolonged nature of the construction project (5+ years) the Council considers that the CoCP fails to ensure that best practice measures are implemented for the lifetime of the project, not just in the early part. The council considers strongly that what is regarded as best practice at the moment may be superceded by improved policies and practices within a couple of years. Requirements need to be put in the Code of Construction practice to ensure that up-to-date measures are used on construction sites for the duration of the construction phase.

We do not agree that this is an omission within our documentation.

We do, however, agree that the future-proofing of best practice is important. This is covered in the CoCP Part A Section 7.2, where we state that the most recent version of the GLA best practice guidance The control of dust and emissions during construction and demolition would be complied with and any subsequently published versions.

7.23 Para 5.6.1 to 5.6.6 relates to use of the river to transport materials. As a minimum the Council considers that a requirement is put in place to maximise the use of river transport to ensure emissions from road traffic are minimised. A commitment on the emissions performance of the river transport to be used for the project should also be required to ensure we are not substituting emissions from relatively clean

See our response to para. 5.36. Also, in addition to commitments set out in the Transport Strategy, we will require contractors to transport all specified materials by river, subject to approved derogations. If derogation is implemented without a valid approval, contractor costs will be disallowed. There are also incentives to encourage contractors to commit to the movement of additional materials, not specified in the Transport Strategy, by river.



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vehicles with high emissions from boats/shipping. Statutory regulations relevant to the movement of materials by river as part of the project would be adhered to.

7.24 This Section outlines the broad approach to be taken to limit emissions from vehicles and plant/equipment and to control dust emissions from material handling. The GLA’s Best Practice Guidance (BPG) on Controlling Dust and Emissions from Construction and Demolition is referenced. The council considers that the following documents should also have been used in developing the approach to managing air quality impacts: the GLA Air Quality Strategy and the annual LB Hammersmith and Fulham Air Quality Reports.

As per the provision in the CoCP Part A, local authorities would approve the air quality management plans. Through this mechanism they will be able to ensure that relevant guidance is taken into consideration (including annual air quality reports).

7.26 The GLA’s BPG document is the most appropriate guidance to follow in developing suitable mitigation measures to manage projects such as this. However, it is about to be updated, so we need to ensure the most recent version is used to guide the measures proposed in any CEMP/air quality management plan. In terms of monitoring, the broad proposals seem reasonable, although specific details of how much monitoring will be undertaken, which methods will be used, where monitors will be located, how trigger levels will be set are not covered in this document and will need to be covered elsewhere as full details are not provided in this document.

The GLA’s Best Practice Guidance is referenced in Section 7.2 of the CoCP. The most recent version of the guidance would be followed. The local authority would be consulted on full details of the monitoring specifics as part of the air quality management plan, as detailed in Section 7 of the CoCP Part A.

7.27 There does not appear to be any intention to carry out an assessment of the potential impact on local NO2 levels. Given the high number of vehicle movements expected as part of the daily site activities, the likelihood that specialist plant/equipment will be in use on the sites, which could have higher emissions than conventional vehicles, there could be an increase in local NOx emissions. Therefore, NO2 should form

The air quality assessment in the ES includes an assessment of construction traffic, construction plant and equipment and, where appropriate, barges. Emissions of nitrogen dioxide (NO2) and particulate matter (PM10) from these sources were predicted using detailed dispersion modelling. The assessment methodology is described in ES Vol 2, Section 4 and the results for each site in Section 4 of Vols 4, 5 and 10, for Acton Storm Tanks, Hammersmith Pumping Station and Carnwath Road Riverside,



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part of the air quality assessment in addition to dust/PM10. respectively. NO2 monitoring is ongoing, and will continue. This will be included in the air quality management plan for local authority approval.

7.28 “The council has significant concerns about the implementation of the mitigation measures as most of the mitigation measures are included in the Code of Construction Practice and design principles. The requirements within the Development Consent Order refer to these two documents; however neither the Code of Construction Practice, nor the design principles are part of the Order. They are non-statutory documents and therefore their implementation is not ensured. All mitigation measures must be included in the Development Consent Order”.

The draft Mitigation Route Map (Doc ref: 9.07) sets out how all mitigation is secured. Many items are secured through the project-wide Requirements that draw the CoCP and design principles into the DCO. The CoCP is secured by both Requirement PW6 and site-specific Requirements. The Requirements are clear that the undertaker must comply with the documents, save where the local authority agrees otherwise. The Planning Act 2008 (Section 161) requires compliance with Requirements and the terms of the DCO generally (Section 160). Thus the documents are drawn into the DCO by reference in the Requirements, in the same way that the approved plans are drawn into the DCO by virtue of Schedule 2. The DCO is a statutory instrument and it would not be appropriate for the wording of the CoCP and design principles to be included in the actual DCO, hence the approach above has been adopted.

See our response to first written question 6.73.

7.29 The Environmental Assessment Methodology (DOC ref: 6.2.02) does not contain the most up-to-date information and data from Defra with regard to emissions. This has resulted in inconsistencies and errors in the applicant’s assessment of Air Quality.

Department for Environment, Food and Rural Affairs (Defra) releases new background concentration data for NO2 and PM10 on an annual basis, based on the most recent year of monitoring data. The air quality assessment was completed in 2012 based on up-to-date background data provided by Defra at the time. The emission factors have not changed significantly since that time. We agree that using these data may lead to an underestimate at some sites. Sensitivity analysis as carried out subsequently to adjust future year NO2 concentrations based on monitored trends. See our responses in relation to Acton Storm Tanks, Hammersmith Pumping Station and Carnwath Road Riverside, below, for further details. We consider that the PM10 results in the

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ES are unlikely to be affected by the more recent data.

7.32 Para 4.5.20 notes that emissions from road vehicles were assessed using Defra’s emissions factor toolkit (2012 version). Defra has since released an updated emissions toolkit (January 2013) which should be used for the assessment. As for the updated background maps, a sensitivity check should be carried out to see if any revisions of the assessment is now required due to the changes in emissions factors.

The air quality assessment was completed in 2012 based on emission factors provided by Defra at the time. Vehicle emission factors were obtained from the Emission Factor Toolkit version 5.1.3 (2012). Defra subsequently released another version of the toolkit (version 5.2) in January 2013. It should be noted that there are no major changes in the emission factors between the two versions. It is notable that NO2 and PM10 factors in both versions are identical. The versions differ insofar as the latter version (version 5.2) incorporates advanced input and output options allowing advanced users to provide user-defined euro compositions and alternative technologies within the vehicle fleet. It also allows the output of relative percentage contributions from each of the euro classes. None of these minor changes would affect the emission factors in the air quality assessment. Therefore, no revision of the assessment is considered necessary.

7.33 Paras 4.5.47 – 4.5.53 details the method followed in assessing emissions from river transport. The council considers that it is highly inadequate as it seems that this particular aspect of the air quality assessment is based largely on assumptions about the barge emissions rather than actual data. There is therefore an element of uncertainty and emissions could be under-predicted. Further work on this is essential to make this aspect of the assessment sound.

The air quality assessment for river transport was undertaken based on the guidance provided in the European Environment Agency, European Monitoring and Evaluation Program Corinair Pollutant Emissions Inventory Guidebook. Default emission factors given in the guidance are derived from marine emission inventory studies in Europe and include actual measurements, data from engine manufacturers, vessel movements and characteristics data and expert experience. The assessment is also based on project information regarding the likely vessel fleet and activity based on construction tunnelling rate and volume of materials required to be moved at each site.

7.34 Section 4.6 concerns the assessment of potential operational impacts. This is limited to the assessment of odour. The council considers that the assessment is not adequate as it

Anthropogenic NOx/NO2 and PM10 are typically generated during combustion processes. During the operational phase of the project, neither the active nor the passive control air treatment

http://www.eea.europa.eu/themes/air/emep-eea-air-pollutant-emission-inventory-guidebook

http://www.eea.europa.eu/themes/air/emep-eea-air-pollutant-emission-inventory-guidebook



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only appears to consider odour as a potential air quality impact once the tunnel is operational. The council cannot find any information in the documents that has shown how or why NOx/NO2 and PM10 can be scoped out as potential emissions from the vents. This omission needs to be addressed if the assessment of the operational impacts is to be considered sound.

plants would involve any combustion. In general, the ventilation plant would only involve extraction fans and/or carbon filters. Therefore, no emissions of these pollutants are expected from the vents at each site. Emissions from the tunnel would be of sewerage nature; odorous emissions are anticipated and were assessed in the ES.

7.35 This Section outlines the scenarios being considered as part of the air quality assessment. In terms of the operational phase, only odour appears to form part of the assessment, although it states “the odour assessment would look at emissions during operational scenarios”. The council considers that it is not explicitly stated that NO2 and PM10 will be assessed as part of operational assessment. This needs to be rectified.

We proposed scoping out NO2 and PM10 in the Scoping Report which accompanied our request for a scoping opinion, which was sent to all local authorities on 7 March 2011. No response was received from LBHF.

7.36 Section 9 states that gaps in air quality data gathered from local authorities would be supplemented with 6 months worth of NO2 diffusion tube monitoring and that monitoring of particulates would take place “at higher risk sites” in the 12 months prior to construction. The council’s understanding of the commitments given in the Code of Construction Practice documents was that 12 months of monitoring would be done for both NO2 and PM10. The higher risk sites are not defined in this section, but we would expect all 3 sites (inc Acton Storm tanks) of concern for LB Hammersmith & Fulham to be classified as such, so background monitoring should be taking place for both NO2 and PM10 at Acton Storm Tanks, Hammersmith Pumping Station and Carnwath Road sites. As a minimum, we would expect the full 12 months of monitoring to be undertaken, as committed to in the CoCP.

The CoCP states that 12 months of background monitoring would be undertaken, where required, unless agreed otherwise with the local authority.

If the Council requires 12 months of background monitoring, then this is committed to within the CoCP.



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7.37 This summarises the potential issues as being: dust/PM10 impacts during construction, emissions from construction plant and transportation and odour from the ventilation column once the tunnel is operational. As well as odour, the Council would also consider that there could be a risk of NOx and PM10 emissions from the ventilation shafts when operational (until we see evidence to the contrary). This issue should be investigated further and supporting information submitted for consideration by the Council.


7.38 Throughout the air quality related documentation there seems to be an inconsistent approach on monitoring as some of the proposed construction sites have site-specific information on monitoring, but others do not, even when there are sensitive receptors in close proximity to proposed sites. All sites with residential and other potentially sensitive sites adjacent to the proposed construction sites should have site-specific proposals in terms of monitoring. For example, Cremorne Wharf (in the Royal Borough of Kensington & Chelsea) has real-time monitoring of particles down as a site-specific requirement even though it does not appear to be any more sensitive a site in terms of potential impacts than the 3 sites in Hammersmith and Fulham. At Chambers Wharf (Southwark) there is a site-specific requirement for baseline monitoring of PM10 and NO2 to be undertaken for a minimum of 12 months, prior to the works commencing. The council considers that, as a minimum, a a similar commitment from Thames Water should have been included for all 3 of the H&F sites – ie, 12 months worth of baseline monitoring.

Throughout the last three years, we have engaged with local authorities on the content of the CoCP, including site-specific requirements to be included in the Part Bs. LBHF has not previously indicated what it requires in the CoCP Part B.

The measures in the CoCP Part A are reinforced in the CoCP Part B at sites where requested bylocal authorities, eg, at sites where they would definitively require the minimum 12 months of baseline monitoring.

If LBHF would like this to be added to the CoCP Part Bs for the sites within the borough, then this can done.

In the next draft of the CoCPs, text will be added to the CoCP Part Bs Section 7for sites in the London Borough of Hammersmith and Fulham as follows: “Baseline monitoring of PM10 and NO2 to be undertaken for a minimum of 12 months, prior to the works commencing”.

7.39 There are a number of documents relating to Air Quality that deal with similar issues. As a result, establishing the

The air quality assessment is contained in ES Vols 2 to 27, Section 4. The CoCP (Part A, Section 7) contains measures to mitigate air



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chronology of which documents were produced when and whether or not information in one document supercedes information provided in another is very difficult to ascertain. This inconsistency is a fundamental flaw of the application as it makes it very difficult to make a sound assessment of the information for the purposes of this Local Impact Report.

quality impacts and the approach to monitoring of air quality, while the Air Management Plan (Doc ref: 7.14) contains details on the ventilation strategy. All of these documents were produced at the same time and support each other.

7.40 The applicant’s Air Management Plan is inadequate. It is not consistent with the ventilation strategy and does not include sufficient information on the potential release of pollutants.

This Air Management Plan describes the ventilation and air treatment systems to control the air released from and flowing into the tunnel under the operational scenarios under all expected weather conditions. The plan demonstrates how the air management plant would operate to control and treat air exhausted from the tunnels such that any malodours are either not perceivable or negligible, within Environment Agency standards. The Air Management Plan contains our ventilation strategy.

Air quality management plans (CoCP Part A Section 2 and 7) would be prepared by the contractor to include details of dust and air pollution control measures, vehicle and plant emissions and odour during the construction phase.

Active ventilation plant is proposed at six locations (Acton Storm Tanks, Carnwath Road Riverside, Greenwich Pumping Station, Abbey Mills Pumping Station and two at Beckton Sewage Treatement Works) to provide the required tunnel ventilation. At Hammersmith Pumping Station, only seven hours of emissions are anticipated over a year so passive ventilation with carbon filters to remove odour is sufficient. All air releases at passive sites would be treated through carbon filters.

7.41 Para 2.1.4: The Air Management Plan (AMP) defines how air from the proposed Thames Tideway Tunnel project is vented into and out of the tunnel system and how air releases will be controlled and treated. The focus of the AMP is to control and

See above comment on 7.34.

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limit nuisance odour impacts. There is no consideration given to other pollutants possibly being released from the ventilation shafts.

7.43 The council considers that it is a significant oversight by the applicants that most shafts have not been designed to have active air treatment systems integrated. Acton Storm Tanks and Carnwath Road sites are to have active control systems, but not Hammersmith Pumping Station, despite its location adjacent to sensitive receptors.

See our response above to para. 7.40.

7.45 Para 3.3.6: At passive sites (ie, Hammersmith Pumping Station), all released air would be treated by passing through the carbon filters. It is not clear from the application details, including the AMP whether there could be releases of pollutants such as NOx and PM10 from the vents. It is also not clear whether the planned air management processes deal with these pollutants. There is no information on this aspect of the potential air quality impacts which needs to be rectified.

As explained in our response to para. 7.34, no combustion processes would occur within or vent into the tunnel to generate emissions of NOx or PM10; therefore no mitigation is required for these pollutants.

7.46 The Thames Tideway Tunnel, as with any major development within the Borough, will need to comply with the Council’s Development Management Local Plan Policy on air quality (DM H8) which requires all major developments to provide an air quality assessment that considers the potential impacts of pollution from the development on the site and on neighbouring areas, requiring mitigation measures to be implemented to reduce emissions, particularly of nitrogen oxides and small particles, where assessments show that developments could cause a significant worsening of local air quality. At present, the information provided by Thames Water is not adequate to make a proper assessment of compliance with this policy.

The air quality assessment in ES Vols 4 (Acton Storm Tanks), 5 (Hammersmith Pumping Station) and 10 Carnwath Road Riverside) Section 4 of the ES assesses the air quality effects of construction, including nitrogen oxides and small particles, on the local area. Measures to reduce emissions are contained with the CoCP Part A, Section 7.

The ExA has advised that policies of a general nature which cover topics already addressed in the NPS are unlikely to be important and relevant. Site allocations and site-specific designations and guidance are more likely to be important and relevant. We direct LBHF to paras. 3.7.3 and 4.11.4 to 4.11.8 of the NPS, which we have adhered to and addressed in the application.



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7.47 The London Plan policy on Improving Air Quality (Policy 7.14) requires major developments to be at least ‘air quality neutral’. The AMP does not include any information on this and at present, the information provided by Thames Water is not adequate to make a proper assessment of compliance with this policy.

The Air Management Plan describes the ventilation and air treatment systems to control and treat air exhaust from the tunnels. The assessment of air quality and odour effects is contained in Section 4 of ES (Vols 4, 5 and 10 for sites of relevance to LBHF). Overall, no significant adverse effects are predicted at Acton Storm Tanks, Hammersmith Pumping Station or Carnwath Road Riverside, during construction or operation. Therefore we consider that the proposals comply with this London Plan policy.

7.48 Although the air quality assessment has considered NO2 and PM10 during the construction phase, the information provided so far is not adequate. Also, these pollutants have not been included in the operational phase assessment. Further work is therefore required to show that the impacts of the development, both during construction and operational phases, have been properly assessed. Without this additional work, the Air Management Plan is considered to be unsound.

Emissions of NOx and PM10 would increase during the construction phase and these were assessed in the ES, and mitigation is detailed in the CoCP). We consider that the assessment and mitigation represent a robust approach.

Emissions of NOx and PM10 are not expected to increase during the operational phase as there would be no increase in traffic nor any combustion processes occurring due to the tunnel. Therefore these were not assessed in the EIA. The Air Management Plan covers the operational phase and does not discuss construction phase emissions.



7.50 “In terms of site lay-out, no site-specific information is provided, it just states: “As per text in CoCP Part A”. Given the close proximity of sensitive receptors (ie, nearby local residential areas), further details on the site layout should be provided.”

See our response to para. 7.60.



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7.51 “In terms of vehicle and plant emissions in Section 7 of the CoCP, no site-specific information is provided, it just states “As per text in CoCP Part A”. For the dust/emissions control section, reference is made to agreeing locations and data provision only with Ealing and Hounslow councils, not Hammersmith & Fulham. The focus of monitoring appears to be Greenend Rd in Ealing. For the dust/emissions control section, reference should also be made to agreeing monitoring locations and data provision with LB Hammersmith and Fulham council as Emlyn Gardens is in our borough and is directly adjacent to part of the Acton site. This is also the case for the residential flats on Warple Road. These areas should also be considered when developing the monitoring programme as there is potential for impacts on a high number of sensitive receptors here as well as in Greenend Rd, Ealing.”

Measures to reduce vehicle and plant emissions would be applied at each project worksite and are contained in the CoCP Part A, Section 7.

The dust/emission monitoring was agreed with the London Borough of Ealing during meetings to discuss the development of the CoCP. LBHF chose not to engage at these points; however we would be happy to discuss and agree dust emissions monitoring locations and dust provision and included in the CoCP Part B. The full details of the monitoring specifics will be consulted with the local authority as part of the air quality management plan, as is detailed in Section 7 of the CoCP Part A.

7.52 “The ES (Vol 4 Acton Storm Tanks Site Assessment) does not contain information on other pollutants that could be emitted from the tunnel. As a minimum, the identification and assessment of all potential pollutants by the applicant is required.”


7.53 “Para 4.1.3: “Local air quality effects are not assessed during operation on the basis that the only relevant operational source of air pollutants would be from the infrequent visits of maintenance vehicles which would not result in a significant effect”. If this is because the ventilation shaft will only ever serve as an intake, during operation of the tunnel, thereby preventing emissions to air at this location, then scoping this out of the assessment is reasonable. If emissions could occur, which presumably could be the case when air is being released from the tunnel vents, then this potential impact should form




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part of the operational air quality impact assessment.”

7.54 “Paras 4.2.13-4.2.15: “The below ground air treatment chamber would have a total air treatment capacity of 20m3/s. Having been treated in the underground chamber, the air would be released from the ventilation column. When air flows are greater than 20m3/s, as could occur during a heavy storm, the excess air would be released through a bypass vent in the ventilation column. This would occur for about 15 hours during a typical year. During the typical year scenario, treated air would be released from the ventilation column for 99 per cent of the time. An active ventilation and air treatment plant would be included as part of the design. The air treatment units would remove any odours emanating from the tunnel”. The emissions from the ventilation shaft will be treated, but the focus is on odour abatement. The “air” being vented presumably could contain particulates and gases from within the tunnel. Further information on the emissions from the tunnel during operation should be provided and assessment carried out to show that there will be no detrimental impacts in terms of local air quality pollutants.”

It is unlikely that NOx or PM10 would be emitted from the ventilation column given that combustion processes would not occur within the tunnel. Odour emissions were assessed in the air quality and odour assessment in ES Vol 4: Acton Storm Tanks (Doc ref: 6.2.04, Section 4).

7.55 “The council also notes the reference made to “typical year scenario” and we would question why other scenarios have not been considered, including a worst case scenario. As a minimum, consideration should be given to what could happen in a worst case scenario.”

A ‘typical use’ year and ‘frequent use’ year were assessed. The results for the typical use year are in the ES (Vol 4, Section 4). The results for the frequent use year were generally found to be similar to those in the typical use year and are discussed qualitatively in the ES. The frequent use year would result in a greater number of hours of releases from the vents, but because the sewage in the stormwater would be more dilute, due to the larger volume of rainwater in the tunnel, the odour emissions would not be materially greater.

http://infrastructure.planningportal.gov.uk/wp-content/ipc/uploads/projects/WW010001/2.%20Post-Submission/Application%20Documents/Environmental%20Statement/6.2.04_Environmental_Statement_Volume_4_Acton_Storm_Tanks_Site_Assessment_Sections_1_to_15.pdf



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7.56 “The Construction Effects Assessment of the Acton Storm Tanks site forecasts that the construction phase will have a small impact on NO2 annual mean concentrations – ranging from 0.0 to 0.2 μg/m3. For PM10, no impact on annual mean concentrations was found in the assessment. No exceedences of the NO2/PM10 annual mean objectives are predicted and the Assessment determines that all impacts of the construction phase are negligible. For the Operational Effects Assessment, only odour has been assessed with no assessment of potential local air quality issues. As stated earlier, the assessment of the construction phase needs to be reviewed and updated and further information is required to show whether or not NOx/PM10 can be emitted from the ventilation stacks during the tunnel’s operational phase. If this is the case, then mitigation measures will need to be proposed to show that there will be no detrimental impacts.”


7.57 “The strategy for storing and handling materials is unclear and further mitigation measures are required to control the stockpiling of materials on site.”

Measures to control air quality, through control of dust and emissions, are detailed in Section 7 of the CoCP Part A.

7.58 “There are some large storage and material handling areas shown on the plan, but it is unclear how storage requirements for materials have been calculated. The council considers that, as a minimum, there should be a requirement that stockpiling of materials that could give rise to PM10 emissions is only allowed under cover. Storage areas should be located away from sensitive receptors wherever possible. Some of the proposed areas are close to residential properties along Warple Way.

“Material handling must also be minimised and any process that could cause dust and small particles to become airborne

The plans submitted showing construction phase storage arrangements are illustrative, but serve to demonstrate how the construction site may be configured. The size of areas set aside for storage is based on quantities of material needed to adequately service the construction process. The contractor may choose to configure the construction site in a different manner, but would be required to comply with the dust control measures stipulated in CoCP Part A Section 7.3 (Dust emissions) and Section 7.4 (Dust control). This process would be monitored in accordance with Section 7.5 (Dust monitoring).



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should be subject to mitigation measures, agreed in advance with the Council.”



7.59 The Code of Construction Practice (Part B – Site Specific Requirements) does not contain adequate information in relation to Hammersmith Pumping Station to effectively assess the impact of the Thames Tideway Tunnel on Air Quality.

See our response to para. 7.6, which sets out the basis for the assessment. The impact of the project on air quality is assessed in the ES. The CoCP outlines the control and mitigation measures.

When the contractor produces the air quality management plan (detailed in the CoCP Part A, Section 7), it would include the site-specific mitigation and control measures, and be for the approval of the local authority.

As noted in our response to para. 7.6, LBHF has not engaged in development of the CoCP to date. We would be happy to discuss site-specific amendments to Part B of this document.

7.60 In terms of site lay-out, no site-specific information is provided, it just states “As per text in CoCP Part A”. Given the close proximity of sensitive receptors, further details on the site layout should be provided.

This is not the purpose of this document. Section 1 of each CoCP Part B explains the purpose, which is to detail site-specific differences to the control measures outlined in Part A.

7.61 In terms of all headline issues in Section 7 of the CoCP, no site-specific information is provided, it just states “As per text in CoCP Part A”. Given the close proximity of sensitive receptors in the form of nearby local residential street (Chancellor’s Road) and potentially Frank Banfield Park, further details on the locations to be monitored should be provided.

The locations to be monitored would be agreed with the local authority in due course (see Section 7 of the CoCP Part A).

7.62 The ES (Vol 5 Hammersmith Pumping Station Assessment) See our response to para. 7.34.



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does not contain information on other pollutants that could be emitted from the tunnel. As a minimum, the identification and assessment of all potential pollutants by the applicant is required.

7.63 Para 3.3.2: “The drop shaft would be advanced in incremental cycles. After 1m has been excavated the primary sprayed concrete lining would be constructed. The concrete would be batched on site. Alternatively, concrete may be delivered by ready mix concrete truck”. To minimise emissions, concrete should be batched on-site, not delivered by truck.

There are advantages and disadvantages of on-site concrete batching for the sprayed concrete lining. Disadvantages include the space required on-site for material storage and noise from the batching plant. Advantages include the ability to supply concrete on demand and apply strict quality control measures. Given the specialist requirements for the concrete, we consider that flexibility should be retained until contractors have been appointed, in order to identify the most practical and optimum solution to achieve health, safety, environmental, cost and programme objectives.

