Response to the City of Westminster and Historic Buildings and Monuments Commission for England (HBMCE) 3 March 2014 submissionDoc Ref: APP198.08

Folder 249 11 March 2014DCO-DT-APP-ZZ100-980800

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Thames Tideway Tunnel Thames Water Utilities Limited

Application for Development ConsentApplication Reference Number: WWO10001

Response to submissions from HBMCE and WCC

Responses to third-party submissions on 3 March 2014

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1 Response to submissions from Historic Buildings and Monuments Commission for England and Westminster City Council

1.1 Summary

1.1.1 In this response to the Examining Authority (the ‘ExA’), Thames Water seeks to address the submissions by both the Historic Buildings and Monuments Commission for England (HBMCE) and Westminster City Council (WCC) on 3 March 2014 with respect to the relocation of the existing permanently moored Tattershall Castle vessel.

1.1.2 The submissions from HBMCE and WCC are in response to the ExA’s request for further information R55.3:

a) relating to the degree of harm to the Grade II listed embankment wall and the Whitehall Conservation Area

b) para. 4.10.14 of the National Policy Statement on Waste Water (the ‘NPS’) regarding the need to weigh any harmful impact on the significance of a designated heritage asset against the public benefit of development.

1.1.3 In the response below, we address the key matters raised under the following headings:

a. Definition of substantial harm

b. Effect of service moorings

c. Effect of the works to relocate Tattershall Castle

d. Consideration of alternatives

e. Archaeological mitigation for dredging

1.1.4 We have undertaken a balanced and considered assessment of all the relevant environmental and planning effects of these proposals and are of the opinion that the relocation of the Tattershall Castle (approximately 127 metres upstream in the construction phase and 87 metres in the operational phase) is the appropriate mitigation for this existing business.

1.1.5 In relation to the effect on heritage assets we do not consider that HMBCE or WCC have raised any new issues and consider that the works cause less than substantial harm and that our proposals are consistent with the overall setting and use of the river.

1.1.6 Para. 1.4.4 of the NPS identifies that given the likely geographical location of potential projects in large conurbations effects need to be considered in relation to a mature urban environment. As a result a range of short-term adverse effects are likely to arise, including cultural heritage effects. However, these effects must be weighed against the public benefit and these “could outweigh damage or loss to heritage assets or their setting”. We consider that the public benefits of the works at Victoria Embankment Foreshore, for which there is no alternative, do outweigh the damage and

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loss to heritage assets and their setting. The relocation of the Tattershall Castle is an essential part of mitigating the land use and socio economic effects of those works. The effects of securing that mitigation are not significant and the public benefits of the proposals outweigh the harm caused from the damage and loss to the heritage assets.

1.2 Detailed response

1.2.1 The following is a response to matters raised by the Historic Buildings and Monuments Commission for England (HBMCE) and Westminster City Council (WCC) with respect to the temporary and permanent relocation of Tattershall Castle.

1.2.2 It is important to note that, in relation to all the matters raised in this representation, the Tattershall Castle is an existing permanently moored vessel on the River Thames. It is already located within the Whitehall Conservation Area within existing views towards the Palace of Westminster World Heritage Site from the Jubilee/Hungerford Bridge. From its current position the Tattershall Castle will be relocated approximately 127 metres upstream in the construction phase and 87 metres in the operational phase. This means that the vessel will be 31 metres from the RAF memorial in the construction phase and 71 metres in the permanent phase (Distance taken from the bow of the vessel to the centre of the memorial).

1.2.3 The new element in the setting of the various nearby heritage assets noted in both WCC and HBMCE responses is the Foreshore Structure.

1.2.4 The River Thames as can been seen from the aerial images taken in 2012 (Figure 1.1 to Figure 1.3) between Westminster Bridge and Blackfriars Bridge contains a large number of permanent moorings for both static boats such as the Tattershall, Hispaniola, President and Wellington, service moorings for charter boats and piers for Transport for London river services. In addition there are a number of permanent moorings such as Savoy, Temple and Chrysanthemum piers which do not have any vessels currently mooring against them.

