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Appendix 1 Thames Tunnel Phase 2 Consultation Response Mayor of London

1 This appendix contains the Mayors and TfLs detailed comments on the following aspects of the Thames Tunnel proposals: General issues in relation to tunnelling and construction sites Site specific comments on the 24 preferred construction sites Route of the main tunnel and connecting tunnels under TfL assets

Overview of Changes since Phase 1 Consultation


2 Thames Water has worked up the phase 1 consultation proposals for the Tunnel into more detailed proposals. This has resulted in changes to all sites. In some cases the changes are minor in terms of strategic impacts, in other cases there are more significant changes including a number of sites which have been moved altogether. The preferred Tunnel route has remained broadly the same, although there are important changes to the tunnelling methodology and direction from some sites. 3 The overall proposal is for a tunnel, broadly underneath the Thames between Acton Storm Tanks and the Lee Tunnel at Abbey Mills (which is currently under construction). The tunnel will have a number of connection points along its route to enable the combined sewer overflows to discharge into the tunnel. The tunnel will be 6.5m diameter between Acton and Carnwath Road, Fulham and 7.2m diameter between Carnwath Road and the Lee Tunnel. The tunnel will transfer captured flows to Beckton Sewage Treatment Works. This is broadly the route as proposed by the Thames Tideway Strategic Study in 2005. 4 There are also connecting tunnels from other parts of the sewer network into the main tunnel. Whilst these are all smaller and shorter than the main tunnel, some of them are major engineering projects in themselves, notably: Frogmore Connection Tunnel between King Georges Park and the Main tunnel via Bell Lane Creek - this is approximately 2.6m diameter and 1.1km long Greenwich Connection Tunnel between Greenwich to Chambers Wharf, via Deptford Church Street and Earl Pumping Station this is approximately 5m diameter and 4.6km long There are a number of other short connecting tunnels also required at individual CSO connection sites

5 The tunnel is proposed to be constructed at depths in excess of 35m below ground level and up to 75m below ground level. This takes the tunnel beneath all tube, rail, road and foot tunnels and beneath all known other utility services. Connecting shafts are required at 17 sites to connect the existing overflow points along the river to the tunnel. The connection shafts are significant engineering projects in themselves,
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6 The main tunnel drive sites are situated at locations close to changes in geology, and are influenced by land availability and safe tunnelling distances. 7 The tunnelling drive programmes are set out below: (tunnelling not set out chronologically, some drives will be going on at the same time) Proposed Tunnelling Drive sites Carnwath Road to Acton Storm Tanks Kirtling Street to Carnwath Road Kirtling Street to Chambers Wharf Chambers Wharf to Abbey Mills Greenwich to Chambers Wharf Bell Lane Creek to King Georges Park Bell Lane Creek to Main tunnel 8 In response to the Phase 1 consultation the Mayor stated a preference for the Abbey Mills Tunnelling route. This was, and remains Thames Waters preferred route. The Mayor continues to support this route because it offers the shortest option that captures the relevant sewer overflows. It therefore entails the least disruption and lowest cost. 9 Suggestions of alternative tunnel routes and strategies have been made during the consultation period. The Mayor encourages both Thames Water and others to continue to consider alternatives, especially if they have the potential to reduce costs and disruption. However, of the alternatives that the Mayor has been made aware of thus far, the Mayor sees little merit in them. In particular the proposal from the Thames Tunnel Commission that a shorter tunnel between Acton and Kirtling Street should be implemented on its own, the Mayor finds unsatisfactory. Not only would this proposal fail to address the CSOs in central and east London, but it would suffer from a considerable problem in disposing or treating the captured combined sewage due to a lack of capacity in sewers running through central London to the main sewage treatment works in east London. The Mayor would be concerned that if such a proposal were to be implemented it would be a relatively short period of time, say 10-20 years before the tunnel would need to be extended to connect to the Lee Tunnel. In such circumstances the increased disruption and further lack of suitable sites can be expected to increase costs even further.

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General issues in relation to tunnelling and CSO connection construction sites


General
16 It is clear that any construction project of this scale is going to lead to disruption and impacts. These effects are exacerbated as the project necessarily needs to be undertaken in the densely developed and populated core of London with its complex arrangement of infrastructure, buildings, congested roads, open spaces and historic/cultural assets. It is imperative that Thames Water minimise the construction related impacts at all available stages. This is particularly important given that this is a project specifically to improve the environment. The changes to the proposal have generally moved to reduce impacts. However, it is clear that there are a significant number of issues that are yet to be clarified or resolved. 17 The Phase 2 consultation material gives further information on the nature of construction impacts, however this still falls short of giving a complete picture. In particular the Mayor has concerns in relation to work that is on-going and not available for the Phase 2 consultation.

Transport
18 The Mayor recognises that the Thames Tunnel project presents a logistical challenge to the promoter but he must ensure it is delivered in an acceptable way in Transport terms. There is one site, Greenwich, where there is a fundamental problem with the position of the shaft and there are several sites where there are significant transport related concerns that cannot be fully assessed with the material available at present. 19 London Plan policy 7.26 and Mayors Transport Strategy both support the use of the river for freight movement and in particular the movement of bulk materials associated with construction sites located near to the Blue Ribbon Network. River transport can play a significant role in mitigating the impact associated with construction activity and in particular the reduction of lorry trips on the road network. 20 The cost effective maximisation of the use of the river and/or rail is key to this. This will be an important factor in reducing the impact of the scheme overall by reducing the number and frequency of HGV movements on congested and sensitive parts of both the strategic and local road network of London. In the Phase 2 documentation the use of the river is limited to part removal of tunnel arisings, cofferdam infill import and removal and limited deliveries by barge. This will be particularly important at the three principal proposed tunnel drive sites (Carnwath Road, Kirtling Street and Chambers Wharf). It is also important at sites where access is constrained (Putney Bridge for example) or where sites are immediately adjacent to very sensitive corridors such as Victoria and Chelsea Embankments. Furthermore the Greenwich PS site will be the excavation point for the Greenwich connection tunnel which at 5m diameter and 4.6km long will be a major excavation in the vicinity of a congested area of the road network. It is disappointing that the proposals are not more positive about the use of barges here.

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21 Furthermore a nominal figure of 70m increase in project costs has been identified to account for the use of barges. TfL has not seen the evidence or breakdown of this cost and therefore cannot comment on whether it is a reasonable estimate or to what extent other impact costs (such as air quality, congestion and safety) can be averted. Furthermore it is highlighted that many permanent facilities such as transhipment points and new rail heads are being put in place by the current Crossrail major project and that if Thames Water were to install further facilities, these may themselves have a value for other uses after completion of the Tunnel. The identification and appraisal of these facilities should be explicitly considered and opportunities for use explored and identified within expected social cost benefit analyses. 22 There are also some suggestions of potential rail opportunities but these do not appear to be worked through at this stage. Therefore it is evident that modes other than the road (both water and rail) are not maximised within an acceptable cost margin at present and it follows that the current proposed transportation logistics is unacceptable. 23 One element which is of paramount importance to any major scheme such as this, is the Construction Logistics Plan (CLP) which has yet to be developed by the scheme promoter, although given 20 or so pages of text within Volume 2 of the PEIR documentation. 24 Thames Water recently (Jan 2012) confirmed to TfL/GLA that the Transport Strategy Study is being developed outside the Phase 2 consultation. This limits the detail into which these comments can go at this stage. TfL would encourage that such a study fully addresses the comments contained within this response. We would urge TW to engage with all stakeholders during the undertaking of this task, consulting with affected London Boroughs at the earliest opportunity. TfL have consistently and continually placed such a study as the priority piece of work required and it is regretful that such a study was not undertaken earlier so that the collective findings could have been incorporated into Phase 2 consultation and used to inform the wider community. 25 The following comments are therefore based only upon published Thames Tunnel Phase 2 consultation material. We would take the opportunity to highlight that from TfLs perspective we would wish to promote a logistics plan that: Maximises the use of river and rail transportation Minimises impact on the strategic and local highway network Minimises overall and local environmental impacts Is cost effective considering all direct and indirect costs and benefits consistent with established Government guidance on transport investment

26 In TfLs comments contained within the Mayors Phase 1 response, TW as the scheme promoter was expected to address handling issues cited as being the reason for tunnel and shaft linings not being proposed to be delivered via the river and recognise that barges also offer storage facilities which can reduce work site areas. Issues and factors such as these have still not been addressed and we would expect these to be explained fully within such a Construction Logistics Plan. 27 The scheme provides the opportunity to enhance pedestrian, cycle and vehicle infrastructure and general public realm within the environs of each of the work sites.
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Impact on Highway Network & All Users during Construction 28 Given the scale of this proposed scheme the Mayor remains concerned about the potential impacts of the scheme during construction on the Transport for London Road Network (TLRN) and all its users. To ensure that safe and efficient transport operations and infrastructure can be maintained during construction it is essential that these impacts are identified and minimised through appropriate mitigation measures. Therefore, some key issues yet to be resolved with TfL are: 29 Assessing Impact on Highway Network & Users: It is important that appropriate strategic and local traffic modelling is undertaken to inform the overall Transport and Environmental Assessments being undertaken by the scheme promoter. This work has still not yet been completed by the scheme promoter and will help ensure that the scheme impacts are mitigated against and adequately managed. It is important that TfL agrees the scope and methodology of the traffic modelling and transport assessment process. At present full agreement on these processes has not yet been reached. TfL anticipates making further comments on the scheme once the Transport Assessment has been completed. 30 We note that the phase 2 consultation documentation presents daily average HGV flows at each site (derived from monthly average HGV flows). TfL remains concerned that use of these average flows in these assessments will under-represent both the local and strategic impacts of the scheme. The forecast vehicle demand flows to be used in any traffic modelling and transport assessment must be discussed and agreed with TfL to ensure it is appropriate. 31 It is noted that a secondary tunnel lining, comprising an additional layer of reinforced concrete may be required and that this shall be clarified in future design work. The scheme promoter is requested to prioritise this piece of work and confirm to what degree such a requirement is included within Traffic modelling figures and for each site duration programme. It is noted that if required the necessary works would be undertaken 24 hours /day with site batching of concrete being necessary. This raises further questions on other areas, noise levels for example, which may be impacted upon and similar confirmation is sought as to works effects at the earliest opportunity. 32 Construction Logistics Strategy: Fundamental to minimising the degree of impact on the TLRN will be the preferred approach of the scheme promoter to Construction and Logistics Management (both scheme-wide and at each specific site). This will determine the strategic and local mode share between highway and river based construction traffic, and in turn the scale of scheme impacts on the highway network and various TfL operations and assets. 33 As the Construction and Logistics Strategy is not yet available it is not clear from the Phase 2 material what alternative approaches to Construction Logistics have been developed and considered (including greater use of river transport), how they have been assessed (their costs and benefits) and why the currently preferred approach was selected.

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34 Implementing the Construction Logistics Strategy: It is not clear from the Phase 2 consultation materials, or from discussions with the scheme promoter, how they will ensure that the contractors appointed to construct the scheme will deliver materials in accordance with this strategy. Within the Phase 2 consultation literature there is reference to contractor flexibility, TfL is not aware how the scheme promoter will ensure that Consented Project Requirements are delivered. TfL is concerned as to the guarantee that such mechanisms are put in place and, if they are, prove effective enough to ensure that commitments made by the scheme promoter to a strategy that utilises river transport are monitored and met. 35 Day to Day Management of Construction Logistics (HGV Routing, Site Operating Hours, Abnormal Loads, Traffic Management Arrangements): Whilst the phase 2 consultation material proposes routes for HGVs during the construction period it will be vital that the scheme promoter establishes a resource or team to centrally coordinate and manage all construction logistics activity across the scheme. One of its remits will be the need to provide the adequate enforcement of agreed routes by any construction traffic to the satisfaction of TfL. Close liaison between this function and TfL/other local highway authorities will help ensure that the most appropriate HGV routes, delivery hours etc are selected for each site based on the latest network conditions and other works taking place at that time. It will also be essential to help TfL and the various highway authorities in their network management duties. 36 Road Safety: Minimising the risk of collisions arising from the proposed scheme works is essential. The proposed scheme will generate significant HGV movements on the network, which will increase the risk of accidents, particularly for vulnerable road users such as cyclists and pedestrians. It is notable that a number of the lorry routes are along roads containing existing or proposed Cycle Superhighway routes. All proposed site accesses, traffic management arrangements, diversionary routes (for vehicles, pedestrians and cyclists) etc must all be designed and appropriately assessed (safety audit) so as to minimise the risk of accidents. TfL would encourage the use of blindspot safety mirrors (trixis) at each of the construction sites. A final version of the TfLs Cyclists at Roadworks document should be available shortly and should be referred to when finalising traffic management designs. 37 Maintaining Operating Capacity and Journey Time Reliability for Users: Works at a number of proposed sites (eg. Blackfriars, Victoria Embankment, Chelsea Embankment, Deptford Church Street) will significantly impact on highway capacity for extended periods of time. This would have significant impacts on journey times and reliability for users of the network, including bus services. TfL is very concerned that every effort is made to look at ways to minimise the need for any works that require the loss of any lane capacity. If works must take place then they should be for as short a period as possible and appropriate mitigation measures put in place. 38 Site Design Workshops with TfL/Transport Assessment: TfL has already raised a series of detailed comments regarding the scheme and the proposed work sites at a series of workshops. Many of these comments are covered below but some are not. We recognise that these comments have been captured by the scheme promoter and would highlight that these comments are still relevant. Many have not yet been addressed by the scheme promoter and require further work. TfL is also anticipating making further comments once a draft Transport Assessment and other documents have been submitted by the scheme promoter.(see comments on individual sites)

