Response to the Save Your Riverside 3 March 2014 submissionDoc Ref: APP198.34

Folder 249 11 March 2014DCO-DT-APP-ZZ100-983400

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Thames Tideway Tunnel Thames Water Utilities Limited

Application for Development ConsentApplication Reference Number: WWO10001

Response to submission by Save Your Riverside

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1 Response to submission by Save Your Riverside

1.1 Introduction

1.1.1 This document provides a response to the written submissions from Save Your Riverside (SYR), submitted to the Examining Authority (ExA) on 3 March 2014. The submission largely includes matters raised in SYR’s previous submission (12 February 2014) which have been addressed in our response to the 3 March 2014 submission (Doc ref: APP168) to the ExA.

1.1.2 A response is provided to points where clarification is required or to signpost where matters are addressed in other documents.

1.2 River Transport Strategy

1.2.1 At the development consent order (DCO) issue specific hearing on 21 February 2014, we made submissions in response to questions from the ExA and other parties on the National Policy Statement for Waste Water (the ‘NPS’) review.

1.2.2 Since the hearing, we have reviewed the proposals and removed the NPS review process from the River Transport Strategy. A final version of the strategy (Doc ref: APP207.02) was submitted on 11 March 2014, which includes removal of the NPS review.

1.3 Environmental Statement update report

Downings Road Moorings

1.3.1 With respect to the points raised by SYR regarding Downings Road Moorings, additional baseline noise monitoring was carried out to confirm the assumptions in the Environmental Statement. Taking this information into account, the Environmental Statement update report (Doc ref: APP208.01.26) confirms that noise and vibration effects on Downing’s Road Moorings would not be significant. Our response to request for information question 57.16 (Doc ref: APP167) and Appendix E to the Written summary of the cases put orally at the hearings held on 20 February 2014 (Doc ref: APP157) also confirm that there would be no significant effects at the moorings due to underwater noise from river vessels associated with the Thames Tideway Tunnel project (the ‘project’).

Residual noise effects

1.3.2 See our responses below regarding mitigation eligibility and acceptability of Chambers Wharf as a main tunnel drive site.

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1.4 Mitigation and compensation policy

1.4.1 Our revised documents submitted on 3 and 11 March 2014 address the concerns raised by SYR. In relation to the matters raised in para. 15 of SYR’s submission, the Independent Compensation Panel (ICP) will be appointed by the undertaker but, as detailed within Schedule 3, Part 1 1(e) of the Legal Agreement for securing Noise Mitigation and Compensation Policies (Doc ref: APP182), the undertaker will consult with the relevant local authority regarding the proposed appointment and take account of any written representations received concerning the appointment of the Chair. The legal agreement makes clear that the panel is independent from Thames Water.

1.4.2 The revised Non-statutory Off-site Mitigation and Compensation Policy (Doc ref: APP210, 11 March 2014) has been amended with regards to the point raised in para. 16 of SYR’s submission. The ICP will only consist of independent experts and not Thames Water or the contractors (para. 2.3.2). However, under para. 2.3.3, the ICP may call upon other specialists as the chairperson deems necessary, which may include Thames Water or its contractors.

1.4.3 Our response to request for information question 57.13 (Doc ref: APP167) addresses the issues raised by SYR in para. 17 of its submission. See also the Written summary of the cases put orally at the hearings held on 20 February 2014 (Doc ref: APP157).

1.4.4 In relation to the compensation policies (para. 18), the role of the Independent Complaints Commission (ICC) is limited as stated. Its role is to ensure that processes are followed.

1.4.5 The revised Exceptional Hardship Procedure (Doc ref: APP189, 3 March 2014) has been amended to address the issue raised by SYR in para. 19. The text in para. 4.1.5 now reads a “pressing need” and the ‘no prior knowledge criteria’ in para. 6.5.1 now reads “provided the property was acquired prior to 27 March 2013 (the date the application for development consent was accepted) you will meet this criterion” to address the issue raised in para. 20.

1.4.6 In relation to the comments on valuation (para. 21), the Exceptional Hardship Procedure (Doc ref: APP189, para. 7.4.3) was amended to provide for a third valuation; should the two required valuations be more than ten per cent apart, the outlier will be discarded from the process.

1.5 Noise and vibration

Compliance with the NPS

1.5.1 We have set out in oral submissions how the Draft DCO complies with NPS noise policy, particularly NPS para. 4.9.9 (Doc ref: APP102.03, Appendix B and Doc ref: APP157, Appendix A).

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Draft Luna House trigger action plan

1.5.2 See Appendix A for the latest update to the draft Luna House trigger action plan (TAP). The latest draft TAP responds to the queries raised by SYR in written and oral submissions and follows further engagement with SYR over the last week.