1.2.5 Figure 1.1 to Figure 1.3 show that the line of vessels and moorings is almost continuous including between Westminster and Lambeth Bridges opposite the Palace of Westminster. These images demonstrate how vessels and river traffic are an important part of the setting and vitality of the river through this part of the city and are a visible reminder of the historical primacy of the tidal Thames in London’s commercial life as set out in para. 13.6.4 in our response to question 27.13 of the ExA’s second written questions (Doc ref: APP54).

1.2.6 In responding to the submissions we believe the key matters raised can be responded to under the following headings:

a. Definition of substantial harm

b. Effect of service moorings

c. Effect of the works to relocate Tattershall Castle

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d. Consideration of alternatives

e. Archaeological mitigation for dredging

Definition of substantial harm

1.2.7 We note that in response to the ExA’s question R55.3, HBMCE and WCC do not provide any evidence as to how they quantify their assessment of substantial harm with respect to the partial demolition of the embankment wall and construction of the foreshore structure. This is in contrast to the detailed qualitative and quantitative assessment carried out by Thames Water and provided in our response to first written question 8.11(Doc ref: APP08).

1.2.8 In Para. 11.3.3 of our response to question 8.11 we state that:

“the length of the wall that would be permanently removed for the construction of the foreshore structure would be approximately 50.8m, or only approximately 2.63 per cent of the length of the listed building.’ Therefore as noted in Para. 11.5.2, we state that this would represent “only partial diminution of significance to the listed structure overall, which would not come near to its destruction and would represent less than substantial harm”.

1.2.9 The extent of the listed wall is defined in two parts under HBMCE list entries 1237712 for the wall within the City of Westminster and 1358921 for the section of wall in the City of London. We would note that although the listing is in two parts, it comprises a single wall built as part of the original Victoria Embankment Works by Sir Joseph Bazalgette.

1.2.10 With respect to the Whitehall Conservation Area and Palace of Westminster World Heritage Site the National Policy Statement for Waste Water (para. 4.10.15) states that:

“…Not all elements of a World Heritage Site or Conservation Area will necessarily contribute to its significance...The decision maker should take into account the relative significance of the element affected and its contribution to the significance of the World Heritage Site or Conservation Area as a whole”.

1.2.11 In our response to question 55.3a we set out in para. 55.3.10 that the river frontage in the north-eastern part of the conservation area contributes only partly to the significance of the area as a whole and represents only a portion of its river frontage. The level of harm would therefore be far below the threshold of substantial harm.

1.2.12 In para. 13.6.12 of our response to second written question 27.13 (Doc ref: APP54) in respect of the effects on the Palace of Westminster World Heritage Site, we say that in relation to the outstanding universal value for which it is designated, which includes Westminster Abbey and the full gamut of views of the Palace of Westminster, the combined effects would have little impact on its setting.

1.2.13 In WCC’s response to the ExA’s question 55.3(a)(i), it discusses the loss of seven London Plane trees and ‘some’ Sturgeon Lamp Standards. We note that the indicative landscape plan (drg ref. DCO-PP-16X-VCTEF-

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180012) secured through Requirement VCTEF16 shows eight trees being proposed as replacements. With respect to the Sturgeon Lamp Standards we note that three are proposed to be permanently removed and their reuse would be governed by para. 2 of Requirement VCTEF8. The loss of the Sturgeon Lamp Standards is unavoidable due to the intervention of the foreshore structure into the line of the lamp standards on the river wall.

1.2.14 Given the defined size of the listed building (the wall runs between Westminster Bridge and just upstream of Blackfrairs Bridge) we therefore do not agree with WCC and HBMCE that the works would cause substantial harm. We note that the works to the river wall would cause local harm, as we have explained in our response to ExA question 8.11 (Doc ref: APP08) but, this does not amount to substantial harm.

Service moorings

1.2.15 Para. 3.3 of the HBMCE response raises matters regarding the two service moorings upstream of Tattershall Castle and submits that this and any consequent relocations of the structures along that part of the river could give rise to an appearance of substantial clutter in this visually sensitive location, that has not been assessed.

