100-RG-CMN-00000-000004| 24 July 2012

Response to the Thames Tunnel (Selborne) Commission
Summary report

Thames Tideway Tunnel Response to the Thames Tunnel (Selborne) Commission
List of contents
Page number

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Background ...................................................................................................... 1 Executive summary ......................................................................................... 2 Introduction ...................................................................................................... 4 3.1 4.1 4.2 Context of the Thames Tunnel Commission‟s report ............................... 4 Regulatory drivers ................................................................................... 5 Other legislative factors ........................................................................... 6 Dissolved oxygen criteria ......................................................................... 9 Economic climate .................................................................................... 9 SuDS and GI ......................................................................................... 10 Other alternatives .................................................................................. 11 Alternative recommendations by the Commission ................................. 14 Assumptions .......................................................................................... 15 Modelling ............................................................................................... 15 Aesthetic ................................................................................................ 16 Public health .......................................................................................... 16 Regulatory drivers and requirements ............................................................ 5

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Reassessment of targets ................................................................................. 9 5.1 5.2

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Alternatives..................................................................................................... 10 6.1 6.2 6.3

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Assumptions and modelling ......................................................................... 15 7.1 7.2

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Aesthetic and public health issues .............................................................. 16 8.1 8.2

Response to Thames Tideway Tunnel (Selborne) Commission

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1 Background

1
1.1.1

Background
The Thames Tunnel (Selborne) Commission1 was set up in July 2011, sponsored by five London boroughs, Hammersmith and Fulham, Kensington and Chelsea, Richmond, Southwark and Tower Hamlets, under the chairmanship of The Earl of Selborne GBE FRS. Other members of the Commission included Professor Richard Ashley, Henry Henderson, Dr Jean Venables CBE and Dr.I R. Frans H.M. van de Ven. The stated aim and purpose of the Thames Tunnel Commission was fourfold: a. review the findings of previous studies relating to the Thames Tideway Tunnel and reassess the assumptions made in those studies in the light of subsequent research and more up-to-date scientific knowledge b. examine the recent responses of other world cities to the problems of pollution, flooding and potential water shortages c. consider evidence from stakeholders, experts in the field and other interested parties

1.1.2

d. reassess the options for addressing EU Directive 91/271/EC in the light of developing international perspectives on wastewater management and in the light of the recent EU White Paper on Adaptation and Surface Water Management. 1.1.3 In October 2011 the Commission published its findings2, which favoured a shorter tunnel with "greener" options for preventing rain water entering the sewerage system, and suggested that such alternatives require further study and should be “evaluated with equal consideration as the tunnel”. Thames Water published a brief initial response3 to the Commission‟s report which explained that, in the company‟s view, the Commission‟s findings failed to provide a viable, economic or timely alternative to the proposed Thames Tideway Tunnel to tackle sewage discharges into the River Thames. This document provides Thames Water‟s full response to the Commission‟s report.

1.1.4

1.1.5

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2

http://www.lbhf.gov.uk/Images/BkACE%20Thames%20Tunnel%20Commission%202011%20WEB_tc m21-165704.pdf
The Thames Tunnel (Selborne) Commission, p31 http://www.lbhf.gov.uk/Images/BkACE%20Thames%20Tunnel%20Commission%202011%20WEB_tcm21165704.pdf 3 http://www.thameswater.co.uk/cps/rde/xchg/corp/hs.xsl/14829.htm

