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110-RG-PNC-00000-000784 | May 2012

Supplementary report on phase two consultation


Chapter 2 Need, solution, tunnel route and alignment

2 The need, solution, tunnel route and alignment

Thames Tunnel Supplementary report on phase two consultation


List of contents
Page number

The need, solution, tunnel route and alignment ............................................................................................................. 2-1 2.1 2.2 2.3 2.4 2.5 2.6 Introduction ............................................................................................................................................................... 2-1 The need for the project............................................................................................................................................ 2-1 The solution ............................................................................................................................................................ 2-18 Tunnel route ........................................................................................................................................................... 2-71 Alignment of the Abbey Mills route ......................................................................................................................... 2-83 Our view of the way forward ................................................................................................................................... 2-91

Supplementary report on phase two consultation

2 The need, solution, tunnel route and alignment

List of tables Page number Table 2.2.1 Number of respondents commenting on the need to reduce the amount of sewage that enters the tidal River Thames (Q9) .............................................................................................................................................................................. 2-1 Table 2.2.2 Supportive and neutral feedback comments in relation to the need to reduce the amount of sewage that enters the tidal River Thames ............................................................................................................................................................... 2-2 Table 2.2.3 Supportive (qualified) comments in relation to the need to reduce the amount of sewage that enters the tidal River Thames ......................................................................................................................................................................... 2-4 Table 2.2.4 Objections, issues and concerns in relation to the need to reduce the amount of sewage that enters the tidal River Thames ......................................................................................................................................................................... 2-7 Table 2.3.1 Number of respondents commenting on our decision that a tunnel is the right way to meet the need to reduce the amount of sewage that enters the tidal River Thames (Q10) ...................................................................................... 2-18 Table 2.3.2 Supportive and neutral feedback comments in relation to the decision that a tunnel is the right way to meet the need to reduce the amount of sewage that enters the tidal River Thames .............................................................................. 2-19 Table 2.3.3 Supportive (qualified) feedback comments in relation to the decision that a tunnel is the right way to meet the need to reduce the amount of sewage that enters the tidal River Thames .............................................................................. 2-22 Table 2.3.4 Objections, issues and concerns in relation to the decision that a tunnel is the right way to meet the need to reduce the amount of sewage that enters the tidal River Thames ................................................................................................ 2-28 Table 2.3.5 Alternative solutions ................................................................................................................................................. 2-55 Table 2.4.1 Number of respondents commenting on our preference for the Abbey Mills route (Q11) ........................................ 2-71 Table 2.4.2 Supportive and neutral feedback comments in relation to the preference for the Abbey Mills route ........................ 2-72 Table 2.4.3 Supportive (qualified) feedback comments in relation to the Abbey Mills route ....................................................... 2-73 Table 2.4.4 Objections, issues and concerns in relation to the preference for the Abbey Mills route ......................................... 2-75 Table 2.4.5 Objections, issues and concerns in relation to the preference for the Abbey Mills route ......................................... 2-81

Supplementary report on phase two consultation

2 The need, solution, tunnel route and alignment Table 2.5.1 Number of respondents commenting on the proposed alignment of the Abbey Mills route (Q12) ........................... 2-83 Table 2.5.2 Supportive and neutral feedback comments in relation to the alignment of the Abbey Mills route........................... 2-84 Table 2.5.3 Supportive (qualified) feedback comments in relation to the alignment of the Abbey Mills route ............................. 2-84 Table 2.5.4 Objections, issues and concerns in relation to the alignment of the Abbey Mills route ............................................ 2-85

Supplementary report on phase two consultation

2 The need, solution, tunnel route and alignment

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2.1
2.1.1

The need, solution, tunnel route and alignment


Introduction
This chapter sets out the feedback comments received in the phase two consultation on the need for the project, the nature of the solution, our preferred tunnel route and the alignment of the Abbey Mills route. In each of the following sections, the feedback comments have been grouped under supportive and neutral comments, and objections, issues or concerns. Our responses to the feedback comments raised by respondents are set out in the tables. Where more than 250 respondents have made a feedback comment the details of the respondent IDs are set out in annex B to this report. Where a response contains reference to our website, go to www.thamestunnelconsultation.co.uk for further information, or to access the documents referred to. The final section of this chapter sets out our initial view of the way forward, having regard to the feedback comments received.

2.1.2 2.1.3 2.1.4

2.2
2.2.1

The need for the project


During the phase two consultation, respondents were given a further opportunity to comment on the need to reduce the amount of sewage that enters the tidal River Thames (please see question 9 of the phase two consultation feedback form, provided in appendix M to the Main report on phase two consultation). Table 2.2.1 sets out details of the different groups who responded to confirm whether they had comments or not. Tables 2.2.2 - 2.2.4 then detail the feedback comments received in relation to need for the project along with our responses. It should be noted, that not all respondents who provided feedback comments confirmed whether they had comments or not. Table 2.2.1 Number of respondents commenting on the need to reduce the amount of sewage that enters the tidal River Thames (Q9) Respondent type Number of respondents Comments Statutory consultees 2 - Consumer Council for Water (CCW) - Orange Telecom (OT) Local authorities 4 - London Borough of Hammersmith and Fulham (LBHF) - London Borough of Southwark (LBS) - Royal Borough of Greenwich (RBG) - Sevenoaks District Council (SDC) Landowners Community consultees Petitions Total 56 612 0 674 16 413 0 430 61 4,814 9 4,915 0 13 No comments 1 No response 18

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2 The need, solution, tunnel route and alignment

Supportive and neutral feedback comments


Table 2.2.2 Supportive and neutral feedback comments in relation to the need to reduce the amount of sewage that enters the tidal River Thames Ref 2.2.2 Supportive and neutral comments General support for the project including that the objective should be zero discharge except in very exceptional conditions. Agree that there is a need to reduce the amount of sewage entering the River Thames so that limits established by the Environment Agency and by experts throughout the world are met. The existing situation is unacceptable, in particular in relation to the effect on London's reputation. The River Thames is a valuable London asset and the proposals will maintain or improve its quality. Improving the quality of the tidal River Thames will increase quality of life. Improving the quality of the tidal River Thames will improve London's image. Important to reduce pollution and clean up the River Thames. Reasons for this included in order to prevent severe risks to the environment as well as potential health risks. The existing situation will worsen if no action is taken. Need to protect river wildlife from the effects of combined sewer overflows. Wildlife cited included: wildlife found in the British channel and other British estuaries; birds; fish species including smelt; sand smelt; salmon; dace; flounder; common goby and bass. Reducing sewage entering the River Thames will support economic activity. Reducing sewage entering the River Thames will encourage tourism. Need to comply with the Urban Waste Water Treatment Directive (UWWTD) and thereby avoid EU fines. Respondent ID No. Our response Your comments are noted. The primary purpose of the proposed works is to reduce the amount of untreated wastewater that is discharged into the tidal Thames and improve water quality in order to meet legal requirements. This will have benefits for residents, visitors, business and wildlife. It should be noted that it would not be cost-effective to intercept all combined sewer overflow (CSO) events that could occur as the size of the project would be much larger with much greater cost. The greater project size would have far larger impacts and the costs would be prohibitive when compared to the marginal benefits achieved. For example, we are reducing CSOs that occur up to 60 times per year to four or fewer (with such residual discharges occurring in the winter months). Whereas if the control target was one event or fewer, the project storage volume (or tunnel length and/or diameter) would at least double. The Environment Agency has agreed that the capture of 96 per cent of the current discharge in a typical year leaving four events or less is a practical and cost-effective level of control.

12544, 7003, 7012, 7174, 7175, 7217, 7249, 11 7289, 7366, 7536, LR13417 See annex B of this report 721

2.2.3

2.2.4

9003LO, 7198, 7231, 7404, 7528, 7744, 7855, 7988, 8450, 8501, 8777, 9299, LR9275 11683, 12008, 7108, 7124, 7128, 7458, 8688, LR9491 13363, 8538, 8685, 8813, 9012, LR9275 8231 (LR)RBKC, 7024, 7159, 7342, 7447, 7489, 7758, 7813, 8039, 8186, 8890, 9395, 9475

13

2.2.5

2.2.6 2.2.7 2.2.8

6 1 13

2.2.9 2.2.10

7623, 9282 11373, 12023, 7198, 7231, 7326, 7457, 7489, 7801, 7855, 8200, 8323, 8399, 8453, 8812, LR13473, LR9491

2 16

2.2.11 2.2.12 2.2.13

7198, 7997, 8685 7243 (LR)CCW, 13363, 7243, 8685, LR9315, LR9447

3 1 6

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2 The need, solution, tunnel route and alignment Ref 2.2.14 Supportive and neutral comments Reducing the amount of sewage entering the River Thames will improve property prices along the riverfront. Reducing the amount of sewage entering the River Thames will bring ecological benefits including in downstream Marine Conservation Zones. The existing situation is a health hazard to users of the River Thames. Reducing sewage entering the River Thames will bring recreational benefits. There is a need to update and future proof our sewerage infrastructure. This will ensure that population and housing growth can be catered for. Respondent ID 7489 No. 1 Our response

2.2.15

EA, RBG, SDC, 8399, 9012, 9030, 9282, LR9315, LR9491

2.2.16

EA, 11631, 7198, 7251, 7457, 7747, 7801, 7855, 8188, 8222, 8399, 8493, 8637, 8638, 9257, 9282, LR13473 SDC, 7243, 7326, 8188, 9012, LR13473, LR9121, LR9154 (LR)CCW, 9285LO, 11446, 11635, 12952, 13161, 13170, 13363, 7025, 7198, 7418, 7801, 7851, 7865, 7905, 7928, 7951, 8027, 8039, 8099, 8109, 8200, 8231, 8447, 8741, 8758, 9027, 9042, 9204, LR9154, LR9447, LR9491

17

Noted. The proposed works will secure long-term benefits in terms of the water quality of the tidal River Thames and thereby reduce the risk of harm to river users.

2.2.17 2.2.18

8 32 Agreed. The Needs report confirms that the existing sewerage system does not have sufficient capacity to accommodate sewage and storm water during periods of rainfall, which results in discharges into the River Thames after as little as 2mm of rainfall. This problem will only be exacerbated by projected population growth and climate change. Once the storage tunnels have been developed and are in operation they will be a strategic component of Londons infrastructure and will provide flexibility to adapt the network for future conditions, including opportunities for the flows from new sewerage infrastructure to be diverted to the tunnel. Work has been underway on examining the solutions to the problem of sewage discharges to the River Thames for more than 10 years, initially through the independently chaired Thames Tideway Strategic Study (TTSS) group. Given the importance of properly meeting the objective for the project and the complexity of the proposed solution, the evolution of the tunnel has been rapid compared with the time taken to develop other large London projects such as Crossrail, East London Line improvements and Thameslink 2000. The timetable for delivery of the Thames Tunnel project is set out in the Timing project information paper and is the earliest possible delivery given the construction work involved. Your comments are noted.

2.2.19

This issue should be addressed as soon as 7046, 7198, 7251, 7287, 7312, 7574, 7684, 7768, 7905, 8078, 8099, 9012, 9139 possible to provide sufficient capacity for population growth and to provide a healthy environment for river users and residents living close to the River Thames. This issue should have been addressed sooner. Reasons for this included: - given the ever-growing community. Understand why this issue needs to be addressed. Project addresses the effects of climate change. Other reasons for support included: - it will address visual impacts of pollution on the river and foreshore - it will provide a positive improvement to London's environment - sewage spills for which we will have to pay large fines should not be allowed - the suggestion that the UK should have 7620, 7905, 8016, 8740

13

2.2.20

2.2.21 2.2.22 2.2.23

7017, 7100, 7243, 7280, 7772, 8495, 8534, 8644, 8761, 8763, 9078, 9189 7855 EA, GLA, 7383, 8281, 8399, 8453, 9030, 9282

12 1 8

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2 The need, solution, tunnel route and alignment Ref Supportive and neutral comments Respondent ID lower standards of cleanliness because of the current economic situation is unacceptable - to improve the River Thames we are going to have to make sacrifices, which includes putting up with building disruption and increases to our water bills - the proposals will lead to improvements in biological water quality within the River Thames as measured in accordance with the Water Framework Directive. Not qualified to comment on this technical matter. 7168, 7495, 8284, 9089 No. Our response

2.2.24

The purpose of consultation is to explore as fully as possible what those with an interest in the project think about our proposals. We will have regard to comments received from both technical and non-technical consultees.

Qualified support
Table 2.2.3 Supportive (qualified) comments in relation to the need to reduce the amount of sewage that enters the tidal River Thames Ref 2.2.25 Qualified support comments Agree with the need to reduce the amount of sewage entering the River Thames, but disagree/concerned with the proposed solution/route/proposed sites. Respondent ID 7285LO, 7996LO, 8082LO, 8304LO, 8410LO, 8795LO, 8796LO, 8949LO, 9392LO, 10735, 12051, 12314, 13171, 13395, 13469, 7003, 7037, 7045, 7102, 7120, 7135, 7155, 7167, 7190, 7237, 7245, 7277, 7372, 7396, 7409, 7420, 7427, 7428, 7438, 7446, 7451, 7464, 7483, 7485, 7490, 7514, 7556, 7613, 7639, 7648, 7661, 7663, 7693, 7743, 7791, 7804, 7808, 7828, 7831, 7856, 7894, 7919, 7933, 7967, 7968, 7972, 7982, 7995, 8006, 8015, 8026, 8089, 8090, 8114, 8203, 8204, 8209, 8237, 8242, 8282, 8313, 8330, 8354, 8396, 8402, 8404, 8412, 8478, 8497, 8528, 8557, 8565, 8578, 8581, 8640, 8642, 8692, 8725, 8726, 8727, 8740, 8755, 8764, 8766, 8770, 8780, 8786, 8804, 8831, 8834, 8844, 8854, 8856, 8857, 8874, 8878, 8880, 8897, 8900, 8903, 8937, 8986, 8998, 9013, 9055, 9088, 9098, 9099, 9101, 9137, 9153, 9262, 9349, 9353, 9361, 9388, 9445, 9446, 9476, 9486, 9494, 9496, 9497, LR13498, LR9112, LR9280, LR9398, LR9471 No. 143 Our response The need for a full-length storage tunnel solution is set out in the Needs report, which is available on our consultation website. Both the previous government, on 1 March 2010, and the Coalition Government, on 7 September 2010, 16 November 2010 and 3 November 2011 indicated their support for the project in ministerial statements and have proposed that it should be designated as a nationally significant infrastructure project (NSIP). As set out in the Route and tunnel alignment project information paper, the Abbey Mills route remains our preferred route because: it is the shortest route; it is the least disruptive and most cost-effective option, costing 20 per cent less compared to the other two options, while still meeting all the required environmental objectives; it requires the least number of worksites; and it requires less tunnelling at depth through chalk in the east. Deep tunnelling through chalk is potentially more difficult and would bring greater health and safety issues. In relation to our proposed sites, the sites that we consulted on at phase two consultation have been identified through an extensive site selection process (see our Site selection methodology paper on our website). We consulted and agreed the methodology prior to its use with key stakeholders including potentially directly affected local authorities and utilised a multidisciplinary approach to assess potential CSO sites and main tunnel/connection tunnel drive options against engineering, planning, environmental, property and community considerations. We recognise that, given the locations where we are seeking to construct and operate the tunnel, many of the shortlisted sites are constrained in some way. However, based on our assessment we

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2 The need, solution, tunnel route and alignment Ref Qualified support comments Respondent ID No. Our response consider that on balance our preferred sites are the most suitable. For further details on the results of the site selection process, refer to the Phase two scheme development report. We have been assessing the likely significant effects that may arise as a result of the works as part of an environmental impact assessment. This will set out measures necessary to mitigate any significant adverse effects that are identified. An Environmental statement, which records the findings of the environmental impact assessment, will accompany our DCO application. The initial environmental assessment work that has been carried out on the project is contained within the PEIR, which is available on our website. As part of the phase two consultation, we also sought feedback on the potential effects arising from our proposals and how the effects will be mitigated. Where possible, we will take feedback comments into account as we develop our proposals. Cost benefit analysis has already been undertaken, which showed that a storage and transfer tunnel option, combined with improvements at sewage treatment works and the Lee Tunnel had the highest net benefits. This work informed the Ministerial Statement in March 2007 and the request that we develop a tunnel solution. The Government has undertaken further cost benefit analysis, which informed the Ministerial Statement in November 2011, in which the Secretary of Statement said we continue to believe that a tunnel represents the preferred solution for dealing with the untreated sewage that is polluting the River Thames. As the project develops, we have been and will continue to be closely scrutinised by the industry economic regulator Ofwat and by the Department for the Environment, Food and Rural Affairs (Defra). Agreed. The Needs report confirms that the existing sewage system does not have sufficient capacity to accommodate sewage and storm water during periods of rainfall, which results in frequent discharges into the River Thames. This problem will only be exacerbated by population and housing growth. Once the storage tunnel has been developed and is in operation it will be a strategic component of Londons infrastructure and will provide flexibility to adapt the network for future conditions, including opportunities for the flows from new sewerage infrastructure to be diverted to the tunnel. The UWWTD contains the European Unions requirements concerning the collection, treatment and discharge of wastewater. The objective of the Directive is to protect the environment from adverse effects of wastewater discharges. The requirements of the UWWTD have been transposed into domestic legislation in the Urban Waste Water Treatment Regulations 1994. The legal drivers for the project are set out in the Needs report. These derive from the UWWTD and the Water Framework Directive (WFD). The project is needed to ensure that the UK complies with the requirements of the UWWTD. It will also help to achieve the objectives of the WFD. The European Commission (EC) is taking action against the UK for alleged breach of the UWWTD in respect of discharges of

2.2.26

Agree with the need to reduce the amount of sewage entering the River Thames, but concerned about effects that will arise from addressing the problem. The impacts associated with addressing this problem need to be proportionate to the benefits.

13494LO, 7216, 7223, 7297, 7351, 7420, 7616, 7731, 7864, 8037, 8202, 8242, 8285, 8566, 8654, 8775, 8792, 8799, 9135, LR9236 7259, 8671, 8892, 9125

20

2.2.27

2.2.28

The costs associated with addressing this problem need to be proportionate to the benefits.

7259, 8462, 8473, 8909

2.2.29 2.2.30

London's existing sewage infrastructure does not have the necessary capacity. The current system is inadequate/ in need of modernisation.

8047 7163

1 1

2.2.31

Qualified support subject to: - provide clarification regarding the reasons for EU involvement

OT, 7277, 7312, 7754, 7871, 8021, 8335, 8690, 8871, 8923

10

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2 The need, solution, tunnel route and alignment Ref Qualified support comments Respondent ID No. Our response untreated sewage in the River Thames. Under article 258 of the Treaty of Lisbon, the EC has powers to take legal action when it considers that a member state is not respecting its obligations under the UWWTD. On 16 June 2010, the EC launched legal proceedings before the European Court of Justice for alleged failure to comply with obligations under the UWWTD in relation to discharges of urban wastewater into the Thames. An oral hearing was held on 10 November 2011 and on 26 January 2012 the Advocate General issued an opinion which recommends that the court should declare that the UK Government has failed to comply with requirements of the UWWTD. While the Advocate Generals opinion recognises that the UK Government intends to install a storage and transfer tunnel to address overflows into the River Thames, the proposed action against the Government is to be taken against previous unacceptable discharges into the River Thames. The decision of the court has not yet been issued, but it has the power to seek fines consisting of a lump sum and a periodic penalty, which could amount to considerable sums. It is therefore necessary for action to be taken to avoid such penalties being applied for future non-compliance with the UWWTD. The need for the Thames Tunnel project has been reinforced by the Ministerial Statement in November 2011 that said: we continue to believe that a tunnel represents the preferred solution for dealing with the untreated sewage that is polluting the River Thames and the report published by Defra on November 2011 entitled Creating a River Thames fit for our future: A strategic and economic case for the Thames Tunnel This report concludes a tunnel solution remains the most appropriate and cost-effective of the solutions considered. We have considered a number of options to reduce the amount of untreated sewage that flows into the River Thames according to the timetable specified by Government, including sustainable urban drainage systems (SuDS), separation of the sewerage system, and bubblers and skimmers. However, none of these options were considered viable when compared with a storage and transfer tunnel solution. We have also considered the recommendations of the Selbourne Commission and others who have suggested alternatives to the Thames Tunnel project and we do not consider that these represent viable alternatives, within the timescale specified by the Government.] The Thames Tunnel project is therefore our preferred solution since it addresses the problem of sewage entering the River Thames in the most cost-effective way and within the required timescale. Our response to the Selbourne Commission can be found on our website Consideration of the key issues raised by the Selbourne Commission is also dealt with in section 5 of the Waste Water National Policy Statement, Appraisal of Sustainability Post Adoption Statement, March 2011. In relation to the comment that the solution should be as cheap as possible, we consider that the Thames Tunnel project is the most costeffective solution. This is supported by a government report entitled Creating a River Thames fit for our future: A strategic and economic

- the Thames Tunnel project must not become a profit making venture - confirmation that it is the most appropriate solution
- if experts consider that it is necessary

then agree with proposals

- ensuring that the chosen solution is as

cheap as possible

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2 The need, solution, tunnel route and alignment Ref Qualified support comments Respondent ID No. Our response case for the Thames Tunnel, which contains an appraisal of alternative solutions and concludes that a tunnel solution remains the most appropriate. A combined or storm sewer discharge is a combination of foul sewage and surface water runoff. It is classified as raw sewage because it is untreated. The proportion of foul sewage in combined sewage is highly variable as it will depend not only on the intensity of the rainfall but will also change throughout the duration of the rainfall event. This proportion can typically vary from as high as 80 per cent foul sewage to five or ten per cent. However, when it rains and creates a first flush this will pick up the pollutants and materials from streets and the sediment already in the sewer system. This means the pollutant load can be significant at the start of a combined sewer discharge. The end of the discharge is less polluted but still contains foul sewage from peoples homes and businesses. Water quality pollution statistics from combined sewer discharges can therefore be very variable and dependent upon rainfall, how dry it has been before the discharge and the source of water contributing to the discharge. The proposed switch facility is not currently located within close proximity to our preferred route or sites, and therefore we do not anticipate that the switch facility will be affected. An integral part of the pre-application process is the legal requirement that we consult with the communities and stakeholders in the vicinity of the tunnel route and the sites we intend to use in constructing and operating the project, and that we take account of all the comments received in response to consultation. We also need to have regard to guidance issued by the Secretary of State in respect of the preapplication consultation requirements. The process is intended to be open and transparent and to ensure that project promoters give careful consideration to consultation responses and where necessary adjust their proposals accordingly. We are committed to this approach. While we understand the concerns of bill payers about the implications for our wastewater charges, the way in which we are regulated means that a standard approach is adopted across the water industry. Major improvements to clean up rivers and beaches are paid for by the customers of the relevant water companies.

- concerns raised regarding accuracy of

storm water flows data being resolved

- the proposed works not affecting the

operation of a telecoms switch facility


- ensuring that concerns of the

community are addressed

- costs not being borne by customers.

Objections, issues and concerns


Table 2.2.4 Objections, issues and concerns in relation to the need to reduce the amount of sewage that enters the tidal River Thames Ref 2.2.32 Objections, issues and concerns Do not agree that there is a need to reduce the amount of sewage entering the River Thames. Respondent ID No. Our response The needs case for the Thames Tunnel project is set out in detail in the Needs report, which is available on our website. It is also summarised in a non-technical form in our publications Why does London need the Thames Tunnel? and Why does Londons economy need the Thames Tunnel?. The need for the project has been confirmed and reaffirmed

7260LO, 8278LO, 9110LO, 11030, 11226, 34 11372, 11686, 11753, 12419, 12504, 12927, 13019, 13123, 13191, 7276, 7315, 7321, 7394, 7395, 7434, 7469, 7497, 7507, 7841, 7892, 8191, 8210, 8540, 8737, 8923, 9097,

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2 The need, solution, tunnel route and alignment Ref Objections, issues and concerns Respondent ID LR13390, LR13446, LR9136 No. Our response both by the past and present Government. This was made clear in written Ministerial Statements to Parliament in September 2010 and again in November 2011. Further reinforcement of the need for the project is contained in the documents published by Defra in November 2011 Creating a River Thames fit for our future: a strategic and economic case for the Thames Tunnel and Costs and benefits of the Thames Tunnel. The National Policy Statement (NPS) for Waste Water, which was designated on 26 March 2012, clearly states that the need for the project has been demonstrated. It concludes that detailed investigations have confirmed the case for a Thames Tunnel as the preferred solution. The designation of the NPS was supported by an Appraisal of Sustainability Post-Adoption Statement which contains further detail on the significant amount of work undertaken to establish the need for the Thames Tunnel project and assess alternative options, on the basis of which the government considers the need for the project to be established. Having regard to the extensive work that has been undertaken since 2000, as detailed in the reports mentioned above, we consider that the need for the project has been clearly demonstrated. In relation to disruption caused by construction works, we have been assessing the likely significant effects that may arise as a result of the works as part of an environmental impact assessment. This will set out measures necessary to mitigate any significant adverse effects that are identified. An Environmental statement, which records the findings of the environmental impact assessment, will accompany our DCO application. The initial environmental assessment work that has been carried out on the project is contained within the PEIR, which is available on our website. As part of the phase two consultation, we also sought feedback on the potential effects arising from our proposals and how the effects will be mitigated. Where possible, we will take feedback comments into account as we develop our proposals. We recognise that water quality has improved and that in some locations along the River Thames, there may not be visible signs of water pollution, although overflows from CSOs can result in visible litter being discharged into the river. Despite the improvements that have already been achieved, there is still an urgent need to reduce discharges of untreated sewage into the River Thames to ensure compliance with the UWWTD and the Urban Waste Water Treatment Regulations 1994, which transpose the UWWTD into UK legislation. Spills from CSOs into the River Thames can lead to fish kills due to the reduced levels of oxygen in the river; the Thames Tunnel project is therefore required to continue to improve water quality. Also, as population increases, the frequency of spills will increase, because the current capacity of the existing sewage system is put under further strain. The existing sewers are generally in a good physical condition but their capacity is inadequate. This project will provide the additional capacity required.