1.2.16 Thames Water does not accept this and believes that our application documents are clear and comprehensive. The Planning Statement (Doc ref: 7.01, Appendix P, para. P.4.22) explains that the two service moorings would be removed during the works with only one being able to be returned post construction. In addition the demolition and site clearance drawing (drg ref. DCO-PP-16X-VCTEF-180007 Rev 2 dated November 2013) in the Book of Plans (Doc ref: 2) also shows that both moorings will go temporarily with one being returned.

1.2.17 As noted in para. 1.2.4 above Figure 1.1 to Figure 1.3 show the number of moorings, etc, on the river. Given the number of existing moorings and the extent of activity on this stretch of the river we do not believe that the potential temporary relocation of two moorings and permanent relocation of one mooring will add to the clutter in this part of the river. We are continuing discussions with the Port of London Authority (PLA) to identify suitable alternative mooring locations.

Effects of moving the Tattershall Castle

1.2.18 In answer to the ExA’s question 55.3(a)(ii), WCC states that the repositioned Tattershall Castle will be an additional structure projecting into the foreshore where currently there is none and that it will create a more cluttered townscape, eroding the clean line of the river wall and encroaching on the RAF Memorial. However, as set out in para. 1.2.2 above, the Tattershall Castle is not an ‘additional’ structure but a structure ‘relocated’ from a short distance away. Any assessments of the effects on heritage assets need to start from this basis. We have included in Appendix A two verifiable photomontages from the Environmental Statement (Doc ref: 6.2.17, Vol 17: Victoria Embankment Foreshore, Figure 11.6.4 and Figure 11.6.6). These demonstrate that the Tattershall

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Castle does not encroach on the RAF Memorial in the operational phase of the project. In addition it should be noted that the location where the Tattershall Castle would be located contains two existing service moorings where vessels are intermittently moored and therefore obscure the river wall.

1.2.19 In our response to question 27.13 paras. 13.5.2 to 13.5.4, para. 13.5.2 discusses the construction phase assessment for viewpoint 2.14 and notes that the relocation works themselves represent a barely perceptible change in the panorama. Furthermore, the relocated vessel would be positioned approximately 31 metres from the RAF Memorial; therefore views of this distinctive feature would be preserved. Para. 13.5.3 deals with the construction phase assessment for viewpoint 2.21 which explains that while the vessel would be apparent during the highest tides, for the majority of the time, most of the vessel would be largely obscured by the intervening river wall and other structures. Given that the boat moorings and vessel itself would be contiguous with river use and, for much of the year, the trees along the embankment provide a significant visual barrier and would remain the dominant feature in the view, the effect is considered to be negligible. In winter, while the vessel would be more apparent, the lack of leaves on the trees would also open up the view to the opposite side of the river more widely, reducing the visual incursion of the relocated vessel.

1.2.20 Para. 13.5.4 looks at the operational phase assessment for viewpoint 2.21 and notes that this is similar to the construction phase in that the relocated vessel would be largely obscured except during the highest tides. Furthermore, in its permanent location more than half of its length would be obscured from view. We would also note that the view of the vessel and moorings would be contiguous with river use.

1.2.21 HBMCE in its question 27.14 to the ExA, references the historic image of the embankment in Figure 19.23 of the Design and Access Statement (Doc ref: 7.04) to illustrate among other things the uncluttered nature of the embankment. Not surprisingly the river and its surrounding area have both become much busier with the passage of time and the current situation contrasts with this historic image. The following images are reproduced from Environmental Statement (Doc ref: 6.2.17, Vol 17, Section 11, Townscape and visual) provide an idea of the number of vessels and river-related structures currently in this stretch of the river.

a. Vol 17 Plate 11.4.2 River Thames – Houses of Parliament Reach TCA

b. Vol 17 Plate 11.4.4 River Thames – Central London Reach TCA

c. Vol 17 Plate 11.4.24 Viewpoint 2.9: winter view

d. Vol 17 Plate 11.4.28 Viewpoint 2.10: winter view towards Blackfriars Bridge Foreshore (east).

