Report on Post Phase Two Consultation Compressed

7/30/2019 Report on Post Phase Two Consultation Compressed

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Report on post phase two consultation i

Thames Tideway Tunnel

Report on post phase two consultation

List of contents

Page number

1 Foreword ........................................................................................................... 1

2 Introduction ...................................................................................................... 2

2.1 The purpose of this report........................................................................ 2

2.2 The proposed project ............................................................................... 3

2.3 Route to consent ..................................................................................... 3

2.4 Pre-application consultation and engagement to date ............................. 4

2.5 Structure of this report ............................................................................. 5

3 Our approach to post phase two consultation .............................................. 7

3.1 Introduction .............................................................................................. 7

3.2 Consultation report .................................................................................. 8

3.3 Our consultation strategy ......................................................................... 8

3.4 Targeted consultation .............................................................................. 9

3.5 Section 42 consultation ......................................................................... 14

3.6 Responding to requests for information ................................................. 16

3.7 Access for all ......................................................................................... 16

3.8 Means of providing feedback ................................................................. 16

4 Method of analysis of feedback and development of our responses ........ 17

4.1 Consultation feedback ........................................................................... 17

4.2 Method of analysis ................................................................................. 17

4.3 Our responses ....................................................................................... 21

4.4 Presentation of our findings ................................................................... 21

5 Targeted consultation: Barn Elms ................................................................ 23

5.1 Introduction ............................................................................................ 23

5.2 Number of respondents ......................................................................... 24

5.3 Feedback in relation to the site access route......................................... 25

5.4 Feedback in relation to the PEIR Addendum......................................... 39

5.5 Our view of the way forward .................................................................. 40

6 Targeted consultation: Putney Embankment Foreshore ............................ 41

6.1 Introduction ............................................................................................ 41



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6.3 General comments ................................................................................ 43

6.6 Configuration of the temporary replacement slipway ............................. 60

6.8 Main construction site ............................................................................ 71

6.9 Permanent works ................................................................................... 76

6.10 PEIR Addendum.................................................................................... 88

6.11 Our view of the way forward .................................................................. 89

7 Targeted consultation: Albert Embankment Foreshore ............................. 91

7.1 Introduction ............................................................................................ 91


7.3 Construction traffic access route ........................................................... 93

7.4 PEIR Addendum.................................................................................. 101

7.5 Our view of the way forward ................................................................ 102

8 Targeted consultation: Victoria Embankment Foreshore ........................ 103

8.1 Introduction .......................................................................................... 103

8.2 Number of respondents ....................................................................... 104

8.3 Revised construction site layout and extent......................................... 105

8.4 Revised design .................................................................................... 107

8.5 Amended proposals for the Tattershall Castle ..................................... 116

8.6 PEIR Addendum.................................................................................. 118


9 Section 42 consultation: Modifications to site boundaries ...................... 120

9.1 Introduction .......................................................................................... 120


9.3 Project-wide comments in relation to modifications to site boundaries 121

9.4 Feedback in relation to Cremorne Wharf Depot .................................. 123

9.5 Feedback in relation to Chelsea Embankment Foreshore ................... 124

9.6 Non-site specific feedback ................................................................... 125


10 Section 42 consultation: Modifications to the tunnel alignment ............. 129

10.1 Introduction .......................................................................................... 129


10.3 Supportive and neutral comments ....................................................... 130

10.4 Objections, issues and concerns ......................................................... 130


11 Section 42 consultation: Ground water abstraction ................................. 139

11.1 Introduction .......................................................................................... 139



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Report on post phase two consultation iii

11.3 Potential effects of the project on ground water abstraction ................ 140

11.4 The preferred sites .............................................................................. 144

11.5 Tunnel route and alignment ................................................................. 164

11.6 Consultation process ........................................................................... 164


12 Other comments ........................................................................................... 168

12.1 Introduction .......................................................................................... 168


12.3 Feedback in relation to project-wide themes ....................................... 169

12.4 General other comments ..................................................................... 183

12.5 Feedback in relation to our preferred sites .......................................... 189


12.7 Feedback in relation to our approach to consultation .......................... 232

13 Conclusions and next steps ........................................................................ 240

13.1 Targeted consultation .......................................................................... 240

13.2 Section 42 consultation ....................................................................... 241

13.3 Next steps ............................................................................................ 242

Appendices ........................................................................................................... 243

Appendix A :Statutory consultees, local authorities and the GLA .................. 244

Appendix B : List of newspaper advertisements ............................................... 250

Appendix C : Means of invitation and copies of invitation letters ................... 251

Appendix D :Site notices ..................................................................................... 253

Appendix E : List of town halls and libraries where post phase two consultationinformation was available............................................................................ 254

Appendix F :Targeted consultation exhibitions ................................................. 257

Appendix G : Feedback forms ............................................................................. 258

Appendix H :Modifications to site boundaries ................................................... 260


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Report on post phase two consultation iv

List of tables

Page number

Table 4.1 Means of providing feedback .................................................................... 17

Table 4.2 Number of respondents by respondent group .......................................... 17

Table 5.1 Respondents to targeted consultation and Section 42 consultation inrespect of changes to the site boundary at Barn Elms............................. 24

Table 5.2 Statutory consultees and local authorities that responded to targetedconsultation and Section 42 consultation in respect of changes to the siteboundary at Barn Elms ............................................................................ 24

Table 5.3 Barn Elms: Supportive and neutral comments in relation to the site accessroute ........................................................................................................ 25

Table 5.4Barn Elms: Objections, issues and concerns in relation to the site access

route ........................................................................................................ 26

Table 5.5 Barn Elms: Supportive and neutral comments in relation to the PEIRAddendum ............................................................................................... 39

Table 6.1 Respondents to targeted consultation and Section 42 consultation inrespect of changes to the site boundaryat Putney Embankment Foreshore................................................................................................................. 42

Table 6.2 Statutory consultees and local authorities who responded to targetedconsultation and Section 42 consultation in respect of changes to the siteboundary at Putney Embankment Foreshore .......................................... 43

Table 6.3 Putney Embankment Foreshore: Supportive and neutral comments inrelation to general issues ......................................................................... 43

Table 6.4 Putney Embankment Foreshore: Objections, issues and concerns inrelation to site selection ........................................................................... 44

Table 6.5 Putney Embankment Foreshore: Objections, issues and concerns inrelation to general issues ......................................................................... 56

Table 6.6 Putney Embankment Foreshore: Supportive and neutral comments inrelation to the configuration of the temporary slipway .............................. 61

Table 6.7 Putney Embankment Foreshore: Objections, issues and concerns inrelation to the configuration of the temporary slipway ............................. 62

Table 6.8 Putney Embankment Foreshore: Supportive and neutral comments inrelation to the extent of the main construction site .................................. 71

Table 6.9 Putney Embankment Foreshore: Objections, issues and concerns inrelation to the extent of the main construction site .................................. 72

Table 6.10 Putney Embankment Foreshore: Supportive and neutral comments inrelation to the permanent design ............................................................. 76

Table 6.11 Putney Embankment Foreshore: Objections, issues and concerns inrelation to the permanent design ............................................................. 79

Table 6.12 Putney Embankment Foreshore: Supportive and neutral comments inrelation to the PEIR.................................................................................. 89


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Table 6.13 Putney Embankment Foreshore: Objections, issues and concerns inrelation to the PEIR .................................................................................. 89

Table 7.1 Respondents to targeted consultation and Section 42 consultation inrespect of changes to the site boundary at Albert Embankment Foreshore................................................................................................................. 92

Table 7.2 Statutory consultees and local authorities that responded to targetedconsultation and Section 42 consultation in respect of changes to the siteboundary at Albert Embankment Foreshore ............................................ 92