Practicality and end result of secondary glazing at Luna House

1.5.3 The updated draft TAP for Luna House confirms that noise insulation can be installed to all eligible rooms with windows on the east and north façades of the building, and will be installed if accepted by the residents.

1.5.4 The more detailed proposals in the latest draft TAP confirm that wherever windows can be opened, they would continue to be operable with the insulation installed. This means that residents would be able to open windows, as they do now, during the vast majority of the construction period where on-site mitigation would minimise adverse noise effects and hence avoid significant effects during the evening and night, and for all but four months in the daytime (during site set-up).

1.5.5 We note again that the elevated daytime noise levels at Luna House and Axis Court are only over a four-month period due to daytime works only, due to site set-up. This is very similar to the increased noise accepted by the London Borough of Southwark when it granted planning permission to residential development at the Chambers Wharf site (Doc refs: APP31.02 and APP102.04). With our scheme, off-site mitigation is offered and, if accepted, will be provided to avoid the significant observed adverse noise effects.

Mitigation and eligibility

1.5.6 We disagree that development of mitigation measures has been rushed. Detailed mitigation proposals are substantially more advanced on the project than other benchmark projects at the equivalent planning stage.

1.5.7 The Environmental Statement took account of substantial incorporated mitigation. Over the course of the examination, we have committed to additional specific on-site mitigation:

a. as set out in the Code of Construction Practice (CoCP) Part B for Chambers Wharf (Doc ref: APP178.35) and

b. the ‘not environmentally worse than’ (NEWT) commitment in the CoCP Part A (Doc ref: APP205.01, Section 2.1) and the Environmental Statement Update Report (Doc refs: APP208.01 and APP208.01.26) which take into account the additional mitigation in the CoCP.

These measures provide substantial additional protection for all receptors around Chambers Wharf.

1.5.8 We have committed to provide off-site noise mitigation at receptors where residual significant effects are predicted, without waiting for noise levels to be confirmed in the contractor’s detailed construction method (Doc refs: APP209.05 and APP209.03). Para. 3.2.2 of the Non-statutory Off-site Mitigation and Compensation Policy (Doc ref: APP210.01) confirms this commitment.

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1.5.9 Off-site mitigation is not required at other receptors because they are protected from becoming significantly affected by the ‘NEWT’ commitment (see our response to question 53.1, Doc ref: APP163). We set out why the trigger values adopted are appropriate and consistent with the relevant British Standard, government noise policy and precedent in Doc ref: APP157, Section 3.2 and Appendix A, and Doc ref: APP187.

1.5.10 Off-site mitigation would avoid the remaining significant observed adverse noise effects at Chambers Wharf and minimise any residual adverse noise effect as far as practicable (Doc ref: APP210.01). This is secured by the legal agreement and associated Section 106 unilateral undertaking (Doc refs: APP209.05, APP209.03 and APP119.14).

1.5.11 The performance of the mitigation to be provided is secured by internal noise levels now defined in the Non-statutory Off-site Mitigation and Compensation Policy, the legal agreement and associated Section 106 unilateral undertaking (Doc refs: APP209.05, APP209.03 and APP119.14).

1.5.12 We believe that the foregoing provide the security and certainty required to enable the Examining Authority to give full weight to this mitigation that meets in full the three aims of NPS para. 4.9.9. The third aim would be met by the legacy benefit of the off-site mitigation, which would reduce exposure to existing and future noise, particularly from the forthcoming residential development at Chambers Wharf.

1.5.13 As stated in our oral submissions to the hearings, we have actively engaged with SYR and continue to do so to develop and agree the Luna House trigger action plan, which will detail the mitigation to be provided. We discussed the mitigation proposals in the TAP to give confidence to residents and the ExA that off-site mitigation solutions in a modern building such as Luna House (for rooms on both the east and north façades) are practicable. The mitigation is still being developed, but the latest draft TAP (in Appendix A) makes clear that providing insulation is feasible.

Underestimation of impacts on local residents

1.5.14 We have not underestimated any impacts of the project at this site on local residents. We have set out why our assessment method is appropriate, consistent with the relevant British Standard (BS5228-1:2014) and government noise policy, and best practice (Doc ref: APP157, Section 3.2).

1.5.15 The engagement, information and support processes secured under the CoCP and Non-statutory Off-site Mitigation and Compensation Policy place the onus on the undertaker, employer and contractor, and are intended to reduce the impact on local residents associated with the works, including the provision of off-site mitigation.