Reasons included: - there will be disruption and damage to the quality of life of local residents during the construction period

- no problems caused by sewage either

by smell or sight have been noticed

- it would not be needed if maintenance

of the sewer network had been undertaken

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2 The need, solution, tunnel route and alignment Ref Objections, issues and concerns
- query why if this is an EU requirement,

Respondent ID

No.

Our response Regarding the timescale for the project, as set out above, optioneering studies commenced in 2000. Given the importance of meeting the environmental objectives for the project and the complexity of the proposed solution, the evolution of the tunnel has been rapid compared with the time taken to develop other large London projects such as Crossrail, East London Line improvements and Thameslink 2000. The timetable for delivery of the Thames Tunnel project is set out in the Timing project information paper and is the earliest possible delivery given the construction work involved. Due to the tidal nature of the River Thames, sewage discharged into the river, is moved into the Channel. Depending on where the discharge into the River Thames occurs, this process can take several weeks or even months. While the River Thames is able to remove the sewage, it cannot treat the sewage or the effects on the environment and recreational users of the River Thames. The Thames Tunnel project will mean that sewage captured by the main tunnel will be treated and effects on the environment etc arising from the discharges avoided.

the project has only just commenced

- the River Thames is able to remove

sewage naturally.

2.2.33

This is not an essential project; the case for a tunnel has to be proved rather than just being desirable. Further clarification required regarding whether this is a wish list rather than essential project. More information about the extent of the problem is needed. Specific comments included: - query which CSOs are most polluting

12752, 12959, 7252, 7321

4 For our response, refer to first two paragraphs of response contained in paragraph 2.2.32.

2.2.34

12267

2.2.35

7394, 7669, 7690, 7733, 7915, 8075, 8206, 8559, 8831, 8909, 9357, 9467

12

The response at paragraph 2.3.32 also applies to the objections, issues and concerns raised within this paragraph. You may wish to consider the response at paragraph 2.3.32 as well as the text below. The Environment Agency has categorised the CSOs into four groups, which are based on the environmental impact and frequency of operation. For further information on the four categories refer to chapter four of the Needs report. Table 4.2 of this document also lists each of the CSOs and which category they fall into. The discharges from Mogden Sewage Treatment Works are physically separate from the Beckton and Crossness catchments, and therefore any discharges within the Mogden catchment are in addition to the 39 million tonnes which are discharged from 57 CSOs with the Beckton and Crossness catchments. We are upgrading Mogden Sewage Treatment Works to increase its treatment capacity by around 50 per cent. This will significantly reduce both the quantity and the number of times we need to discharge storm sewage from the sewage treatment works into the River Thames following heavy rain. Our records show that over the last 13 years, Mogden Sewage Treatment Works has needed to discharge in to the River Thames on just over 1,000 days. Many of those discharges were very small, with the total amounting to 77.7 million tonnes of storm sewage, acknowledging that all storm discharges were subject to some screening and

- query what can be done to treat

effluence at sites like Mogden Sewage Treatment Works, which are likely to be more polluting than some of the CSOs being intercepted

Supplementary report on phase two consultation

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2 The need, solution, tunnel route and alignment Ref Objections, issues and concerns Respondent ID No. Our response settlement. This represents around five per cent of the total flow arriving at the sewage treatment works. If the current improvements we are making had been in place, and assuming the same weather patterns were experienced, we estimate that the sewage works would only have discharged in to the River Thames on a total of five occasions during those 13 years, following exceptional amounts of rainfall with discharges totalling around 3.3 million tonnes. In the future, we would expect flows reaching the sewage treatment works to overflow into the River Thames about once every two and a half years. Improvements to the sewage treatment works will mean that even where there are discharges, the most polluting flows will have been captured for treatment. As set out in Why does London need the Thames Tunnel, the Thames Tunnel project will result in the annual number of CSO discharges falling from up to 60 a year to just four or fewer. If the Thames Tunnel project were not implemented, the annual average volume of all CSO discharges to the River Thames would still be 18 million cubic metres and discharges would still occur nearly 60 times in a typical year, which is still far too high. The Thames Tunnel project is not a reaction to 'freak' flash floods in recent years. The Thames Tideway Strategic Study (TTSS) was established in 2000 to find a solution to an identified problem, namely impact of intermittent discharges of storm sewage in the Thames Tideway, and to identify objectives for improvement and propose potential solutions having regard to costs and benefits. Based on over a decade of analysis we consider that the Thames Tunnel project is necessary to address this problem. The quoted figure of 39 million cubic metres represents the spill in a typical year. The range is from 10 million cubic metres to 90 million cubic metres. This is based on modelling, verified by monitoring and agreed with the Environment Agency. The West Putney CSO was monitored through equipment placed in the overflow sewer. As the River Thames is a tidal system the surface area is not a constant. The EU Directives apply to the whole water body so this is not an appropriate metric to consider.

- query what the scale of the reduction

that would be achieved and Thames Water's confidence at achieving this

- this is a reaction to 'freak' flash floods

over recent years

- query how accurate the figure of 39m

tonnes is

- on how West Putney CSO was sampled - an explanation of the surface area of

the river which fails EU water standards (1) as a result of current CSO events and (2) as a result of the proposed modifications is required
- query how much infiltration has affected

capacity
- on the maintenance condition of the

Infiltration has a limited effect on discharges which are caused by rainfall. The existing sewers are generally in a good physical condition 8807LO, 7468, 9357, LR9278 4 The response at paragraph 2.3.32 also applies to the objections, issues and concerns raised within this paragraph. You may wish to consider the response at paragraph 2.3.32 as well as the text below. The Needs report concludes that the installation of water meters and

sewers. 2.2.36 Should reduce volume of wastewater entering the sewage system to address this problem by means of:

Supplementary report on phase two consultation

2-10

2 The need, solution, tunnel route and alignment Ref Objections, issues and concerns - installing individual water meters - building regulations to ensure that new housing includes water meters. Respondent ID No. Our response other water conservation measures will not be effective since they will not reduce foul sewage flows to a sufficient extent to counteract the impacts of population growth. In addition, as little as 2mm of rainfall can result in a discharge into the River Thames. The installation of water metres would not address rainfall which flows into the combined sewage system. In relation to building regulations, these only affect new residential buildings that are built and do not apply to new buildings which are constructed for other purposes or to the existing building stock. In respect of existing development, we also cannot control the amount of wastewater entering the sewage network. As the population grows, so will the amount of sewage. Since the problem of sewage discharges results from both rainfall and wastewater entering the sewage system, this intervention alone will not address the problem. The case for the Thames Tunnel project has been demonstrated through various studies undertaken since 2000. The documents relating to the needs case including the Needs report are available on our website. The conclusions of the Needs report have been reinforced by the Governments report Creating a River Thames fit for our future: A strategic and economic case for the Thames Tunnel, which was published in November 2011. We therefore consider that the Thames Tunnel project is essential to address the problem. The Thames Tunnel project is also necessary to address an existing problem. The Needs report confirms that the existing sewerage system does not have sufficient capacity to accommodate sewage and storm water during periods of rainfall, which results in discharges into the River Thames after as little as 2mm of rainfall. We recognise that the water quality of the tidal River Thames has improved. This is a result of investment by many bodies including projects on which we have worked with the Environment Agency as recognised by the award of the Theiss River Prize. Despite the improvements that have already been secured, there is still an urgent need to reduce discharges of untreated sewage into the River Thames to ensure compliance with the UWWTD and the Urban Waste Water Treatment Regulations 1994, which transpose the UWWTD into UK legislation. Spills from CSOs into the River Thames can lead to fish kills due to the reduced levels of oxygen in the river. Discharges can also result in litter entering the River Thames, which given its nature, may affect the health of recreational users of the river. The Thames Tunnel project is therefore required to continue to improve water quality. Also, as population increases, the frequency of spills will increase, because the current capacity of the existing sewage system will be put under further strain. The case for the tunnel is documented in the Needs report. The response at paragraph 2.3.38 also applies to the objections, issues

2.2.37

Query whether the Thames Tunnel project 11038, 11456, 11502, 11686, 11798, 11955, 9 is really necessary to address the problem; 12138, 7346, 7469 it appears it is being installed to address an expected future problem.

2.2.38

Water quality in the River Thames has already improved significantly including as recognised by the Greater London Authority, Environment Agency and the Theiss River Prize.

13397LO, 8321LO, 9131LO, 10155, 11607, 32 12231, 12495, 12722, 12803, 12819, 12902, 7117, 7120, 7208, 7209, 7232, 7422, 7549, 7900, 8643, 8647, 8662, 8680, 8683, 8728, 8737, 8820, 8838, 9097, 9303, 9446, LR13472

2.2.39

It is not clear that there is a problem with

12419, 12525, 12821, 12824, 12902, 12937, 26

Supplementary report on phase two consultation

2-11

2 The need, solution, tunnel route and alignment Ref Objections, issues and concerns water quality. Reasons included: - it is not clear why this problem needs to be addressed now
- query the validity of the water quality

Respondent ID 13021, 13168, 13199, 7238, 7892, 7900, 8041, 8083, 8094, 8109, 8225, 8411, 8459, 8649, 8734, 8838, 8909, 9015, 9303, 9351

No.

Our response and concerns raised within this paragraph. You may wish to consider the response at paragraph 2.3.38 as well as the text below. A combined or storm sewer discharge is a combination of foul sewage and surface water runoff. It is classified as raw sewage because it is untreated. The proportion of foul sewage in combined sewage is highly variable as it will depend upon not only the intensity of the rainfall but will also change throughout the duration of the rainfall event. This proportion can typically vary from as high as 80 per cent foul sewage to five or ten per cent. However, when it rains and creates a first flush this will pick up the pollutants and materials from streets and the sediment already in the sewer system. This means the pollutant load can be significant at the start of a combined sewer discharge. The end of the discharge is less polluted but still contains foul sewage from peoples homes and businesses. Water quality pollution statistics from combined sewer discharges can therefore be very variable and depend on rainfall, how dry it has been before the discharge and the source of water contributing to the discharge. While rubbish may be thrown into the River Thames, this is not the main source of pollution. Our response at paragraph 2.2.32 sets out why we consider there is a need to reduce CSO discharges.

pollution statistics

- the problem is with rubbish thrown into

the River Thames which is not from CSO discharges. 2.2.40 Whether the project necessary given that the frequency of overflows and volume of the discharge is low. Particular comments were raised in relation to: - the proportion of rainwater to sewage in discharges; over 95 per cent of discharges is considered to be rainwater - the construction of the Lee Tunnel will address 21 out of the 39 million tonnes of combined sewage entering the River Thames. 13397LO, 8807LO, 9092LO, 9110LO, 11581, 11740, 7208, 7209, 7364, 7395, 7456, 7529, 7568, 7637, 7663, 7704, 7843, 7920, 8091, 8472, 8673, 8738, 8742, 8776, 8909, 9007, 9199, 9303, 9357, 9461 30

The frequency of discharges can be once a week and the annual volume is around 39 million cubic metres in a typical year. We do not consider this to be low. Once rainwater and sewage is mixed within the sewerage system, it becomes combined sewage and is inseparable. It is therefore classified as raw sewage because it is untreated. The proportion of foul sewage in combined sewage is highly variable as it will depend upon not only the intensity of the rainfall but will also change throughout the duration of the rainfall event. This proportion can typically vary from as high as 80 per cent foul sewage to five or ten per cent. Therefore, even if the proportion of foul sewage is relatively low it still needs to be treated. As set out in Why does London need the Thames Tunnel, if the Thames Tunnel project is not implemented, the annual average volume of all CSO discharges to the River Thames would still be 18 million cubic metres and discharges would still occur nearly 60 times in a typical year. This is still too high to meet the objective of securing compliance with the UWWTD. We consider that we have undertaken a thorough and comprehensive consultation exercise. As part of this, we carefully considered the information we made available at our phase two consultation to ensure that consultees had sufficient information to respond to the consultation. The need for the project is described and illustrated in the phase two consultation material including the Overflow project information paper, which provides an overview with more detail in the Needs report. We are confident therefore that the information we have provided is sufficient.

2.2.41

Insufficient information has been provided on the extent of the problem.

8779

Supplementary report on phase two consultation

2-12

2 The need, solution, tunnel route and alignment Ref Objections, issues and concerns In particular, the need is not so much to reduce the amount of sewage as to reduce local concentrations and adverse effects. Respondent ID No. Our response We disagree that the need is not about the amount of sewage. We are unable to influence the extent of dilution that is available as this is due to freshwater river flows and tidal movement. Hence, the need is associated with the volume of discharges and the adverse impact this has on the River Thames. 8647, 8737, LR13408 3 We have a range of duties to the environment and our customers and we have consistently given high priority to leakage of clean water and preventing flooding. The existing sewers are generally in a good physical condition but their capacity is inadequate. We are regulated by Ofwat, who determines our priorities for future work. A careful balance is therefore sought between maintaining existing infrastructure and, where necessary, improving our infrastructure against the costs of not doing so. We are not always allowed to spend the funding as we would like, for instance, our programme of Victorian Mains Replacement works, which addresses leakage, was not fully funded in the 2010 price review. But this does not mean that such important work cannot and does not proceed. Water resources are an important issue, particularly at the present time. However the problem of CSOs discharging into the River Thames is also important. Thames Water is large enough to deal with multiple issues. It is, however, a regulated utility and we are only allowed to spend certain amounts on Victorian Mains Replacements. With regard to the comment relating to reservoirs. Thames Water has recently sent its draft final Water Resource Management Plan for the period 2010-2035 to the Secretary of State. This no longer selects a reservoir in the preferred scheme for the London Water Resources zone, but further work to define the yield, cost, and on-going risks will be carried out for our next plan, which is to be submitted in 2014. The response at paragraph 2.3.32 also applies to the objections, issues and concerns raised within this paragraph. You may wish to consider the response at paragraph 2.3.32 as well as the text below. Despite the improvements that have already been secured, there is still an urgent need to reduce discharges of untreated sewage into the River Thames to ensure compliance with the UWWTD and the Urban Waste Water Treatment Regulations 1994, which transposes the UWWTD into UK legislation. When there are spills from CSOs into the River Thames, this leads to fish kills due to the reduced levels of oxygen in the river. The Thames Tunnel project is therefore required to continue to improve water quality. Also, as population increases, the frequency of spills will increase, because the current capacity of the existing sewage system will be put under further strain. Furthermore, on 26 March 2012 the Government designated the Waste Water National Policy Statement. This reaffirms that it is government policy for the Thames Tunnel project to be taken forwards. Paragraph 2.6.34 states: "The examining authority and the decision maker should undertake any assessment of an application for the development of the

2.2.42

There are other more pressing issues to deal with including flooding, repairs to water supply pipes/upgrade works and the hose pipe ban. The latter could be addressed through provision of a reservoir. Work will delay other necessary improvements.

2.2.43

8806LO

2.2.44

Need to address the amount of sewage entering the River Thames is not properly evidenced. Reasons included: - there do not appear to be valid financial or ecological reasons

13397LO, 7394, 7414, 7900, 7914, 8543, 8737, 8753, 8804, 9243, 9467, LR9136

12

Supplementary report on phase two consultation

2-13

2 The need, solution, tunnel route and alignment Ref Objections, issues and concerns Respondent ID No. Our response Thames Tunnel on the basis that the national need for this infrastructure has been demonstrated. The appropriate strategic alternatives to a tunnel have been considered and it has been concluded that it is the only option to address the problem of discharging unacceptable levels of untreated sewage into the River Thames within a reasonable time at a reasonable cost." As part of the TTSS a modelling group was established. The work of this group is explained in their published reports and in section 4.7.3 of the Needs report. The modelling is based on a 34 year period and is agreed with the Environment Agency. In February 2012 Defra undertook a review of the need from a scientific perspective. Their publication Thames Tunnel Evidence Assessment indicates that the any limited shortfalls in the evidence base could easily be corrected and that they do not fundamentally affect the wider conclusions that support a tunnel solution. In March 2012 the Waste Water National Policy Statement that supports a tunnel solution was designated by the Government following a debate in Parliament. The need is therefore current and has recently been reaffirmed. Monitoring equipment is place in the sewer beneath a manhole as is standard practice and captures the complete flow. To place it too close to the river would be at risk of picking up incoming tidal flow. LBHF, 7331LO, 7156, 7394, 7422, 8411, 8459, 8531, 8673, LR9418 10 Cost benefit analysis has already been undertaken, which showed that a storage and transfer tunnel option, combined with improvements at sewage treatment works and the Lee Tunnel had the highest net benefits. This work informed the Ministerial Statement in March 2007 and the request that we develop a tunnel solution. The Government has undertaken further cost benefit analysis (set out in Creating a River Thames fit for our future: a strategic and economic case for the Thames Tunnel), which informed the Ministerial Statement in November 2011, in which the Secretary of Statement said: "we continue to believe that a tunnel represents the preferred solution for dealing with the untreated sewage that is polluting the River Thames. As the project develops, we have been and will continue to be closely scrutinised by the industry economic regulator Ofwat and by Defra. The disruption caused by the proposal has been raised. This was assessed by government as part of its cost benefit analysis, where it concluded that the tunnel represents the preferred solution. We have also been assessing the likely significant effects that may arise as a result of the works as part of an environmental impact assessment. This will set out measures necessary to mitigate any significant adverse effects that are identified. An Environmental statement, which records the findings of the environmental impact assessment, will accompany our DCO application. The initial environmental assessment work that has been carried out on the project is contained within the PEIR, which is available on our website. As part of the phase two consultation, we also sought feedback on the potential effects arising from our proposals

- there is insufficient historical data which

supports undertaking a project of this scale


- new information has emerged; the

forecasted need is therefore out of date

- concern that Thames Water is not

measuring full depth flows at the CSOs but at a single manhole prior to the overflow. 2.2.45 The cost of addressing this problem outweighs the benefits. Reasons for this included: - it is a disruptive proposal - public health, recreational and safety benefits are negligible - water quality has improved substantially over recent years.

Supplementary report on phase two consultation

2-14

2 The need, solution, tunnel route and alignment Ref Objections, issues and concerns Respondent ID No. Our response and how the effects will be mitigated. Where possible, we will take feedback comments into account as we develop our proposals. As a responsible organisation, we need to ensure that pollution in the River Thames is at an acceptable level. We do not consider that the public health, recreational and safety benefits which will be derived from the Thames Tunnel project are negligible. Furthermore, the recreational and public health benefits were considered by the Environment Agency when identifying the CSOs that need to be intercepted. For further details on the benefits of the Thames Tunnel project, refer to the Needs report. In relation to water quality, we recognise it has improved over recent years. Despite the improvements that have already been achieved, there is still an urgent need to reduce discharges of untreated sewage into the River Thames to ensure compliance with the UWWTD and the Urban Waste Water Treatment Regulations 1994, which transpose the UWWTD into UK legislation. Spills from CSOs into the River Thames can lead to fish kills due to the reduced levels of oxygen in the river. Discharges can also result in litter entering the River Thames, which given its nature, may affect the health of recreational users of the river. The Thames Tunnel project is therefore required to continue to improve water quality. Also, as population increases, the frequency of spills will increase, because the current capacity of the existing sewage system will be put under further strain. The TTSS established in 2000, led to three proposals being proposed to address discharges into the Crossness and Beckton catchments. These include: upgrades to sewage treatment works; the Lee Tunnel; and the Thames Tunnel project. Without these interventions, annual CSO discharges into the River Thames would reach 70 million cubic metres in a typical year by 2020. If the Thames Tunnel project is not constructed, the annual average volume of all CSO discharges to the River Thames would remain at 18 million cubic metres, which is too high. Further information is available in the Needs report and Why does London need the Thames Tunnel. Infraction proceedings relate to discharges of wastewater from CSOs into the River Thames in respect of the Beckton and Crossness catchments. The European Commission has proceeded with infraction proceedings against the UK Government with respect to this matter. The decision of the court has not yet been issued, but it has the power to seek fines consisting of a lump sum and a periodic penalty, which could amount to considerable sums. It is therefore necessary for action to be taken to avoid such penalties being applied for future non-compliance with the UWWTD. In relation to Mogden Sewage Treatment Works, the discharges are physically separate from the Beckton and Crossness catchments, and therefore any discharges within the Mogden catchment are in addition to the 39 million tonnes which are discharged from the 57 CSOs. We are upgrading Mogden Sewage Treatment Works to increase its treatment

2.2.46

The need can be addressed through existing projects such as upgrade works to the sewage treatment works including Mogden Sewage Treatment Works and the construction of the Lee Tunnel. In particular, in the recent EU court case, the resolution mostly related to discharges from the sewage treatment works and not the CSOs.

9092LO, 9093LO, 9131LO, 11502, 12663, 12664, 12709, 7022, 7364, 8041, 8091, 8542, 8653, 8658, 8774, 8838, 8891, 9007, 9303

19

Supplementary report on phase two consultation

2-15

2 The need, solution, tunnel route and alignment Ref Objections, issues and concerns Respondent ID No. Our response capacity by approximately 50 per cent. This will significantly reduce both the quantity and frequency of storm sewage discharges from the sewage treatment works into the River Thames following heavy rain. Our records show that over the last 13 years, Mogden Sewage Treatment Works has needed to discharge in to the River Thames on just over 1,000 days. Many of those discharges were very small, with the total amounting to 77.7 million tonnes of storm sewage, acknowledging that all storm discharges were subject to some screening and settlement. This represents around five per cent of the total flow arriving at the sewage treatment works. If the current improvements we are making had been in place, and assuming the same weather patterns were experienced, we estimate that the sewage works would only have discharged in to the River Thames on a total of five occasions during those 13 years, following exceptional amounts of rainfall with discharges totalling around 3.3 million tonnes. In the future, we would expect flows reaching the sewage treatment works to overflow into the River Thames approximately once every two and a half years. Improvements to the sewage treatment works will mean that even where there are discharges, the most polluting flows will have been captured for treatment. The UWWTD contains the European Unions requirements concerning the collection, treatment and discharge of wastewater. The requirements of the UWWTD have been transposed into domestic legislation by the Urban Waste Water Treatment Regulations 1994. In terms of the tidal Thames and River Lee, compliance with the UWWTD requires that sewage (domestic, industrial and rainwater run-off) is collected and conveyed to plants for secondary treatment, overflows are reduced and measures taken to limit pollution of the tidal Thames and the River Lee from CSOs. The European Commission (EC) is taking action against the UK for alleged breach of the UWWTD in respect of discharges of untreated sewage into the River Thames. Under article 258 of the Treaty of Lisbon, the EC has powers to take legal action when it considers that a member state is not respecting its obligations under the UWWTD. The EC issued a reasoned opinion on 26 January 2012 about the significant repeated discharges of untreated sewage into the River Thames. On 16 June 2010 the EC launched legal proceedings before the European Court of Justice for alleged failure to comply with obligations under the UWWTD in relation to discharges of urban wastewater into the Thames. An oral hearing was held on 10 November 2011 and, on 26 January 2012, the Advocate General issued an opinion which recommends that the court should declare that the UK Government has failed to comply with requirements of the UWWTD. While the Advocate Generals opinion recognises that the UK Government intends to install a storage and transfer tunnel to address overflows into the River Thames, the proposed action against the Government is to be taken against previous unacceptable discharges

2.2.47 2.2.48 2.2.49

The relationship of the project to the UWWTD is not fully understood. The European Commission, rather than scientific need, is driving the project. The only real justification for reducing the amount of sewage entering the River Thames is to avoid regulatory fines from the EU. Concern that there have not been discussions with the EC about whether the proposed action is sufficient to meet the UWWTD and Water Framework Directive. We should ignore the requirements of the UWWTD.