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Figure 1.1 Aerial view of river Thames Lambeth Bridge to the London Eye

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Figure 1.2 Aerial view of river Thames London Eye to Somerset House

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Figure 1.3 Aerial view of river Thames Somerset House to Blackfriars Bridge

Access brows/gangways

1.2.22 Details of our proposals with respect to the Access brows/gangways are set out in our response to question 27.13. We note in para. 13.4.10 that the existing access brows approved by WCC (application ref.

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03/01592/FULL) are currently of a basic and utilitarian design. In the new position much more could be done in terms of careful design integration of the gangway, access steps, ramps, signage, canopies and gates to minimise the potential visual clutter of such structures. For example, the handrail, balustrade treatment and structural sections could be kept to a minimum. Such detailed design development would lessen the visual impact of the structures on the listed wall and other heritage assets and reduce visual clutter.

1.2.23 City of Westminster states that the ramp at the Savoy Pier is in a less sensitive area but, we consider that there are many similarities between the two cases. For example, the ramp (see Figure 1.4 below) is against the same listed river wall, is in a conservation area (Savoy conservation area), and has the back drop of listed buildings (the Grade II Shell-Mex Building and Savoy Hotel (southern extension)) and the 1930s Adelphi building and Institute of Electrical Engineers (which although not listed, are noted as a building of merit in Westminster Councils Adelphi and Savoy Conservation Area Audits). The pontoon of the pier is also approximately 36 metres from the centre of the Grade I listed Cleopatra’s Needle and the ramp is approximately 55 metres from the same point. This is closer than the relocated Tattershall Castle is to Grade II RAF memorial. Finally as can be seen in Figure 1.4 the pier is arguably within the setting of the Grade II listed Waterloo Bridge which can be seen in the background. We therefore consider our approach to be consistent with this scheme consented by WCC (application ref. 03/00392/FULL).

Figure 1.4 Savoy Pier ramp

1.2.24 Furthermore, planning and listed building approval (WCC ref.

11/07569/FULL and 12/01456/LBC) for a new Savoy Pier comprising a

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substantial new pier with associated access facilities and buildings on the Thames wall was granted in June 2012. The mooring pontoon will run from the Grade II listed Waterloo Bridge to just downstream of Grade I listed Cleopatra’s Needle. The pontoon will be connected to a permanent

‘boat house’ structure comprising two 200m2 rooms on a 130m long pontoon which will sit alongside the listed wall. These were apparently considered acceptable by WCC, but raise similar heritage issues to the Victoria Embankment Foreshore works.

1.2.25 WCC also indicate that the width of the path will be reduced to approximately 2.75m. We would accept that this is slightly worse than the existing situation but not significantly. However, it is far better than the approved schemes at Savoy and Millbank piers. The following is a comparison of clear space on the pavement adjacent to these other structures. We would note that these figures are estimated from plans and photographs.

a. Existing Tattershall Castle steps provide clear space of 3.25m.

b. Existing Savoy Pier provide clear space of less than 2m, due to a sphinx bench adjacent to the ramp.

c. Existing Millbank Pier ramp provide clear space of less than 1.2m due to location of a lamp column.

1.2.26 We have provided a ramp to improve accessibility for the Tattershall Castle mooring, which is consistent to approaches at the consented Millbank and Savoy Piers. Given that the Tattershall Castle has not been modified to make it fully accessible we believe that it is reasonable to provide an alternative solution to the ramp which would reduce the effect on the listed wall. The details of the access structures including the ramp would be for the approval of WCC in consultation with HBMCE through DCO Requirement VCTEF10 so they would be the effective decision maker with regard to the final proposals. If they consider our proposed solution unreasonable given the visual effect, we can discuss alternatives solutions which would be more acceptable.

1.2.27 We consider that through discussions on the design as set out above, the access brow/gangways can be designed to be an improvement on the existing situation and reduce the potential clutter created by such structures.