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39 Tree Removal and Replacement on Embankment: Further discussions with TfL are required regarding proposed tree removal and replacements at sites on Victoria and Chelsea Embankment. At locations where tree removal proves unavoidable substantial replacements will be required (TfL will provide more detail on exact tree specifications). The viability of replanting will need to be determined prior to any removal. To help mitigate the loss of mature trees along the Embankment TfL also suggests there are opportunities as part of this scheme for some succession planting and would welcome the opportunity to discuss this further with the scheme promoter. Note that tree planting near to flood defences may require flood defence consent from the Environment Agency (EA). The scheme promoter will need to consult further with the EA regarding any proposed tree planting plans (following approval of the plans from TfL). 40 Mitigation Measure costs: The cost of any identified mitigation measure to TfL highway network (eg. Required junction improvements), assets (eg. Piers) or services (eg. Bus operation costs for service diversions and changes to facilities) would need to be met by the scheme promoter. Impact on existing assets owned by TfL 41 Ordinarily for 3rd party projects such as this, as previously advised, TfL would expect a 3rd party interface agreement and set of protective provisions that fully assure TfL in respect of all of its concerns and otherwise regulates the acquisition, temporary occupation or granting of rights in respect of any of TfLs land relative to any CPO powers TWUL may secure, whereby either: (i) Rights or interests are granted consensually for which purpose any agreement would include a prohibition on TWUL exercising any CPO powers against TfL; or, (ii) TWUL exercising any CPO powers in an agreed way, for which purpose any agreement would include obligations regulating TWULs exercise of CPO powers. (a) Depending how any wider agreement with TfL develops, any TfL subsidiary may well require its own bespoke agreement with TWUL to cover the above points and the scheme promoter interfaces specific to any TfL subsidiary consistent with the MOU and any successor agreements, any TfL subsidiary must reserve its position. (b) It is considered that with respect to LU infrastructure, all issues are being managed effectively through the formal approval process which shall continue with the scheme promoter. It is confirmed by LU that within Phase 2 alignment proposals all crossings are being picked up through the recent ongoing Preliminary Impact Assessments from The Thames Tunnel team. One crossing of the Jubilee Line Tunnels from the long connection tunnel from Chambers Wharf Shaft under St Jamess Road had not been covered in our recent inspections but it has been agreed with the scheme promoter to be covered in an Impact Assessment in due course. None of the above to be assumed as agreement to the proposed DCO wholly or in any part.

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(c) Further assessment work, discussions and approval processes will be required for works to existing Piers and embankments owned by TfL. (d) The Mayor will expect such agreements to be binding and secured in any Development Consent Order. Transport Environmental Issues 42 When considering the EIA, NSIP and the IPC it would be useful for the scheme promoter to explain the level of detail that will be assessed and the potential need to provide for some flexibility on detailed design and how this will be assessed. The IPC has a useful guidance note on this entitled Using the Rochdale Envelope albeit this has been drafted with wind farms in mind. We would also request that the inter-relationship with the requirements of other consents and licenses (eg. From the EA/MMO/PLA etc.) are explained. (a) Within Volume 1 of the PEIR Section 4, the Marine Works (EIA) Regulations 2007 should be referenced. (b) Throughout the various volumes of the PEIR there are many references to other future developments. The scheme promoter is reminded that TfL will require further reassurance that all of the transport schemes in the Mayors Transport Strategy (MTS)/London Plan either as safeguarded or developed eg. Chelsea/Hackney/river crossings and the developments in the Opportunity Area Planning Frameworks (OAPFs) have been fully taken into account. (c) Within Volume 5 of the PEIR we would advise that there should be reference to the Mayors Air Quality Strategy (December 2010) (d) Within future EIA work, future phases of both cycle hire and cycle superhighways will need to be accounted for with details provided through liaison with TfL. (e) As a more detailed comment, Table 11.4.1 within Chapter 5 of the PEIR has significance criteria for hazardous loads which seem subjective the origination or basis of these criteria needs to be defined. (f) TfL will expect the DCO to set limitations on the power to deviate to the extent that it might adversely affect a TfL Asset.

Construction Impacts

43 Alongside Transport Impacts, construction impacts are the source of the greatest level of concern from people living and working close to the proposed work sites. This is understandable, particularly when it is not yet clear as to the full extent of those impacts. Even when the impacts are more fully modelled and reported, there will remain a local concern as to the real nature of the construction works. Thames Water should therefore undertake to establish open Fora for each work site to enable local issues to be discussed and resolved during construction. 44 In order to minimise impacts, it will be important for Thames Water to work with the relevant public authorities, notably the London boroughs and Transport for London for which bi-lateral discussions are essential. There is also an inter-Boroughs group that
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Air quality Noise & vibration Waste management Land quality Transport (both land and river transport)

Noise
Site Selection 45 The documentation provided identifies 24 sites that would be necessary to facilitate the construction of the tunnel. It appears as though noise monitoring at these sites is ongoing, but broad-brush statements relating to the likely mitigation measures that would be required to reduce the construction site noise have been made. These statements seem sensible, but more information, particularly from the site surveys, would be helpful in considering the noise impacts of the sites more thoroughly. It is noted that at main tunnelling sites it is proposed to cover the construction shaft with a temporary warehouse style building. Code of Construction Practice 46 At this stage of the project it seems sensible for some common rules to be applied across the whole project. With this in mind, a Code of Construction practice (CoCP) has been prepared that looks to provide rules on how the environmental impacts of construction site activity. To date, only Part A: General Requirements is available, but it is stated that Part B of the CoCP will be geared more to the local circumstances at each of the construction sites. This, undoubtedly, is a response to the fact that a one size fits all approach will not be appropriate across the 14 Local Authorities that the tunnel is proposed to go through. With this in mind, it could be argued that a one size fits all approach may also not be appropriate for Part A of the CoCP. In particular, Appendix B of Part A provides guidance on how to apply for a s61 agreement under the Control of Pollution Act 1974. Table B.1 provides an indication of the hours that would need to be used when predicting the noise levels from construction activity. This table assumes that the standard hours of work for the purposes of the Control of Pollution Act are 08:00 18:00 Monday to Friday, and 08:00 13:00 Saturday. This assumption does not allow for local authority discretion in these work hours. 47 The Mayor will wish to give further consideration to the noise impacts of the proposed sites, once more information is available. 48 Thames Water should make clear the local nature of s61 Agreements under the Code of Construction Practice.

Air Quality

49 The GLA's and London Council's Best Practice Guidance (BPG) The control of dust and emissions from construction and demolition http://legacy.london.gov.uk/mayor/environment/air_quality/docs/construction-dust-bpg.pdf should be implemented across the proposed sites. By the time construction is underway, it is likely that the BPG will have full statutory status as Supplementary Planning Guidance to the London Plan and so will be formally required as minimum. This will ensure that
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the construction and demolition activities are managed and thus minimise any nuisance for existing sensitive receptors.

Odour Impacts
50 The Air Management Plan focuses on the 22 locations that air can enter and exhaust from the sewer tunnel system. As the tunnel system controls combined sewer overflows, it would receive flow intermittently, depending on rainfall. It is estimated that in a typical year of rainfall, the tunnel would be empty for about 7075% of the time, with no air emissions from the majority of sites during this time. When the tunnel is filling, a limited amount of air would be exhausted at sites, depending on how full the tunnel becomes. Air exhausted would be treated to ensure acceptable air quality. In a typical year, most sites would have emissions for five to 50 hours in total, spread over one to 15 events. 51 The odour control is split between active and passive control sites:

Active Sites - Active odour control would be undertaken at six of the locations, with exhaust air being treated by carbon filters. These sites would operate continuously at a low rate during times when the tunnel is empty to ensure airflow through the tunnel: Acton Storm Tanks, Carnwath Road Riverside, Abbey Mills Pumping Station, Greenwich Pumping Station, Beckton Connection Shaft Beckton

52 These sites have ventilation columns generally set 15m above ground level. Each has multiple vents from the Odour Control Unit, along with a bypass vent for when treatment capacity is exceeded. This is intended to be once in every fifteen years. Air intake would primarily be at Blackfriars Bridge Foreshore and Greenwich Pumping Station. 53 Passive Sites - The remaining sites would be passive plants that would treat air being discharged whenever the tunnel fills with exhausted air being passed through passive carbon filters. The passive sites have ventilation columns set at a height of 4 m (complying with hazardous zoning requirements under Thames Water standards). 54 When the tunnel starts to fill with wastewater, shafts gradually fill and displace the air inside them. This starts at the eastern end of the tunnel first. This means eastern sites would vent/be drowned out more frequently with 25-50 hours each year, compared to 5-15 hours in a typical year at the western end. This venting would all go through charcoal filters (at both active and passive sites). 55 Under extreme events, estimated to occur once every 15 years, the capacity of the treatment units would be exceeded and air from the sewer would be vented directly via the bypass vent. This is predicted to occur for a period of less than 10 minutes. When the system is full and the Combined Sewer Outfalls revert to entering the river there is an additional risk of uncontrolled venting (estimated to be on average 10 hours per year).
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56 The report states that The quality of the air released would be similar to the air quality that is associated with the current CSO discharges and would not cause odour nuisance or problems. 57 Details of the odour modelling is cited as being spread across 22 volumes of the Preliminary Environmental Information Report and has not been compiled as a technical annex for the Air Management Report. The report outlines minimum maintenance and inspection routines: Active sites would be visited once a week, whilst passive sites would receive a quarterly inspection and maintenance check, covering: a. monthly check of duty/standby fan and motors b. annual checks on residual lifetime of Odour Control Unit (OCU) media c. retention of critical spares for each OCU 58 There is a commitment to rectify normal and abnormal faults within 48 hours. No indication has been given of any monitoring programme other than H2S to be undertaken as part of the inspections. 59 The report outlines a preliminary complaints procedure, through reporting to Thames Water Customer Services Central Customer Centre followed by a checking and validation procedure. No indication is given with regard to the speed of the complaint validation, or any reporting of problems to relevant local authorities or the GLA. 60 In paragraph 2.3.4 of the Air management Report, the relationship between the bypass vent and the separate vent structure with weighted dampers is unclear, particularly in respect of the expectation of operation once every 15 years. Para 2.3.5 does not clearly detail the relationship between normal conditions and when the weighted pressure relief dampers are open. 61 The report states that The odour concentrations at ground level and at elevation beyond the site boundary at each site have been modelled in relation to the 98th percentile of hourly odour concentrations in a year and also the concentrations at buildings where people could be exposed. However no clear details are provided in the document. Preliminary modelling results are cited as being presented in volumes 7-28 of the Preliminary environmental information report (PEIR). These volumes do not appear to be in the Document Library and therefore the absence of any detail on these has meant that it has not been possible to assess these. 62 In any case, the Mayor does not consider it reasonable to reference technical details across 22 separate volumes without producing a more detailed summary of the findings beyond the statement The modelling results presented in the PEIR demonstrate that with the air management system developed, there would be no significant risk of nuisance odours associated with the Thames Tunnel project. All of the sites would achieve the 98th percentile odour criterion. 63 Paragraph 3.4.4 suggests that active OCU sites would be visited once a week but provides no indication of the inspection or maintenance. 64 Whilst having a monitoring programme for H2S can identify some elements of odour, it is not the only odorous compound associated with wastewater treatment. The
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65 Paragraph 3.5.1 mentions motorised dampers, however these have not been clearly described elsewhere in the report (presuming they are different to the weighted dampers described in section2). 66 There is no process set out for keeping public or regulatory bodies informed of complaints, or problems with the operation of the system. Odour Conclusions 67 The information provided thus far does not enable a full assessment of the odour implications. The information has not been provided coherently, rather this has been loosely referenced simply as being presented in 22 separate volumes of general preliminary environmental information which do not appear to be on the document website. In the presentation of an Air Management Plan such as this it would be expected that these details would be assembled in a single Technical Annex that would be simple to access. 68 However, under normal operating conditions it is not expected that there will be any significant increases to untreated odour emissions, assuming that the equipment is operating correctly. 69 Extreme events requiring the untreated venting of air are anticipated to occur only once in every 15 years. Whilst undesirable, this is felt to be reasonable. 70 The proposed mitigation and control methods appear to be satisfactory under the circumstances set out in the Air Management Plan, and are therefore considered unlikely to pose a significant risk of causing undue odour problems. However, insufficient evidence was available to check the robustness of the scenario outlined in the main Air Management Plan report. 71 Whilst rudimentary details of inspection, maintenance, and complaints procedures are given and generally appear to be acceptable, there is no clear indication of how overall operations will be recorded and, where necessary reported on to relevant public/regulatory bodies. 72 Suitable arrangements should be ensured to control, manage and address any unforeseen problems should they arise once in operation.

