Stephanie Malik
Planning and Borough Development
Kensington Town Hall
Hornton Street
London W2 7NX
Sent by email: planning@rbkc.gov.uk
Your ref
Our ref
Name
Phone
E-Mail
PP/14/07125
37665
Mark Dickinson
0203 577 9998 devcon.team@thameswater.co.uk
7 November 2014
Dear Ms Stephanie Malik
Masterpiece London Art, Antique and Design Fair, South Grounds, Royal
Hospital Chelsea, Royal Hospital Road, London, SW3 4SR (Application Ref:
PP/14/07125)
Thames Water Utilities Limited (TWUL) would like to provide comment on the
Royal Hospital Chelsea and Masterpiece London Art, Antique and Design Fair
(Masterpiece) planning application, with regards to the Thames Tideway Tunnel.
We note that the application is for the temporary use of South Grounds of the
Royal Hospital Chelsea for Masterpiece London Art, Antique and Design Fair
(‘Masterpiece’) for a period of eight days each year, to include erection of a temporary marquee for 41 days from the first Friday in June each year, together with temporary plant, temporary disabled parking and other temporary associated works ancillary to this use.
TWUL has no objection to the planning application for Masterpiece, which has been held at the Royal Hospital Chelsea each year since 2011 following the
Royal Horticultural Society’s annual Chelsea Flower Show. It is understood that a separate planning application was submitted each year for the past events and that this application seeks to secure the event for the future and the regular source of income for Royal Hospital Chelsea. The arrangements proposed are the same as utilised for 2014.
TWUL has an interest in the Royal Hospital Chelsea, including the Bull Ring, as the Ranelagh Sewer (Main Line) runs towards the River Thames below the South
Grounds and Ranelagh Gardens, and the Thames Tideway Tunnel site at
Chelsea Embankment Foreshore will be partially within and adjacent to the grounds. TWUL has been liaising with the Royal Hospital Chelsea and other stakeholders including the Royal Borough of Kensington and Chelsea (RBKC) regarding the Thames Tideway Tunnel since 2010.
Thames Water Utilities Limited
Ground Floor East
Clearwater Court
Vastern Road
Reading
RG1 8DB
T 020 3577 9077
I www.thameswater.co.uk
Registered in England and Wales
No. 2366661 Registered office
Clearwater Court, Vastern Road, Reading,
Berkshire, RG1 8DB
1

It is noted that the application documents do not make reference to the Thames
Tideway Tunnel project but we can confirm we are aware of the event and have taken account of both it and the Chelsea Flower Show in our application for development consent and in the now consented scheme.
Thames Tideway Tunnel
As you are aware, Thames Water Utilities Ltd. (TWUL) submitted an application for development consent under the Planning Act 2008 for the construction and operation of a wastewater storage and transfer project of national significance, known as the Thames Tideway Tunnel. The Secretaries of State granted development consent for this application on 12 September 2014, and it came into force on 24 September 2014. This consent is a material consideration of substantial weight in the determination of all applications in the vicinity of the project.
The National Policy Statement for Waste Water and the Examining Authority’s
Report make clear that the Government considers that there is an established, urgent need for this nationally significant infrastructure. The tunnel alignments and sites that form part of the Thames Tideway Tunnel are safeguarded by means of Article 52 of the Thames Water Utilities Limited (Thames Tideway
Tunnel) Order 2014 . Article 52 requires the local planning authority to consult
TWUL and to take into account the recommendation of the undertaker before granting planning permission for development to which this article applies. To date we have not yet been formally consulted although RBKC have the
Safeguarding Plans and the GIS shapefiles of the safeguarded area.
The project is also supported by regional policy in the London Plan Policy 5.14 –
Water Quality and Wastewater Infrastructure and the Thames Tideway Tunnel is referenced in local policy (RBKC Core Strategy 2010, Policy CE2 - Flooding).
The Thames Tideway Tunnel works will commence in 2015 and be operational in
2023. At Chelsea Embankment Foreshore works are programmed to commence in 2017 for approximately five years, which will coincide with five event seasons at Royal Hospital Chelsea.
Chelsea Embankment Foreshore
The Chelsea Embankment Foreshore site will intercept the Ranelagh Combined
Sewer Overflow (CSO), connect to the northern Low Level Sewer No.1 and transfer flows into the main tunnel beneath the River Thames.
There will be a new foreshore structure opposite the Bull Ring Gate to enclose the CSO drop shaft, CSO interception chamber, valve chambers and the new
CSO outfall and there will be an overflow weir chamber partially below the boundary wall of Ranelagh Gardens on the existing northern Low Level Sewer
No. 1 within Chelsea Embankment. Other works in Chelsea Embankment for utilities and connections are required and there will be closures and diversions to the pedestrian footpaths. See Figure 1 below for the site context and location plan.
2