Degree of harm

1.2.28 We note that in both WCC (final paragraph on page 2) and HBMCE (para. 3.5) representations of 3 March 2014, they do not argue that the relocation of the Tattershall Castle to either the temporary or permanent location causes substantial harm. This is significant and seems inconsistent with other aspects of their 3 March 2014 submissions.

Public benefit

1.2.29 In para. 3 on p. 3 of WCC’s response and para. 3.7 of HBMCE’s response of 3 March 2014, both parties consider that the benefits of the foreshore

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structure outweigh the level of harm they consider to be caused to the heritage assets in the vicinity. However, in terms of public benefit neither WCC nor HBMCE provide any reasoned policy or other justification for their view that the Tattershall Castle provides no public benefit. We would draw the attention of the ExA to what we have said in response to the ExA’s question 55.3b, which summarises the arguments made in Appendix P of the Planning Statement.

1.2.30 As we conclude in answer to the ExA’s question 55.3b, the significant permanent or long-term public benefits of the scheme relate to improvements in river water quality, a new area public realm from which to enjoy the river and the retention of an established business. We consider that these benefits would be substantial and outweigh the harm caused to the heritage assets, in terms of the balance required by NPS para. 4.10.14.

Tattershall Castle consideration of alternatives

1.2.31 Both WCC and HBMCE consider that Thames Water has failed to seek alternative means of mitigating the impact on the affected heritage assets through the following:

a. Relocating the Tattershall Castle to another less sensitive location along the Thames.

b. Relocating the vessel to an alternative accommodation/location on land.

c. Offering an appropriate compensation package to the owners of the Tattershall Castle for the closure of their business.

1.2.32 We did not consider it was necessary to go to these lengths as our assessment of the effects of moving the Tattershall Castle from its current location to a new permanent location 87 metres away do not provide sufficient justification for it to be relocated further afield. We have assessed this location as suitable based on our environmental impact assessment and planning assessment. The responses to the ExA questions have not raised substantial new matters which would change our assessment.

1.2.33 The relocation of Tattershall Castle does not result in significant environmental effects and, as stated in the Planning Statement (Appendix P, para. P.5.115), we consider a temporary nearby relocation and a permanent location close to the existing is appropriate insofar as local policy designations and nearby land uses are concerned for the following reasons:

a. The use of the vessel in this location is supported in Central Activities Zone and Blue Ribbon Network policy.

b. The vessel was granted planning permission in the context of very similar built heritage designations and local policy principles in respect of its significance and association with London as contained in current local policy.

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c. Current local policy is demonstrably concerned with proposals for additional vessels rather than relocations.

d. Several permissions have been granted for a significant refit and changes to the appearance of the vessel, along with on-going licenses for the use and the gangway. These supported and facilitated the continued use of the vessel for many years.

e. The relocation of the Hispaniola to facilitate the footbridge project was permitted without question of the principle of the use continuing at the nearby relocation site or abandonment of use at the original site.

1.2.34 Para. 4.8.5 of the NPS requires applicants to assess any effects of replacing an existing development or use of the site with the proposed project, or preventing a development or use on a neighbouring site from continuing. Para. 4.8.19 of the NPS requires applicants to mitigate their proposals by minimising the direct effects of a project on the existing use of the proposed site, or proposed uses near the site by the application of good design principles, including the layout of the project. These both clearly imply that impacts on existing land uses should be minimized and we believe that our proposals to move the Tattershall a short distance is an appropriate design solution to mitigate the effects on the existing land use.