Waste
73 The project will result in the excavation of a large amount of tunnel spoil. Earlier comments have already indicated an imperative to ensure that the vast majority of this is transported using water transport. In parallel with this, further consideration is required to identify the most beneficial use for the spoil and whether it is suitable for a positive use as aggregate material. In particular it would be beneficial to examine whether any of the early shaft excavation material or excavation material from other projects, notably Crossrail or National Grid Tunnelling, could be used as infill material for the cofferdam sites in the River.

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74 The landfill diversion target of 90% is considered appropriate to begin with, however it is suggested that a reuse and recycling target of 95% should be implemented by 2020 at the latest for the project as a whole. This will bring the project target in line with the London Plan target which is important given that this project will generate a significant percentage of London's annual Construction, Demolition and Excavation (CDE) waste. 75 The Mayor welcomes the use of the Waste Hierarchy as a guide for this strategy. He would however like to see more emphasis on waste reduction and over the course of the project, would like to see ambitious targets set for limiting the amount of waste generated in the first place. Further detail on how the Waste Hierarchy will inform the pre-construction stages of the overall project and the individual site projects - e.g. the planning and design, through to material specification and procurement stages. 76 The use of reused and recycled materials in construction should be an integral consideration right from the design stage onwards through specification, contract and construction. It is suggested that a target for the use of reused and recycled materials is set from the outset in order to drive the work of the various contractors. The Site Waste Management Plan monitoring process could be used to understand if this target was being planned for and met by the individual site contractors. 77 In respect of demolition waste, surveys of existing buildings or infrastructure, to identify potentially reusable and recyclable materials, are carried out well in advance of demolition. Further, arrangements should be put in place to allow for such materials to be recovered prior to demolition. 78 Detailed Waste points: Para 5.4.12 of the Waste Strategy says that '[C]ontractors would be encouraged to improve segregation of different waste types on site". This should be strengthened to become a requirement unless demonstrably impossible due to site constraints. Para 5.4.16 of the Waste Strategy states that contractors would be encouraged to make use of local permitted and exempt facilities that accept, process and recycle construction materials. This should be a firm requirement. Special consideration should be given to the potential for recycled material content in concrete used for the project, given that concrete is the most significant material being used. The potential for use of cement and aggregate substitutes, such as China Clay sand and incinerator ash, should be looked at well in advance and should be built into specifications and contracts with the principal contractor, where appropriate. On-site treatment of excavated material, for use as fill material, should be explored in sites where there may be space available. A target of 70% recycling is suggested for welfare waste, with appropriate facilities and monitoring procedures put in place.

Energy
79 This project will create a considerable demand for energy in many aspects. Initially, the construction of the tunnel and all the CSO connection sites will involve large amounts of energy in transporting large volumes of materials, estimated at 8

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80 The operation of the tunnel will represent a large and on-going commitment to energy use, both directly in pumping the captured sewage overflows and less obviously in the increased flows through Beckton Sewage treatment Works. The Mayor is aware that calorific value from sewage is captured at the sludge powered incinerator at Beckton, but also that the calorific value from the sewer overflows is relatively low because there is a high proportion of rainwater. 81 Thames Water need to ensure that energy demand, and the carbon emissions related to this, are considered and minimised in all elements of the project from the energy used in tunnel construction and spoil transportation to embodied energy in tunnel materials. 82 Thames Water also needs to examine opportunities for on-site low or zero carbon energy generation. The Mayor is not yet convinced that all opportunities to achieve this have been taken. Through discussions Thames Water has indicated that capturing energy from the sewer overflows entering the tunnel and flowing along it is not practical. While understanding the difficulties, the Mayor urges Thames Water to keep an open mind to opportunities to capture some of that energy. The project should also consider possible links to support wider energy generating and distribution infrastructure, especially in key development areas such as Nine Elms or near the SELCHP plant in Lewisham, where viable opportunities for decentralised energy and specifically district heating networks have been identified.

River Impacts
83 The construction works and permanent works will result in direct impacts on the river and its foreshore in many locations. These impacts will need to be investigated and assessed in more detail. Of particular concern are the hydraulic impacts that more structures in the river may have on river flows. In many locations the introduction of such structures may lead to either increased erosion or increased sedimentation. These effects may prove damaging to other river structures and to navigation, and, if not designed out may need on-going management, for example by dredging. Changes to river flows will also impact on navigation and could lead to difficulties for river passenger, freight or leisure/tourist services. The Mayor is aware that further work on these issues has been undertaken since the Phase 1 consultation. However, this work has not yet reached a full conclusion and further detail is required. The Mayor will seek advice from the Port of London Authority and Environment Agency on these aspects.

Design and Heritage


84 Whilst it is appreciated that designs are not finalised, Thames Water will have to present improved design options for the sites in the Development Consent Order (DCO) submission. This will apply both to the screening, fencing etc of construction sites and to any permanent structures visible at surface level. Many of the sites are in sensitive locations with Listed Buildings and Structures and Conservation Areas adjacent or nearby, some of these structures are amongst the most high profile heritage assets in the country. In addition some of the structures are close to or within viewing corridors of important buildings within London. The original sewer scheme by Bazalgette has set

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85 Since Phase 1 Thames Water has presented proposals for each site to the Design Council/CABE. This has generated a good deal of useful advice to the design team in continuing to develop the proposals.

Legacy/Re-instatement
86 The re-instatement works following the construction should achieve a positive legacy. This will require a clearly thought through approach to the sites individually and as a series. Thames Water should work with the Mayor, boroughs and local interests to design and deliver these improvements in line with local priorities, the principles of the Mayor's manifesto for improving public spaces, London's Great Outdoors and the All London Green grid. This should include the introduction of the Legible London wayfinding scheme and consultation with TfL. The re-instatement works should incorporate cycling infrastructure for example secure parking, Barclays Cycle Hire docking stations wherever possible and appropriate within the public realm strategy for the legacy. 87 Of particular concern is the fact that many of the sites will not be re-instated for several years, some in excess of 10 years. During this time we can expect many changes to local circumstances and new opportunities, for example through new development, that could not be anticipated at present. Therefore it will be important for Thames Water to retain a degree of flexibility in respect of legacy/re-instatement proposals. 88 Many of the construction sites will retain overflow points to the Thames for times of excessive rainfall. Consideration should be given at this stage to fitting monitoring equipment to check the performance of the Tunnel during operation.

Property
89 GLA /TfL will expect any occupation of its property by Thames Water to be on the basis of agreement as opposed to by exercise of powers. There are issues that TfL Group Property would wish to see addressed in agreements prior to Thames Water entering onto TfL sites. References to such issues need to be consistent with matters that need to be covered in subsequent legal agreements.

Integration with other major construction projects


90 The project is of such a scale that it should be integrated with other large projects, which may offer the opportunity for integration and the possibility of sharing construction and logistics sites and equipment. Crossrail is an obvious example and the shift of timescale of the Thames Tunnel means that the main construction activities will now follow on from those of Crossrail rather than partially overlapping. This should increase the scope for sharing infrastructure/assets. There may also be other infrastructure/utilities projects, such as the proposed Northern line extension, and redevelopment schemes at or close to Thames Tunnel construction sites, not least of which will be development of the Vauxhall Nine Elms Battersea Opportunity Area. The shared use of barge transport facilities and sites should be explicitly considered.

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Conclusion on general impacts


91 There are a range of potentially serious impacts, mainly in relation to transport, that will have to be addressed by the project. Phase 2 consultation contains less information than was anticipated, especially in relation to transport. The failure to more fully embrace the river for transport purposes is a serious shortcoming that the Mayor remains to be convinced is justified. Furthermore, due to the lack of information there may be other aspects of impact on transport modes or structures that may not be acceptable.

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Preferred Construction Sites


The tables below set out the Mayors issues and views on each of the 24 sites identified as the preferred sites to deliver the tunnel. For completeness a short table is also included for those sites which were in the Phase 1 consultation but are no longer required. The Mayor objects to the Greenwich Pumping station site as currently designed. The Mayor has significant concerns about the following sites, although it is anticipated that with appropriate further work these concerns are capable of being addressed: Kirtling Street, Chelsea Embankment, Victoria Embankment, Blackfriars Embankment and Chambers Wharf. The Mayor has identified a range of other concerns at the remaining sites.
Site Name Borough Purpose Construction Period Key Issues 1 Acton Storm Tanks Ealing CSO Connection and main tunnel reception site Approximately 3 years 1. Construction close to residential properties. 2. Construction traffic impacts will be all via road requiring new access to Canham Road. The impacts of this on the surrounding highway network, in particular The Vale (A4020) have not been fully explored, 3. Ventilation plant is close to industrial properties in Canham Road. 4. There are occasional exiting odour problems at this site at present. The alternatives suggested would require the relocation of existing business premises. The Tunnel construction site has been moved to the northern end of the site and access has changed from the residential roads to the south and east to the industrial estate to the north. Some of the construction spoil material will be used to fill 2 of the existing storm tanks on site. Ventilation plant is further from residential properties. There is more scope for bring forward development once construction is complete. The Mayor accepts that the preferred option is the best option as it has the fewest impacts. It has also reduced impacts since the Phase 1 consultation by moving construction works and site access to the less sensitive northern end of the site. However Thames Water need to: Ensure that construction impacts are minimised to an acceptable level Undertake traffic modelling to ensure that traffic impacts on the road network, especially the A4020 are acceptable. Opportunities to reduce road distances, potentially by using consolidation centres at nearby barge/rail served sites should be investigated. Examining options for further use of spoil to infill the last 4 storage tanks. Ensure that the location and design of the ventilation plant minimises any noise/odour impacts on nearby residents. Options for using the storm tanks to store surface water should be considered prior to confirming that they will be infilled given the wider issues of surface water management in west London. Legacy Examine how the site could be brought forward for development upon completion of the works.
Appendix 1 Mayors Response to Thames Tunnel Consultation Phase 2 Page 17 of 51

Alternatives Changes since Phase 1

Conclusion

Site Name Borough Purpose Construction Period Impacts

2 Hammersmith Pumping Station Hammersmith & Fulham CSO Connection 3 Years 1. Construction close to residential and commercial premises and to Public Open Space. 2. Site/adjacent land is also subject to planning permission for a residential development 3. Traffic on SRN Fulham Palace Road (A219) and impacts on Hammersmith Gyratory Phases The alternatives suggested would have higher impacts on Greenfield sites or sites closer to residential properties as opposed to the brownfield site preferred. The scale of operations has been reduced at this site due to a change in tunnelling methodology so that this site is no longer required to act as a main tunnel reception site and the drive site for a connection tunnel to Acton Storm Tanks. Thames Water has been in negotiation with residential developer to ensure that the Tunnel and development can be phased together. The Mayor accepts that the preferred option is the best option as it has the fewest impacts. However, Thames Water need to: Properly examine the options of using the river for transport. The local road network is particularly congested and the residential development should also be able to make use of a river delivery facility. It is disappointing that a more proactive approach to using barges has not been taken. The proposed quantity of HGVs, especially in an area where the local road network is so busy, warrants further examination of the use of barges, especially as there should be opportunities to combine such a facility with the importation of materials for the adjacent residential development Ensure that arrangements are in place to minimise impacts on the redevelopment of Hammersmith Embankment/Fulham Riverside development this may include the shared use of any river transport facilities. Ensure that construction impacts are minimised to an acceptable level. It is likely that 2.4m acoustic screens be recommended for site boundaries close to residential properties Ensure that a good quality Thames Path diversion is put in place. Ensure that the location and design of the ventilation plant minimises any noise/odour impacts on nearby residents Legacy: The design and location of any facilities to support river transport should be designed in such a way that they have a purpose following construction such as river transport or river sports/recreation. An improved Thames Path and public realm should be re-instated This site will continue to have a sewer overflow to the Thames for occasions when the Thames Tunnel capacity is reached. Equipment should be installed to monitor the performance of the system once operational. The design of finished Pumping Station and boundary wall appears bland and needs to be improved.