Response to Thames Tideway Tunnel (Selborne) Commission

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2 Executive summary

2
2.1.1

Executive summary
The Thames Tunnel Commission (the „Commission‟) reports that the scale of sewage discharges into the Thames Tideway is recognised and unacceptable. The Commission acknowledges that even with the improvements to the sewage treatment works (STWs) and the Lee Tunnel in place, the remaining sewage overflows and the annual number of spills from certain combined sewer overflows (CSOs) would still result in adverse water quality. The Commission challenges the need for the proposed Thames Tideway Tunnel and suggests that alternative solutions, such as Green Infrastructure (GI) and Sustainable Drainage Systems (SuDS), should be considered instead. The Commission calls for cheaper solutions; however, the alternative solutions they suggest would be more expensive and much more disruptive. The Commission calls for further consideration of GI and SuDS, concentrating on the alleged potential to deliver multiple benefits. However, it ignores the basic inability of these measures adequately to reduce CSO discharges in London, despite evidence from studies carried out on specific areas of the city. The Commission accepts that SuDS could not be a complete solution to CSO discharges. However, the excessive costs and disruption associated with retrofitting GI and SuDS in such a densely populated and built-up area are overlooked by the Commission, even though evidence of the practical difficulties of retrofitting SuDS in London was presented to the Commission. The repeated overstating of the potential contribution of SuDS to deal with the scale of the existing problem in London risks bringing the whole concept into disrepute. Without presenting evidence, the Commission asserts that alternative options for reducing CSO discharges by storm and foul water separation by means of GI, constructing local detached STWs, constructing distributed storage or enhancing the existing sewerage network would allow for a partial tunnel solution, at a lower cost, or even a non-tunnel solution. However, these assertions are unfounded and ignore all the information that already exists on potential alternative solutions that have been investigated. There has been significant investigation of alternative methods to control CSO discharges, such as retrofitting SuDS analysis and separation studies, together with the assessment of mixed solutions reported in the Supplementary Report to Government and Tackling London’s Sewer Overflows. The conclusions of these studies undermine the Commission‟s assertions and demonstrate that their proposed alternative approaches would be less effective, more disruptive, take longer to implement and be more costly compared to the proposed Thames Tideway Tunnel.

2.1.2

2.1.3

2.1.4

2.1.5

2.1.6

Response to Thames Tideway Tunnel (Selborne) Commission

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2 Executive summary 2.1.7 With reference to the Commission‟s suggestion of new local detached STWs at CSO locations, the Commission specifically accepts that such an option would inevitably prove controversial and recognises the practical difficulties of finding suitable sites. The areas of land required would be considerable. Drawing on the experience of the site selection process for the Thames Tideway Tunnel and results from previous consultations, the siting of such local STWs in the urban environment of London, as well as the acquisition of sufficient site areas, would be virtually impossible. A similar option was proposed by Sir Joseph Bazalgette for the Hammersmith and Fulham area in 1862, but this was soundly rejected by the local authorities, on similar grounds. The Commission refers to several legislative and policy statements to support their calls for alternative solutions of SuDS and GI. Although the policy statements referenced, in particular the Natural Environment White Paper The Natural Choice; Securing the Value of Nature, suggest that GI is expected to help reduce pollution and bring greater resilience to climate change, the statements do not rule out other solutions. Supporting studies have demonstrated that a full-length tunnel solution will be resilient to climate change and reduce pollution by controlling CSO discharges at a lower cost and with less impact on London than SuDS and GI. The Commission has not produced any estimated costs for the alternative solutions that it suggests, nor has it included any performance measures or quantified the effectiveness of solutions proposed to control CSO discharges. Their principal recommended action is to undertake further studies. The Commission reports that, although it is widely agreed that pollution in the tidal Thames has vastly improved over the past 30 years, the current levels of sewage going into the tidal Thames are unacceptable. The Commission therefore concludes that there is indeed an urgent need to address the problem of CSO discharges. The Commission does not suggest any alternative solutions to the proposed Thames Tideway Tunnel that would meet the objectives set by the Thames Tideway Strategic Study (TTSS) for the health and ecology of the tidal Thames within the time scale set by the Government and that would help to ensure compliance with the Urban Waste Water Treatment Directive (UWWTD).

2.1.8

2.1.9

2.1.10

2.1.11

Response to Thames Tideway Tunnel (Selborne) Commission

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3 Introduction

3 3.1
3.1.1

Introduction
Context of the Thames Tunnel Commission’s report
The Commission recognises that the scale of sewage discharges into the Thames Tideway is unacceptable. It also acknowledges that even with the improvements to the STWs and the Lee Tunnel in place, the remaining sewage overflows and the annual number of spills from CSOs would result in adverse impacts on the Thames Tideway that will intensify with predicted increases in the population and possible climate change. The Commission sets out challenges in their report that can be collated and responded to under the following five main headings: a. Regulatory drivers, basic need and legislative requirements b. Reassessment of targets in light of the economic climate c. Alternatives such as SuDS, GI, local treatment and storage d. Assumptions and modelling questioned e. Aesthetic and public health issues.