7.64 Para 3.3.30: “The excavated material would be transported along the connection tunnel via an underground railway, up the drop shaft to a temporary stockpile prior to loading to lorry for onward disposal.” The council would question why material is being removed from site by lorry when it should be removed by barge given the proximity of the river to this site. Potential emissions from the barge movements would also need to form part of the Air Quality Assessment.

As part of the transport strategy development work in early 2012, local authorities, the PLA and TFL were involved in a number of workshops looking at the practicalities of river use at all sites. The assessment work concluded that although Hammersmith Pumping Station is close to the river, it is not practical to create a new river access along Chancellors Way and the required in-river infrastructure at this location.

Transport Strategy Section 6.3 sets out the rationale for areas where river usage is not proposed. However, as stated in para. 7.1.1 of the Transport Strategy, the strategy does not preclude any appointed contractor from increasing the use of river transport, wherever safe, practicable and cost-effective.

7.65 Para 3.3.36: Reference is made to the need for an air management structure on site during the construction process. This will comprise of “an above-ground ventilation structure, underground air treatment chamber, for ventilation control and

Odour emissions were assessed in the ES, taking into account the carbon filtration proposed. See our response to para. 7.34, which explains why there would be no other emissions during the operational phase.



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an electrical and control equipment”. However, emissions from this structure do not appear to have been included in the air quality assessment.

7.66 As for the Acton Storm Tanks site, “Local air quality effects are not assessed during operation on the basis that the only relevant operational source of air pollutants would be from the infrequent visits of maintenance vehicles which would not result in a significant effect”. The council considers that if emissions could occur, then it should form part of the operational air quality impact assessment.

Operational transport effects associated with maintenance vehicles would be infrequent and short-term. Therefore, these effects were scoped out of the assessment. It is expected that a light commercial vehicle would be on site every three months during the operational phase. This additional traffic (eight movements in a year) is very unlikely to have any significant effect on local air quality. There would be more substantial maintenance visits every ten years, which would involve two mobile cranes and support vehicles. This maintenance visit would be short-term with very limited number of additional traffic movements.

7.67 Paras 4.2.12-4.2.14: ”A ventilation structure would treat air released from the tunnel. The air would be treated by passing air through a carbon filter housed in a below ground air treatment chamber. Natural pressure during tunnel filling would allow air to pass passively without the need for fans. The capacity of the passive filter would be 0.5m3/s. The maximum air release rate during a typical year is expected to be less than 0.1m3/s, therefore all air in a typical year would be treated through the passive filter. No nuisance odours are therefore expected. Air would be released from the ventilation structure for less than ten hours in a typical year, all of which would have passed through the passive filter. For the remaining hours, no air would be released although air intake would occur as the tunnel is emptied. A carbon filter would be included as part of the ventilation structure design and construction. The passive filter would remove odours by adsorption onto the filter”.

As detailed in our response to para. 7.34, there would be no emissions of NOx or PM10 since no combustion processes would be incorporated in the tunnel ventilation system.



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7.68 The council is concerned that there is no indication as to whether the carbon filter integrated into the air treatment chamber that deals with odour could also reduce emissions of other pollutants such as particulates (PM10) and/or NOx. As for the Acton Storm Tanks site, further information on the emissions from the tunnel at Hammersmith Pumping Station during operation should be provided and an assessment carried out. If impacts are predicted, then mitigation measures will need to be proposed to show that there will be no detrimental impacts.

As detailed in our response to para. 7.34, there would be no emissions of NOx or PM10 given that no combustion processes would be incorporated in the tunnel ventilation system.

7.69 Para 4.4.8: States that monitoring took place at 5 locations around Hammersmith Pumping station between September 2011 and April 2012. This is a short period of monitoring that does not cover the summer months. Monitoring was undertaken form April 2011 to April 2012 at Acton Storm Tanks. All sites should be monitored for 12 months to establish good levels of data for current pollutant levels.

NO2 diffusion tube monitoring was carried out for a full year (between April 2011 and April 2012) at all project sites except for sites within the London Borough of Hammersmith and Fulham. There was a lengthy delay in obtaining a permit from the Council to commission monitoring. All short-term monitoring data was adjusted to annual mean concentrations based on trends monitored at other long-term continuous monitoring sites in London, in accordance with the methodology described in Defra’s Local Air Quality Monitoring Technical Guidance TG(09). Therefore the assessment baseline is considered robust.

7.70 The Construction Effects Assessment of the Hammersmith Pumping Station site forecasts that the construction phase will have a small impact on NO2 annual mean concentrations – ranging from 0.0 to 1.8 μg/m3. For PM10, projected impacts range from 0.0 to 0.4 μg/m3. Exceedences of the NO2 annual mean objective are predicted across most of the receptor sites assessed, although exceedences are predicted regardless of whether or not the Tunnel project goes ahead. Exceedences could be higher than predicted as the assumptions about background levels of NO2 (from Defra maps) could

The construction phase air quality assessment was completed in 2012 based on background data provided by Defra at the time. We agree that using these data may lead to an underestimation of effects at some sites. Sensitivity analysis was carried out subsequently to adjust future year NO2 concentrations based on trends from monitoring data. While annual mean NO2 concentrations would be higher than those presented in the ES, the analysis showed that the magnitude of impact from construction works, and the associated significance of effect, are unlikely to be changed. Air quality effects from PM10 emissions




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underestimate future levels of NO2 in the borough. No exceedences of the PM10 objective are forecast. For the Operational Effects Assessment, only odour has been assessed with no assessment of local air quality issues. As stated earlier, the assessment of the construction phase needs to be reviewed and updated and further information is required to show whether or not NOx/PM10 can be emitted from the ventilation stacks during the tunnel’s operational phase. If this is the case, then mitigation measures will need to be proposed to show that there will be no detrimental impacts.

presented in the ES would not differ. The predictions for NO2 using the alternative method led to higher concentrations compared with the Defra method at sensitive receptors.

As noted in our response to para. 7.34, no operational air quality effects are predicted as pollutants such as NO2 and PM10, which are typically generated from combustion processes, are unlikely to be emitted from the ventilation stack.

7.71 The strategy for storing and handling materials is unclear and further mitigation measures are required to control the stockpiling of materials on site.


7.72 There are some large storage and material handling areas shown on the plan, but it is unclear how storage requirements for materials have been calculated. The council considers that as a minimum there should be a requirement that stockpiling of materials that could give rise to PM10 emissions is only allowed under cover.

Storage areas should be located away from sensitive receptors wherever possible. Some of the proposed areas are close to residential properties along Chancellor’s Road. Material handling must also be minimised and any process that could cause dust and small particles to become airborne should be subject to mitigation measures, agreed in advance with the Council.




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7.73 The Code of Construction Practice (Part B – Site Specific Requirements) not contain adequate information in relation to Carnwath Road Riverside to effectively assess the impact of the Thames Tideway Tunnel on Air Quality.


7.74 In terms of site lay-out, no site-specific information is provided, it just states: “As per text in CoCP Part A”. Given the close proximity of sensitive receptors, further details on the site layout should be provided.


7.75 In terms of all headline issues in Section 7 of the CoCP, no site-specific information is provided, it just states “As per text in CoCP Part A”. Given the close proximity of sensitive receptors in the form of nearby local residential development (The Piper Building) and potentially the Hurlingham Club grounds, the river and South Park, further details on the locations to be monitored should be provided.

The locations to be monitored would be agreed with the local authority in due course (as detailed in Section 7 of the CoCP Part A).

7.76 The ES (Vol 10 Carnwath Road Riverside Assessment) does not contain information on other pollutants that could be emitted from the tunnel. As a minimum, the identification and assessment of all potential pollutants by the applicant is required.


7.77 Para 4.2.12 : “At the Carnwath Road Riverside site there would be approximately 9,000m3 of demolition material generated while the amount of amount of material moved during the earthworks would be approximately 785,500 tonnes. The volume of building material used during construction would be approximately 81,000m3”. The council considers that to minimise emissions, the use of barges for removal of material should be maximised in

Transport Strategy para. 4.1.2 sets out the key elements of the strategy regarding transportation of construction material by river. A target of 90 per cent of the following material would be transported by river, subject to derogations, at Carnwath Road Riverside:

a. main tunnel excavated material

b. shaft excavated material



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preference to using HGVs. c. sand and aggregates for the secondary lining.

7.78 Para 4.2.16: Reference is made to the need for a ventilation column on the site to treat air released from the tunnel. The air would be treated by an active ventilation plant consisting of below ground air treatment chambers each with fans within an above ground housing directing treated air to the ventilation column. Emissions from this structure do not appear to have been included in the air quality assessment. There is no indication if the air treatment chamber that deals with odour could also reduce emissions of other pollutants such as particulates and or NOx. Further information on the emissions from the tunnel during operation should be provided and assessment carried out to show that there will be no detrimental impacts in terms of local air quality pollutants.

Odour emissions were assessed in the ES, taking into account the filtration proposed. See our response to para. 7.34, which explains why there would be no other emissions during the operational phase.

7.79 The Construction Effects Assessment of the Carnwath Road Riverside site forecasts that the construction phase will have a small impact on NO2 annual mean concentrations - ranging from 0.2 to 1.4 μg/m3. For PM10, projected impacts range from 0.0 to 0.2 μg/m3. Exceedences of the NO2 annual mean objective are predicted at some of the receptor sites assessed, although exceedences are predicted regardless of whether or not the Tunnel project goes ahead. Exceedences could be higher than predicted as the assumptions about background levels of NO2 (from Defra maps) could underestimate future levels of NO2 in the borough. No exceedences of the PM10 objective are forecast. For the Operational Effects Assessment, only odour has been assessed, with no assessment of local air quality issues. As stated earlier, the assessment of the construction phase needs to be reviewed and updated and further information is required to show whether or not NOx/PM10 can be emitted from the




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ventilation stacks during the tunnel’s operational phase. If this is the case, then mitigation measures will need to be proposed to show that there will be no detrimental impacts.

7.80 The strategy for storing and handling materials is unclear and further mitigation measures are required to control the stockpiling of materials on site.


7.81 There are some large storage and material handling areas shown on the plan, but it is unclear how storage requirements for materials have been calculated. The council considers that, as a minimum, there should be a requirement that stockpiling of materials that could give rise to PM10 emissions is only allowed under cover. Storage areas should be located away from sensitive receptors wherever possible.

Some of the proposed areas are close to residential properties at the Piper Building. Material handling must also be minimised and any process that could cause dust and small particles to become airborne should be subject to mitigation measures.


7.82 It is noted that Thames Water's Site Suitability Report for Carnwath Road identifies the site as being less suitable for use as a main tunnel single drive and main tunnel reception/intermediate site from an air quality perspective. As identified above, this is due to the close proximity of residential properties which could be impacted by dust during the construction process. The report also recognises that there is potential for HGV movements on the local road network to cause localized air quality impacts in areas of already poor air quality.

ES Vol 10, Section 4 contains an assessment of construction dust and construction traffic emissions on air quality. Both these assessments considered the proximity of sensitive receptors to the pollution source. The assessment found that effects would be, at most, minor adverse (ie, not significant) for construction dust, with the implementation of best practice measures in the CoCP, and likewise minor for construction road traffic.

7.83 As outlined in our comments, the Council considers that inadequate consideration has been given to the potential impacts that the construction and operational phases could have on local

Impacts on local air quality were assessed in accordance with the assessment methodology contained in ES Vol 2, Section 2. Site-specific data is contained in ES Vol 10, Section 4, and



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air quality. There is a need for more site-specific data on impacts and details of the required mitigation measures.

mitigation measures are contained in CoCP Part A Section 7. We consider that this represents a robust assessment of likely significant effects.

6 Land contamination (Response to Section 8 of LIR


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6 Land contamination (Response to Section 8 of LIR)

6.1 General matters: Land contamination


8.3 – 8.4 All new developments are asked to consider the effects that historical land use may have on the surrounding area and the effects surrounding land use may have on them. The development of a site with a potentially contaminative history requires a full assessment of contamination on site, that which may already be migrating into the surrounding area and any that is migrating into the site from elsewhere. Only once this has been done, can any full assessment of risk be made and suitable remedial actions taken. The ES (Vol 2: Environmental assessment methodology) is not adequate as it does not take account of standard requirements and remediation procedure for both the construction and operational phases.

We have detailed a clear and robust approach which is summarised in each of the site-specific volumes of the ES (Section 8.2) and would be secured via project-wide Requirement PW6 on the CoCP Part A, with further details included in CoCP Part A Section 9. Site-specific contaminated land Requirements (eg, ACTST3) are set out in the Draft DCO. These Requirements require the production of a risk assessment, further site investigation as necessary, a site-specific remediation strategy and validation report.

We are currently reviewing these requirements with the Environment Agency and will take account of other representations.

8.5 Land Quality in Table 2.4.2 has been scoped out of the Operational Phase on the assumption that there are not anticipated to be any operational effects, ie, that all land contamination issues would be completed within the construction phase. However, there are several remedial strategies that would involve activity continuing into the operational phase of the development. Remedial techniques such as: Groundwater Pump and Treat, Air Sparging, in-situ Chemical or Biological Remediation, Reactive Barriers, Monitored Natural Attenuation and others, may require a long term monitoring or management programme several years long which would extend into the operational phase of the

This was done because the measures contained in the CoCP Part A (Section 9.2) and the site-specific contaminated land requirements would ensure that the site was ‘fit for use by year one’. This means that, even if there were ongoing remediation, it would not result in ‘likely significant effects’ during the operational phase. This distinction is important as there is a difference between an environmental assessment for the purposes of a EIA as opposed to a risk assessment. A risk assessment relies on more detailed information.

Scoping out of the operational phase was done in consultation with the Environment Agency.



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project. Long term remedial actions such as these may not be required, but the possibility cannot be discounted prior to proper assessment and investigation.

8.6 The council considers that the assessment and remediation of land contamination may extend from pre-construction into the operational phase Therefore, nominating a single year prior to final site assessment and remedial strategy being agreed in Section 3.5 may not accurately reflect the situation. Similarly, land quality issues may extend into the operational phase.

The approach is to assess the year when the greatest impact is likely to occur. For operational effects, see above response to para. 8.5.

8.7 The council is concerned that the assessment of effects (paragraph 3.7.7) only appears to consider effects directly connected with the construction phase. There is no consideration of legacy contamination from previous site use that may already be impacting on local receptors.


It is unclear what is meant by legacy contamination. Inevitably, contamination would be the result of previous activities we have assessed. Our assessment and sources of baseline data are explained in the ES and not repeated here.

A detailed risk assessment and remediation strategy would be prepared the contractor for each site to ensure that any legacy contamination is identified and dealt with accordingly. This process would be agreed with the local authority and Environment Agency in line with CLR11 (as detailed in the CoCP Part A Section 9.2).

8.8 The council is also concerned that the assessment of effects (paragraph 3.7.9) only appears to consider effects directly connected with the operational phase. There is no consideration of legacy contamination from previous site use or the effect of ongoing remedial actions.


8.9 Land quality effects are, by their nature, site-specific. The council has significant concerns that nowhere in Section 3 is a consideration of the effects that historic contamination may already be having on off-site receptors that need to be addressed to clear the potential Part IIa risk.

We detailed a clear and robust approach, which is summarised in each ES site-specific volume (Section 8.2) and would be secured via project-wide Requirement PW6, with further details included in Section 9 of CoCP Part A. There are site-specific, contaminated land Requirements (eg, ACTST3) in the Draft DCO. These require



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the production of a risk assessment, further site investigation as necessary, a site-specific remediation strategy and validation report. We are currently reviewing these Requirements with the Environment Agency and will take account of other representations.

8.10 The ES (Vol 2: environmental assessment methodology) is not adequate as it does not take account of the potential forland contamination to effect air quality, aquatic ecology, historic environment and groundwater.

See our response to 8.5 above. Cross-topic considerations including effects on and from land quality are integrated in the topic based assessments in the ES. The CoCP measures (Part A Section 9) require a full risk assessment and subsequent remediation strategy to be developed in consultation with the Council and Environment Agency. Application of these measures would ensure that sources and pathways for contamination to reach receptors are addressed and are not likely to result in significant effects.

8.11 The only assessment of potential effects of contamination on air quality across all sites (Section 4) appears to be at the Earl Pumping Station site where there are known naphthalene issues. In addition, the Council are concerned that the effects identified are only in regard to the construction phase, no consideration of potential for fugitive emissions or pre-existing emissions. In addition, potential releases of other volatile or other land sourced vapours and gases does not appear to have been anticipated. As a minimum the Council considers that a formal mechanism is put in place to ensure relevant information is passed into the air quality process from land quality.


Ground gas and vapour effects were assessed in the land quality sections of the site-specific volumes of the ES (Section 8.5). At Earl Pumping Station, there is evidence of gross contamination on the site, which has the potential to volatilise and impact local residents. No similar baseline has been identified elsewhere.

8.12 While not in H & F, the Council is concerned that soils at the Earl Pumping Station site are known to be contaminated with volatile hydrocarbons, principally Naphthalene and it is not clear in Section 4 whether assessments concerning vapour contributions from land contamination to internal and external air quality will form part of this work or as part of the Land

See our response to paras 8.10 and 8.11 above.



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Quality work outlined in Section 8. The council seeks clarification on this matter.

8.13 The potential for land contamination to effect local aquatic ecology does not appear to have been addressed. As a minimum, the Council considers that for sites sufficiently close to the Thames, an assessment of the potential for contamination to enter the river by direct or indirect means should be made and information concerning the potential contaminants provided for this assessment.

Effects on aquatic ecology were assessed as necessary in the ES. See our response to para. 8.10 above.

The consultation applied to the land quality assessment described in response to para. 8.5 also applied to aquatic ecology.

8.14 Table 5.5.1 Aquatic Ecology impacts on individual receptors, does not include the potential effects of land based contamination entering the aquatic environment directly or indirectly from sites in close proximity with the river.

Measures to control such effects are explained in each assessment of aquatic ecology under Review of proposed development – construction.

8.15 The council considers that there should be a formal mechanism in place to forward information gathered as part of this assessment, that could indicate historic industrial land use, into the land contamination process and vice versa.

The site-specific contaminated land Requirements in the Draft DCO and the measures described in Section 9.2 of the CoCP Part A are the formal mechanism for undertaking a risk assessment and developing a remediation strategy. Both of these mechanisms require us to seek approval for these documents with the local authority; this would involve sharing the content of the risk assessment and remediation strategy, including site information.

8.16 Groundwater contamination ‘in isolation’ is dealt with in Section 13, but it is not clear whether the possibility of contaminated groundwater affecting down gradient receptors is included in the assessment in Section 8. The council would like the applicant to clarify whether this has been included in the assessment.


8.17 The ES (Vol 2: Environmental assessment methodology) is inadequate as it fails to have regard to prescribed rules of engagement with Local Authorities, to provide adequate mitigation of dust and vapours and to take account of

See our response to paras 8.9 and 8.10 above and CoCP Part A Section 7 (Air quality).



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fundamental issues such as site history and characteristics.

8.18 Section 8 of the ES appears to regard the engagement with local authorities as having been completed and does not commit to making this an ongoing process. Other parts of the documentation for this application make it clear that local authorities are not expected to be involved again until a Remedial Strategy is submitted for approval. This is not in line with Environment Agency Model Procedure CLR11 which makes it clear that: “Meaningful dialogue with stakeholders is key to the successful outcome of risk management projects and essential2 in relation to regulators who have specific statutory duties and powers for health and environmental protection…” As a minimum, the applicant needs to provide an essential framework so that issues such as full stakeholder engagement are built into the process. The reasons why local authority input is necessary are as follows: • Remedial actions require the approval of the local authority • Compliance with Environment Agency Model procedure CLR11 • Local authority contaminated land officers often have additional local knowledge

See our response to para. 8.9 above and the commitment to follow the guidance in CRL11 in the CoCP Part A 9.2.1.

8.19 The council considers that the Land Quality Assessment (paragraph 8.1.10) is inadequate as it only considers mitigation of dust or vapours during construction, not pre and post construction and as we have already noted, there is the potential for remedial actions to continue into the operational phase.

See our response to paras. 8.5 and 8.9 above. The ES assessment considered impact rather than risk, seeking to assess the ‘likely significant effects’ of the development. This was completed for contamination, including vapors, in the land quality sections of the ES. Any pre- and post-construction impacts would be identified and addressed via the risk assessment – specifically the remediation strategy, validation plan and validation report.

8.20 Soil samples taken as part of a geotechnical site investigation should not be expected to provide representative information in regard to contamination. To provide useful information

The baseline presented in the land quality and groundwater sections relied on existing sources of information to provide a robust basis for the impact assessment. Geotechnical borehole records provide



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about land quality, investigations have to be targeted and based on an understanding of a sites history, both in regard to the sampling locations and the analysis suite used. Any Quantitative Risk Assessment and Remedial Strategy based on a geotechnical investigation alone is probably going to be unacceptable because of poor assumptions made at the start of the process.

precise site data. We also used historical maps, site visits, local authority records and any further site investigation data to generate a baseline. The level of data in some sites is not as detailed as that which would be presented in the subsequent risk assessment. It is, however, sufficient information for an EIA.

8.22 Paragraph 8.4.6: Commercial/Industrial assessment criteria will be suitable for the site itself, but will not necessarily be protective of sensitive neighbouring off-site receptors such as residential properties.

This would be further detailed through the risk assessment and remediation strategy process, the securing mechanisms for which are detailed in response to para. 8.9 above.

8.23 The conservative criteria in paragraph 8.4.7 are to be used only in regard to future on-site risks where relevant. It is usual to calculate site-specific remedial targets based on actual site conditions and risks. This will avoid a site being ‘over remediated’ and remedial actions being carried out where not required or to too high a standard.

This would be further detailed in the risk assessment and remediation strategy process, the securing mechanisms for which are set out in response to para. 8.9 above.

8.24 Paragraph 8.4.18: it should not be assumed that all land contamination issues will be dealt with in Site Year 1 of construction. It is possible that such issues may require remedial works to be started prior to Yr 1 and extend into the operational phase.

Some work may occur early in or prior to site year 1, such as site investigation or for sites known to be grossly contaminated. See our response to para. 8.9 above for clarification of the risk assessment, remediation and validation process.

8.26 Paragraph 8.4.21: This paragraph demonstrates the requirement for a proper site-specific investigation and risk assessment at the earliest stage in the development, but it fails to address the possibility that remedial processes may take time, months or years. It is possible for some long term remedial actions to be undertaken during and post construction.

It is possible that remedial actions may continue into the operational phase. This would be determined by the remediation strategy, as described in response to para. 8.9 above.

8.27 Paragraph 8.4.23: It is unclear how these pre-construction remedial measures can be robust and effective when there is




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insufficient information provided about the way in which the information to design them is to be provided.

8.29 Paragraph 8.5.2: In particular situations, the peak year for land quality effects may be construction year -1. In order to be robust and effective, some remedial options may require the site to be undisturbed until completion.

Site investigation would be undertaken during the detailed design phase, prior to year 1. If this indicates that extensive remediation is required this will be agreed with the local authority and Environment Agency as detailed in response to para. 8.9 above.

8.30 Paragraph 8.5.5: It is not clear whether this assessment includes the necessity for additional investigation or remedial works resulting from failures to properly assess the site. Clarification from the applicants is required.

A detailed risk assessment would be undertaken to inform the remediation strategy (see response to para. 8.9 above). The EIA looks at ‘likely significant effects’; this is an important distinction in terms of the detail required (see response to para. 8.20 above).

8.31 Paragraph 8.5.6: The assessment area should also include any off-site sources, pathways and receptors that could be affected by physical works and ground disturbance or by the introduction of new receptors, ie, site workers, or the creation of potential pathways to the principal aquifer at depth.

The risk assessment would include this.

In the ES we included a 250m buffer around the site in establishing our baseline. Our assessment does include an assessment of adjacent land users.

For effects on groundwater (including aquifers), we direct LBHF to ES Section 13. Again, the Council should consider that what we have undertaken to date is an EIA, not a risk assessment.

8.32 Paragraph 8.5.7: The development of a Conceptual Site Model is a progressive process, starting with a desk study identifying historic land use, local geology, hydrogeology etc. and then refining this by investigation, an iterative process if done properly. In normal circumstances, planning conditions will be imposed requiring approval of the Preliminary Risk Assessment (a report detailing the Conceptual Site Model and the potential risks to identified receptors). Subsequent conditions require prior approval of any Site Investigation Scheme based on the results of the Preliminary Risk Assessment, approval of a Quantitative Risk Assessment (the identified risks) etc. All these conditions are

Agreed. The ES reports on a very early stage in the development of the conceptual model. Subsequent risk assessments and remediation strategies would further refine this. The contaminated land requirements and CoCP Part A measures detailed in response to para. 8.9 above would require pre-commencement works, which could include additional site investigation.

We are currently reviewing these requirements with the Environment Agency and will take account of other representations.



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precommencement and require addressing before development can begin. Hammersmith and Fulham’s standard conditions may be found later in this text.

8.33 Paragraph 8.5.8: These assumptions must be made with regard to the intended as well as the current use of the site, ie, where a source, pathway and receptor will be present at the completion of the works.

This would be included in the site risk assessment; see our response to para. 8.9 above.

8.34 Paragraph 8.5.10 indicates that the applicants have used the standard methodology for assessing potentially contaminated sites, and, as outlined above most if not all the sites to be used for this project will have had a potentially contaminative history and will require the full land contamination process as outlined in CLR11 and similar documentation from preliminary risk assessment to remedial verification.