Draft DCO falls short of the required assessment of impacts

1.5.16 The Draft DCO does not fall short of the required assessments. The assessment of impacts and significant effects as presented in the Environmental Statement and Environmental Statement Update Report

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(Doc ref: APP208) is robust, complete and in line with government policy. We confirmed the robustness of the assessment and compliance with NPS noise policy in submissions at the hearings (Doc refs: APP102.03, APP115.01 and APP157).

Effective mitigation is not practicable

1.5.17 The latest draft of the Luna House TAP demonstrates that effective mitigation is practicable and we have actively engaged with SYR as part of developing the draft TAP that responds to all the matters which have been raised.

1.5.18 The mitigation (predominantly sound insulation) would ensure that noise levels inside properties (both on the east and north façades of Luna House) would meet the guidance in the relevant British Standard (BS8233:2014) and would still be ‘reasonable’ (as defined by the Standard), even during the four noisiest months during site set-up (daytime works only).

Unacceptability of Chambers Wharf as a main tunnel drive site

1.5.19 The updated Environmental Statement (Doc ref: APP208.01.26) confirms that taking account of the committed onsite mitigation would avoid all significant noise effects, save for:

a. daytime significant effects for four months at Axis Court and Luna House during site set-up (similar effects were accepted by the local planning authority for the construction of the consented residential development at the site) (see Doc refs: APP31.02, and APP178.35)

b. daytime (and evening) significant indirect effects at Fountain Green Square due to movements of project river vessels.

1.5.20 These residual significant effects would be avoided by offsite mitigation (see Doc ref: APP210.01) as secured by the legal agreement (Doc ref: APP209.03).

1.5.21 We set out in our oral submissions how the secured mitigation in our proposals complies with the NPS (Doc ref: APP157, Appendix A). We also demonstrated that there are many benchmarks for Chambers Wharf in relation to proximity and sensitivity of receptors as well as the nature, duration and intensity of works, ie, noise levels (Doc ref: APP102.04, Appendix A and APP157, Section 5.3). These are also benchmarks with regards to the scale and cost of off-site mitigation (ie, noise insulation).

1.5.22 The above demonstrates the acceptability of Chambers Wharf as a main tunnel drive site.

Eligibility for trigger action plans and protection for non-eligible residents

1.5.23 All residents are protected by the substantial onsite mitigation committed to in the CoCP (Doc refs: APP178.01 and APP178.35). The qualification procedure for residential buildings is outlined in Doc ref: APP186, Section 4. As per para. 3.1.5 of that document, where significant effects were not

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identified at the Environmental Statement stage, the residence would be protected by the NEWT commitment such that no new significant effect could be generated. Therefore, no further residential properties need to be eligible for trigger action plans. Special cases (Doc ref: APP186, Section 7) are subject to the circumstances of individuals; therefore they may be identified at any time and be eligible under the Non-statutory Off-site Mitigation and Compensation Policy (para. 3.1.6).

Request for trigger action plans for Wrayburn House, Fountain House and 210-212 Bermondsey Wall West

1.5.24 As stated above, there is no requirement to provide TAPs for these properties as no significant effect was identified. In the case of 210-212 Bermondsey Wall West, SYR correctly assumes that this receptor was referred to in the noise section of the site-specific volume of the Environmental Statement as CW7 210-212 Bevington Street.

1.5.25 This being the case, no significant effects were predicted at the buildings to this side of the site (Doc ref: APP208.01.26). They are therefore all protected by the NEWT commitment and cannot become significantly affected.

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Appendix A: Draft Luna House trigger action plan

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Trigger Action Plan (Draft / Work in progress/ For information)

1 Executive Summary

This Trigger Action Plan document has been prepared to set out the mitigation that will be provided to the northern and eastern facades of the residential properties in Luna House.

Section 2 provides a glossary to explain the technical terms which are used in the document.

Section 3 sets out the purpose of the document more fully, defining the parties and policies to which this Plan relates.

Section 4 provides a general explanation of Trigger Action Plans, a description of the receptor to which this Plan relates and the works that the Plan relates to.

Section 5 sets out the mitigation packages that will be provided to the residences.

Section 6 defines the programme for acceptance of this TAP and the installation of the mitigation described in Section 5.

Section 7 defines noise levels which would trigger further mitigation measures, if predicted to be exceeded.

Section 8 sets out corrective measures, which will be put into place in the event that Trigger Action Levels, which have not been predicted to be exceeded, are exceeded in practice.

The Appendices provide more detailed information on each of the items within the plan itself. These are intended more for a technical readership, whereas the main body of the Plan is intended specifically for the beneficiaries of the scheme.

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2 Glossary of Terms

The Infrastructure Provider

- The Infrastructure Provider as defined in article 2(1) of the DCO or, with the consent of the Secretary of State, another body who implements the DCO.