Figure 1: Chelsea Embankment Foreshore: Site context and location plan
The new foreshore structure will form an area of public realm with a lower terraced area flowing around its river-facing sides. The details of the public realm and terraces will be developed to a detailed design in line with the site-specific design principles and the approved parameters. The final designs and materials will be approved by RBKC in consultation with other stakeholders subject to the
Requirements (similar to planning conditions) in Schedule 3 of the Order.
The construction and operational design for the site at Chelsea Embankment
Foreshore has been developed through public consultation and engagement with the Royal Borough of Kensington and Chelsea (RBKC), English Heritage,
Environment Agency, Royal Hospital Chelsea and the Royal Horticultural
Society.
In developing the construction works for the site the project had consideration of the annual events at Royal Hospital Chelsea, including Masterpiece, and has sought to accommodate the events requirements identified by the Royal Hospital
Chelsea, through the site-specific Code of Construction Practice (CoCP) Part B
The contractor must comply with CoCP and the relevant clauses are included in our comments on the application below.
The Royal Hospital Chelsea and TWUL have also signed property agreement
Heads of Terms and are progressing towards the final property agreement. The
Heads of Terms refer to accordance with the CoCP.
3

General comments on the Masterpiece planning application
Appendix E of the Masterpiece Transport Statement is a Construction
Management Plan, setting out measures and initiatives to control the routing and timing of construction vehicle access, confirming the applicant ’s commitment to actively managing construction vehicle activity so as to ensure that there will be no material impact on the adjacent public highway.
We note the paragraph 2.23 of the document identifies that, in order to facilitate the smooth operation of the construction and breakdown processes, it will be necessary to apply for the temporary suspension of parking bays in the immediate vicinity of the Bull Ring Gate. During the Chelsea Embankment
Foreshore construction programme the parking spaces in the Bull Ring will be suspended by TWUL for periods.
Liaison
The Public Liaison section of the Construction Management Plan (paragraphs
2.33 – 2.35) explains that the promoters of Masterpiece will hold a public consultation / liaison meeting for local residents/businesses, in order to ensure that local residents/ businesses are fully appraised of the construction and breakdown process. It is requested by TWUL that we are included in the liaison meetings in advance of, and during, the Thames Tideway Tunnel construction years. It will be important that TWUL, the Royal Hospital Chelsea, Masterpiece and the Royal Horticultural Society consult and coordinate on the set up, actual event and set down of the Chelsea Flower Show and Masterpiece to minimise impact on local residents and the road network.
The Thames Tideway Tunnel CoCP Part B commits to the following:
Communications and community/stakeholder liaison: The Royal
Hospital Chelsea shall be included as a stakeholder for the purposes of the community liaison plan.
Control measures: The contractor shall include the dates of the Chelsea
Flower Show and Masterpiece events, including setup and take-down days, within the construction programme. The contractor shall establish a protocol for communication with the Royal Hospital Chelsea and the organisers of events at that venue. Before each event, the contractor shall inform the Royal Hospital Chelsea and event organisers of planned construction activities during the events.
The contractor for the construction works at Chelsea Embankment Foreshore will be appointed in 2015 and will then seek to liaise and plan ahead before the main works commence in 2017.
Pedestrian access, traffic management and other mitigation
TWUL will work with event organisers to minimise disruption to both traffic and pedestrians and have made the following commitments in the CoCP Part B:
Traffic Management: Access through the Bull Ring entrance for set-up and take-down of the Chelsea Flower Show and Masterpiece events shall be maintained. The public access during the events shall also be maintained. Emergency access from Chelsea Embankment (A3212) shall
4

be maintained during the events via the Bull Ring, river and ambulance gates.
Event Restrictions: Management arrangements during events in the adjacent area, including the utility diversion works, shall be confirmed in consultation with the local highway authority, the Royal Horticultural
Society, the Royal Hospital Chelsea and Transport for London .
It is noted that pedestrians accessing the Bull Ring and Ambulance gates from
Chelsea Bridge Road will have to cross and re-cross a TfL red route main road in order to circumvent the Thames Tideway Tunnel overflow chamber site occupying the north-side footway just east of the Ambulance gate. Traffic marshals will be required to ensure pedestrians cross safely and to regulate the traffic flow.
To mitigate against effects on the events at Royal Hospital Chelsea including
Masterpiece, the Thames Tideway Tunnel CoCP Part B states:
Control measures: As far as is reasonably practical, during Chelsea
Flower Show and Masterpiece events (not including set-up and takedown periods), the contractor shall: a) avoid activities that generate high levels of noise b) consult with the Royal Hospital Chelsea and event organisers to investigate and implement additional mitigation measures.
Conclusion
TWUL has no objection to the planning application for Masterpiece which has been held at the Royal Hospital Chelsea each year since 2011, following the
Royal Horticultural Society’s annual Chelsea Flower Show. TWUL has made commitments to mitigate possible construction effects on the events at the Royal
Hospital Chelsea and there will need to be full coordination so as to minimise disruption to the Thames Tideway Tunnel and Masterpiece programmes, and minimise impact on local residents and road network.
In order to assist TWUL and the contractor in achieving the commitments, TWUL would like to see informatives on the decision notice relating to the following items:

TWUL and the Thames Tideway Tunnel project team are to be included in any Masterpiece community liaison groups.