12458 12696, 13048, 7277, 7637, 8779, 8820, 8861 7208, 7209, 7843, 8472, 9446

1 7 5

2.2.50

8887LO, 7497, 9186

Supplementary report on phase two consultation

2-16

2 The need, solution, tunnel route and alignment Ref Objections, issues and concerns Respondent ID No. Our response into the River Thames. The decision of the court has not yet been issued, but it has the power to seek fines consisting of a lump sum and a periodic penalty, which could amount to considerable sums. It is therefore necessary for action to be taken to avoid such penalties being applied for future non-compliance with the UWWTD. In November 2011, the Secretary of State for Environment, Food and Rural Affairs, in a written Ministerial Statement, said: "the need to upgrade the sewerage system in London which in places is running out of capacity even in dry weather, and for a solution to the resulting environmental challenges in the Thames Tideway remains persuasive. I will today place in the Libraries of both Houses a paper Creating a River Thames fit for our future summarising the strategic and economic case for the Thames Tunnel project. This builds on the impact assessment produced in 2007. It explains why we continue to believe that a tunnel represents the preferred solution for dealing with the untreated sewage that is polluting the River Thames. Some of the issues identified in this document include the scientific justification based on research from relevant academics, for example the impact on fisheries. Phase one consultation was undertaken between 9 September 2010 and 14 January 2011. We publicised our phase one consultation in accordance with our Statement of community consultation (SOCC); methods included an advertisement in the London Evening Standard and local newspapers, sending letters to over 173,000 properties, holding exhibitions in the vicinity of preferred and shortlisted sites and provision of written material at exhibitions, on our website, at local libraries and town halls and on request. 2,866 individuals and organisations responded to phase one consultation, the findings from which are contained in our Report on phase one consultation. Where new sites have been brought forward at phase two consultation there is still the opportunity to comment on all the matters raised in phase one consultation. Therefore we do not consider that respondents who were not aware of phase one consultation have been disadvantaged in any way. Your comment is noted. Comments submitted as part of phase one consultation have been taken into account. Refer to our Report on phase one consultation for further details. The level of fines that may be imposed is not linked to the economic climate. It would be based on a published formula that has regard to the seriousness and duration of the breach, as well as the size of the country involved. Fines are calculated using equations that consider the duration and seriousness of the infringement and the individual Member States capacity to pay. The maximum daily penalty payment that could currently be imposed on the UK is 620,000 per day. The minimum size of a lump sum payment that could currently be imposed on the UK is 8,500,000 and there is no maximum lump sum payment. All UK tax payers may have to help foot the bill. Providing a balanced analysis in our consultation material was

2.2.51

Not aware of phase one consultation.

7361, 7383

2.2.52

Commented on the need for the project at phase one consultation. Other issues, concerns and objections raised included: - query whether heavy fines would be imposed. The scale of any potential penalties to the UK and the likelihood of fines being applied in the current fiscal environment appear overstated.
-

9109LO, 7157, 7339, 8728, LR9114

2.2.53

13397LO, 8658, 8680, 8737, 8849, 9303, 9467

- Thames Water is deliberately

Supplementary report on phase two consultation

2-17

2 The need, solution, tunnel route and alignment Ref Objections, issues and concerns misinforming the public of the need for their preferred solution Respondent ID No. Our response imperative and we do not agree that the material was inaccurate or misleading. All the material presented contained necessary information for consultees to understand our proposals and make their own judgements. Environmental objectives were developed in the TTSS. For further details of how the objectives were established refer to the TTSS, which is on our website. It is the view of government, as stated for example in the publication Creating a River Thames fit for our future: A strategic and economic case for the Thames Tunnel November 2011, that there is an adverse reputational impact on London as a result of the discharges to the Thames. It states that building the Thames Tunnel project will ensure that the UKs capital remains a flourishing tourist destination that is attractive for business, protecting the Londons reputation around the world. Future predications of discharges are adjusted for population growth and climate change.

- the desired standards which the project

is being measured against have not been justified - do not agree that London's international reputation is being damaged by current level of water quality

- it is the rate of discharge and highest

single event volume of discharge, adjusted for population growth and global warming event predictions that should be used in the projects design assessment.

2.3
2.3.1

The solution
During the phase two consultation, respondents were invited to comment on possible solutions for addressing the need to reduce the amount of sewage entering the tidal River Thames and the decision that a tunnel is the right way to meet that need (see question 10 of the phase two consultation feedback form, provided in appendix M to the Main report on phase two consultation). Table 2.3.1 sets out details of the different groups who responded to confirm whether they had comments or not. Tables 2.3.2 - 2.3.5 then detail the feedback comments received in relation to possible solutions for addressing the need for the project. It should be noted, that not all respondents who provided feedback comments confirmed whether they had comments or not. Table 2.3.1 Number of respondents commenting on our decision that a tunnel is the right way to meet the need to reduce the amount of sewage that enters the tidal River Thames (Q10) Respondent type Number of respondents Comments Statutory consultees 9 - Consumer Council for Water (CCW) - Crown Estate (CE) - English Heritage (EH) - London Councils (LC) - Greater London Authority (GLA) - NATS En Route (NERL) Safeguarding (NERL) - NHS Barking and Dagenham (NHSBD) No comments 1 - Environment Agency (EA) No response 11

Supplementary report on phase two consultation

2-18

2 The need, solution, tunnel route and alignment - Orange Telecom (OT) - The Highways Authority (HA) Local authorities 7 - London Borough of Hammersmith and Fulham (LBHF) - London Borough of Richmond Upon Thames (LBR) - London Borough of Ealing (LBE) - Royal Borough of Greenwich (RBG) - London Borough of Southwark (LBS) - London Borough of Waltham Forest (LBWF) - Sevenoaks District Council (SDC) Landowners Community consultees Petitions 52 2,785 1 - 256 signatories Total 2,854 530 2,635 22 506 0 59 2,548 8 1 - Olympic Delivery Authority Planning Decisions Team (ODA PDT) 9

Supportive and neutral feedback comments


Table 2.3.2 Supportive and neutral feedback comments in relation to the decision that a tunnel is the right way to meet the need to reduce the amount of sewage that enters the tidal River Thames Ref 2.3.2 2.3.3 2.3.4 2.3.5 2.3.6 2.3.7 Supportive and neutral comments The tunnel is the right solution, in particular because alternatives are not viable. The tunnel is the most practical and reasonable solution. The tunnel would be less disruptive than installing a separate sewage system. The tunnel offers a long-term solution. The tunnel is the most sensible solution. The tunnel is the most effective and efficient solution. In light of this, the London Plan also expresses specific support for the principle of the Thames Tunnel project. Respondent ID See annex B of this report LBW, 7147, 7264, 7290, 7735, LR13473 7761, 8450 7777, 8098, 8399, 8541 7445 GLA, 11591, 7198, 7530, 7800, 7801, 7855, 8188, 8399, 8741, 9282 No. 771 6 2 4 1 11 Our response We agree. Analysis has already been undertaken as part of the Thames Tideway Strategic Study (TTSS) and subsequent studies, which showed that a storage and transfer tunnel option, combined with improvements at sewage treatment works, had the highest net benefits including improvements to water quality and other environmental benefits, that it will cause less disruption than other alternatives investigated and offers a long-term solution to the problem. This work informed the Ministerial Statement in March 2007 and the request that we develop a tunnel solution. The Government has also recently published a report entitled Creating a River Thames fit for our future: A strategic and economic case for the Thames Tunnel. This report provides an update to the 2007 regulatory impact assessment and takes into account data that has emerged since that time and concludes that a tunnel solution remains the most appropriate and cost-effective of the solutions considered. The National Policy Statement (NPS) for Waste Water, which was

Supplementary report on phase two consultation

2-19

2 The need, solution, tunnel route and alignment Ref 2.3.8 Supportive and neutral comments The tunnel is the most cost-effective solution; in particular the data from Defra indicates that the economic benefits alone of a cleaner River Thames will exceed the costs involved. The tunnel is the most viable solution. The tunnel will deliver greatest improvements to water quality. The tunnel is the best solution from environmental perspective. The current sewage system is inadequate/ in need of modernisation. The tunnel builds on existing infrastructure and projects. The tunnel would cater for population and housing growth. The tunnel is considered to be sustainable. The tunnel should be constructed as soon as possible. Work on the tunnel should have commenced earlier. Respondent ID 11691, 7147, 7396, 7530, 7615, 8399, 9384 No. 7 Our response designated on 26 March 2012, clearly states that the need for the project has been demonstrated. It concludes that detailed investigations have confirmed the case for a Thames Tunnel as the preferred solution. The designation of the NPS was supported by an Appraisal of Sustainability Post-Adoption Statement which contains further detail on the significant amount of work undertaken to establish the need for the Thames Tunnel project and assess alternative options, on the basis of which the government considers the need for the project to be established.

2.3.9 2.3.10 2.3.11 2.3.12

8612, 8644, 9253, LR9236 7198, 9205 9287LO, 12367, 7198, 8399, 8765, 9030, 11373, 11558, 11971, 11972, 12530, 13115, 13133, 13363, 7539, 7804, 7951, 8231, 9042, 9170, LR9154, LR9447 7231 12744, 12786, 12807, 12985, 13133, 8741, LR9154 CoL, 7198 7046, 7133, 7198, 7251, 7287, 7404, 7457, 7615, 7629, 7690, 7758, 7988, 8222, 8399, 9139, 9257, LR13473 7323, 7690, 7905, 8893

4 2 6 16

2.3.13 2.3.14 2.3.15 2.3.16

1 7 2 17 Work has been underway on examining the solutions to the problem of sewage discharges to the River Thames for more than ten years, initially through the independently chaired TTSS group. Given the importance of properly meeting the objective for the project and the complexity of the proposed solution, the evolution of the tunnel has been rapid compared with the time taken to develop other large London projects such as Crossrail, East London Line improvements and Thameslink 2000. The timetable for delivery of the Thames Tunnel project is set out in the Timing project information paper and is the earliest possible delivery given the construction work involved. Agreed. As set out in our response to the Selbourne Commission, we consider that a tunnel is the only solution that will meet the objectives set by the TTSS and ensure compliance with the UWWTD within the timescale required. Agreed. Your comments are noted.

2.3.17

2.3.18

The tunnel is a rebuttal to the Selbourne Commission report.

7198, 8119, 8854

2.3.19 2.3.20

Ensures compliance with the UWWTD. Other supportive comments included: - respondents are willing to pay for Thames Tunnel project - Thames Water should provide more information to counter false claims against the Thames Tunnel project - respondents welcome the reduction in the number of proposed CSO worksites that encroach into the River Thames or

EA, 13363, 9282, LR9447 PLA, (LR)CCW, 9287LO, 7383, 7457, 7651, 7754, 7847, 8399, 8413, 8453, 8541, 8559, 8727, 8779, 8893, 9012, 9078, LR13473, LR9114, LR9121, LR9152

4 22

Supplementary report on phase two consultation

2-20

2 The need, solution, tunnel route and alignment Ref Supportive and neutral comments on safeguarded wharves - respondents welcome any intervention by the Government that reduces the potential financial impact on Thames Waters customers via the Water Industry (Financial Assistance) Bill - it is least disruptive to the fabric of the city. - the cost of the Thames Tunnel project, and the time for development and commissioning, is dwarfed by the potential cost, disruption and time for implementation of other options which have been examined. - respondents realise that to improve the River Thames we are all going to have to make sacrifices including putting up with building disruption and increases in customer water bills - respondents agree with the conclusions of the TTSS that the most practical and financially viable solution for London would be to intercept the CSOs with a new tunnel system as currently proposed - the alternative solutions would not meet the logistical, environmental and financial criteria and are therefore easily ruled out - respondents recognise in particular that the North East Storm Relief at King Edward Memorial Park is an important source of storm flows and certainly needs to be intercepted. - it will enhance the long-term image for tourism, employment, all residences and businesses which operate on or near the River Thames. Not qualified to comment on this technical matter. Respondent ID No. Our response

2.3.21

13494LO, 11187, 11260, 11273, 11307, 11725, 11738, 11751, 11788, 11806, 12009, 12027, 12074, 12228, 12293, 12402, 12440, 12602, 12716, 12721, 12723, 12748, 12876, 12974, 13033, 13067, 13077, 13211, 13215, 7131, 7135, 7168, 7382, 7427, 7428, 7483, 7485, 7495, 7663, 7708, 7818, 7871, 7966,

50

The purpose of consultation is to explore as fully as possible what those with an interest in the project think about our proposals. We will have regard to comments received from both technical and non-technical consultees.

Supplementary report on phase two consultation

2-21

2 The need, solution, tunnel route and alignment Ref 2.3.22 Supportive and neutral comments No comment. Respondent ID 8104, 8111, 8313, 8496, 9063, 9067, 9089 NERL, HA, (LR)DoC, ODA PDT, SDC, LBH, LBWF No. 7 Our response

Qualified support
Table 2.3.3 Supportive (qualified) feedback comments in relation to the decision that a tunnel is the right way to meet the need to reduce the amount of sewage that enters the tidal River Thames Ref 2.3.23 Qualified support comments Agree that a tunnel is the right solution but do not agree with use of greenfield sites to construct and operate the project. Respondent ID 11280, 11578, 11642, 11646, 11658, 11682, 11729, 11754, 11755, 12003, 12016, 12032, 12084, 12153, 12248, 12411, 12506, 12586, 12673, 12677, 12686, 12735, 12738, 12785, 12830, 12849, 12858, 12897, 12969, 12998, 13023, 13045, 13072, 13073, 13088, 13094, 13100, 13158, 7037, 7864, 8006, 8202, 8775, 8780, 9385, 9454 13494LO, 13476, 7744, 7842, 7884, 7886, 8202, 8792, 9137, 9166, 9339, 9365 No. 46 Our response The sites that we consulted on at phase two consultation have been identified through an extensive site selection process (see our Site selection methodology paper on our website). We consulted and agreed the methodology prior to its use with key stakeholders including potentially directly affected local authorities and utilised a multidisciplinary approach to assess potential CSO sites and main tunnel sites, and main tunnel/connection tunnel drive options, against engineering, planning, environmental, property and community considerations. Whether a site is brownfield or greenfield/open space was taken into account along with other considerations as set out in the Site selection methodology paper. However, given that we had a limited search area to identify suitable CSO and main tunnel sites, we did not consider it was appropriate to exclude sites based on whether they were brownfield or greenfield/open space when compiling our long-list of sites. The sites that we consulted on at phase two consultation have been identified through an extensive site selection process (see our Site selection methodology paper on our website). We consulted and agreed the methodology prior to its use with key stakeholders including potentially directly affected local authorities and utilised a multidisciplinary approach to assess potential CSO sites and main tunnel sites, and main tunnel/connection tunnel drive options, against engineering, planning, environmental, property and community considerations. We recognise that, given the locations where we are seeking to construct and operate the tunnel, many of the shortlisted sites are constrained. However, based on our assessment we consider that, on balance, our preferred sites are the most suitable. For further details on the results of the site selection process, refer to the Phase two scheme development report. As set out in the Route and tunnel alignment project information paper, the Abbey Mills route remains our preferred route because: it is the shortest route; it is the least disruptive and most cost-effective option, costing 20 per cent less compared to the other two options, while still meeting all the required environmental objectives; it requires the least number of worksites; and it requires less tunnelling at depth through chalk in the east. Deep tunnelling through chalk is potentially more

2.3.24

Agree that a tunnel is the right solution but works should take place on brownfield sites.

12

2.3.25

Agree that a tunnel is the right solution but do not agree with the preferred sites/site selection.

8002LO, 8303LO, 9104LO, 11451, 11627, 12883, 7012, 7133, 7137, 7190, 7327, 7342, 7370, 7496, 7567, 7636, 7673, 7794, 7847, 7851, 7888, 7941, 7953, 7971, 7972, 8037, 8111, 8192, 8396, 8412, 8420, 8480, 8486, 8538, 8548, 8609, 8642, 8648, 8707, 8740, 8749, 8764, 8766, 8829, 8844, 8854, 8874, 8878, 8897, 8902, 8937, 9013, 9099, 9101, 9153, 9425, 8551PET 11285, 11390, 11509, 11898, 12020, 12256, 13136, 13205, 7143, 7544

57

2.3.26

Unsure whether the tunnel is the correct solution, but do not agree with preferred sites.

10

2.3.27

Agree that a tunnel is the right solution but do not agree with the tunnel route/alignment.

8303LO, 13469, 7496

Supplementary report on phase two consultation

2-22

2 The need, solution, tunnel route and alignment Ref 2.3.28 Qualified support comments Agree that a tunnel is the right solution but concerned about the impact of the project during construction. Agree that a tunnel is the right solution but the project should seek to minimise the impact on the environment. Respondent ID 7799LO, 8277LO, 7556, 7768, 8655, 9337 No. 6 Our response difficult and would bring greater health and safety issues. We have been assessing the likely significant effects that may arise as a result of the works as part of an environmental impact assessment. This will set out measures necessary to mitigate any significant adverse effects that are identified. An Environmental statement, which records the findings of the environmental impact assessment, will accompany our DCO application. The initial environmental assessment work that has been carried out on the project is contained within the PEIR, which is available on our website. As part of the phase two consultation, we also sought feedback on the potential effects arising from our proposals and how the effects will be mitigated. Where possible, we will take feedback comments into account as we develop our proposals. The programming of works at all sites will be configured to minimise the duration of works and associated disruption to the local area where possible. The length of the construction period as set out in the consultation documents was the period assessed in the PEIR that works would be underway and it is hoped that in many cases there will be periods during which there will be no activity or less intensive activity on some sites. We recognise that the construction of the Thames Tunnel project may result in some disruption. We have been assessing the likely significant effects that may arise as a result of the works as part of an environmental impact assessment. This will set out measures necessary to mitigate any significant adverse effects that are identified. An Environmental statement, which records the findings of the environmental impact assessment, will accompany our DCO application. The initial environmental assessment work that has been carried out on the project is contained within the PEIR, which is available on our website. As part of the phase two consultation, we also sought feedback on the potential effects arising from our proposals and how the effects will be mitigated. Where possible, we will take feedback comments into account as we develop our proposals. Cost benefit analysis has already been undertaken, which showed that a storage and transfer tunnel option, combined with improvements at sewage treatment works and the Lee Tunnel had the highest net benefits. One the benefits if improved water quality which will also benefit recreational users of the River Thames. This and other work, including the conclusions of the TTSS, informed the Ministerial Statement in March 2007 and the request that we develop a tunnel solution. The Government has since undertaken further cost benefit analysis, which informed the Ministerial Statement in November 2011, in which the Secretary of Statement said: "we continue to believe that a tunnel represents the preferred solution for dealing with the untreated sewage that is polluting the River Thames." As the project develops, we have been and will continue to be closely scrutinised by the industry economic regulator Ofwat and by Defra. In relation to recreational benefits, the proposed works will secure long-

2.3.29

13115, 7137, 7223, 8502, 8720, 9079

2.3.30

Agree that a tunnel is the right solution but during construction the project should avoid/seek to minimise the impact on residents/residential areas. Should avoid residential areas. Agree that a tunnel is the right solution but works should not affect community facilities.

11335, 11583, 11697, 12466, 12871, 13070, 13126, 7006, 7135, 7137, 7241, 7477, 7518, 7661, 7881, 7971, 8026, 8521, 8747, 8759, 8966, 9012, 9125, 9488 11275, 13054, 13055, 7846, 8857, 8884 8759

24

2.3.31 2.3.32

6 1

2.3.33

The tunnel must deliver long-term benefits including recreational benefits.

7784, 7842, 9031

Supplementary report on phase two consultation

2-23

2 The need, solution, tunnel route and alignment Ref Qualified support comments Respondent ID No. Our response term benefits in terms of the water quality of the tidal River Thames and thereby reduce the risk of harm to river users. As set out in the Design project information paper, we want our designs to be of high quality and provide value to the local community, while also having regard to cost. We aim to ensure that the designs respect each site's individual location and setting, while recognising the common function all sites have of providing a cleaner, healthier River Thames. For further details on our design proposals, refer to the site information papers and the Design development report. Chapter 3 of the Design development report also sets out the process we have followed to achieve good design. We estimate that the tunnel would directly employ about 4,250 people in construction and related sectors, as well as providing further secondary employment. We actively support the Crossrail Tunnelling and Underground Construction Academy, which is currently training and gaining employment for 70 apprentices a year. As set out in our publication Why Does Londons Economy Need the Thames Tunnel the Thames Tunnel procurement process will aim to deliver business opportunities for small and medium sized enterprises as well as utilising local products, services and labour through the supply chain where possible. Any such targets will be subject to market sounding to ensure their commercial viability and compliance with EU regulations. We aim to meet a target on employing in excess of 20 per cent local labour. In addition to the Thames Tunnel project, other improvement works are being undertaken to address overflows within other parts Beckton and Crossness catchments. These comprise primarily of the Lee Tunnel and improvements to sewage treatment works. We are also working with the Environment Agency, Greater London Authority and other stakeholders on complementary measures. We are involved in the formulation of local development plans in which we press for policies that reduce water use and encourage the development of SuDS. We hold education campaigns such as the bin it, dont block it campaign to encourage customers to reduce waste flushed down toilets as well as reducing cooking far poured down sinks. We fully support the use of SuDS in new developments but the scale of the problem is such that SuDS cannot address the issue without massive land take and excessive cost. We have investigated the feasibility of separating the sewerage system into two systems: one for foul sewage and another for storm sewage. This was considered as one alternative by the TTSS and more recently reported in the Needs report (appendix D). Separating the combined system would involve building a second pipe and making sure that all connections from buildings and roads are connected into the correct system. Construction of a separated system would be extremely disruptive throughout London and would entail digging deep trenches in most

2.3.34

The tunnel must achieve a high standard of 13070, 7690 design.

2.3.35

The tunnel must employ local people.

LR9154

2.3.36

In addition to the tunnel, other complementary measures need to be introduced including sewer improvements, drain clearance, measures to reduce hard surfaces including residents concreting over their gardens. In addition to the tunnel, other supporting initiatives should be introduced including sustainable urban drainage systems (SuDS), improved filtration on CSOs, education initiatives and separation of sewers. Thames Water should develop a SuDS strategy to become the fourth part of the London Tideway Improvement Works.

11660, 12070, 7160, 8029

2.3.37

EH, 9003LO, 7108, 7792, 8019, 8099, 8285, 8462, 8519, 8688, 8846, 8986, 9079, LR9491

14

Supplementary report on phase two consultation

2-24

2 The need, solution, tunnel route and alignment Ref Qualified support comments Respondent ID No. Our response streets. Such construction would take considerable time to complete. In addition, sewers gets deeper so that the sewage can flow by gravity; this would mean that there would be a substantial need for pumping stations to either lift foul sewage to the interception sewers or to pump storm sewage to the river, which would have a considerable energy requirement. Separating the combined system would also have a net increase in pollutant loadings to the tidal Thames as polluted street drainage, in particular, would be discharged into the river rather than captured by the tunnel system. Estimates showed that the construction cost alone would be in excess of 12billion. We do not therefore consider this to be a viable option. It is our intention to use the river for the removal of excavated materials as much as possible and where practical and cost-effective to do so. We will also seek to reduce the potential for significant effects on local roads and residents, having regard to relevant policies in the London Plan and the Waste Water National Policy Statement once the project has been designated as a nationally significant infrastructure project. There will be some materials which have to be transported to sites by road. The site information papers set out the proposed logistics strategy for each of our preferred sites, and the Transport project information paper provides a more strategic overview of our proposals. We are also undertaking a Transport assessment, which will be submitted with our DCO application. This will identify any mitigation that is required to minimise disruption caused by site traffic. Our initial findings are contained within the PEIR, which is available on our website. Work has been underway on examining the solutions to the problem of overflow sewage discharges to the River Thames for more than ten years. The independently chaired Thames Tunnel Steering Group concluded in 2005 that that a large diameter storage and transfer tunnel was the preferred solution. A comprehensive cost benefit analysis was undertaken at that time. The cost benefit analysis showed that a storage and transfer tunnel option (Lee and Thames tunnels), combined with improvements at the sewage treatment works, and had the highest net benefits. Subsequent sensitivity testing and analysis demonstrated that, even though there is uncertainty around some of the assumptions underlying the cost benefit analysis, the benefits would have to drop to a quarter of those assessed to change the conclusion that the net benefits are positive. The Needs report at Table 5.10 sets out the cost of the preferred route of the tunnel in comparison with the alternative routes and alternative solutions. The Government has recently published a report entitled Creating a River Thames fit for our future: A strategic and economic case for the Thames Tunnel. This report provides an update to the 2007 regulatory impact assessment and takes into account data that has emerged since that time. The report contains an appraisal of alternative solutions and concludes that a tunnel solution remains the most appropriate and cost-

2.3.38

Construction traffic associated with the tunnel should be focused on using the river.

11813, 7457, 7695, 7731, 8708, 8945, 8978, 9012, 9423, 9442, LR9278

11

2.3.39

Agree that a tunnel is the right solution as long as the costs are appropriate to the benefits it will bring.

7639, 8099

Supplementary report on phase two consultation

2-25

2 The need, solution, tunnel route and alignment Ref Qualified support comments Respondent ID No. Our response effective of the solutions considered. As the project develops, we have been and will continue to be closely scrutinised by the industry economic regulator Ofwat and by Defra. The Environment Agency identified the most polluting CSOs, which cause unacceptable environmental impacts because of the frequency or volume of the overflow, or because they discharge into an environmentally sensitive part of the River Thames. The project will address the overflows from these CSOs, either by connecting them directly to the main tunnel, or by making other alterations to the sewerage system which will utilise the existing capacity more effectively. Since we began work on the project, we have managed to reduce the number of proposed construction sites. As part of phase two consultation we included information on three preferred sites from our phase one consultation which are no longer required, since we are able to address the discharge from the CSO through in-sewer modifications. We will continue to seek to minimise the number and size of our worksites as the project develops. The design of life of the tunnel is 120 years. We therefore consider that we are proposing a long-term solution to the problem of CSO discharges. Analysis has been undertaken since 2000, to investigate and assess strategic alternatives to addressing the problem of CSO discharges into the tidal Thames. The needs case for the Thames Tunnel project is set out in detail in the Needs Report, which is available on our website. It is also summarised in an easy to read and non-technical form in our publications Why does London need the Thames Tunnel? dated July 2011. The need for the project has been confirmed and reaffirmed both by the past and present Government. This was made clear in written Ministerial statements to Parliament in September 2010 and again in November 2011. Further reinforcement of the need for the project is contained in the documents published by DEFRA in November 2011 Creating a River Thames fit for our future - a strategic and economic case for the Thames Tunnel and Costs and benefits of the Thames Tunnel. The National Policy Statement for Waste Water, which was designated on 26 March 2012, clearly states that the need for the project has been demonstrated. It concludes that detailed investigations have confirmed the case for a Thames Tunnel as the preferred solution (paragraph 2.6.33). The designation of the NPS was supported by an Appraisal of sustainability post-adoption statement dated March 2012 which contains further detail on the significant amount of work undertaken to establish the need for the Thames Tunnel project and assess alternative options, on the basis of which the government considers the need for the project to be established. Having regard to the extensive work that has been undertaken since 2000, as detailed in the reports mentioned above, we consider that the need for the project has been clearly demonstrated.