Best Practicable Means

- “best practicable means” as defined in the Control of Pollution Act (1974), where: “practicable” means reasonably practicable having regard among other things to local conditions and circumstances, to the current state of technical knowledge and to the financial implications The “means” to be employed include the design, installation, maintenance and manner and periods of operation of plant and machinery, and the design, construction and maintenance of buildings and acoustic structures.

Section 61 Consent - A prior consent for work on a construction site given by a local authority under Section 61 of the Control of Pollution Act (1974)

Lowest Observed Adverse Effect Level

- As defined in the Noise Policy Statement for England (March 2010), i.e. the level above which adverse effects on health and quality of life can be observed. Refer also to emerging National Planning Practice Guidance (noise)

Significant Observed Adverse Effect Level

- As defined in the Noise Policy Statement for England (March 2010), i.e. the level above which significant adverse effects on health and quality of life could occur. Refer also to emerging National Planning Practice Guidance (noise)

The Policy - The Thames Tideway Tunnel (TTT) Non Statutory Off-site Mitigation and Compensation Policy

The Noise Insulation Regulations

- Statutory Instrument No. 428, The Noise Insulation (Railways and Other Guided Transport Systems) Regulations 1996.

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3 Purpose

3.1.1 This is a Trigger Action Plan (TAP) for the eastern and northern façades of the residential properties at Luna House, Bermondsey (Luna House).

3.1.2 This TAP forms part of the Thames Tideway Tunnel (TTT) Non Statutory Off-site Mitigation and Compensation Policy („the Policy‟ – Doc ref: APP186) and is enforceable under the Policy. This TAP should be read in conjunction with the Policy.

3.1.3 Mitigation will be implemented to ensure that significant noise impact at the residential flats is avoided and that noise impacts are minimised as far as practicable. This TAP defines internal and external noise level targets to be achieved by the mitigation provided.

3.1.4 This TAP is agreed by Thames Water Utilities Ltd (TWUL) and either the owners of the properties at Luna House or the Independent Compensation Panel as defined in Appendix A.

3.1.5 This TAP has been ‘pre-triggered’. The mitigation defined in this TAP will be provided, unless rejected by a beneficiary, before the start of construction without waiting for confirmation of detailed construction noise levels as confirmed by section 61 consent with the local authority.

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4 Introduction

4.1 Trigger Action Plans

4.1.1 TWUL1 acknowledges that the circumstances surrounding the potential airborne noise impacts of the construction works at the Chambers Wharf worksite will mean that some of the residential properties at Luna House are potentially significantly affected by noise2.

4.1.2 The specific mitigation to be provided, as a minimum, on site to reduce noise and vibration at all receptors is defined in the site specific Code of Construction Practice (CoCP) Part B – (Doc ref: APP178.35).

4.1.3 The Environmental Statement (ES), as revised during the examination process, sets out the potential residual significant noise and vibration effects taking account of the mitigation in CoCP part B.

4.1.4 The Infrastructure Provider has to deliver the works such that the residual noise and vibration effects are no worse than those reported in the ES2.

4.1.5 The Infrastructure Provider and its contractors are required by the CoCP, Part A (Doc ref: APP178.02), to carry out the construction of the „Proposed Scheme‟ in a manner that will minimise the emission of noise and vibration as far as reasonably practicable.

4.1.6 Since onsite mitigation is exhausted at this stage of planning, this Trigger Action Plan (TAP) has been prepared for Luna House to define the mitigation package that will be implemented to ensure that significant noise impact at the properties is avoided and that noise impacts are minimised as far as practicable. This mitigation package is pre-triggered at Luna House.

4.1.7 The noise insulation package, as defined under the Project‟s policy, will be installed using the principles identified in the Noise Insulation Regulations. The Regulations were established in 1975 and considering the windows at this time - typically single glazed windows in wood or metal frames - and the improvement afforded by the secondary glazing, with secondary glazing in place, the overall sound insulation performance of the glazing as stipulated in the Noise Insulation Regulations is estimated to be in the range of 30 – 35 dB R’w.

4.2 Receptors

4.2.1 This is a Trigger Action Plan (TAP) for Luna House.

4.2.2 The postal address for these properties is: 37 Bermondsey Wall West, London SE16 4RN.

1 Thames Water Utilities Ltd (TWUL). The Draft Development Consent Order (DCO) contains an ability for TWUL

to transfer powers to an Infrastructure Provider (as defined in article 2(1) of the DCO) and/or, with the consent of the Secretary of State, another body. 2 As reported in the Environmental Statement as amended during the DCO application examination, see ES

Update report (AP208.01).

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4.2.3 The property freeholder is Berkeley Homes.