3.1.2

3.1.3

The challenges set out by the Commission appear throughout the sections of their report, in various levels of detail. This document seeks to respond to each of the five main areas in a summary manner, with examples where appropriate.

Response to Thames Tideway Tunnel (Selborne) Commission

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4 Regulatory drivers and requirements

4 4.1
4.1.1

Regulatory drivers and requirements
Regulatory drivers
The Commission suggests that the primary drivers for addressing the problem of CSO discharges in the tidal Thames are EU Directives, stating that in the opinion of the European Commission (EC), wastewater collecting systems in London are left to spill untreated wastewater from CSOs too frequently and in excessive quantities into the Thames Tideway. The objective for the UK Government is therefore to address infraction proceedings taken against them by the European Commission for being in breach of the Urban Waste Water Treatment Directive (UWWTD). While the UWWTD, and to some extent the Water Framework Directive (WFD), are indeed the regulatory drivers for the scheme, the simple fact is that with or without EU directives, CSO discharges are causing ecological damage to the tidal Thames. Proper control of CSO discharges has been an aspiration for decades, long before the advent of such EU directives. The Commission expresses the view that EU infraction proceedings against the UK are the driving force for a single tunnel solution and that the assumed timetable for compliance inhibits the implementation and adoption of longer-term GI and SuDS solutions. The Commission also states that the Government is overly-reliant on the TTSS report of 2006 and Appendix E of the Needs Report (included in the 2010 consultation documents) in determining that green solutions would be difficult to implement to meet the requirements of the UWWTD. However, the Commission itself uses the same results from these studies to formulate its proposals for GI and SuDS. The Commission points out that it found no evidence of any dialogue with the European Commission (EC) on the acceptability of other solutions for the presumed infraction of the UWWTD, or on the long-term sustainability of other solutions. Alternative solutions have not been presented to the EC as all studies into other alternative solutions, including SuDS and GI, have demonstrated that such measures would cost significantly more than the single tunnel option and would not achieve sufficient levels of CSO control to provide the tidal Thames with the necessary level of protection. Infraction proceedings present the risk that the UK Government – and, in turn, the UK tax payer – would be required to cover the cost of substantial fines that could total over £200 million per year.

4.1.2

4.1.3

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4 Regulatory drivers and requirements

4.2
4.2.1

Other legislative factors
The Commission refers to several legislative and policy statements related to water management that have emerged both in the EU and the UK. They include: a. EU Biodiversity Strategy b. EC White Paper Adapting to Climate Change: Towards a European framework for action c. Water Framework Directive Common Implementation Strategy, Guidance Document No. 24

d. UK Government Natural Environment White Paper The Natural Choice; Securing the Value of Nature e. UK National Ecosystem Assessment: Understanding nature’s value to society f. Manual for Cities: Ecosystem Services in Urban Management. The Commission asserts that these legislative and policy statements should be used to help inform the development of a solution to the problem of CSO discharges, which implies that they have been omitted from the process. This is not the case. Where applicable, these statements have been used to develop our proposals to control CSO discharges. 4.2.2 The EU Biodiversity Strategy includes many targets and actions. The Commission quotes Target 2 of the EU Biodiversity Strategy, which states that by 2020 ecosystems are to be maintained and enhanced by establishing GI and restoring at least 15 per cent of degraded ecosystems. By controlling CSO discharges to the proposed standards, the proposed Thames Tideway Tunnel would ensure approximately 100ha to 150ha of foreshore is no longer degraded by the adverse impact of pollution from CSO discharges. The target the Commission refers to is also associated with developing strategies for GI and is related to the challenges of flooding, overheating and lack of green space, not the control of CSO discharges. The EC White Paper Adapting to Climate Change: Towards a European framework for action looks at improving policies and developing measures to address biodiversity loss and climate change in an integrated manner. It is unclear why the Commission chose to refer to this paper, as it does not propose any practical measures that could be introduced. Even so, the proposed Thames Tideway Tunnel, which would operationally be fully integrated with the Lee Tunnel, tidal STWs improvements and the existing sewerage system, would enhance the sewerage system‟s ability to respond and adapt to climate change. The Commission quotes the Water Framework Directive Common Implementation Strategy, Guidance Document No. 24 as promoting infrastructure with long life spans, and favouring measures that are resilient to a wide range of plausible climate conditions. The proposed
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4.2.3