2.3.40

Need to reduce the number of construction sites. In particular, if this is not done, it would add extra financial, social and environmental costs to the project. Ofwat and the Environment Agency have urged Thames Water to keep the number of worksites to a minimum.

8204, 8890, 9063, 9067, 9385, 9395, 9475, 9488, LR9112

2.3.41

The tunnel must have sufficient long-term capacity. If Thames Water is sure, then the tunnel should proceed.

7218

2.3.42

7159, 7784, 8010, 8186

Supplementary report on phase two consultation

2-26

2 The need, solution, tunnel route and alignment Ref 2.3.43 2.3.44 Qualified support comments Should not object to bill increase. Respondent ID 7847 No. 1 13 Our response Your support for the increase in water bill associated with this project is noted and welcomed. The proposed switch facility is not currently located within close proximity to our preferred route or sites, and therefore we do not anticipate that the switch facility will be affected. The Government have indicated that they will be keeping a close eye on cost through our regulator, Ofwat. They will seek to ensure that the project is delivered and operated in a way that is economic and efficient. We would also expect that the way in which the project is tendered would encourage contractors to find more effective ways of building the tunnel. Refer to paragraph 2.3.50 for our response to this feedback comment. As we refine our proposals, we will seek all possible ways to minimise the cost impact and offer good value to our customers through the design, construction and operation of the tunnel. In preparing our cost estimates we will continue to have regard to the Treasury Green Book, which is the standard for this type of project and includes accounting for risk. Cost benefit analysis has already been undertaken, which showed that a storage and transfer tunnel option, combined with improvements at sewage treatment works had the highest net benefits. This work informed the Ministerial Statement in March 2007 and the request that we develop a tunnel solution. The Government has recently published a report entitled Creating a River Thames fit for our future: A strategic and economic case for the Thames Tunnel. This report provides an update to the 2007 regulatory impact assessment and takes into account data that has emerged since that time. The report contains an appraisal of alternative solutions and concludes that a tunnel solution remains the most appropriate and cost-effective of the solutions considered. We have been assessing the likely significant effects that may arise as a result of the works as part of an environmental impact assessment. This will set out measures necessary to mitigate any significant adverse effects that are identified. An Environmental statement, which records the findings of the environmental impact assessment, will accompany our DCO application. The initial environmental assessment work that has been carried out on the project is contained within the PEIR, which is available on our website. As part of the phase two consultation, we also sought feedback on the potential effects arising from our proposals and how the effects will be mitigated. Where possible, we will take feedback comments into account as we develop our proposals. The sites that we consulted on at phase two consultation have been identified through an extensive site selection process (see our Site selection methodology paper on our website). We consulted and agreed

Qualified support subject to: OT, NHS B&D, LBR, WCC, 8569LO, - the Thames Tunnel project not negatively 13395, 7037, 8021, 8041, 8075, 8649, 8817, LR9491 impacting the operation of telecoms switch facility
- investigation into more effective ways of

building and operating the tunnel

- the Thames Tunnel project not becoming

a profit making venture


- refinement of the overall cost as the

project progresses

- a suitable cost benefit analysis being

undertaken

- appropriate mitigation of effects on open

space, river access and residential communities

- the use of brownfield sites which are

sufficiently far away from residential buildings/would be less disruptive to local

Supplementary report on phase two consultation

2-27

2 The need, solution, tunnel route and alignment Ref Qualified support comments residents Respondent ID No. Our response the methodology prior to its use with key stakeholders including potentially directly affected local authorities and utilised a multidisciplinary approach to assess potential CSO sites and main tunnel sites, and main tunnel/connection tunnel drive options, against engineering, planning, environmental, property and community considerations. Whether a site is brownfield or greenfield/open space was taken into account along with other considerations as set out in the Site selection methodology paper. However, given that we had a limited search area to identify suitable CSO and main tunnel sites, we did not consider it was appropriate to exclude sites based on whether they were brownfield or greenfield/open space when compiling our long-list of sites. We recognise that as part of a long-term solution, SuDS provide a valuable tool to reduce surface water entering into the sewer system. We will continue to work with the GLA and local authorities to promote the use of SuDS with new developments and particularly application of SuDS as part of the solution of local flooding.

- the Selbourne Commission

recommendations alone will not bring ecological benefits to the River Thames without the Thames Tunnel project, although the project should help deliver green infrastructure along the tunnel route
- WCC welcome the reduction in the

number of proposed worksites although significant issues and implications are still to be resolved with regard to site at Victoria Embankment Foreshore.

We welcome your support regarding the number of proposed worksites and will continue to liaise with City of Westminster to address concerns raised regarding use of the Victoria Embankment Foreshore site.

Objections, issues and concerns


Table 2.3.4 Objections, issues and concerns in relation to the decision that a tunnel is the right way to meet the need to reduce the amount of sewage that enters the tidal River Thames Ref Objections, issues and concerns Respondent ID See annex B of this report No. Our response

2.3.45 Disagree that the tunnel is the right solution.

1,244 Analysis has been undertaken since 2000, to investigate and assess strategic alternatives to addressing the problem of CSO discharges into the tidal Thames. The needs case for the Thames Tunnel project is set out in detail in the Needs report, which is available on our website. It is also summarised in an easy to read and non-technical form in our publications Why does London need the Thames Tunnel? dated July 2011. The need for the project has been confirmed and reaffirmed both by the past and present Government. This was made clear in written Ministerial statements to Parliament in September 2010 and again in November 2011. Further reinforcement of the need for the project is contained in the documents published by DEFRA in November 2011 Creating a River Thames fit for our future - a strategic and economic case for the Thames Tunnel and Costs and benefits of the Thames Tunnel. The National Policy Statement for Waste Water, which was designated on 26 March 2012, clearly states that the need for the

Supplementary report on phase two consultation

2-28

2 The need, solution, tunnel route and alignment Ref Objections, issues and concerns Respondent ID No. Our response project has been demonstrated. It concludes that detailed investigations have confirmed the case for a Thames Tunnel as the preferred solution (paragraph 2.6.33). The designation of the NPS was supported by an Appraisal of sustainability post-adoption statement dated March 2012 which contains further detail on the significant amount of work undertaken to establish the need for the Thames Tunnel project and assess alternative options. The report concludes that a tunnel solution remains the most appropriate and cost-effective of the solutions considered. As a result, the Government confirmed that the detailed studies undertaken have and continue to demonstrate the case for the Thames Tunnel project The tunnel will be used around 60 times in an average year. The Tunnel solution is supported by the Waste Water National Policy Statement which is the main planning policy document for the project. The TTSS, established in 2000 concluded that three elements are required to address discharges into the Crossness and Beckton catchments. These include: upgrades to sewage treatment works the Lee Tunnel and the Thames Tunnel project. Without these interventions, annual CSO discharges into the River Thames would reach 70 million cubic metres in a typical year by 2020. If the Thames Tunnel project is not constructed, then even with the Lee Tunnel and sewage treatment works upgrades in operation, the annual average volume of all CSO discharges to the River Thames would remain at 18 million cubic metres, which is too high. Further information is available in the Needs report and Why does London need the Thames Tunnel. We do not agree that the tunnel is an outdated, inflexible and disproportionate solution. Once the storage tunnel has been developed and is in operation, it will be a strategic component of Londons infrastructure and will provide flexibility to adapt the network for future conditions, including opportunities for the flows from new sewerage infrastructure to be diverted to the tunnel. Planning Policy Statement 1 has been cancelled following the publication of the National Planning Policy Framework. The Thames Tunnel project protects the environment as set out on page 2 of the Defra publication Creating a River Thames fit for our future: A strategic and economic case for the Thames Tunnel. The slope of the main tunnel is designed so that the flows are gravity led with pump out at the end.

Reasons cited included: - unnecessary since the tunnel will be empty for the majority of the year
- the Lee Tunnel will address 6 per cent

of spills

- a tunnel is an outdated, inflexible and

disproportionate solution

- the project is contrary to Planning

Policy Statement 1 in that it is the wrong development, in the wrong place at the wrong time. Tunnel also compromises the natural environment, open spaces and vital resources. It is also considered irresponsible to create a tunnel which only functions by pumping
- the tunnel is ecologically unsound

The primary purpose of the proposed works is to reduce the amount of untreated wastewater that is discharged into the tidal Thames and improve water quality in order to meet legal requirements. This will have benefits for residents, visitors, business and wildlife. We do not

Supplementary report on phase two consultation

2-29

2 The need, solution, tunnel route and alignment Ref Objections, issues and concerns
- the tunnel should be a last resort once

Respondent ID

No.

Our response therefore agree that the tunnel is ecologically unsound. We have considered a wide range of options to reduce and control the amount of untreated sewage that flows into the River Thames, including local storage and treatment, SuDS, separation of the sewerage system, bubblers and skimmers. None of these options were considered practical; they costed more and often did not provide the same level of CSO control or the same benefits when compared to the tunnel solution. In comparison to SuDS and the separation of sewerage system, the Thames Tunnel project can be implemented more quickly. Refer to paragraph 2.3.94 for our response to this issue.

green infrastructure solutions have been put in place


- should treat storm water at the

source/invest in integrated approach to water management - should select a solution that allows for rapid implementation
- should treat sewage locally, rather

than transferring sewage from west London to east London, or in east and west London where 90 per cent of spills occur
- wrong solution to the wrong

requirements (ie, should be going for elimination)

As part of the TTSS work, the Environment Agency assessed the CSOs, categorised them and identified those that we need to control. It would not be cost-effective to capture all CSO events that could occur as the size of the project would be much larger with much greater cost. The greater project size would have far larger impacts and the costs would be prohibitive when compared to the marginal benefits achieved. For example, we are reducing CSOs that occur up to 60 times per year to four or fewer (with such residual discharges occurring in the winter months). Whereas if the control target was one event or fewer, the project storage volume (or tunnel length and/or diameter) would at least double. The Environment Agency has agreed that the capture of 96 per cent of the current discharge in a typical year leaving four events or less is a practical and cost-effective level of control. With regards to whether the tunnel is the right solution, refer to first three paragraphs of response set out in paragraph 2.3.45. The UWWTD contains the European Unions requirements concerning the collection, treatment and discharge of wastewater. The requirements of the UWWTD have been transposed into domestic legislation by the Urban Waste Water Treatment Regulations 1994. The European Commission (EC) is taking action against the UK for alleged breach of the UWWTD in respect of discharges of untreated sewage in the River Thames. The Thames Tunnel project addresses the problem which has led to the EC taking legal action against the Government, since this is an on-going problem.

- do not consider that EU legislation is

relevant in a time of austerity


- the proposed tunnel goes beyond what

is required under the UWWTD as evidenced by the recent legal case, which concluded that the UK was only in breach of the UWWTD for failing to ensure appropriate treatment of wastewater in the Beckton, Crossness and Mogden Sewage Treatment Works. To go beyond improvement works to the sewage treatment works imposes a disproportionate cost on Thames Water customers
- independent research including the

We consider that the report from the Selbourne Commission does

Supplementary report on phase two consultation

2-30

2 The need, solution, tunnel route and alignment Ref Objections, issues and concerns Selbourne Commission and Professor Binnie has indicated that these works are unnecessary Respondent ID No. Our response not begin to suggest any alternative to the Thames Tunnel project which would both demonstrate compliance with UWWTD, and meet the objectives set by the Environment Agency for the health of the river, within the time scale set by the Government. There are no costings associated with the findings of the report and the principal recommended action is for further studies. Our full response to the Selbourne Commission can be found on our website. In relation to Professor Binnie's suggestion, we understand that he has since changed his view. On 6 March 2012 he stated in Parliament in a meeting organised by Simon Hughes MP that subject to some caveats he supported the single tunnel solution. Appendix B of the Needs report is an independent report by Exeter University that examines the approaches to the UWWTD in relation to combined CSOs in major cities across the EU. Other EU cities that have used tunnels for CSO control include Paris and Vienna. The most common approach to resolving CSO issues was identified to be the addition of extra sewer capacity for storage and transfer of captured CSO to treatment. Large storage tunnels in conjunction with one or several other storm water control techniques such as Real Time Control have been built or are planned by several cities. In North America, storage and transfer tunnels are a common solution for CSO control with tunnel projects recently completed in Portland OR and existing systems in Toronto ON, Milwaukee WI, Providence RI and many other communities. Other cities planning additional tunnel systems include Washington DC. It is important to note that the systems in Milwaukee and Chicago are performing to their design specification. The Greenwich connection tunnel would collect flows from three CSOs and has a high capacity. Other options have been considered but rejected because they result in hydraulic instability/unacceptable performance, require additional large diameter shafts and/or would still not eliminate the need for a shaft near the change in ground geology near Chambers Wharf. The Environment Agency has identified the most polluting CSOs, which cause unsatisfactory environmental impacts because of the frequency or volume of the overflow, or because they discharge into an environmentally sensitive part of the tidal Thames. In relation to the specific CSOs identified: - The Needs report identifies the West Putney Storm Relief CSO as falling within the category of CSOs which most urgently need to be addressed. Table 4.2 of the Needs report provides further details. Monitoring data from 1 October 2010 to 30 September 2011 also confirms that this CSO continues to overflow, with 31 separate discharges identified within this period. Bacteria data collected in 2011 also indicates high levels of e.coli and the presence of human waste in the discharge, confirming the health risk from discharges from West Putney.

- experience from the United States of

America, particularly Milwaukee and Chicago, show that similarly designed tunnels do not deliver the desired results

- do not agree that the long connection

tunnel from Chambers Wharf to Greenwich Pumping Station is necessary

- do not agree that all CSOs need to be

intercepted including West Putney Storm Relief and North East Storm Relief

Supplementary report on phase two consultation

2-31

2 The need, solution, tunnel route and alignment Ref Objections, issues and concerns Respondent ID No. Our response - The North East Storm Relief CSO is estimated to discharge over 30 times in a typical year at a volume of approximately 780,000 cubic meters, which is the equivalent of 312 Olympic swimming pools of untreated sewage. Monitoring data at the outfall supports this estimation. As a result, it has been identified by the Environment Agency as a category 1 CSO, where overflows most urgently need to be addressed. Landowners may have a statutory entitlement to claim compensation for the diminution on the value of their property due to the construction of the tunnel. In addition to the statutory process, we have published an exceptional hardship procedure which sets out how we will assess claims from householders who contend that they are suffering exceptional hardship as a result of being unable to sell their property because it is potentially impacted by the currently published Thames Tunnel project proposals. We have also published A guide to the Thames Tunnel compensation programme which sets out details of compensation that would be available during construction arising from damage or loss, for required protection measures, and for compulsory purchase. We consider that there is an economic case for the Thames Tunnel project. We estimate that the tunnel would directly employ about 4,250 people in construction and related sectors, as well as providing further secondary employment of up to 5100 further jobs. We actively support the Crossrail Tunnelling and Underground Construction Academy, which is currently training and gaining employment for 70 apprentices a year. As set out in our publication Why does Londons Economy need the Thames Tunnel the Thames Tunnel procurement process will aim to deliver business opportunities for small and medium, sized enterprises as well as utilising local products, services, and labour through the supply chain where possible. Any such targets will be subject to market sounding to ensure their commercial viability and compliance with EU regulations. We aim to meet a target on employing in excess of 20 per cent local labour. The Government has recently published a report entitled Creating a River Thames fit for our future: A strategic and economic case for the Thames Tunnel. This report provides an update to the 2007 regulatory impact assessment and takes into account data that has emerged since that time. The report contains an appraisal of alternative solutions and concludes that a tunnel solution remains the most appropriate and cost-effective of the solutions considered. As a result, the Government confirmed that the detailed studies undertaken have and continue to demonstrate the case for the Thames Tunnel project. We have also recently published Why does Londons economy need the Thames tunnel?, which provides a nontechnical form the economic benefits of the Thames Tunnel project. See annex B of this report 667 The response at paragraph 2.3.45 also applies to the objections, issues and concerns raised within this paragraph. You may wish to

effect on property prices

- the tunnel does not increase economic

potential at a time of financial difficulty

2.3.46 Unsure whether it is the right solution.

Supplementary report on phase two consultation

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2 The need, solution, tunnel route and alignment Ref Objections, issues and concerns Reasons included: - support for the interception of the West Putney Storm Relief CSO is contingent on evidence which demonstrates that discharges are sufficiently polluting to justify the works Respondent ID No. Our response consider the response at paragraph 2.3.45 as well as the text below. The Environment Agency has identified the most polluting CSOs, which cause unsatisfactory environmental impacts because of the frequency or volume of the overflow, or because they discharge into an environmentally sensitive part of the tidal Thames. The Needs report identifies the West Putney Storm Relief CSO as falling within the category of CSOs which most urgently need to be addressed. Table 4.2 of the Needs report provides further details. Monitoring data from 1 October 2010 to 30 September 2011 also confirms that this CSO continues to overflow, with 31 separate discharges identified within this period. Bacteria data collected in 2011 also indicates high levels of e.coli and the presence of human waste in the discharge, confirming the health risk from discharges from West Putney. Work has been underway on examining the solutions to the problem of overflow sewage discharges to the River Thames for more than ten years. The independently chaired Thames Tunnel Steering Group concluded in 2005 that that a large diameter storage and transfer tunnel was the preferred solution. A comprehensive cost benefit analysis was undertaken at that time. The cost benefit analysis showed that a storage and transfer tunnel option (Lee Tunnel and Thames Tunnel project), combined with improvements at the Sewage Treatment Works, and had the highest net benefits. Subsequent sensitivity testing and analysis demonstrated that, even though there is uncertainty around some of the assumptions underlying the Cost Benefit Analysis, the benefits would have to drop to a quarter of those assessed to change the conclusion that the net benefits are positive. The Needs report at Table 5.10 sets out the cost of the preferred route of the tunnel in comparison with the alternative routes and alternative solutions. This work informed the Ministerial Statement in March 2007 and the request that we develop the tunnel solution. The Government has recently published a report entitled Creating a River Thames fit for our future: A strategic and economic case for the Thames Tunnel project. This report provides an update to the 2007 regulatory impact assessment and takes into account data that has emerged since that time. The report contains an appraisal of alternative solutions and concludes that a tunnel solution remains the most appropriate and cost-effective of the solutions considered. As the project develops, we have been and will continue to be closely scrutinised by the industry economic regulator Ofwat and by Defra. We recognise that the costs for the Thames Tunnel project have changed; in 2010 we estimated that the project would cost 3.6 billion at 2008 prices. As design development has continued and an allowance has been made for a later completion date and in response to phase one consultation, costs have been included for greater use of brown-field sites and river transport. The cost base

- query whether the problem require a solution of this magnitude

- given the escalation in costs and

unfavourable apportioning of benefit and risk.

Supplementary report on phase two consultation

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2 The need, solution, tunnel route and alignment Ref Objections, issues and concerns Respondent ID No. Our response has also been updated to 2011 prices. On this basis the estimates for the project costs are now 4.1 billion. This includes 0.9 billion of risk allowance and optimism bias. These estimates have been examined by independent advisers on behalf of Ofwat and confirmed to reflect best practice in the industry. As set out in Why does London need the Thames Tunnel, the Thames Tunnel project will result in the annual number of CSO discharges falling from an average of 60 a year to just four or fewer. If the Thames Tunnel project were not implemented, the annual average volume of all CSO discharges to the River Thames would still be 18 million cubic metres and discharges would still occur nearly 60 times in a typical year. The introduction of the Thames Tunnel project will reduce CSO spills to four or fewer (with such residual discharges occurring in the winter months) in a typical year. The Environment Agency has agreed that the capture of 96 per cent of the current discharge in a typical year leaving four events or less is a practical and cost-effective level of control. The design of life of the tunnel is 120 years. We therefore consider that we are proposing a long-term solution to the problem of CSO discharges. We disagree. The tunnel addresses the problem by capturing and sending for treatment untreated sewage that would otherwise enter the River Thames. We are proposing the Thames Tunnel project because we consider that it is the most appropriate solution to address the problem of CSO discharges into the River Thames. The reasons for this are comprehensively documented and the proposed solution is supported by Government. For further information refer to our response at paragraph 2.3.45.

2.3.47 The Thames Tunnel project is not a long-term solution as it does not have sufficient capacity.

11260

2.3.48 Need for a more long-term solution.

13397LO, 9107LO, 11012, 11796, 12281, 12799, 13093, 7430, 7449, 7623, 7677, 7767, 7865, 7916, 8090, 8125, 8281, 8306, 8557, 8662, 8786, 8880, 9283, 9389, LR9277, LR9398

26

2.3.49 The proposed solution treats the symptoms but not the problem itself. 2.3.50 This solution has been chosen because it will provide Thames Water with a revenue stream. 2.3.51 This solution has been chosen because Thames Water can secure a profit from the tunnel's construction.

13379LO, 8803LO, 9105LO, 9107LO, 13118, 7232, 7343, 16 7429, 7448, 7695, 7865, 7889, 8190, 8750, 9283, LR9277 7262LO, LR9272LO, 11038, 11284, 12157, 13212, 7125, 7127, 7197, 7261, 7384, 7389, 7476, 7502, 7532, 7877, 8139, 8890, 9395, 9475, 9496, 9497, 9599, LR9112 13397LO, 13495LO, 7260LO, 7460LO, 8560LO, 8562LO, 8795LO, 8802LO, 9083LO, 9084LO, 9085LO, 9086LO, 9105LO, 9107LO, LR9271LO, LR9272LO, 10155, 10872, 11038, 11404, 11708, 11863, 12083, 12086, 12103, 12160, 12281, 12343, 12400, 12419, 12670, 12953, 12970, 13010, 13013, 13020, 13047, 13051, 13130, 13135, 13137, 13148, 13197, 13206, 13227, 13364, 13484, 7023, 7118, 7125, 7129, 7140, 7170, 7190, 7192, 7199, 7226, 7230, 7261, 7271, 7277, 7342, 7343, 7361, 7363, 7382, 7396, 7406, 7408, 7438, 7479, 7490, 7497, 7514, 7532, 7547, 7549, 7580, 7584, 7628, 7633, 7663, 7669, 7671, 7675, 7698, 7704, 7731, 7741, 7789, 7795, 7824, 7828, 7844, 7877, 7916, 7932, 7933, 8022, 8041, 8042, 8062, 8094, 8117, 8210, 8235, 8404, 8452, 8473, 8497, 8567, 8658, 8725, 8737, 8753, 8755, 8782, 8793, 8817, 8849, 8857, 8909, 8923, 8953, 9007, 9193, 9199, 9316, 9353, 9357, 9387, 9389, 9445, 9460, 9476, 9581, 9588, LR13446, LR9315 7226, 8062 24

139

2.3.52 The tunnel is only supported by the

The Defra publication Creating a River Thames fit for our future: A

Supplementary report on phase two consultation

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2 The need, solution, tunnel route and alignment Ref Objections, issues and concerns Government because it will bring economic benefits. Respondent ID No. Our response strategic and economic case for the Thames Tunnel, dated November 2011 concludes that there is an environmental case for action and in addition there is a economic case. It is not therefore correct to say that it is only supported because of economic benefits. The response at paragraph 2.3.45 also applies to the objections, issues and concerns raised within this paragraph. You may wish to consider the response at paragraph 2.3.45 as well as the text below.

2.3.53 The reasons for choosing a tunnel as the solution are not properly evidenced and further work should be undertaken to demonstrate that the tunnel is the right solution. Specific comments included: - the use of estimated annual discharge figures/information about individual CSOs is inadequate

(LR)CCW, (LR)LBS, 13397LO, 8802LO, 8949LO, 9110LO, 9417LO, 9481LO, LR9274LO, 11033, 11123, 11230, 11231, 11236, 11252, 11267, 11500, 11544, 11562, 11567, 11571, 11627, 11689, 11840, 11879, 11920, 12029, 12159, 12282, 12304, 12456, 12581, 12697, 12706, 12743, 12755, 12781, 12799, 12824, 12834, 12907, 12949, 12967, 12996, 13009, 13030, 13048, 13062, 13076, 13113, 13128, 13175, 13185, 13234, 7127, 7146, 7252, 7346, 7364, 7386, 7472, 7499, 7510, 7514, 7627, 7741, 7767, 8094, 8109, 8191, 8402, 8415, 8505, 8517, 8528, 8753, 8772, 8774, 8779, 8804, 8831, 8834, 8849, 8903, 8953, 9010, 9206, 9240, 9243, 9283, 9303, 9347, 9384, 9467, LR13383, LR13498, LR9136, LR9280, LR9341, LR9398

100

Our approach to long term modelling has been agreed with the Environment Agency, is based on almost 40 years of rainfall data and is robust. Our modelling is comprehensive and has been demonstrated to show an acceptably good representation of actual conditions when the catchment is taken as a whole. In the context of UWWTD compliance and overall tideway quality, any variances at individual CSOs are of limited relevance it is the overall sewerage catchment performance that matters The Environment Agency will continue to monitor water quality. However the, principal outcome of the sewage treatment works improvements is to enhance river quality under dry conditions and to enable more untreated sewage to be treated before discharges to river are made. Under wet weather conditions, while the Lee tunnel will capture the discharges from the Abbey Mills Pumping Station, these projects will not address the other CSO discharges from the Beckton and Crossness catchments and hence there will be limited change to the discharges made along the length of the tidal River Thames. Refer to paragraph 2.3.94 for our response to this issue.