Property use

4.2.4 The properties are residential..

Noise sensitive spaces

4.2.5 Appendix B provides floor plans.

4.2.6 Internal noise-sensitive spaces in the properties surveyed are:

a. Living Rooms / home offices

b. Bedrooms / home offices

Existing noise levels

4.2.7 Monitoring of existing noise inside the noise-sensitive internal spaces as listed in paragraph 4.2.6 was undertaken on 5 February 2014. Details of the surveys and survey results are presented in Appendix C.

Existing sound insulation and noise mitigation

4.2.8 Physical measurements were taken of the various building elements, including the glazing thicknesses. Details of the existing building fabric and sound insulation are presented in Appendix D.

4.2.9 Summary of existing sound insulation and ventilation:

a. Based on the survey data in Appendix D, the sound insulation of the Living Room glazing is estimated to be in the range of 30 – 35 dB R’w.

b. Based on the survey data in Appendix D, the sound insulation of the Bedrooms glazing is estimated to be in the range of 25 – 30 dB R’w.

c. Currently ventilation is provided to the flats through trickle vents, on the east façade, and by opening sliding glass doors on the north façade.

4.2.10 For the living rooms the level of sound insulation is about the same as the sound insulation identified by the Noise Insulation Regulations. For the bedrooms, the level of sound insulation is lower than the sound insulation identified by the Noise Insulation Regulations.

4.2.11 On the basis of the survey information, improving the sound insulation of the bedroom and study windows would provide substantial additional protection against TTT construction noise. To enable the full benefit of the noise insulation to be achieved, where applicable, the existing passive ventilators will need to be amended and a mechanical acoustic ventilator installed to provide alternative ventilation.

4.2.12 Wherever ventilation is currently provided solely through the opening of windows or balcony doors, i.e. on the north façade, both noise insulation and acoustic ventilators will also be provided.

4.2.13 The acoustic ventilators are mechanically powered units and will typically provide equivalent or better ventilation than passive ventilation from opening a window.

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4.2.14 The means for providing the additional noise insulation is described in section 0.

4.3 Project Works

4.3.1 This receptor is adjacent to: Chambers Wharf worksite

4.3.2 The project‟s Environmental Statement (ES) update report (Doc ref: APP208.01) confirms that the east façade of Luna House could be potentially significantly affected by noise indoors arising while the following daytime only activities are taking place over a period of four months:

a. Site setup

b. Demolition

c. Cofferdam construction and fill

4.3.3 The primary cause of the highest forecast noise levels at Luna House is the demolition of existing hard standing, remnant basement structures and the river wall.

4.3.4 The north façade of Luna House would be subject to lower levels of noise exposure from construction activities because there is a „smaller angle of view‟ to the activity (the east façade faces the construction activities, whereas the north façade faces the river and therefore only has a partial view of some of the works). Additionally existing balcony balconies and their balustrades provide some screening to the façade and hence living rooms.

4.3.5 There are no other significant noise effects identified during the total duration of construction and reinstatement as a result of the extensive committed mitigation (e.g. noise enclosures around all 24/7 activities) as set out in the CoCP Part B. This mitigation includes the measures committed to since the ES was published. The principal items are:

a. Commitment to use push piling for the cofferdam (except for initial anchor piles)

b. No night-time movement or loading/unloading of river vessels and engines to be turned off when moored

c. Commitment to deliver tunnel segments by river

4.3.6 The mitigation is confirmed in the CoCP (APP178.02 and APP178.35). The reduction in noise and vibration levels as a result of this mitigation is reported in the ES Update Report (APP208.01).

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5 Mitigation

5.1.1 Based upon the surveys undertaken the noise mitigation package to be provided will comprise the following:

a. Sound Insulation

i Bedrooms and studies (East and North façade)

A temporary secondary internal glazing to be located within the bedroom(s) and study of individual apartments with an east-facing aspect.

The secondary glazing would span vertically between floor and ceiling and would be fitted at the inner edge of the reveal to the existing windows, in line with the inner plastered walls. The secondary glazing would be either just on the inside or the outside of the reveal edge.

The existing half-height Perspex „safety balustrades‟ would remain in place, sitting between the existing outer pane of glass and the inner secondary glazing pane.

Where residents have installed blinds, these would be relocated (or new ones integrated) if the resident wanted the blind on the room side of the secondary glazing (rather than accessed by opening the secondary glazing).

The secondary glazing systems have a variety of opening configurations: sliding, pivoting and sash. The design will maintain access to the existing inner glazing for opening during quiet periods and for cleaning / maintenance.

The proposed arrangement is shown in Figures E.1 and E.2 in Appendix E. This shows pivoting secondary glazing (opening like a door into the bedroom for access to the existing glazing).