4.2.4

Response to Thames Tideway Tunnel (Selborne) Commission

4 Regulatory drivers and requirements Thames Tideway Tunnel would indeed have a long life span and be resilient to a wide range of plausible climatic conditions, providing a centralised and continuous storage system into which CSOs could discharge. The UK Climate Projections 2009 (UKCP09) predict a wide range of potential impacts on rainfall patterns. It is likely that localised SuDS and GI would be overwhelmed by such changes in rainfall patterns and so be even less capable of achieving the required control of CSO discharges. 4.2.5 The Commission refers to the UK Government Natural Environment White Paper, The Natural Choice; Securing the Value of Nature as supporting an approach based on GI and SuDS. However, while the paper emphasises the real potential value of SuDS in rural and semi-rural environments, it does not examine in detail the value of SuDS in densely populated and highly-developed urban areas, such as London. The White Paper does not set out actions that could be put in place now; rather it looks to the future and suggests that more research and study will help determine what might be considered in the future. Although the White Paper suggests that GI is expected to reduce pollution and provide greater resilience to climate change, it does not rule out the consideration of other solutions. Supporting studies have demonstrated that the single tunnel solution will be resilient and adaptable to climate and population change, and will reduce pollution by controlling the CSO discharges at a lower cost and with less disruption in the capital. The Commission cites the UK National Ecosystem Assessment: Understanding nature’s value to society as promoting a more holistic approach. However, the emphasis, as with the UK Government Natural Environment White Paper, is on rural and semi-rural areas. Urban environments are only mentioned in passing, and there are no recommendations for urban environments. The Commission claims that the Manual for Cities: Ecosystem Services in Urban Management provides clear guidance and evidence for taking a multi-functional and multi-value approach to natural and green spaces in urban areas, connecting urban planning and design with ecosystems and water management in an integrated way. These are all extremely valuable and worthwhile aims and represent the fundamental ambitions of Drain London, of which Thames Water is an active and supportive member. However, it is widely recognised that such changes will evolve over the longer term, and that implementation will be measured in generations rather than years. The Commission takes issue with the Draft National Policy Statement for Waste Water (now approved in final form) and in particular with its inclusion of the proposed Thames Tideway Tunnel. The Commission calls for a rigorous analysis of alternative solutions that could potentially address the problem of CSO discharges, along with the investigation of the potential multifunctional value and feasibility of retrofitting mainly GI source control measures. However, the Commission accepts that the studies into GI and SuDS demonstrate that they would not achieve adequate CSO control.
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4.2.6

4.2.7

4.2.8

Response to Thames Tideway Tunnel (Selborne) Commission

4 Regulatory drivers and requirements 4.2.9 In conclusion, the Commission cites several legislative and policy statements to support its call for alternative solutions based on SuDS and GI. While these statements, the White Paper in particular, do set out that GI is expected to reduce pollution and provide greater resilience to climate change, they do not rule out the use of other solutions. Supporting studies have demonstrated that the full-length single tunnel solution would be resilient and adaptable to climate change, and would significantly reduce pollution by controlling the CSO discharges at a lower cost and with less disruption than SuDS and GI could. We support the use of GI and SuDs in the longer term, and expect them to play a key role in ensuring that London‟s drainage infrastructure develops in a way that can be sustained.

Response to Thames Tideway Tunnel (Selborne) Commission

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5 Reassessment of targets

5 5.1
5.1.1

Reassessment of targets
Dissolved oxygen criteria
Against the backdrop of improving numbers of fish species found in the Thames Estuary, and the earlier investment in sewage treatment infrastructure in the Thames catchment, the Commission claims that the ecological standards developed by the TTSS, to turn the Thames Tideway into a sustainable fishery for salmon, smelt and other sensitive species, are too ambitious. The standards consist of four dissolved oxygen (DO) thresholds based on a DO value, frequency of occurrence and duration. The first threshold of 4mg/l DO is lower, and so more relaxed, than those set elsewhere. The other three thresholds allow for the DO to drop to even lower levels, albeit with a reduced frequency and for a shorter duration. It has never been the intention to turn the Thames Tideway into a sustainable fishery for salmon. This assertion is a misinterpretation of the use of salmonid species, amongst others, as indicator species in the fish studies to represent river ecology as a whole. The Commission‟s statement that there seems to be no limit to the budget to sustain the Thames Tideway as a fishery for sensitive fish is misguided. The Commission correctly points out that the UWWTD and UK regulations do not legislate for such an approach. However, its claim that the aim is expensive and unrealistic is at odds with the fact that the proposed standards would facilitate only moderate potential under the Water Framework Directive, which sets a target of 5mg/l of DO for 95 per cent of the year to achieve a „good‟ status.