1.2.35 The NPS also states (para. 4.15.10) that the decision maker should have regard to potential socio-economic impacts that are both relevant and important. The decision maker is required to consider whether an adverse impact would be temporary or reversible within a reasonable timescale. In this case, it is both relevant and important to make reasonable proposals to relocate, rather than extinguish, a business operation that directly employs 20 to 40 people (varying by season). If the Tattershall Castle were not relocated nearby, it would likely experience a significant decline in trade since it relies on its central London riverside location near transport hubs, tourist walking routes and attractions, which would impact on its viability. At present, publicly accessible boats are unusual in central London. The Queen Mary at Savoy Pier closed in 2009 and was in a lower footfall location. Savoy Pier is now the subject of redevelopment proposals for passenger services. Quieter locations further from transport hubs, such as Lambeth or Grosvenor Embankment, would also not have sufficient footfall. The Hispaniola’s mooring has good footfall but is in beneficial use and this mooring could not accommodate the Tattershall Castle.

1.2.36 Figure 1.1 to Figure 1.3 also support our view that the river is congested through central London so finding an alternative location would be extremely difficult.

1.2.37 In response to comments from WCC at several meetings regarding their objection to our proposals to relocate the Tattershall, we discussed with the owners possible options for relocations between Waterloo and Hungerford Bridges and across the river in Lambeth between the London Eye and Hungerford Bridge. However, these options were not considered to be commercially acceptable to the owners of the Tattershall.

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1.2.38 We have not considered relocating the use of the Tattershall to an alternative location as the Tattershall Castle is a vessel and its use as a bar/restaurant on the river is its unique selling point which cannot be replicated by a land-based solution.

1.2.39 With respect to simply offering a compensation package to close their business this was not considered because our assessment was that the proposed alternative location 87 metres away did not give rise to new significant environmental effects and as such there was no justification for Thames Water to take an approach which would have involved very considerable cost to its customers. We would have to:

i acquire and extinguish the Tattershall’s mooring lease using DCO powers

ii compensate TCG Bars for business extinguishment – this will be substantial as they have rights to operate until 2029 – and we might have to arrange for removal and scrapping of the ship

iii compensate Crown Estate and PLA for loss of mooring income

iv compensate City of Westminster for loss of access licence income

1.2.40 The Tattershall Castle’s current mooring is secured by lease/agreements with the Crown Estate, the PLA, and WCC, which all run until April 2029. In accordance with accepted practice, the project has sought to minimise the impact of the proposals on occupiers and businesses by (in this case) identifying a potentially suitable alternative mooring which is within essentially the same setting and trading location, and which is supported by both the owners of the Tattershall and the Crown Estate. Furthermore, both the Mayor of London and the PLA are supportive of retaining river-related uses on the Thames and were keen to ensure an alternative mooring was secured.

1.2.41 As a result of our proposal, the owners of Tattershall Castle did not object to the compulsory purchase order (CPO). Had we proposed an alternative then we are of the firm belief that they would have contested this on the basis there was suitable mitigation and an alternative solution to the extinguishment of their business.

1.2.42 Finally HBMCE and WCC consider that our approach is inconsistent with our house boats policy. Firstly we have treated each case on its merits so where we have had to relocate a vessel because of our physical works we have done so. With respect to the Tattershall castle this involves relocating it a short distance upstream. In other instances we have included proposals to relocate a house boat at Putney, the Battersea Barge at Heathwall Pumping station and the President at Blackfriars Bridge Foreshore. The house boats policy deals with the secondary effects of the works such as noise and allows for the relocation of the vessels by agreement. Parallels should be drawn with the off-site mitigation policy for temporary rehousing and secondary glazing etc.

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Archaeological mitigation for dredging

1.2.43 In response to para. 3.4 of HBMCE’s final written submission which relates to the proposed dredging at the site of the Tattershall Castle relocation, we respond as follows: the low potential for archaeological finds at this site is set out in the Environmental Statement (Vol 17, Section 7) and our subsequent submissions made in September 2013 (regarding proposed minor changes) and October 2013 (in response to the ExA’s procedural decision). We acknowledge, however, that this does not eliminate the possibility of archaeological remains in the area of dredging. Ongoing archaeological evaluation will allow us to further refine our understanding of the potential for remains. We confirm that we will develop and agree an approach to monitoring of the dredging in due course following an agreed process. The following extract from our response to first written question 3.8 (Doc ref: APP03) sets out this approach:

