December 2012 Sustainable Drainage Systems (SuDS) and their potential uses in London Frequently Asked Questions Q1: How

do SuDS work? And why are they so difficult in London? SuDS – sometimes known as ‘Green Infrastructure’ (GI) - work in two main ways. • Infiltration reduces the volume of surface water run-off that enters combined sewers by directing it underground. It principally requires permeable subsoils that can soak up water. This approach has limited potential for London, as the city mostly sits on top of a thick layer of clay and other impermeable or saturated subsoils. The geology of London cannot be altered. Infiltrated water also needs to be kept away from the walls and foundations of buildings and basements to prevent seepage and damage. • Attenuation slows down the rate at which water reaches the sewers, reducing peak flows. This can cut down the potential for combined sewer overflow (CSO) discharges by reducing the frequency with which the sewers fill to capacity. Attenuation does not drastically reduce overall volumes. Its principle requirement is space for short-term storage. Space is at a premium in London, due to the density of development and population. In theory, space for attenuation measures could be made available in London, but would come at a high price and not be straightforward. For example, roadside parking spaces would need to be sacrificed. Attenuation systems are susceptible to being overwhelmed by back-to-back storms, or extended periods of continuous rainfall. They can also be overwhelmed by intense localised rainfall. This can lead to surface flooding of adjacent areas. SuDS methods include: • • • Disconnection of roof downpipes and rerouting to lawns, gardens or water butts. This requires considerable cooperation from property owners ‘Green’ and ‘blue’ roofs ‘Street Edge Alternatives’ (SEA), such as street ‘rain gardens’ or bulb-outs; these can be an effective means of controlling street runoff quantities, provided the storm water controlled can infiltrate into the ground. Soil conditions in London are not conducive to high infiltration because of clayey soils and a high groundwater table Using porous materials on roads and pavements Fitting shallow basins in grassed areas Disconnection of larger impervious surfaces to open, permeable spaces

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Q2.

How did the West Putney study work? What did it show? Who conducted the analysis? The study covered three relatively small CSO catchments (West Putney, Putney Bridge and Frogmore Buckhold Road), identified as most amenable to SuDS techniques (for example due to the locally availability of open space). It was conducted by the independent consultants, the Pennine Water Group, headed by Professor Richard Ashley, a recognised SuDS expert. It aimed to identify the most reasonable and practical level of implementation of retrofit SuDS techniques to address CSO discharges. The detailed study was based on a sophisticated ‘disconnection’ strategy, following established guidelines. It involved categorising existing land type and use. Of the three CSO sub catchment areas investigated, only one (Frogmore Buckhold Road) was found to be suitable for implementing SuDS measures on a scale sufficient to ensure compliance with the required standards. The cost of implementing retrofit SuDS for each area was also found to be far greater than connecting the CSO to the proposed Thames Tideway Tunnel. The study findings were also extrapolated to retrofitting SuDS to the whole of the catchment served by the 34 CSOs that the Thames Tideway Tunnel needs to intercept. It concluded that only one of them would become compliant. The study concluded that retrofitting SuDS in London on a scale large enough to singlehandedly tackle the city’s discharge of sewage to the tidal river Thames is not a practical option and would not be effective within the required timescale for two main reasons: The capital is already far too urbanised and its underlying geology is not conducive to SuDS. The process would cost an estimated £13bn at least, take over 30 years to implement and still not adequately control CSO discharges. SuDS can be cost-effectively embedded in all new development opportunities. Thames Water fully supports such an approach. The problem is that without the Thames Tideway Tunnel, it would not be enough to tackle the CSO discharges quickly enough or effectively enough.

Q3.

What about all the other benefits of SuDS? Don’t they make an important difference to the cost-benefit analysis? A wide range of potential benefits from SuDS and GI have been identified. They have the potential to provide significant and measureable improvements in the urban environment, including: • • • water quality enhancements biodiversity improvements in aquatic and terrestrial ecosystems

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reductions in energy use and greenhouse gas emissions reductions in stress-related illness and mortality reductions in crime