8.35 Paragraph 8.9.2: Because the sites selected are all located in historically commercial/industrial areas, it must be assumed that they will all require a preconstruction assessment. Has the time and resource for this activity been properly assessed? If insufficient assessment and investigation resources (temporal as well as financial) are available, construction may be delayed while the preliminary land contamination conditions are dealt with. Hammersmith and Fulham’s standard conditions may be found later in this text.

With respect time and resources, we believe that sufficient time and resources have been allocated. See our response to para. 8.32 above.

8.36 Paragraph 8.9.4 states that… Potentially contaminating land uses, which may have existed between the dates of the Ordnance Survey mapping may not reveal all historic contamination sources. Additionally, any contaminative land use not identified on Ordnance Survey maps (of which there are a great many in the Hammersmith area alone) will not be identified and assessed. Therefore the work already outlined can only be a preliminary step and a proper land

Agreed; see response to para. 8.9 above.



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contamination process will have to be undertaken for every site.

8.37 Paragraph 8.9.5: Based on the limitations already identified above, there is insufficient information to fully quantify risks and predict the remedial measures that may be required. This will probably cause delays in the land contamination management process because information about historical activities on and around the site which cannot be identified by map searches alone is required for the Preliminary Risk Assessment. A failure to provide a robust Preliminary Risk Assessment will prevent any further development actions until resolved.

The distinction between EIA and risk assessment is important here. See our response to para. 8.9 above.

8.38 Paragraph 8.11.1: Appears to accept that ongoing monitoring actions may be required to demonstrate the success/failure of a remedial action. The council questions why land contamination issues are to be scoped out of all but the construction phase of the project if this assumption has been made here.


8.40 The overlap between land quality and groundwater is significant. There is no inclusion (paragraph 13.1.5) of reducing current levels of pollution. While not enforceable, any opportunity to improve water quality (above or below ground) should be taken rather than just avoiding degradation.

The overlap between these two topics is clearly made in both the land quality and groundwater sections of the ES. Remediation of groundwater would be undertaken if identified in the remediation strategy. See our response to para. 8.9 above.

8.41 Local authorities should be regarded as stakeholders in the assessment of risks to groundwater, especially where the risks from contaminated groundwater are to human health etc. The Environment Agency should be regarded as the prime assessors of the effects of land contamination on groundwater, but the local authority has a place in the assessment of effects of contaminated groundwater on

The local authority will be considered in the risk assessment process as detailed in the response to para. 8.9 above.



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surrounding receptors other than controlled waters.

8.42 The location of geotechnical boreholes (paragraph 13.4.2) may not be adequate to properly assess groundwater quality with regard to land quality. While they may provide useful indicators of local roundwater quality, they will be of limited use to assess information regarding specific potential sources to feed forward into the design of a remedial strategy.

See our response to para. 8.9 above and the groundwater monitoring strategy (ES Vol 3 App K.1). This was updated in consultation with the Environment Agency and the latest version (Groundwater environmental management – dewatering and monitoring strategy APP21, submitted on 4 November 2013) is appended to our response to the Environment Agency relevant representations.

8.43 The Groundwater (desk based) baseline data sources in Table 13.4.1 are incomplete. As a minimum the Council considers that the applicant should include information from local authorities regarding historic land use and the likelihood of contamination.

The baseline data sources are complete. They are included in the land quality section of the ES (Section 8) and are not repeated in the groundwater section.

8.44 The council has identified the following omissions which need to be addressed by the applicant: • Table 13.4.2: Groundwater – receptor value/sensitivity/resource criteria. Does not include effects of contaminated groundwater on other receptors. • Paragraph 13.5.6: There does not appear to be any consideration of the effects of pre-existing contamination outside the construction phase. • Paragraph 13.5.10: There is no reference to where groundwater quality issues are assessed. • Paragraph 13.8.12: It is known that there is a hydraulic connection between the Thames and the shallow gravel aquifer. This should be included in the risk assessment process.

a. Table 13.4.2 relates to receptor sensitivity, not the impact (which would be the impact of contaminated groundwater on a receptor).

b. As detailed above (in response to para. 8.9 above) risk assessments, remediation strategies and validation reports would ensure that where contamination was considered, a risk it would be addressed.

c. Assessed in Section 13 of the project-wide and each of the site assessments.

d. Agreed; it will be.

8.48 The council considers that Appendix B of the ES (Vol 2: Environmental assessment methodology) is inadequate as it fails to address degradation in indoor and outdoor air quality resulting from land contamination by the escape of vapours

See our response to para. 8.9 and 8.10 above.

http://infrastructure.planningportal.gov.uk/wp-content/ipc/uploads/projects/WW010001/2.%20Post-Submission/Representations/ExA%20Questions/04-11-2013%20-%20Responses%20to%20ExA%20Questions%20Round%201/131104_WW010001_Thames_Water_Part_3.zip




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etc.

8.49 The council also considers that Appendix C of the ES (Vol 2: Environmental assessment methodology) is inadequate as it fails to address the potential for interaction between land contamination and ecological receptors.

We believe that Appendix C presents a robust and appropriate methodology for the assessment of effects on aquatic ecology as part of an EIA. Interactions with pollution sources form part of the assessment of effects on aquatic ecology; however, with controls in place as per Section 8 of the CoCP no source pathways have been identified which could give rise to likely significant effects.

8.50 The Scoping opinion and engagement for Land Quality laid out in Appendix F.1 is considered to be unsound. For example, the Technical Memorandum – EHO Position Paper – Land Quality, Section 19 Potential issues (constructional and operational phases) fails to include impacts from sites where an off-site effect on sensitive receptors is already occurring.

We are not clear on the point made by LBHF but consider that the approach presented is robust and appropriate for undertaking an EIA.

8.56 There does not appear to have been any proposal based on this information, other than to determine the best dredging technique for in-river works. There is also no source given for any of the soil screening values, nor is there any information regarding why these contaminants have been selected or why others are missing.

We would contest that it is inadequate and unsound. ES Vol 2 Appendix F.2 provides an overview of the results of sediment sampling at a level which allows an impact assessment to be undertaken. Further detail would be provided in the risk assessment (see response to para. 8.9 above). In addition, the sampling was undertaken to support the assessment of impacts on aquatic ecology and the source for the screening value is provided on p. 15. The reason for the selection of contaminants is provided on p. 14.

8.57 If these results are to be useful, a justification for the selection of criteria used and the substances analysed for has to be made, otherwise any decision made on the basis of this information may not be robust and the work may require repeating with the correct sampling regime in place. For example, if the reason for making this assessment was to assess the risks from various dredging methods, it would be argued that, either the analysis is required to determine

See our response to para. 8.56 above. In addition, see the assessment methodology in ES Vol 2, Appendix F2, p. 15.



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whether the material has to be treated as hazardous waste or to assess the risks to the local aquatic ecology. If this is the case, then different assessment criteria would be required and this sampling and analysis has been a waste of time and money.

8.59 The shallow gravel aquifer may not be regarded as an aquifer proper (see para13.2.9), but it is still a controlled water and protected by legislation. Groundwater quality cannot be ignored completely and an assessment of any degradation of quality or quantity must be made. This includes the effects of grouting or other chemical introduced into the aquifer as part of the construction process.

See our response to para. 8.9 above (controlled waters would be included within the risk assessment).

8.60 The Lambeth group may be in hydraulic continuity with the principal chalk aquifer at depth and any contamination entering the Lambeth Group may have a deleterious effect on this principal aquifer.


8.61 In response to paragraph13.4.23, the Council considers that pathways may also pre-exist where contamination is already having an effect on local receptors. As a minimum, the Council considers that an assessment of the magnitude of this risk must be made and remedial actions designed accordingly.


8.62 In response to paragraph 13.4.32, the Council considers that there is evidence of interaction between ground and surface waters in Hammersmith and Fulham. While this is very unlikely to affect the lower, chalk aquifer, it may permit contaminated groundwater to enter the River Thames. The potential for contaminated groundwater to enter the River Thames exists in the western reach of the Thames, but there does not appear to have been any assessment of this interaction here. The council considers that an assessment of

See our response to para. 8.9 above and measures in the CoCP Part A (Section 8). The scope of the project-wide assessment was agreed with the Environment Agency and published in our Preliminary Environmental Information Report at phase two consultation. LBHF made no such comment on the adequacy of the project-wide assessment at these points. We consider that the methodology presented is adequate and any site-specific issues would be addressed as per the response to para. 8.9 above.



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this interaction is an important element of the project-wide effects that has not been assessed and which should be included in this assessment.

8.64 Removal of hazardous soils should be considered a remedial activity and information about the fate of removed material should be produced. As a minimum the Council considers that WAC testing results, trip notes etc. will be required as part of the remediation verification requirement.

See CoCP Part A Section 10 and the process set out in response to para. 8.9 above.

8.66 Although the Environment Agency is the primary regulatory body as referenced in paragraph 10.4.1 with regard to the management of waste, local authorities will have some requirements of information (as above) which will need to be considered.

A site waste management plan would be developed for each site and be available for inspection.

8.67 The council is concerned with the proposed engagement with external bodies in paragraph 11.5. The need to engage with local authorities with regard to waste management activities, especially when they are the result of land contamination management, must be considered.


8.202 The Code of Construction Practice Part A is considered to be unsound as it fails to accord with the requirements set out in Part 11A of the Environment Act 1995.

Section 9.1 of the CoCP addresses this point, where full reference is made to the Environmental Protection Act 1990 (Part IIA) which came into force through the enactment of Section 57 of the Environment Act 1995.

8.204 Therefore Section 9.2.1, where the local authority appears not to be a consultee for land contamination issues may be regarded as failing in that intent.

Section 9.2.1 of the CoCP lists the local authority as an approving body. See our response to para. 8.9 above.

8.205 Our normal practice in relation to paragraph 9.2.3 is to agree actions in a staged, progressive manner, ie, Preliminary Risk Assessment then Site Investigation Scheme, etc. with each stage being approved before the next can be undertaken. This is to ensure that risks are identified and managed

Para 9.2.3 a) of the CoCP states that the strategy includes liaising with the local authority on how the work would be done; this seems to align with LBHF’s request. This liaison should ensure that the works align with LBHF’s expectations.



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properly. (see example conditions below).

8.206 Paragraph 9.3.3: The local authority and/or Environment Agency should be contacted at the point of discovery, not after risk assessments etc. have been undertaken. The council is concerned that this paragraph suggests that the local authority is a junior partner in the management of land contamination which is not and should not be the case with regard to the proposed Thames Tunnel project.

Para 9.3.4 indicates that the local authority is the prime contact, as it states that if any unacceptable risk is identified, it is the local authority that would agree the remediation, in consultation with the Environment Agency.

Further amendments to the wording of the CoCP will be considered.

8.207 The Code of Construction Practice Part B is completely inadequate as it merely refers to Part A and has no detail on land contamination.

Through engagement on the CoCP Part Bs with local authorities over a number of years, the purpose of Part B is explained (see Section 1 of all Part Bs). The purpose of the document is not to repeat the findings of the ES, it is to stipulate any site-specific differences in control and mitigation, compared to those that would generally be applied through the CoCP Part A.

8.211 The council has the following concerns with regard to land quality and remediation set within the Development Consent Order (DCO):

8.212 In all of these requirements, there is a major failing with regard to CLR 11, The Model Procedures for the Management of Land Contamination. CLR 11 recommends;

“Meaningful dialogue with stakeholders is key to the successful outcome of risk management projects and essential4 in relation to regulators who have specific statutory duties and powers for health and environmental protection…”


8.213 CLR 11 sets out a phased process, of which the Remediation Strategy is step 6 of 9;

Preliminary risk assessment




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Generic quantitative risk assessment

Detailed quantitative risk assessment. This is usually based on at least one intrusive site investigation, but often several, staged, investigations will be required for a complex site.

Identification of feasible remedial options

Detailed evaluation of options

Development of the remediation strategy

8.214 If consultation begins at step 6, it is possible that the regulatory body involved will not accept one of the assessments made at a preliminary stage. In the worst case, if the regulatory body feels that a risk has been underestimated or missed at stage 1 or 2, everything based on that will have to be reassessed, including Risk Assessments, Site Investigations, Options Appraisals etc. possibly incurring unnecessary delays and additional costs. Hammersmith and Fulham have a set of six land contamination conditions (see below) to try and avoid this problem. Therefore we would like these conditions, or similar conditions which require the sequential approval by the Council for each of these steps in addressing potentially contaminated land.


8.215 In line with CLR 11, there are 3 following steps,

Implementation design

Implementation and Verification of Strategy

Long Term Monitoring (if required)

There is no evidence to show that the undertaking to carry out works in accordance with the site-specific remediation strategy includes these requirements, which may extend after




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the construction phase of the project.

8.216 Again, the Specific Requirement does not require the inclusion of the regulatory bodies in any preliminary work prior to reviewing and approving the Remedial Strategy.


8.217 It is to be noted that other Specific Requirements have to involve regulators etc. at a much earlier point in the process, ie, all Archaeological Work requires the prior agreement of a Specific Archaeological Written Scheme of Investigation. This is obviously to ensure that these activities are carried out appropriately first time because of the difficulties going back to do them again. The same consideration should be made in regard to land quality issues, reinvestigating a site because agreement has not been sought on a site investigation scheme etc. wastes money and causes unnecessary delays.


8.218 It is understood that DCO requirements requiring the phased approach described in the last Section have been proposed by Thames Water to the Royal Borough of Kensington and Chelsea. Considering contaminated land is regulated on a bi-borough basis, it is anticipated that the requirements placed will be the same if not similar.


8.219 For reference, the Council includes below [not copied into Thames Water’s response] its standard contaminated land conditions which the Council considers should be considered by the applicant as potential requirements in the DCO in relation to land contamination. These conditions should be considered alongside the objections and observations in this section.




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8.103 The presence of a water supply noted in paragraph 3.3.16 requires that ground conditions are examined with regard to the potential for contamination. Some mobile contaminants can penetrate plastic water supply piping and may require the excavation of clean corridors for services or the particular types of supply piping.


8.104 The requirement for any remedial activity (paragraph 3.3.17) will follow a full review of the Preliminary Risk Assessment and probably involve a site investigation prior to making a Detailed Risk Assessment on which the needs of any Remedial Strategy can be based. To comply with the recommendations of Model Procedure CLR 11, close engagement with the local authority is essential. A suitable Remedial Strategy may include ongoing works that may impact on the main construction work. As has been described earlier, suitable remedial options may continue through pre-construction, construction and into the operational phase of the development.


8.105 Paragraph 4.1.2: It is possible for air quality to be affected by pre-existing land contamination in the form of vapours etc., which may impact on site users and off-site receptors. This does not appear to have been included in this assessment. The assessment is focussed almost entirely on combustion generated gases and odours. The assessment should be reviewed to include this information.


8.105 Paragraph 4.1.2: It is possible for air quality to be affected by pre-existing land contamination in the form of vapours etc.,




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which may impact on site users and off-site receptors. This does not appear to have been included in this assessment. The assessment is focussed almost entirely on combustion generated gases and odours. The assessment should be reviewed to include this information.

8.106 There is some indication that the secondary gravel aquifer and the River Thames are hydraulically connected which may permit contaminants from on-site sources entering the river. Therefore, the potential for contaminants mobilised by construction or other on-site activities to enter the river with a deleterious effect to the neighbouring ecology should be considered.


8.108 Paragraph 8.2.3: The removal of contaminated made ground may constitute a remedial activity which would need agreement with the local authority and suitable reporting etc.


8.109 Paragraph 8.2.10: Measures a. and b. should be agreed sequentially with the local authority, including prior agreement of site investigation schemes, in line with the normal planning conditions placed by the Council within whose boundary works are taking place. Hammersmith and Fulham’s standard conditions may be found later in this text.


8.110 Paragraph 8.4.7: It is not clear how and where the site-specific information has been obtained, is it from a targeted investigation based on current and historic land use on and off site or as a part of the generic geo-technical investigation? It is also not clear whether a suitable investigation regarding influent and effluent groundwater or gases/vapours has been undertaken in line with best practice or relevant guidance. For relevant guidance, see below.

See ES Vol 2 appendix F and response to para. 8.9 above..



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8.111 Paragraph 8.4.9: The council is concerned as to whether an assessment has been made of the risks of on-site contamination entering the River Thames via groundwater.

This is an EIA not a risk assessment. See our response to para. 8.9 above.

8.112 Paragraph 8.4.11: Evidence of previous remedial efforts would have to be in the form of Verification reports accepted by LB of Hammersmith and Fulham.


8.113 Paragraphs 8.4.12/13/14: It is not clear whether these observations are the result of a properly targeted environmental site investigation or as a result of the geotechnical investigation.


8.114 Paragraph 8.5.1: A discussion regarding the adequacy of the current understanding of the risks from land contamination on site users and off-site receptors should be entered into with the local authority prior to further investigation and risk assessment taking place.

See our response to paras 8.20 and 8.9 above. Again this is an EIA not a risk assessment.

8.115 Paragraph 8.5.2: Before any remedial actions can be accepted by LB Hammersmith and Fulham, the preliminary risk assessment, site investigation proposal(s), quantitative risk assessments, remedial options appraisals and remedial strategies would have to be agreed sequentially. There would also be a requirement for a verification report and, if required, proposals for ongoing monitoring for an extended period.


8.116 Paragraph 8.5.3: The council would like the applicant to clarify what is meant by ‘some contamination is considered to be present’ in the context in which it is being used.

This is a baseline assumption for the purpose of undertaking an impact assessment. Further investigation and risk assessment will be undertaken. See our response to para. 8.9 above.

8.117 Paragraph 8.5.4: The sequence of remedial actions required should not be fixed until a better understanding of the site is available.




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8.118 Table 8.5.1: It is possible for on-site contamination to impact on adjacent land users through transport via groundwater and this risk should be included in the source-pathway-receptor summary.

This is an EIA assessment not a risk assessment. The preliminary conceptual model is high level and intended to identify ‘likely significant effects’ not all risks. See our response to para. 8.9 above.

8.119 Paragraph 8.5.11 States that The management of contamination at the site is a two stage process, the first stage comprises the assessment, quantification and, if necessary the removal of the main contamination sources which could impact on construction worker health. The council considers that it is not always necessary to remove contamination sources to successfully manage risks. If it can be done safely, it may be better to leave contamination in-situ and reduce traffic movements, volumes sent to landfill etc. Other remedial measures are also available

This will be addressed through the risk assessment and remediation strategy. See our response to para. 8.9 above.

8.120 Paragraph 8.5.18 States that Impacts on adjacent land-users could occur via excavation and exposure of previously unidentified contaminated soils. This contamination could then migrate onto neighbouring sites. The pathways via which the contamination could migrate are: wind-blown dust and valour diffusion. This assessment fails to identify a potential pathway off-site via contaminated groundwater.

See groundwater assessment and also response to para. 8.118 above.

8.121 Paragraph 8.5.19: There are no apparent proposals to deal with pre-construction impacts on adjacent land users from on-site contamination. A properly constituted Preliminary Risk Assessment would identify existing (pre-construction) risks that may require mitigation.


8.122 Paragraph 8.5.22 States that Based on the assessed impact magnitude and receptor sensitivity, we consider that the proposed development would result in a negligible effect on

This is an EIA assessment and the likely significant effects are considered with the assumption that the embedded mitigation (risk assessment, remediation strategy and verification report) would



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the adjacent light industrial/commercial land users and Thames Path users and recreational land-users such as those within the Frank Benfield Park and a minor adverse effect on the adjacent residential land-users (although the effect is defined as minor adverse, it is considered unlikely that the effect would occur). The council considers that more evidence is required to support this statement.

ensure that there were no impacts.

8.123 Paragraph 8.5.25: The potential for land contamination to interact with new on-site water mains etc. should be assessed.


8.124 Table 8.10.1: Following on from the point above, health effects on adjacent land-users from exposure to contamination entering water supply pipes should be considered. The significance of the effects following the detonation of UXB cannot be regarded as negligible. It is the probability which is important in this type of assessment As with the footnote regarding minor adverse effects that …Although the effect is minor adverse, it is unlikely that the effect will occur. In the case of the detonation of UXB, the significance of the effect is still severe, but the probability is low and further reduced by the measures outlined in paragraph 8.5.26.

This is an EIA, not a risk assessment.

8.127 Paragraph 13:3.21 States that Groundwater level data available for this assessment is limited, with monitoring data available from two boreholes within the upper aquifer, both of which are located to the northwest of the site. The council considers that Hydraulic gradients and groundwater flow directions may have a critical bearing on the need and type of remedial actions required to manage contamination issues on this site. With this in mind we would like to see a suitable site




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investigation proposal that includes proposals to seek information about groundwater flow, both direction and gradient. This will allow a full assessment of the risks to site and neighbouring properties from current and historic land uses.

8.128 Paragraph 13.3.23: The limitations identified above means that the conclusions cannot be regarded as robust.

The conclusions can be considered sufficiently robust for an EIA with the understanding that embedded mitigation, as detailed in response to para. 8.9 above, would be implemented.

8.129 Paragraph 13.4.17: The information gleaned from a single borehole cannot be assumed to give an accurate picture of the groundwater quality over the whole site. Without information regarding the groundwater flow, it will be impossible to determine whether the identified contamination is coming from off-site or from an on-site source.


8.130 Paragraph 13.4.19: The presence of this contamination may have much wider consequences than the disposal of pumped water and requires a full assessment and probably further investigation.


8.131 Paragraph 13.5.1: Although the risks posed by the main excavation is regarded as low, in terms of mobilising contamination, there are other works which may have not all been adequately assessed.


8.132 Paragraph 13.5.7 The statement The baseline groundwater assessment data shows minor groundwater in the upper aquifer on site… …A negligible impact on the upper aquifer, a medium value receptor, from the creation of pathways would result in a negligible effect is not necessarily backed up with information. The assessment as it stands cannot distinguish between on or off-site contamination. A properly designed




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site investigation is required to fully determine the types, severity and sources of contamination as well as determining potential receptors.

8.133 Paragraph 13.8.1: This statement requires a proper assessment of contamination and a detailed risk assessment. It also ignores the potential for land contamination on site already impacting local receptors.

See our response to para. 8.9 above. This would be undertaken as per our commitments in the CoCP and the DCO Requirements.

8.134 Paragraph 13.9.1 and 13.9.2: The case for no mitigation measures being required has not been properly backed up with suitable evidence.

With the measures identified in the CoCP in place, no likely significant effects were identified that would require further mitigation.

8.135 Table 13.10.1 Indicates that deleterious effects on groundwater are regarded as negligible. The council would like to remind the applicant that all groundwater is deemed a controlled water and protected by legislation (eg, Water Resources Act 1991, Groundwater Regulations 1998). Any degradation of groundwater quality must be avoided.

Negligible is the lowest effect reported in the ES. A risk assessment would be undertaken, as per our response to para. 8.9 above. We are aware of our responsibilities under the Water Resources Act 1991 and Groundwater Regulations 1998.

8.136 The possible connection between the shallow groundwater in the RTD and the Thames has not been assessed. There is evidence that tidal effects on groundwater have been seen up to 250m from the Thames wall. In this case, any risk assessment has to take the River Thames into account as a potential receptor, the legacy contamination of historic land use as a source and groundwater as a pathway.


8.137 No discussion has been included in appendix B of potential vapour releases or ground gases that may impact on or off-site. The only factors assessed are those connected with traffic and similar emissions. Potential health effects to on-site or off-site receptors from other sources (ie, land or




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groundwater contamination) should be considered.

8.139 Paragraph F.1.35 The council would like to remind the applicant that all gas assessments should be made in agreement with CIRIA C665 or similar guidance. A minimum of four sampling rounds including at least two under low and falling atmospheric pressure are required to properly assess the risks from soil gases.

See CoCP Part A Section 9.

8.140 F.1.36: The results from a single borehole cannot be assumed to be representative of the whole site. Groundwater flow may carry contamination away from or parallel to the well. In this case, a potentially serious underestimate of the on-site contamination and risk will be made.


8.141 Paragraph F.1.37 The statement The levels of contamination recorded are not considered to pose a risk to human health receptors ignores the possibility that insufficient information has been gathered to make this a defensible conclusion.

The statement reflects that this is an EIA rather than a risk assessment. Further detail would be provided within site-specific risk assessments. See our response to para. 8.9 above.

8.145 Paragraphs F.1.72 and F.1.81 There is no indication whether the gas monitoring was in accordance with the guidance document CIRIA C665. Any monitoring results not taken in line with current guidance cannot be relied on to assess risks to on or off-site users etc. and will need to be repeated.


8.146 Paragraph F.1.89 The council considers that an unvalidated report is not necessarily a definitive statement of ground conditions following a remedial action. To be accepted, the Completion report will outline the actual remedial actions taken together with the evidence to show the degree to which the actions have been successful. A validation sampling report alone does not prove that the samples have been




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taken in line with any approved remedial plan.

8.147 Paragraph F.1.93-95: The evidence presented here does not indicate that a site-specific investigation is not required. A full preliminary risk assessment should be forwarded to the local authority prior to any further investigation or remedial work to ensure that the Council’s concerns are answered.


8.148 Paragraph F.1.111 Insufficient evidence has been provided to show this statement to be robust. A properly constituted Preliminary Risk Assessment will be required before any such assumption can be made.


8.151 Paragraph K.7.5: Any exceedences of human health screening values would indicate that a proper risk management process as outlined in CLR 11 is required.


8.152 There is a known interaction between the secondary gravel aquifer and the River Thames in this area. Any identified levels of contamination should be assessed against the risk of affecting the river.