Alternatives Changes since Phase 1

Conclusion

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Site Name Borough Purpose Construction Period Impacts

3 Barn Elms Richmond CSO Connection 2 Years Loss of open space/playing fields Construction close to residential properties to the south of the site Disruption to Thames Path Construction impacts on Thames Foreshore Limited vehicle access TW are proposing a temporary access road around the edge of the playing fields, approx 1km long 6. Relocation of Scout Hut There are no proposed alternatives to this site as it needs to intercept the existing sewer. In phase 1 Barn Elms was proposed as a main tunnelling site and a CSO connection site. Carnwath Road, Fulham has replaced Barn Elms as a main tunnelling site, therefore the scale and length of works is significantly reduced. The proposal to use the river for barge transport has been dropped for this site due to the much smaller volumes of material. The switch from Barn Elms to Carnwath Road for main tunnelling purposes is supported as this relocates major tunnelling activities from a Greenfield to a partially derelict Brownfield site and increases the viability of barge transport by using a currently vacant safeguarded wharf. The remaining works at Barn Elms to connect the CSO to the tunnel are unavoidable and the Mayor accepts that these can be implemented acceptably. However, Thames Water need to: Re-examine the access route, it seems disruptive to construct such a long haul road, although it is also undesirable to have the embankment/Thames path used for any intensive lorry movements. Ensure that the Thames Path remains open with minimal disruption. Options for using the river need to be further explored. Provide suitable replacement premises for the Scout Hut. Agree the proposed relocation of the bus stop on Rocks Lane with TfL. Design of the permanent structures need to be sympathetic to their setting. 1. 2. 3. 4. 5.

Alternatives Changes since Phase 1

Conclusion

Legacy: The design and location of any river jetty should be designed in such a way it has a purpose following construction such as river transport or river sports/recreation. This should be determined through liaison with river boat operators and sports clubs Thames Water should liaise with school playing field users to identify the reinstatement requirements should be of the site. An improved Thames Path and public realm should be re-instated This site will continue to have a sewer overflow to the Thames for occasions when the Thames Tunnel capacity is reached. Equipment should be installed to monitor the performance of the system once operational.

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Site Name Borough Purpose Construction Period Impacts

4 Putney Bridge Foreshore Wandsworth CSO Connection 3 years 1. Construction close to residential properties 2. Disruption to river users 3. Disruption to Thames Path 4. Limited vehicle access 5. Nearby passenger pier 6. Possible disruption to highway 7. Possible relocation of bus stop No alternatives are proposed. The alternatives put forward in phase 1 were less acceptable than this site. The duration of construction is now expected to take 1 years longer and a temporary slipway will be constructed 300m to the west of Putney Bridge. The preferred option is acceptable. However, Thames Water need to: Re-examine the quantity of materials being transport by barge. The use of barges to transport cofferdam fill material in phases 1 and 5 is welcomed, but the lack of any barges during phases 2-4 requires further consideration, especially as HGVs will need to be manoeuvred in relatively constrained local roads. It will be vital that appropriate measures are put in place to ensure the safety of all local road users. Ensure that construction impacts are minimised to an acceptable level. It is likely that 2.4m acoustic screens be recommended for site boundaries close to residential properties Disruption to the highway and bus operation is minimised and any relocation of bus stops will require agreement with TfL Ensure that disruption to the Thames Path is minimised and that pedestrian crossings, diversionary signage are carefully designed and agreed with TfL. The location and design of the ventilation plant should ensure that any noise/odour impacts on nearby residents are minimised. It is welcomed that a temporary slipway will be installed given the prominence of river sports at this location. Legacy An improved Thames Path and public realm should be re-instated with suitable re-instatement of the river access facilities/slipway should be provided following liaison with river users. It is a concern that the design of the permanent structure appears somewhat unsympathetic to the alignment and character of the river/embankment at this point. This site will continue to have a sewer overflow to the Thames for occasions when the Thames Tunnel capacity is reached. Equipment should be installed to monitor the performance of the system once operational.

Alternatives Changes since Phase 1 Conclusion

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Site Name Borough Purpose Construction Period Impacts

5 King Georges Park Wandsworth CSO Connection 2 Years 1. Loss of open space, including some large trees 2. Impact on Metropolitan Open Land 3. Construction close to residential properties 4. traffic impact on the TLRN. No alternative is given in the consultation material and no site is thought to be readily available that would cause fewer impacts. The proposed construction period is 6 months longer. Changes to the layout have been made to protect an existing mature tree and memorial bench. The preferred option is acceptable. The site forms a relatively small proportion of a large park. However, Thames Water need to: Ensure that disruption to the park is minimised Assess the impact of construction vehicles using the adjacent TLRN Wandsworth one way system any necessary adjustments be agreed with TfL. Investigate opportunities to reduce road distances, potentially by using consolidation centres at nearby barge/rail served sites should be investigated. Ensure that construction impacts are minimised to an acceptable level. It is likely that 2.4m acoustic screens be recommended for site boundaries close to residential properties and to protect park users Ensure that the location and design of the ventilation plant minimises any noise/odour impacts on nearby residents. There appears to be 2 ventilation columns, it would be less obtrusive if these were combined into a single structure. Legacy Thames Water should liaise with LB Wandsworth and park users to determine a good quality re-instatement of the park and public realm. This site will continue to have a sewer overflow to the River Wandle for occasions when the Thames Tunnel capacity is reached. Equipment should be installed to monitor the performance of the system once operational.

Alternatives Changes since Phase 1 Conclusion

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Site Name Borough Purpose Construction Period Impacts Alternatives

6 Dormay Street Wandsworth CSO Connection and Frogmore Connection Tunnel Drives 3 Years 1. Disruption to businesses including LB Wandsworth Depot 2. HGV Movements on nearby A217 (TLRN) This site is a new site and is proposed as an alternative to the previous adjacent Bell Lane Creek site which would have required the relocation of a local business, Panorama Antennas. The alternative shown appears to have similar impacts to the preferred site. New site The Mayor raised concern at the impact on the local business affect by the Phase 1 proposal, therefore this change is generally supported. The proposed site is supported provided that suitable arrangements are in place with LB Wandsworth to manage the impacts on the LB W Depot. However Thames Water will need to: Agree modifications to the design of the Dormay Street/Armoury Way junction with TfL. Dormay Street Figure 2E should be left turn out not right turn out. Examine opportunities to reduce road distances, potentially by using consolidation centres at nearby barge/rail served sites should be investigated. Legacy Ensure that the site is available for productive uses, which are likely to be industrial/storage/distribution, once construction works are complete. This site will continue to have a sewer overflow to the River Wandle for occasions when the Thames Tunnel capacity is reached. Equipment should be installed to monitor the performance of the system once operational.

Changes since Phase 1 Conclusion

Site Name Borough Purpose Construction Period Impacts Alternatives Conclusion

Bell Lane Creek Wandsworth No longer required formerly a CSO Connection None n/a Dormay Street is now proposed as the replacement to this site. The Mayor welcomes the change of preferred site in this location, subject to agreement with LB Wandsworth, as it removes an impact on an existing local business.

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Site Name Borough Purpose Construction Period Impacts

7 Carnwath Road Hammersmith & Fulham Main Tunnelling Site to Acton Storm tanks and reception site from Kirtling Street 6 Years 1. Construction close to residential properties to the north, east and west of the site 2. Loss of light industrial businesses 3. Loss of vacant safeguarded Hurlingham Wharf 4. Loss of potential development site at Whiffen Wharf 5. Additional vehicle movements on Carnwath Road and on surrounding routes 6. Use of 2 barges/day This site is the alternative to Barn Elms as a main tunnel construction site. New site in Phase 2. The switch to Carnwath Road from Barn Elms for main tunnelling purposes is supported as this relocates major tunnelling activities from a Greenfield to a partially derelict Brownfield site which benefits from good navigational characteristics and better access to the Strategic Road Network. However Thames Water will need to: Ensure that existing businesses on site are relocated to suitable alternative premises with minimal disruption Ensure that existing residents are protected from noise and dust. The proposal to enclose the shaft and crane within a building is welcomed, subject to ensuring that it meets the noise, dust etc requirements. Re-examine the extent to which river barges are being used at this site. The 2 barges per week during phases 2 and 3 are welcomed however, this still leaves a significant number of HGVs visiting the site over a six year period. The Mayor remains un-convinced that more of these cannot be switched to barge deliveries as the site is particularly well suited to barges. Undertake traffic modelling to ensure that traffic impacts on the road network are acceptable, especially on Carnwath Road, Wandsworth Bridge Road and the junction. Any proposed modifications, will need to be assessed and agreed with TfL. Potential impact on bus services and stops in the vicinity of this site will also need to be agreed with TfL. There are schools within a relatively close proximity to the site. Due to the heightened usage and vulnerability of pedestrians connected with these schools, safety of construction traffic will be of paramount importance and to reduce the impacts (congestion, air quality etc.) of these vehicles. Legacy: On completion of construction works, the Hurlingham Wharf site must be returned to a viable working wharf and that surrounding land can be brought back into use in line with development plans currently being developed by H&F Council. The design and location of the permanent structures should be agreed with LB H&F but should act as a buffer between residential development to the west of the site and the Safeguarded Wharf. An improved Thames Path and public realm should be re-instated with a suitable diversion inland to Carnwath Road around the Safeguarded Wharf.

Alternatives Changes since Phase 1 Conclusion

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Site Name Borough Purpose Construction Period Impacts Alternatives Changes since Phase 1 Conclusion

Jews Row Wandsworth No longer required formerly a CSO Connection None n/a n/a The site is no longer required as changes to the sewer system mean that the impact of the 2 CSOs at this site will no longer need to be intercepted. The removal of this site is supported as the site currently contains an operational safeguarded wharf which imports construction materials and would have required re-provision elsewhere. Legacy Thames Water should confirm whether any CSOs would still occur at this site once the Tunnel is complete.

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Site Name Borough Purpose Construction Period Impacts Alternatives Changes since Phase 1 Conclusion

8 Falconbrook Pumping Station Wandsworth CSO Connection 3 Years 1. Loss of part of open space 2. Access onto TLRN 3. Relocation of bus stop This site is an alternative to Bridges Court Car Park site contained in Phase 1 consultation. New site which is an alternative to Bridges Court Car Park The preferred option appears to be the best option as it has the fewer impacts than the Phase 1 proposal and enables redevelopment of the Bridges Court Car park to proceed. However, Thames Water need to: Ensure that construction impacts are minimised to an acceptable level. It is likely that 2.4m acoustic screens be recommended for site boundaries close to residential properties Agree final site access junction design with TfL, including provision for the installed Cycle Superhighway 8, therefore cyclist safety will need to be a consideration in the design and assessment. Agree final arrangements for proposed relocation of the bus stop on A3205 York Road with TfL. TheshortconnectiontunneltraversesYorkRoadandthereisadropshaftin closeproximity.ItishighlightedthatproceduresfortheTechnicalApprovalfor HighwayStructuresoutlinedwithintheDesignManualforRoadsandBridges (DMRB)willberequired Legacy Discussions with LB Wandsworth should ensure that the re-instatement works deliver an improved park and public realm. This site will continue to have a sewer overflow to the River Thames for occasions when the Thames Tunnel capacity is reached. Equipment should be installed to monitor the performance of the system once operational. Bridges Court Car Park Wandsworth No longer required formerly a CSO Connection None n/a The Falconbrook Pumping Station site is now proposed as an alternative to this site. The Mayor welcomes the replacement of this site with Falconbrook Pumping Station as this will free up a development site and should result in the improvement of a local park.

Site Name Borough Purpose Construction Period Impacts Alternatives Conclusion

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Site Name Borough Purpose Construction Period Impacts Alternatives Changes since Phase 1 Conclusion

9 Cremorne Wharf Foreshore Kensington & Chelsea CSO Connection 3 Years 1. Disruption to nearby residential properties 2. Disruption to waste transfer station/wharf 3. Potential traffic impact on Lots Road and nearby TLRN (A3220/A3212) No alternatives are suggested. The site has been moved from construction in the Thames Foreshore to on land. This should be a net reduction in cost. The proposed access through the adjacent park has also been removed. The changes to the site and access arrangements of the site are supported and should reduce costs and remove the need to access the foreshore via the nearby park. The use of the safeguarded wharf is considered London Plan policy compliant as long as the majority of construction materials are transported by barge. However, Thames Water need to: Ensure that the construction minimises disturbance to nearby residential properties, in particular those that overlook the Thames and for whom screening may be difficult. Ensure the maximum reasonable use is made of river transportation in order to be compliant with the safeguarded wharf status of Cremorne Wharf and to reduce traffic impacts on Lots Road and the wider network. The Mayor is not convinced that this has currently been achieved, especially as there may be opportunities to share facilities with the development of the adjacent Lots Road site. Undertake traffic modelling to ensure that traffic impacts on the road network, especially the TLRN A3220 are acceptable. The detailed design of the junction of Lots Road/A3220 will need to be agreed with TfL. Ensure that there are suitable alternative operating arrangements for the waste transfer station. Ensure that the location and design of the ventilation plant should minimise any noise/odour impacts on nearby residents. Ensure that the construction of the Tunnel is integrated with construction of the adjacent Lots Road development and that any opportunities to share freight logistics are taken.