Table 7.3 Albert Embankment Foreshore: Supportive and neutral comments inrelation to the construction traffic access route ........................................ 93

Table 7.4 Albert Embankment Foreshore: Objections, issues and concerns in relationto the construction traffic access route .................................................... 93

Table 7.5 Albert Embankment Foreshore: Supportive and neutral comments inrelation to the Albert Embankment Foreshore PEIR Addendum........... 101

Table 8.1 Respondents to targeted consultation and Section 42 consultation inrespect of changes to the site boundary at Victoria EmbankmentForeshore .............................................................................................. 104

Table 8.2 Statutory consultees and local authorities that responded to targetedconsultation and Section 42 consultation in respect of changes to the siteboundaryat Victoria Embankment Foreshore ........................................ 105

Table 8.3 Victoria Embankment Foreshore: Supportive and neutral comments inrelation to the revised site construction design and layout ..................... 105

Table 8.4 Victoria Embankment Foreshore: Objections, issues and concerns in

relation to the revised site construction design and layout ..................... 106

Table 8.5 Victoria Embankment Foreshore: Supportive and neutral comments inrelation to the revised design ................................................................. 107

Table 8.6 Victoria Embankment Foreshore: Objections, issues and concerns inrelation to the revised design ................................................................. 108

Table 8.7 Victoria Embankment Foreshore: Supportive and neutral comments inrelation to the amended proposals for the Tattershall Castle ................. 116

Table 8.8 Victoria Embankment Foreshore: Objections, issues and concerns inrelation to the amended proposals for the Tattershall Castle ................. 116

Table 8.9 Victoria Embankment Foreshore: Objections, issues and concerns inrelation to the Victoria Embankment Foreshore PEIR Addendum ......... 118

Table 9.1 Respondents to Section 42consultation on modifications to site boundaries............................................................................................................... 121

Table 9.2 Statutory consultees and local authorities who provided feedback inrelation to modifications to site boundaries ............................................ 121

Table 9.3 Objections, issues and concerns in relation to project-wide modifications tosite boundaries ...................................................................................... 122

Table 9.4 Supportive and neutral comments in relation to modifications to the siteboundary at Cremorne Wharf Depot ..................................................... 123


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Report on post phase two consultation vi

Table 9.5 Objections, issues and concerns in relation to modifications to the siteboundary at Cremorne Wharf Depot ...................................................... 123

Table 9.6 Supportive and neutral comments in relation to modifications to the siteboundary at Chelsea Embankment Foreshore ...................................... 124

Table 9.7 Objections, issues and concerns in relation to modifications to the siteboundary at Chelsea Embankment Foreshore ..................................... 125

Table 9.8 Non site-specific supportive and neutral comments in relation tomodifications to site boundaries............................................................. 125

Table 9.9 Non site-specific objections, issues and concerns in relation tomodifications to site boundaries............................................................. 125

Table 10.1 Respondents to Section 42 consultation in relation to modifications thetunnel alignment .................................................................................... 130

Table 10.2 Objections, issues and concerns in relation to modifications to the tunnel

alignment ............................................................................................... 130Table 11.1 Respondents to the ground water abstraction consultation .................. 140

Table 11.2 Supportive and neutral comments in relation to the potential effects of theproject on ground water abstraction ...................................................... 140

Table 11.3 Objections, issues and concerns in relation to the potential effects of theproject on ground water abstraction ...................................................... 141

Table 11.4 Supportive and neutral comments in relation to the preferred sites ...... 144

Table 11.5 Objections, issues and concerns in relation to the preferred sites ........ 146

Table 11.6 Supportive and neutral comments in relation to the tunnel route andalignment ............................................................................................... 164

Table 11.7 Supportive and neutral comments in relation to the consultation process............................................................................................................... 165

Table 11.8 Objections, issues and concerns in relation to the consultation process............................................................................................................... 166

Table 12.1 Respondents that provided other comments at post phase twoconsultation ........................................................................................... 169

Table 12.2 Statutory consultees and local authorities that provided other commentsat post phase two consultation.............................................................. 169

Table 12.3 Feedback in relation to project-wide themes ........................................ 170

Table 12.4 Other general comments ...................................................................... 183

Table 12.5 Feedback in relation to our preferred sites ........................................... 189

Table 12.6 Feedback in relation to our approach to consultation ........................... 233


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Report on post phase two consultation vii

List of abbreviations

CCS Community Consultation Strategy

CoCP Code of Construction Practice

CSO combined sewer overflowDCO Development Consent Order

GLA Greater London Authority

HGV heavy goods vehicle

PLA Port of London Authority

SOCC Statement of Community Consultation

SuDS Sustainable Drainage Systems

TfL Transport for London


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1 Foreword

Report on post phase two consultation 1

1 Foreword

Thank you to all those who responded to our post phase two consultation held from6 June until 4 July 2012. This report is the fourth of its kind, and it contains responsesto the feedback we received in response to targeted consultation on alternativedesign solutions at four of our proposed sites, and Section 42 consultation on groundwater abstraction licences and on various changes to site boundaries and thealignment of the main tunnel.

During our post phase two consultation, we focussed on specific areas of ourproposals and received further helpful feedback. We are grateful to all those whoalso contacted us in relation to the matters we sought views on and with furtherquestions and comments about other sites.

We have listened to your views and taken some difficult decisions to get to the pointwhere the proposals are being finalised. We are always very grateful whenindividuals or organisations take the time to write to us or visit the project team atexhibitions where we have the opportunity to share with you our plans and discussthe project in detail.

The views and information received as part of this consultation, and our earlier phasetwo consultation, enabled us to finalise our proposed sites and publish our plans aspart of our Section 48 publicity (16 July to 5 October 2012).

The next step, following Section 48 publicity, is for us to submit the application fordevelopment consent for the project to the Planning Inspectorate, which we aim to doin early 2013. This means that our proposals will be examined in detail by a panel ofindependent, specialist planning inspectors who will make a recommendation on theproject as a whole to the appropriate Secretaries of State.

Please contact us if you have any questions.

Phil Stride Richard AylardHead of the External AffairsThames Tideway and Sustainability DirectorTunnel project


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2 Introduction


2 Introduction

2.1 The purpose of this report

2.1.1 This report is a record of the consultation that was carried out in relation tothe Thames Tideway Tunnel project (the project) after phase twoconsultation and before the proposed application for development consent(the application) was publicised under Section 48 of the Planning Act2008 (as amended by the Localism Act 2011) (the 2008 Act).

2.1.2 This additional consultation was completed in accordance with Section 42and Section 47 of the 2008 Act, including ourStatement of CommunityConsultation (SOCC) published on 4 November 2011. OurSOCCrecognised that we may need to amend our proposals after commencingphase two consultation and stated that we would consider whether any

necessary changes would affect the nature of the comments received atphase two consultation, and (where appropriate) undertake targetedconsultation.

2.1.3 The following additional consultation was undertaken between 6 June2012 and 4 July 2012:

a. consultation with relevant local communities and other categories ofconsultees on potential changes to our proposals for four specificsites, namely Putney Embankment Foreshore, Barn Elms, AlbertEmbankment Foreshore and Victoria Embankment Foreshore

b. consultation with landowners on minor modifications to the proposedboundaries of our preferred sites and minor changes to the proposedalignment of the tunnels

c. consultation with landowners of properties benefiting from groundwater abstraction licences whom we identified that may be affected bythe project.

2.1.4 This consultation described in para. 2.1.3 a) above is referred to in thisreport as targeted consultation. The consultation described in points b)and c) is referred to in this report as Section 42 consultation.