8.153 There is no site plan showing historic buildings or features superimposed on Tideway Tunnel infrastructure. This is the simplest method of making a preliminary assessment of potential sources of contamination from historic land use against the proposed development, this can provide useful information to feed into the risk assessment and remediation processes. The area around the proposed development has had a past industrial use including the storage of fuels and the manufacture and storage of chemicals, sugar refining and motor vehicle repair works.

See ES Vol 5, Figure F.1.1

8.209 Site works/site-specific issues – refers to text in CoCP Part A. No site-specific measures were identified because the measures in



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No specific actions have been proposed by the applicant. the CoCP Part A apply.



8.68 The site assessment for Acton Storm Tanks (Vol 4) is inadequate as it fails to have regard to prescribed rules of engagement with Local Authorities, to provide adequate mitigation and does not take account of standard requirements and remediation procedure for both the construction and operational phases.


8.70 With regard to Section 4 on Air quality and Odour, the Council considers that it is also possible for air quality to be affected by pre-existing land contamination in the form of vapours etc. which may impact on site users and off-site receptors. The council is concerned that this does not appear to have been included in this assessment. The assessment is focussed almost entirely on combustion generated gases and odours and needs to be reviewed.


8.72 Paragraph 8.2.3: The removal of contaminated made ground constitutes a remedial activity which would need agreement with the local authority and suitable reporting etc.


8.73 Paragraph 8.2.10: Measures a. and b. should be agreed sequentially with the local authority, including prior agreement of site investigation schemes, in line with the normal planning conditions placed by the Council within whose boundary works are taking place.




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8.74 Paragraph 8.4.6: A suitable remediation validation report regarding the nature and success of any remedial actions taken on the ex-factory site to the east should be provided to properly assess the potential for contamination to still be affecting the Acton Storm Tanks site from this previous land use. The site(s) to the north should have a full site history to ensure that any industrial or potentially contaminative activities that may still have the potential to affect land quality on the Acton Storm Tanks site are properly assessed.


8.75 Paragraph 8.4.7: It is not clear how and where the site-specific information has been obtained, is it from a targeted investigation based on current and historic land use on and off site or as a part of the generic geo-technical investigation? It is also not clear whether a suitable investigation regarding influent and effluent groundwater or gases/vapours has been undertaken in line with best practice or relevant guidance. (BS 8485 Code of practice for the characterization and remediation from ground gas in affected developments, CIRIA C716 Remediating and mitigating risks from VOC vapours, CIRIA 152 Risk assessment for methane and other gases from ground etc.)


8.76 Paragraph 8.4.8 It is not clear whether the assessment has estimated the potential contamination under the on-site gas oil tank or from the historic filter beds. If this has not been done, the Council considers that this should be included in the assessment.


8.77 Paragraph 8.5.1: A discussion regarding the adequacy of the current understanding of the risks from land contamination on site users and off-site receptors should be entered into with




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the local authority prior to further investigation and risk assessment taking place.


See our response to para. 8.9above.

8.79 Paragraph 8.5.8 States that The management of contamination at the site is a two stage process, the first stage comprises the assessment, quantification and, if necessary the removal of the main contamination sources which could impact on construction worker health. The council considers that it is not always necessary to remove contamination sources to successfully manage risks. If it can be done safely, it may be better to leave contamination in-situ and reduce traffic movements, volumes sent to landfill etc. Other remedial measure are also available that avoid the necessity of moving volumes of contaminated soils to landfill.


8.80 Paragraph 8.5.11: The council considers that the apparent low levels of contamination found on site so far may be a failure in the investigation strategy rather than actual low levels. The investigation undertaken needs to be reviewed to establish whether this is indeed the case.

We contest this point. In addition, further risk assessment would be undertaken in line with our response to para. 8.9 above.

8.81 Paragraph 8.5.16: Impacts on adjacent site-users may already be present and would have to be managed as part of any site-specific remedial actions. In addition, the groundwater pathway has been omitted. Contamination can be transported via groundwater to off-site receptors and affect adjacent land and land users by direct contact or down gradient vapour diffusion. This may occur before, during or




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after construction.

8.82 Paragraph 8.5.24: Impacts on the built environment could also involve the effects of contamination on service pipes etc. on and off-site. Some mobile contaminants can diffuse through existing water supply pipes and could affect neighbouring properties.


8.83 Table 8.10.1: Following on from the point above, health effects on adjacent land-users from exposure to contamination entering water supply pipes should be considered. The significance of the effects following the detonation of UXB cannot be regarded as negligible. It is the probability which is important in this type of assessment. As with the footnote regarding minor adverse effects that …Although the effect is minor adverse, it is unlikely that the effect will occur. In the case of the detonation of UXB, the significance of the effect is still severe, but the probability is low and further reduced by the measures outlined in paragraph 8.5.21.

See our response to para. 8.9

8.87 Paragraph 13.4.10: An accurate determination of groundwater flow direction and hydraulic gradient is required to accurately assess the potential for contamination to enter or leave the site.


8.88 Paragraph 13.4.15: The information gleaned from a single borehole may not give an accurate picture of the groundwater quality over the whole site. Without information regarding the groundwater flow and the location and nature of any potential contamination sources on-site, it will be impossible to determine whether any contamination found is coming from an on-site or off-site source.




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8.89 Paragraph 13.5.1: Although the risks posed by the main excavation are regarded as low in terms of mobilising contamination, there are other works which may have more of an impact on contamination. The council does not consider that these have all been adequately assessed.

This is not a risk assessment but an EIA. See our response to para. 8.9 above.

8.90 Paragraph 13.5.7 States that “…The negligible impact on groundwater quality on a medium value receptor, the upper aquifer, would lead to a negligible effect” The council considers that this statement is not backed up with sufficient information. The applicants will need to provide further information to justify their position.

We disagree. There is sufficient information to make this statement in terms of the EIA. A detailed risk assessment would be undertaken as part of the measures detailed in the CoCP.

8.91 Paragraph 13.8.1: This statement requires a proper assessment of contamination and a detailed risk assessment. It also avoids the potential for land contamination on site already impacting local receptors.


8.92 Paragraph 13.9.1 States that “As no mitigation measures are required, the residual construction effects remain as described in Section 13.5…” The council considers that this statement is not backed up with sufficient information. The applicants will need to provide further information to justify their position.


8.94 In Appendix B (Air Quality and Odour) no discussion has been included in appendix B of potential vapour releases or ground gases that may impact on or off-site. The only factors assessed are those connected with traffic and similar emissions. Potential health effects to on-site or off-site receptors from other sources (ie, land or groundwater contamination) should be considered.




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8.95 Paragraph F.1.46: The fact of the comparatively recent redevelopment of this site does not prove that land contamination issues have been fully resolved. An assessment of any remediation validation documents should be made before assuming this to be true.


8.96 Paragraph F.1.49: See above regarding the redeveloped factory to the east. The current use of the units immediately north of the site does not truly reflect their contamination potential. The council would question whether anything is actually known about the prior use of the site.


8.97 Paragraph K.7.1: OS Maps supplied by Hammersmith and Fulham show industrial sites adjacent to the Acton Storm Tanks site boundary. Previous activity on-site is regarded as potentially contaminative. Historic mapping alone is insufficient to fully assess the potential for contaminative land uses.


8.208 Site works/site-specific issues – refers to text in CoCP Part A. No specific actions have been proposed by the applicant.




8.154 The site assessment for Carnwath Road Riverside (Vol 10) is not adequate as it does not take account of the potential for land contamination to effect air quality, aquatic ecology and groundwater.

See our response to 8.10 above.



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8.155 There is no inclusion here of the possible need to investigate or remediate this site. The requirement for, and design of, any remedial activity will follow a full review of the Preliminary Risk Assessment, Site Investigation and Quantitative Risk Assessment. To comply with the recommendations of CLR 11, close engagement with the local authority is essential. A suitable Remedial Strategy may include ongoing works that may impact on the main construction work.

We note that that LBHF has made a number of comments on the remediation process. We have detailed a clear and robust approach, which is summarised in each ES site-specific volume (Section 8.2) and would be secured via project-wide Requirement PW6 regarding the CoCP Part A (Section 9), which states:

“The contractor would carry out site assessments, investigations and/or risk assessments wherever construction work is planned in order to assess the potential for contamination in both soil and groundwater, in accordance with standard industry guidelines including Model procedures for the Management of Land Contamination, Contaminated Land Report 11.”

Further details on this are included in the CoCP Part A. In addition to this are the site-specific contaminated land Requirements (eg, ACTST3) in the Draft DCO. These would complement the requirements in the CoCP Part A.

The Environment Agency, in its relevant representations (11.9), asked us to amend these requirements. Our response is included in the Environment Agency SoCG and we are seeking to revise the Requirements in the Draft DCO to reflect the agency’s suggestions; this will be done in consultation with the local authority.

8.156 The council considers that the removal of contaminated soils, as indicated in paragraph 3.3.40, may be regarded by the local authority as a remedial measure and would require suitable documentation to verify the success of the works including trip notes, WAC assessments etc.

The CoCP Part A Section 10 describes the approach to managing waste.

8.157 It is possible for air quality to be affected by pre-existing land contamination in the form of vapours etc. which may impact on site users and off-site receptors. This does not appear to have been included in this assessment. The assessment is



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focussed almost entirely on combustion generated gases and odours. The assessment should be reviewed to include this information.

8.158 There is some indication that the secondary gravel aquifer and the River Thames are hydraulically connected which may permit contaminants from on-site sources entering the river. Therefore, the potential for contaminants mobilised by construction or other on-site activities to enter the river with a deleterious effect to the neighbouring ecology should be considered.


8.160 Paragraph 8.2.3: The removal of contaminated made ground may constitute a remedial activity which would need agreement with the local authority and suitable verification reporting etc.


8.161 Paragraph 8.2.8: While this paragraph states that land quality issues will be managed in close liaison with the London Borough of Hammersmith and Fulham, there is no commitment to consult at each stage of the process. This can greatly reduce the number of false starts and revisits to site caused by omissions in Risk Assessments and Investigation Scheme etc.


8.162 Paragraph 8.2.9: Measures a. and b. should be agreed sequentially with the local authority, including prior agreement of site investigation schemes, in line with the normal planning conditions placed by the Council within whose boundary works are taking place. Hammersmith and Fulham’s standard conditions may be found later in this text.


8.163 Paragraph 8.2.10 The land quality management actions outlined in this paragraph would require agreement of each




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stage with the local authority to ensure that issues important to the Council are not omitted and any investigation or assessment work is carried out adequately.

8.164 Paragraph 8.2.11: All four of these programmes would require prior assessment and agreement by the Council.


8.165 Paragraph 8.2.13: - see 8.2.3 re removal of contaminated soils. Explain and elaborate. The council considers that the removal of contaminated soils is a remedial activity and should be documented accordingly.

See our response to para. 8.9 above and CoCP Part A Section 10 and Excavated material and waste strategy (ES Vol 3 App A.3).

8.166 Paragraph 8.4.9: It is unclear as to whether any assessment been made of the risks of on-site contamination entering the River Thames via groundwater. The council would request that if an assessment has not been done that it should be carried out.


8.167 Paragraph 8.4.11: The council considers that evidence of previous remedial efforts would have to be in the form of Verification reports accepted by LB of Hammersmith and Fulham.


8.168 Paragraph 8.5.1: A discussion regarding the adequacy of the current understanding of the risks from land contamination on site users and off-site receptors should be entered into with the local authority prior to further investigation and risk assessment taking place.

See our response to para. 8. 20 above.

8.169 Paragraph 8.5.2: Before any remedial actions can be accepted by LB Hammersmith and Fulham, the preliminary risk assessment, site investigation proposal(s), quantitative risk assessments, remedial options appraisals and remedial strategies would have to be agreed sequentially. There would




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also be a requirement for a verification report and, if required, proposals for ongoing monitoring for an extended period.

8.170 Paragraph 8.5.3: The council would like the applicant to clarify what is meant by ‘some contamination is considered to be present’ in the context in which it is being used.

This is a baseline assumption for the purposes of assessing the likely significant effects where full site information is not available. See our response to para. 8.20 above.

8.171 Paragraph 8.5.4: The sequence of remedial actions required should not be fixed until a better understanding of the site is available.




8.173 Paragraph 8.5.18: Impacts on adjacent sites may already be occurring. The risks will require assessment and may require remediation as part of the project.


8.175 Paragraph 8.5.22 Asserts that …the impact to all adjacent land-users is assumed to be negligible.. This statement requires more evidence, based on a site-specific site investigation and quantitative risk assessment.

See our response to para. 8.9above.

8.176 Paragraph 8.8.1: The assessment outlined above is not comprehensive enough to state that no further work is necessary.


8.177 Paragraph 8.9.1: Assumes that the previous assessment is satisfactory whereas insufficient evidence has been provided.


8.181 Paragraph 13.4.9: The council considers that Hydraulic gradients and groundwater flow directions have a critical bearing on the need and type of remedial actions required to




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manage contamination issues on this site. This information requires three boreholes at least. There is also no evidence to show that wells have been placed with regard to contamination assessment as opposed to geotechnical considerations. The degree of hydraulic connectivity between the river and shallow aquifer should also be assessed.

8.182 Paragraph 13.4.19: The presence of this contamination may have much wider consequences than the disposal of pumped water and requires a full assessment and probably further investigation.

See measures in the CoCP Part A Section 8 and the Groundwater environmental management – dewatering and monitoring strategy (GEMDS) APP21, submitted on 4 November 2013.

8.183 Paragraph 13.5.1: Although the risks posed by the main excavation is regarded as low, in terms of mobilising contamination, there are other works which may and these do not appear to have been adequately assessed.


8.184 Paragraph 13.5.7: There is only information from a single borehole assessed here. There is no evidence that the aquifer is confined by alluvium over the entire site. Therefore, any conclusions drawn may be erroneous and may require a reassessment of possible risks to and from shallow groundwater.


8.185 Paragraph 13.8.1: This statement requires a proper assessment of contamination and a detailed risk assessment. It also ignores the potential for land contamination on site already impacting local receptors.


8.186 Paragraphs 13.9.1 and 13.9.2: Insufficient evidence has been provided to demonstrate that the site has been properly investigated and risks suitably addressed. Therefore the case that no mitigation measures are required has not been






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robustly demonstrated.

8.189 No discussion has been included in Appendix B of potential vapour releases or ground gases that may impact on or off-site. The only factors assessed are those connected with traffic and similar emissions. Potential health effects to on-site or off-site receptors from other sources (ie, land or groundwater contamination) should be considered.


8.191 Paragraph F.1.28: A full site investigation, preceded by a preliminary risk assessment and detailed risk assessment is required to assess the requirement for remedial actions etc. is required.


8.192 Paragraph F.1.35: Details of any remedial actions with regard to the management of contaminated sediments should be reported to the local authority.


8.193 Paragraph F.1.37: This reinforces the requirement for a full site assessment in accordance with CLR11.


8.195 Paragraph F.1.48: The remedial works carried out in 1996 may no longer be regarded as sufficient.


8.197 Paragraph K.7.1: Land quality impact on groundwater quality may already be occurring and will require assessment and possible remedial actions as part of this development.


8.198 Paragraph K8.5: The assessment and remediation of pre-existing contamination at sites is also a potential benefit of this project.


8.199 There is a known interaction between the secondary gravel aquifer and the River Thames in this area. Any identified levels of contamination should be assessed against the risk




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of affecting the river.

8.200 There is no site plan showing historic buildings or features superimposed on Tideway Tunnel infrastructure. This is the simplest method of making a preliminary assessment of potential sources of contamination from historic land use against the proposed development, this can provide useful information to feed into the risk assessment and remediation processes. The area around the proposed development has had a past industrial use including the storage of fuels and the manufacture and storage of chemicals, sugar refining and motor vehicle repair works.

See the land quality figures in ES Vol 10).

8.2.10 Site works– refers to text in CoCP Part A Site Specific Issues/mitigation – Special considerations given to dredging. (This requirement is based on the sediment sampling covered in Vol 2: Environmental assessment methodology appendices. Appendix F Land Quality). Otherwise no specific actions have been proposed by the applicant.


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7 Flooding (Response to Section 9 of LIR


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7 Flooding (Response to Section 9 of LIR)

7.1 General matters: Flooding


9.4 New developments are expected to achieve greenfield run-off rates and at least 50 per cent attenuation of undeveloped sites surface water run-off at peak times. Development proposals are required to demonstrate that there is sufficient water and waste water infrastructure capacity both on and off site to serve the development or the necessary upgrades will be delivered ahead of the occupation of development. The Surface Water Management Plan for Hammersmith and Fulham is expected to be complete in autumn 2013. The council recognises that the DCO application has already been submitted however the Council would welcome the ExA taking into account the findings of this report

The need for previously developed sites to achieve at least 50 per cent attenuation of undeveloped sites’ surface water run-off at peak times (when discharge into a tidal watercourse is not feasible) is reflected in the drainage principle SDRN04 (see revised Design Principles, September 2013, Doc ref: 9.23.01).

Our flood risk assessments were based on the best available information at the time of the preparation of the ES, including information provided by the Environment Agency, the Strategic Flood Risk Assessment completed in 2010, as well as baseline information such as site topography and geology. It should be noted that the Surface Water Management Plan report from the LBHF was not made available for the assessments. The existing and post-development level of flood risk were inferred based on the available information and methodology in the ES, Vol 2, Section 15 agreed with the Environment Agency.

9.6 The ES (Document Reference 6.2) is unclear and lacks important detail with regard to Sustainable Drainage Systems. There is also limited evidence to suggest that any attempt has been made to reduce flood risk.

The need for sustainable drainage systems (SuDS) to be implemented on sites whenever practicable (when discharge into a tidal watercourse is not feasible) is reflected in the drainage principles SDRN01, SDRN.03 and SDRN.04 (see revised Design Principles, Part A).

Where relevant, the possibility to include SuDS was explored on a site-by-site basis and detailed in the flood risk assessment. It should be noted that the contractor would be responsible for selecting the appropriate surface water attenuation measures at

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the detailed design stage, in line with the relevant drainage principles and the site-specific surface water drainage Requirements in the Draft DCO.

9.7 As a minimum there needs to be more information provided on the proposed SuDS. This is particularly important as SuDS is widely acknowledged by the applicant to be an important and complementary element of the overall sustainability of the tunnel project.

See our response to 9.6.

9.8 While the report indicates there will be no overall increase in flood risk, there is limited evidence to suggest that any attempt has been made to reduce flood risk (from all sources) as a result of the developments – a requirement of local plan policy. Steps should be taken to not only reduce the impact of flooding in terms of the new development, but also to provide a significant betterment over the existing situation. For example, an assessment should be undertaken to determine whether a more significant reduction in surface water runoff could be achieved through the use of a more extensive suds system.

The site-specific and project-wide flood risk assessments demonstrate that no significant flood risk effects are anticipated, in line with the requirements of the NPS.



9.16 The council is concerned about the statements made in paragraphs 3.3.26 and 14.2.6 that all site drainage will be drained and discharged to mains foul or combined sewers and any water entering the excavation from either superficial deposits or minor seepage through silt layers would be pumped to the sewer via appropriate settlement tanks. The

Control measures would be implemented during construction, as set out in the CoCP Part A, Sections 8.2.1 to 8.2.5.



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council reiterates the fact that there are existing capacity issues with the combined sewers in Hammersmith and Fulham and any increase in discharge into these sewers could result in an increase in flood risk from the sewers. In addition, a betterment over the existing situation should be provided. Reference is made in paragraph 15.2.6b to an attenuated rate of surface water discharge from the pumping station to the combined sewers. However, there is no mention of what the attenuated rate is going to be. This is an inadequate level of detail which the Council considers needs to be substantiated.

9.17 The council believes that if the existing Bullsditch sewer be decommissioned, as proposed in paragraph15.2.2b, as a minimum a thorough investigation of any other connections to this sewer will be required before decommissioning.

We would ensure that there were no existing connections to any sewer scheduled for decommissioning.

9.18 The council is unable to determine the source of the river modelling data that is being referred to in paragraph 15.3.24 and would welcome clarification from the applicant as to whether the modelling that is referred to is the Environment Agency’s modelling. If it is, the Council would request that the latest modelling is used.

The full modelling report is attached to the ES, Vol 3, Section 15, Appendix M1.

9.19 The council is concerned that in paragraph 15.4.5 the applicant states that no works are proposed to the existing river defences, but earlier in the report, reference is made to the fact that surface water will be discharged to the River Thames. The council considers that this could result in an impact on the existing defences and would request that any potential impact is identified and assessed.

The elements of the scheme that would be located within the Fulham Reach development would be drained by the drainage system designed for this development. It is understood that the proposed drainage would discharge surface water into the tidal Thames through an existing outfall. No impacts on flood defences are therefore anticipated.

9.20 Paragraph 15.4.9 states that surface water discharge will be restricted to 50 per cent of the existing rates. More detail is

This would be provided by the contractors at the detailed design stage.

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required about how this will be achieved.



9.9 The ES (Vols 4 – Acton Storm Tanks) is inadequate as it does not take account of potential flood risk due to the lack of capacity of the existing sewers. The council also considers that the mitigation measures proposed are insufficient and should be reviewed.

See our responses below.

9.10 There is widespread evidence that there are existing capacity issues with the combined sewers in Hammersmith and Fulham. Any increase in discharge into these sewers could result in an increase in flood risk from the sewers. As a minimum, the Council considers that any additional flows into the sewers should be attenuated and discharged at a lower rate after the peak flow has passed through the sewers.

Control measures would be implemented during construction, as set out in the CoCP Part A, Section 8.2.1 to 8.2.5. With the above measures in place, no significant surface water flood risk effects are anticipated.

9.11 The council acknowledges that “existing groundwater information is limited” , but would question why, if that is the case, further groundwater investigation has not been done to provide a more robust assessment. As a minimum, the Council considers that the situation with regard to existing groundwater should have been investigated and, without such information, assumptions are being made without a sufficient evidence base that could potentially cause a greater risk of flooding across the project area.

The existing risk of groundwater flooding is considered to be low because, although there is a relatively shallow depth of groundwater level, there is a restricted pathway to the site.

During construction, sheet piling would be constructed to seal out any groundwater flows from the upper aquifer in the river terrace deposits and the London Clay formation. Groundwater within the sheet pilled walls would be pumped out and discharges to the existing sewerage network once suspended solids have settled.

At the end of the construction phase, sheet piling would be broken up or piped through to prevent groundwater building up behind the



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structure. Therefore, the risk of groundwater flooding would remain low.

In addition, groundwater monitoring would be undertaken during construction and operation.

9.12 The council understands that (paragraph 14.2.4) during construction the reserve tanks at Acton will be taken out of service. The council is concerned that this will reduce the facility’s ability to cope with a situation in which high tide levels occur at the same time as a storm event and hence could result in an increased risk of flooding due to lack of capacity at the facility. The council considers that even with the proposed mitigation in place during construction, up to 6,000m3 of additional discharge volume could be expected – this could pose a flood risk. As a minimum, the Council would like to see some further detail on how will these additional flows will be managed.

The two reserved tanks are used infrequently during large storms that coincide with high tide levels as described in para. 14.2.3.

During construction, tanks would be reserved during larger storm events that coincide with highest tides. This operation (only during high tide and storm forecast) could leave the reserve storage tanks unused or part used resulting in CSO discharges that could have been partially captured. The Environment Agency is aware of this operational condition during construction and has agreed it is an appropriate compromise, balancing potential flood risk and CSO discharge during construction. Therefore the flood risk at Acton Storm Tanks, with active management over the full construction period, is a similar low risk of less than 1.5 per cent (59 per cent x 2 per cent) as the current condition. This is based on the annual probability of a high tide (ie, 2 per cent annual probability) occurring at the same time as the one in five year rainfall event in a four-year construction period (ie, 59 per cent annual probability)).

Acton Storm Tanks is situated in the London Borough of Ealing and the Acton CSO discharges at Chiswick Eyot the London Borough of Hounslow.

9.13 The council understands that (paragraph 14.2.8) all site drainage will be drained and discharged to mains foul or combined sewers. The council is very concerned that there are existing capacity issues with the combined sewers in Hammersmith and Fulham and that any increase in discharge into these sewers could result in an increase in flood risk from


Furthermore, surface water from the operational site would be drained as per the existing regime to the pumping station and pumped to the Stamford Brook sewer at a restricted rate (ie, 50 per cent of the existing rate). Increased landscaping areas and SuDS measures would be used to attenuate any increased surface



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the sewers. As a minimum, the Council would like confirmation that any additional flows into the sewers will be attenuated and discharged at a lower rate after the peak flow has passed through the sewers.

water run-off. With the above measures in place, no significant surface water flood risk effects are anticipated.

9.14 The council is concerned that in both paragraph 15.3.22 and 15.3.48 the risk of surface water flooding to the site appears to be confirmed as medium. If the applicants consider this to be the case, the Council question why the further management of the flood risk has not been included in the DCO application. As a minimum, the Council consider that flood risk management is put in place to address this medium risk that has been identified at Acton Storm Tanks.

The flood risk assessment (ES, Vol 4, Section 15) demonstrates that the proposed development would be appropriate for the area. This is because flood risk to the development would remain unchanged as it would be managed through appropriate design measures and the development would not lead to an increase in flood risk on the surrounding areas. Therefore, no significant flood risk effects are likely.