Some or all of these additional benefits may be deliverable in London, but they cannot contribute to a valid cost-benefit analysis, because SUDS and GI cannot on their own meet the prime objective of reducing CSO discharges to meet legal standards. Q4. Is it true that installing permeable surfaces on just 34% of London’s roads would have the same effect as the tunnel in reducing discharges to the river? This is categorically untrue and cannot be substantiated. We have carried out a detailed evaluation of what could be achieved by halving the 20,600 hectares of total impermeable surfaces for the whole of the Beckton and Crossness catchments. Such a reduction of 10,300 hectares is equivalent to over 70 times the area of Hyde Park. The results showed that such a scenario would reduce total volume of CSO discharges to the tidal River Thames in a typical year by 55 per cent, from 39 million m3 to 17.4 million m3. This would be insufficient to meet quality standards set by the Environment Agency. The overall frequency of CSO discharges would be reduced only slightly. Crucially, this study work assumed that complete disconnection of these areas could be achieved, and surface water run-off eliminated. This is highly unlikely ever to be practically possible. A recent study, led by Professor Ashley of Sheffield University, has estimated that the maximum achievable figure would be approximately 37 per cent. The work required would also be expensive (in the order of £2.2 billion) and create huge traffic disruption across London. Q5. What impact would the widespread use of porous paving and roads have on groundwater levels? The generally impervious or saturated soils underlying London mean that the potential for diverted rainwater to seep into the water table is very limited. Any that did would significantly exacerbate the existing problem of groundwater flooding basement properties and damaging foundations of buildings. It must not be forgotten that London’s combined sewerage system, as it has evolved over the centuries, provides a land drainage function. The tributaries of the Thames, such as the Fleet and the Tyburn, are known as ‘Lost rivers’, precisely because over time they have been converted into sewers. They continue to serve the function of draining the subsoil.

Q6.

How porous can permeable paving/roads be? Does the nature of the subsoil matter? Typically permeable road construction consists of a 155mm layer for attenuation and a 468mm layer, designed to withstand the weight of traffic. Typically, permeable paving will absorb the initial 10 to 15mm of rain that falls on it. Rainfall in excess of this quantity will not be absorbed by the permeable paving and will pass directly into the sewer system. If the underlying subsoil is also permeable, there can be significant infiltration resulting in a significant reduction in the overall volume of surface water run-off. But London’s subsoils are predominantly impermeable or saturated. This means there is little potential for infiltration. Surface water run-off would be attenuated (slowed down) in the permeable paving, but would still ultimately drain back to the sewers.

Q7. A:

Does it really matter that much of London sits on clay? Aren’t the surface layers more porous? London is built predominantly on top of London Clay, which is not porous. The capital’s other subsoils are: Alluvium, a peat-like sandy clay, which is saturated and not particularly porous) and sandy River Terrace Gravels, which although porous is saturated, like a sponge full of water. The plain fact is that London’s geology, which is a given and can’t be changed, is not suitable for infiltration-based SuDS

Q8

Is it true that only 20% or less of the CSO discharges in London is actually sewage. Isn’t the sewage heavily diluted by rainwater and less polluting as a result? When it enters London’s combined sewerage system, surface water run-off from roads and buildings immediately becomes inextricably mixed with the foul sewage. When the local sewer system has filled to capacity and can no longer pass the flows eastwards to the sewage treatment works, the CSOs act as relief outlets and discharge to the river. This prevents flooding of streets and homes. At these times virtually all of the untreated sewage in the sewers will be discharged to the river via the CSOs. The proportion of rainwater in these discharges is irrelevant, because the damage caused by the untreated sewage when it enters the river will be the same regardless of the volume of rainwater with which it is mixed. The ‘polluting load’ is what matters, not the degree of dilution. The other significant factor is that London’s main sewers are relatively flat. They have a very gentle gradient of about 1m of fall for every 2km of length. This means

significant deposits of sediment build up during periods of dry weather when flows are low. This sediment is then swept up by the higher flows that follow heavy rainfall and discharged to the river. This adds considerably to the total polluting load and hence to the damage caused in the river. The Thames Tideway Tunnel will intercept these discharges of combined sewage and keep the associated polluting load out of the river. Q9. Thames Water says it is reducing the amount of water lost through leaks. If most of the water that leaks ends up in the sewers, then surely the flows will be decreasing? Thames Water has significantly reduced leakage, in line with targets set by Ofwat. The amount of water lost through pipes, from water treatment works to tap, is now at its lowest ever recorded level in London. Leakage from water pipes has very little impact on the baseline flows in the sewers. The water distribution network and the sewerage network are entirely separate different systems.

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