TWUL and the Thames Tideway Tunnel project team are to be consulted by RBKC in respect of any subsequent submissions pursuant to any traffic management planning conditions
We would be happy to communicate directly with Masterpiece or through the
Royal Hospital Chelsea, who as stated above shall be included as a stakeholder in the Thames Tideway Tunnel community liaison plan and consulted with on matters such as construction management arrangements during the events in the adjacent area.
We are engaged in productive discussions with RBKC regarding the Thames
Tideway Tunnel on the proposals at Chelsea Embankment Foreshore and the
Cremorne Wharf Depot site also in the borough. These meetings will continue as we transition from planning to construction.
5

I trust the above information is of use as you consider the planning application, but please do not hesitate to contact me if you have any queries.
Waste Comments
There are public sewers crossing or close to your development. In order to protect public sewers and to ensure that Thames Water can gain access to those sewers for future repair and maintenance, approval should be sought from
Thames Water where the erection of a building or an extension to a building or underpinning work would be over the line of, or would come within 3 metres of, a public sewer. Thames Water will usually refuse such approval in respect of the construction of new buildings, but approval may be granted in some cases for extensions to existing buildings. The applicant is advised to contact Thames
Water Developer Services on 0845 850 2777 to discuss the options available at this site.
Thames Water recommends the installation of a properly maintained fat trap on all catering establishments. We further recommend, in line with best practice for the disposal of Fats, Oils and Grease, the collection of waste oil by a contractor, particularly to recycle for the production of bio diesel. Failure to implement these recommendations may result in this and other properties suffering blocked drains, sewage flooding and pollution to local watercourses.
Thames Water would advise that with regard to sewerage infrastructure capacity, we would not have any objection to the above planning application.
Thames Water requests that the Applicant should incorporate within their proposal, protection to the property by installing for example, a non-return valve or other suitable device to avoid the risk of backflow at a later date, on the assumption that the sewerage network may surcharge to ground level during storm conditions.
Surface Water Drainage - With regard to surface water drainage it is the responsibility of a developer to make proper provision for drainage to ground, water courses or a suitable sewer. In respect of surface water it is recommended that the applicant should ensure that storm flows are attenuated or regulated into the receiving public network through on or off site storage. When it is proposed to connect to a combined public sewer, the site drainage should be separate and combined at the final manhole nearest the boundary. Connections are not permitted for the removal of groundwater. Where the developer proposes to discharge to a public sewer, prior approval from Thames Water Developer
Services will be required. They can be contacted on 0845 850 2777. Reason - to ensure that the surface water discharge from the site shall not be detrimental to the existing sewerage system.
No impact piling shall take place until a piling method statement (detailing the depth and type of piling to be undertaken and the methodology by which such piling will be carried out, including measures to prevent and minimise the potential for damage to subsurface sewerage infrastructure, and the programme for the works) has been submitted to and approved in writing by the local planning authority in consultation with Thames Water. Any piling must be undertaken in accordance with the terms of the approved piling method statement. Reason: The proposed works will be in close proximity to
6

underground sewerage utility infrastructure. Piling has the potential to impact on local underground sewerage utility infrastructure. The applicant is advised to contact Thames Water Developer Services on 0845 850 2777 to discuss the details of the piling method statement.
Water Comments
Thames Water recommend the following informative be attached to this planning permission. Thames Water will aim to provide customers with a minimum pressure of 10m head (approx 1 bar) and a flow rate of 9 litres/minute at the point where it leaves Thames Waters pipes. The developer should take account of this minimum pressure in the design of the proposed development.
No impact piling shall take place until a piling method statement (detailing the depth and type of piling to be undertaken and the methodology by which such piling will be carried out, including measures to prevent and minimise the potential for damage to subsurface water infrastructure, and the programme for the works) has been submitted to and approved in writing by the local planning authority in consultation with Thames Water. Any piling must be undertaken in accordance with the terms of the approved piling method statement. Reason:
The proposed works will be in close proximity to underground water utility infrastructure. Piling has the potential to impact on local underground water utility infrastructure. The applicant is advised to contact Thames Water Developer
Services on 0845 850 2777 to discuss the details of the piling method statement.
Yours sincerely
Mark Dickinson
CC. Chris Colloff – Thames Water
7