- should continue to monitor water

quality before making a final decision, in order to determine the impact of the Lee Tunnel and the upgrades to sewage treatment works. Extrapolating from the current data relies heavily on assumptions about how this work, which is already underway, will affect the river once it is complete.
- there is a lack of evidence that tunnel

is needed along the length of the River Thames; 90 per cent of discharges occur to the east and west of the city
- respondents require an environmental

and economic reassessment of the proposal

Cost benefit analysis has already been undertaken, which showed that a storage and transfer tunnel option, combined with improvements at sewage treatment works and Lee Tunnel had the highest net benefits. This work informed the Ministerial Statement in March 2007 and the request that we develop a tunnel solution. The Government has recently published a report entitled Creating a River Thames fit for our future: A strategic and economic case for the Thames Tunnel. This report provides an update to the 2007 regulatory impact assessment and takes into account data that has emerged since that time. The report contains an appraisal of alternative solutions and concludes that a tunnel solution remains the most appropriate and cost-effective of the solutions considered. Furthermore, the Waste Water National Policy Statement does not require the submission of any further cost benefit analysis. We therefore do not consider that it is necessary to re-appraise this

Supplementary report on phase two consultation

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2 The need, solution, tunnel route and alignment Ref Objections, issues and concerns
- the use of water and amount of

Respondent ID

No.

Our response element of the scheme. We agree that the use of water we use in the future is likely to drop. However the population increases will more than make up for this benefit. Also, rainfall is not related to population. The cause of the CSO discharges is rainfall falling on the impervious catchment connected to the sewers. This is far more important than the dry weather component and while falling consumption might allow for marginally more rainwater to be captured, it will not make a significant difference to the frequency or extent of CSO discharges. Extensive information was provided in the PEIR that was published at phase two consultation and more will be available at the application stage, including in the Environmental statement. The project is required by European law. Most opinion is that the frequency and volume of overflows as they currently operate is neither sustainable nor environmentally acceptable. The publication Why does Londons Economy need the Thames Tunnel? sets out the economic benefits the Thames Tunnel project. This refers to the indirect employment of 5,100 jobs in addition to the 4,250 that would be employed at the peak of construction activity. While there would be far fewer people employed after the completion of the project the economic effect would be significant and lasting skills legacy.

wastewater we create in the future is likely to drop per capita

- further information is needed on the

environmental/sustainability case for changing the current situation

- the boost to London's infrastructure

has been overstated; post construction, the project does not generate any economic growth or employment.

2.3.54 Query the effectiveness of the solution, particularly in relation to: - the effectiveness of the design in dealing with extreme weather events

13397LO, 8002LO, 8887LO, 11072, 11182, 11525, 11840, 11948, 11949, 12229, 12405, 12412, 12839, 12866, 12890, 12955, 12971, 13002, 13009, 13013, 13038, 13124, 13238, 7045, 7146, 7218, 7294, 7342, 7387, 7397, 7430, 7449, 7496, 7558, 7648, 7676, 7795, 7839, 7865, 7883, 7955, 8022, 8089, 8306, 8404, 8472, 8725, 8864, 8880, 8903, 8923, 9098, 9145, LR9398

54

We are designing the CSO control system taking into account the variability of rainfall across the catchment. We have simulated over 300 historical storm events from the past 40 years and are confident that the tunnel system will be able to capture both locally intense storms and widespread frontal storms. The project is not, however, a flood alleviation scheme as we are dealing with the discharges to the river rather than local flooding problems that may be caused by local capacity problems during very intense local rainfall-runoff from heavily developed areas. We would welcome specifics on where other tunnel systems have not been as successful as anticipated. The tunnel system in Milwakee WI, for example, has consistently captured more CSO than originally planned. Our experiences on other tunnel systems indicate a high level of success with often greater benefits realised because of synergies with the operations of the existing sewer system and treatment works. As part of the TTSS work, the Environment Agency assessed the CSOs and categorised them identifying those that we need to control. It would not be cost-effective to capture all CSO events that could occur as the size of the scheme would be much larger with much greater cost. The greater project size would have far larger impacts and the costs would be prohibitive when compared to the marginal benefits achieved. For example we are controlling CSOs from up to 60 times per year to four or fewer (with such residual

- in the experience of other cities, a

tunnel has not been as successful as anticipated

- the tunnel will only tackle a portion of

the CSOs

Supplementary report on phase two consultation

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2 The need, solution, tunnel route and alignment Ref Objections, issues and concerns Respondent ID No. Our response discharges occurring in the winter months). Whereas if the control target was one event or fewer the projects storage volume (or tunnel length and/or diameter) would at least double. The Environment Agency has agreed that the capture of 96 per cent of the current discharge in a typical year but with leaving four or less events is a practical and cost-effective level of control. The secondary lining has been designed to last 120 years and is an important part in ensuring the durability of the main tunnel. The future need for further tunnels to feed into the Thames Tunnel project is a possibility. The main tunnel may act as a spine or backbone for the sewer network. We recognise that the construction of the Thames Tunnel project may result in some disruption. We have been assessing the likely significant effects that may arise as a result of the works as part of an environmental impact assessment. This will set out measures necessary to mitigate any significant adverse effects that are identified. An Environmental statement, which records the findings of the environmental impact assessment, will accompany our DCO application. The initial environmental assessment work that has been carried out on the project is contained within the PEIR, which is available on our website. As part of the phase two consultation, we also sought feedback on the potential effects arising from our proposals and how the effects will be mitigated. Where possible, we will take feedback comments into account as we develop our proposals. The response at paragraph 2.3.55 also applies to the objections, issues and concerns raised within this paragraph. You may wish to consider the response at paragraph 2.3.55 as well as the text below.

- whether the secondary lining will last

for 120 years and if not, query how it will be repaired/replaced


- in the future, additional tunnels likely to

be required. 2.3.55 The question is less about the need for the tunnel and more about the potential effects arising from it. 2.3.56 The tunnel will affect regeneration proposals along the River Thames. 12618, 7249, 8903 3

7199, LR9459

2.3.57 Concerned about the scale of construction and associated disruption.

Particular concerns included: - effects must be mitigated


- Thames Water is only seeking to

mitigate the damage caused by the Thames Tunnel project to the minimum extent necessary
- the proposals will affect some of the

(LR)CCW, LC, 7260LO, 8807LO, 9110LO, 9131LO, 11054, 11084, 11246, 11446, 11652, 12257, 12630, 12928, 12930, 12931, 12934, 12941, 13043, 13189, 13229, 7105, 7165, 7166, 7170, 7179, 7208, 7209, 7216, 7218, 7230, 7245, 7294, 7304, 7338, 7340, 7366, 7391, 7406, 7415, 7462, 7475, 7476, 7497, 7502, 7523, 7539, 7549, 7557, 7564, 7731, 7828, 7958, 7968, 8037, 8295, 8318, 8402, 8411, 8463, 8497, 8566, 8646, 8647, 8671, 8673, 8680, 8683, 8708, 8755, 8772, 8782, 8838, 9075, 9082, 9203, 9351, 9353, 9372, 9385, 9446, LR9154

82

poorest local communities

We recognise that some of our preferred sites are located within deprived communities. As set out above, we are assessing the effects of our works at each site, which includes undertaking a socioeconomic assessment of our proposal. Where necessary we will be putting in place appropriate mitigation to address these effects. Our assessment methodology is in line with the Infrastructure Planning (Environmental Impact Assessment) Regulations 2008, which requires assessment of cumulative effects. We have identified the schemes in the local area that will be included in the assessment

- a cumulative assessment of works

across London has not been undertaken.

Supplementary report on phase two consultation

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2 The need, solution, tunnel route and alignment Ref Objections, issues and concerns Respondent ID No. Our response based on applications which have been referred to the GLA, consistent with Planning Inspectorate Advice note nine. Section 2 of the site volumes of our PEIR set out the details of any relevant developments that will be taken into consideration. We will continue to monitor proposed development in the local area and any relative cumulative effects would be reported in our Environmental statement that will be submitted as part of our DCO application. An integral part of the pre-application process is the legal requirement that we consult with the communities and stakeholders in the vicinity of the tunnel route and the sites we intend to use in constructing and operating the project, and that we take account of all the comments received in response to consultation. In phase one consultation we presented the tunnel as our preferred solution along with three tunnel routes with sites and ancillary facilities such as air treatment. We analysed all feedback received and where possible have made changes to our proposals in light of the feedback comments received. More details can be found in the Changes project information paper. The purpose of consultation is to explore as fully as possible what affected parties think about that preference. During both phase one and phase two consultations we have kept an open mind about the conclusions we will reach. As part of the TTSS work, the Environment Agency assessed the CSOs, categorised them and identified those that we need to control. It would not be cost-effective to capture all CSO events that could occur as the size of the project would be much larger with much greater cost. The greater project size would have far larger impacts and the costs would be prohibitive when compared to the marginal benefits achieved. For example, we are controlling CSOs from up to 60 times per year to four or fewer (with such residual discharges occurring in the winter months). Whereas if the control target was one event or fewer the projects storage volume (or tunnel length and/or diameter) would at least double. The Environment Agency has agreed that the capture of 96 per cent of the current discharge in a typical year but leaving four events or fewer is a practical and costeffective level of control. As part of the overall London Tideway Thames Improvements we are upgrading Mogden Sewage Treatment Works to increase its treatment capacity by around 50 per cent. This will significantly reduce both the quantity and the number of times we need to discharge storm sewage from the sewage treatment works into the River Thames following heavy rain. We consider that there is an overriding need to manage the wastewater discharges that annually flow into the River Thames from CSOs. The Thames Tunnel project provides a long-term solution to address this problem, which embraces principles of sustainable development. This position is consistent with the Governments own assessment of the need for the project, which considered a number

2.3.58 The solution appears to be pre-decided.

8571LO, 12927, 13071, 13099, 13212, 7429, 8300, 8415, 8459, 8548, 8753, 8762, 8772, 8786, 9155

15

2.3.59 Once the tunnel is operational, raw sewage will still enter the River Thames despite the huge cost and disruption. The tunnel will also not eliminate discharges from Mogden Sewage Treatment Works.

(LR)RBKC, 12279, 12300, 12691, 7127, 7265, 7432, 7527, 7549, 7557, 7702, 8206, 8209, 8281, 8662, 8673, LR9398

17

2.3.60 Query the sustainability of the tunnel; not considered to be a green solution. A Civil Engineering Environmental Quality Assessment (CEEQUAL) assessment has not been undertaken and further information is needed on sustainability

7743, 8497, 8816, 9384

Supplementary report on phase two consultation

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2 The need, solution, tunnel route and alignment Ref Objections, issues and concerns related matters. Respondent ID No. Our response of alternative options. Sustainability concerns the balanced consideration of social, economic and environmental objectives: the three pillars of sustainability. We believe that the project can achieve positive benefits under each. The principal environmental outcome for the project will be the improvements to water quality in the River Thames, which will assist to meet Water Framework Directive requirements for good quality waters. We recognise that the construction of the project has the potential to cause environmental effects. We have been assessing the likely significant effects that may arise as a result of the works as part of an environmental impact assessment. This will set out measures necessary to mitigate any significant adverse effects that are identified. An Environmental statement, which records the findings of the environmental impact assessment, will accompany our DCO application. The initial environmental assessment work that has been carried out on the project is contained within the PEIR, which is available on our website. As part of the phase two consultation, we also sought feedback on the potential effects arising from our proposals and how the effects will be mitigated. Where possible, we will take feedback comments into account as we develop our proposals. The positive benefits for water quality may have on-going social and economic benefits for London. The projects long-term solution, takes account of the need to adapt to future climate change. Our submission will be accompanied by a sustainability assessment that will cover similar issues to CEEQUAL. A sustainability appraisal has also been undertaken as part of the adoption process for the Waste Water National Policy Statement. This is published in the Appraisal of Sustainability Post-Adoption Statement. In relation to further information, an energy assessment and carbon footprint modelling exercise is being undertaken which provides an evidence-based solution to address the energy use and emissions arising from the project. The exercise draws from the Mayor of Londons Energy Hierarchy and will demonstrate how emissions have been taken into account and reduced where practical and possible, helping to contribute to the Mayor of Londons targets of a long-term reduction of carbon dioxide in the capital of 60 per cent by 2025. The exercise is testing the potential for the project to achieve as high a level of energy efficiency as practical in its construction and operation as well as the potential for incorporating renewable energy technologies. The exercise will be reported in the Energy statement, which supports our DCO application. The Thames Tunnel project is a major and complex engineering project so the cost of it is going to be considerable, and we appreciate that consultees are concerned about that fact. On 7 September 2010 the Secretary of State confirmed that the project the cheapest solution by far. Table 5.10 of the Needs report (which

2.3.61 The cost of the tunnel is unacceptable.

13397LO, 9110LO, 11581, 11662, 11747, 11748, 11852, 12157, 12301, 12492, 12503, 12504, 12635, 12670, 12699, 12836, 12843, 12872, 12971, 13003, 13168, 13191, 7022, 7050, 7117, 7125, 7140, 7157, 7170, 7196, 7202, 7218, 7232, 7277, 7338, 7342, 7366, 7384, 7391,

82

Supplementary report on phase two consultation

2-39

2 The need, solution, tunnel route and alignment Ref Objections, issues and concerns Respondent ID 7396, 7422, 7431, 7435, 7475, 7476, 7490, 7502, 7510, 7513, 7519, 7523, 7539, 7557, 7627, 7663, 7675, 7701, 7789, 7795, 7919, 7968, 7973, 8047, 8203, 8318, 8402, 8411, 8772, 8779, 8820, 8838, 8849, 8856, 8909, 9015, 9082, 9160, 9161, 9186, 9351, 9353, 9445 (LR)RBKC, 8887LO, 9083LO, 9084LO, 9085LO, 9086LO, 11312, 11404, 12525, 12704, 12712, 12713, 12791, 12968, 12994, 13020, 13185, 13194, 13364, 7148, 7183, 7364, 7366, 7394, 7452, 7568, 7671, 7844, 8486, 8558, 8662, 8737, 8885, 8890, 8923, 8943, 9129, 9361, 9395, 9475, LR9112 No. Our response is available on our website) shows that the cost of the Thames Tunnel project options is least relative to the alternatives of sewer separation and SuDS. The Government has recently published a report entitled Creating a River Thames fit for our future: A strategic and economic case for the Thames Tunnel. This report provides an update to the 2007 regulatory impact assessment and takes into account data that has emerged since that time. The report contains an appraisal of alternative solutions and concludes that a tunnel solution remains the most appropriate and cost-effective of the solutions considered. As the project develops, we have been and will continue to be closely scrutinised by the industry economic regulator Ofwat and by Defra.

2.3.62 The cost of the tunnel is not appropriate during a time of financial constraint.

41

2.3.63 The tunnel is an expensive option.

8807LO, 9105LO, 9108LO, 9110LO, 11246, 11262, 7022, 33 7117, 7146, 7166, 7245, 7338, 7386, 7430, 7523, 7564, 7613, 7669, 7702, 7704, 7784, 7876, 8042, 8473, 8497, 8614, 8662, 8738, 8749, 8750, 9075, 9308, LR9315 LC, (LR)CCW, LBW, (LR)LBS, 13495LO, 8562LO, 8563LO, 8564LO, 8569LO, 8571LO, 8795LO, 8801LO, 9108LO, 9131LO, 9392LO, LR9386LO, 8410LO, 11001, 11002, 11003, 11004, 11005, 11006, 11007, 11384, 12060, 12068, 12817, 13065, 13128, 13147, 13173, 13189, 7022, 7294, 7423, 7472, 7523, 7558, 7833, 8062, 8251, 8252, 8254, 8255, 8256, 8258, 8259, 8260, 8266, 8268, 8270, 8272, 8273, 8300, 8386, 8393, 8394, 8415, 8416, 8417, 8418, 8419, 8420, 8423, 8426, 8428, 8431, 8432, 8557, 8558, 8566, 8567, 8572, 8653, 8866, 8890, 8927, 8951, 8953, 9098, 9191, 9303, 9333, 9353, 9357, 9366, 9395, 9475, LR11000, LR13382, LR13472, LR13498, LR9112, LR9136, LR9289, LR9315, LR9341, LR9352, LR9360 100

2.3.64 Concern about the scale of the cost of the project. Query whether Thames Water has considered that the Water Framework Directive (WFD) allows the adoption of less stringent environmental objectives where achieving the standards would be technically unfeasible or disproportionately expensive, subject to conditions. The Consumer Council for Water also queries, given concerns with the cost benefit analysis, whether the tunnel can properly be described as value for money for customers. Even when comparing the highest figure in the range of benefits (5.1 billion) with, the potential cost of the Thames Tunnel project in addition to costs for the Lee Tunnel and associated works, the case is less than compelling. 2.3.65 The negative effects from construction outweigh the benefits of the scheme. 2.3.66 There is a need to balance costs and benefits.

The response at paragraph 2.3.65 also applies to the objections, issues and concerns raised within this paragraph. You may wish to consider the response at paragraph 2.3.65 as well as the text below. We note the reference to the WFD but the main driver is the UWWTD, which is not explicitly subject to a cost/benefit test. The adoption of less stringent quality standards under WFD would not necessarily assist in compliance with UWWTD, which has a basic presumption that all wastewater flows are captured and fully treated before returned to the environment The Thames Tunnel project is needed to secure compliance with the UWWTD and the Government recognises that it is the most appropriate solution having regard to the best technical knowledge not entailing excessive cost (BTKNEEC) test.

8321LO, 11850, 12273, 12750, 12794, 13043, 13235, 7646, 8411, 8459, 8531, 9026 11052, 13024, 13059, 8892, 8903

12 5

Work has been underway on examining the solutions to the problem of overflow sewage discharges to the River Thames for more than ten years. The independently chaired Thames Tunnel Steering Group concluded in 2005 that that a large diameter storage and transfer tunnel was the preferred solution. A comprehensive cost benefit analysis was undertaken at that time. The cost benefit analysis showed that a storage and transfer tunnel option (Lee Tunnel and Thames Tunnel project), combined with improvements at the sewage treatment works, and had the highest net benefits. Subsequent sensitivity testing and analysis demonstrated that, even though there is uncertainty around some of the assumptions underlying the cost benefit analysis, the benefits would have to drop

Supplementary report on phase two consultation

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2 The need, solution, tunnel route and alignment Ref Objections, issues and concerns Respondent ID No. Our response to a quarter of those assessed to change the conclusion that the net benefits are positive. The Needs report at Table 5.10 sets out the cost of the preferred route of the tunnel in comparison with the alternative routes and alternative solutions. This work informed the Ministerial Statement in March 2007 and the request that we develop the tunnel solution. The Government has recently published a report entitled Creating a River Thames fit for our future: A strategic and economic case for the Thames Tunnel. This report provides an update to the 2007 regulatory impact assessment and takes into account data that has emerged since that time. The report contains an appraisal of alternative solutions and concludes that a tunnel solution remains the most appropriate and cost-effective of the solutions considered. As the project develops, we have been and will continue to be closely scrutinised by the industry economic regulator Ofwat and by Defra. The European Commission has proceeded with infraction proceedings against the UK Government with respect to frequent discharges of sewage into the tidal Thames. The decision of the court has not yet been issued, but it has the power to seek fines consisting of a lump sum and a periodic penalty, which could amount to considerable sums. It is therefore necessary for action to be taken to avoid such penalties being applied for future non-compliance with the UWWTD. We are aware that construction effects can be disruptive, but we are consulting and working to ensure that such effects are minimised over the construction period. The benefits of the project, such as removing sewage from the River Thames, are long-term and will benefit current and future generations. The response at paragraph 2.3.65 also applies to the objections, issues and concerns raised within this paragraph. You may wish to consider the response at paragraph 2.3.65 as well as the text below. While we understand the concerns of bill payers about the implications for our wastewater charges, the way in which we are regulated means that a standard approach is adopted across the water industry. Major improvements to clean up rivers and beaches are paid for by the customers of the relevant water companies. It should be noted that the Thames Water Trust Fund, set up in February 2009, is able to help customers in financial difficulty or hardship. The Trust is able to provide grants to help people experiencing difficulty in paying their bill. Although set up by us, the Trust operates independently of the company and customers can contact the Trust themselves, or be referred by third parties. Cost benefit analysis has already been undertaken, which showed that a storage and transfer tunnel option, combined with improvements at sewage treatment works had the highest net benefits. This work informed the Ministerial Statement in March 2007 and the request that we develop a tunnel solution. The Government

2.3.67 The cost of the tunnel outweighs its benefits due to disproportionate and unacceptable financial burden it places on Thames Water's customers.

(LR)CCW, 7331LO, 7996LO, 9093LO, 11077, 11391, 11872, 11984, 12173, 12231, 12863, 12902, 13043, 13240, 7192, 7226, 7261, 7351, 7385, 7423, 7429, 7475, 7522, 7549, 7566, 7637, 7675, 8041, 8459, 8531, 8724, 8751, 8779, 9303

34

2.3.68 Further information should be provided on costs and benefits including:


- re-appraisal of the costs and benefits

of the full tunnel and of the alternative

(LR)CCW, LBHF, 13495LO, 8410LO, 8562LO, 8563LO, 8564LO, 8571LO, 8795LO, 8801LO, 9093LO, 9417LO, 9481LO, LR9386LO, 11001, 11002, 11003, 11004, 11005, 11006, 11007, 11307, 11707, 11734, 12100, 12979, 12984, 12986, 12987, 12988, 12989, 12990,

119

Supplementary report on phase two consultation

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2 The need, solution, tunnel route and alignment Ref Objections, issues and concerns options is required, especially as cost benefit analysis is five years old and based on outdated and challengeable assumptions including willingness to pay Respondent ID 12994, 13000, 13004, 13005, 13006, 13007, 13025, 13028, 13032, 13033, 13034, 13035, 13036, 13037, 13043, 13053, 13056, 13063, 13082, 13083, 13084, 13085, 13111, 13146, 13160, 13179, 13180, 13184, 13192, 13195, 13198, 13200, 13201, 13207, 13213, 7395, 7833, 7968, 8062, 8249, 8251, 8252, 8256, 8258, 8259, 8266, 8270, 8271, 8272, 8273, 8386, 8393, 8394, 8402, 8415, 8416, 8417, 8418, 8419, 8420, 8423, 8426, 8428, 8430, 8431, 8432, 8566, 8567, 8568, 8572, 8603, 8753, 8831, 8849, 8951, 8953, 9160, 9333, 9353, 9357, 9467, LR11000, LR9136, LR9341, LR9352, LR9360, LR9418 No. Our response has recently published a report entitled Creating a River Thames fit for our future: A strategic and economic case for the Thames Tunnel. This report provides an update to the 2007 regulatory impact assessment and takes into account data that has emerged since that time. The report contains an appraisal of alternative solutions and concludes that a tunnel solution remains the most appropriate and cost-effective of the solutions considered. Furthermore, the Waste Water National Policy Statement states that the appropriate strategic alternatives to a tunnel have been considered and it has been concluded that it is the only option to address the problem of discharging unacceptable levels of untreated sewage into the River Thames within a reasonable time at a reasonable cost. We therefore do not consider that it is necessary to re-appraise this element of the scheme. At this stage a more accurate business model cannot be offered, as the financial delivery model remains under discussion with the Government. In November 2011 the Government published Creating a River Thames fit for our Future: A Strategic and Economic Case for the Thames Tunnel. This was accompanied by a document with the title Costs and Benefits of the Thames Tunnel which is the latest on the cost benefit of the Thames Tunnel project. We understand that the document was prepared in accordance with Government guidance. As we are not the author of the document we would suggest that if the respondent has concerns about the approach that they take this up with Defra. There is no explicit test of either excessive or disproportionate cost in the UWWTD, and as the UWWTD is seen as a basic measure (that is, a pre- existing Directive that must be complied with) then there is no clear requirement to assess whether action taken under UWWTD is (or is not) excessively or disproportionately costly. The Environment Agency has identified the most polluting CSOs, which cause unacceptable environmental impacts because of the frequency or volume of the overflow, or because they discharge into an environmentally sensitive part of the River Thames. In relation the West Putney CSO, the Needs report identifies this CSO as being within the category of CSOs which most urgently need to be addressed. Table 4.2 of the Needs report provides further details. Monitoring data for the West Putney CSO from 1 October 2010 to 30 September 2011 also confirms that this CSO continues to overflow with 31 distinct discharges identified within this period. Bacteria data (e.coli) collected in 2011 also indicates high levels and the presence of human waste in the discharge confirming the health risks from discharges from West Putney CSO. The cost of acquiring, constructing and operating each site is treated as commercially confidential information. While we continue to

- a more accurate business model for the project and more detailed cost breakdown
- confirming the adequacy of the

willingness to pay and benefits assessments undertaken to date and addressing concerns raised by the Consumer Council for Water in relation to the adequacy of these assessments

- the need to demonstrate the scheme

complies with the UWWTD and the Water Framework Directive in that it does not have sufficiently negative cost benefit ratio that would be deemed 'excessive' or 'disproportionate'
- a cost benefit analysis and budget for

proposed works at West Putney Storm Relief

Supplementary report on phase two consultation

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2 The need, solution, tunnel route and alignment Ref Objections, issues and concerns Respondent ID No. Our response develop and revise our proposals we are not in a position to be able to comment further on cost for individual work areas. The cost of acquiring, constructing and operating each site is treated as commercially confidential information. While we continue to develop and revise our proposals we are not in a position to be able to comment further on cost for individual work areas. GLA, LC, (LR)CCW, LBW, 7260LO, 8303LO, 13166, 13173, 13229, 7003, 7127, 7192, 7208, 7209, 7222, 7269, 7323, 7361, 7479, 7496, 7523, 7610, 7663, 7804, 7843, 7892, 8007, 8085, 8211, 8725, 8782, 8793, 8890, 9075, 9395, 9475, 9476, 9487, LR9112, LR9315 40 We recognise that the costs for the Thames Tunnel project have changed. In 2010 we estimated that the project would cost 3.6 billion at 2008 prices. As design development has continued and allowance has been made for a later completion date and in response to phase one consultation, costs have been included for greater use of brownfield sites and river transport. The cost base has also been updated to 2011 prices. On this basis the estimates for the project costs are now 4.1 billion. This includes 0.9 billion of risk allowance and optimism bias. These estimates have been examined by independent advisers on behalf of Ofwat and confirmed to reflect best practice in the industry. As we refine our proposals, we will seek all possible ways to minimise the cost impact and offer good value to our customers through the design, construction and operation of the tunnel. In preparing our cost estimates, we will continue to have regard to the Treasury Green Book, which is the standard for this type of project and includes accounting for risk. As set out in the Funding project information paper, the development and subsequent construction of the Thames Tunnel project will be paid for by our wastewater customers through their sewerage bills. This approach is standard across the UK water industry. Ofwat will scrutinise all aspects of the project to ensure costs are kept as low as possible. While we understand the concerns of bill payers about the implications for our wastewater charges, the way in which we are regulated means that a standard approach is adopted across the water industry. Major improvements to clean up rivers and beaches are paid for by the customers of the relevant water companies. The Flood and Water Management Act 2010 allows companies to reduce charges for individuals who would have difficulty in paying in full, through subsides provided by other customers. The draft guidance setting out the rules that will enable companies to introduce social tariffs have recently been consulted upon by Defra, who have indicated that they expect to issue final guidance spring 2012. At this stage it is not yet clear how it will operate or the extent to which some households will benefit. However we take our social responsibilities seriously and we already have a number of schemes in place which provide some degree of affordability benefit/relief to household customers. We are conscious that while our supply area not only includes many

- the cost of Greenwich connection

tunnel.