9.21 The ES (Vols 10 – Carnwath Road Riverside) is inadequate as it does not take account of potential flood risk due to the lack of capacity of the existing sewers and does not include important detail on groundwater. The council also considers that the mitigation measures proposed are insufficient and should be reviewed.


9.22 Table 3.6.1 gives no reason as to why the alternative option for the river wall was not progressed.

Based on the information currently available, the sections of river wall generally fronting the Hurlingham Wharf and Carnwath Road Industrial Estate were assessed as requiring replacement.

9.23 Paragraph 13.3.2 indicates that no on site ground investigation has been done. This is completely inadequate and means that the assumptions made on ground conditions may be incorrect

See our responses to paras. 8.9 and 8.42 in the land quality section of this document.




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which, in turn, could result in conditions differing from those expected. There is also a lack of detailed groundwater level information in paragraph 13.3.23 which also may mean that incorrect assumptions have been made, resulting in a lack of understanding of the potential to impact on groundwater flooding. In addition there is a lack of data for a prolonged wet period which may mean that the potential for groundwater flooding has been under-estimated. The council considers that these omissions are significant and that they need to be addressed immediately and rectified if the application is to progress further.

9.24 Paragraph 13.5.5 highlights the use of sheet piles to obstruct groundwater flows. The council is concerned that the resulting increase in hydraulic pressure caused by the sheet piles could disrupt groundwater flows to a point that there is an increase in the risk of groundwater flooding. The council considers that the use of sheet piles and their effect on groundwater flooding needs to be more thoroughly considered by the applicants.

A worst case assessment was undertaken on the assumption that sheet piles would be used around the entire site. The results demonstrate that there is no risk of an increase in groundwater flooding to the site as a result of the development. Furthermore, groundwater levels would be monitored during construction although the flood risk is predicted to be low.

9.25 Paragraph 14.1.3 indicates that operational impacts on surface water were not assessed. Although there will be no CSO interception, the development will result in overland flows and the Council considers that the impacts of these should be considered by the applicant.

The operational impact was assessed in the flood risk assessment (ES, Vol 10, Section 15), which demonstrated no increase in surface water flood risk.

9.26 As with the other site assessments, it is stated in paragraph 14.2.8 that all site drainage will be drained and discharged to mains foul or combined sewers. The council is concerned that there are existing capacity issues with the combined sewers in Hammersmith and Fulham and any increase in discharge into these sewers could result in an increase in flood risk from the sewers. As a minimum the Council considers that any

Control measures would be implemented during construction, as set out in the CoCP Part A, Section 8.2.1 to 8.2.5.

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additional flows into the sewers should be attenuated and discharged at a lower rate after the peak flow has passed through the sewers.

9.27 Paragraph 14.5.14 states that appropriate drainage will be used to control the risk of pollutants entering the river which is commendable, but unfortunately it does not provide any detail on this drainage regime. As a minimum the Council considers that a drainage regime be put in place.

See our response to para. 9.26 above

9.28 The council is concerned that in paragraph 14.5.16 the applicant refers to ‘potential’ remediation measures to reduce the pollution impact of the dewatering but does not make a firm commitment to this. As a minimum, the Council considers that the applicants should make this commitment.

See our responses to paras 8.9 and 8.42 in the land quality section of this document.

9.29 Paragraph 15.3.45 states that surface water may need to be stored onsite in the event of a high tide preventing discharge into the River Thames. The council would like to see clarification as to how this will be stored to ensure it does not create a flood risk.

The preferred approach for this site (in agreement with the Environment Agency) is to discharge run-off directly into the tidal Thames. As per site-specific Requirements and design principles, the contractor would be responsible for developing a detailed drainage strategy, which shows no increase in flood risk, including consideration of tide locking scenarios when discharging to the ruver and provision of any necessary on-site storage.

9.30 The council considers that if the existing sewers need to be demolished, as highlighted in paragraph 15.3.60, surface water and the foul water systems should be separated to reduce the risk and impact of flooding. The applicants should carefully consider their options and implement efficiencies and alternative sustainable measures wherever possible.

See our response to paras 9.26 and 9.29 above

9.31 Paragraph15.4.15 states that the proposed measures will not reduce the risk of surface water flooding during construction. Given the scale of work and the long timescale for the




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proposed work at Carnwath Road the Council considers measures should be implemented that can reduce the risk of surface water flooding at this site.

8 Ventilation (Response to Section 10 of LIR)


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10.2 The Council understands the general philosophy behind the Air Management Plan and the general principles of keeping the air space within the tunnel under negative pressure to encourage gases to be drawn into the tunnel rather than being passively expelled in a chaotic manner. However, to achieve this objective gases have to be actively extracted and treated at key sites rather than passively vented. The objections to the ventilation strategy are around the selection of the Carnwath Road Riverside site as the sole main tunnel extraction site upstream of Abbey Mills extracting and expelling exhaust gases, operating twenty four hours a day 365 days a year.

Yes; treated air would be released at Carnwath Road Riverside 24 hours a day, 365 days a year, similar to building ventilation.

See our response to paras. 10.1 to 10.13.

The odour impact at all of the proposed active and passive ventilation sites was assessed and would fall within the Environment Agency odour benchmark for no significant pollution. A number of sites were considered as a drive site in addition to Carnwath Road Riverside. These are described in the Final Report on Site Selection Process (Doc ref: 7.05, Vol 9 Carnwath Road Riverside).

10.4 The air management strategy is to extract untreated air from the tunnel, keeping it in negative air pressure and drawing fresh air in from other sites. This will force external air to be drawn into the tunnel rather than foul gases from within the tunnel being expelled. To reduce the air pressure in the tunnel it will be pumped at the six active sites which will remove and treat foul air from within the tunnel. Active air extraction will be operating continuously when the tunnel is empty at Acton and Carnwath Road which are the two sites upstream of Abbey Mills selected to deliver this.

In order to achieve a reduced air pressure in the tunnel, there would naturally be an air inflow, otherwise there would be a vacuum. The fresh air inflow would displace the potentially foul air in the tunnel that is drawn to the extraction and air treatment facilities.

10.6 The council considers that the selection of Carnwath Road Riverside as the main air extraction site for the Thames tunnel,

The proposed air extraction and treatment facilities at Carnwath Road Riverside and Abbey Mills Pumping Station are

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upstream of Abbey Mills is inappropriate and not the best location for the treatment of foul exhaust gases.

approximately equidistant from Blackfriars Bridge Foreshore where air flows into the tunnel. This arrangement provides a balanced and efficient air circulation throughout the tunnel, which would not be the case otherwise.

10.7 The Carnwath Road main ventilation building is proposed to be 20 x 8.5 x 5.5 cubic metres in volume compared to Acton, where most of the system would be housed below ground, where the ventilation building heights are limited to 2.5m.

The ventilation building at Carnwath Road Riverside would be sized to accommodate both the extraction fans in their acoustic enclosures, the large ductwork and the electrical switchgear room. The plan area needs to allow for adequate access to maintain the fans and ducts. The height of the building is determined by the height of the fan units and the additional brown roof feature.

At Acton Storm Tanks, each extraction fan would be housed in an acoustic enclosure as this is a secure Thames Water site and does not require a separate building for the fans. The air ducts would be in the open air and the electrical switchgear housed within the existing Thames Water buildings. The size of each acoustic enclosure is approximately 4m x 2.5m in plan and 3.5m high.

10.8 The council does not consider that Carnwath Road Riverside is a suitable site for continuous active air extraction and treatment. The ventilation shaft is in close proximity to a large number of houses and schools. The council considers that the shaft should be located away from the residential area.

Although the ventilation plant at Carnwath Road Riverside is in the vicinity of some residential properties, the site is on a presently disused wharf and is mostly in the vicinity of businesses and commercial properties.

Furthermore, ES Vol 10, Table 4.10.2 (Doc ref: 6.2.10) states that there would be a negligible impact in terms of odour on identified receptors at the site.

10.9 The selection of Barn Elms would place the ventilation system nearer the head of the tunnel and also allow for any gas extraction to be more distant from residential properties. Acton, as either the main or secondary ventilation site, would be a more appropriate use of the land, replacing existing open storm water overflow tanks. The council believes that if the

The design of the tunnel ventilation system requires an air extraction and treatment facility at both Acton Storm Tanks and Carnwath Road Riverside.

The ES identifies that there would be negligible impacts in terms of odour at both Carnwath Road Riverside and Acton Storm Tanks. Moving the active ventilation site to Barn Elms would make no



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applicant were to put the main ventilation at Acton Storm Tanks it might reduce the land requirement at Carnwath Road and hence the overall cost of the scheme.

determinable difference in impacts on residential receptors.

In terms of reducing the overall cost of the scheme, the land required for a main tunnel drive site would not likely alter to the extent that less would be required. Furthermore land acquisition is a complex matter and it would not be a simple case of not acquiring one small parcel of land due.

10.10 The selection of Carnwath Road as the sole site for gas extraction from the main tunnel will cause unnecessary and concentrated odour release in a residential area.

The design of the tunnel ventilation system requires an air extraction and treatment facility at both Acton Storm Tanks and Carnwath Road Riverside, thus Carnwath is not “the sole site for gas extraction.”

Furthermore, the ES Vol 10, Table 4.10.2 states that there would be negligible impact in terms of odour on identified receptors at the site.

10.11 Thames Water has acknowledged in Section 3.3.2 of the Air Management Plan that there are 22 potential sites for air extraction. Forced exhaust extraction needs to be at the upstream end of the tunnel to be effective as the downstream sites become progressively drowned out when the tunnel begins to be flooded with sewage.

Although there are 22 sites where air can flow out of and into the tunnel and associated shaft, there are only six sites where the shaft is directly on the line of the main tunnel. An active ventilation plant needs to be positioned on the line of the main tunnel to be effective. The other 16 sites are located at the end of short connection tunnels that link them to the main tunnel.

10.13 Carnwath Road has no combined sewer overflow located at this point on the north side of the river and is located in a densely populated area. If a second site, beyond the one located at Acton, is required it may be possible to locate the active ventilation shaft at Barn Elms at a greater distance from residential properties.

ES Vol 10, Table 4.10.2 states that there would be negligible impact in terms of odour on identified receptors at the site.

10.14 The council considers that the standards for the expulsion of foul sewer exhaust gases are not acceptable for this project.

For 99.7 per cent of the time during the typical year, the air extracted at Carnwath Road Riverside plant would be treated; therefore this is not foul sewer gas. The treatment process would remove 95 per cent of the odour in the released air to undetectable



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levels. The Environment Agency H4 guidance is the only recognised standard available to assess odours in England.

Paras. 10.14 to 10.19 question the use of the odour benchmark set by the Environment Agency at 1.5 ouE/m3 for the 98th percentile of hourly values in a year. The benchmark was set for highly offensive odours such as processes involving septic effluent or sludge and relates to a standard of 'no significant pollution' as required by the Integrated Pollution Prevention and Control Directive, which has now been superceded by the Industrial Emissions Directive which has the same aim. A 98th percentile of hourly concentrations allows the specified concentration to be exceeded for 175 hours in a year and prevents the results being skewed by infrequent meteorological conditions.

The main source of research into odour impacts in the UK has been the wastewater industry and the most in-depth study study in the UK of the correlation between of modelled odour impacts and human response (dose-effect) was published by UK Water industry Research (UKWIR) in 2001. This was based on a review of the correlation between reported odour complaints and modelled odour impacts in relation to nine wastewater treatment works in the UK with ongoing odour complaints. The findings of this research (and subsequent UKWIR research) were used by CIWEM to develop the following indicative guidelines:

At modelled exposures of below 3ouE/m3 for the 98th

percentile, complaints are unlikely to occur and exposure below

this level is unlikely to constitute significant pollution or

significant detriment to amenity unless the locality is highly

sensitive or the odour highly unpleasant in nature.

At modelled exposures between 5ouE/m3 and 10ouE/m3 for the



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98th percentile, complaints may occur and depending on the

sensitivity of the locality and nature of the odour, this level may

constitute a nuisance.

At modelled exposures greater than 10 ouE/m3, complaints are

highly likely and odour exposure at these levels represents an

actionable nuisance.

5ouE/m3 for the 98th percentile impact criterion has since been accepted as appropriate in a number of wastewater treatment works planning applications for avoidance of significant risk of annoyance and a low risk of nuisance.

The Chartered Institute of Water and Environmental Management (CIWEM) position on the differing odour impact criteria available is that the selection of the most appropriate criterion should be determined by the objective of the assessment (whether against a standard of avoidance of nuisance or 'significant pollution') and the nature of the odour under assessment.

For this assessment, we selected the most stringent criterion: 1.5 ouE/m3 for the 98th percentile of hourly values in a year.

Air movement in and out of the tunnel is a function of how the tunnel system fills and empties and how air is therefore displaced. The volume and frequency of air released at each ventilation site was modelled using hydraulic and air movement models. The hydrogen sulphide concentration in the tunnel air was calculated based on the sulphide content of the storm water and odour concentrations estimated from this based on measurements of eight London CSO discharges.

10.15 If the volumes of untreated gases to be vented at Carnwath Road Riverside meet the Environment Agency’s standards then it should be questioned whether the air quality standards

The Environment Agency H4 guidance is the only recognised standard available to assess odours in England. From the odour dispersion analyses, even with untreated releases the levels of



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are acceptable for this location. odour would be negligible. The maximum one hour odour at ground level is predicted to be 28ouE/m3, whereas the peak background odour measured at Carnwath Road Riverside is up to a level of 440ouE/m3.

10.16 During intense storms, when the rate sewage discharge into the tunnel is high, the extraction pumps at Carnwath Road will have to be bypassed. Thames Water’s design estimates that the system will pass untreated tunnel gases directly into the atmosphere for a total of over 23 hours on 17 separate events in a typical year (Table 3.2). This equates to an average of 80+ minutes (ie, 23x60 minutes over 17 events) of untreated tunnel gases being released for a single event every 21 days (365day/17events).

The 23 hours and 17 events giving 80 minutes per event of untreated emission are taken out of context in this statement. The odour dispersion modelling is based on hourly time steps because that is how the meteorological data, which defines the level of dispersion, is recorded by the Meteorological Office. This is the smallest time step that can be applied. In reality, the untreated exhausts would be for periods of minutes within the hourly time step, thus the average time of the event would be less than the 80 minutes.

10.17 This degree of emissions would be deemed acceptable under the Environment Agency standard H4 as it allows for 2 per cent of time when the breaches of the standard are acceptable, some 10 hours over each 21 day period. (2 per cent of 21 x 24).

The Environment Agency H4 guidance refers to emissions during a period of one year.

10.18 The Air Management Plan does not explain why or how the figures for untreated gases have been calculated for Acton and Carnwath Road but it argues that these durations for untreated foul gases to be allowed to be vented directly into the area is acceptable because the Environment Agency standards allow for considerably in excess of this degree of venting.

The Air Management Plan is a distillation of other reports and calculations that were not submitted with the application. The untreated air releases are based on the air flow rates displaced when wastewater rapidly fills the tunnel during storm events in the typical year. On average, across the tunnel system, the untreated releases are for approximately 20 hours a year (0.2 per cent of the time). This is ten times better than recommended by the Environment Agency guidance.

10.19 However, the Council is concerned whether the design parameters allow for scheduled and/or unscheduled plant down times. Treated foul tunnel gases will be expelled 365

There are two independent air treatment streams, each with separate extraction fans and air treatment units at the ventilation plant in Carnwath Road Riverside. If one of these is down due to

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days a year with at least one monthly event when untreated tunnel gases are expelled directly into the atmosphere, and at worst considerably in excess of this. The council considers that the standards for the expulsion of untreated foul sewer exhaust gases proposed by Thames Water are not acceptable for this project, particularly in densely populated residential areas such as that found at the Carnwath Road Riverside site.

maintenance, the other one can provide a level of emergency back-up. In the unlikely event that only one treatment stream is available for the whole year, the number of hours by-pass would increase fourfold to approximately 100 hours. This is still within the 175 hours permissible under Environment Agency guidance. A complaints procedure is set out in the Air Management Plan, where if odours are detected, Thames Water is required to carry-out investigation and implement mitigation measures.

10.20 The odour assessments produced by the applicant are inconsistent across the application documentation, making it difficult to assess the impacts with any great certainty.

Odour assessment is not inconsistent; it is complicated because of the many different scenarios analysed.

Regarding paras. 10.21 to 10.22, odour information is presented in a number of ways in the application. Information is provided on emissions (ie, the amount of odour released over time from ventilation columns) and concentrations (or the strength of the odour, the amount of odour dispersed in 1m3 of air). The two are very different as an odorous substance could be released from a vent but by the time it reaches ground level or a nearby building, the substance mixes with air and would be present in lower concentrations than in the vent and might be below the concentration at which it can be detected. The Air Management Plan presents information on emissions in Table 3.2. The ES Vol 10 presents information on the predicted impact of the emissions (ie, concentrations) in Tables 4.6.1 and 4.6.2.

10.21 In relation to the odour assessments, there seems to be different data in different documents. For example the Air Management Plan provided under the heading of Technical Report in the phase two consultation material states in table

2.2 ‘Site ventilation structure types and expected hours of air exhaust emissions for the typical year’ for Carnwath Road Riverside on page 10 that ‘the number of hours of untreated

Paras. 10.21 and 10.22 relate to the different figures quoted for the hours of untreated releases. Our response is as follows:

a. The 34 hours over 14 events of untreated releases given in the phase two consultation technical report relates to the control philosophy for wastewater inflow at that time.

b. The 23 hours over 17 events results from applying an updated



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exhaust will be released for 34 hours over 14 events per year or just 0.4 per cent of time. But the ES Vol 10 Carnwath Road Riverside Section 4.6, states:

‘The odour benchmark is 1.5 OUe/m3 for the 98th percentile of hourly values. Dispersion modelling has been carried out to assess the impact. The maximum number of hours in a year with odour above 1.5ouE/m3 near Carnwath Road Riverside site is 75 either at a building or at ground level) so is well within the benchmark which permits 175 hours above this value. The impact is therefore well within the Environment Agency’s odour benchmark which is widely used across the country.’

wastewater inflow control philosophy hence reducing the displaced air emissions at the preferred location of the ventilation column.

The 75 hours stated in the ES for odour levels greater than 1.5ouE/m3 at a building with the ventilation column located at the worst position within the allocated zone rather than at the preferred location. The number of hours when odour levels are greater than 1.5ouE/m3at a building for the preferred location of the ventilation column would be 31. The contractor, who would produce the detailed design of the ventilation facility, may wish to re-position the column within the allocated zone.

10.22 The Air Management Plan (7.14) gives the number of hours of untreated exhaust for Carnwath Road (table 3.2) as 23 hours (17 releases) which again is different to the data given above. In order to assess the impact on odour emissions in the local area it is important that the applicant provides consistent and justified projections. However, the Council considers that no regular, scheduled or unscheduled odour emissions are acceptable at this location.

See our response to para. 10.21. As with all designs relating to natural events, such a rain storms over London, a return period needs to be assigned. For the project, a one in 15 year catchment-wide storm is chosen to calculate the peak air displaced from the filling tunnel. This is equivalent to a one in 40 to 50 year event when area reduction is applied and is the highest practical storm, which would cause rapid tunnel filling as well as potential street flooding. This storm was applied to design the tunnel ventilation system.

10.23 There is a concern that treated exhaust gases may be a loss of amenity, even if such treatment has removed the hydrogen sulphide gases to the extent that they no longer constitute a statutory nuisance.


The carbon filters can remove all odorous gases, not just hydrogen sulphide. It was assumed that the carbon filters would remove 95 per cent of the odour in the exhaust air, so 5 per cent of odour was assumed to be released and was modelled. The remaining odour may not be as offensive as the original odour. Hydrogen sulphide would be measured in the exhaust air at Carnwath Road Riverside before and after it passes through the carbon filter. Hydrogen sulphide is measured as an indicator of the release of other sewage odour; it can be measured easily than other gases. Odour



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concentrations were modelled at ground level and the high rise buildings near the ventilation column and were all predicted to be less than the Environment Agency odour benchmark: 1.5 ouE/m3 for the 98th percentile of hourly concentrations in a year, ie, 175 hours can exceed 1.5 ouE/m3, (ES Vol 10). The largest impact is predicted to be 75 hours of odour in a year at a residential building to the west of the site.

10.24 While Thames Water has made much of the treatment standards they intend to achieve for extracted foul gases using the latest carbon filter technology, the likelihood is that even treated gases will smell albeit not necessarily with a foul odour or creating a nuisance. The testing for nuisance smell is measured for the presence of hydrogen sulphide as this is a detectable gas. This therefore does not rule out the possibility of smells from other undetected gases being emitted from the site even if that were not to constitute being within the definition of a nuisance. Thames Water state that the smells, particularly when discharged from the 15m vent column will be dissipated more easily. But the Carnwath Road site has high rise residential buildings within the immediate vicinity. The odour monitoring is at the site edge but this does not define the height at which it is monitored or measured.

We acknowledge that the activated carbon removes 99 per cent of hydrogen sulphide and 95 per cent of other odours. The dispersion modelling applies both these removal rates for predicting the hydrogen sulphide and odour concentration respectively both at ground level and at buildings. The model takes the lowest emission concentration released from the ventilation column to be 200ouE/m3, which represents the smell of carbon. The predicted maximum one hour odour concentration at ground level, which represents an amenity, is 28ouE/m3 equivalent to a very low odour. Otherwise the 98th percentile at ground level is 0.3ouE/m3. The dispersion modelling predicts odours at different heights. The maximum one hour concentration at a building is predicted to be 120ouE/m3 equivalent to a low odour.

10.24 The odour measurements need to be at the point of release into the atmosphere if there is to be any confidence in the measurement of smell.

The odour measurement does not need to be at the point of release to the atmosphere. Both we and the Environment Agency prefer to measure the hydrogen sulphide (H2S) concentration post-treatment since this gives the most accurate and conservative value. Measurements at the top of the ventilation column can be diluted by the blow back of air and may not be representative.

Regarding paras. 10.24-10.26, the H2S measurements would be made inside the vent both before and after passing through the



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carbon filter to ascertain the effectiveness of the filter and determine the concentration in the released air. The odour benchmark for odour impact studies is set for locations where the general public could be exposed to odour. Our dispersion modelling assessed odour at ground level and at height at buildings where people could be exposed, including those adjacent to the Carnwath Road Riverside site. It is not appropriate to assess odour where no-one could smell it,eg, the point of release.

10.25 The measurement of odour is carried out at ground level at the site boundary. The logic of this being that this would present the most severe case for an adjoining neighbour at ground level and that one of the ways of reducing the impact of the odour is to discharge the gases via a 15m high chimney allowing the gases to drift at a higher than ground level, and considerably above the height of the average residential dwelling. However at Carnwath Road the immediate neighbours to the north are in the Piper Building which is a high rise tower block situated well above the height of the exhaust chimney and hence in line for drifting exhaust gases. This building has balconies and roof terraces.

The predicted odour concentration at different heights was modelled and the results are shown below. This demonstrates that in all cases the Environment Agency standard would be met:

Height 98th per centile Max

6m 0.2ouE/m3 39ouE/m3

12m 0.6ouE/m3 120ouE/m3

15m 0.4ouE/m3 13ouE/m3

10.26 Measuring the odour at the site boundary at ground level when the point of discharge is at 15m above this level and within the site does not reflect accurately the risk of local residents being able to identify the smell.


10.28 The risk assessment for the release of odour and creating a nuisance uses distorted scales and the scores given to odour risk appear to be too conservative as the worst case scenario states that there is no odour risk during normal operations. (Normal must mean when up to 2 per cent of foul gases are

See our response to 10.31 below.

Regarding paras. 10.28-10.37, the scale is 0 to 5 for the odour severity with 0 and 1.5 ouE/m3 for the 98th percentile of hourly values as the two extremes. 1.5 ouE/m3 is the level for no significant pollution and is considered to be stringent. A score of 0



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expelled without treatment) to 5 is given for the likelihood of causing a nuisance. As the 98th percentile odour concentration is predicted to be less than 1.5 ouE/m3 at all sites, including Carnwath Road Riverside, for the typical use year or normal operation, the severity is deemed to be 0 or 1. The likelihood of nuisance is deemed to be 1 as odour concentrations are predicted to be less than 1.5 ouE/m3 for the 98th percentile. The odour emission risk is therefore 0 or 1 as the predicted concentrations are less than the Environment Agency benchmark and less than the CIWEM guideline for 98th percentile concentrations of 3 ouE/m3, which are unlikely to cause a significant detriment to amenity.

10.31 For the odour severity, the developer has opted to score the extremes from 0 OUe/m

3 to 1.5 OUe/m3, the latter being the

value which causes a nuisance. The value of 1.0 OUe/m3 is

defined under Environment Agency Odour Management Guidance H4 as an odour which half of people are unable to detect. This scale from 0 OUe/m

3 to 1.5 OUe/m3 for the odour

severity means that any score from 0 OUe/m3 to 1 OUe/m

3 would be virtually undetectable. Logic suggests that the entire odour severity from 0 to 5 should be represented by the two extremes from barely detectable (1.0 OUe/m

3) to a nuisance (1.5 OUe/m

3) This should be the base line value rather than zero.

The risk assessment is a methodology we applied for sewage treatment works to assess the effect on odour released due to components of the works failing. For sewage treatment works, the severity is likely to be high, but in the case of the Thames Tideway Tunnel, since the odour releases would be so infrequent and of such a low concentration, the severity in effect would be negligible in comparison. This is why such a low score was applied.