2.1.5 The Section 42 consultation on the proposed changes to site boundaries

and tunnel alignments (para. 2.1.3 b) above) was undertaken withstatutory consultees and with all newly affected landowners. We formedthe view that these changes were minor in nature and did not necessitateconsultation with the local community, further to the SOCC

2.1.6 The Section 42 consultation on ground water abstraction (para. 2.1.3 c)above) was undertaken with landowners further to Section 42(1) (d) of the2008 Act. We carried out technical assessment work that established thatthe project may affect the ability of landowners who hold abstractionlicences to abstract water or operate ground source heat pumps. As itwas only the landowners who would be affected by this, we did not consult

the local community further to ourSOCCor the other Section 42 statutoryconsultees.


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2 Introduction


2.1.7 This report describes the post phase two consultation undertaken as partof our multi-stage pre-application process. This report describes why andhow we carried out our post phase two consultation activities. It sets outthe feedback received and our responses. This report also describes thenext steps for the project.

2.2 The proposed project

Project context

2.2.1 At present, untreated sewage mixed with rainwater (combined sewage)regularly overflows into the River Thames from Londons Victoriansewerage system via combined sewer overflows (CSOs).

2.2.2 Combined sewage discharges must be reduced in order to comply withrelevant wastewater legislation. The UK Government is obliged to meetthe requirements of the EU Urban Waste Water Treatment Directive

(UWWTD) and the Water Framework Directive. Thames Water must meetthe requirements of the Urban Waste Water Treatment Regulations 1994and the Water Environment (Water Framework Directive) (England andWales) Regulations 2003, which transpose the UWWTD into English law.

2.2.3 Solutions to the problem of wastewater discharges into the tidal reaches ofthe River Thames have been under examination for more than ten years.The project has been determined to be the most technologically-soundand cost-effective means of controlling CSO discharges and satisfyingregulatory requirements. This has been confirmed by independent studiesand by Thames Water.

The proposed solution

2.2.4 The project would control CSO discharges by intercepting and divertingcombined sewage flows into a new storage and transfer tunnel. The tunnelwould run from Acton Storm Tanks in west London to Abbey MillsPumping Station in the east, where it would connect to the Lee Tunnel,which would transfer the flows to Beckton Sewage Treatment Works fortreatment.

2.2.5 The new infrastructure would protect the tidal Thames from increasingpollution for at least the next 100 years. The current assumption is that

main construction would commence in 2016 and be completed by 2023.

2.3 Route to consent

2.3.1 On 23 June 2012, the Infrastructure Planning (Waste Water Transfer andStorage) Order 2012 came into force. This Order was made by theSecretary of State under powers conferred by Section 14(3) and (4) of the2008 Act. The effect of the Order was to create a new category ofNationally Significant Infrastructure Project (NSIP) for the purposes of the2008 Act, covering infrastructure for the transfer or storage or waste water.The project falls within this new category of NSIP.


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2.3.2 Article 3 of the Order contains the following supplementary provision:

(1) For the purpose of any requirement of any provision specified inparagraph (2), where a project is a nationally significant infrastructureproject, by virtue of the amendments made by article 2 of this Order, theSecretary of State may treat anything done before the date on which this

Order comes into force as compliance with that requirement, if it wouldhave complied with that requirement had it been done after that date.

(2) The provisions referred to in paragraph (1) are any provision of

(a) section 2 of Part 5 of the Act;

(b) the Infrastructure Planning (Environmental Impact Assessment)Regulations 2009; or

(c) the Infrastructure Planning (Application: Prescribed Forms andProcedure) Regulations 2009.

2.3.3 This supplementary provision enables the Secretary of State

1

to treat pre-application activities carried out before 23 June 2012 (the date on whichthe Order came into force) as having complied with the specified statutoryrequirements, if those activities would have complied with the relevantrequirements had they been undertaken after 23 June 2012.

2.3.4 The Order came into force after we had commenced our post phase twoconsultation. However, anticipating that the project would be decidedunder the 2008 Act, we carried out this stage of the pre-applicationconsultation in accordance with the requirements of Chapter 2 of Part 5 ofthe 2008 Act, and relevant secondary legislation, as if such had applied.We also had regard to associated published guidance and advice.

2.4 Pre-application consultation and engagement todate

2.4.1 The overriding aim of our public consultation process is to provide allconsultees with the opportunity to influence our proposals, in accordancewith the requirements of the 2008 Act. Prior to our post phase twoconsultation, we undertook other consultation and engagement activities,which are summarised as follows:

d. Prior to phase one consultation, we consulted with local authoritiesand statutory consultees on our consultation strategy.

e. At the start of phase one consultation (13 September 2010), wepublished the SOCC, which set out our consultation strategy, in theLondon Evening Standard.

f. We undertook phase one consultation between 13 September 2010and 14 January 2011.

1In this case, the Secretaries of State for the Department for Communities and Local Government and the

Department for Environment, Food and Rural Affairs will act as joint decision maker.


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2 Introduction


g. OurReport on phase one consultation was published in March 2011;this report sets out the feedback received and our responses,including how the feedback influenced the design of the project.

h. Following phase one consultation, we identified possible alternativesites and uses to those presented at phase one consultation. Between

11 March 2011 and 11 October 2011, we held interim engagementevents to seek comments on our alternative proposals.

i. We had regard to comments received at interim engagement whendetermining our preferred sites for phase two consultation. Thefeedback from interim engagement and the projects responses are setout in the Interim engagement reportand the Interim engagementaddendum.

j. We also re-consulted with local authorities and statutory consultees onour revised draft SOCCbetween 15 June 2011 and 18 July 2011.Details are set out in ourLocal authority and stakeholder consultationfeedback report on the draft Statement of Community Consultationand accompanying draft Community Consultation Strategy, which waspublished in summer 2011.

k. At the start of phase two consultation (4 November 2011), wepublished ourSOCC, which set out our revised consultation strategy,in the London Evening Standard. We held our phase two consultationbetween 4 November 2011 and 10 February 2012.

l. We published ourReport on phase two consultation in May 2012; thisreportsets out the feedback received and our responses, and how thefeedback influenced the design of the project.

2.4.2 Post phase two consultation commenced on 6 June 2012 and closed on4 July 2012.

2.5 Structure of this report

2.5.1 This report is structured as follows:

a. Section 3 sets out our approach to post phase two consultation anddetails how we carried out targeted consultation and Section 42consultation.

b. Section4 explains our method for analysing the feedback from postphase two consultation and describes:

i how we analysed the feedback

ii how we responded to the feedback

iii how the method of analysis and structure of this report reflects therequirements of the 2008 Act and relevant guidance and advice.

c. Sections 5 to 8 set out the feedback received in relation to thetargeted consultation on the proposed amendments at Barn Elms,Putney Embankment Foreshore, Albert Embankment Foreshore and

Victoria Embankment Foreshore.


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2 Introduction


d. Section 9 sets out the feedback received in relation to the Section 42consultation on modifications to the boundaries of our preferred sites.

e. Section 10 sets out the feedback received in relation to the Section 42consultation on modifications to the tunnel alignment.

f. Sections 9 and 10 each set out:i details of the respondents and whether any responded late

ii the feedback received

iii our response to the feedback

iv our view of the way forward and how the proposals are likely tochange as a result of the feedback.

g. Section 11 sets out the feedback received in relation to the Section 42consultation on ground water abstraction, including:

i details of the respondents and whether any responded lateii the feedback received

iii our response to the feedback

iv our view of the way forward and how the proposals are likely tochange as a result of the feedback.

h. Section 12 sets out the feedback received at post phase twoconsultation that did not relate to the proposed amendments and ourresponses to this feedback.

i. Section 13 sets out our conclusions from the post phase two

consultation including key findings, any changes under considerationand further investigations/assessments that will be carried out as aresult of the consultation. It also provides a summary of our nextsteps.