Legacy On completion of construction works, Cremorne Wharf must be returned to a viable working wharf Ensure that the re-instatement makes provision for completing the Thames path in this location. This site will continue to have a sewer overflow to the River Thames for occasions when the Thames Tunnel capacity is reached. Equipment should be installed to monitor the performance of the system once operational.

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Site Name Borough Purpose Construction Period Impacts

Alternatives

Changes since Phase 1 Conclusion

10 Chelsea Embankment Foreshore Kensington & Chelsea CSO Connection 4 Years 1. Construction impacts on the Thames Foreshore 2. Disruption to Thames Path 3. Traffic impact and construction into highway (Chelsea Embankment (A 3212) is part of the TLRN and narrow lane two way working is proposed) 4. Impact on Listed Buildings and structures and Conservation Areas Consideration has been given to a site within Ranelagh Gardens. This alternative has drawbacks of being closer to residents and occupying an area of open space, however it does have the advantages of reducing the works in the Thames Foreshore and on the A3213 Chelsea Embankment. The period of construction is now expected to be 4 years, more detail is available in respect to impacts on the TLRN and a more sympathetic treatment of the new river wall is proposed. The choice between the preferred site and Ranelagh Gardens appears finely balanced, particularly as the currently proposed use of the river for transport is not felt to be comprehensive (only in connection with the construction of the cofferdam area). This is not acceptable given that the site is particularly sensitive in traffic terms and that TfL have not yet seen suitable traffic modelling. The Mayor is not yet convinced that the preferred site is the optimal one. Thames Water need to consider the following points: This site is located immediately adjacent to and within the A3212 Chelsea Embankment, a critical east-west route through central London, which experiences significant volumes of traffic throughout the day. Accommodating the site works and site access proposals would require use of the existing highway space and a narrowing of existing lanes. This will impact on capacity for road users and raises safety concerns. TfL has not yet seen detailed traffic modelling identifying the likely impacts on the highway network. Existing highway capacity on A3212 Chelsea Embankment should be maintained at all times. Where any lane or parking/loading capacity is required this should be a temporary arrangement and for as short a period as possible to minimise disruption to road users. The impact of these arrangements will need to be assessed (considering the impact of any pedestrian diversions requiring additional crossing movements) with appropriate traffic modelling tools and discussed with TfL. Any traffic management arrangements will need to be discussed and agreed with TfL. The works proposed at Chelsea Embankment, Victoria Embankment and Blackfriars will all impact on a critical east-west corridor through central London. As a result their impact will need to be assessed together as part of the construction logistics strategy and ongoing TA/EIA work being undertaken, and depending on the outcome of that assessment, careful consideration given to the phasing of works so as to minimise disruption to users. The works phase 1 site drawings show both the sites on either side of Chelsea Embankment in operation. TfL had understood that works phase 1 would only show a single site in operation. It is noted that there is an underground structure planned below the A3212 and a large drop shaft planned to abut this road. It is highlighted that procedures for the Technical Approval for Highway Structures outlined within the DMRB will be required.
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Appendix 1 Mayors Response to Thames Tunnel Consultation Phase 2

Until these issues have been considered by TfL, the Mayor cannot come to a position as to whether this proposal is acceptable. Once a position has been reached, the following issues will remain concerns that Thames Water will need to address: Any requirement to narrow carriageway widths on the Embankment raises safety issues, particularly for cyclists. Clearly this will need to be a key consideration in the design and assessment of proposals in this area. Mitigation measures to address this may be required. The impact of the proposed diversion of the Thames Path will need assessing and appropriate mitigation put forward, including pedestrian crossings, diversionary signage etc which will need to be discussed further with TfL. As part of the permanent scheme arrangement changes are proposed to the highway design on Chelsea Embankment, including changes to pedestrian crossing arrangements. The impacts of these changes on highway capacity, safety etc need assessing and further discussion is required with TfL. The design of the site access/cross-over to the permanent foreshore appears over engineered considering the low level of proposed use. Tree Removal and Planting. The scheme proposes the removal of a number of mature trees within the highway. This needs further discussion with TfL to explore options for retaining the trees, to discuss proposed replacement tree planting at this location and other potential mitigation measures and to ensure adequate measures are put forward to protect other existing highway trees in the vicinity of the site. Arrangements to allow buses to turn right from A3212 Chelsea Embankment into the bus turning circle will need to be maintained. Determine the details regarding how the works will affect the highway, it can be expected that there will be tight constraints on these works given the congested and strategic nature of the TLRN. To reduce the impacts (congestion, air quality etc.) of HGVs accessing the site further consideration should be given to greater use of the river for transporting materials to and from this site during construction. Ensure that the temporary diversion of the Thames Path is of good quality. Legacy Further work on the completed scheme needs to be undertaken to ensure that the re-instatement provides an improved Thames Path and public realm appropriate for this a high profile location. Discussion are required with river users, TfL, PLA and the LPA regarding the potential future use of the site for river uses including as a freight wharf or recreational jetty. This site will continue to have a sewer overflow to the River Thames for occasions when the Thames Tunnel capacity is reached. Equipment should be installed to monitor the performance of the system once operational.

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Site Name Borough Purpose Construction Period Impacts

11 Kirtling Street Wandsworth Main Tunnel Driving site east to Chambers Wharf & west to Carnwath Road, 6 Years 1. Delays to development of the Vauxhall Nine Elms Battersea (VNEB) Opportunity Area including delivering homes and jobs, subject to current planning application 2. Impact on or relocation of riverboat dwellings 3. Impact on or relocation of local businesses 4. Disruption to Thames Path 5. Impacts on Safeguarded Wharves notably Kirtling Wharf 6. Potential impact on proposed Northern Line extension 7. Impact on the TLRN (A3205 Nine Elms Lane) A number of alternative sites have been examined. Sites south of Nine Elms Lane do not appear to be practical given their remote location from the river and the emerging new development in this area. Site 1 with Battersea Park is unlikely to be acceptable given that there are brownfield sites available and site 4 is clearly too small. Sites 2 and 3 comprise parcels of land in and around Battersea Power Station. Given the considerable uncertainties and long term timescale surrounding the redevelopment of the Power Station, these sites are worthy of further, more detailed consideration. The reasons cited as potential difficulties with these sites, the redevelopment of Battersea Power Station, could in fact be advantages allowing use of a derelict site with good access to the river and the potential to re-use and/or share river jetty facilities and logistics. The site has changed due to the grant of planning permission for a residential development on part of the previous preferred site. One consequence of the change is that the local CSO connection is now proposed to take place on a separate site (Heathwall Pumping Station), whereas these sites were previously joined. The site is now proposed to be a double drive site ie from Kirtling St to Carnwath Road and from Kirtling St to Chambers Wharf. The Mayor is not yet convinced that this site is the best site to be used and a further exploration of the potential of using land in and around Battersea Power Station should be undertaken. If the Battersea Power Station area is not feasible or not preferred following more detailed examination, the, Kirtling Street site may be acceptable subject to resolving the following concerns: The Mayor remains unconvinced that the full use is being proposed of the river for transport. As a double drive site, this will be the site with the greatest amount of construction activity. There should also be opportunities to integrate the use of river facilities with the redevelopment of the surrounding VNEB Opportunity Area and potentially the construction of the Northern Line extension to Battersea. Opportunities for utilising rail access to this site should also be explored further given the proximity of the Stewarts Lane sidings and other potential major developments in the area. The impact on the Nine Elms Lanes junctions (Cringle Street, Kirtling Street), including any proposed modifications, during construction will need to be assessed and discussed further with TfL. The impact of the proposed diversion of the Thames Path along Nine Elms Lane will need assessing and appropriate mitigation put forward, including pedestrian crossings, diversionary signage etc which will need to be discussed further with
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Alternatives

Changes since Phase 1

Conclusion

Appendix 1 Mayors Response to Thames Tunnel Consultation Phase 2

There are a number of other major development proposals impacting on this area. To minimise the impact of the proposed scheme it will be important to consider opportunities to work closely with other scheme promoters and coordinate/share construction logistics plans. It is noted that the site abuts the A3205 and that there is a large drop shaft planned within the site. It is highlighted that procedures for the Technical Approval for Highway Structures outlined within the DMRB may be required. Details of the interaction between the logistics plan and strategy for this site and Heathwall Pumping Station, needs to be fully examined, discussed and understood with careful monitoring during the construction phase.

Thames Water will also need to: Ensure that the safeguarded wharves of Cringle Dock and particularly the aggregates depot at Kirtling Wharf can continue to operate as freight wharves Examine opportunities to share construction/waste facilities with the developments within the surrounding VNEB Opportunity Area. Ensure the suitable relocation of any affected businesses. Ensure suitable relocation of any affected boats. Ensure that the location and design of the ventilation plant should minimise any noise/odour impacts on nearby residents including future redevelopments Ensure that the design of both the permanent and temporary works into the river does not cause unacceptable siltation, erosion or other hydrological impacts Ensure that there is no conflict with the Northern Line extension construction requirements Legacy Ensure that re-instatement works minimise their impact on the regeneration of the area including the development potential of the site. On completion of construction works, Kirtling Wharf site must be returned to a viable working wharf. Further work on the completed scheme needs to be undertaken to ensure that the re-instatement provides an improved Thames Path and public realm appropriate for this changing location.

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Site Name Borough Purpose Construction Period Impacts

12 Heathwall Pumping Station Wandsworth CSO Connection 3 Years 1. Delays to development of the Vauxhall Nine Elms Battersea Opportunity Area including delivering homes and jobs, subject to current planning application 2. Impact on or relocation of riverboat dwellings 3. Impact on or relocation of local businesses 4. Disruption to Thames Path 5. Impact on Safeguarded Middle Wharf The only alternative presented is to construct the CSO connection in the foreshore. This would have a similar level of impact and be likely to be more expensive. The site has changed due to the grant of planning permission for a residential development on part of the previous site. This CSO connection was previously on a single site along with the Tunnel Construction activities that are now proposed at Kirtling Street, a short distance west. The current site is broadly acceptable. However, Thames Water need to: Re-examine the use of barges for this site, particularly given the sites safeguarded wharf designation. The safeguarded wharf is not currently in use, therefore there is no need to re-provide a wharf during construction Ensure a good quality signposting of the Thames Path, during construction works. Ensure suitable relocation of any affected boats. Ensure that the location and design of the ventilation plant should minimise any noise/odour impacts on nearby residents including future redevelopments Ensure that the design of both the permanent and temporary works into the river does not cause unacceptable siltation, erosion or other hydrological impacts The site abuts the A3205 and that there is a large drop shaft planned within the site. It is highlighted that procedures for the Technical Approval for Highway Structures outlined within the DMRB may be required. Details of the interaction between the logistics plan and strategy for this site and Kirtling Street needs to be fully examined, discussed and understood with careful monitoring during the construction phase. Final site access junction design from Nine Elms Lane will need agreeing with TfL. It is noted that there is a large drop shaft planned which abuts the A3205. It is highlighted that procedures for the Technical Approval for Highway Structures outlined within the DMRB will be required. Legacy Ensure that re-instatement works minimise their impact on the regeneration of the area including the development potential of the site. On completion of construction works, Middle Wharf must be returned to a viable working wharf. Thames Water has indicated that the design of the permanent structures is fully compatible with this, and as such this is welcomed. Thames Water has indicated that a new Thames Path will be created along the river front, with a gate for times when the wharf is un/loading. This would represent an improvement on the existing situation where the Thames Path is routed along Nine Elms Lane. This site will continue to have a sewer overflow to the River Thames for occasions when the Thames Tunnel capacity is reached. Equipment should be installed to monitor the performance of the system once operational.