10.33 For Carnwath Road, which is presented as the worst case scenario, the applicants have given a score of 1 out of 5 for odour severity and 1 out of 5 for likelihood of such an event occuring which gives a combined score of odour emission risk of 1 (1x1). An odour severity of 1 given by Thames Water as the worst possible scenario represents an odour value of 0.3oue/m

3. An odour severity of 1.0 oue/m3 is barely detectable

It is correct to say that there is no risk of a detectable smell within 98th percentile. The risk assessment considered the whole year and not just the 2 per cent of the time when odours would exceed 1.5ouE/m3; thus in this context the risk assessment is plausible. In any event, the odour dispersion predicts that the maximum one hour odour at ground level is 28ouE/m3 and at a receptor 120ouE/m3. Comparing maxima, both these levels of odour are



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to the average human being. The applicant’s assessment is that there is no risk of a detectable smell, despite the Environment Agency’s 2 per cent standard where the smell levels can be exceeded. The council considers that this is not plausible.

less than the peak background odour measured on site of 440ouE/m3.

10.34 This means they consider that the worst possible severity of odour emission would be completely undetectable to humans. As a consequence even if this were to occur all the time there would be no risk of any odour being detected. An explanation of these measurements is provided in figure 22 below.

Since only treated air would be released for 99.7 per cent of the time during the typical year no detectable odour would emante from the tunnel for more than 98 per cent of the time, as per the Environment Agency guidance. On the rare occasions when the treatment capacity would be exceeded, the level of odour would be very low and lower than the smell from existing CSOs discharging.

10.36 With the severity ratings from 0 to 5 a score of 3.3 (equivalent to 1.0oue/m

3) would have to be achieved before it would become detectable and a score of 5 (equivalent to 1.5oue/m

3) before it becomes a nuisance. This is a dilution of the risk. Scores of odour severity should be scored over the range from when it is detectable to the human being to when it becomes a nuisance.

The risk table was not indented to dilute risk, it was intended to demonstrate that the risk of odour is negligible and odour would be undetectable compared to odour from sewage treatment works.

10.37 The ventilation strategy assumes that a level of escape of untreated foul gases is acceptable but the risk assessment takes no account of this, suggesting that, even in the most extreme cases the level of risk of a smell is undetectable with a score 1 out of 5 which equates to a 0.33 oue/m

3 score which is undetectable.

Correct. When untreated air escapes from the 15m high ventilation column it would be diluted by dispersion and have a very low concentration (about 120ouE/m3 at a receptor) – less than background peak odour measured in Carnwath Road Riverside (440ouE/m3). The 0.3ouE/m3 is the 98th percentile applied to assess risk throughout the year rather than risk during 0.3 per cent of the year when treatment would be by-passed.

10.38 The applicant’s risk assessment analysis suggests that there are no risks of odour during all operating scenarios at Carnwath Road Riverside site which is not plausible.

The object of the risk assessment is precisely to show that for the 99.7 per cent of the time, when the released air would be within the treatment capacity of the ventilation plant, the risk of odour is negligible. When the capacity is exceeded for 23 hours out of



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8,784 hours, the odour released would be very low and less than the peak background odour at Carnwath Road Riverside. If all the air released during the typical year were treated, the plant capacity would need to increase from 20m3/s to 80m3/s; a ventilation plant four times bigger would be required at Carnwath Road Riverside to treat this one hour peak air exhaust.

Regarding paras. 10.38-10.42, LBHF states that our risk assessment suggests that there is no risk of odour during all operating scenarios at Carnwath Road Riverside. LBHF has misunderstood the risk assessment. The risk assessment concludes that there is a low risk of nuisance from odour, rather than no risk of odour. The ES Vol 10, Table 4.6.1 shows that there would be 22 hours of odour at the worst-affected location at ground level and 75 hours of odour at the worst-affected building. The Environment Agency odour benchmark is based on there being up to 175 hours of odour (> 1.5 ouE/m3) in a year before there is significant pollution.

10.41 As the Applicant elects not to assess the emergency option stating that even in the event of total breakdown of all sites the passive filters would continue to operate. This means that when there is a break down with the active ventilation the surrounding air remains protected as any expelled air would pass through passive filters and remain undetectable. If the passive filters are able to manage exhaust gases being released from the tunnel as it fills with sewage then the sole purpose of the air extraction is to reduce odour within the tunnel rather than dealing with any release. There can be little purpose in this if it can be adequately filtered via the passive filters. This explanation of the extreme event must question the purpose and value of the active system.

The purpose of the active ventilation plant is to maintain the tunnel at a pressure less than atmospheric to prevent any release at the passive filters and promote the one air change per day in the tunnel empty scenario. During this scenario, the ventilation plant would operate at a nominal rate, with Carnwath Road Riverside and Abbey Mills Pumping Station extracting air at 15m3/s. When the tunnel fills with wastewater, all the active ventilation facilities ramp up to maximum capacity in order to maintain the low pressure for as long as possible before the inflow of wastewater displaces air, which pressurises the tunnel. Thus the active ventilation plant is specifically required to manage air movement, which would otherwise be released in an unpredictable manner. The emergency condition when all active ventilation facilities are



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inoperable is equivalent to a London wide black-out, which is considered a rare emergency when councils and the public would have greater concerns than odour.

10.42 The council’s observations on this risk assessment are as follows:

1. The odour values scored between 0 and 5 should be over the range of 1.0oue/m

3 to 1.5oue/m3 rather than the 0oue/m

3 to 1.5oue/m

3 because they are virtually undetectable below 1.0oue/m

3.

2. While odour relates to scores not exceeded 98 per cent of the time, this infers that 2 per cent of the time this value may be exceeded and this is not accounted for in the risk assessment and is deemed to be acceptable performance.

3. The assessment suggests that the site is either working actively, or when broken down supported by other sites, or in times when the entire Tideway Tunnel system is not working the site would still not be a nuisance because the odour would pass through passive filters. This does not take account of times when the systems are bypassed and discharged directly into the atmosphere.

4. The Air Management Plan suggests that in the most extreme scenarios the smells would be no worse than that experienced from the CSO but we should be reminded that there are no CSO discharges from the Carnwath Road Riverside.

5. The council objects to the presumption that treated gases would not smell and that the 24/7 gases extracted from the tunnel at Carnwath Road, after treatment, would not smell. While it may be that the hydrogen sulphide, the gas used to

Responses:

1) The range of 0 to 1.5ouE/m3 is taken in order that the 98th percentile of 0.3ouE/m3 can be represented. This value could not feature in the range 1 to 1.5ouE/m3. The whole point of this exercise is precisely to demonstrate that the level of odour is undetectable.

2) Conversely if the risk assessment considered the 2 per cent of the time that 0.3ouE/m3 would be exceeded, this would accentuate the effect of odour and not be representative, since for 98 per cent of the time the odour would not be detectable.

3) The 23 hours during the typical year when the capacity of the air treatment would be exceeded is included in the 8,784 hours of the whole year analysis (the typical year includes a leap year), therefore by-passes are taken into account.

4) Correct, there is no CSO at Carnwath Road Riverside, but Hammersmith Pumping Station contributes a significant volume of discharge (approximately 2.2m3 during the typical year), which flows past Carnwath Road Riverside.

5) Activated carbon would remove 99 per cent of hydrogen sulphide and 95 per cent of other odours. At the ventilation column, treated air was assigned a minimum odour level of 200ouE/m3, which is the smell of carbon, but after dispersion this is odour would be undetectable. Hydrogen sulphide is already present at Carnwath Road Riverside at peak levels over 35μg/m3 equivalent to over 400ouE/m3.

6) The methodology is plausible when considered over one year in



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detect smells, has been removed and therefore the measurement of smell would be undetectable, the remaining treated expelled gases may still smell in the same way that air fresheners do. While this may not constitute a nuisance it would still be unacceptable in a residential area.

6. The risk assessment that in all modelled scenarios the risk of smell would be undetectable is not plausible.

7. Any smells, whether treated or untreated in such a densely populated and prime riverside frontage area where there are high rise residential buildings locally is completely unacceptable, particularly when there are other non-residential areas further upstream that could better and more appropriately accommodate such a system and that

8. the Environment Agency standard, which TW say is used nationally, is not appropriate to be applied in a dense urban environment such as that found at Carnwath Road.

accordance with the Environment Agency guidance.

7) Presently the site is not as densely populated as other parts of London. There are a number of commercial and business in the vicinity and the wharf itself is derelict. There may be future plans to develop high class residential properties along the frontage but such properties would face increasing sewage smells from the river if the project does not proceed.

8) There are a number of non-residential areas upstream, including Hurlingham Park and Bishop’s Park, but these were ruled out during early phases.

The Environment Agency H4 guidance is specifically designed to protect residents in the vicinity of works that can emit potentially malodorous exhaust, therefore it is the appropriate standard to apply.

9 Aquatic and terrestrial ecology through direct habitat los (Response to Section 11 of LIR)


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9 Aquatic and terrestrial ecology through direct habitat loss (Response to Section 11 of LIR)

9.1 General matters


11.5 The council is concerned that the construction phase will have an adverse impact on aquatic and terrestrial ecology through direct habitat loss. The council considers that the proposed mitigation measures are inadequate and not proportionate to the potential impacts identified.


11.6 The Thames Tideway Tunnel will have an impact on habitats and species within the borough at Carnwath Road, Hammersmith Pumping Station and Acton Storm Tanks located across the borough boundary. Thames Water and its consultants have delivered a wide range of ecological surveys through desktop analysis and field surveys which are included in their application. While much of the information, especially the habitat and species surveys have delivered useful and new information and understanding, this has not fed into appropriate mitigation where effects have been identified. For example, the Council is concerned that the proposed jetty area at Carnwath Road will have a negative impact on aquatic ecology, but the mitigation put forward by the applicant is unclear and insufficient. It does not identify the specific species that would be affected at this site and is unclear about how appropriate mitigation measures would be secured. The local authority has a duty of care towards the Freshwater and the

A full assessment of effects on aquatic ecology, including temporary habitat loss during construction at Carnwath Road Riverside, was completed and is provided in ES Vol 10, Section 5. Specific species are discussed in the baseline and the assessment of effects. This assessment takes account of mitigation measures designed to ensure that there would be minimal impact on habitats and species and would be secured through the CoCP and project-wide Requirement PW6.



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inter-tidal mudflat habitats under Section 41 of the Natural Environment and Rural Communities Act 2006 and we therefore require further clarification and information in order that we can be satisfied that where there is a loss or impact on a specific habitat or species that an appropriate condition or requirement is secured in the Development Consent Order (DCO).

11.7 The ecological analysis and field surveys undertaken by the applicants appear to indicate that there will be a minimal impact on the majority of the aquatic habitat and that only the proposed jetty areas will pose longer lasting negative impacts on the aquatic habitat directly affected by the build. The council considers that mitigation for this should be demonstrated providing an equal or greater net quantity of habitat delivered post construction on site and/ or there should be an increase in the value in the habitat and a no net loss of species on and around the sites for the longer term.

As noted in ES Vol 10, Section 5.8, we do not consider it possible to mitigate the significant adverse effect arising from the loss of smelt spawning habitat should the campshed plus jetty option be taken forward. However, the effect would be temporary and the foreshore at Carnwath Road Riverside would be reinstated on completion of works.

Habitat compensation for temporary habitat loss is therefore not proposed. Compensation where permanent loss would occur from foreshore structures is being progressed through the Habitat Compensation Working Group (see our responses to first written questions 2.7 to 2.11). The group has agreed the area required for aquatic habitat compensation.

11.8 The council is equally concerned that direct habitat change/loss will negatively impact on terrestrial ecology in the areas around the proposed construction sites and as with the aquatic ecology it is not clear which specific species and habitats might be affected. The council considers that appropriate mitigation is required which is specific to the habitats and species that are to be affected. For example, the Council considers that it is essential that the applicants include mitigation through conditions and/or requirements in the DCO to mitigate the impact on feeding/ foraging of protected bird and bat species throughout the construction phase.

A full assessment of effects on terrestrial ecology, including temporary habitat loss during construction (at each site in Section 11 of the LIR including Acton Storm Tanks) was completed and is provided in Section 6 of ES Vols 4, 5 and 10. Each site volume includes details of specific species. The assessment takes account of the necessary proposed embedded mitigation measures (secured through the CoCP and design principles) designed to minimise impact on habitats and species. It must be noted that no residual significant adverse effects requiring mitigation are predicted on terrestrial ecology at any of the three sites.



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11.9 The council is concerned that the construction phase will have an adverse impact on SINC sites, major habitat sites and foraging sites in close proximity to the build sites. The council considers that the proposed mitigation measures are inadequate and not proportionate to the potential impacts identified.

See our response to 11.8.

11.10 The areas of habitat that are of concern within 500- 750 metres of the build sites and known or likely to be bat foraging sites. For the purposes of consideration, ecological descriptions of Sites of Importance to Nature Conservation (SINC), and the other major habitat sites within 750 metres of the proposed development sites have been listed. The direct loss of immediate habitat may be minimal but the potential for disruption to foraging bats is a concern and should be adequately mitigated for in the construction phase. Of particular concern is the light spillage along the Thames from additional barges carrying materials from March to October in the potential bat foraging times. This needs to be demonstrated as having minimal impact. Additional river traffic should also demonstrate a minimal effect on foreshore feeding birds or for example migrating common eel as a protected species.

The loss of small amounts of foraging habitat would result in some displacement but this is not likely to affect local bat or wintering bird populations and no significant adverse effects are predicted to occur for which further mitigation, beyond that already embedded in the CoCP or design principles, would be required. There would be no significant effects on the Sites of Interest for Nature Conservation mentioned in the LIR except the River Thames Site of Interest for Nature Conservation in relation to aquatic ecology should the option of a campshed and jetty be progressed, see our response to 11.7 for further information.

11.12 Porous surfaces

To help with sustainable drainage and healthier tree plantings, surfaces should demonstrate at least a 50 per cent reduction in surface water runoff rates. The design and materials used should be agreed in advance with the local authority.

We are committed to ensuring that post-development surface water run-off rates do not exceed existing rates (see Section 3.6 of the Design Principles). This includes a commitment (SDRN.04) to the Mayor’s essential standard as follows:

a. use SuDS measures, wherever practical

b. achieve 100 per cent attenuation of the undeveloped site’s surface water run-off at peak times (ie, Mayor’s Preferred



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Standard). Where 100 per cent attenuation is unachievable, justification shall be provided. Where 100 per cent attenuation is unachievable, achieve as a minimum 50 per cent attenuation of the undeveloped site’s peak surface water run-off at peak times (ie, the Mayors Essential Standard).

11.13 The aquatic habitat, inter tidal zones and river wall

The areas of habitat that currently exist will be lost through the construction phase. Sufficient areas in size and species richness as mitigating habitat should be agreed with the local authority prior to construction.



None raised.


None raised.



11.11 The main areas of habitat that will be lost which are of concern are the mudflat areas and river wall where the jetties may be required. All habitat areas provided as mitigation should have ecological management and maintenance plans in perpetuity agreed by the local authority. There is also waste land that

See our response to paras. 11.7 and 11.8 above. It should also be noted that the design principles include the provision of brown roofs at both Hammersmith Pumping Station and Carnwath Road Riverside.



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may be lost on the Carnwarth Road Riverside site that is a habitat contained with the London Biodiversity Action Plan. The mitigation for these areas should demonstrate an increase in area of habitats or enhanced species richness. For example, Green/brown roofs can help to increase local biodiversity, increase evapotranspiration and help to attenuate rainfall. The mixes used should encourage native species and be agreed with the local authority in advance. The council does not consider that such things have been considered in the application and should be revisited by the applicants to establish more appropriate and effective mitigation.

10 Equality (Response to Section 12 of LIR)


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10.1 General matters


12.7-12.10 and 12.35

Consultation

(See LIR for full text)

The overriding aim of the public consultation process was to ensure that all interested or potentially affected parties had the chance to understand and influence our proposals. Our Community consultation strategy and Statement of Community Consultation were published in 2010 (prior to phase one consultation), and revised and reissued in November 2011 (prior to phase two consultation). These documents outlined our intention and proposed methods to consult on our proposals. We also sought to adhere to government guidance and ensure an equal and accessible process.

The consultation approach set out in the Statement of Community Consultation, included exhibitions and other methods to encourage people to comment. In addition to publishing material in the London Evening Standard, we wrote to individuals living in the vicinity of sites; landowners; statutory consultees and community organisations. We sought assistance from the relevant local authorities to help identify, through a community audit, relevant community groups. Each exhibition venue was assessed to ensure it was accessible and did not disadvantage any groups from visiting. The same approach was adopted with public meeting venues, unless a specific group required the meeting to be held in a venue of its choice.

We made a conscious decision to provide details of all materials in hard copy as well as online via our dedicated consultation website

http://www.thamestunnelconsultation.co.uk/doclib/community-consultation-strategy-2/?came_from=411

http://www.thamestunnelconsultation.co.uk/doclib/statement-of-community-consultation-2/?came_from=411

http://www.thamestunnelconsultation.co.uk/doclib/statement-of-community-consultation-2/?came_from=411



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(www.thamestunnelconsultation.co.uk) to ensure ease of access to information. We provided free copies of documents and DVDs on request.

We deliberately provided a range of methods to submit feedback, including comment cards at exhibitions, emails direct to [email protected], feedback questionnaires (with a freepost envelope), and an online feedback questionnaire. The electronic and hard copy feedback questionnaires contained an equality sheet; however completion was not mandatory. We acknowledged that the variety of feedback methods would mean that equality information would be difficult to assemble from all respondents. However, we considered that the overriding objective was to maximise feedback to each phase of consultation.

While the consultation results are invaluable, we need to be mindful of the small number or respondents who completed the equalities form. We must not be preoccupied with equality groups that may appear to be over-represented or under-represented in the responses. The vast majority of respondents did not complete the equalities questionnaire, which suggests that no conclusions can be made on the representativeness of such responses.

12.14 & 12.32

Data

The EqIA uses Census 2001 data and this should be updated as there are more recent datasets now available from the 2011 Census. The risk of using old data is that when the Secretaries of State for Communities and Local Government, and Environment and Rural Affairs (‘the Ministers’) make a decision on the application by Thames Water, they will make it on the wrong data and thus risk a challenge:

Census data overall

The Equalities Impact Assessment (Doc ref: 7.16) (EqIA) was based on the latest comprehensive data sets from Census 2001. The report (para. 6.3.1) acknowledges the issues in using this dated set of statistics. Mid Year Estimates were only available for population estimates and not the full range of data sets required for equality groups; therefore they were not used in the EqIA.

Since the release of Census 2011, we completed a brief analysis of the new data sets and considered in detail the profile of LBHF. We reviewed the use of the 2001 census data in the assessment

http://www.thamestunnelconsultation.co.uk/

mailto:[email protected]

http://infrastructure.planningportal.gov.uk/wp-content/ipc/uploads/projects/WW010001/2.%20Post-Submission/Application%20Documents/Other%20Documents/7.16_Equalities_Impact_Assessment.pdf



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We recommend that all analysis based on 2001 Census data are revisited by Thames Water and the EqIA adjusted accordingly, using 2011 Census data.

in order to determine the extent of any potential change. The table below provides a summary of:

a. how the 2001 Census data were used within our technical assessments

b. whether any relevant updates have been (or are scheduled to be) released from the 2011 Census

c. whether the 2011 Census data may affect the outcome of the technical assessments presented in the application.

Table 1: Implications of 2011 Census data for equalities assessment

How Census 2001 data were

used

Relevant updates from 2011 Census?

Potential effect of 2011 Census

data on outcome of assessment

Equalities

The following data sets from the 2001 Census were analysed for the socio-demographic profiling around each site and along the entire route alignment:

age

The 2011 Census data sets used to determine age, ethnicity, gender, religion and disability, non car household, marriage and civil partnerships were:

Age: Age Structure, 2011 (KS102EW)

Ethnicity: Ethnic Group, 2011

We are reviewing the use of the 2001 data in the EqIA to determine if there are any implications.

http://neighbourhood.statistics.gov.uk/dissemination/LeadTableView.do?a=7&b=6275295&c=wandsworth&d=13&e=62&g=6339582&i=1001x1003x1032x1004&m=0&r=1&s=1365619418922&enc=1&dsFamilyId=2474







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ethnicity

gender

religion

disability

The assessment also examined deprivation, sexual orientation, pregnancy and maternity, marriage and civil partnerships, immigration and crime data; however these data sets were not sourced via the census.

(QS201EW)

Gender: Usual Resident Population, 2011 (QS104EW)

Religion: Religion, 2011 (QS208EW)

Disability: Long-Term Health Problem or Disability, 2011 (QS303EW) – appears to be the closest comparable stat to the 2001 dataset ‘Long Term Limiting Illness’, used in assessments

Non Car Households: Car or Van Availability (QS416EW)

Marriage & Civil Partnership: Marital & Civil Partnerships Status (KS103EW)

These data sets are available now.








http://neighbourhood.statistics.gov.uk/dissemination/LeadTableView.do?a=7&b=6275295&c=wandsworth&d=13&e=6&g=6339582&i=1001x1003x1004&m=0&r=1&s=1365619710984&enc=1&dsFamilyId=2504







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12.15 Paragraph 8.4.17 on p55 uses the terms: ‘wider relevant local authorities’, ‘wider local authorities’ and ‘Greater London’ without explaining the differences or when each is applicable according to Thames Water. This should be made clearer for the Ministers. For the purposes of this response, LBHF uses ‘London’ to mean all London boroughs, and LBHF, to mean the London Borough of Hammersmith and Fulham.

The terminology used in para. 8.4.17 is as follows:

‘wider relevant local authorities’ – the local authorities in which the main tunnel and connections tunnels would pass beneath

‘wider local authorities’ – the local authorities in which the main tunnel and connections tunnels would pass beneath

‘Greater London’ – the administrative area comprising the City of London and 32 London Boroughs.

12.16 Age

A disproportionately high number of over-65s responded: 21 per cent vs. overall population of 11 per cent. This is a large difference and one that has not been addressed in the analysis of impact on Age. Just one example of why this matters, can be found on p101-102 of the EqIA, which analyses the impacts of moving a bus stop. (see Direct and indirect impacts below)

The assessment examined the potential equalities impacts on a variety of individuals and communities in the vicinity of each site. The equality groups, including age, were identified within a 250m buffer of each site and demographic proportions assessed against the London Borough in which the site is located. This enabled an appreciation of the representation of the equalities groups in the 250m buffer area (see EqIA Table 8.2). This analysis was used to assess the impacts for relevant equalities groups at each site, see EqIA Tables 9.1 to 9.24.

12.17 – 12.25

Disability (See LIR for full text) We acknowledge the widely recognised difficulties in defining disability due to the diverse nature of conditions and impairments; therefore the assessment considers both long-term limiting sick and disability living allowance to enable a more rounded approach to examining impacts on those with a disability. This is demonstrated in EqIA Tables 9.1 to 9.24 and the socio-demographic profiling in Appendix D.

EqIA para. 8.4.17 compares the proportions of disabled respondents with the proportions of those claiming disability living allowance in the wider boroughs, which is comparable.

Comparison of the proportion of disabled consultation respondents (3 to 4 per cent) with Census 2011 long-term health problems or



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disability1 proportions in the relevant borough and Greater London is still comparable (7 per cent) and, in accordance with our assessment criteria (Table 8.2), the representation of this equalities group was proportional.

The table produced in Issue 12.22 has been updated below using Census 2011 long-term health problems or disability (QS303 EW).

Ou

r b

aseli

ne

(%)

Cen

su

s

2001

Co

nsu

ltati

on

resp

on

ses

(%)

Cen

su

s 2

01

1

data

LB

HF

(%)

Cen

su

s 2

01

1

data

Lo

nd

on

(%)

Dif

fere

nc

e

LB

HF

usin

g

ou

r b

ase

lin

e

(%)

Dif

fere

nc

e

Lo

nd

on

usin

g o

ur

baselin

e (

%)

15 (LTLI)

4 (DLA)

3 to 4 7.3* 6.9 * 2.3 1.9

LTLI – long-term limiting illness DLA – Disability Living Allowance

*Category used - ‘day to day activities limited a lot’

12.26 – 12.28

Ethnicity (See LIR for full text) The assessment classifies the term ‘white’ as White British, Irish, Gypsy or Irish Traveller and Other White. See our response to para. 12.16.

The table produced in Issue 12.26 has been updated as below using Census 2011 Ethnic Group (QS201EW). This demonstrates

1 Census 2011 (QS303 EW) ‘day to day activities limited a lot’ category used.



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that the consultation respondents are not proportionally representative of LBHF or Greater London ethnic demography.

Ou

r b

aseli

ne

(%)

Cen

su

s 2

00

1

Co

nsu

ltati

on

resp

on

ses (

%)

Cen

su

s 2

01

1

data

LB

HF

(%

)

Cen

su

s 2

01

1

data

Lo

nd

on

(%)

Dif

fere

nc

e

LB

HF

usin

g

ou

r b

ase

lin

e

(%)

Dif

fere

nce

Lo

nd

on

usin

g

ou

r b

as

elin

e

(%)

69 White

31 BME

90 White

4 BME

6 Did not respond

64 White

36 BME

43 White

57 BME

5 White

5 BME

26 White

26 BME

12.29 - 12.31 (please see LIR for associated table in 12.29)

Religion

LBHF disputes that the proportion of respondents is in line with the overall population and that the response rate to the consultation is therefore in line with the proportion of Londoners of different religious groups.