2.5.2 The appendices provide further information in relation to how we prepared,publicised and carried out the post phase two consultation.

2.5.3 This Report on post phase two consultation will inform the ConsultationReportthat is required under Section 37 of the 2008 Act and willaccompany our application for development consent. We had regard tothe guidance and advice notes2 produced by the Department for

Communities and Local Government (DCLG) and the PlanningInspectorate in preparing this report.

2DCLG (2009) Planning Act 2008, Guidance on pre-application consultation;Planning Inspectorate

(2012)Advicenote fourteen: Compiling the consultation report; Planning Inspectorate (2012)Advice note sixteen:The developers pre-application consultation, publicity and notification duties; DCLG Guidance on pre-application

process: consultation (April 2012).


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3 Our approach to post phase two consultation



3.1 Introduction

3.1.1 We have carried out the public consultation for the project having regard tothe DCLGs Guidance on pre-application consultation(September 2009),which states that:

effective public consultation is an important aspect of the development ofmajor projects prior to the submission for planning approval. The earlyinvolvement of local communities, local authorities and statutoryconsultees at this stage can bring about significant benefits for all parties,such as:

a. allowing members of the public to influence the way projects are

developed by providing feedback on potential options, and providingthem with an opportunity to shape the way in which their communitydevelops

b. helping local people better understand what a particular projectmeans for them so that concerns resulting from misunderstandings areresolved early

c. obtaining important information about the economic, social andenvironmental impacts of a project from consultees, thus helpingpromoters identify project options which are unsuitable and not worthdeveloping further

d. enabling potential mitigation measures to be considered and, in somecases, built into the project before an application is submitted

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

Overall, effective pre-application consultation will lead to applicationswhich are better developed, and in which the important issues have beenarticulated and considered as far as possible in advance of submission tothe consent-granting bodies.3

3.1.2 It is important to recognise that the design of the project is driven by the

engineering requirements to intercept CSOs and connect them to the maintunnel at fixed locations. For this reason, the main tunnel route and thelocation of the worksites are more constrained than other types ofinfrastructure projects.

3.1.3 The overriding aim of our pre-application consultation is to inform statutoryconsultees, local authorities, landowners and the community about theproject and to provide them with opportunities to influence the proposals.

3.1.4 We provided information on why site boundaries had changed at allaffected sites and along all tunnel routes; a PEIR Addendum report, aDesign development report Addendum, supplementary site information

3DCLG (2009) Planning Act 2008, Guidance on pre-application consultation


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papers and a book of plans for the four targeted consultation sites; and aconsultation project information paper explaining why we were undertakingadditional consultation.

3.2 Consultation report

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

3.2.2 Section 37(7) states:

in subsection (3) (c) the consultation report means a report giving detailsof

(a) what has been done in compliance with sections 42, 47 and 48 inrelation to a proposed application that has become the application,

(b) any relevant responses, and

(c) the account taken of any relevant responses.

3.2.3 This report is a record of the post phase two consultation only. Details ofall other consultation activities and publicity undertaken for the project willbe set out in the Consultation Reportthat will be submitted with ourapplication.

3.2.4 The Consultation Reportwill contain sections that address the consultationand engagement activities undertaken with statutory consultees, localauthorities, landowners and community consultees since 2008. Thesection on post phase two consultation will be informed by this report,which will be provided in an appendix to the Consultation Report.

3.3 Our consultation strategy

3.3.1 The SOCCand Community Consultation Strategy (CCS) set out ourproposed approach to and strategy for consultation. The SOCCand CCSwere subject to three rounds of consultation with local authorities andstatutory consultees. Full details of these consultations are provided inSection 2.3 of ourMain report on phase two consultation. The SOCCinrespect of phase two consultation was published on 4 November 2011,consistent with Section 47(6) of the 2008 Act.

3.3.2 The SOCCstates:

We may need to amend our scheme after the commencement of ourphase two consultation. Should this be necessary, we would consider on asite by site basis whether our changes would affect the nature of thecomments received from the public at phase two consultation, and whereappropriate undertake further targeted consultation. This would comprisepublic exhibitions and provision of project information, and would be for aperiod of not less than 28 days. We would also give 14 days noticethrough the publishing of local adverts and provision of information on ourwebsite.


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3.3.3 Targeted consultation on the proposed amendments at Barn Elms, PutneyEmbankment Foreshore, Albert Embankment Foreshore and VictoriaEmbankment Foreshore was undertaken further to the SOCC.

3.3.4 We considered the degree of changes, the potential effects on the localcommunity and the likely level of public interest as guiding factors in

determining whether further consultation was necessary under the termsof the SOCC. We consider that this approach is consistent with theguidance provided in para. 78 of the DCLGs Guidance on pre-applicationconsultation (2009) and paras. 53 and 54 of the DCLGs draft Guidance onpre-application process: consultation (April 2012).

3.4 Targeted consultation

What we consulted on

3.4.1 We undertook targeted consultation on the following matters:

a. Putney Embankment Foreshore: re-locating the site further away fromPutney Bridge and the existing draw dock

b. Barn Elms: a proposed new access route along Queen Elizabeth Walkinstead of the previously proposed temporary route alongsideBeverley Brook

c. Albert Embankment Foreshore: a proposed alternative constructionaccess route

d. Victoria Embankment Foreshore: a proposed new design for thepermanent works.

Whom we consulted

3.4.2 In accordance with Sections 42 and 47 of the 2008 Act and ourSOCC, weconsulted the following groups:

a. all statutory consultees, including the Marine ManagementOrganisation and the Greater London Authority (GLA) (see paragraph3.4.3)

b. relevant local authorities, including potentially directly affected localauthorities and adjacent local authorities

c. landowners (see para.3.4.6)d. community consultees, including the general public, local property

owners/occupiers, local businesses, community representatives, andcommunity groups, including hard-to-reach groups.

Statutory consultees

3.4.3 Section 42(1) (a) of the 2008 Act requires applicants to consult certainprescribed persons on their proposals. Regulation 3 of the InfrastructurePlanning (Applications: Prescribed Forms and Procedure) Regulations2009 provides that, for the purposes of Section 42(1)(a), the prescribedpersons are those listed in Schedule 1 of the regulations, who must beconsulted in specified circumstances. We undertook targeted consultationwith the prescribed persons (referred to in this document as statutory


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consultees) listed in Appendix A. We also consulted the MarineManagement Organisation in accordance with Section 42(1) (aa), and theGLA, pursuant to Section 42(1) (c) of the 2008 Act. The GLA is includedas a statutory consultee in this report. It should be noted that the GLAsconsultation response also contained feedback on behalf of Transport for

London (TfL).Local authorities

3.4.4 Section 42(1) (b) of the 2008 Act states that local authorities that fall withinSection 43 must be consulted. This includes local authorities within whoseareas the proposed development is located and neighbouring localauthorities. We consulted the 14 London borough councils within whoseareas the project as a whole falls, the neighbouring London boroughcouncils and the Common Council of the City of London. In view of thestrategic nature of the project, we also consulted the remaining 19 Londonborough councils and other councils that border London. A list of the local

authorities consulted is provided in Appendix A.