Alternatives Changes since Phase 1 Conclusion

Appendix 1 Mayors Response to Thames Tunnel Consultation Phase 2

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Site Name Borough Purpose Construction Period Impacts

13 Albert Embankment Foreshore Lambeth CSO Connection 3 Years Construction in Thames Foreshore Access off the TLRN Construction close to Victoria Line Tunnels Construction risks to TLRN (A202 Vauxhall Bridge) and highway impacts on TLRN (A3036 Albert Embankment) 5. Historic embankment structure 6. Construction close to commercial properties 7. Disruption to river slipway (Lacks Dock) No alternative locations are proposed for this site. The proposals now envisage using the Lacks Dock slipway entrance to access the site. The preferred option is acceptable and the change in access arrangements is supported as it means that an additional access onto the TLRN is not created. However, Thames Water need to: Further investigate the use of barges to this site. This is particularly important given the location within central London. Demonstrate suitable arrangements for holding/inspecting vehicles arriving at site, without disrupting the operation of the TLRN (A3036) Ensure that construction impacts are minimised to an acceptable level. It is likely that 2.4m acoustic screens be recommended for site boundary close to the commercial office properties Ensure suitable protection to Vauxhall Bridge and the Victoria Line tunnels and operation The diversion route for the Thames Path is acceptable, although diversionary signage etc which will need to be discussed further with TfL.. The ability of other vessels to use Lacks Dock will need to be considered. Ensure impacts on historic embankment structures are minimised. The design of the permanent works into the river appears generally sympathetic to its location although more detailed clarification is needed. The addition of public space is welcomed. Need to confirm that the in river structures do not cause unacceptable siltation, erosion or other river impacts Legacy Discuss with river users, TfL and the LPA possible uses of the site for river uses including as a public wharf. Ensure that an improved Thames Path and public realm are re-instated. The permanent structures offer the opportunity for interesting public spaces and safe access to the foreshore should be retained/improved. This site will continue to have a sewer overflow to the River Thames for occasions when the Thames Tunnel capacity is reached. Equipment should be installed to monitor the performance of the system once operational. 1. 2. 3. 4.

Alternatives Changes since Phase 1 Conclusion

Appendix 1 Mayors Response to Thames Tunnel Consultation Phase 2

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Site Name Borough Purpose Construction Period Impacts

14 Victoria Embankment Foreshore Westminster CSO Connection 4 Years 1. Construction close to/under tube lines (Bakerloo & District) 2. Impact on the TLRN (A3211 Victoria Embankment), including coach parking 3. Impact on navigation, in particular river passenger services at Embankment Pier 4. Construction in Thames Foreshore 5. Impact on Listed Buildings and structures and Conservation Areas 6. Impact on existing floating businesses such as the Hispaniola and Tattershall Castle 7. Impact on London View Management Framework view 17A.1 and 17A.2 from Hungerford bridge upstream There are no realistic alternatives to this site The construction is now expected to take 4 years (previously 2). The location of the site has been moved slightly to be further south, this means it is further from Bakerloo Line tunnels, Embankment Pier and Hungerford Bridge. The preferred option will be disruptive and there are does not appear to be any realistic alternative. However, the Mayor has significant concerns about the site and Thames Water will need to undertake further work to ensure that the site can be delivered in an acceptable way: This site is located immediately adjacent to A3211 Victoria Embankment, a critical east-west route through central London, which experiences significant volumes of traffic throughout the day. Accommodating the site works and site access proposals would require use of the existing highway space and a narrowing of existing lanes. This will potentially impact on capacity for road users and raises safety concerns. To reduce the impacts (congestion, air quality etc.) of HGVs accessing the site further consideration should be given to greater use of the river for transporting materials to and from this site during construction. In particular Phases 2 and 4 do not anticipate using barge transport. Existing highway capacity on A3211 Victoria Embankment should be maintained at all times. Where any lane or parking/loading capacity is required this should be a temporary arrangement and for as short a period as possible to minimise disruption to road users. The impact of these arrangements will need to be assessed (considering the impact of any pedestrian diversions requiring additional crossing movements) with appropriate traffic modelling tools and discussed with TfL. This should include assessing the impact on bus services. Any traffic management arrangements will need to be discussed and agreed with TfL. Any requirement to narrow carriageway widths on the Embankment raises safety issues, particularly for cyclists. Clearly this will need to be a key consideration in the design and assessment of proposals in this area. Mitigation measures to address this may be required. The works proposed at Chelsea Embankment, Victoria Embankment and Blackfriars will all impact on a critical east-west corridor through central London. As a result their impact will need to be assessed together, and depending on the outcome of that assessment, careful consideration given to the phasing of works so as to minimise disruption to users. The impact of the proposed diversion of the Thames Path will need assessing and appropriate mitigation put forward, including pedestrian crossings, diversionary signage etc which will need to be discussed further with TfL. The scheme proposal will require the temporary loss of coach parking on Victoria
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Alternatives Changes since Phase 1 Conclusion

Appendix 1 Mayors Response to Thames Tunnel Consultation Phase 2

The design of the site access/cross-over to the permanent foreshore appears over engineered considering the low level of proposed use. Tree Removal and Planting The scheme proposes the removal of a number of mature trees within the highway. This needs further discussion with TfL to explore options for retaining the trees, to discuss proposed replacement tree planting at this location and other potential mitigation measures and to ensure adequate measures are put forward to protect other existing highway trees in the vicinity of the site. It should be noted by the scheme promoter that any new trees would require a commuted sum being paid for future care and maintenance. It is noted that the low level sewer interception chamber will affect the A3211 Victoria Embankment. It is highlighted from that procedures for the Technical Approval for Highway Structures outlined within the DMRB will be required. It is also highlighted to the scheme promoter that there will be effects from works surrounding Bazelgettes Pipe subway (WCC owned) and statutory undertakers plant that are located between the revetment and the carriageway. The details of these works will need to be agreed with both TfL and WCC. It is noted that during the construction, vessels used to build the site may require anchors or ground mooring which could cause problems to the safe navigation of passenger services from the Pier. Vessels departing the Pier to navigate upstream would have to pass close to the site through the No 1 Arch of Charing Cross Railway Bridge. Further details on the operations and logistics of the site are required. Detailed discussions with London River Services and the PLA are advised. There is a potential interface with the London Underground District & Circle Line and Bakerloo Line Tunnels and further advanced detailed discussions on the intended work are required to ensure that there is no risk to these structures.

Thames Water will also need to: Ensure that there are suitable relocation arrangements in place for the impacted businesses, notably Tattershall Castle. Ensure that the design of both the permanent and temporary works into the river does not cause unacceptable siltation, erosion or other hydrological impacts Ensure acceptable impacts on Listed Buildings and Structures and Conservation Areas. Ensure that LVMF view is not harmed Legacy Ensure that an improved Thames Path is re-instated and the additional public realm has a clear purpose reflecting its high profile location. There may also be opportunities to incorporate cycle facilities in the new area of public realm.

Appendix 1 Mayors Response to Thames Tunnel Consultation Phase 2

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Site Name Borough Purpose Construction Period Impacts

15 Blackfriars Bridge Foreshore City CSO Connection 5 Years Protection of Waterloo & City and District tube lines Impact on the TLRN (A3211 Victoria Embankment), including coach parking Closure of Westbound sliproad from Blackfriars Bridge. Impact on navigation, in particular river passenger services due to relocation of Blackfriars Pier 5. Construction in the Thames Foreshore 6. Impact on Listed Buildings and structures and Conservation Areas Impact on existing businesses such as those in the Blackfriars Pier Structure 7. Impact on London View Management Framework view 16B.1 and 16B.2 from Gabriels Wharf Hungerford bridge upstream No alternatives are identified. The construction phase is now expected to last 5 years (previously 4). Westbound slip road to be closed. The preferred option will be very disruptive and there are does not appear to be any realistic alternative to this site. However, the Mayor has significant concerns about the site construction proposals and the likely impact on highway capacity and road users in this area. Thames Water need to undertake further work with TfL and all relevant stakeholders, including considering alternatives approaches to both construction and logistics, to ensure that the site can be delivered in an acceptable way: This site is located immediately adjacent to A3211 Victoria Embankment and its junction with A201 Farringdon Street/Blackfriars Road & Bridge. The site adjoins the slip road from Blackfriars junction down to the Victoria Embankment W/B carriageway. Victoria Embankment is a critical east-west route through central London, which experiences significant volumes of traffic throughout the day. Blackfriars Bridge is an important North-South route into The City of London. The junction at Blackfriars Bridge is an extremely busy and important intersection for vehicles, pedestrians and cyclists. The existing Blackfriars pier is located at this site. Accommodating the site works and site access proposals would require the closure of the Blackfriars junction slip road and/or the narrowing of lanes on Victoria Embankment for significant periods of time during the 5 year construction works. These current proposals are therefore likely to have very significant and unacceptable impacts on highway capacity and road users in the area. The proposals also raise road safety concerns. To help reduce the impacts of construction at this site the Mayor therefore strongly believes that the vast majority of material and equipment transported to and from this site during construction should be by river barge. The Mayor also believes that all construction options should be reviewed at this site that will help maintain existing highway capacity at the Blackfriars junction and on the A3211 Victoria Embankment at all times. If this work shows that a loss of lane or parking/loading capacity is required then this must only be a temporary arrangement and for as short an agreed period of time as possible. He is also very concerned that the traffic impacts of the proposed construction arrangements and any alternatives have not yet been fully assessed in detail (including considering the impact of any pedestrian diversions requiring additional road crossing movements). This must be done with appropriate traffic modelling tools and discussed further with TfL. This assessment should include considering the impact on bus services in the area. Any traffic management
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1. 2. 3. 4.

Alternatives Changes since Phase 1 Conclusion

Appendix 1 Mayors Response to Thames Tunnel Consultation Phase 2

Phase 3 is shown as being for a period of 2 years. It is during this phase that the closure of the slip-road adjacent to the site is proposed. A closure of the slip road for this period of time would be unacceptable. As set out above, alternatives approaches that allow the closure to be avoided, or the closure period to be minimised, should be fully explored and assessed further with TfL. The Phase 2 assessment indicates that the impact of the proposal on road users in this area is minor adverse. This assessment clearly does not adequately reflect the nature and period of impact arising from the scheme proposals. Any requirement to narrow carriageway widths on the Embankment raises general safety issues, particularly for cyclists. Clearly this will need to be a key consideration in the design and assessment of proposals in this area. Mitigation measures to address this will be required. The works proposed at Chelsea Embankment, Victoria Embankment and Blackfriars will all impact on a critical east-west corridor through central London. As a result their impact will need to be assessed together as part of the construction logistics strategy and ongoing TA/EIA work being undertaken, and depending on the outcome of that assessment, careful consideration given to the phasing of works so as to minimise disruption to users. The impact of the proposed diversion of the Thames Path will need assessing and appropriate mitigation put forward, including pedestrian crossings, diversionary signage etc which will need to be discussed further with TfL. The scheme proposal will require the temporary loss of coach parking on Victoria Embankment. To mitigate this impact alternative provision will need to be made. This should be discussed with TfL. The design of the site access/cross-over to the permanent foreshore appears over engineered considering the low level of proposed use. Tree Removal and Planting The scheme proposes the removal of a number of mature trees within the highway. This needs further discussion with TfL to explore options for retaining the trees, to discuss proposed replacement tree planting at this location and other potential mitigation measures and to ensure adequate measures are put forward to protect other existing highway trees in the vicinity of the site. It should be noted by the scheme promoter that any new trees would require a commuted sum being paid for future care and maintenance. The scheme proposes the removal of the existing Blackfriars Pier. The provision of a new pier is imperative and is currently proposed to the east of Blackfriars Bridge. A more detailed assessment of this proposal on users of the pier and on pedestrian movements in this area is required to understand the impacts and what mitigation measures may be required to ensure safe and convenient step free pedestrian access which facilitates easy access to other modes of transport. This assessment needs to consider access for people with mobility impairments. The New Pier must be in place prior to the present Pier closing so that there is a continuous service provided with the new Pier being built to the same or improved standards with regard to passenger amenities and services. Loss or removal of this provision would require consideration of a formal objection from the Mayor. Further discussions will be required with TfL regarding the design of the proposed new pier, the facilities to be provided and the proposed access arrangements for pedestrians. Additional capacity for more river services at this pier would be beneficial. Thames Water should be aware that TfL has a tenant within the existing pumphouse at Blackfriars Pier. Alternative accommodation for the tenant would need to be provided within the same vicinity. It may be possible to provide some office accommodation as part of the new pier facilities. It is noted that during the construction, vessels used to build the site may require anchors or ground mooring which could cause problems to the safe navigation of
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Appendix 1 Mayors Response to Thames Tunnel Consultation Phase 2

There were no construction routes identified for this site. It is noted that the low level sewer interception chamber will affect the A3211 The Embankment and there may be a clash with works required to Blackfriars Bridgehead structure (NW link from the bridge down onto the A3211). It is highlighted that procedures for the Technical Approval for Highway Structures outlined within the DMRB will be required alongside permissions from the City of London as CoL own below ground property and footways at this location. There is a potential interface with the London Underground Waterloo & City Line and District & Circle Line Tunnels and as such, further advanced detailed discussions on the intended work is advised. Ensure that the design of both the permanent and temporary works into the river does not cause unacceptable siltation, erosion or other hydrological impacts. This is a particular concern given the scale of the in-river works and the fact that this is a particularly sensitive location in terms of river hydraulics. Ensure impacts on historic embankment structure are minimised. Ensure that where the diversion of the Thames Path crosses major roads, the arrangements for pedestrian crossing are satisfactory. Ensure acceptable impacts on Listed Buildings and Structures and Conservation Areas Legacy The proposals indicate an improved Thames Path and imaginative public realm proposals on re-instatement. This is welcomed but needs to be subject to more detailed agreement, notably with City of London. There may also be opportunities to incorporate cycle facilities in the new area of public realm.