5.1.2

5.1.3

5.2
5.2.1

Economic climate
The Commission suggests that the environmental criteria set by the TTSS and adopted by the Environment Agency (EA) should be revised downwards “in today‟s economic climate”. Whether it is appropriate for Environmental Quality Standards (EQSs) to be revised and reduced to “fit” a solution which appears be more convenient under short term economic conditions is a matter for the UK Government. However, EQSs are derived to protect ecology as the end point and are underpinned by science. The call for cheaper solutions appears inconsistent with the Commission‟s own position as the alternatives it advocates are of a significantly greater cost than the proposed Thames Tideway Tunnel.

5.2.2

Response to Thames Tideway Tunnel (Selborne) Commission

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6 Alternatives

6 6.1
6.1.1

Alternatives
SuDS and GI
The Commission overstates the case for GI and SuDS by concentrating on the potential for multiple benefits to society. It ignores their inadequacy in controlling large scale CSO discharges and the excessive costs and disruption associated with retrofitting them in such a densely built-up environment. The fundamental point that the Commission does not acknowledge is that for a “mixed” solution to adequately control CSO discharges, a tunnel system would still be required, and so the overall cost would be substantially higher. The company believes that the work undertaken by Commission member Professor Ashley for the Thames Tideway Tunnel project in assessing the potential for SuDS to control CSO discharges has been misrepresented and taken out of context by the Commission, leading to inconsistent recommendations. The three pilot areas selected for assessment by Professor Ashley were judged to be the most amenable for implementing a progressive programme of retrofitting SuDS to control CSO discharges. All three pilot areas generally have significant areas of green space, and are less densely populated than most parts of London. A sophisticated disconnection strategy, following recognised guidelines, was applied by Professor Ashley‟s team to the three pilot catchment areas to assess the reasonable and practical level of SuDS that could be retrofitted. Existing land type and use was categorised, and a detailed assessment made of the relevant application of retrofit SuDS techniques. These included the conversion of flat roofs to green or blue roofs; the disconnection of rear roof drainage to lawn areas; the implementation of large rainwater butts, detention ponds, swales, and pocket rain gardens; and the conversion of paved and parking areas from impervious to pervious surfaces. While the results were deemed “promising”, the pilots demonstrated that, despite the large areas that would need retrofitting and modification, only one of the sub-catchment areas might attain the required level of CSO control. The Commission also omitted the estimated costs for implementing the retrofit SuDS calculated by Professor Ashley. In all cases, the cost of retrofitting SuDS was greater than controlling the CSO discharges by interception to the proposed Thames Tideway Tunnel, with an estimated cost for the three sub-catchments of about £130 million. This is compared to approximately £80 million for connecting the three CSOs to the proposed Thames Tideway Tunnel. Based on Professor Ashley‟s work, the Commission reports that the disconnection of 50 per cent of the impermeable area (10,327ha) “must be feasible” (Section 4.3.6, page 21). Even with the massive disruption this would entail, it would represent only a partial solution, as the Commission itself accepts, and would „reduce the total overflow volume by 54 per cent‟, as outlined in Section 4.3.6. Even this large scale
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6.1.2