The table produced in Issue 12.29 has been updated as below using Census 2011 Religion Group (QS208EW). This demonstrates that the consultation respondents are proportionally representative of LBHF non-Christian demography but not of Greater London.

Ou

r b

as

eli

ne

(%)

Cen

su

s 2

00

1

Co

ns

ult

ati

on

res

po

nse

s (

%)

Cen

su

s 2

01

1

da

ta L

BH

F (

%)

Cen

su

s 2

01

1

da

ta L

on

do

n

(%)

Dif

fere

nc

e

LB

HF

us

ing

ou

r b

as

eli

ne

(%)

Dif

fere

nc

e

Lo

nd

on

us

ing

ou

r b

as

eli

ne

(%)

16 Non Christian

14 Non Christian

14 Non Christian

22 Non Christian

5 Non Christian

3 Non Christian



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12.33 – 12.34

LGBT

Where there are gaps, the EqIA uses other datasets and this approach follows best practice and is a logical way to fill the gaps. However, the quoted statistic for LGBT people is disputed by this authority. Thames Water give a figure of two per cent for Greater London and six per cent across wider local authorities [p55, TW EqIA]. However, LBHF uses the figure of between six and ten per cent as given by the Department for Trade and Industry and supported by a LBGT charity that carried out a London-wide mapping exercise of the LBGT voluntary sector. This is the figure we used for our Core Strategy. It is likely that in larger cities, the LGBT figure will be higher than is towns or areas with less access to support services and so we recommend that this figure is revisited by Thames Water and the EqIA adjusted accordingly.

The assessment examined data from http://www.lgbtconsortium.org.uk/ website for analysis at local authority level. We propose to examine the data suggested by LBHF and any new data sets and update the full assessment accordingly.

12.36 – 12.41

Direct and Indirect impacts (See text in LIR. Too lengthy too repeat here).

We will consider, as part of any required full assessment update, a review of the analysis and outcomes of direct/indirect impacts on equalities groups.

12.42-12.43

Children (See LIR for full text) The full assessment on children may be reviewed in the light of any Census 2011 updates.

12.44-12.49

Women (See LIR for full text) The full assessment on women may be reviewed in the light of any Census 2001 updates.

11 Hammersmith Bridge: Settlement (Response to Section 13 of LIR)


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13.3 “The bridge is weight limited to 7.5 tonnes with exceptions for buses and emergency service vehicles and has had a history of problems with the Barns support tower. The borough is therefore naturally concerned over the potential impact that a shallow tunnel may have if driven in close proximity to the Barnes chain anchor foundation.”

Noted. To address LBHF’s concerns, we are in communication with the borough regarding an updated structural assessment of the bridge. The current conservative assessment predicts a ground movement of less than 1mm. Movements generated by the seasonal thermal effects on the bridge are likely to be far in excess of 1mm.

13.6 “The council is concerned over the proximity of the tunnel alignment, particularly in the permitted extreme to the below ground anchor chambers on the south eastern abutment of Hammersmith Bridge.”

Noted. The updated assessment, referred to in 13.3 above, will include the proximity of the tunnel. We are communicating with LBHF and have pointed out that the alignment in the updated assessment would be further from the bridge than in the original assessment. As such, predicted effects are likely to be even less than 1mm.

13.7 “The DCO application submitted by Thames Water includes a report "Tunnel and Bridge Assessment Report” (Tunnel and Bridge Assessment Hammersmith Bridge ref: 0.15.10) that gives precise tunnel co-ordinates of the tunnel as it passes the Hammersmith Bridge southern abutment. The council's consultants have assessed the impact of the tunnel at this given location and have determined agreement with the conclusion that the maximum initial settlement would be in the region of 1mm (Appendix 8). However they advise that the effects of long term settlement should be considered for such a structure, given the bridge support elements are so remote

Noted and we welcome the statement that LBHF’s engineers are in broad agreement with the 1mm movement prediction.

We are communicating with LBHF and have provided a copy of the Report on Long-term Settlement (9.10.05) to the borough. We have requested a technical meeting with LBHF to address its concerns as it is clear that its opinion on long-term settlement does not accord with the Report on Long-term Settlement.

http://infrastructure.planningportal.gov.uk/wp-content/ipc/uploads/projects/WW010001/2.%20Post-Submission/Representations/23-09-2013%20-%20Applicant's%20submissions%20made%20for%20the%20deadline%20of%2023%20September%202013./9.10.05_Report_on_Long_Term_Settlement.pdf



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from each other. It is not satisfactory to assume the shallower settlement gradients from long term effects are less detrimental. In this case the relative settlement between supports is of key interest and this must be clarified in the assessment study.”

13.8 “Of greater concern is that the Works Plans (refDCO-WP_000-ZZZZZ¬010005) for the tunnel as it passes Hammersmith Bridge show the tunnel to be in a significantly different position (moving the tunnel vertically to a datum from 21m to 9m below the base of the Barns Anchor Chamber foundation and moving 0.5m horizontally near the foundation. The calculations need to be re-run using this revised tunnel location information to determine whether the settlement is of greater concern. Any excessive settlement of the anchorage chamber would have an inbalancing affect on the suspension system which may adversely affect the catenary suspension chain, hangers and tower bracing elements. Our Consultant has recommended monitoring of the structure before and during construction as well as afterwards for a period of 6 months (Appendix 8).”

Noted. As stated in 13.3 above, we are communicating LBHF regarding an updated assessment and will share the findings of this assessment.

13.9 “Additionally the DCO allows, if permission is granted, for the tunnel to be sited anywhere within the application footprint horizontally and, +/-3.0m vertically. If the tunnel were to be positioned in the worst case scenario that might be permitted, then the settlement would increase to 38mm which would be an unacceptable tolerance.”

Noted. The assessment is based on conservative geotechnical parameters to address this point. These parameters led to conservative movement predictions on which the structural assessment was based. This conservatism compensates for the fact that the tunnel alignment has limits of deviation. This analytical approach is standard industry practice and is common on all tunnelling projects.

13.10 “The Council require clarification of the intended tunnel alignment as it passes the southern abutment to Hammersmith Bridge and also an amendment of the requirements to confine the intended position of the tunnel within acceptable limits of

Noted. The tunnel alignment and limits of deviation are given in the application documents.



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allowable deviation. The council further requires structural monitoring of the bridge to ensure this sensitive structure is not unduly affected.”

13.11 “The council notes in the Settlement Information Paper doc ref 7.21 that condition and monitoring can be used for assistance with settlement claims and that their view is that no protective mitigation measures are required for Hammersmith Bridge.”

Noted.

13.12 “The authority does not consider that the approach of paying compensation in the event of movement arising from the construction of the tunnel is the correct approach for this structure notwithstanding that any settlement and damage to the integrity of Hammersmith Bridge would be subject of litigation. The authority prefers an approach that would minimise or remove the risk of any movement to the foundations of this bridge.”

Noted. We are communicating with LBHF and have requested a technical meeting. We have no objection to the principle of structural monitoring for a period before, during and after construction at a given location, where the assessment concludes that such monitoring has merit.

13.14 “We did make it clear and express our concern because of the history of structural problems with the Barns side of the bridge during its 150 history over the risks of any work within the sphere of influence of the structure. We are now aware that the worst case position of the tunnel is extremely close to the structure and that should there be any horizontal or vertical movement in the Barnes abutment arising from tunnelling activities this will have an impact either on the safety of the bridge or give rise to bridge strengthening requirements with a possible reduction in the residual life of this listed structure.”

Noted. As stated in 13.3 above, we are communicating with LBHF regarding an updated assessment. It is conservatively expected that any effects on the bridge will be less than 1mm.

13.15 “We note in the Settlement Information Paper that protective measures may be considered depending on the methods of tunnelling proposed by the contractor and on this basis we would require further consideration of the impact of the tunnel

Noted. As stated in 13.12 above, we have no objection to the principle of structural monitoring for a period before, during and after construction at a given location, where the assessment concludes that such monitoring has merit.



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on the structure and for Thames Water to fund the continuous structural monitoring both pre- and post-construction.”

13.16 “Because of the concern over the proximity of the tunnel to Hammersmith Bridge the borough is engaging consultants to validate TW’s assertion that no protective measures are necessary and also to determine whether the assessment methodology is appropriate for a structure such as Hammersmith Bridge. The impact of any settlement will affect the stresses throughout the bridge because of its design and the nature of the materials it is made of.”

Noted. We are communicating with LBHF and have requested a technical meeting to discuss any concerns with the Council’s consultants.

13.17 “The consultant’s report and their key findings are attached as Appendix 8 to the LIRt.”

Noted.

13.18 “Because the draft regulations permit the tunnel alignment to vary within the application footprint horizontally and plus or minus three metres vertically the assessment needs either to account for the settlement implications for the worst case scenario or for the locus of permitted tunnel locations to be amended to ensure any settlement is within acceptable limits. The council’s initial assessment is that, if the tunnel is placed to its maximum northern alignment horizontally and plus three metres vertically, then the possible settlement to the Barns abutment would be in the order of 30mm.”

Noted. As stated in 13.3 above, we are communicating with LBHF regarding an updated structural assessment of the bridge to reflect the up-to-date alignment.

As stated in 13.9, the conservative nature of the assessment compensates for the fact that the tunnel alignment has limits of deviation.

13.19 “Our consultants have advised that any settlement of 10mm or more would place undue stress on the structural bridge members.”

Noted. We are communicating with LBHF and have requested a technical meeting to discuss any concerns with its consultants.

13.20 “While the methodology adopted by Thames Water to estimate settlement is considered to give conservative results, the methodology does not accommodate ground consolidation and

Noted. As stated in 13.7 above, we are communicating with LBHF and have provided a copy of the Report on Long Term Settlement. We have requested a technical meeting with LBHF to address its concerns as it is clear that its opinion on long-term settlement does



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future settlement.” not accord with the report.

13.21 “Additionally our consultants advise that the bridge is sensitive to any settlement, particularly if the performance of the saddle bearings on the towers is poor. In view of the age of the structure and the current bearings we consider that any settlement of the Barns abutment will overstress the tower bracings.”

Noted.

13.22 “Our consultants have advised continuous structural monitoring be carried out from the start of construction and for at least twelve months following tunnel completion.”

Noted. As stated in 13.12 above, we have no objection to the principle of structural monitoring for a period before, during and after construction at a given location, where the assessment concludes that such monitoring has merit.

13.23 “We have received quotes for continuous structural monitoring but our concerns are over the risks that any movement is likely to trigger. Our view is that any movement on the Barnes anchor chamber will at best affect the residual life of the bridge and at worst give rise to reduced carrying capacity and weight limits and possible unscheduled bridge closures that will disrupt traffic throughout West London.”

Noted. We are communicating with LBHF and have requested a technical meeting to discuss any concerns with the its consultants.

12 Noise (Response to Section 14 of LIR)


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14.5 The DCO application as submitted fails to adequately assess the impact of noise and vibration on construction sites within the borough. The council is concerned that it has been deprived of the opportunity to provide a full and robust assessment of noise and vibration on the proposed work sites as a result of the limited information provided and the timings of updated and new submissions made by the applicant.

We consider that the ES presents a robust and accurate assessment of potential noise and vibration effects. Further information requested by the ExA was submitted on 23 September and 4 November 2013. LBHF has the opportunity to review and respond to this material. In summary, the following material has been submitted:

a. noise contour plans and assessment summary plans

b. responses to first written questions 11.1 to 11.41.

14.6 The council considers that it is not acceptable that an application of this magnitude has been submitted with such limited information on noise and vibration impacts. Noise and vibration will be key issues on many of the proposed work sites. This lack of detail on noise and vibration is evident in the Environmental statements, the Code of Construction Practice (CoCP) and the DCO itself. In particular, the noise mitigation measures proposed are unclear and not secured through the DCO itself, relying instead on vague principles in the CoCP. With such limited information provided on noise and vibration, the Council has been unable to make a full and robust assessment. The shortcomings of the applicant’s data and assessment on noise and vibration has been emphasised by the amount of further information requested in the Inspector’s first set of written questions issued on the 26th September

The noise and vibration control measures presented in the CoCP Parts A and B represent best practicable means and measures that go beyond best practicable means. The measures are secured by the CoCP. The contactor would be bound to the provisions and requirements of the CoCP, both directly via Requirement PW6 and through the construction contract. Non-compliance with DCO Requirements is also a criminal offence and could be enforced by the local authority under Part 8 (Enforcement) of the Planning Act 2008.

Our response to first written question 11.10 provides further detail on how these measures are to be secured and enforced in the DCO.



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2013.

14.7 While the Council appreciates the additional information requested by the ExA in the Rule 6 letter and subsequently in the first written questions, the lack of information on noise and vibration provided by the applicant means that it is very difficult to assess the impact of noise, vibration and dust on sensitive receptors. The council is submitting this Local Impact Report on 4th November 2013, while revised noise contour maps were only made available on 2nd October and the further information from the applicants in response to the first written questions will only be submitted on 4th November. The council questions the timings of these submissions as it only allows very limited time for local authorities or interested parties to consider any potential local impacts associated with the scheme which may be highlighted by the updated information. The council requests that further time is given to the local authority and interested parties to adequately assess the new or revised data that is being provided by the applicants. Without this opportunity the Council considers that a fair and transparent examination of the application may not be achieved.

We consider that the ES presents a robust and accurate assessment of potential noise and vibration effects. We have submitted further information requested by the ExA.

14.8 The council strongly objects to the absence of noise contour mapping for the Carnwath Road Riverside site. We note the ExA’s request in the Rule 6 letter for noise contour mapping for above ground construction sites. The applicants have since provided this information (2nd October) but this does not include Carnwath Road Riverside. The council is concerned that there is no information for Carnwath Road which is proposed as a main drive site with 24-hour working in a residential area with works over 7 years.

Noise contour maps for Carnwath Road Riverside were submitted on 23 September 2013 on the Planning Inspectorate website at:

http://infrastructure.planningportal.gov.uk/wp-content/ipc/uploads/projects/WW010001/2. per cent20Post-Submission/Representations/23-09-2013 per cent20- per cent20Applicant's per cent20submissions per cent20made per cent20for per cent20the per cent20deadline per cent20of per cent2023 per cent20September per

http://infrastructure.planningportal.gov.uk/wp-content/ipc/uploads/projects/WW010001/2.%20Post-Submission/Representations/23-09-2013%20-%20Applicant's%20submissions%20made%20for%20the%20deadline%20of%2023%20September%202013./9.11.02_Noise_Contours_and_Assessment_Summary_Plans_Car








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cent202013./9.11.02_Noise_Contours_and_Assessment_Summary_Plans_Carnwath_Road_Riverside.pdf

14.9 Mitigation measures included in the Code of Construction Practice and design principles are referred to in the DCO but neither of these are part of the Order. They are non-statutory documents and therefore not binding. All mitigation measures should be included in the DCO.


14.11 The CoCP (Part A) has limited information on vibration with the focus predominantly on noise. Vibration is acknowledged by the applicants as an issue in the environmental statement and it would be logical therefore that it should appear in more detail in the CoCP in the form of risk attenuation, risk assessment and methods of construction. This is a significant omission which needs to be rectified by the applicant by issuing further information and including conditions on vibration within the DCO.

The CoCP contains a comprehensive suite of measures to address vibration effects which are based on best practical means and guidance provided in British Standards 5228, 6472 and 7385 (see CoCP Part A Section 6.4). Prior to construction, the contractor would agree working methods, plant and proposed mitigation in applications to the local authority for prior consent under Section 61 of the Control of Pollution Act 1974. CoCP Part A para. A.1.2 states that “For clarity, and consistency with the CoPA, the term ‘noise’ includes vibration”; therefore both noise and vibration have been adequately covered. The CoCP also sets out information on vibration monitoring in Section 6.6.

In our responses to first written questions 2.4, 11.23-11.25, we conducted further assessments into the feasibility of low noise/vibration piling techniques to reduce the effect of these activities.

14.12 The council supports the ExA’s question to the applicants (Q11.10) regarding Best Practice Measures (BPM) and how adherence to these will be ensured and enforced in the DCO. The reference to BPM is made in numerous places in the CoCP and in particular in relation to noise and vibration mitigation. The council is concerned that defaulting to best

Further information is provided in our response to first written question 11.10.





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practice methods is too broad and we would concur with the ExA that conditions should be included within the DCO to ensure that mitigation measures for noise and vibration are fit for purpose and can be enforced.

14.13 Mitigation measures are left to the contractor and this increased uncertainty about their implementation and quality is of concern. It may result in the Council having to spend time and money in discharging the requirements and enforcing the Code of Construction Practice.

The CoCP requires the contractor to seek prior consent from the local authority in accordance with Section 61 of the Control of Pollution Act. This process requires the contractor, not the local authority, to identify any best practicable means to implement mitigation measures to control noise, for approval by the local authority. Additionally, should the application be accepted, we would be obliged to ensure that no new significant adverse effects are generated and that the effects are as defined by the ‘envelope’ of the assessment.

14.14 In the CoCP Section 6 Carnwath Road Part B CoCP (page 4) it is proposed that on some sites the material handling areas will be screened as a noise mitigation measure. The applicants also seek to provide an onsite noise enclosure over the shaft, but this is illustrative and not for approval. However, it is not clear how unmitigated noise levels from barge loading and unloading may impact on properties facing the sites from both H & F and Wandsworth. The council supports the ExA’s request for a time line to show noise levels resulting from a barge docking, unloading, loading of waste material from the conveyor or excavator and leaving the dock side. This has been requested for both the riverside without the screening and the landward side with the screening. The council suggests that the timeline needs to be produced for at least a 24 hour period which has not been specified in the Inspector’s questions. This is to take into account the potential noise impacts when barge movements are carried out at times of the

The enclosure over the shaft is shown on an illustrative Construction phasing plan. However, the requirement for a shaft enclosure is set out in the CoCP Part B Carnwath Road Riverside, and secured through the DCO (see our response to para. 14.6 above). The CoCP Part B also sets out requirements for noise screening/enclosure of all static plant, the concrete batching plant, grout plant, conveyors to load barges and material storage/handling areas.

Our response to first written question 11.7 presents a timeline for a barge docking, unloading and loading. The timeline does not present noise effects over a 24-hour period, but as the predicted noise levels are for a typical docking, loading and unloading scenario, they are applicable to any time of day when barge movements are required.



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day when the ambient noise level is at its lowest.

14.15 The CoCP Part A seeks to ensure piling methods which limit noise and vibration are selected where possible in order to reduce the vibration effects to “not significant”. The council is concerned about the potential piling methods proposed at both Hammersmith Pumping Station and Carnwath Road Riverside and the associated impacts of noise and vibration on residents in nearby properties. The council supports the request from the ExA for more information regarding the process by which the applicant would ensure that low noise/vibration installation techniques would be used where feasible. The council would also welcome information about where low noise/vibration installation is not technically feasible and what mitigation is proposed. The council would also support the inclusion of such methods within the DCO in order to ensure compliance by the applicant and the infrastructure provider.

In our responses to first written questions 2.4, 11.23-11.25, we conducted further assessments into the feasibility of low noise/vibration piling techniques to reduce the effect of these activities.

14.17 The overriding issue with the DCO application and the associated site plans is that they are not subject to approval in the DCO application. The site layout will be decided by the contractors at a later stage and while indicative and illustrative plans have been provided, these do not provide the Council with any certainty as to how the sites will be laid out and therefore what the likely noise and vibration impacts will be and in turn what level of impact this will have on local receptors. For example, if the applicant houses plant equipment on a certain part of a site, the effectiveness of acoustic barriers cannot be fully determined and neither can the effect on receptors or even which receptors will be most likely affected. On the plans for Carnwath Road (090014), for example, the site power structure is shown to be outside residential

Our response to first written question 15.15 provides further information on the illustrative site layouts and how the noise and vibration assessments took these into account. The plans provide an illustrative layout of how the contractor may choose to arrange construction activities on the site, whereas the assessment of effects assumed a ‘worst case’ layout within the site boundary (except where a specific control in the CoCP was factored in to the assessment). The assessments also took account of the noise and vibration control measures to meet and often to exceed best practicable means in the CoCP. The contractor may vary the construction layout but must comply with the control measures in the CoCP and demonstrate to the local authority that noise and vibration effects would be mitigated. Adherence to best practical means and other best



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properties which from a noise and vibration perspective is not considered to be the best location. In addition the plans do not make it clear as to whether the conveyor that will carry spoil will be enclosed and it is also a concern of the Council that the noise enclosure at Carnwath Road is to be dismantled on site after use to allow for the construction of another structure. The council considers that such elements of the construction phase should be considered in the noise assessment, but as with most noise impacts in this DCO application there appears to have been limited recognition and analysis done by the applicants. The absence of such figures does not allow the operation to be classed as having significant or marginal significant impact. As a minimum the Council considers that a before and after noise assessment showing the predicted noise levels should be carried out by the applicants.

practice measures would be monitored by the contractor and externally enforced by the local authority through the Section 61 process (see also our response to para. 14.6 above).

14.18 The council would like the applicants to explain the criteria that will be used to ensure site layout is such that there will be a minimum impact on local receptors. At present, the Council questions whether the applicants have actually identified all the sensitive receptors on the sites. The council considers that there are so many outstanding issues with regard to site layout that the assessment of noise by the local authority or even the applicant is virtually impossible. The examination stage has been reached and there is insufficient information on noise and vibration to make a robust assessment regarding the suitability of the sites for construction, the impact on sensitive receptors and the need for mitigation measures. Without conditioned mitigation levels in the DCO, it will be open to the contractor/sub contractor to employ whatever method suits them not one which will necessarily benefit the receptors.

The assessment considers construction noise at unscreened receptors within a 300m buffer from the site. However, in built-up areas, with relatively high ambient noise levels it is expected that effects would be limited to a smaller radius where there are two or more intervening rows of buildings screening the works from noise-sensitive receptors. The quantitative assessment therefore focuses on the receptors closest to the site or those within approximately 300m that are not substantially screened from the site. These representative receptors included residential properties and sensitive non-residential uses such as schools, places of worship and offices.

With regards to noise and vibration control measures and how these are secured in the DCO, see our response to para. 14.6 above. The EIA was an iterative process and assessment results informed the identification of the mitigation measures



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embedded in the CoCP. Our response to para. 14.17 above covers concerns regarding the illustrative site layout.

Our response to first written question 11.10 provides further detail on how the contractor would be required to implement noise and vibration control measures in the Section 61 application to be agreed with the local authority. The contractor would seek to implement control measures that benefit local receptors by reducing noise and vibration effects.

14.63 As pressure increases for further expansion of airport capacity in London and the south east, it is possible that Heathrow will be allowed to expand or make operational changes that could increase the number of flights and level of disturbance. There is concern that this could increase the frequency of overflying, with periods of respite from aircraft movements, which are currently provided by alternating the use of the runways, being eroded or lost altogether.

The majority of noise associated with the project would occur during construction, which is scheduled to be complete across the route by 2022. After this time it would have minimal impact on the noise climate. The future of aviation is currently under review by the Airports (Davies) commission; however as the findings will not be published until summer 2015, the possibility of noise intensification is speculative at this point. We consulted LBHF on our methodology for the assessment of cumulative effects, which sets out the criteria for inclusion of schemes, in February and September 2012. However, we received no response. The methodology explains that plans, policies and programmes were not included, since limited or no information is available on the design and timescales for implementation, which is required for a robust assessment of cumulative effects.



14.20 Firstly, the Council considers that the applicants have not included all of the properties in the borough of Hammersmith

The assessment locations were selected to represent residential receptors at locations around the site. We assessed the worst-



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and Fulham that will be potentially affected by the proposed construction at Acton Storm Tanks. This is indicated by Appendix G (G.1.3) which outlines who has been consulted on the noise assessment survey and which properties are included in the overall assessment of impact. For example, some London Borough of Hammersmith and Fulham (LBHF) residents on Warple Way have not been considered in the applicant’s assessment. The council would welcome a justification from the applicant as to why properties between 41 and 84 Tesla Court and 215 – 229 Lea Court, for example, have been excluded from the assessment.

affected part of Tesla Court and no significant adverse effects were predicted. Lea Court is further from the works than Longford Court, which was a receptor for the assessment, at which no significant adverse effect was predicted.

14.21 Secondly, the Council has an issue with the rating level assumed by the applicants for control of noise from fixed plant noise sources. The council acknowledges that engagement with the applicant on this issue was not carried out. Nevertheless the Council does not agree with the default position assumed by the applicant in volume 2 of the environmental statement which assumes a rating level of 5db below the typical background noise level. Hammersmith and Fulham Council has a rating level of 10db below the background noise level for control of noise from fixed plant noise sources. It is our view that whether we engaged with the applicant or not, a developer has a responsibility to meet the standard set by the local authority. The council has had the standard of 10db below since BS4142 was produced and have applied it on all relevant planning applications in this period. The council considers that the applicant has assumed an inappropriate rating level which runs contrary to the Council’s applicable standard (in SPD Appendix 4 page 143) and the assessment made by the applicant is therefore inaccurate and should be reviewed. 10dB below the background is a positive

We have adopted LBHF’s standard of 10dB and this would be mandated in the construction contract.



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indication that complaints are unlikely. 5dB below background is a less likely indicator that complaints will occur but not a positive indication.