The detailed design of the system will ensure that the level of safety protection provided is as high as or greater than currently exists.

Whilst designed to standards for a permanent system, the insulation is intended to be temporary (for the duration of project works). If requested by the resident, after completion of the works, the secondary glazing could remain as a legacy, to increase the thermal performance of the apartments and protect residents from noise during the construction of the permitted residential development at Chambers Wharf.

ii Living rooms and balconies (north façade)

It is proposed to extend the existing parapets on the east side of each balcony, from balcony floor height up to the height of the next floor. This would be as a glazed element, maintaining views. This would reduce construction noise on the balconies and have the added benefit of providing additional screening along the north façade to both balconies and windows to living and bedrooms (refer to Appendix E,

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E.6). The structural engineering design of this option has yet to be confirmed.

As noted earlier in the TAP, sound insulation of the Living Room glazing is estimated to be in the range of 30 – 35 dB R’w. This is equivalent to the sound insulation identified by the Noise Insulation Regulations.

The mitigation required for the living rooms on the northern façade is therefore the provision of alternative ventilation to enable the existing windows (balcony doors) to be kept closed during the 4 months of daytime site set up. Alternative ventilation is described in the next section.

With the existing windows closed noise levels inside north facing living rooms would meet the guidance in the relevant British Standard (BS8233: 2014) and would still be „reasonable‟ (as defined by the Standard) even during the four noisiest months during site set up (daytime works only).

If preferable to the beneficiaries of the TAP, then a temporary secondary glazing system would be installed in the living rooms of individual apartments. These systems would be of similar design to the east façade and are shown on the sketches at Appendix E, E.3.

iii Alternative ventilation

Mechanical, sound attenuated, ventilators will be installed within the living room and bedrooms of individual apartments with an east-facing or north-facing aspect. This will provide alternative, and equivalent, ventilation and cooling to that provided by opening the windows.

Current information indicates that a central mechanical ventilation system does not exist, and therefore temporary mechanical ventilation to provide fresh air into the interior would have to be achieved through the cladding and secondary glazing. However if there does prove to be a central mechanical system, a further option will be developed.

In bedrooms and studies, to avoid penetrating the precast concrete cladding panels, an attenuated fan unit (refer to Appendix E, E.5) will be mounted on the inside of the existing aluminium insulated spandrel panels with a duct penetrating through to the exterior (refer to Appendix E, E.1, E.2, and E.4).

These fans would be of a comparable type to the unit shown in Appendix E.5, which is a Titan Sonair mechanical ventilation unit, measuring approximately 30cm wide by 45cm tall by 15cm deep. This unit achieves a noise reduction of 52 dB Dn,e,w.

The external inlet grille will be flush to the external panel face. Wherever windows are currently operable, then the sliding window will be able to pass, allowing the existing windows to be opened.

The attenuated fan unit can be installed at a high or low level on the existing walls, depending on the individual residents‟ preferences.

The existing trickle vents would be temporarily blocked.

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After the TTT works are complete the fan, duct and grille would be removed, unless the resident requested to adopt them, and the aluminium spandrel panel restored and over clad to its full extent externally to return it to its existing weathering and appearance.

In locations where there is no aluminium spandrel panel (i.e. north facing living rooms), the ventilator will be installed via a frame cut-out in one of the glazing panels to one side of the balcony doors (see Appendix E, E.3). These panels would be pre-fabricated and used to replace the existing panels on-site, using the method defined for replacing the glazing in the existing units. The existing panels would be placed in storage and put back into place after project construction works are finished, unless the residents want to adopt the alternative ventilation system.

b. Other Observations

As-built trade contractors drawings and specifications, in particular the cladding system and its interfaces, are required to be made available in order to finalise the detailed design of the mitigation. A further draft of this TAP will be provided when this information is made available.

The mitigation works set out in this TAP require access to individual apartments for installation.

5.1.2 Plans, sketches and data sheets showing the proposed mitigation together with a schedule of what will be provided at each qualifying flat are provided at Appendix E.

5.1.3 The following consents are required to install this insulation package. Copies of the consents are provided at Appendix F.

Consent Required and granted?

Tenant Required

Feeeholder Required

Planning permission Not Required

Conservation area Not Required

Listed building Not Required

Building regulations Required

5.1.4 Initial discussions with the Building Control department at London Borough of Southwark indicate that the works would be subject to local authority approval, but that there are no in-principle objections to the works.

5.1.5 Should the project be granted consent, the proposals within this document will be discussed further with the Building Control department at London Borough of Southwark and their comments requested, and any relevant comments incorporated into the design.