6.1.3

6.1.4

6.1.5

Response to Thames Tideway Tunnel (Selborne) Commission

6 Alternatives implementation of GI and SuDS throughout London would be insufficient to adequately reduce the volume and frequency of CSO discharges to the level achieved by the proposed Thames Tideway Tunnel. The Commission gives no justification or evidence in support of its claim that this level of area change throughout London must be feasible, nor any indication of the likely cost. The area in question represents over 20 per cent of the entire catchment area, and is equivalent to 71 times the area of Hyde Park, or 41 times the area of Kensington Gardens and Hyde Park combined. Put another way, it is the same size as 15,000 football pitches. 6.1.6 The Commission calls for extended investigation into mixed solutions, based on GI and SuDS that would, it claims, deliver multiple benefits to London. While the medium and long-term “greening” of London is a progressive and important goal in improving the capital‟s sustainability, the Commission consistently disregards the inability of such measures to sufficiently reduce CSO discharges. If the Commission‟s recommended approach of adopting these measures in the medium to long-term was adopted, the tidal Thames would continue to be subject to serious pollution from CSO discharges. CSO discharges would also ultimately fail to be adequately addressed even in the long term, because of the limitations of SuDS in controlling rainfall-runoff that leads to CSO discharges. The Commission asserts, without supporting evidence, that SuDS are a better solution when climate change is considered. We disagree with this assertion. The single tunnel solution is, in fact, resilient to a wide range of plausible climatic conditions, as it would provide centralised and continuous storage for all the CSO discharges. The UKCP09 predict a wide range of potential impacts on month by month rainfall patterns. The projected changes in winter rainfall will make it more likely that localised SuDS and GI will be overwhelmed, and so be even less likely to control CSO discharges. The proposed Thames Tideway Tunnel would provide the flexibility to adapt to future changes in rainfall. While the implementation of SuDS and GI will not achieve sufficient CSO control, their longer-term implementation, delivered locally as part of redevelopments throughout London, may assist the easing of local flooding issues, and may well support marginal reductions in CSO discharge volumes. Their development and utilisation is therefore supported by Thames Water. SuDS also have an important role to play in new developments, but their introduction will be an evolutionary process that reduces local flooding and helps ensure the longevity of the Thames Tideway Tunnel, rather than an alternative with the potential to control CSO discharges to the required level.

6.1.7

6.1.8

6.2
6.2.1

Other alternatives
The idea of dispersed STWs in peripheral catchment areas, as proposed by the Commission, is not only impractical but entirely unrealistic for such densely populated and heavily developed areas in London. The Commission accepts that such an option would inevitably prove controversial, and recognises the practical difficulties of finding one or
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Response to Thames Tideway Tunnel (Selborne) Commission

6 Alternatives more suitable sites, but suggests that dispersing treatment facilities along the river would be a better option than a long distance conveyance system, such as the proposed Thames Tideway Tunnel. The Commission does not take account of the fact that, as wet weather flows are far greater than the typical dry weather flows, localised sewage works would require significant volumes of storage to balance the flow to treatment. 6.2.2 For example, for the Hammersmith Pumping Station CSO, the local dry weather flow is approximately one cubic metre per second (cumec), which implies, by UK practice, a Sewage Treatment Works (STW) with three cumec maximum treatment capacity. A new STW of this capacity would require a footprint of about 15ha, or 25 football pitches – an amount of space that is not available in Hammersmith. For comparison, the combined area of Frank Banfield Park and the proposed Fulham Reach Development, adjacent to Hammersmith Pumping Station, is about 5.3ha. To control CSO discharges the wet weather flows would need to be captured, which would require storage. At Hammersmith Pumping Station the current maximum capacity of the pumping station is 24 cumec during wet weather events. This means a localised sewage treatment plant would require huge storage tanks, approximately 150,000 cubic metres in volume, to capture the peak flows to ease flows to treatment. Hammersmith Pumping Station currently discharges combined sewage to the River Thames 55 times in a typical year, with an annual total of about 2.2 million cubic metres of sewage. Constructing a local STW of three cumecs without associated storage would only capture 363,000 cubic metres, leaving an annual total of about 1.9 million cubic metres of untreated storm sewage entering the River Thames. The number of discharges would also only be reduced to around 30 times in a typical year. This is clearly unacceptable, as it fails to meet the required water quality requirements. The approach outlined above would, in order to adequately control CSO discharges, have to be repeated in a similar manner for all the remaining large CSOs. The volume and frequency of discharges, combined with the virtual impossibility of siting several large new STWs throughout central London, make this approach demonstrably unrealistic. The Commission refers to the review by Jacobs Babtie and in particular their proposal for an alternative tunnel option and mixed solution. The Commission‟s description of this alternative proposal is inaccurate, as the Jacobs Babtie option was based on only one tunnel located in the west, and not two shorter tunnels as stated. The Jacobs Babtie option also included a screening plant at Heathwall, and not a treatment plant as stated. The Jacobs Babtie proposal consisted of a hybrid option based on the following elements, which were considered and discounted by the TTSS: a. enhanced Primary treatment at Abbey Mills, ie, a new treatment works at Abbey Mills