Landowners

3.4.5 Section 42(1) (d) of the 2008 Act states that each person who falls withinone or more of the categories set out in Section 44 of that Act must beconsulted by project promoters. Section 44 sets out three categories ofpersons that must be identified and consulted as follows:

a. Category 1: If the promoter, after making diligent inquiry, knows thatthe person is an owner, lessee, tenant (whatever the tenancy period)or occupier of land required for the development.

b. Category 2: If the promoter, after making diligent inquiry, knows thatthe person (a) is interested in the land, or (b) has power to i) sell andconvey the land or ii) to release the land.

c. Category 3: If the promoter, after making diligent inquiry, believes that,if the Development Consent Order (DCO) for the project were to bemade and fully implemented, the person would or might be entitled a)as a result of implementing of the order, b) as a result of the orderhaving been implemented or c) as a result of use of the land once theorder has been implemented, to make a relevant claim. A relevantclaim includes a claim under Section 10 of the Compulsory Purchase

Act 1965 for injurious affection arising from the construction of thedevelopment or a claim under Part 1 of the Land Compensation Act1973 for depreciation in value of a property interest arising from theoperation of the development.

3.4.6 At targeted consultation, we consulted every person who falls within oneor more of the Section 44 categories. These persons are collectivelyreferred to as landowners for the purposes of this report.

3.4.7 All three categories of persons were identified in our extensive landreferencing exercise, which was carried out on all properties potentiallyaffected by the project.


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Community consultees

3.4.8 Under Section 47 of the 2008 Act, applicants must consult the localcommunity in the vicinity of the project. Consultation must be carried out inaccordance with the proposed approach set out in the SOCC. Ourdefinition of community consultees includes ward councillors, local MPs

and MEPs, and other community representatives, individuals ororganisations that formally or informally represent local interests including,but not limited to:

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

b. individuals, owners/occupiers, businesses and groups based, or living,further away but that have, or represent, an interest in a given site

c. local people who live near, use or overlook a given site

d. local environmental groups

e. voluntary organisations (including residents associations and blackand minority ethnic support groups)

f. faith communities

g. schools and colleges in the immediate vicinity

h. local hospitals, care homes and private healthcare organisations in theimmediate vicinity.

3.4.9 We carried out community audits prior to commencing phase one andphase two consultations in order to identify all the groups listed above that

have a potential interest in the project. We also liaised with localauthorities to identify additional community groups.

3.4.10 In order to define the areas around each site in which to notify people ofphase two consultation directly in writing, we set a minimum distance ofapproximately 250m from the site boundary and a broad corridor along thepreferred tunnel route. The boundary was applied flexibly according to thescale and nature of the proposed works, having regard to thecharacteristics of the surrounding area. The publicity methods weemployed are detailed below.

3.4.11 When developing ourSOCC, we consulted with local authorities to ensure

that the consultation boundaries were appropriate.

How we undertook the consultation

3.4.12 We carried out the targeted consultation in accordance with ourSOCC,which states that targeted consultation would last for a period of not lessthan 28 days. Targeted consultation was in fact open for a period of 29days between 6 June 2012 and 4 July 2012 (inclusive).

3.4.13 This section sets out how we publicised and carried out the targetedconsultation.

Publicity

3.4.14 We publicised our targeted consultation in a range of media and publicawareness initiatives.


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Advertisements

3.4.15 In accordance with ourSOCC, advertisements were placed in localnewspapers to inform readers of the nature of the changes at the relevantsites and to advise the specific exhibition dates. The advertisements wereplaced a minimum of 14 days prior to the start of targeted consultation.

The publications and advertisement dates are provided in Appendix B.

Letters

3.4.16 A total of 11,874 letters containing information on the project were postedto consultees via Royal Mail on 6 June 2012: 256 letters were sent tostatutory consultees, 55 to local authorities, 1,712 to landowners and9,851 to community consultees. The letter set out relevant details for eachsite in relation to the scope of the targeted consultation, the planned drop-in exhibitions, and the means of providing feedback. Copies of the letterssent to each respondent group are provided in Appendix C.

Site notices and leaflets3.4.17 We also posted site notices in the vicinity of each of the four targeted

consultation sites 14 days prior to the start of targeted consultation. Thenotices set out the proposed changes to our proposals and details of thelocal drop-in exhibitions, and advised where to find more information andhow to provide feedback. Where agreed with the local authority, the sitenotices also provided details of the language line. A copy of the sitenotices and details of where they were displayed is provided inAppendix D.

Press release

3.4.18 We issued a press release publicising our proposals on 17 May 2012.

Consultation website

3.4.19 The project has its own dedicated consultation website, which providesinformation on the project and the targeted consultation. The websiteformed a dedicated point for respondents to leave feedback. Paperfeedback forms were also provided at the drop-in exhibitions and onrequest.

3.4.20 Our website sought to meet best practice standards of accessibility andusability. It provided electronic versions of all the information published for

targeted consultation that was distributed at the drop-in exhibitions.3.4.21 The website remains a live resource, and all materials from targeted

consultation and previous consultation and engagement activities areavailable to view. We will continue to update the website with otherpublications, including Section 48 publicity material, prior to thesubmission of the application.

Provision of written information

3.4.22 We provided a range of both technical and non-technical writteninformation, which was available online. We also produced a Targetedconsultation project information paper, which provided an overview of thetargeted consultation.


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3.4.23 Supplementary site information papers were produced for the fourtargeted consultation sites, which contained the following:

a. an overview of the changes under consideration at each site

b. activities that would be undertaken at each phase of construction

c. the potential effects of our construction works and how we propose toaddress them

d. the potential effects of our operational works and how we propose toaddress them (at Putney Embankment Foreshore and VictoriaEmbankment Foreshore only)

e. illustrations of the proposed permanent structures and details of theissues that influenced the design (at Putney Embankment Foreshoreand Victoria Embankment Foreshore only).

3.4.24 Other documents prepared for targeted consultation were also made

available to the public at the drop-in exhibitions and on the website,including:

a. Design development report Addendum

b. PEIR Addendum to Volume 9: Barn Elms

c. PEIR Addendum to Volume 19: Putney Embankment Foreshore

d. PEIR Addendum to Volume 19: Albert Embankment Foreshore

e. PEIR Addendum to Volume 20: Victoria Embankment Foreshore

f. Book of plans

g. Targeted consultation drop-in exhibitions leaflet.

3.4.25 Documentation from earlier phases of consultation and other projectdocuments were also made available on our website to allow consulteesto compare the proposed changes with the earlier scheme.

3.4.26 The project information papers, supplementary site information papers,feedback forms and posters were made available at local libraries and onrequest. A full list of locations at which reference information was madeavailable is provided in Appendix E.

Programme of drop-in public exhibitions

3.4.27 As stated in ourSOCC, we held public drop-in exhibitions in the vicinity ofthe four targeted consultation sites, which were advertised locally inadvance (see paras. 3.4.15 and 3.4.17). The exhibitions were open for twoconsecutive days in each location, between 2pm and 8pm. Members ofthe project team (including representatives from the planning,environment, community, property and engineering disciplines) werepresent to answer questions, assist with interpreting materials orcompleting feedback forms, and encourage consultees to have a say.

3.4.28 A list of all drop-in exhibitions, including the venues, opening hours andthe number of visitors is provided in Appendix F.

3.4.29 At each exhibition we displayed information to inform visitors about theproject and the local worksite(s). The information was consistent with the


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project information papers and supplementary site information papers, andinformation on our website. We also provided information from the phasetwo consultation exhibitions to illustrate the proposed changes to thoseproposals.

3.4.30 Members of the public were encouraged to use our website to register

their comments; however, paper feedback forms were also made availableat the exhibitions. Where requested, respondents were given support to fillin the feedback form.