5.1.6 With the Building Control comments incorporated, a letter will be issued to the freeholder detailing the works to be undertaken, and providing evidence that planning consent is not required. Once the freeholder has

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accepted the proposal, letters will be issued to the individual leaseholders specifying the works to be undertaken and requesting their agreement and contact details to make arrangements for survey and installation. Any tenants will be informed of the works proposed, and requested to contact their leaseholder.

5.1.7 Once the works have been completed, the Building Control department at London Borough of Southwark will be informed and will be requested to undertake a visit to confirm satisfactory installation.

5.2 Reimbursement of Beneficiaries for Cost of Increased Electricity Consumption

5.2.1 Based on information received from Sonair, a worst case calculation shows that each fan would consume 367kWh of electrical energy each year if it were run on full power 24 hours per day, 7 days per week. This would equate to an annual additional electricity bill of £55 per fan at a typical electricity unit cost of 15p/kWh.

5.2.2 There will be some savings in heating energy from the increased thermal insulation that the secondary glazing will provide, but because the flats are already fairly well insulated this is not a large saving overall and is perhaps 20 times less than the additional fan energy for the assumed worst case. Heating energy savings made via the additional glazing may also be slightly reduced as there would be a slightly higher cooling energy requirement in the summer due to more heat being trapped inside.

5.2.3 To compensate for this potential additional cost, TWUL will provide an advance annual payment to each household to cover the potential running cost of each fan as above.

5.2.4 If a resident were to elect to adopt the mitigation after the construction of the project is complete, then the resident would become responsible for running costs after the point of adoption.

5.3 Reinstatement of Building Fabric after completion of the Works

5.3.1 The costs of reinstatement and making good of any flooring, walls or other building fabric which has been altered by the mitigation works, will be arranged and paid for in full by TWUL.

5.3.2 The substitution of the glazing units on the north façade will not adversely affect the sealing of the glazing, since the frames will have been designed to allow for replacement of glass, in case of accidental damage for example. TWUL will ensure that the sealing of the frames of the glazing units is not compromised by providing comprehensive inspection and upon both installation and removal of the mitigation.

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6 Programme

6.1.1 Based on the surveys undertaken, the programme for providing the mitigation triggered under this plan is set out below. The Starting Date is the date on which this Plan is formally agreed with all the relevant parties.

Weeks after Starting Date

Stage

0 Comments requested from LB Southwark Building Control department.

4 Formal agreement of TAP

6 Structural design drawings completed

8 Freeholder informed

12 Leaseholder informed

6.1.2 The installation of noise insulation will seek to take place at a time when it will minimise detrimental effects on the quality of lives of the residents of Luna House. Therefore the most convenient times will be agreed individually with the residents whose properties are to receive the mitigation.

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7 Further Measures

7.1 Noise

7.1.1 This TAP has been „pre-triggered‟ so the mitigation defined will be installed before start of construction without waiting for detailed construction noise levels to be confirmed through section 61 consent with the local authority.

7.1.2 Further measures are available as set out in section 4 of the Policy. This would be confirmed by section 61 consent with the local authority. In the unlikely and unforeseen event that further measures are required residents would be notified and arrangements agreed as set out in the Policy before the relevant works were started.

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8 Corrective action

8.1.1 If monitoring during construction confirms construction noise levels are greater than the temporary rehousing levels for the period designated within the noise insulation and temporary rehousing policy, then this further mitigation shall be applied to the affected residents. Before the mitigation has been applied, either:

a. The relevant construction activity will be stopped until the mitigation has been implemented, or

b. The relevant construction activity will be modified to keep the level of exposure below the trigger value until the mitigation or agreed alternative3 has been implemented.

8.1.2 If residents prefer not to accept the mitigation solution offered for either façade, then temporary rehousing will be provided for the period where noise levels exceed noise insulation trigger levels.

3 Temporary re-housing for example

Draft #3: Trigger Action Plan – Luna House (Work in progress / For information)

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Appendices

Appendix A – Agreement and Approval of this TAP

Appendix B – Floor Plans

Appendix C – Existing Noise Levels

Appendix D – Existing Sound Insulation

Appendix E – Drawings and Schedule of Proposed Mitigation

Appendix F – Consents and Permissions

Draft #3: Trigger Action Plan – Luna House (Work in progress / For information)

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Appendix A – Agreement and Approval of this TAP

Draft #3: Trigger Action Plan – Luna House (Work in progress / For information)

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Appendix B – Floor Plans

Draft Trigger Action Plan – Luna House (Work in progress / For information)

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Draft Trigger Action Plan – Luna House (Work in progress / For information)

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Draft Trigger Action Plan – Luna House (Work in progress / For information)

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Draft Trigger Action Plan – Luna House (Work in progress / For information)