“8.8.4 In the event that this archaeological evaluation confirms, or identifies reasonable potential for, archaeological assets within the proposed area of dredging and in dredged areas not exposed at low tide, the mitigation would comprise an archaeological watching brief. Such a watching brief would be undertaken by a suitably qualified and experienced archaeologist present on board the excavator pontoon during all dredging activity. The work would be carried out in accordance with the agreed methodology contained within the Site-specific Archaeological Written Scheme of Investigation, to be prepared in line with the Overarching Archaeological Written Scheme of Investigation (Doc ref: 7.13). This would include protocols to ensure that national and local archaeological curators, and the PLA, are notified of any significant archaeological discoveries.”

Appendix

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Appendix A Figure 11.6.4 and 11.6.6 from Environmental Statement Vol 17

Appendix

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Operational phase verifiable photomontage

Expanded image

Expanded image

Victoria Embankment ForeshoreCity of Westminster

Townscape and visualViewpoint 2.14 Operational phase verifiable photomontageVol 17 Figure 11.6.41PL03-TS-40461January 2013

Environmental Statement

Technical informationLocation: Viewpoint 2.14: View northwest from the Thames Path alongside Jubilee GardensDate taken: 8 March 2011Time taken: 13.10Tide position: High tideFocal length: 51.677mm

This verifiable photomontage shows an illustration of the site in Year 1 of operation. The layout of the proposed development may change within the zones shown on the Site works parameter plan [see volume of figures – Section 1], however the assessment of effects would be no worse than that described in the Environmental Statement Vol 17 Victoria Embankment Foreshore – Section 11 Townscape and visual.

Current baseline

Westminster Palace London Eye Millennium Pier Thames Path

RAF Memorial Ministry of Defence Golden Jubilee footbridge

New river wallVentilation columns

Relocated Tattershall Castle vesselReinstated London plane trees

Hispaniola vesselTattershall Castel vessel

Floodable terrace

Operational phase verifiable photomontage

Expanded image

Expanded image

Expanded image

Victoria Embankment ForeshoreCity of Westminster

Townscape and visualViewpoint 2.19 Operational phase verifiable photomontageVol 17 Figure 11.6.51PL03-TS-40463January 2013

Environmental Statement

Technical informationLocation: Viewpoint 2.19: View north from the Thames Path adjacent to Westminster Millennium PierDate taken: 6 December 2011Time taken: 12.33Tide position: High tideFocal length: 51.67 mm

This verifiable photomontage shows an illustration of the site in Year 1 of operation. The layout of the proposed development may change within the zones shown on the Site works parameter plan [see volume of figures – Section 1], however the assessment of effects would be no worse than that described in the Environmental Statement Vol 17 Victoria Embankment Foreshore – Section 11 Townscape and visual.

Current baseline Golden Jubilee footbridge

New river wallVentilation columns

Relocated Tattershall Castle vessel

Expanded image

Tattershall Castle vessel

Floodable terrace

Tattershall Castle vessel Hispaniola vessel

Operational phase night time verifiable photomontage

Expanded image

Expanded imageVictoria Embankment ForeshoreCity of Westminster

Townscape and visualViewpoint 2.14Operational phase verifiable photomontageVol 17 Figure 11.6.61PL03-TS-40462January 2013

Environmental Statement

Technical informationLocation: Viewpoint 2.14: View northwest from the Thames Path alongside Jubilee GardensDate taken: 1 March 2012Time taken: 18.16Tide position: High tideFocal length: 51.685mm

This verifiable photomontage shows an illustration of the site in Year 1 of operation. The layout of the proposed development may change within the zones shown on the Site works parameter plan [see volume of figures – Section 1], however the assessment of effects would be no worse than that described in the Environmental Statement Vol 17 Victoria Embankment Foreshore – Section 11 Townscape and visual.

Current baseline Westminster Palace

London Eye Millennium Pier Thames Path

Whitehall CourtMinistry of Defence Golden Jubilee footbridge

Ventilation columnsRelocated Tattershall

Castle vessel

Hispaniola vesselTattershall Castel vessel

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.