14.22 The properties in the borough that were assessed for noise and vibration impacts by the applicant (Section 9) include 250 -269 Longford Court, 1- 66 Edison Court and 1-40 Tesla Court. All of these properties have been identified as highly sensitive receptors by the applicant as shown in table 9.4.1. The council considers that the assessment of noise that has been made by the applicant for these properties is based on limited evidence and assumptions regarding internal and external noise which are reliant on residents behaviour, for example, keeping windows shut.

We have explained and fully justified the approach utilised in the assessment of significance at these receptors in ES Vol 2, Section 9, paras. 9.5.41 to 9.5.51. It should be noted that the internal noise level is only one of a number of factors considered in order to determine whether the impact would have a significant adverse effect.

14.23 Edison Court, for example, is a five storey building located just 10 metres from the site boundary and 150 metres from the proposed shaft. Paragraph 9.5.32 states that construction noise levels are estimated to exceed the ABC (BS8223) significance criteria during the day for one month. However, internal levels will apparently not go above guidance level of 40dblaeq with windows closed. The council considers that for this to be the case it would rely on the time of the year, for example if it occurs in summer then we consider it is unreasonable to expect residents to keep windows closed as a form of informal mitigation.


14.24 Paragraph 9.8 concludes that the noise levels anticipated at the properties do not exceed the potential significance criteria for residential receptors. However, the Council is concerned that the applicants are not in a position to make such conclusions based on the limited analysis that has taken place. The council is surprised that such levels are not regarded as

ES Vol 2, Section 9, paras. 9.5.41 to 9.5.51 explain the approach used in the assessment of significance of effects for all receptors. The noise levels over the entire period of works were assessed and predicted noise levels at each receptor were included in the relevant appendix (Vol 4, Appendix G, plates G8 to 18). As set out in the ES Vol 4, Table 9.10.1 to 4, no significant noise or vibration



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significant against sensitive residential receptors because the noise contours for Acton Storm Tanks produced by the applicants and made available on 2nd October indicate significant noise levels which trigger the noise insulation regulations on site. However this contradicts what is stated in the ES Appendix G Section 9.5.2, plate G, which concludes that demolition work at Tesla Court for two months will be above the criterion threshold.

effects are predicted during the construction and operational phases of the project.

It is unclear how the noise contour plan information indicates that properties would be eligible for noise insulation, as the noise levels indicated in these drawings were within the bands indicated by the ABC method. The noise insulation thresholds have a lower cut-off, which is the same during the periods presented as category C of the ABC method. The noise levels outside of the limits of land to be acquired or used are generally below category A and so noise levels at the façade of the nearest residences would be well below the noise insulation threshold on the basis of the contour plans.

14.28 The council considers that Vol 4 regarding the post construction proposals at Acton Storm Tanks is inconsistent and needs to be clarified by the applicant. Paragraph 3.1.1 indicates that the 4 remaining storm tanks are to be hydraulically isolated on completion of the works. This contradicts 4.6.4 which states tanks will be rarely used and also contradicts paragraph 3.3.20 which says that the tanks will be modified to maximise storage. The council is confused as to what the future use, if any, of the tanks actually is. Are they as Section 4.6.4 indicates to be rarely used or are they to be hydraulically isolated as Section 3.1.1 states? Perhaps the applicant could define what is meant by hydraulically isolated. This might clarify the confusion felt by the Council on this matter.

During the construction phase, the two northernmost tanks (tanks 5 and 6) would be decommissioned and filled as part of the main tunnel shaft construction process. The remaining four tanks (tanks 1 to 4) would remain operational until the project is completed. In order to maintain adequate flood protection, the height of the walls on the remaining four tanks may need to be raised by up to 1m. Consequently, para. 3.3.20 relates to the construction phase, not the permanent operational phase. Once the project is completed, the remaining four tanks would be hydraulically isolated. This means they would not be demolished or filled, but would not receive flows under normal Thames Tideway Tunnel operating conditions. Excess flows from Acton Storm Tanks are currently transferred to the River Thames by gravity. The topography of the area means that, during certain high spring tides, the existing pipework can become tide locked, such that flows are unable to transfer to the river. During periods of project maintenance, if a high spring tide were to coincide with a significant rainfall event, flows would need to be transferred to the remaining four tanks. It is anticipated that the frequency of this scenario and the transfer of flows to the



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remaining tanks, would be approximately every two years. Para. 4.6.4 relates to this very infrequent use of the four remaining storm tanks. We would be willing to provide further explanation, should LBHF consider this to be beneficial.



14.31 The council is generally concerned that the Fulham Reach development has been an afterthought in many of the assumptions made regarding impact. For example in paragraph 3.3.14 there is reference to the hoarding specified in Part B of the CoCP. But the Council considers that the proximity and height of the Fulham Reach scheme would mean that windows and balconies could be affected as they exceed the height of the proposed hoarding. The council would welcome confirmation from the applicant that this has been considered in their assessment.

The assessment included the hoarding height specified in the CoCP Part B in the assessment assumptions. Higher hoardings are proposed in the CoCP Part B to mitigate noise effects at properties that would sit immediately behind the hoarding. We acknowledge that properties in higher storeys would overlook the site, including properties in the Fulham Reach development. This is reflected in the assessment in ES Vol 5, Section 9.5, where significant adverse effects were predicted at Blocks B and F.

14.32 The council understands from paragraph 4.3.9 that phases 6 and 7 of the Fulham Reach development would be under construction at the same time as the Thames Tunnel construction. The council would like confirmation from the applicant that the cumulative noise and vibration impact of both schemes on local receptors has been fully considered.

Phases 5, 6 and 7 of the Fulham Reach development were included in the assessment of cumulative noise and vibration effects (see ES Vol 5, para. 9.3.10 and Section 9.7).

14.33 Paragraph 4.4.15 and Table 4.4.6 indicate that the sensitivity of the majority of receptors to dust and odour is medium to high. The council considers that having identified the impact on receptors to be mostly high, the applicants have not

ES Vol 5, para. 4.4.15 and Table 4.4.6 describe receptors based on sensitivity to the effects of local air quality, construction dust and odour emissions. A summary of the project effects on sensitive receptors is provided in ES Vol 4 Table 4.10.1. The



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substantiated their conclusion that there will be no significant impact. The council would welcome clarification and where appropriate further information on this matter.

effects are in the range of negligible to minor adverse significance. It should be noted that the sensitivity of a receptor is taken into account when deriving the significance of an effect, as per the methodology set out in ES Vol 2, Section 4.

14.34 Paragraph 4.5.24 indicates that there would be 50-100m of unpaved haul roads onsite. However, the applicant states that there would be between 25-100 construction lorries per day. In paragraph 3.36 the applicant states that this will increase during peak period to 42. The council would like to see some further detail with regard to the safety implications and potential impacts of dust from having a large Section of frequently used, but unpaved road adjacent to highly sensitive local receptors. The council reiterates the concerns raised in the air quality Section of this report that the area is an air quality management area and the potential dust has not be fully considered or satisfactory mitigation put in place. For example the Council has indicated that wheel washing should be considered as a minimum measure to ensure that dust and spoil is not spread through the site onto local roads and past sensitive receptors.

Construction dust effects associated with using the haul roads were assessed in the construction dust assessment, in ES Vol 5, Section 4. It should be noted that the close proximity of sensitive receptors (such as residential properties) was taken into account when assessing the significance of effects related to construction dust generated from track-out activities. Part A of the CoCP contains measures to minimise dust generation and mitigate the deposition of mud and debris on the highway. Paragraph 5.4.2 in Part A of the CoCP states that “vehicle wash-down points to clean vehicle wheels at each exit point from the site” will be implemented.

14.35 Paragraph 4.5.26 indicates that the site is classified as a high risk site overall. The sensitivity of the area has been defined as very high. Paragraph 4.5.28 indicates that when measures outlined in the CoCP (Section 7) are applied, the significance of the effect would be reduced to minor adverse for receptors within 50 metres of construction area and negligible for receptors beyond 50m. The council considers that measures in Section 7 are not detailed enough for the applicant to justify a reduction in impact to minor adverse or even negligible beyond 50 metres. In particular, paragraph 7.3.2 states that the

Our response to Section 7 of the LIR explains how air quality management plans would be prepared, in consultation with the local authority.



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contractor would design and implement appropriate measures to limit the impact of dust. The Council is concerned about the level of detail included in the Code of Construction Practice. The mitigation measures are vague. In paragraph 7.4.7 reference is made to an air quality management plan, which will identify the appropriate control measures for dust. However it is not clear when this air quality management plan will be produced or if it will be submitted and approved by the local authority. As this is a mitigation measure not covered in the DCO, the Council is concerned about the degree and level of control measures the contractor would employ.

14.36 Assessment summary table 4.10. The council disagrees that significance of residual effect is minor or negligible. At present the mitigation measures are vague, it is up to the contractor to design and implement the appropriate measures and these will not be part of the DCO, therefore it is difficult to assume or predict in the case of table 4.10 that the effects will be negligible or minor. As the site is classed as high risk overall and with receptors at Fulham Reach, less than 10 meters from the site and at high level, it is premature to say that there will be minor adverse effect.

In line with the robust methodology detailed in ES Vol 2, Section 4, measures to control emissions are set out in Section 7 of the CoCP Part A. In accordance with the CoCP Part A, contractors would be required to follow best practice. The process for preparing and consulting on air quality management plans is set out in our response to Section 7 of the LIR.

14.37 Paragraph 9.2.8 states that generic measures have been put in place to reduce noise and vibration effect in the CoCP Part A. However, the Council is concerned that these measures are not standards that a contractor has to adhere to, they are simply best practice. The council would like to reiterate its concerns with regard to Best Practice measures (BPM) as in the written representations (Section 6) and would welcome standards in the CoCP and conditions in the DCO that a contractor would have to adhere to. The council considers that

The measures set out in the CoCP to control noise and vibrationare secured by the CoCP. The contactor would be bound to the provisions and requirements of the CoCP both directly via Requirement PW6 and through the construction contract.



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such measures cannot be used to artificially reduce impact in the environmental assessment unless they are secured by a condition.

14.38 Paragraph 9.2.9 introduces further site-specific measures for reducing the impact of noise and vibration, for example a hoarding of 3.6m. The council considers that these measures could be unenforceable as they are not secured through the DCO and also that insufficient information has been made available for the Council to understand the appropriateness or indeed the effectiveness of such measures. For example, what is the hoarding going to be constructed of and what acoustic properties does it incorporate. The council considers that the applicant must include further information on these measures and that they should be secured by way of the DCO or included in the CoCP as standards.

For information on how noise and vibration control measures are secured and enforced in the DCO, see our response to para. 14.6 above and our response to first written question 11.10. Further information on the control measures to be employed by the contractor at each site would be included in the application for prior consent under Section 61 of the Control of Pollution Act. The contractor must ensure that the control measures attenuate noise levels sufficiently in order for the contractor to comply with the Section 61 consent.

14.39 The council is concerned with regard to the following sections of the Environmental Assessment Vol 5 (Section 9):

c. Paragraph 9.3.2 makes reference to general methodology on monitoring locations in volume 2, paragraph 9.3.15. However, the Council cannot locate paragraph 9.3.15. This omission needs to be rectified by the applicant.

d. Paragraph 9.4.1 indicates that there will be high levels of noise at night in Chancellor's Road. In fact all of the noise readings at night for the streets have been deemed as quite high. The council is surprised by these figures and we would question the applicant’s conclusion that nothing below 64 day and 50 at night for that area is unusual. The Defra noise maps show that the background noise level on Chancellors during the day is below 55 Laeq and at night below 49Laeq.

First bullet: this refers to para. 9.3.15 of Vol 5, not Vol 2, which reads: “A response has not been received from LB of Hammersmith and Fulham specifying their requirements for the control of noise from fixed plant noise sources at residential receptors during the operational phase. Vol 2 refers to a proposed approach where guidance has not been received from the local authority. This approach is that noise emissions from this type of source are designed to meet a rating level (as defined in BS4142) which is 5dB below the typical background noise level over the operational period of the plant at 1m from the facade of the nearest residential receptor.”

As noted in our response to para. 14.21, we will adopt LBHF’s standard of 10dB below the background noise level for control of noise from fixed plant noise sources.

In terms of LBHF’s comment on para. 9.4.1, the baseline noise



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measurements were undertaken using the methodology presented and agreed with the local authorities at the Environmental Health Officer forum and presented in ES Vol 2 Section 9 and Appendix G.1.

The Defra noise maps focus on the strategic road network, which does not include Chancellor’s Road. Therefore the levels on the noise maps will not include the contribution from this and other local roads, or other site-specific sources measured during the attended surveys.

14.40 Paragraph 9.5.14 indicates that the noise level with windows closed will reach an internal level of 41db and with windows open it would reach 53db. This would be for a period of one month only. The council considers that there are variables that could change these levels. For example, this particular one month period could coincide with construction phases of the Fulham Reach development of which the cumulative impact has not been considered adequately by the applicant. In addition the one month period could occur during the summer months when residents would want to keep their windows open. The council considers that the applicants cannot conclude that the impact of noise will be ‘not significant’ without committing to conditions which alleviate the variables that exist on site.

ES Vol 2, Section 9, paras. 9.5.41 to 9.5.51 explain and fully justify the approach utilised in the assessment of significance of effects at the Fulham Reach development. It should be noted that the internal noise level is only one of a number of factors considered in order to determine if the impact results in a significant effect.

14.43 Overall the Council considers that the mitigation measures put forward by the applicant on the Hammersmith Pumping Station site are inadequate. Where significant effects have been identified, the applicant has not put forward mitigation measures and instead rely on residents, keeping windows shut, accepting, insulation or being re-housed. For example, paragraph 9.8.1 indicates that the applicant believes that apart

A range of mitigation measures to address noise and vibration effects are detailed in the CoCP. Para. 9.8.1 relates to on-site mitigation measures. We identified as many on-site mitigation measures as possible, which we consider would be both effective at reducing noise and vibration effects, and practicable from a construction point of view. The Noise insulation and temporary re-housing policy and the compensation procedures appended to the



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from re-housing or noise insulation no other mitigation measures are possible to receptors of Block B and Block F at Fulham Reach. It is a fact that if residents (receptors) decide not to take these offers up, the residual noise effects remain. These can have a negative impact on the receptors’ health and well-being.

Statement of Reasons (Doc ref: 4.1), provide a means to address any remaining significant adverse effects through off-site means. We would continue to liaise with those residents who do not accept noise insulation, temporary re-housing or compensation to determine the best course of action to address their concerns.



14.45 Paragraph 3.2.21 discusses the proposed arrangement for control measures and where they are included in the CoCP Part A and B. The council reiterates its concern that the control measures will be the responsibility of the contractor and that it is not clear who will oversee this to ensure the measures are being applied and what expertise they will have to successfully deliver such measures and also monitor and enforce them. The council also reiterates its concern with regard to the lack of information contained in CoCP Part B for individual sites including Carnwath Road Riverside.

See our response to para. 14.6 above and to first written question 11.10 with regards to how control measures would be secured and enforced in the DCO.

14.46 Paragraph 3.3.47 indicates that the highest lorry movement at Carnwath Road Riverside would be during tunnel construction where there would be 45 HGV lorries equivalent to 90 movements a day. The council is concerned that the increase in lorry and other vehicle movements in this location late at night or early in the morning will have a profound impact on a generally quiet road in the evening/night. In turn this will impact on the sensitive receptors that have been identified by the

A thorough assessment of noise associated with traffic movements is presented in ES Vol 10 Section 9.5. Aircraft noise is covered in the background noise surveys and therefore forms part of the baseline ambient noise levels in the ES.

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applicant, including the residential dwellings immediately adjacent to the site on all three sides and across the river into Wandsworth Borough. Irrespective of the frequency of lorries, the noise impacts generated by vehicle movements combined with construction noise at previously quiet times of the day is a major concern. The noise assessment has also failed to consider the cumulative impact of aircraft noise in the area of South Fulham.

14.47 Paragraph 9.2.9, Point F states that the proposed hoarding would be of a height and extent to achieve appropriate noise attenuation. The council does not believe that such a statement can be made, for example how high can the hoarding realistically be in order to attenuate noise for properties that are above ground/first floor? The applicant indicates that the hoarding would be no more than 3.5m on the Western side of the site which is in close proximity to the Piper Building. The Piper building is significantly taller than 3.5 metres. The effectiveness of the hoarding will also vary depending on the final site layout. Also the access road into the site is directly opposite houses on Philpot Square.

Higher hoardings are proposed at this site in order to maximise noise attenuation as far as possible. We accept that this alone would not attenuate all sources of noise, particularly for properties above the height of the hoarding, but this is one onsite measure among several, such as enclosing the main tunnel shaft, all items of static plant, the concrete batching plant, grout plant, conveyors to load barges and material storage/handling areas; and restricting the movement of vehicles on-site outside standard working hours.

14.48 As a minimum the Council would like to know what the proposed hoarding and the noise enclosure onsite are going to be constructed of and what acoustic properties will be incorporated. The council considers that the applicant must include further information on these measures and where appropriate they should be secured by way of the DCO or included in the CoCP as standards.

Further information on the control measures to be employed by the contractor at each site would be included in the application for prior consent under Section 61 of the Control of Pollution Act. The contractor would be required to ensure that the control measures attenuate noise levels sufficiently in order to comply with the Section 61 consent.

14.49 Paragraph 9.3.15 indicates that the London Borough of Hammersmith and Fulham did not engage with the applicant and therefore they have assumed a rating level for control of

As noted in our response to para. 14.21, we will adopt LBHFs standard of 10dB below the background noise level for control of



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noise from fixed plant noise sources. The council acknowledges that engagement with the applicant on this issue was not carried out. Nevertheless the Council does not agree with the default position assumed by the applicant in volume 2 of the environmental statement which assumes a rating level of 5db below the typical background noise level. Hammersmith and Fulham Council has a rating level of 10db below the background noise level for control of noise from fixed plant noise sources. It is our view that whether we engaged with the applicant or not on this issue, a developer has a responsibility to meet the standard set by the Council. The council has had the standard of 10db and has applied it on all relevant planning applications since BS4142 was produced. The council considers that the applicant has assumed an inappropriate rating level which runs contrary to the Council’s applicable standard in SPD Appendix 4 page 143. 10dB below the background is a positive indication that complaints are unlikely. 5dB below background is a less likely indicator that complaints will occur but not a positive indication.

noise from fixed plant noise sources.

14.52 The council is surprised that the noise levels projected are not regarded as significant in relation to the sensitive receptors identified and apart from measures in the CoCP, no further practicable on-site noise mitigation is to be adopted by the applicant. The council considers that the CoCP is not detailed enough or sufficient in demonstrating BPM and there is therefore a noticeable absence of mitigation for noise and vibration. For example, it is plausible that under the current measures put forward by the applicant that some properties that exceed prescribed noise levels may not be eligible to obtain insulation or even be rehoused (Paragraph 9.8.4). This point has also been raised by the Inspector’s first set of

The ES and ES errata (submitted on 23 September 2013) identified significant adverse effects at 89-101 Carnwath Road and 5 Carnwath Road due to river-based construction traffic.

See our response to para. 14.6 above and to first written question 11.10 with regards to the CoCP and how it is secured.

See also our response to first written question 11.35 for further information on the mitigation available to residents who do not qualify for noise insulation or temporary re-housing.

The contractor would submit an application for prior consent to the local authority under Section 61 of the Control of Pollution Act through which working hours, construction methods, and



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questions (Q 11.35) and the Council welcomes a response from the applicant on this matter. Some sites in the Carnwath Road area are just 5dB below the criterion level (table 9.5.1). In light of this it is important that the contractor is required to demonstrate, before any works commence, how they will ensure these noise levels are not exceeded. The local authority would need to see the method agreed to achieve this.

mitigation measures would be agreed.

14.53 The council considers that in the absence of further noise related data from the applicant, such as noise contour maps and assessment of such things as noise spikes from lorries for example, it is difficult for the Council to make a full assessment of the noise impacts on nearby residents. With this in mind, the Council welcomes the further information requested by the ExA, including revised noise assessments in Q11.13 of the written questions and the request for a table of all parameters and codes used in the assessments (Q11.14). However, the Council would wish to see noise contours produced for the Carnwath Road Riverside site, as have been produced for other construction sites.

See our response at para. 14.8 and to first written questions 11.13 and 11.14.

14.55 Paragraph 3.3.16 refers to the potential odour released through the proposed 15 metre high vent column at Carnwath Road Riverside. The council’s concerns with regard to ventilation at Carnwath Road are addressed in more detail in the ventilation Section of this Local Impact Report. However, the Council notes the proximity of the Piper Building which is a sensitive residential receptor. Paragraph 4.2.17 indicates that there will be 35hrs in a year when untreated air would be released at the top of the column. However, the frequency of the release appears to be projected differently in different sections and paragraphs. For example paragraph 4.6.4

ES Vol 10, para. 4.2.17 gives the number of hours in a typical year (35 hours) when untreated emissions would be released from the stack; this data is therefore emissions data. During the hours of releases from the ventilation column (both treated and untreated emissions), the meteorological conditions would vary and any odour would be blown in different directions. Dispersion modelling was carried out to assess what effect all of the releases during the year would have on concentrations at nearby sensitive receptors. The meteorological data used in the modelling was for the same year as the emissions data, which is based on rainfall throughout the year. The meteorological data is therefore realistic



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indicates that the most frequent occurrence of odour at a building could occur on the third floor of residential flats in Carnwath Road with 75 hours in a typical year. The council would like to see the inconsistencies regarding frequency of odour release clarified by the applicant.

and consistent with the emissions data. The concentrations predicted from the dispersion modeling are discussed in ES Vol 10 para. 4.6.4. The numbers in the ES relate to predicted concentrations at sensitive receptors and not the number of hours of untreated emissions from the ventilation column.

14.56 The council considers that during periods of high rainfall when the ventilation system is bypassed, the prevailing wind could cause significant and unpleasant odour issues for residential properties such as those within the Piper Building and beyond and also for schools and parks. The potential negative impact of this release of odour does not appear to have been acknowledged or adequately mitigated by the applicant.

Dispersion modelling was carried out for a full year of emissions from the ventilation column to assess the likely odour concentrations at sensitive receptors. The results of the modelling are described in ES Vol 10 para. 4.6.4. All of the predicted odour concentrations were within the odour benchmark set by the Environment Agency.

14.59 The council is concerned with regard to the following sections of the Environmental Assessment Vol 10 (Section 9 and 10):

Paragraph 9.2.12. The operational plant installed would have the potential to create noise impacts, but it is not clear where these are covered in the ES. The applicant should provide this information.

Paragraph 9.5.4. The properties referenced are only 5m away from the site boundary. The council considers that the applicant therefore needs to take into account reverberant sound in their assessment.

Paragraph 9.5.9. Windows closed for one month 32dB and windows open 51dB. But depends on time of year. If it is the summer, windows are likely to be open. The council therefore disagrees that the impact is not significant. If residents are to be expected to keep windows closed alternative ventilation needs to be produced which will not result in the resident having to pay to use this.

Bullet 1: See ES Vol 10, Section 9.6 for the assessment of operational noise and vibration effects.

Bullet 2: The predictions were made at 1m from the façade of the building at the worst-affected floor. The reverberant sound level increase as a result of the interaction of sound between the noise barriers and the side of the building is minimal given that the space is still open on the largest dimension and the two ends.

Bullet 3: ES Vol 2, Section 9, paras. 9.5.41 to 9.5.51 explain and justify the approach utilised in the assessment. It should be noted that the internal noise level is only one of a number of factors considered in order to determine if the impact results in a significant effect.

Bullet 4: The Errata to Doc ref: 6.2.10 Environmental Statement Vol 10 Carnwath Road Riverside corrected this error and identified significant adverse effects at 5 Carnwath Road as a result of river based construction traffic.

Bullet 5: 50 Carnwath Road is not a residential building and the

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P21 Section 9.5.69. River traffic noise levels at 5 Carnwath Road will be significant for the whole duration of the project. This does not appear to have been considered thoroughly in the assessment.

Table 9.6.1. Ref CR3 states that plant noise will be less than 66dB. The council considers that is same as the background noise level. Is this a typing error?

Paragraph 10.5.15 is not clear what conclusion the applicants are trying to make. The council would like clarification on this paragraph.

plant criteria are therefore as presented in ES Vol 2 Section 9, para. 9.6.14.

Bullet 6: The paragraph is intended to state that at times when there is no river-based construction traffic to generate noise, the moderate adverse effect on residential amenity could be lower (ie, minor adverse).

14.60 The council is concerned that there will be a significant cumulative noise impact on residents as a result of excessive aircraft noise combined with noise generated by the construction of the Thames Tideway Tunnel

Aircraft noise is included in the background noise surveys and therefore forms part of the baseline ambient noise levels in the ES.

Copyright notice Copyright © Thames Water Utilities Limited December 2013. All rights reserved. Any plans, drawings, designs and materials (materials) submitted by Thames Water Utilities Limited (Thames Water) as part of this application for Development Consent to the Planning Inspectorate are protected by copyright. You may only use this material (including making copies of it) in order to (a) inspect those plans, drawings, designs and materials at a more convenient time or place; or (b) to facilitate the exercise of a right to participate in the pre-examination or examination stages of the application which is available under the Planning Act 2008 and related regulations. Use for any other purpose is prohibited and further copies must not be made without the prior written consent of Thames Water. Thames Water Utilities LimitedClearwater Court, Vastern Road, Reading RG1 8DB The Thames Water logo and Thames Tideway Tunnel logo are © Thames Water Utilities Limited. All rights reserved.

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