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Draft Trigger Action Plan – Luna House (Work in progress / For information)

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Draft Trigger Action Plan – Luna House (Work in progress / For information)

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Draft Trigger Action Plan – Luna House (Work in progress / For information)

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Draft Trigger Action Plan – Luna House (Work in progress / For information)

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Draft Trigger Action Plan – Luna House (Work in progress / For information)

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Draft Trigger Action Plan – Luna House (Work in progress / For information)

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Appendix C – Existing Noise Levels

Existing noise sources that affect this property are primarily road traffic and river traffic. Existing noise levels in the internal noise sensitive spaces in the property are as follows:

C.1 Living Rooms and Bedrooms

The ambient noise level measured in the living room of 24 Luna House during the daytime was 34 dB LAeq. This is around the middle of the recommended range for living rooms in BS 8233.

Draft Trigger Action Plan – Luna House (Work in progress / For information)

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Appendix D – Existing Sound Insulation

D.1 General Architectural Description

The building is a large eight-storey residence of recent design and construction comprising a number of apartments in a variety of sizes and configurations. The building is a rational cubic volume set back from the river, with cantilever balconies projecting over a large riverside terrace on the north side. The ground floor is mainly retail, the residential accommodation above being one and two bedroom apartments and duplexes.

The accommodation is of good quality fabric and a high quality of finish. The building was constructed within the last ten years and as such is well insulated - probably to Part L1A 2002 standards.

Access was granted to apartment 24, on the fourth floor. The accommodation has a combined living and kitchen area with a cantilever balcony on the north side with panoramic views of the river through a full height window wall, covering the entire north elevation and turning through 90 degrees to meet the east flank wall of the building. Opening full height double sliding windows provide access to the projecting balcony, which appear to require adjustment to the seals to block up an air path at the meeting stiles.

The bedrooms are located on the east side overlooking the Thames Tideway Tunnel works site each having full height sliding windows with inner glass balustrading. The bathroom and other accommodation are internal.

No construction drawings were available, however the structure is probably a reinforced concrete flat slab with perimeter full height precast panels that support the slab edge. The floor slab edge is expressed externally as a horizontal precast band matching the vertical panels.

In between the precast structure, the building is clad in a modular system of curtain walling, using a combination of full height insulated natural anodised aluminium panels, and full height double- glazing within aluminium frames. The glazing is openable by sliding the frames along top and bottom rails, which are stowed externally in their open position.

There are vertical full height blinds internally to the windows operated by a switch.

Background ventilation is provided via trickle ventilation and extract through WC and kitchen ventilation systems. Within the bedrooms there is an adjustable „hit and miss‟ type grille to close off the trickle ventilation path if required, connected to an opening in the underside of the insulated aluminium panel. For additional ventilation the large sliding doors can be opened in the living and bedrooms.

Heating is provided via ceiling mounted fan coil units ducted to a linear slot supply grille within the living room and also in bedrooms. These fan coil units

Draft Trigger Action Plan – Luna House (Work in progress / For information)

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are likely to be a refrigerant based VRV system with external condensers mounted on the roof. These units can be switched on and off as required and can also provide cooling as well as heating.

D.2 Living Rooms

The sliding doors in the living rooms are double glazed, with 6mm glass panes either side of a 16m air gap. The estimated sound insulation of this configuration is 30 - 35 dB R’w. This is in the range of sound insulation identified by the Noise Insulation Regulations.

D.3 Bedrooms

The windows in the bedrooms are also double glazed, with 6mm glass panes either side of a 16m air gap. However due to the presence of the vents, the estimated sound insulation of this lower – approximately 25 - 30 dB R’w

This is lower than the sound insulation identified by the Noise Insulation Regulations.

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E.5 Brochure of Example Ventilator

Draft Trigger Action Plan – Luna House (Work in progress / For information)

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Appendix F– Consents and Permissions

Copyright notice

All rights reserved. Any plans, drawings, designs and materials (materials) submitted by Thames Water Utilities Limited (Thames Water) as part of this application for Development Consent to the Planning Inspectorate are protected by copyright. You may only use this material (including making copies of it) in order to (a) inspect those plans, drawings, designs and materials at a more convenient time or place; or (b) to facilitate the exercise of a right to participate in the pre-examination or examination stages of the application which is available under the Planning Act 2008 and related regulations. Use for any other purpose is prohibited and further copies must not be made without the prior written consent of Thames Water. Thames Water Utilities LimitedClearwater Court, Vastern Road, Reading RG1 8DB The Thames Water logo and Thames Tideway Tunnel logo are © Thames Water Utilities Limited. All rights reserved.

Copyright © Thames Water Utilities Limited March 2014.