PS/1/A United Utilities Water Limited (Eccles Waste Water Treatment Works) CPO 2016 Engineering proof of evidence Robert Longworth BSc(Hons) CEng MIMMM 22 May 2018 Peel Land and Property Mott MacDonald Spring Bank House 33 Stamford Street Altrincham WA14 1ES United Kingdom T +44 (0)161 926 4000 F +44 (0)161 929 8915 mottmac.com Peel Land and Property Peel Dome Intu Trafford Centre United Utilities Water Limited Trafford City PS/1/A Manchester (Eccles Waste Water M17 8Pl Mott MacDonald Treatment Works) CPO 2016 Engineering proof of evidence Robert Longworth BSc(Hons) CEng MIMMM 22 May 2018 Mott MacDonald Limited. Registered in England and Wales no. 1243967. Registered office: Mott MacDonald House, 8-10 Sydenham Road, Croydon CR0 2EE, Peel Land and Property United Kingdom Mott MacDonald | United Utilities Water Limited (Eccles Waste Water Treatment Works) CPO 2016 Engineering proof of evidence Robert Longworth BSc(Hons) CEng MIMMM This document is issued for the party which commissioned it and for specific purposes connected with the above-captioned project only. It should not be relied upon by any other party or used for any other purpose. We accept no responsibility for the consequences of this document being relied upon by any other party, or being used for any other purpose, or containing any error or omission which is due to an error or omission in data supplied to us by other parties. This document contains confidential information and proprietary intellectual property. It should not be shown to other parties without consent from us and from the party which commissioned it. This Re por t has be en p rep are d solely for use by t he p arty w hich c om mission ed it (the 'Client') i n co nnecti on wit h the cap tione d p roject . It s hould not be used for any oth er p urp ose. N o p erso n ot her tha n th e Client or any party who has expr essly a gre ed t er ms of relia nce wit h us (the 'Recipie nt(s )') m ay r ely on the cont ent, info rma tion or any view s exp ress ed in the R epo rt. This R epo rt is co nfide ntial and c ont ains p rop riet ary in tellect ual p rop erty and we ac cept no duty of ca re, resp onsibility or li ability t o any oth er recipi ent o f this R epo rt. N o re pre sent ation , wa rran ty o r un dert aking , exp ress or i mplie d, is made an d no res ponsi bility or liability is acce pted by us to any p arty oth er t han the Cli ent or a ny Reci pient (s), as t o the accu racy or c om plete ness of th e info rm ation cont aine d in t his Rep ort. 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PS/1/A | 22 May 2018 Mott MacDonald | United Utilities Water Limited (Eccles Waste Water Treatment Works) CPO 2016 Engineering proof of evidence Robert Longworth BSc(Hons) CEng MIMMM Contents 1 Introduction 1 1.1 Personal details 1 1.2 Witness declaration 2 1.3 My involvement in the scheme 2 1.4 Scope of evidence 3 1.5 Structure of evidence 3 2 CPO scheme engineering description 5 2.1 Tunnel route and geometry 5 2.2 The CPO Scheme 6 2.3 Ground conditions 8 2.4 Tunnelling operations 11 2.5 Further information on the CPO scheme 17 3 Engineering overview of the land area affected by the CPO scheme 18 3.1 Overview 18 3.2 Access routes into Port Salford and the Stadium Land 19 3.3 Water courses 21 3.4 Eccles WwTW existing outfall 21 3.5 Built structures 22 4 Land use and future development 23 4.1 Overview 23 4.2 Port Salford 24 4.3 Rail line – consented infrastructure 27 4.4 Port Salford masterplan 30 4.5 Port Salford master plan engineering development 32 4.6 Rail connection and rail line development 36 4.7 Salteye Brook diversion masterplan scheme 43 4.8 Topography and ground works for Salteye Brook diversion 44 4.9 CoSCoS Stadium site 48 4.10 CoSCoS retail site 50 5 Schedule and use of land plots 53 5.1 Introduction to land plots in the CPO 53 6 Plots 3, 3E, 3I, 3S and 3T 56 PS/1/A | 22 May 2018 Mott MacDonald | United Utilities Water Limited (Eccles Waste Water Treatment Works) CPO 2016 Engineering proof of evidence Robert Longworth BSc(Hons) CEng MIMMM 6.1 Location and ownership of plots 3, 3E, 3I, 3S and 3T 