6.2.3

6.2.4

6.2.5

Response to Thames Tideway Tunnel (Selborne) Commission

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6 Alternatives b. construction of a west tunnel – a 9km, 7.2m diameter tunnel from Hammersmith to Heathwall, together with an associated screening plant at Battersea to capture discharges from the tunnel c. a screening plant at Earl Pumping Station, with no suggestions for capture of the large discharges from Fleet, Deptford Storm Relief Sewer, Greenwich Pumping Station and Northeast Storm Relief Sewer

d. the deployment of skimmer vessels to collect litter as a mitigation measure, but no control of other harmful pollutants e. a medium to long-term strategy of using SuDS and other measures to reduce sewer flows, proposed without consideration of their practicality and the time and cost to implement them. 6.2.6 The Jacobs Babtie west tunnel, following a route under the River Thames, would store combined sewage until there was capacity within the current system to transfer it to the Beckton and Crossness STWs for treatment. The screening facility at Battersea would discharge into the tidal Thames when the western tunnel was full. Unscreened discharges would continue at 17 other CSOs not connected to the tunnel in the west, with the exception of Earl Pumping Station, which would be screened but continue to discharge into the River Thames. The evaluation of screening at Earl Pumping Station was not developed in any detail, and so failed to consider the practicalities of operating a screening plant within a densely populated residential neighbourhood. The Jacobs Babtie scheme was not adopted because, although apparently cheaper to construct, the much shorter tunnel would only address a fraction of the discharges into the tidal Thames. In addition, and of fundamental importance, the current collection system has virtually no spare capacity that could be utilised to convey stored combined sewage from the Jacobs Babtie tunnel for treatment. This would mean that sewage would need to be stored in the tunnel for long periods at a time, while waiting for spare capacity in the sewers downstream to become available. This would lead to septicity and odour problems in the vicinity of the tunnel and then throughout London as the septic sewage is conveyed through the existing sewers for treatment. The deployment of skimmer crafts to remove sewage derived litter in the river from the remaining unconnected and uncontrolled CSOs would not reduce the polluting load into the River Thames. This is purely an aesthetic mitigation measure and would not ensure compliance with the UWWTD, which requires adequate secondary treatment of discharges from collection systems. The Jacobs Babtie report made no recommendation regarding the scale and cost of medium and long-term implementation of SuDS and other measures to reduce sewer flows. In conclusion, the Jacobs Babtie alternative solution would be wholly inadequate, failing to meet the environmental targets and to ensure compliance with the UWWTD.
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6.2.7

6.2.8

6.2.9

6.2.10

Response to Thames Tideway Tunnel (Selborne) Commission

6 Alternatives 6.2.11 The Commission makes reference to the recommendations by Mr Chris Binnie (former chairman of the TTSS) that the alternative option of a western tunnel should be revisited in the light of the improvements to be delivered by the Lee Tunnel and programme to upgrade sewage works on the tidal Thames. This western tunnel alternative is effectively a slight modification of the west tunnel element of the Jacobs Babtie proposal and so suffers from the same shortcomings already described. Primarily, the CSO discharges between Vauxhall Bridge and the Thames Barrier would be ignored. The Commission also reports that Mr Binnie suggested that present estimates of projected dry weather flows are overstated, and that some of the environmental standards are in certain respects inappropriate. The argument regarding projected dry weather flows is largely insignificant, as CSO discharges are caused by rainfall runoff. Although variation in predicted dry weather flow may have some minor influence on the anticipated “spare” capacity of the existing sewerage system to receive stored flows from Mr Binnie‟s proposed west tunnel, these are swamped by the sewerage demands of the proposed significant redevelopment of the area around Battersea and Heathwall. The Commission did not provide any further clarification to set out their concerns in relation to environmental standards. The Commission misinterprets, or fails to understand, the impact of the Lee Tunnel on the tidal Thames. Although the Lee Tunnel will capture the discharge from Abbey Mills sewage pumping station to the River Lee it will do nothing to reduce the discharges between Acton and the Tidal Barrier.