2.3.69 Concern about Thames Water's ability to ensure that costs do not escalate, particularly given the recent increase in cost of the project. Incentives should be put in place to guard against further escalation of anticipated project costs and against cost overruns once the project commences. Thames Water should also ensure that costs are kept under control in order to minimise the impacts of bill increases on Thames Water customers. 2.3.70 Present quoted costs will not reflect the actual cost of the tunnel, particularly given existing increase in the cost of the project that has already been seen. 2.3.71 Query where the money will come from to fund the project.

LC, 11772, 12981, 7475, 7549, 7877, 8473, 8668, 8782, 8849, 8926, 9186, 9191, 9443, 9487, LR9278

16

8001LO, 10156, 11010, 11707, 7524, 9357

2.3.72 Concerned about increase to customer bills. Reasons included: - bill increases will exacerbate existing affordability issues and may well create new problems when combined with the companys intended roll out of compulsory metering - it is a socially regressive means of paying for the Thames Tunnel project since it most affects the poorest in society - the social tariff which will be introduced is only likely to help those in most extreme hardship - query how long customers will have to pay increase in water bills to recoup the cost of building the tunnel.

LC, (LR)CCW, LBR, (LR)RBKC, 7996LO, 8410LO, 8807LO, 11034, 11384, 11404, 11956, 12492, 12544, 12679, 12703, 12962, 13024, 13038, 13140, 7022, 7121, 7127, 7169, 7170, 7186, 7230, 7245, 7269, 7271, 7277, 7337, 7338, 7366, 7389, 7431, 7470, 7472, 7475, 7476, 7496, 7497, 7502, 7520, 7522, 7524, 7532, 7545, 7549, 7558, 7572, 7577, 7591, 7632, 7669, 7671, 7675, 7704, 7731, 7844, 7876, 7877, 7898, 8007, 8024, 8043, 8109, 8211, 8221, 8668, 8673, 8856, 8891, 8909, 8926, 8977, 9075, 9191, 9203, 9303, 9399, 9446, 9460, 9486, LR13498, LR9154, LR9315

86

Supplementary report on phase two consultation

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2 The need, solution, tunnel route and alignment Ref Objections, issues and concerns Respondent ID 7140, 7312, 7497 7022, 9366 13397LO, 8562LO, 10830, 12917, 12918, 7221, 7366, 7671, 7892, 8022, 8062, 8871, 8923, LR13382 11283, 7169, 7632, LR13390 No. 3 2 14 4 Our response wealthy households it also has 19 of the 50 lowest income Boroughs in the country. We will consult with customers and customer representatives to seek their views on the design, eligibility criteria and levels of cross subsidy, before a tariff is introduced. The level of cross subsidy will therefore limit the number of customers that can be helped through a social tariff. A majority of customers will be required to pay more to reduce the bills of customers eligible for a social tariff. The project will not have any impact on bills before 2013 at the earliest. It is expected that the construction and operation of the Thames Tunnel project will require our customers' bills to have risen by slightly more than 1 a week by 2018. We consider that we have undertaken a thorough and comprehensive consultation exercise. As part of this, we carefully considered the information we made available at our phase two consultation to ensure that consultees had sufficient information to respond to the consultation. Information on the proposed increases to water bills was contained within the Funding project information paper. We are confident therefore that the information we have provided is sufficient.

2.3.73 Thames Water (not customers) should bear the cost. 2.3.74 The Government (not customers) should bear the cost. 2.3.75 Customers should not bear the cost. 2.3.76 Customers located outside of London should not bear the cost.

2.3.77 Increase to water bill has not been properly addressed during phase two consultation.

11013, 11033, 11047, 11105, 11112, 11351, 11359, 11375, 11394, 11410, 11426, 11428, 11548, 11550, 11610, 11642, 11655, 11667, 11696, 11715, 11722, 11724, 11735, 11753, 11757, 11764, 11768, 11782, 11831, 11861, 11866, 11888, 11890, 11923, 11940, 11964, 11989, 11997, 12028, 12066, 12070, 12111, 12150, 12171, 12194, 12197, 12202, 12211, 12219, 12222, 12239, 12243, 12254, 12255, 12295, 12296, 12297, 12298, 12304, 12321, 12333, 12345, 12374, 12379, 12385, 12427, 12515, 12529, 12530, 12539, 12626, 12687, 12715, 12720, 12729, 12742, 12758, 12772, 12777, 12819, 12858, 12879, 12898, 12939, 13012, 13063, 13075, 13077, 13086, 13104, 13114, 13135, 13148, 13183, 13188, 13190, 13199, 13204, 13206, 13217, 13221, 13232, 7181, 7518, 7567, 8621, 8683, 8874, 9191 (LR)CCW, 9400LO, 13140, 7408, 7475, 7621, 8831, 8926, 8953, 9303, 9487

109

2.3.78 Query whether a cheaper scheme would meet the requirements of the UWWTD and in particular whether the BTNEEC (best technical knowledge not entailing excessive cost aspect of the UWWTD has been applied.

11

For the reasons set out in the Needs report, we consider that the project is necessary and accords with the BTNEEC test. We have considered a wide range of options to reduce and control the amount of untreated sewage that flows into the River Thames, including local storage and treatment, SuDS, separation of the sewerage system, bubblers and skimmers. None of these options were considered practical; they costed more and often did not provide the same level of CSO control or benefits when compared to the tunnel solution. We believe that the combination of works improvements and tunnels applies the best available technologies given the nature of the CSO problem. Although the best technologies are common practices (treatment works and tunnels) we have considered the application of these technologies to a practical level for CSO control: otherwise we would have much larger treatment works and storage/transfer tunnels. Although the costs are large they are not considered excessive given the magnitude of the problem that will be solved. We believe the costs would be excessive if the best technologies were applied fully and CSO control was implemented at 100 per cent. The Government has recently published a report entitled Creating a

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2 The need, solution, tunnel route and alignment Ref Objections, issues and concerns Respondent ID No. Our response River Thames fit for our future: A strategic and economic case for the Thames Tunnel. This report provides an update to the 2007 regulatory impact assessment and takes into account data that has emerged since that time. The report contains an appraisal of alternative solutions and concludes that a tunnel solution remains the most appropriate and cost-effective of the solutions considered. As a result, the Government confirmed that the detailed studies undertaken continue to confirm the case for the Thames Tunnel project.

2.3.79 Query what the effect on customer's bills See annex B of this report will be.

2,044 The project will not have any impact on bills before 2013 at the earliest. It is expected that the construction and operation of the Thames Tunnel project will require our customers' bills to have risen by slightly more than 1 a week by 2018. This means that the bills of our customers, which have for many years been among the lowest in the country, would rise to around the national average. The Thames Water Trust Fund, set up in February 2009, is able to help customers in financial difficulty or hardship. The Trust is able to provide grants to help people experiencing difficulty in paying their bill. Although set up by us, the Trust operates independently of the company and customers can contact the Trust themselves, or be referred by third parties. 7 As is industry standard for large bore tunnels, there will be a programme of inspections every ten years to maintain the tunnel. Any repairs necessary to the tunnel (which runs up to approximately 65m below ground level) are very likely to be carried out from within the tunnel. The effects of tunnel maintenance are being considered as part of the environmental impact assessment. As described in the Build project information paper, our tunnel will be built using a closed face tunnel boring machine (TBM). This type of machine is very secure and well tested in the soils under London. The front section of the tunnel is fully supported by the shell of the machine itself and the reinforced concrete tunnel lining is erected in the machine as it moves forward. There is no point in the process at which the ground is left unsupported. Our tunnel will also be built to comply with all relevant regulations and policies, and best practice such as the British Standards. The work of the contractor building the tunnel will be under review and observation by independent supervisors. With these measures in place, tunnel collapse is an extremely remote possibility. We have designed the tunnel so that it is a failsafe system. This means that in the event that above ground mechanical and electrical equipment fails, the tunnel has been designed not to cause flooding. There is no mechanical or electrical equipment within the tunnel and therefore it is not possible for the tunnel to have a fault. Should the pumps fail at Beckton Sewage Treatment Works or at one of the shafts, then sewage would be discharged into the River Thames.

2.3.80 Concerned about tunnel maintenance.

8210, 8716, 8781, 8923, 9098, 9191, 9446

Particular concerns included: - the risk of the tunnel collapsing

- what happens when the tunnel has a fault

Supplementary report on phase two consultation

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2 The need, solution, tunnel route and alignment Ref Objections, issues and concerns
- whether the collection of fats, oils and

Respondent ID

No.

Our response The tunnel has been designed hydraulically to be self cleansing and convey all floating and suspended materials to the pumping station at Beckton Sewage Treatment Works where facilities are provided to remove sewage and any associated materials. The experience from the operation of other major international CSO tunnels such as Singapore and Chicago has been that the intervals between main inspections has been increased to greater than 10 years, which is the frequency with which we expect to undertake maintenance visits. The tunnel infrastructure is designed to have a 120 year design life with minimal maintenance. It is not envisaged that major works will be required over and above the 10 year inspections, cleaning and nominal maintenance activities. The use of the tunnels will result in reduced hygiene risks since it will capture sewage instead of it being discharged into the River Thames as is currently the case. The tunnels will be emptied 48 hours after storms have abated and the sewage within the tunnels treated at Beckton Sewage Treatment Works. Currently there is an increase in viral infections to river users following CSO discharges to the River Thames. The significant reduction in discharges into the River Thames will bring health benefits by minimising these discharges. The large 7.2m internal diameter of the main tunnel is considered too large to become blocked as items entering the main tunnel are restricted in size by the vortex generators and existing pumping stations. All CSO interception works have flap valves that prevent backflow from the Thames Tunnel system into the local sewers

greases in the tunnel without powered mixing facilities within the tunnel will lead to the need for more frequent maintenance visits

- what works will be needed during the 120 year life of the tunnel

- hygiene risks

- whether a blockage within the tunnel or

failure cause back-flow to Putney.

2.3.81 Concerned about the length of the construction period and the construction running on time.

LBR, 8303LO, 13043, 7127

The length of the construction period indicated in the phase two consultation documents is the maximum period that works would be underway. The programming of works at all sites will be configured to minimise the duration of works and associated disruption to the local area where possible. The potential impact on property values either temporarily during the construction phase or permanently as a direct consequence of the completed works is fully recognised. As part of our preparation for phase two consultation, we undertook a land referencing exercise to identify those who might have a relevant claim for compensation as a result of the project. For further information on how we notified those who might have a relevant claim refer to chapter 2 of the Main report on phase two consultation and for further details on how this exercise was undertaken refer to appendix M of the Main report on phase two consultation. We have published our Exceptional hardship procedure, which will

2.3.82 The tunnel will affect property values in surrounding areas.

7199

Supplementary report on phase two consultation

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2 The need, solution, tunnel route and alignment Ref Objections, issues and concerns Respondent ID No. Our response assess claims from householders who contend that they are suffering hardship as a result of being unable to sell their property because it is potentially impacted by the Thames Tunnel project proposals. Further details on the Exceptional hardship procedure are available on our website. It is true that the project will give rise to emissions during the construction phase. A comprehensive energy assessment is being undertaken for the project which considers the whole life cycle for carbon embedded in the project. This assessment is being used to identify how engineering decisions can influence carbon embedded in the project, allowing us to minimise these emissions where possible and practical. The results of energy assessment will be contained within the Energy statement submitted with our DCO application. While it must be accepted that emissions embedded in the project are inevitable, steps are being taken to reduce emissions as far as possible. Examples include design changes to enable a shorter tunnel and elimination of active air treatment plants at all shafts. Design development will continue to take into account opportunities for reductions in emissions. Emissions have also been taken into account in the development of our transport and waste strategies. We recognise that production and use of concrete is carbon intensive. However, options are available to reduce embedded carbon through practical yet cost-effective specification of materials. This specification is subject to on-going consideration, and will take account of emissions. This must be balanced against the durability of the materials, ensuring that the long-term benefits of the project will be achieved, and construction and life-cycle costs. Using the tunnel system for pumped storage would be very problematic when the tunnel is needed for CSO control since there is no way of adequately assuring that the storage would be available for CSO control. Pump out time, to match the benefits of meeting peak electric demand and using off-peak electric surplus capacity, is indicated at multiple days unless a substantial pumping station was installed (>50m3/s). Storage would have to be recovered within 24hours to allow for CSO control. The intakes and outlets would have to be near each other to avoid drying-up parts of the River Thames and areas near Beckton Sewage Treatment Works, which is composed of saline water. Introduction of saline tidal Thames water into the tunnel system would require additional concrete protection. Introduction of river water would also require fine screens to avoid entrapping fish.

2.3.83 Concerned about the sustainability of certain elements of the tunnel's construction and operation. Particular concerns included: - fossil fuels will be burnt during construction of the tunnel
- carbon costs associated with the

(LR)CCW, GLA, 7402, 7476, 7502, 8456, 8497, 8624, 8643, 8651, 8776, 8779, 8861, 8909, 9283, LR9398

16

project should be quantified including carbon costs for movement of excavated material and manufacture of other materials for the tunnel
- the carbon footprint for the project

- large amounts of concrete will be used

in the tunnel's construction

- energy mitigation and optimisation

measures should be incorporated, including modifying the system to enable dual use for pumped storage

- the Thames Tunnel project offers

unique scope for an electrically pumped storage facility, providing a bottom reservoir, approximately 1,000,000 cubic meters at a depth of 60-70m below river level, to be used in conjunction with the river itself as top storage. There is the potential to generate approximately 200MWhrs every time the tunnel is filled.

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2 The need, solution, tunnel route and alignment Ref Objections, issues and concerns
- no proposals have been put forward for

Respondent ID

No.

Our response We are also exploring the feasibility of implementing renewable energy technologies and other forms of energy recovery. The conclusions of our investigation will be contained within the Energy statement submitted with our DCO application. We recognise the energy requirements and associated carbon emissions relating to the project. An energy assessment and carbon footprint modelling exercise is being undertaken which provides an evidence-based solution to mitigate potential impacts of the project. The exercise draws from the Mayor of Londons Energy Hierarchy and will demonstrate how emissions have been taken into account and reduced where practical and possible, helping to contribute to the Mayor of Londons targets of a long-term reduction of carbon dioxide in the capital by 60 per cent by 2025. The exercise is testing the potential for the project to achieve a high level of energy efficiency in its construction and operation as well as the potential for incorporating renewable technologies to meet the energy demands of each site. The calculation of the projects carbon footprint, which is an integral part of the energy assessment, considers both the construction and operational phases of the project and seeks to identify ways in which the emissions of greenhouse gas can be minimised. A carbon modelling tool is being used for carbon analysis, option comparison, reduction and reporting. The model has been designed to analyse hot spots in project carbon performance so that interventions (changes in energy supply technology, alternative materials, alternative logistical arrangements etc) may be prioritised and targeted accordingly. The output of the exercise, including the feedback and response to stakeholder consultation is being incorporated into the projects sustainability strategy and will be reported in an Energy statement which will be submitted with the DCO application.

energy recovery

- operation of the tunnel will use a great

deal of energy in both pumping and treatment of the captured sewage. The Mayor of London seeks to ensure that the equipment used is as efficient as possible and that opportunities to generate renewable energy are taken during the project. The Mayor of London would also like to see energy being captured from the inflowing sewage but understands that at present there does not appear to be a robust and reliable way of doing this.

2.3.84 The tunnel will not address basement flooding.

8562LO, 12997, 7192, 7196, 7361, 7386, 7479, 7497, 7510, 7522, 7523, 7549, 7702, 8318, 8725, 9353

16

When some sewers fill to capacity under intense rainfall, the combined sewage backs up and finds the lowest point at which it can escape the system. This can sometimes be basement toilets or bathrooms and streets. The Thames Tunnel project is not designed to deal with localised street or basement flooding but as the capacity of the system will be substantially increased at some critical points, it will mean that the tunnel system could potentially alleviate some sewer flooding problems. Specifically, in relation to basement flooding in Hammersmith and Fulham, our long-term programme involves a major upgrade to the sewerage network in the Counters Creek area. This work will be taken forward separately to address the specific flooding problems in the area. In the short term our programme involves installing (free of charge) anti-flood devices at properties with basements which have the highest risk of sewer flooding. This programme began in May 2010,

Supplementary report on phase two consultation

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2 The need, solution, tunnel route and alignment Ref Objections, issues and concerns Respondent ID No. Our response with a plan to protect approximately 600 properties by the end of 2012. As set out in Why does London need the Thames Tunnel?, there are human, environmental and legal reasons for the Thames Tunnel project. Further details are also contained within the Needs report. Both documents are available on our website. The Government report entitled Creating a River Thames fit for our future: A strategic and economic case for the Thames Tunnel also sets out the reasons for the project. In March 2007 the Government requested that we develop the tunnel solution. This decision was based on the evidence base established by the TTSS and subsequent studies. The Thames Tunnel project is not politically motivated. Without it, the pollution of the River Thames will get worse given the increasing population, new developments and the impact of climate change. Noted. Comments submitted as part of phase one consultation have been taken into account. Refer to our Report on phase one consultation for further details. We are in discussions with Government and the economic regulator Ofwat on the appropriate delivery model for the Thames Tunnel project. One of the options being considered is an Infrastructure Provider which could see a third party finance and build the tunnel. Until the delivery model has been agreed it is not possible to provide further information.

2.3.85 The project is politically motivated.

13397LO, 7003, 7343, 8210, 11404

2.3.86 Commented on the solution for the project at phase one consultation. 2.3.87 Other issues, concerns and objections raised included: - the financial interests of Thames Water regarding the construction have not been sufficiently disclosed

7339, 8728

GLA, LC, (LR)CCW, LBW, 13379LO, 13397LO, 8562LO, 8563LO, 8564LO, 8571LO, 8795LO, 8801LO, 8843LO, 9417LO, 9481LO, LR9386LO, 11001, 11002, 11003, 11004, 11005, 11006, 11007, 11351, 11565, 11660, 12153, 12981, 13020, 7003, 7112, 7395, 7403, 7409, 7489, 7620, 7675, 7704, 7801, 7844, 7854, 7937, 8042, 8047, 8098, 8209, 8251, 8252, 8256, 8258, 8259, 8260, 8266, 8270, 8272, 8273, 8394, 8416, 8417, 8418, 8419, 8420, 8423, 8426, 8428, 8430, 8431, 8432, 8566, 8567, 8568, 8572, 8653, 8680, 8725, 8737, 8774, 8861, 8866, 8890, 8891, 8951, 8953, 8977, 9007, 9098, 9186, 9197, 9262, 9303, 9333, 9334, 9353, 9357, 9366, 9395, 9467, 9475, 9486, 9487, LR11000, LR13408, LR13472, LR9112, LR9136, LR9341, LR9352, LR9360, LR9459

109

2.3.88 the benefit of any government contributions/funding must accrue to Thames Water customers, and not to the benefit of Thames Water or its shareholders: Defra, Her Majestys Treasury and Ofwat need to impose funding structures and regulatory controls to deliver this 2.3.89 - customer acceptability and affordability should be key considerations in the timing and mechanisms for cost

We acknowledge that the appropriate delivery model which is ultimately agreed for the Thames Tunnel project, through our discussions with Government and the economic regulator (Ofwat), will need to be capable of demonstrating to all parties that it provides value for money for both taxpayers and customers.

The delivery model which is agreed for the Thames Tunnel project will need to include a robust approach to cost recovery. Thames Water is in discussions with Government and the economic regulator Ofwat to determine how that delivery model can provide value for

Supplementary report on phase two consultation

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2 The need, solution, tunnel route and alignment Ref Objections, issues and concerns recovery Respondent ID No. Our response money and affordability. Value for money and affordability are key issues that will help to frame decisions on cost recovery. Thames Water is in discussions with Government and the economic regulator Ofwat on the appropriate delivery model for the Thames Tunnel project which will include the treatment of efficiency savings. While no decisions have been reached on the financing structure for the Thames Tunnel project, all options are being examined with a view to ensuring value for money and affordability. Thames Water continues to discuss with both the Government and Ofwat the most appropriate delivery model for the tunnel. The financing of the tunnel is an important issue which will include consideration of Government support. This is the subject of on-going discussions between Thames Water and Government together with Ofwat as the regulatory body. Thames Water is in discussions with Government and the economic regulator Ofwat on the appropriate delivery model for the Thames Tunnel project which includes the consideration of risk. A key driver of the solution will be ensuring it is value for money for both taxpayers and customers. A key driver of any decision which is taken in relation to the delivery model will be to ensure value for money for both taxpayers and customers. We are continuing on-going discussions with Government and the economic regulator Ofwat to test all available options.

2.3.90 - suitable protections should be in place to ensure that any efficiency savings and under spends are given back to customers 2.3.91 - if long-term bonds would offer a better option for spreading the cost then that route should also be considered

2.3.92 - the Government must provide a meaningful contribution to the financing of such an exceptional project 2.3.93 - respondents object to taxpayers being liable for the project risk, if tunnelling problems are encountered

2.3.94 - to ensure that costs are minimised, a structure should be established that incentivises minimising project spend; funding and transactional work should be undertaken by banks not related to the current owners of Thames Water; a mechanism should be put in place to claw back excessive profits if operating costs come in lower; the marginal return allowed on the increase in the Regulated Asset Base should be in line with money market risk-free rates for the depreciable period of the asset 2.3.95 - query whether there will be a cap on shareholder benefit during the seven years to avoid bill payers being skimmed 2.3.96 - it should be a condition of the project that Thames Water should not be able to declare profit and pay shareholder dividends or employee bonuses until customers have been paid back in full 2.3.97 - Ofwat and government should reassure Thames Waters customers

Thames Water is in discussions with Government and the economic regulator Ofwat on the appropriate delivery model for the Thames Tunnel project. We anticipate the delivery of the tunnel will be an activity that will be closely monitored by the regulator. Thames Water is in discussions with Government and the economic regulator Ofwat on the appropriate delivery model for the Thames Tunnel project. A key driver of the solution will be ensuring it is value for money for both taxpayers and customers. Thames Water is in discussions with Government and the economic regulator Ofwat on the appropriate delivery model for the Thames

Supplementary report on phase two consultation

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2 The need, solution, tunnel route and alignment Ref Objections, issues and concerns that the most sensible and costeffective solution will be followed for funding the project. Query whether these bodies are able to make an unbiased decision Respondent ID No. Our response Tunnel project. A key driver of the solution will be ensuring it is value for money for both taxpayers and customers. Ofwat is an independent regulator who is held to account by parliament.

2.3.98 - if customers are required to pay then we should be canvassed on willingness and ability to pay

2.3.99 - respondents suggest that Thames Water secures additional funding from the Government, private firms and lottery to develop better system 2.3.100 - all the proposed sites require mitigation measures to limit the construction impacts to an acceptable minimum. In some cases there will be a long list of relatively expensive mitigation measures. Thames Water will need to determine whether these have any further impact on the cost of the project or whether they have been allowed for 2.3.101 - proceeding with the Thames Tunnel project is a miss-use of public funds

Thames Water is in discussions with Government and the economic regulator Ofwat on the appropriate delivery model for the Thames Tunnel project. A key consideration of the solution will be ensuring it is value for money and takes account of customer affordability. We also continue to engage with the Consumer Council for Water, which is an independent representative for customers, with regard to the impact upon customer affordability. The TTSS included 'willingness to pay' surveys. Thames Water continues to discuss with Government and the economic regulator Ofwat the appropriate delivery model for the Thames Tunnel project. The financing of the tunnel is an important issue which will include consideration of a wide range of financial sources and the potential for Government support. We have been assessing the likely significant effects that may arise as a result of the works as part of an environmental impact assessment. This will set out measures necessary to mitigate any significant adverse effects that are identified. An Environmental statement, which records the findings of the environmental impact assessment, will accompany our DCO application. Cost estimates include a significant risk element to allow for scenarios such as this.