3.5 Section 42 consultation

What we consulted on

3.5.1 We undertook Section 42 consultation on the following matters:

a. Tunnel alignment: minor changes to the proposed limits of deviation of

the main tunnel.b. Minor changes to the limits of land to be acquired or used to construct

and operate the project at all sites.

c. Ground water abstraction: as a result of further technical design work,we determined that our proposals could have an effect on the ability ofcertain persons to abstract water or operate ground source heatpumps.

Whom we consulted

3.5.2 We consulted the following persons :

a. In relation to changes to site boundaries, we consulted statutoryconsultees and every person who, as a result of the boundarychanges proposed now fell within one or more of the Section 44categories described in para. 3.4.5 above (ie, new landowners). Wealso re-consulted all previously consulted persons where the proposedchanges would result in a greater effect than previously anticipated.

b. In relation to tunnel alignment modifications, we consulted statutoryconsultees and each person who, as a result of the changesproposed, now fell within one or more of the Section 44 categories asdescribed in para. 3.4.5 above (ie, new landowners). We also re-

consulted all previously consulted persons where the proposedchanges would result in a greater effect than previously anticipated.

c. In relation to ground water abstraction issues, we consultedlandowners (as defined in Section 42(1) (d)) of property with thebenefit of ground water abstraction licences whom we determined maybe affected by the project. We consulted these persons on the basisthat they fell within Category 3 under Section 44 since they might havea relevant claim due to the potential effects of the project on theirability to abstract ground water or operate a ground source heat pump.

3.5.3 The Section 42 consultation on changes to site boundaries and

modifications to the limits of deviation of the main tunnel was undertakenwith landowners newly affected by the project and any previously


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consulted landowners who would potentially experience greater effects asa result of the changes. We did not re-consult other landowners consultedat phase two consultation where the effects on their land would notmaterially change as result of the proposed changes. We considered thatfurther consultation with such landowners on the proposed changes was

not necessary on the basis that the changes were so minor that theirresponses to the consultation exercise would not be affected. Havingregard to the minor nature of the changes, we also formed the view thatconsultation with statutory consultees under Section 42(1) and the localcommunity further to the SOCC under Section 47 was not necessary.

3.5.4 The Section 42 consultation on groundwater abstraction issues wasundertaken only with landowners whose property benefitted from theability to abstract groundwater under an abstraction licence and would bepotentially affected by the project. We did not consider it necessary toconsult other persons about these matters.

How we undertook the consultation

3.5.5 We undertook our Section 42 consultation having regard to para. 78 of theDCLGs Guidance on pre-application consultation (2009) and para. 54 ofthe DCLGs draft Guidance on pre-application process: consultation (April2012), which state that additional consultation must cover a period not lessthan 28 days. The Section 42 consultation was open for a period of29 days between 6 June 2012 and 4 July 2012 (inclusive).

3.5.6 This section sets out how we publicised and carried out the Section 42consultation.

Publicity3.5.7 A total of 3,142letters containing information on the project were posted to

landowners via Royal Mail on 6 June 2012. The letter set out relevantdetails for each site in relation to the scope of the consultation, and meansof providing feedback. It also highlighted that more detailed information onthe project was available on the projects consultation website.

3.5.8 The 2,014 letters sent to ground water consultees advised them that thedewatering required to ensure safe construction of the tunnel might havean effect on their rights to use groundwater. It also provided a dedicatedpoint of contact for any queries and details of exhibitions attended by

members of the project team. Copies of the letters sent are provided inAppendix C.

Consultation website

3.5.9 The consultation website provided information on the project and details ofthe Section 42 consultation. For further information on the consultationwebsite, refer to paras.3.4.19 to 3.4.21.

Provision of written information

3.5.10 We provided written information on the changes to the site boundaries andtunnel alignments, which was available online, in the Book of plans and in

the Tunnel alignment overview sheet.


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3.5.11 Documentation from earlier phases of consultation and other projectdocuments were also made available on our website to allow consulteesto compare the proposed changes with the earlier scheme.

3.6 Responding to requests for information

3.6.1 We responded to individual written queries and phone calls at post phasetwo consultation. Our Customer Centre handled over 348 phone calls and50 written queries in addition to the written feedback forms andcorrespondence received.

3.7 Access for all

3.7.1 We sought to ensure that all consultees could respond to the consultationand offered a range of solutions for those who required additionalassistance. For example, consultation information was available in large

print, braille and audio format on request. Our Customer Centre offered atelephone service to translate consultation materials into any language onrequest. This service was not requested during post phase twoconsultation.

3.7.2 We reviewed the Customer Centres database to identify consultees in thepost phase two consultation who might require special services. No suchconsultees were identified.

3.7.3 We carried out a health and safety audit of the potential exhibition venuesfor post phase two consultation to strike a suitable balance betweenaccessibility of the buildings and proximity to the residents wishing toattend. All the exhibition locations used were deemed accessible.Members of the project team were in attendance to facilitate access andassist the public.

3.8 Means of providing feedback

3.8.1 Feedback was primarily provided by means of feedback forms, which wereavailable online and in hard copy. We provided one feedback form for thetargeted consultation and Section 42 consultation on changes to siteboundaries and tunnels alignments. We produced a separate feedback

form for the Section 42 ground water abstraction consultation. Copies ofthese feedback forms are provided in Appendix G. We also receivedcorrespondence, which was processed in the same way as the feedbackforms.


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4 Method of analysis of feedback and development of our responses


4 Method of analysis of feedback anddevelopment of our responses

4.1 Consultation feedback4.1.1 A total of 139 respondents provided feedback to the post phase two

consultation, of which 12 responded after the close of the consultationperiod. We analysed and considered their responses nonetheless (seepara. 4.2.12).

4.1.2 Table 4.1 and Table 4.2 provide a breakdown of the feedback receivedduring the consultation period.

Table 4.1 Means of providing feedback

Means of feedback Number of respondentsFeedback form (online and hard copy) 85

Correspondence 50

Petitions 2

Table 4.2 Number of respondents by respondent group

Consultee type Number of respondents

Statutory consultees 8

Local authority 4

Landowners 21

Community consultees 104*

* The respondents defined as community consultees under Section 47 of the 2008 Act (with theexception of two) were identified from those who identified themselves as local residents,organisation in Question 2 of the targeted consultation and Section 42 consultation feedback form.

Two community consultees responded using the groundwater consultation feedback form; see para.4.2.3 for our definition of community consultees. A copy of the feedback forms is provided in

Appendix G.

4.2 Method of analysis

4.2.1 We received feedback by various different means including online/hardcopy feedback forms and correspondence such as letters, emails andpetitions. This section sets out our approach to analysing the feedbackreceived.

Feedback forms

4.2.2 We received feedback forms online via our website and in hard copy.

Logging of feedback forms

4.2.3 Before analysing the content of the feedback forms, we took the followingsteps:


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a. Each feedback form was logged and given a unique referencenumber. Respondents who submitted their feedback forms online wereassigned a unique 13 digit reference code. For the purposes of thisreport, we used unique five digit ID numbers.

b. The online system enabled respondents to submit feedback forms as

many times as they wished. In order to ensure that our analysis wasnot skewed by multiple submissions from a single respondent, allfeedback received from one respondent was allocated the same IDnumber. Our analysis was based on the number of respondents ratherthan the amount of feedback submitted by any particular respondentor group.

c. The Consultation Reportthat must accompany our application fordevelopment consent will detail the feedback from each group ofrespondent (Section 42 of the 2008 Act) and from the community(Section 47 of that Act). The targeted consultation and Section 42

consultation feedback form requested respondents to state thecapacity in which they responded. Respondents were assigned to agroup as follows:

i statutory consultees: respondents listed in Appendix A

ii local authority: respondents listed in Appendix A

iii landowners: respondents on the list of identified landowners weverified the status of respondents who identified themselves aslandowners, but if respondents did not identify themselves assuch, we did not carry out any verification checks

iv community consultees: respondents who selected the localresident/organisation groups and respondents who did not fall intoany of the three groups above

v other: respondents who selected other were re-assigned to oneof the four groups above in accordance with the categories set outin the 2008 Act. Respondents who selected this group werechecked against the list in Appendix A and the results of our landreferencing exercise and designated as a statutory consultee,local authority or landowner if there was a positive match. Wherethere was no positive match, respondents were designated as

community consultees.d. In order to understand how respondents to the groundwater

consultation might be affected by the project, they were asked to statetheir capacity on the feedback form as follows:

i an owner, lessee or occupier of a premises that enjoys the benefitof ground water abstraction

ii a person who uses such premises or is otherwise interested inthem

iii an agent acting on behalf of a person in the above categories.

e. We followed the same process for logging feedback as for targetedconsultation and the Section 42 consultation.