56 6.2 Description of plots and their current and proposed use 56 6.3 Rights sought by the order for plot 3E 61 6.4 Rights sought by the order for plot 3 63 6.5 Rights sought for plots 3I, 3S and 3T 65 6.6 Justification of the rights claimed 66 6.7 Conflicts with existing and proposed use 70 6.8 Rights offered by CoSCoS and PSL 72 6.9 Conclusion on plots 72 7 Plots 3B, 3C and 3D 73 7.1 Location and ownership of plots 3B, 3C and 3D 73 7.2 Description and current use 73 7.3 Rights sought for plots 3B, 3C and 3D 75 7.4 Implications of the rights for the landowner 77 7.5 Justification of the rights claimed 81 7.6 Conflicts with existing and proposed use 87 7.7 Rights offered by CoSCoS 87 7.8 Conclusions on the plots 88 8 Plots 3P, 3Q and 3R 89 8.1 Location and ownership of plots 3P, 3Q and 3R 89 8.2 Description and current use 89 8.3 Rights sought by UU 90 8.4 Justification of the rights claimed 92 8.5 Conflicts with existing and proposed use 95 8.6 Rights offered by CoSCoS 96 8.7 Conclusions on the plots 96 9 Plots 3J, 3L, 3M, and 3N 98 9.1 Location and ownership of plots 3J, 3L, 3M and 3N 98 9.2 Description and current use 98 9.3 Rights sought by UU 100 9.4 Justification of rights claimed 102 9.5 Conflicts with existing and proposed use 104 9.6 Rights offered by CoSCoS and PSL 105 9.7 Conclusions on the plots 105 10 Plots 3F, 3G ,3H, and 3K 106 10.1 Location and ownership of plots 3F, 3G, 3H and 3K 106 10.2 Description and current use 106 10.3 Rights sought by UU for plot 3F 108 10.4 Rights sought by UU for Plot 3G 109 PS/1/A | 22 May 2018 Mott MacDonald | United Utilities Water Limited (Eccles Waste Water Treatment Works) CPO 2016 Engineering proof of evidence Robert Longworth BSc(Hons) CEng MIMMM 10.5 Plots 3H and 3K 109 10.6 Justification of the rights claimed 111 10.7 Rights offered by CoSCoS 114 10.8 Conclusions on the plots 114 11 Plots 4B, 4F, 4P, 4W, 4Z, 4AA, 4AF, 4AG, 4AM, 4AN, 4AP, 5G, 5H, 5J, and 5P 115 11.1 Location and ownership of plots 4B, 4F, 4P, 4W, 4Z, 4AA, 4AF, 4AG, 4AM, 4AN, 4AP, 5G, 5H, 5J, and 5P 115 11.2 Description and current use 116 11.3 Rights sought for plot 5G 117 11.4 Rights sought for plots 5P, 5H and 4W 118 11.5 Rights sought for 4F, 4B, 4AP, 5J, 4AA, 4AG and 4AM 119 11.6 Justification of the rights 120 11.7 Conflicts with existing and proposed use 123 11.8 Rights offered by PSL 124 11.9 Conclusions on the plots 124 12 Plots 4I, 4Q, 4R, 4S, 4V, 4AB, 4AC, 5, 5D and 5M 125 12.1 Location and ownership of plots 4I, 4Q, 4R, 4S, 4V, 4AB, 4AC, 5, 5D and 5M 125 12.2 Description and current use 126 12.3 Rights sought by UU for plots 4I, 4Q, 4S, and 4AC 127 12.4 Rights sought by UU for plots 4R and 5M 129 12.5 Rights sought by UU for plots 4V, 4AB and 5 130 12.6 Justification of the rights claimed 132 12.7 Conflicts with existing and proposed use 134 12.8 Rights offered by PSL 134 12.9 Conclusion on plots 135 13 Plots 4G, 4H, 4J, 4K, 4M, 4N, 4P, 4T, 4AD, 4AE, 4AF, 4AH, 4AJ, 4AK, 4AL, 5C, 5E, 5F, 5L, 5R, 5Q and 5T 136 13.1 Location and ownership of Plots 4G, 4H, 4J, 4K, 4M, 4N, 4P, 4T, 4AD, 4AE, 4AF, 4AH, 4AJ, 4AK, 4AL, 5C, 5E, 5F, 5L, 5R, 5Q and 5T 136 13.2 Description and current use 137 13.3 Rights sought 138 13.4 Justification of the rights claimed 139 13.5 Conflicts with existing and proposed use 145 13.6 Rights offered by PSL 149 13.7 Conclusion on plots 150 14 Open offer to UU 151 14.1 Introduction 151 14.2 The offer 152 14.3 Access 153 14.4 Build Over Agreement 154 PS/1/A | 22 May 2018 Mott MacDonald | United Utilities Water Limited (Eccles Waste Water Treatment Works) CPO 2016 Engineering proof of evidence Robert Longworth BSc(Hons) CEng MIMMM 14.5 Site compound 156 14.6 Enabling Works for Salteye Diversion 158 14.7 Summary 159 15 Conclusions and Summary 160 15.1 Rights sought in the order 160 15.2 Tunnelling 161 15.3 Proposed rights 163 16 Appendices list 165 PS/1/A | 22 May 2018 Mott MacDonald | United Utilities Water Limited (Eccles Waste Water Treatment Works) CPO 2016 1 Engineering proof of evidence Robert Longworth BSc(Hons) CEng MIMMM 1 Introduction 1.1 Personal details My name is Robert Longworth.