We have considered a number of options to reduce the amount of untreated sewage that flows into the River Thames to the agreed timetable, including SuDS, separation of the sewerage system, bubblers and skimmers. However, none of these options were considered viable when compared with the benefits of building a tunnel with CSO interceptions. We therefore do not agree that this scheme represents a miss-use of public funds. The Government have made it clear that they are carefully monitoring cost. In the Ministerial Statement of 7 September 2010 a Thames Tunnel project continues to offer (by far) the lowest cost solution to the problem and I believe Thames Water should continue to press forward with this project working with Ofwat, the Environment Agency and DEFRA on the regulatory, commercial and planning processes. We with Ofwat will continue to ensure that the costs are scrutinised and reviewed so that I can be assured before Thames Water sign a construction contract that the final proposal represents proper value for money. Shareholders are kept briefed on the project.

2.3.102 - there is not effective accountability on the part of Thames Water regarding the cost of the project

2.3.103 - shareholders have yet to take notice of the dangers that exist in this project for

Supplementary report on phase two consultation

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2 The need, solution, tunnel route and alignment Ref Objections, issues and concerns their shareholder value Respondent ID No. Our response We are in discussions with Government and the economic regulator Ofwat on the appropriate delivery model for the Thames Tunnel project. A key consideration of the solution will be ensuring it is value for money and takes account of customer affordability. The Environment Agency identified the most polluting CSOs which cause unacceptable environmental impacts because of the frequency or volume of the overflow, or because they discharge into an environmentally sensitive part of the River Thames. The project will address the overflows from these CSOs, either by connecting them directly to the main tunnel, or by making other alterations to the sewerage system which will utilise the existing capacity more effectively. Since we began work on the project, we have managed to reduce the number of proposed construction sites. As part of phase two consultation we included information on three preferred sites from our phase one consultation which are no longer required, as we able to address the discharge from the CSO through in-sewer modifications. Information about the projected increases in customer bills associated with this project was contained in the annual bill. The annual bill is received by all our customers, both inside and outside of London. Information was also contained within the Funding project information paper, which was available at our exhibitions and on our website. At this stage in the project, we therefore consider that we have provided sufficient information on this matter. As the project progresses, we will continue to review how we communicate on bill increases with our customers. We are in discussions with Government and the economic regulator Ofwat on the appropriate delivery model for the Thames Tunnel project. Separate billing of costs may be one outcome of this process. We are in discussions with Government and the economic regulator Ofwat on the appropriate delivery model for the Thames Tunnel project. However, it is unlikely that this will include a cap on the bill impacts. Ultimately this is a matter for Government. The Water Industry (Financial Assistance) Bill provides for financial support for the customers of South West Water, but there is no indication that such support will be extended to the customers of Thames Water in the future. In the Ministerial Statement of 7 September 2010 a Thames Tunnel continues to offer (by far) the lowest cost solution to the problem and I believe Thames Water should continue to press forward with this project working with Ofwat, the Environment Agency and DEFRA on the regulatory, commercial and planning processes.We with Ofwat will continue to ensure that the costs are scrutinised and reviewed so

2.3.104 - respondents do not know who will eventually own the tunnel although they will have to pay for it 2.3.105 - the best way to reduce the 4.1 billion cost is to reduce the number of sites

2.3.106 - Thames Water has not adequately communicated the cost of the project to Londoners/more information needs to be provided on bill increases

2.3.107 - costs attributed to this scheme should be shown separately on water and sewerage bills to allow customers to see how these investments are impacting on what they pay 2.3.108 - there should be a cap which restricts the amount by which customers water bills will increase

2.3.109 - Thames Water argues that bills will only rise towards the national average, ignoring both the higher cost-of-living in London and the South East and the potential for bills to rise by more than forecast. The recent Ministerial

Supplementary report on phase two consultation

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2 The need, solution, tunnel route and alignment Ref Objections, issues and concerns Statement warned that: 'relatively small changes in the cost of capital for the project could have a significant impact on bills, which was not reflected in consultation documents. Respondent ID No. Our response that I can be assured before Thames Water sign a construction contract that the final proposal represents proper value for money. The Government still submit Thames Water to this scrutiny.

2.3.110 - Thames Water should use 75 per cent of the profit generated from this project to contribute to the local areas where the tunnel is constructed 2.3.111 - Thames Water should compensate all residents within 100 metres of worksites by waiving their water charges for the duration of work on these particular sites 2.3.112 - Thames Water does not have the necessary experience to undertake a project of this kind and therefore the Government should take over project 2.3.113 - query why potentially suitable sites for the Thames Tunnel project previously owned by Thames Water has been sold off 2.3.114 - climate models can only predict 60 years beyond the stated completion date, therefore it is not correct to claim a life expectancy of more than 100 years 2.3.115 Further information is required including: - clarification regarding whether this project will clean up the River Lee 2.3.116 - the existing levels of contamination and the damage and risks that arise from it should be provided in graphical form. This should be extrapolated for the next ten years. 2.3.117 - on the impacts of failing to undertake this massive improvement now and why this is the optimum solution 2.3.118 - how the new constructions be accommodated 2.3.119 - on the specific levels of water quality that will be improved and environmental risks that will be

The application will negotiate legal agreements similar to section 106 agreements using the normal approach to the mitigation of any adverse impacts. The main impact of the project will be a significant improvement to the River Thames. We recognise that our proposal may cause disruption and that in some cases compensation will be appropriate. Further details on this can be found in A guide to the Thames Tunnel compensation programme, which is available on our website. We will learn lessons from the construction of the Lee Tunnel, which is now underway. We have appointed CH2M Hill as project managers and they bring international experience of similar projects, which they will bring to the management of site works and budget. We received a formal request from the Government to proceed with the construction of a full-length storage tunnel in 2007. We are not aware that we have sold any potential sites since then. Indeed it has purchased more than one potential construction site. The design life is 120 years. It is correct to say that the climate models only extend to 2080 but that does not alter the fact that the Thames Tunnel project is designed to last 120 years.

The Lee Tunnel is a separate project, which will intercept two CSOs that discharge into the River Lee. Construction work for the Lee Tunnel has commenced. For further information on this project visit: http://www.thameswater.co.uk/cps/rde/xchg/corp/hs.xsl/10113.htm More information on existing ground conditions will be provided in the Environmental Statement submitted with our DCO application.

Table 4.2 of the Needs report sets out the predicted level of spills at 2021 if the Lee Tunnel and sewage treatment works upgrades are complete but the Thames Tunnel project has not been built. The consultation material illustrates how the new constructions might be accommodated on the sites. More information on water quality will be in the Environment statement submitted with our DCO application.

Supplementary report on phase two consultation

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2 The need, solution, tunnel route and alignment Ref Objections, issues and concerns reduced Respondent ID No. Our response A Strategic environmental assessment (SEA) is required at the plan/programme level, not the project level. In this instance the plan/programme is the Waste Water National Policy Statement which was designated on 26 March 2012 and is accompanied by an Appraisal of Sustainability that incorporates an SEA. We are therefore satisfied that an SEA has been carried out by the appropriate body. We estimate that the tunnel would directly employ about 4,250 people in construction and related sectors, as well as providing further secondary employment estimated at a further 5100 indirect jobs. We actively support the Crossrail Tunnelling and Underground Construction Academy, which is currently training and gaining employment for 70 apprentices a year. Following the Crossrail model, we will specify in our contracts the number of apprenticeships that will be required by the contractors. The level of fines that may be imposed is not linked to the economic climate. It would be based on a published formula that has regard to the seriousness and duration of the breach, as well as the size of the country involved. Fines are calculated using equations that consider the duration and seriousness of the infringement and the individual Member States capacity to pay. The maximum daily penalty payment that could currently be imposed on the UK is 620,000 per day. The minimum size of a lump sum payment that could currently be imposed on the UK is 8,500,000 and there is no maximum lump sum payment. All UK tax payers may have to help foot the bill. We are upgrading Mogden Sewage Treatment Works to increase its treatment capacity by around 50 per cent. This will significantly reduce both the quantity and the number of times we need to discharge storm sewage from the sewage treatment works into the River Thames following heavy rain. Our records show that over the last 13 years, Mogden Sewage Treatment Works has needed to discharge in to the River Thames on just over 1,000 days. Many of those discharges were very small, with the total amounting to 77.7 million tonnes of storm sewage, acknowledging that all storm discharges were subject to some screening and settlement. This represents around five per cent of the total flow arriving at the sewage treatment works. If the current improvements we are making had been in place, and assuming the same weather patterns were experienced, we estimate that the sewage works would only have discharged in to the River Thames on a total of five occasions during those 13 years, following exceptional amounts of rainfall with discharges totalling around 3.3 million tonnes. In the future, we would expect flows reaching the sewage treatment works to overflow into the River Thames approximately once every two and a half years. Improvements to the sewage treatment works will mean that even where there are

2.3.120 - why a strategic environmental assessment (SEA) has not been undertaken

2.3.121 - the employment and wider economic benefits Within the UK we do not have an appropriately skilled work force to undertake construction.

2.3.122 - the allusion to "heavy fines being imposed on the UK government" for non-compliance appears to overstate both the scale of any potential penalties to the UK and the remote probability of their being applied in the current fiscal environment

2.3.123 - it is not clear that works at Modgen Sewage Treatment Works will be sufficient. Query whether the Thames Tunnel project should be extended to Mogden Sewage Treatment Works.

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2 The need, solution, tunnel route and alignment Ref Objections, issues and concerns Respondent ID No. Our response discharges, the most polluting flows will have been captured for treatment.

Alternative solutions
Table 2.3.5 Alternative solutions Ref 2.3.124 Alternative solutions comments Query whether other solutions may be available given that the original study was undertaken in 2001. Respondent ID 9092LO, 11022, 11275, 11331, 11740, 11790, 11873, 12116, 12719, 12965, 13006, 13010, 13093, 13141, 13148, 13181, 13229, 13234, 7012, 7194, 7212, 7216, 7233, 7343, 7429, 7499, 7539, 7557, 7691, 7698, 7741, 7934, 8300, 8890, 9007, 9395, 9467, 9475, 9486, LR9112 No. 40 Our response The Thames Tideway Strategic Study (TTSS) group was established in 2000 although it did not report until 2005 and additional work was carried out in 2006 leading to the Ministerial Statement in 2007. We have been working on refinement of the tunnel options, for example the alterative tunnel route now proposed. Refer to the Needs report for further details. The Government has recently published a report entitled Creating a River Thames fit for our future: A strategic and economic case for the Thames Tunnel. This report provides an update to the 2007 regulatory impact assessment and takes into account data that has emerged since that time. The report contains an appraisal of alternative solutions and concludes that a tunnel solution remains the most appropriate. Appendix B of the Needs report is an independent report by Exeter University that examines the approaches to the UWWTD in relation to combined CSOs in major cities across the EU. The most common approach to resolving CSO issues was identified to be the addition of extra sewer capacity. Large storage tunnels in conjunction with one or several other storm water control techniques such as Real Time Control have been built or are planned by several cities. Real Time Control is not possible in London as a solution in its own right because of a lack of capacity. The use of a fleet of bubblers and skimmers has been dismissed because it would not ensure compliance with the UWWTD as it would not limit the flows to the River Thames. We have therefore concluded that it is not a long-term viable solution. Nevertheless, skimmers may continue to be used to remove flotsam and jetsam, which accumulates in the river from various sources (other than combined sewer overflows). The River Thames is very different to Cardiff Bay. Cardiff Bay is an enclosed area of still water, while the River Thames is a fast flowing tidal river. The solution used at Cardiff Bay is therefore not suitable. We have investigated the feasibility of separating the sewerage system into two systems: one for foul sewage and another for storm sewage. This was considered as one alternative by the TTSS and more recently reported in the Needs report (appendix D). Separating the combined system would involve building a second pipe and making sure that all connections from buildings and roads are connected into the correct system. Construction of a separated system, even in certain limited locations,

2.3.125 2.3.126

Query how other cities have addressed this 12458, 12981, 13075, 7934, 7968, 8413, problem. 8654, 8680, 9089 Solutions used in other cities should be explored including in Germany (North Rhine-Westphalia and Berlin), Chicago, Oregon, Philadelphia, New York and Milwaukee. LBHF, 9110LO, 11038, 11580, 11640, 11727, 12661, 12981, 13065, 13188, 13364, 7105, 7117, 7121, 7134, 7170, 7192, 7212, 7215, 7271, 7371, 7513, 7564, 7626, 7637, 7671, 7756, 7824, 7932, 7934, 8095, 8225, 8404, 8497, 8640, 8684, 8856, 8926, 8943, 9007, 9361, 9377, 9460, 9467, LR9418 7460LO, 9092LO, 9093LO, 9417LO, 9481LO, 7261, 7338, 7844, 8653, 8725, 8751, 9353,

9 45

2.3.127

Would prefer bubblers and skimmers, in particular looking at the 'bubbling' solution installed at Cardiff Bay.

12

2.3.128

Would prefer separate sewage and storm water systems. We recognise that although the overall cost is more expensive, given the costs to local populations of undertaking the Thames Tunnel project and that separating sewers provides the best long-term solution separating sewers would not be more expensive.

GLA, 9110LO, 11012, 11960, 13002, 13093, 13118, 13214, 13232, 7010, 7121, 7156, 7228, 7261, 7301, 7338, 7434, 7451, 7518, 7527, 7743, 7756, 7865, 7967, 8028, 8190, 8291, 8646, 8725, 8742, 8774, 8886, LR9398

33

Supplementary report on phase two consultation

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2 The need, solution, tunnel route and alignment Ref Alternative solutions comments The Mayor of London is open to the view that separation of sewers may be appropriate in certain locations as opportunities arise and this will help to reduce the amount of surface water entering the combined sewer system. Respondent ID No. Our response would be extremely disruptive throughout London and would entail digging deep trenches in most streets. Such construction would take a considerable time to complete. In addition, because of the need to gravity flow the sewage there would be a need for substantial pumping stations to either lift foul sewage to the interception sewers or to pump storm sewage to the river, which would have a considerable energy requirement. Separating the combined system would also have a net increase in pollutant loadings to the River Thames as polluted street drainage in particular would be discharged into the river rather than captured by the tunnel system. Estimates showed that the construction cost alone would be excess of 12billion. We do not therefore consider this to be a viable option. Separation of the sewerage system is an option for future developments as opportunities arise, but this will not address current problems. We have investigated the feasibility of applying sustainable urban drainage systems as an option to controlling CSO discharges. This was considered as one alternative by the TTSS and more recently reported in the Needs report (appendix E). The Needs report reaffirmed the original TTSS conclusion that SuDS is not a practical and cost-effective CSO control solution because: - SuDS will not achieve compliance with the UWWTD as it only partially addresses the number and volume of discharges and would therefore not meet environmental requirement - SuDS may be technically feasible in some areas, however, there are significant logistical, legal and regulatory impediments to its utilisation - we could only implement SuDS in limited areas because of the lack of open spaces in the highly developed areas that generate the most rainfall-runoff which results in CSO discharges - for large areas to be made available at the required scale to reduce CSO discharges, the construction cost alone would be in excess of 14billion - the disruption to streets and parks would be extensive - parking spaces would be lost and sections of open areas in parks would be used for ponding water - a high level of property-owner involvement would be required to realise some of the flow reduction. We therefore concluded that SuDS is not cost-effective compared with a less expensive solution that fully meets the need to address wastewater discharges from CSOs. However, we recognise that as part of a longterm solution, SuDS provide a valuable tool to reduce surface water entering into the sewer system. We will continue to work with the Greater London Authority and local authorities to promote the use of SuDS with new developments and the application of SuDS as part of the solution of local flooding. This is not an alternative to CSO control.

2.3.129

Would prefer SuDS/green infrastructure because they are more environmentally friendly, more cost-effective than the Thames Tunnel project and would tackle two risks related to rainwater (floods and drought) which the project cannot address. The Mayor of London also recognises that while technically this could be achieved it would take many years and significant financial incentives and new legislative requirements to be implemented. Notwithstanding, increasing the permeability of Londons urban fabric will, over time, reduce the volume of rainwater entering the combined sewer system. This will help to reduce the volumes that are discharged to the Thames Tunnel project and give it a buffer against one of the projected effects of climate change which is to see more intense rainstorms.

GLA, 8887LO, 9107LO, 9147LO, 9417LO, 9481LO, 13397LO, 11038, 11110, 11253, 11305, 11332, 11531, 11684, 11727, 11910, 12015, 12049, 12069, 12075, 12114, 12346, 12507, 12705, 12711, 12747, 12869, 13002, 13193, 13229, 13231, 7105, 7112, 7155, 7157, 7222, 7233, 7250, 7265, 7338, 7343, 7371, 7385, 7402, 7423, 7476, 7502, 7547, 7669, 7760, 7833, 7844, 7949, 7967, 7969, 8028, 8083, 8091, 8095, 8139, 8206, 8213, 8285, 8497, 8559, 8652, 8653, 8716, 8727, 8776, 8861, 8944, 8964, 9068, 9069, 9075, 9385, 9467, 9488, LR13383, LR9277

81

2.3.130

Would prefer another alternative solution. Suggestions included:-

13397LO, 7460LO, 8560LO, 8803LO, 8807LO, 9083LO, 9084LO, 9085LO,

158

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2 The need, solution, tunnel route and alignment Ref Alternative solutions comments - lobby for less development and spend money on educating planners
- undertake further and better maintenance

of the existing sewerage system


- Counters Creek Flood Alleviation

investigations
- integrate with the London Ring Main

Water Tunnels to facilitate west to east bulk water transfer will alleviate dry summers and general water shortages in the dry east
- increase the diameter of the Jubilee Line

Extension tunnels
- hold a design competition - pump sewage out of the sewerage

system more quickly at the point at which it is treated


- use Thames Barrier to improve the

flushing of the river to enable a less demanding treatment standard

Respondent ID 9086LO, 9092LO, 9147LO, 9254LO, 9417LO, 9481LO, 10155, 10156, 11017, 11080, 11247, 11371, 11548, 11589, 11710, 11715, 11750, 11784, 11829, 11961, 11982, 11994, 12011, 12050, 12489, 12539, 12569, 12607, 12671, 12743, 12983, 13019, 13042, 13043, 13078, 13093, 13159, 13183, 13197, 7006, 7015, 7029, 7036, 7121, 7125, 7127, 7140, 7157, 7172, 7194, 7216, 7231, 7238, 7321, 7351, 7366, 7402, 7413, 7423, 7449, 7468, 7489, 7490, 7496, 7510, 7527, 7544, 7558, 7591, 7605, 7620, 7621, 7629, 7633, 7637, 7685, 7692, 7698, 7756, 7767, 7786, 7919, 7932, 7934, 7948, 7949, 7973, 8041, 8086, 8106, 8142, 8151, 8194, 8234, 8284, 8285, 8401, 8407, 8413, 8456, 8459, 8557, 8558, 8565, 8575, 8614, 8624, 8643, 8646, 8649, 8653, 8662, 8668, 8673, 8683, 8722, 8725, 8737, 8738, 8743, 8753, 8764, 8774, 8779, 8786, 8831, 8838, 8861, 8909, 8953, 9007, 9149, 9161, 9191, 9283, 9296, 9346, 9357, 9384, 9446, 9467, 9487, 9488, 9496, 9497, LR9278, LR9279, LR9398, LR9459, LR13432

No.

Our response

The first part of the overall London Tideway Improvements involves capacity expansion at Beckton and Crossness Sewage Treatment works, therefore we are pumping more sewage out of the system and maximising flow to treatment. This would not provide any CSO control: CSO discharges would continue. The net seaward flow in the River Thames is low compared to its size, particularly in the summer months; therefore it can several weeks for any pollution to be flushed out of the river. Operation of the barrier would further hinder this seaward movement and therefore cannot be utilised to enable a less demanding treatment standard. Any works needed to build and operate the Thames Tunnel project would be at specific sites that we identify through our site selection process. A programme of undefined lower cost projects (presumed to include SuDS measures and system modifications) would not be an alternative to CSO control since they would not provide the same level of CSO control, would not be deliverable in the required timeframe, would be far more disruptive throughout urban London, and would ultimately be significantly more expensive. Although products for oil absorption exist we are not aware of such products for sewage. The micro-organisms that naturally occur in the river eventually break down the sewage, but at the expense of using oxygen and thus causing its depletion. This is why sewage is collected and then treated, mainly by biological processes at sewage treatment works. Sewage treatment works use processes of sedimentation and biological treatment to treat sewage to meet required pollutant discharge limits. Discharge volumes are too large to consider this type of arrangement; barges at each location would need to be enormous to provide the require storage and treatment facilities. The size of the facilities would

- lower cost projects implemented

incrementally would remove the need for works at specific sites

- use a product that naturally breaks down

sewage in water

- put a barge mounted system at the CSO

discharge points, so that the sewage can be treated in situ and then collected

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2 The need, solution, tunnel route and alignment Ref Alternative solutions comments Respondent ID No. Our response block the river which would increase flooding risk and impact the uses of the river. This is not a viable CSO control alternative. Four smaller pipes would not be sufficient to control CSOs. Up to 18, 2m diameter pipes would be required with large pumping stations at approximately 1km intervals to move the water through the pipes. The smaller the pipe, the higher the head and therefore the larger the pumping stations. The energy consumption would be substantial (Hammersmith CSO alone would require the energy equivalence as 5,000 households every year). Blockages and maintenance would be problematic and combined with disturbance of river bed sediments and other challenging construction issues, this suggestion is not viable. It is not possible to adequately treat the large and intermittent CSO flows without significant storage, which the tunnel provides, so that the intercepted flows can be pumped out at a consistent rate to treatment. The plant required for debris removal (screening) sedimentation etc at the peak flows would be huge (several times greater than Beckton Sewage Treatment Works itself). With the current sewage treatment works extension at Beckton, there will be sufficient capacity to treat the tunnel pump out. The existing sewer system adequately delivers the combined sewage generated to the river. A major replacement of Londons major sewer system (eg capacity expansion of the interceptor sewers) would be substantially more expensive and disruptive than the Thames Tunnel project. The Thames Tunnel project is the most cost-effective extension to Londons sewer system. There is insufficient clearance from existing tunnels in many locations (for example, some tube tunnels are very shallow under the river) and such works would raise issues regarding stability of bridges and other structures; these issues alone would exclude this approach. To construct the tunnel using this approach, a sectional sheet piled cofferdam would have to be constructed along the entire length of the river bed to facilitate construction of a river bed tunnel to protect the works from the high tidal range and to contain the width of dredging. This would impact on virtually the full width of the River Thames. This would cause major adverse effects impacts to river navigation, flood risk and the ecology of the River Thames. The existing sewage treatment works are being expanded and this expansion is an integral part of the overall London Tideway Improvement Programme. The capacity expansion, existing sewer system and tunnels have been optimised to make maximum use of the expanded works and existing sewer system while limiting the size of the tunnels. Aeration systems are only considered as a mitigation measure: they do not control CSO discharges. Such systems would only provide limited benefits in increasing dissolved oxygen locally. The tidal Thames has a large tidal range and this would result in exposure of bed mounted

- use four smaller diameter plastic pipes

that would sit on the river bed and have inlet arrangements at different points along the river

- adapting the design of the sub-river

sections of the tunnel so that in-line treatment (debris removal, sedimentation, digestion, oxidation and filtration) could be carried out

- extend the existing sewage system

- dredge a channel and lay the tunnel in

the river. This would be less disruptive and more cost-effective although it would require additional tunnelling where existing tunnels cross the river.