Appendix 1 Mayors Response to Thames Tunnel Consultation Phase 2

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Site Name Borough Purpose Construction Period Impacts Alternatives Changes since Phase 1 Conclusion

Druid Street no longer required Southwark CSO Connection n/a Thames Water have withdrawn this site as a construction site because changes to the sewer system at Shad Thames mean that the overflows are managed elsewhere. Site no longer proposed. The Mayor supports the removal of this site, as this was one of the sites from Phase 1 Consultation where the impacts of construction would have been hardest to manage and mitigate. 16 Shad Thames minor works Southwark Sewer alterations 1 years 1. Construction works adjacent to residential properties. 2. Vehicle access on narrow, primarily residential street. No alternative suggested. The site is an alternative to the Druid Street site from Phase 1 consultation New site The Mayor supports the sewer works that enable the removal of this site. The Mayor would wish to be re-assured as to the number of expected spills at this CSO as this is a site where the overflow is immediately in front of residential premises and into an area of residential barges. Thames Water will need to: The works are in close proximity to existing residential properties and high levels of sound/vibration protection will be required. Careful traffic management on the narrow local roads will need to be agreed with LB Southwark. The impact of construction vehicles using the adjacent TLRN A200 Jamaica Road will need to be assessed and discussed further with TfL.

Site Name Borough Purpose Construction Period Impacts Alternatives Changes since Phase 1 Conclusion

Appendix 1 Mayors Response to Thames Tunnel Consultation Phase 2

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Site Name Borough Purpose Construction Period Impacts

17 Chambers Wharf Southwark Main tunnel drive site to Abbey Mills, main tunnel reception site, from Kirtling Street and Greenwich connection tunnel reception site 6 years 1. Construction close to residential properties 2. Construction close to school 3. Construction into the River Thames 4. Traffic impact on TLRN (A200 Jamaica Road) 5. Delay in residential development of the site Chambers Wharf has been proposed as an alternative to the Kings Stairs Gardens site which is on a Greenfield site. In addition Chambers Wharf is able to make use of the river for transport. As such the selection of Chambers Wharf is supported. New site since Phase 1. The selection of Chambers Wharf is accepted in principle. However, a number of issues require further work. The Mayor is not satisfied that barges are being utilised to a reasonable maximum level at this site. This is a particular concern given that significant volumes of HGVs are identified as being required to access this site during this long construction period. Site access is proposed via relatively narrow roads, through a residential area and directly past Riverside Primary School on Bevington Street. It is also noted that 2 further schools are within 100m of the site they being St Josephs primary school on George Row and St Michaels college on Chamber St opposite the western edge of the site. Due to the heightened usage and vulnerability of pedestrians connected with these schools, safety of construction traffic will be of paramount importance and to reduce the impacts (congestion, air quality etc.) of these vehicles. The proposed noise enclosure should address most concerns in relation to noise at the site, however further details are required to ensure that this is satisfactory, especially given the close proximity of residential premises to the work site. The impact of construction vehicles using the adjacent TLRN A200 Jamaica Road will need to be assessed and discussed further with TfL.

Alternatives Changes since Phase 1 Conclusion

Legacy Thames Water need to ensure that the location and design of the ventilation plant should ensure that any noise/odour impacts on nearby residents are minimised. The proposals indicate that the design and layout of the completed works will enable residential development on the site, this is supported. The existing Thames Path goes around the site, but following completion of the works the Thames Path should be routed along the river front, with appropriate connections back inland. This does not appear to be illustrated at present. Consideration should also be given to the provision of cycle facilities at this site as part of an improved public realm.

Appendix 1 Mayors Response to Thames Tunnel Consultation Phase 2

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Site Name Borough Purpose Construction Period Impacts Alternatives Changes since Phase 1 Conclusion

Kings Stairs Gardens Southwark n/a

This site has been replaced by the Chambers Wharf proposal. No longer required The Mayor supports the use of Chambers Wharf rather than Kings Stairs Gardens as this would avoid impacts on an open Greenfield site, Chambers Wharf also has existing river frontage better suited to freight operations.

Appendix 1 Mayors Response to Thames Tunnel Consultation Phase 2

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Site Name Borough Purpose Construction Period Impacts

18 King Edward VII Memorial Park Foreshore Tower Hamlets CSO Connection 3 years 1. Construction in Thames Foreshore 2. Construction on part of park 3. Construction close to residential properties 4. Access to TLRN (The Highway A1203) via Glamis Road 5. Impact on local sailing club (Shadwell Basin Outdoor Activity Centre) 6. Avoidance or protection of nearby Rotherhithe Tunnel Four alternatives have been examined, in particular the potential of Heckford Street has been examined following suggestions from the local community. This alternative would require works in the park as well as the relocation of a number of local businesses at Heckford Street. It also significantly reduces the viability of using barges and introduces a greater length of tunnelling under land as opposed to river. The access road has been changed, the construction area reduced slightly. On balance the preferred option is considered the most appropriate, giving rise to the fewest impact. Thames Water need to: Ensure that construction impacts are minimised to an acceptable level. It is likely that 2.4m acoustic screens be recommended for site boundaries close to residential properties. Thames Water should also explore whether the construction activities can be moved slightly further west to reduce these impacts or whether a building enclosing the main works is required. Give further consideration to greater use of the river for transporting materials to and from this site during construction, to reduce the impacts (congestion, air quality etc.) of HGVs accessing the site. The gating and temporary closure of the Thames Path is acceptable in principle, however, good quality diversionary signage, pedestrian crossings, etc will need to be discussed further with TfL. Potential impacts on bus services and proposals to relocate bus stops in the vicinity of this site will require further discussion with TfL. Ensure suitable protection to the Rotherhithe Tunnel Ensure suitable relocation of the nearby Shadwell Basin sailing facilities Ensure that the design of both the permanent and temporary works into the river does not cause unacceptable siltation, erosion or other hydrological impacts Ensure that the location and design of the ventilation plant should ensure that any noise/odour impacts on nearby residents are minimised. Legacy The re-instatement of the park will increase the area of the park in this location which is recognised as being short of open space. The illustrative re-instatement diagrams are encouraging and Thames Water should continue to work to: Ensure good quality re-instatement of the park and public realm in consultation with LB Tower Hamlets and local communities, the Thames Path and the multi use sports area Ensure good quality re-instatement of sailing club facilities Investigate whether cycle facilities should be installed as part of the reinstatement Work with TfL, river operators and the LB Tower Hamlets to determine whether the re-instatement works should be designed to leave passenger, freight or recreational river facilities at the site.

Alternatives

Changes since Phase 1 Conclusion

Appendix 1 Mayors Response to Thames Tunnel Consultation Phase 2

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Site Name Borough Purpose Construction Period Impacts Alternatives Changes since Phase 1 Conclusion

19 Bekesbourne Street Tower Hamlets Sewer alterations 7 months Construction close to residential properties This proposal is an alternative to works at Butcher Row New site since Phase 1 The Mayor sees minimal differences in impact between this site and Butcher Row, with either option being acceptable provided that Thames Water: Ensure satisfactory highway management measures, particularly given that the street is narrow and shared between vehicles and pedestrians Ensure that construction impacts are minimised to an acceptable level. It is likely that 2.4m acoustic screens be recommended for site boundaries close to residential properties The location of the proposed electrical and control kiosk at the corner of Bekesbourne St and Ratcliffe Lane lies wholly within land owned by TfL, the current arrangement is not acceptable and will need to be adjusted with the agreement of TfL/DLR.

Site Name Borough Purpose Construction Period Impacts Alternatives Changes since Phase 1 Conclusion

Butcher Row Tower Hamlets n/a n/a The Bekesbourne Street proposal has removed the need for works at Butcher Row No longer required n/a

Appendix 1 Mayors Response to Thames Tunnel Consultation Phase 2

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Site Name Borough Purpose Construction Period Impacts Alternatives Changes since Phase 1 Conclusion

20 Earl Pumping Station Lewisham CSO Connection 4 years 1. Construction close to residential and commercial properties 2. Relocation of some local businesses Thames Water has not indicated any alternative sites, although it is noted that there were alternatives in the Phase 1 consultation. Site required for 4 years (previously 3), minor adjustments to site internal layout The preferred option appears to be acceptable, however Thames Water need to: Discuss and agree with TfL and local highway authorities the proposed diversionary routes so as to avoid the works proposed on Deptford Church St as far as possible. Give consideration to the opportunity to tranship materials to and from the site locally to the safeguarded Convoys Wharf, approximately 600m south east of the site. The fact that a Planning Application for the redevelopment of the Convoys Wharf area is acknowledged, the application includes the provision of a 2.6ha wharf for which the applicant is currently seeking wharf operators. This would have the benefit of avoiding directing additional HGVs onto Deptford Church St which will be affected by another construction site for this project. Ensure an acceptable minimum level of disruption to nearby residents. Given the proximity of the residential properties noise and vibration problems seem likely at this location Ensure that local businesses are suitably relocated Ensure that the location and design of the ventilation plant should ensure that any noise/odour impacts on nearby residents are minimised. Legacy Ensure that part of the site is suitable for redevelopment following completion of the works, this is indicated in the consultation material.

Appendix 1 Mayors Response to Thames Tunnel Consultation Phase 2

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Site Name Borough Purpose Construction Period Impacts

21 Deptford Church Street Greenwich CSO Connection 3 Years 1. Loss of open space 2. Construction close to school 3. Construction close to Grade 1 Listed Church 4. Disruption to A2209 Deptford Church Street 5. Disruption to local businesses 6. Relocation of bus stops This site has been proposed as an alternative to Borthwick Wharf. A further alternative has been suggested at Bronze Street. Alternative 2 is unlikely to be preferable as it is in close proximity to residential premises, the original Borthwick Wharf site was close to residential properties, with limited vehicle access and would involve a more costly foreshore site. New site since Phase 1. The preferred option is preferable to the alternatives and offers the prospect of an improved public space upon completion which should enhance this area which is in need of regeneration. However, the Mayor has significant concerns about the site and Thames Water will need to undertake further work to ensure that the site can be delivered in an acceptable way: Two way working must be retained on Deptford Church St. Deptford Church Street is an important local North-South route, which experiences significant volumes of traffic throughout the day and accommodates a busy bus route. The site works and site access proposals would require the use of significant existing highway space during the construction phase, including the use of the existing bus lanes. This will impact on highway capacity for bus services and other road users. 2-way traffic operation (with alternative diversionary route) on Deptford Church Street should be maintained at all times if possible rather than a one-way operation with diversion. The period of phase 3, during which the bus lanes on Deptford Church Street are removed, should be kept to an absolute minimum. The impact of these arrangements will need to be assessed (considering the impact of any pedestrian diversions requiring additional crossing movements) with appropriate traffic modelling tools and discussed with TfL. This should include assessing the impact on bus services using Deptford Church Street. Any traffic management arrangements will need to be discussed and agreed with TfL. Consideration should be given to the opportunity to tranship materials to and from the site locally to Convoys Wharf, approximately 600m north of the site. The fact that a Planning Application for the redevelopment of the Convoys Wharf area is acknowledged, the application includes the provision of a 2.6ha wharf for which the applicant is currently seeking wharf operators. To mitigate the impact on bus service frequency, journey times and journey time reliability both an enhanced service frequency (preferred) or a diversion of the route should be considered. The additional cost of any agreed mitigation measure would have to be met by the scheme promoter. Potential impact on bus services and proposals to relocate bus stops in the vicinity of this site will require further discussion with TfL. Any requirement to narrow carriageway widths on Deptford Church Street raises general safety issues, particularly for cyclists. Clearly this will need to be a key consideration in the design and assessment of proposals in this area. Mitigation measures to address this may be required. The impact of the proposed diversion of pedestrian routes on Deptford Church
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Alternatives

Changes since Phase 1 Conclusion

Appendix 1 Mayors Response to Thames Tunnel Consultation Phase 2

Ensure that any disruption to the school and church are minimised, consideration should be given to an enclosure building as is proposed at other sites. The proposal to enhance other public open space during the works is welcomed as the area is notably short of good quality open space. Legacy Thames Water should work with LB Lewisham, the school and Church to ensure that the re-instatement works result in a positive benefit to the local area and enhance the public realm. Borthwick Wharf Foreshore Greenwich no longer required n/a n/a Deptford Church Street has been suggested as an alternative No Longer required The Mayor accepts the use of a site at Deptford Church Street as it will have fewer impacts and has the ability to improve the public realm.

