We suggest that no-one responds to the Thames Water’s Statutory Consultation using the online questionnaire / statutory feedback form.
The statutory feedback form is a framework designed by Thames Water to focus on Thames Water preferred topics.
The statutory consultation brochure contains the information that Thames Water have decided is sufficient for people to have in order to respond to their selected feedback topics.
There are 20 questions in the feedback questionnaire.
- 12 questions relate to the operation, design, location and then construction of the infrastructure.
- 3 questions are about “legacy and benefits”.
- There is 1 question each on the topics of Land (views on the land that will be required), the Consultation and Engagement process (what you think of the materials presented etc) and Any Other views you would like to share.
- There is 1 question for feedback on “Draft Design Principles”.
- There is 1 question on feedback on the “predicted environmental effects”.
Most of the feedback questions refers consultees to specific pages in the consultation brochure only. There are some exceptions:
- Q13 to 16 about construction refers to the “code of construction practise – Appx 4.3”.
- Q12 about design refers to the “Preliminary Townscape and Environmental Master plan” within Chapter 2 of the PEIR documentation and also PEIR Figure 2.5.
- Q20 about the environmental effects refers consultees to the “PEIR Non-Technical Summary” and the Preliminary Environmental Information Report (PEIR). (The PEIR report itself is a collection of over 40 documents).
Thames Water asks for feedback on 19 points to do with very specific infrastructure topics; location, design and construction methods and asks just 1 question on possible environmental effects.
Environmental effects are a core (by law) aspect of the consultation. The PEIR NTS and PEIR documents provide essential information on the impacts of the operation, construction, location and design of each aspect of the infrastructure.
It gives people extra information which directly relate to the feedback questions that Thames Water have in their feedback form. It also gives information on topics like water quality, aquatic ecology, alternatives etc. Topics which Thames Water asks for no feedback on.
Don't let Thames Water put you off balance
The presentation and emphasis of the consultation brochure and feedback form is very unbalanced. The absence of clear signposts in the consultation brochure to relevant pages of the PEIR NTS and relevant chapters of the PEIR documents is a failure that could impact peoples understanding of the project’s effects.
Respond to the consultation by e-mail or freepost so you can give your feedback on the topics that you think Thames Water should listen to and to stop this project altogether.
Consultation brochure lacks critical information
The following example shows how the consultation brochure and feedback questionnaire are limiting to consultees.
When you (hopefully) get to the end of this please consider if you think Thames Waters presentation of information is sufficient to have allowed you to give informed feedback on any topic. Include your thoughts on this in your consultation response!
Two of the feedback questions relate to TLT infrastructure on Burnell Open Space. Neither the feedback questionnaire nor the brochure signpost to the “managing environmental impact” pages in the brochure, or to any PEIR document.
There is quite a bit of information in the brochure about the location and the structures of the 2 different TLT connections:
- That the Burnell TLT option is the preferred option.
- It is an underground “adit” from the intake to the TLT.
- It would be a 3.5m diameter, 70-meter-long tunnel, dug out by an excavator (a conventional digger).
- It would be built using a sprayed concrete lining.
- It would have less construction impacts than the Tudor drive TLT option.
- The Tudor Drive TLT option would 2.2 meters diameter, 500 meters long built by pipejacking.
- The material from the pipejacking would be taken from the starting shaft in Burnell open space.
- One extra snippet is in a section about working hours that mentions 24 hour working at these sites.
All useful information, but nothing about the environmental effects. Despite that Thames Water has already started to “point” people to the feedback questions at this stage in the brochure.
The only “external” document that the brochure refers to at this stage is the “draft Code of Construction Practise (CoCP)”. This draft CoCP is, well, a draft, and generic in the extreme. In the “working hours” part it states the following = “TLT connection activities at the Tudor Drive and Burnell Avenue sites which will require 24/7 construction …”. That isn’t additional information as it is mentioned in the consultation brochure already.
Anything about environmental impact?
At 44 pages into the 60 pages of the brochure there are some 8 pages the section on “Managing Environmental Effects”. The second page of this section references the PEIR non-technical summary document (PEIR NTS) and the PEIR documents. This is followed by 7rl pages covering some 15 sub-headings, one of which is “Noise and Vibration”. Here, there is mention of “significant noise”, but it is not related to any specific locations.
There is also mention of Thames Water “considering” the use of noise reduction measures to limit noise. But there is no signposting from this section to any specific “environmental documents”.
It is now clear that the consultation brochure does not have all the information needed to provide informed feedback. Nor has it pointed out where that specific information can be found.
Preliminary Environmental Information Report
Reading through the whole of the PEIR NTS (60 pages) confirms the following: “either [of the] TLT connection option would require some 24/7 construction work at the Burnell Avenue site”.
With some more detail “… significant nighttime noise effects are predicted for residential properties within 60 meters of the works on Dysart Avenue and Biggin Hill Close. […] associated […] during the construction of the Thames Lee Tunnel adit and conveyance pipeline [Tudor Drive TLT option]. The night time [Burnell] adit works would have a construction duration of six and a half months while the conveyance pipeline connection [Tudor Drive TLT option] would have a construction duration of three months”
“Further assessment and mitigation will be explored as part of the assessment included in the ES.”
Noise impact
The next source of information on noise is the PEIR chapter 14 Noise and Vibration assessment (52 pages). None of this is signposted from the consultation brochure.
In these documents what consultees will find (amongst other things) is, for example;
- Only 2 baseline studies for noise have been completed by Thames Water – both at Mogden.
- many streets near Mogden and Burnell are described as likely to suffer from adverse noise impacts, including (not limited to): Burnell Ave, Dysart Ave, Biggin Hill Close, Wainwright Grove and Harvesters Close, Hilary Drive and Beaumont Place.
- Thames Water “may” undertake baseline noise surveys in the Ham and Burnell work site areas.
- the assumptions and interpretations of when significant adverse levels of noise will be measured is not well explained.
- Thames Water will undertake further assessments on the noise impacts going forward to include in their DCO application.
Critical information still missing
At the end of this process, what is clear is that responding to a feedback question based on what is in the consultation brochure would be responding without critical pieces of information. Some of this information is not in the consultation brochure nor is not clearly signposted from the brochure.
The statutory consultation brochure allows Thames Water to focus the consultation in a way that suits their own end. It frames information so it appears to be quite detailed when in fact significant details (that are available) are not presented.