6.2.12

6.2.13

6.3
6.3.1

Alternative recommendations by the Commission
The Commission recommends that if the options for the medium to long term solutions to the problem of unacceptable discharges into the tidal Thames could be fairly represented as a choice between the proposed Thames Tideway Tunnel, or SuDS and other GI measures, then the case for the Thames Tideway Tunnel would be more convincing. We believe that such a choice between the two options has been demonstrated, and the Thames Tideway Tunnel is both the most effective and most cost effective solution.

Response to Thames Tideway Tunnel (Selborne) Commission

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7 Assumptions and modelling

7 7.1
7.1.1

Assumptions and modelling
Assumptions
The Commission suggests that the EA‟s methodology for determining whether a CSO has unacceptable and adverse environmental impacts should be supported by a scientifically robust evidence base, informed by adequate monitoring, validated computer models and measures which can be precisely calculated. This is exactly what has been done to determine which CSOs are unsatisfactory. The EA, as seen in their evidence to the Commission, followed an audited process to verify the accuracy of the classification of unsatisfactory CSOs. Each CSO has been (and continues to be) monitored to show the frequency of the overflows. Data from the Automated Quality Monitoring Stations (AQMS) operated by the EA indicates the impacts on DO in the tidal Thames, across London, when discharges occur. The water quality model, used to predict the effectiveness of solutions and compare options, has been calibrated and validated using data collected during CSO events. The sewer catchment model has been continuously validated by contrasting and comparing it with past and current monitoring data. The Commission fails to acknowledge the work and scientific analysis undertaken and the factual evidence in relation to the impact of CSO discharges.

7.1.2

7.2
7.2.1

Modelling
The Commission challenges the suitability of the models but fails to specify why it believes the models are unacceptable, or offer suitable alternatives. In fact, the uncertainties associated with the potential performance of alternative approaches, such as SuDS and GI, are far greater than for a single tunnel option. The models used represent the best available technology to assess the impact of CSO discharges on the tidal Thames and the relative performance of options presented. The sewer catchment model in particular has been continuously improved throughout the feasibility study and design development. As such, it is a predictive tool that is appropriate no matter what potential solution is considered. The Commission‟s claim that there is limited data and a lack of scientific knowledge behind these models is wholly unsubstantiated. We fundamentally disagree with this claim. The models are the best available technology and entirely fit for purpose.

7.2.2

7.2.3

Response to Thames Tideway Tunnel (Selborne) Commission

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8 Aesthetic and public health issues

8 8.1
8.1.1

Aesthetic and public health issues
Aesthetic
The Commission argues that some expert witnesses questioned the extent to which the aesthetic criterion was of relevance in terms of the UWWTD. However, the Commission accepts the need to take into account aesthetic and health impacts of CSO discharges, as well as DO impacts. The Commission accepts that the criteria for assessing the effect of CSO discharges on aesthetic quality is less straightforward than that for assessing the impact on DO, but criticises the pragmatic approach taken by the EA, which was based on location, ease of access to the public and the number of people in the vicinity, as well as frequency and size of the CSO discharge. However, the Commission does not offer any alternative, other than replacing the EA‟s approach with more study, monitoring of results, data analysis and a measure which can be „precisely‟ calculated. Monitoring CSO discharges, visual recordings of discharges and routine sampling of standard public health criteria has shown the aesthetic problem and the risk to human health. Previous and ongoing monitoring and the collecting of samples wholly support the assessment by the EA.

8.1.2

8.2
8.2.1

Public health
The Commission has largely ignored one of the objectives of the Thames Tideway Tunnel project, which is to help protect river users by substantially reducing the elevated health risk due to CSO discharges. The Commission fails to include evidence from a collaborative partnership between the City of London Port Health Authority and the Health Protection Agency, whose final report was published in 2007. The studies and report clearly document these elevated health risks to river users after CSO discharges. Alternative solutions, such as GI and SuDS, would not adequately reduce the frequency of CSO discharges and therefore the health risks will not be diminished. By comparison, the proposed Thames Tideway Tunnel would reduce the frequency of CSO discharges to just four or less in a typical year, thereby dramatically reducing the number of days on which river users are exposed to human waste and associated bacteria and viruses.

8.2.2

Response to Thames Tideway Tunnel (Selborne) Commission

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