Site Name Borough Purpose Construction Period Impacts Alternatives Changes since Phase 1 Conclusion

Appendix 1 Mayors Response to Thames Tunnel Consultation Phase 2

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Site Name Borough Purpose Construction Period Impacts

22 Greenwich Pumping Station Greenwich CSO connection and drive site for the connecting tunnel to Chambers Wharf 5 years 1. Protection of National Rail and DLR viaducts 2. Works in or adjacent to the tidal Deptford creek 3. Recent planning permission for residential development in the vicinity 4. Scale of lorry movements There is no realistic alternative option to this site. The proposal is now to drive the Greenwich connection tunnel from this site, rather than to this site. This results in a longer period of construction now 5 years (previously 2 years) and a significant increase in construction activities. The preferred option is not acceptable to the Mayor due to the proximity of the drop shaft being too close to the DLR viaduct. DLRL has protection zone rights that both enable DLRL to access the protection zone area to maintain its railway and secondly protect the operation of the railway and the viaduct structure against interference/damage due to 3rd party activities. The protection zone rights extend to all the land and airspace 5 metres out from the face of the DLR viaduct both sides and the airspace under the viaduct. The airspace over the viaduct is in DLRLs freehold ownership. No crane oversailing or otherwise interference or entry into DLRLs airspace would be allowed. DLRL would require all activities to be fully regulated by way of 3rd party interface technical assurance and would most likely require the protection zone to remain clear, other than for construction plant passing beneath the viaduct (relative to the areas illustrated and coloured brown as Internal site road on TWULs consultation leaflet), but again in a regulated way, in particular height restrictions and physical protection to the DLR viaduct support columns. Referring to the site plans the areas coloured purple and noted as maintenance workshop and storage would need to be laid out so there are no buildings within the DLR protection zone, nor any obstructions to DLRL accessing the area for maintenance. DLRL would otherwise exercise its rights of access to its protection zone across TWULs land and the worksite to be maintained during the course of TWULs use. DLRL cannot be expected to suspend its access in favour of TWULs activities. Similar protection to the national Rail viaduct will also be required. If this issue can be resolved, Thames Water need to: Significant volumes of HGVs are identified as being required to access this site. It is also in close proximity to Greenwich Town Centre, is relatively constrained in size and has a number of access points. Although Deptford Creek serving the site is constrained by tidal flow, it presents potential beneficial opportunities for use of the nearby river/wharfs for transporting materials to and from this site during construction. The Mayor is not convinced that these opportunities have been fully explored. The scheme promoter must ensure that accessibility to DLRL concessionaires offices and operation and maintenance compound on the north side of Norman Road, directly opposite the TWUL worksite is maintained at all times. From this facility, our concessionaire for the Lewisham Extension (City Greenwich Railway Enterprises plc) manages the extension. Ensure acceptable minimal impacts on nearby residents, including any new residents as a result of recent planning permission(s). It is welcomed that the proposals include a building over the main shaft to reduce noise. Ensure that the location and design of the ventilation plant should ensure that any noise/odour impacts on nearby residents are minimised

Alternatives Changes since Phase 1 Conclusion

Appendix 1 Mayors Response to Thames Tunnel Consultation Phase 2

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Legacy Thames Water should examine opportunities to enhance river uses using any structures required for this project Site Name Borough Purpose Construction Period Impacts Alternatives Changes since Phase 1 Conclusion 23 Abbey Mills Pumping Station Newham Main Tunnel reception site and connection to the Lee Tunnel 4 years 1. Loss of open space 2. Impact on potential redevelopment/Olympic Legacy There are no realistic alternatives to this site. However, it is questioned whether the Lee Tunnel Shaft could be re-used for the removal of the Tunnel Boring Machine and other connection works. Site is now a reception site (previously a drive site). This has reduced the length of works and the scale of construction traffic. The preferred option is acceptable, however Thames Water need to: Explain why the Lee Tunnel Shaft cannot be used as the reception shaft instead of constructing a new shaft. It is noted that an option to use barges is identified, however, Thames Water do not appear to be supportive of this option. Ensure that the location and design of the ventilation plant minimises any noise/odour impacts on future development in this area. The current proposals appear to show a spread of permanent plant across a wide area, this should be rationalised where possible. 24 Beckton Sewage Treatment Works Newham Minor works 4 years These works are expected to have limited impacts, as they are within the existing Beckton Sewage Treatment Works. No alternatives have been identified Not clear, but not expected to be significant The extent of works are likely to be broadly acceptable, however Thames Water should ensure that: Any significant movement of construction materials/spoil away should be by barge from the site Any opportunities to further reduce odour nuisance should be taken.

Site Name Borough Purpose Construction Period Impacts Alternatives Changes since Phase 1 Conclusion

Site Name Other Works There are a number of other minor works that will be necessary to enable the project to proceed. These are not set out in any detail at present but will need to be assessed and any impacts/risk managed. Thames Water should set these out more clearly as the combined impact of so much construction activity needs to be examined together.

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Tunnel Alignment
The comments below relate to concerns TfL have with TfL structures and/or assets only. It should be noted by the scheme promoter that other structures which are traversed by the tunnel alignment and on which TfL services rely eg Network Rail owned Chelsea Rail Bridge or on which network capacity depends, will have specific approval procedures which must be adhered to which shall be advised by such other stakeholders but in which TfL may have an input. Tunnel Works Description Main Tunnel 6.5m 7.2m diameter, 25km long

a) Approximate Chainage 1080 of the Main Tunnel sited west of Stamford Brook Station the tunnel runs under the LU District and Piccadilly Line Tunnels; LU noted that this is being picked up within a separate impact assessment from the scheme promoter. b) Approximate Chainage 1670 of the Main Tunnel under and about Great West Road (A4) at British Grove; It is highlighted that procedures for the Technical Approval for Highway Structures outlined within the DMRB will be required. c) Approximate Chainage 5810 of the Main Tunnel under and about Putney Rail Bridge; LU notes that this is being picked up within a separate impact assessment from the scheme promoter. d) Approximate Chainage 9590 of the Main Tunnel under and about Battersea Bridge; It is highlighted that procedures for the Technical Approval for Highway Structures outlined within the DMRB will be required. e) Approximate Chainage 13000 of the Main Tunnel under the LU Victoria Line Tunnels; LU noted that this is being picked up within a separate impact assessment from the scheme promoter. f) Approximate Chainage 13065 of the Main Tunnel under and about Vauxhall Bridge; It is highlighted that procedures for the Technical Approval for Highway Structures outlined within the DMRB will be required. g) Approximate Chainage 13925 of the Main Tunnel under and about Lambeth Bridge; It is highlighted that procedures for the Technical Approval for Highway Structures outlined within the DMRB will be required. h) Approximate Chainage 14630 of the Main Tunnel under and about Westminster Bridge; It is highlighted that procedures for the Technical Approval for Highway Structures outlined within the DMRB will be required.

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i) Approximate Chainage 14700 of the Main Tunnel under the LU Jubilee Line Tunnels; LU noted that this is being picked up within a separate impact assessment from the scheme promoter. j) Approximate Chainage 15200 of the Main Tunnel under the LU Bakerloo Line Tunnels; LU noted that this is being picked up within a separate impact assessment from the scheme promoter. k) Approximate Chainage 15300 of the Main Tunnel under the LU Northern Line Tunnels; LU noted that this is being picked up within a separate impact assessment from the scheme promoter. l) Approximate Chainage 16390 of the Main Tunnel under and about Blackfriars Bridge; It is highlighted that procedures for the Technical Approval for Highway Structures outlined within the DMRB will be required although it is brought to the attention of the scheme promoter that the bridge is under the ownership of City of London and as such, procedures will be controlled by CoL. m) Approximate Chainage 16500 of the Main Tunnel under the LU Waterloo & City Line Tunnels; LU noted that this is being picked up within a separate impact assessment from the scheme promoter. n) Approximate Chainage 17780 of the Main Tunnel under and about London Bridge; It is highlighted that procedures for the Technical Approval for Highway Structures outlined within the DMRB will be required although it is brought to the attention of the scheme promoter that the bridge is under the ownership of City of London and as such, procedures will be controlled by CoL. o) Approximate Chainage 17800 of the Main Tunnel under the LU Northern Line Tunnels; LU noted that this is being picked up within a separate impact assessment from the scheme promoter. p) chj Approximate Chainage 18680 of the Main Tunnel under and about Tower Bridge; It is highlighted that procedures for the Technical Approval for Highway Structures outlined within the DMRB will be required although it is brought to the attention of the scheme promoter that the bridge is under the ownership of City of London and as such, procedures will be controlled by CoL. q) Approximate Chaniage 20390 of the Main Tunnel under and about Thames Tunnel Wapping to Rotherhithe.."ELL has a primary concern with this interface of prospective settlement. This will need to be picked up within a separate impact assessment from the scheme promoter r) Approximate Chainage 21100 of the Main Tunnel under and about Rotherhithe Tunnel (A101); It is highlighted that procedures for the Technical Approval for Highway Structures outlined within the DMRB will be required. s) Approximate Chainage 22140 of the Main Tunnel under and about Limehouse Link (A1203);
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It is highlighted that procedures for the Technical Approval for Highway Structures outlined within the DMRB will be required. t) Approximate Chainage 22200 of the Main Tunnel under and about the DLR in the vicinity of Westferry/Limehouse; DLR has a primary concern with this interface of prospective settlement (DLR is on a combination of Victorian brick viaduct and modern day concrete viaduct here). The land required for the tunnel where it passes under the DLR railway would also be of issue, as under the Victorian viaduct part, the subsoil is generally in DLRLs freehold ownership. Where modern day concrete viaduct, the subsoil is not generally in DLRLs freehold ownership, as in this circumstance, DLRL generally has a flying freehold. u) Approximate Chainage 22210 to 22235 of the Main Tunnel under and about the proposed alignment of Crossrail tunnels Detailed separate discussions with the Crossrail team have been ongoing and it is with this in mind that the scheme promoter is reminded to: i) Their commitment to carrying out the recommendations made in the Thames Tunnel Project Preliminary Impact Assessment Report Doc No. 315-RG-TPI-TU021-000001 Rev AE (specifically a monitoring and pre and post construction surveys), in the event that Thames Tunnel goes ahead as defined. Provide a signed Cat II check to Crossrail at the detailed design stage. Work with Crossrail to develop a construction interface management plan

ii) iii)

v) Approximate Chainage 22360 of the Main Tunnel under and about Commercial Road (A13); It is highlighted that procedures for the Technical Approval for Highway Structures outlined within the DMRB will be required. w) Approximate Chainage 22685 of the Main Tunnel under and about Burdett Road (A1205); It is highlighted that procedures for the Technical Approval for Highway Structures outlined within the DMRB will be required. x) Approximate Chainage 23740 of the Main Tunnel under and about the DLR in the vicinity south of Devons Road; DLRL has a primary concern with this interface of prospective settlement (DLR is on concrete viaduct here). The land required for the tunnel where it passes under the DLR railway would also be of issue, as the subsoil is in DLRLs freehold ownership. y) Approximate Chainage 24165 of the Main Tunnel under and about Blackwall Tunnel Northern Approach (A12); It is highlighted that procedures for the Technical Approval for Highway Structures outlined within the DMRB will be required.

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Tunnel Works Description

Frogmore Connection Tunnel 2.6m diameter, 1.1km long

a) Approximate Chainage 220 of the Frogmore Connection Tunnel under and about Armoury Way; It is highlighted that procedures for the Technical Approval for Highway Structures outlined within the DMRB will be required. b) Approximate Chainage 395 of the Frogmore Connection Tunnel under and about Wandsworth High Street; It is highlighted that procedures for the Technical Approval for Highway Structures outlined within the DMRB will be required. Tunnel Works Description Greenwich Connection Tunnel 5.0m diameter, 4.6km long

a) Approximate Chainage 320 of the Greenwich Connection Tunnel under and about Jamaica Road (A200); It is highlighted that procedures for the Technical Approval for Highway Structures outlined within the DMRB will be required. b) Approximate Chainage 350 of the Greenwich Connection Tunnel under the LU Jubilee Line Tunnels ; LU noted that this is being picked up within a separate impact assessment from the scheme promoter. c) Approximate Chainage 1700 of the Greenwich Connection Tunnel under and about East London Line; ELL has a primary concern with this interface of prospective settlement. This will need to be picked up within a separate impact assessment from the scheme promoter. d) Approximate Chainage 4450 of the Greenwich Connection Tunnel under and about East London Line viaduct; ELL has a primary concern with this interface of prospective settlement. This will need to be picked up within a separate impact assessment from the scheme promoter. e) Approximate Chainage 4590 of the Greenwich Connection Tunnel DLRL has a primary concern with this interface of prospective settlement (DLR is on modern day concrete viaduct here) concerned with the connection tunnel. The land required for the connection tunnel where it passes under the DLR railway is unlikely to be of issue, as where a modern day concrete viaduct as in this case, the subsoil is not generally in DLRLs freehold ownership, as in this circumstance, DLRL generally has a flying freehold. As referred to in the site specific comments above, the position of the drop shaft is too close to the DLR viaduct support columns and needs to be moved.

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