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Analysis of feedback received

4.2.4 The targeted consultation and Section 42 consultation feedback formcomprised three questions. The first two questions requested respondentsdetails and the capacity in which they responded. The third soughtfeedback on the proposed site-specific changes and the modifications to

site boundaries and the tunnel alignment.

4.2.5 The ground water abstraction feedback form was divided into two parts.The first part requested respondents details and the capacity in whichthey responded, and sought comments on the projects potential to affectground water abstraction during the construction period. The second partof the form comprised a slightly modified version of the phase twoconsultation feedback form to afford this group of consultees theopportunity to provide full comments on both strategic and specificelements of the project. Copies of both feedback forms are provided inAppendix G.

4.2.6 We broadly analysed the feedback against the questions in the feedbackforms, except where it was clear that comments under a particularquestion in fact related to another question on the forms. This enabled usto analyse comments of a similar nature together.

4.2.7 In order to ensure consistency with the approach we adopted for previousphases of consultation, we classified feedback according to a number ofthemes, such as transport and access. The comments were alsocategorised as supportive and neutral comments, or objections, issuesand concerns.

4.2.8 The unique ID numbers for each respondent (recorded with everycomment) enabled us systematically to identify where the same commentwas made by more than one respondent and thereby determine thevolume of feedback received under each theme. We sought to takeaccount of all responses, whether or not they were in the minority.

Correspondence

4.2.9 In addition to the feedback forms, we also received consultation responsesin writing (by email and post) for both targeted consultation and Section 42consultation. As with the feedback forms, we carried out the followingsteps before analysing the content of the correspondence:

a. All correspondence was assigned a unique ID number.

b. We checked whether the respondent had previously submittedfeedback. If they had, the correspondence was assigned the same IDnumber as the first submission.

c. We logged the capacity of the respondent (see para. 4.2.3).

d. We analysed the correspondence against the questions on thefeedback form. The following points should be noted:

i On the feedback form, respondents were asked to state their viewon certain questions by means of tick boxes. Where respondentsdid not expressly identify a view that matched the options set outin each question, no view was assigned.


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ii Feedback that did not respond to any of the questions in thefeedback form was classified as other comments.

4.2.10 Having completed these steps, we followed the same process as for thefeedback forms to identify themes within the feedback.

Petitions4.2.11 We received two signed petitions expressing views on our proposals at

targeted consultation and Section 42 consultation. The process foranalysing petitions was the same as for correspondence. In this report,petitions are discussed alongside community consultees and are countedas one petition response. The number of signatories is provided.Petitions were assigned an ID number with the suffix PET.

Late responses

4.2.12 Any feedback received after the close of post phase two consultation at

5pm on 4 July 2012 was categorised as a late response. Any feedbacksubmitted between the close of consultation and 13 July 2012 was alsoconsidered and categorised as a late response. This approach follows pre-application consultation guidance provided by the DCLG.

4.2.13 Depending on the form in which the late responses were received, theywere analysed according to the processes set out above. In addition tounique ID numbers, they were assigned the prefix LR (late response).The number of late respondents is indicated at the start of each section ofthis report.

Cross checks

4.2.14 In accordance with Planning InspectorateAdvice Note Fourteen (April2012) we implemented safeguards to ensure that the comments weregrouped appropriately. Firstly, we categorised the comments assupportive or neutral, objections, issues or concerns or mitigation,suggestions or alternative solutions and then assigned them to a topicsub-theme, such as heritage or transport and access. We also compiled alist of anticipated comments that could be adapted as necessary. We thenfollowed a series of processes to ensure that similar feedback was dealtwith in a consistent manner. The processes included:

a. The sub-themes were assigned to members of the analysis team, whothen analysed all the feedback on that theme.

b. Where our existing sub-themes did not accurately summarise thefeedback received, we adapted them as necessary.

c. We created new sub-themes for any new points raised by respondentsthat were not on our list of anticipated comments.

d. We adapted our anticipated comments to include specific detailsraised by respondents. For example, the anticipated comment: shoulduse/consider an alternative site was updated to include detailedfeedback in relation to Putney Embankment Foreshore as: should

use/consider an alternative site that would cause less nuisance toresidential properties.


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4.2.15 A team member who was not directly involved in the analysis of thecomments then reviewed samples of the feedback allocated to the othermembers of the analysis team to check that these processes werefollowed correctly.

4.3 Our responses4.3.1 Having completed the process of logging and categorisation, we reviewed

all the feedback, having regard to engineering, planning, environment, andproperty and community considerations. We then considered how thefeedback might influence the development of the project.

4.3.2 Sections 5 to 12 set out how we propose to address the feedbackreceived. Where our proposals remain the same as presented at postphase two consultation, we have provided appropriate justifications.

4.4 Presentation of our findings

4.4.1 In producing this report we had regard to advice relating to the content ofthe consultation report required under Section 37(3) (c) of the 2008 Actpublished by the Planning Inspectorate and guidance from the DCLG. Wewill also prepare a full consultation report in due course, which willaccompany our application for development consent.

4.4.2 We had regard to paras. 94 to 102 of the DCLGs Guidance on pre-application consultation (September 2009). The Planning InspectoratesAdvice note fourteen: Compiling the consultation report(April 2012) alsoprovides guidance on how to present feedback in the consultation report.

4.4.3 At the start of each section of this report (5 to 12), we have indicated theform in which feedback was received (feedback form, correspondenceetc,) and the number of respondents in each group (statutory consultees,local authorities, landowners, community consultees and petitions). Thefeedback for each site is grouped by theme in order to aid navigation andreduce repetition. The respondent groups(s) that submitted eachfeedback comment are identified in the appropriate table.

4.4.4 In each section, we set out the feedback received in tables, together withour response to every comment. Firstly, we address the supportive andneutral comments followed by the objections, issues and concerns. Eachsection ends with a sub-section entitled Our view of the way forward,

which summarises our overall response to the feedback received. Whereappropriate, we state any changes that are under consideration.

4.4.5 In Sections 5 to 8, and 11 to 12, each table containing the objections,issues and concerns includes a final column entitled C (change). In thiscolumn, we indicate whether the feedback led to a change or no change,as defined below:

a. C: In response to the feedback received, we are considering or nowpropose a change (including mitigation)4 to our phase two

4

Mitigation here refers to a wide range of measures set out in our phase two and targeted consultation proposalsincluding, for example, the Code of construction practice and other documents, as well as the mitigationmeasures set out in the PEIR Addendum and our Section 48 publicity materials.


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consultation, targeted consultation and Section 42 consultationproposals.

b. N: We do not propose to change our proposals.

c. N/A: Any feedback that did not relate to sites, route, design, form or

scale of the scheme. The Planning InspectoratesAdvice notefourteen (April 2012) states that feedback should relate to at least oneof these categories.

4.4.6 We adapted this approach from that recommended for the consultationreport in the Planning Inspectorates Advice note fourteen (April 2012),which suggests classifying issues according to whether they directlyresulted in a change, mitigation or no change. In this report, we only statewhether feedback led to a change or no change. We did not includemitigation as a separate category. We consider that the distinctionbetween change and mitigation' is often artificial because in many caseschanges are proposed in order to mitigate effects identified byrespondents.

4.4.7 Following the close of post phase two consultation and before publicisingour proposals in accordance with the requirements of Section 48 of the2008 Act, we reviewed all of the feedback received to determine whetherany changes to our preferred scheme were required. On 16 July 2012, wecommenced our Section 48 publicity. As this report was published afterthe start of Section 48 publicity, we note (where appropriate) where furtherinformation is available in our Section 48 publicity materials.


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5 Targeted consultation: Barn Elms



5.1 Introduction

Our proposal

5.1.1 We still propose to use the southeastern corner of the sports field of the Barn Elms Schools Sports Centre for ourconstruction works and to accommodate the permanent structures required to operate the main tunnel. The site would beused to connect the existing local CSO, known as the West Putney Storm Relief CSO, to the main tunnel.

5.1.2 At phase two consultation, we proposed that construction traffic would access the site via a temporary access road alongthe northern side of the Beverley Brook watercourse. In response to feedback from phase two consultation, we nowpropose that construction traffic would access the site from Upper Richmond Road (A205), travel along Rocks Lane(A306) and turn right into Queen Elizabeth Walk. For further information on our amended proposals for this site attargeted consultation, refer to the Barn Elms supplementary site information paper.

Structure of this section

5.1.3 This section sets out targeted consultation feedback in relation to the proposed amendments at Barn Elms, together withSection 42 consultation feedback in respect of changes to the site boundary. Feedback that related to Barn Elms, but notto the proposed amendments at this site at targeted consultation, is outlined in Section12: Other comments.

5.1.4 This section is organised as follows to reflect the scope of targeted consultation:

a. Section 5.2: Number of respondents

b. Section 5.3: Site access route

c. Section 5.4:PEIR Addendum

d. Section 5.5: Our view of the way forward.

5.1.5 In Sections 5.3 to 5.4we detail the groups and total number of respondents, the comments received and the projectsresponse.


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5.2 Number of respondents

5.2.1 A total of 38 respondents provided feedback in relation to Barn Elms at targeted consultation and Section 42 consultationin respect of changes to the site boundary, of which two responded after consultation had closed. The number ofrespondents in each group is set out in Table 5.1.

Table 5.1 Respondents to targeted consultation and Section 42 consultation in respect of changes to the site boundaryat Barn Elms

Respondent group Number of respondents

Statutory consultees (SC) 2

Local authorities (LA) 1

Landowners (LO) 4

Community consultees (CC) 31

Petitions (PET) 0

5.2.2 Table 5.2 sets out the statutory consultees and local authorities that provided feedback for this site.

Table 5.2 Statutory consultees and local authorities that responded to targeted consultation and Section 42consultation in respect of changes to the site boundary at Barn Elms

Statutory consultees Local authorities

English Heritage (EH) London Borough of Wandsworth (LBW)

Transport for London (TfL)

5.2.3 Feedback in relation to this site was received in a number of forms, including feedback forms and correspondence(emails and letters).


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5.3 Feedback in relation to the site access route

5.3.1 This section sets out feedback in relation to the proposed construction site access route at Barn Elms. The supportiveand neutral comments are provided in Table 5.3 and the objections, issues and concerns in Table 5.4. The commentsare grouped by theme, as denoted by the sub-headings shaded in orange.

Supportive and neutral comments

Table 5.3 Barn Elms: Supportive and neutral comments in relation to the site access route

Ref Supportive and neutral comments Total/ID number Our response

5.3.2 Proposals would not affect wildlife. 1 14038 Your comment is noted and welcomed.

5.3.3 Proposals would not affect the enjoyment of theopen space.

1 14038 Your comment is noted and welcomed.

5.3.4 Proposals would not affect sporting activities atthe Barn Elms Schools Sports Centre.

1 14127LO Your comment is noted and welcomed.

5.3.5 Proposals would be less intrusive on thegreenfield site.


5.3.6 Support for the proposed access route asQueen Elizabeth Walk is already an establishedthoroughfare.

9 14004, 14024,14028, 14033,14038, 14106,14114, 14115,14119

Your comments are noted and welcomed.

5.3.7 Support for the proposals subject to resolution of

detailed matters including:a. Thames Water should provide new,

permanent changing rooms that should beopen before carrying out works

b. minimal disruption to the playing pitchesduring construction and in the long term.

1 LBW Your comments are noted. As detailed in ourPEIR

Addendum (Volume 9, Section 2.3), alternative changingrooms and track and field facilities would be provided withinthe Barn Elms Schools Sports Centre grounds prior todemolition. If the proposed changes are taken forward, theexact location of the new changing rooms would be agreedwith the London Borough of Wandsworth, which owns thesite, and the London Borough of Richmond, which is thelocal planning authority. It is likely that new changing rooms


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Ref Supportive and neutral comments Total/ID number Our response

would be provided in close proximity to the existingfacilities.

We can confirm that the replacement facilities will beincluded in the application.

5.3.8 The proposed access route is an improvementon the proposals presented at phase twoconsultation. Support retaining this route as thepermanent route following construction. Note the

London Borough of Wandsworth would considerremoving the existing route that runs across theplaying field area.

3 LBW, 14011,14108

Your comments are noted and welcomed.

5.3.9 Proposals would be less disruptive to localtraffic.


5.3.10 Queen Elizabeth Walk is suitable for heavyconstruction traffic.


5.3.11 Reassured by the limited number of constructionvehicles expected (16 movements per day).


Objections, issues and concerns

Table 5.4Barn Elms: Objections, issues and concerns in relation to the site access route

Ref Objections, issues and concerns Total/ID number Our response C

Natural environment (terrestrial)5.3.12 Proposals would result in the loss of trees

including:

a. period lime trees

b. several mature conifers.

4 CABE, LBW,

14060, 14062

The proposed access route that was presented attargeted consultation would require trees along thealignment of the construction access road to bepruned or removed. The two lime trees that would beremoved are young and there are no plans to removethe mature conifers on-site.

The phase two consultation proposals made provision

N

5.3.13 Ensure that tree protection measures are put in 1 LBW N


35/334



Ref Objections, issues and concerns Total/ID number Our response C

place, including for the trees in the vicinity of theboathouse.

to remove and prune mature trees near BeverleyBrook and the highway access point on Rocks Lane.In the targeted consultation proposals, fewer maturetrees near Beverley Brook by the main constructionsite and along the northern and eastern perimeters ofthe Barn Elms Schools Sports Centre would beremoved.

Our draft CoCP(Section 11.6) sets out how we wouldprotect existing trees during construction. Measuressuch as protective fencing and prohibition of storingmaterial in the protected area would be implemented,as specified in British Standard BS5837, wherepracticable and in consultation with the LondonBorough of Richmond upon Thames tree officer.

5.3.14 Concerns regarding possible effects on thenatural environment included:

a. the proximity to the WWT London WetlandCentre's wildlife and habitats

b. the potential effect on protected species ofbats.

2 14127LO,

14107

The PEIR Addendum (Volume 9, Section 4.3) statesthat as the main construction site would lie at adistance from the WWT London Wetland Centre Siteof Special Scientific Interest (SSSI), the onl

Report on Post Phase Two Consultation Compressed

Documents

Transcript of Report on Post Phase Two Consultation Compressed