- increase the capacity of existing sewage

treatment works

- install permanently located re-aeration

systems

Supplementary report on phase two consultation

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2 The need, solution, tunnel route and alignment Ref Alternative solutions comments Respondent ID No. Our response aeration systems and means that for a large part of the tidal cycle there would be insufficient water depth for oxygen transfer. Such systems when they have been applied need to use oxygen (not air) and therefore plant would be required on-shore to produce or store oxygen (in tanks). These types of systems would not achieve any benefits to health or remove sewage solids and litter and therefore would not address the need to reduce overflows in the River Thames. The existing sewerage system has limited spare capacity to use Real Time Control for limiting CSO discharges. However the expansion of the works will capture more of the first flush. Where storage in the existing sewers is available, this has been used to limit the size of the tunnels and where work is needed. Oxygen injection is not a complete treatment process as it can only supplement the oxygen dissolved in the discharge. This would result in the river providing the settlement and treatment processes. Deep shaft treatment would have similar or larger shaft areas to capture CSO volumes and therefore would impose similar construction and operational impact. Return of the treated sewage would be limited because of the available capacity in the existing sewers with a general concern of long emptying time and high risk of odour nuisance. Handling of solids, settled in the shaft, would require surface facilities to lift such materials out of the shaft and to store and transport away for disposal most likely to landfill sites. CSO discharges are a result of rainfall runoff not dry weather flow. The potential reduction in dry weather flow (from domestic devices) would not free up sufficient capacity as storm flows (which generate CSO discharges) are an order of magnitude higher than that of dry weather flow. These options have been investigated and none provide a viable alternative solution except for the Thames Tunnel project which is in fact a cost-effective storage tank under the river. Finding suitable locations for new localised sewage works in urban London would be extremely difficult. As storm flows are large, sewage treatment processes, in particular the biological processes, cannot adequately deal with such rapid flow. More significantly the rate of flow occurring at CSOs would require very large areas for such treatment works. The SuDS approach has been investigated in detail; refer to the Needs report (appendix E). SuDS would impact much of London and cannot deliver sufficient surface water runoff removal to reduce CSO discharges to acceptable levels. Also, SuDS cannot be implemented within the required timeframe, would be very disruptive to streets and properties, and would be 3-4 times more costly than the Thames Tunnel project. Smaller local tunnels would not provide sufficient attenuation of storm flow to adequately reduce CSO discharges. Smaller diameter tunnels are also less cost-effective as the cost per unit volume is greater than

- use Real Time Control and sensing to

retain the damaging first flush and subsequent clearance of solids, and allow diluted storm volumes into the River Thames
- treat sewage before it is discharged

through the CSOs by oxygen injection or deep shaft treatment using the shafts proposed as part of the Thames Tunnel project

- introduce supply water saving devices en

masse

- localised systems should be used

including storage tanks under the river in the worst affected areas, use of SuDS, smaller local tunnels, with screening or localised sewerage treatment works

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2 The need, solution, tunnel route and alignment Ref Alternative solutions comments
- implement a tunnel but not the currently

Respondent ID

No.

Our response large diameter tunnels. This option has been investigated in detail. A tunnel which picks up a small number of the most polluting CSOs does not deliver required objectives as the discharges from the remaining unsatisfactory CSOs are not controlled. It does not achieve the environmental objectives set out in the TTSS and compliance with the UWWTD would not be secured The Thames Tunnel does pick up the most polluting CSOs, which have been categorised as such by the Environment Agency. We have considered numerous tunnel routes (see TTSS materials and Phase 1 consultation) and our suggested preferred route, the Abbey Mills route, delivers a cost-effective balance between acceptable CSO control, tunnel size, tunnelling risk and limiting disruption This option has been investigated in detail and does not deliver the required objectives as it does not control the discharges from 17 unsatisfactory CSOs (including two large CSOs at Greenwich and Deptford). It does not achieve the environmental objectives set out in the TTSS and compliance with the UWWT would not be secured. This is reported in Tackling Londons Sewer Overflows. Fine screening at CSOs was investigated by TTSS. Huge plant is required to deal with peak flows which will require large areas of land at or adjacent to the CSO outfalls. These large screening plant installations would inflict local impacts associated with the handling and removing of screened materials and require control of nuisance odours. As screening plant inevitably imposes a head loss on the flow pumping plant would be required, at most locations, to address the potential increase in upstream flood risk. Screens can also block which would increase flood risk. With ultrafiltration pumping plant would have to be used to overcome the head losses through the screens and to lower flooding and other risks. This is not an alternative to CSO control as there is no treatment of the sewage. Pollutants that depress oxygen in the river would continue to discharge and therefore the ecology of the river would continue to be impacted. In general we support the use of SuDS measures where they can be effectively implemented. We agree that SuDS through appropriate legislation and funding mechanisms can form part of a long-term strategy to help reduce surface run-off. However, SuDS for urban London would take many decades to implement and cannot deliver sufficient rainfall-runoff reduction to control CSO discharges in a costeffective manner. The SuDS approach has been investigated in detail; refer to the Needs report (appendix E). Streets are a major contributor to rainfall- runoff and CSO discharges. However, we have investigated separation of streets and other impervious areas and found separation be to significantly more expensive and disruptive than the Thames Tunnel project (see Needs report, appendix D). Early aerobic treatment is an undefined and

designed solution; suggestions include a longer tunnel or one that only picks up the most polluting CSOs

- construct two shorter tunnels in east and

west London

- Screen excess flows followed by

ultrafiltration as a pre-discharge process

- introduce new legislation making it

compulsory for new dwellings to have a system to store rain water, which will be used for flushing toilets, cleaning cars, watering gardens, etc. For existing houses, use a water butt to save rain water from being lost to the sewer
- should work with highway authority to

separate the storm water runoff so that roads, underground tunnels and existing infrastructure could be used to recreate local 'brooks' to carry storm water

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2 The need, solution, tunnel route and alignment Ref Alternative solutions comments
- undertake early separation of rain water,

Respondent ID

No.

foul and grey water and early aerobic treatment regeneration; joined-up Thames Estuary virtuous development
- campaign to encourage people to use

Our response unknown process and therefore cannot be considered a viable treatment process for CSO discharges.

less water, to recycle water and to discharge rainwater from roofs and paved areas into soak-aways in gardens

This is part of an on-going and long-term strategy, but is not an alternative to todays need for CSO control. Water use reduction would have limited impact on CSO volumes as CSO discharges are driven by rainfall. Roof and paved areas runoff controls have been investigated under SuDS (see Needs report, appendix E)and were found to be inadequate in controlling CSOs to an acceptable level, would be very disruptive in urban London, would take up a lot of space, would take a long-time to implement and would cost 3-4 times more than the Thames Tunnel project. This is an on-going process which is standard procedure at sewage treatment works. We are capturing about 96 per cent of the CSO volume currently discharging to the river and by maximising the use of the expanded treatment works we will create more bio fuel benefits. Work at Mogden is part of the overall London Tideway Improvement Programme. However, this work does not control the CSO discharges to the tidal Thames that will be captured by the Thames Tunnel project. In general we support the use of SuDS measures where they can be effectively implemented. We agree that SuDS through appropriate legislation and funding mechanisms can form part of a long-term strategy to help reduce surface run-off. However, SuDS for urban London cannot deliver sufficient rainfall-runoff reduction to control CSO discharges within the required timeframe and in a cost-effective manner. The SuDS approach has been investigated in detail; refer to the Needs report (appendix E). It is unlikely that a suitable site (or sites) could be located within London for a new suitably sized reservoir. Treating street runoff to an acceptable and safe level for re-use would require a significant water treatment plant which would also be difficult to locate.

- use sewage as a biofuel

- undertake works at Mogden Sewage

Treatment Works
- provide a subsidised rainwater harvesting

scheme for every development


- take a more integrated and

multifunctional ecosystem approach to the management of water and wastewater


- construct a sustainable urban reservoir

where rain water is harvested from the streets in order to be separated and reused. The additional cost to separate the waste from grey water in environmental resource and human terms is considered appropriate in the light of future population needs Site specific solutions were also suggested: - intercept the North East Storm Relief offshore, in the middle of the River Thames
- intercept the Frogmore Storm Relief

An offshore interception would require much more disruption of the river and would not remove the need to use a portion of King Edward Memorial Park as the North East Storm Relief ends at the outfall in the river wall. This is not a viable alternative since it is not possible to intercept the Frogmore Storm Relief Buckhold Road CSO without some surface works to get underground. We have identified in our consultation material, including the Chambers Wharf site information paper, that we need sites to build the main tunnel

Buckhold Road underground; do not drill a hole from over ground


- the solution should avoid undertaking

works in Bermondsey

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2 The need, solution, tunnel route and alignment Ref Alternative solutions comments Respondent ID No. Our response at locations where the type of geology that the tunnel will go through changes. At this location the geology will change from clays, sands and gravels to chalk. To meet health and safety requirements to construct the tunnel with a considered and acceptable low risk of major tunnel failure, we consider it necessary to use different tunnelling machines for the different geology conditions. In addition we will need to connect the three existing local CSOs, at Earl Pumping Station, Deptford Church Street and Greenwich Pumping Station, to the main tunnel so the discharges can be conveyed to Beckton Sewage Treatment Works for treatment. In addition to using sites to intercept the CSOs we also need sites to construct the main tunnel to transfer the sewage to Beckton Sewage Treatment Works for treatment instead of discharging directly into the tidal Thames. Preventing the current regular discharges into the river will therefore have benefits not just for those areas closest to CSOs but for other riverside communities such as the area around Chambers Wharf. While there is not a CSO that needs to be intercepted at this site, Southwark does have a CSO at the Shad Thames Pumping Station approximately 400m to the west of Chambers Wharf. We are proposing to manage this CSO by utilising the existing sewer system in this area and modifying the pumping station: thereby avoiding additional shaft sites and tunnel work in the Bermondsey area. Control of the Shad Thames PS CSO by our proposed method would not be possible if we did not intercept the other CSOs to the east of Southwark, particularly Earl Pumping Station on the Lewisham/Southwark border. The CSO discharges from Greenwich Pumping Station, the Deptford Storm Relief and Earl Pumping Station all need to be intercepted. The CSO discharge at Greenwich is the second largest to the tidal Thames. A connection tunnel is required to convey flow to the main tunnel for transfer to treatment. This would not reduce the need for a works to intercept the West Putney CSO but would lead to increased disruption associated with the construction of the transfer pipeline (or tunnel) between West Putney Storm Relief CSO and Putney Bridge CSO and increase the impact at Putney Bridge as the shaft would be need to be larger and control works more extensive to receive the two flows from different directions. This would lead to a larger area impact, to provide the storage needed to control the West Putney CSO Suitable sites would continue to be in the playing fields or in the commons. Such a storage/retention tank would require access for cleaning operations (similar to Acton Storm Tanks). Active ventilation and odour control together with pump-out plant would be required.

- construct the tunnel without a spur from

Chambers Wharf to Greenwich Pumping Station

- divert the West Putney Storm Relief

waters back under Beverly Brook to the Putney Embankment area and intercept the flows at the Putney Embankment Foreshore site
- undertake near surface temporary

storage/detention of excess flows below ground at the West Putney Storm Relief CSO using Real Time Control for return to the existing system following a deluge
- at West Putney Storm Relief CSO,

construct near surface temporary storage/detention of excess flows below ground


- address discharges from Greenwich

These discharges would still need to be collected and transferred (via a

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2 The need, solution, tunnel route and alignment Ref Alternative solutions comments Pumping Station CSO, Deptford Storm Relief and Earl Pumping Station CSO through a local treatment facility. Respondent ID No. Our response tunnel) to any new treatment facility. Such a facility would require a large land area, would need solids handling and disposal facilities and active odour treatment to avoid nuisance odours. Treating the large (but intermittent) flow rates is highly problematic for biological sewage treatment works processes as they require continuous and relatively consistent flow to maintain viability. As storm flows can be over ten times local dry weather flow the biological process would be overwhelmed by such an increase flow and would cease to provide treatment. A combination of measures including the tunnel would by definition be more expensive than the tunnel alone and hence not cost-effective. A combination of measures not including the tunnel, such as SuDS and sewer separation, will not address the drivers for the project and will fail to deliver a solution given the urgent need. Analysis has been undertaken since 2000, to investigate and assess strategic alternatives to addressing the problem of CSO discharges into the tidal Thames. The needs case for the Thames Tunnel project is set out in detail in the Needs Report, which is available on our website. It is also summarised in an easy to read and non-technical form in our publications Why does London need the Thames Tunnel? dated July 2011. The need for the project has been confirmed and reaffirmed both by the past and present Government. This was made clear in written Ministerial statements to Parliament in September 2010 and again in November 2011. Further reinforcement of the need for the project is contained in the documents published by DEFRA in November 2011 Creating a River Thames fit for our future - a strategic and economic case for the Thames Tunnel and Costs and benefits of the Thames Tunnel. The National Policy Statement for Waste Water, which was designated on 26 March 2012, summarises the significant amount of work undertaken to assess alternative options and clearly states that the need for the project has been demonstrated. It concludes that detailed investigations have confirmed the case for a Thames Tunnel as the preferred solution (paragraph 2.6.33). The designation of the NPS was supported by an Appraisal of sustainability post-adoption statement dated March 2012 which contains further detail on the significant amount of work undertaken to establish the need for the Thames Tunnel project and assess alternative options. The report concludes that a tunnel solution remains the most appropriate and cost-effective of the solutions considered. As a result, the Government confirmed that the detailed studies undertaken have and continue to demonstrate the case for the Thames Tunnel project. We have considered a number of options to reduce the amount of untreated sewage that flows into the River Thames given the urgent need, including SuDS, separation of the sewerage system, bubblers and skimmers. However, none of these options were considered viable when compared with the benefits of building a tunnel with CSO interceptions.

2.3.131

Would prefer a range of measures. Suggestions included: - construct additional flood storage capacity and facilities to deal with water stress - implement the tunnel and SuDS - implement SuDS and a reduced capacity tunnel - implement the tunnel for the ten most polluting CSOs and localise solutions for other CSOs - create a separate sewage system and undertake a comprehensive rebuild of Londons entire infrastructure: sewage, water, power and communications - implement green infrastructure, Lee Tunnel, upgrades to sewage treatment works and a larger fleet of skimmers and bubblers - find a longer term mixed solution that manages the water cycle as a whole, from source control or SuDS to separation, storage and enhancement of the existing sewerage network and sewage treatment works; rain harvesting; grey infrastructure filtration and storage solutions - implement SuDS, water metres and education initiatives.

LBHF, 7996LO, 8887LO, 11884, 7198, 7233, 7347, 7429, 7518, 7528, 7583, 7677, 7695, 8651, 8692, 8831, 9098, 9303, 9445, LR9418

20

2.3.132 2.3.133

The tunnel is not the only solution; there are other viable options. The tunnel should capture more of the outflows.

11303, 12099 9487

2 1

Supplementary report on phase two consultation

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2 The need, solution, tunnel route and alignment Ref 2.3.134 Alternative solutions comments Should adopt a shorter tunnel in combination with: - green infrastructure - less expensive alternatives to control overflows - SuDs, bubblers and skimmers and separate sewers - SuDs and bubblers and skimmers Respondent ID LBHF, 8410LO, 8571LO, 8632LO, 11037, 11427, 12053, 12698, 12813, 12814, 12981, 7156, 7361, 7408, 7429, 7461, 7479, 7493, 7741, 7756, 7767, 8497, 8673, 9349, LR13498, LR9117, LR9418, LR9459 No. 28 Our response This type of option (a combination of short tunnel with Green Infrastructure and/or SuDS) has been investigated in detail. It does not achieve the environmental objectives set out in the TTSS and compliance with the UWWTD would not be secured. In particular retrofitting SuDS within the densely built up areas of London would not reduce CSO discharges sufficiently and would be more expensive and disruptive to construct. Because of the magnitude of the CSO problem, no less expensive (even if less effective) options to control CSO discharges have been found. All other options, which approach achieving the required objectives, are more expensive than the storage and transfer tunnel solution and in all cases impose greater impact and disruption of the community and cannot be implemented in the timeframe required. Bubblers and skimmers are interim mitigation options and do not provide a long-term solution to CSO discharges. This type of option (a combination of western tunnel, local treatment and remedial in-river measures) has been investigated. A western tunnel would not provide any control of 17 other unsatisfactory CSOs and would be more costly per volume of CSO control achieved, if the same as the current proposal would not provide the same level of control as the full-length tunnel. To achieve the same level of control for the western CSOs it would need to be larger. Not intercepting the remaining 17 CSOs (including Greenwich and Deptford) does not achieve the environmental objectives set out in the TTSS and compliance with the UWWTD would not be secured. Use of bubblers is a mitigation method for low dissolved oxygen and they do not control CSO discharges which would continue under this suggestion. Localised treatment would require a large land area and entail significant construction and operational impacts. The large area required for a new sewage treatment works is not available. 7460LO, 8562LO, 8887LO, 11010, 11191, 11192, 11193, 11194, 11195, 11196, 11197, 11198, 11199, 11200, 11201, 11202, 11203, 11204, 11205, 11206, 11207, 11208, 11209, 11210, 11211, 11212, 11213, 11214, 11215, 11216, 11217, 11218, 11219, 11220, 11221, 11222, 11228, 11234, 11659, 11837, 11956, 12161, 12163, 12663, 12664, 12707, 12728, 12792, 12979, 12986, 12988, 12989, 12992, 13000, 13005, 13007, 13025, 13028, 13031, 13032, 13034, 13035, 13036, 13037, 13039, 13056, 13063, 13081, 13082, 13083, 13084, 13103, 13109, 13111, 13144, 13145, 13146, 13160, 13179, 13180, 13184, 13195, 13198, 13200, 13201, 125 As part of the TTSS work, the Environment Agency assessed the CSOs, categorised them and identified those that we need to intercept. A shorter tunnel would not enable us to intercept the identified CSOs and would not have enough volume to capture a sufficient proportion of the discharges. A shorter tunnel may cost less, but it will not meet the environmental objectives that have been set.

Other proposals included a shorter tunnel covering the western CSOs along with localised treatment; two most polluting CSOs in the east London (Greenwich and Deptford) that could be dealt with by bubblers.

2.3.135

Would prefer a shorter tunnel.

Reasons for this included: - it would be 20 per cent of the cost and achieve 95 per cent or higher reduction in sewage discharges
- it would avoid the need to undertake

construction works in central London


- it is an adequate solution which would be

cheaper and affect fewer people


- it would save large amounts of concrete

As set out above, a shorter tunnel would not enable us to intercept all the identified CSOs, and therefore it would not be possible to avoid undertaking construction works in central London or to implement a scheme which would potentially give rise to fewer effects. As set out above, a shorter tunnel would not meet the environmental objectives that have been set and therefore this benefit would not be

being poured which contributes to climate

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2 The need, solution, tunnel route and alignment Ref Alternative solutions comments change Respondent ID 13224, 13230, 7003, 7050, 7155, 7197, 7222, 7236, 7261, 7314, 7315, 7321, 7435, 7446, 7490, 7523, 7532, 7551, 7637, 7663, 7709, 7791, 7833, 7949, 8095, 8226, 8234, 8456, 8541, 8557, 8662, 8680, 8725, 8774, 8953, 9193, 9353, 9357, LR13472, LR9118, LR9279 No. Our response realised. We are exploring options to reduce embedded carbon contained within concrete through practical yet cost-effective specification of materials. This specification is subject to on-going consideration, and will take account of emissions. This must be balanced against the durability of the materials, ensuring the long-term benefits of the project will be achieved, and construction and life-cycle costs. Further details will be contained within the Energy statement submitted with our DCO application. The Environment Agency has identified the most polluting CSOs, which cause unsatisfactory environmental impacts because of the frequency or volume of the overflow, or because they discharge into an environmentally sensitive part of the tidal Thames. The Needs report identifies the West Putney Storm Relief CSO as falling within the category of CSOs which most urgently need to be addressed. Table 4.2 of the Needs report provides further details. Monitoring data from 1 October 2010 to 30 September 2011 also confirms that this CSO continues to overflow with 31 separate discharges identified within this period. Bacteria data collected in 2011 also indicates high levels of e.coli and the presence of human waste in the discharge confirming the health risks from discharges from West Putney. Discharges from the West Putney Storm Relief CSO therefore do need to be collected by the tunnel. The Lee Tunnel is a project required to address discharges from the Abbey Mills Pumping Station CSO into the Channelsea River, which are separate to the 34 CSOs identified for control or interception as part of the Thames Tunnel project. The Greenwich connection tunnel collects flow from three sites (Earl Pumping Station, Deptford Church Street and Greenwich Pumping Station) and has a high capacity. Other options for delivering these flows to the main tunnel have been considered but rejected because they result in hydraulic instability/unacceptable performance; require additional large diameter shafts; and/or would still not eliminate the need for a shaft near the change in ground geology near Chambers Wharf. Other alignments of the connection tunnel using different sites to collect flows from CSOs have been rejected following a multidisciplinary review that concluded that the preferred alignment was the most favourable. Refer to response in paragraph 2.3.94 for further details. 8565, 9296, LR9278 3 The Needs report recognises that the installation of water meters and other water conservation measures, will not be effective as a solution to the problem of CSO discharges, since it will not reduce foul sewage flows to a sufficient extent to counteract the impacts of population growth. In addition, as little as 2mm of rainfall can result in a discharge into the River Thames. The installation of water metres would not address rainfall which flows into the combined sewage system. Analysis has been undertaken since 2000, to investigate and assess

- it would concentrate on the major outfalls

and ignore the less polluting CSOs including West Putney Storm Relief

- with the Lee Tunnel reducing discharges,

a scaled down tunnel is appropriate

- it would avoid the spur from Chambers

Wharf to Greenwich Pumping Station, where the Earl Pumping Station could be addressed without the tunnel

- it would avoid the need for a site in

Southwark. 2.3.136 Need water meters/ incentives to economise water use.

2.3.137

Should find a cheaper/more cost-effective

8562LO, 8887LO, 8949LO, 9108LO,

93

Supplementary report on phase two consultation

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2 The need, solution, tunnel route and alignment Ref Alternative solutions comments alternative solution, particularly given rise in projected costs of the project. Respondent ID 9392LO, 11012, 11016, 11391, 11746, 11797, 11879, 11900, 11920, 12005, 12026, 12056, 12060, 12068, 12078, 12160, 12263, 12267, 12406, 12413, 12525, 12766, 12771, 12804, 13043, 13047, 13051, 13098, 13119, 13147, 13206, 13224, 13364, 7012, 7037, 7104, 7125, 7127, 7140, 7165, 7172, 7187, 7218, 7221, 7245, 7338, 7350, 7361, 7384, 7391, 7427, 7428, 7461, 7464, 7483, 7485, 7568, 7580, 7638, 7669, 7697, 7741, 7756, 7789, 7793, 7833, 7870, 7900, 7931, 7968, 8117, 8300, 8459, 8473, 8614, 8668, 8738, 8749, 8753, 8849, 8884, 8923, 8943, 8953, 9015, 9055, 9082, 9160, 9399 No. Our response strategic alternatives to addressing the problem of CSO discharges into the tidal Thames. The National Policy Statement for Waste Water, which was designated on 26 March 2012, summarises the significant amount of work undertaken to assess alternative options and clearly states that the need for the project has been demonstrated. It concludes that detailed investigations have confirmed the case for a Thames Tunnel as the preferred solution (paragraph 2.6.33). The designation of the NPS was supported by an Appraisal of sustainability post-adoption statement dated March 2012 which contains further detail on the significant amount of work undertaken to establish the need for the Thames Tunnel project and assess alternative options. The report concludes that a tunnel solution remains the most appropriate and costeffective of the solutions considered. It is not possible to specify precisely the amount of money spent on exploring green alternatives not least because the term is not well defined. This issue will be considered more fully in our response to the Selbourne Commission. The alternatives, such as SuDS and sewer separation will have a much greater effects than the Thames Tunnel project.

2.3.138

Should find a more environmentally friendly 8887LO, 9105LO, 11570, 11607, 11651, solution. 11896, 11909, 11983, 12056, 12078, 12124, 12406, 13051, 13166, 13206, 13364, 7003, 7012, 7140, 7187, 7194, 7232, 7305, 7461, 7697, 7789, 7793, 7824, 7865, 7870, 7932, 8125, 8219, 8281, 8300, 8452, 8488, 8519, 8643, 8728, 8738, 8749, 8825, 8953, 9082, 9166, 9366, LR9112, LR9341 Should choose an alternative that has less effect on local communities. 8321LO, 8569LO, 8796LO, 8887LO, 8949LO, 11556, 11610, 11797, 11850, 11879, 11896, 11900, 11920, 12056, 12060, 12068, 12267, 12820, 13098, 13147, 13183, 13364, 13395, 7012, 7125, 7218, 7221, 7338, 7350, 7361, 7391, 7417, 7421, 7427, 7428, 7483, 7485, 7568, 7621, 7638, 7669, 7789, 7833, 7900, 7932, 8117, 8300, 8459, 8566, 8690, 8738, 8753, 8923, 8943, 9135, LR9112 8560LO, 8887LO, 9092LO, 9105LO, LR9272LO, 11016, 11017, 11027, 11038, 11043, 11045, 11046, 11182, 11277, 11332, 11402, 11404, 11405, 11433, 11448, 11499, 11543, 11662, 11663, 11673, 11708, 11748, 11798, 11818, 11821, 11839, 11873, 11950, 12049, 12096, 12107, 12266, 12267, 12269, 12373, 12525, 12574, 12670, 12694, 12697, 12705, 12748, 12768, 12784, 12831, 12869, 12917, 12918, 12953,

49

2.3.139

56

2.3.140

The alternatives have not been properly tested. Significantly less money has been invested in exploring available green alternatives which have proven successful elsewhere.

137

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2 The need, solution, tunnel route and alignment Ref Alternative solutions comments Respondent ID 12957, 12959, 12971, 12975, 13002, 13010, 13020, 13021, 13047, 13059, 13064, 13066, 13071, 13103, 13114, 13123, 13125, 13137, 13141, 13156, 13181, 13197, 13204, 13215, 13221, 13222, 13231, 7170, 7181, 7215, 7261, 7271, 7364, 7396, 7427, 7428, 7429, 7434, 7476, 7483, 7485, 7502, 7512, 7569, 7618, 7675, 7692, 7695, 7761, 7916, 7922, 7932, 7949, 8007, 8091, 8096, 8125, 8234, 8300, 8402, 8423, 8472, 8668, 8753, 8755, 8782, 8804, 8861, 8890, 8891, 8923, 8926, 8944, 9098, 9197, 9283, 9303, 9361, 9395, 9467, 9475, 9488, LR13441, LR9112 See annex B of this report No. Our response

2.3.141

Other options should be considered and investigated. In particular, the Mayor of London encourages both Thames Water and others to continue to consider alternatives, especially if they have the potential to reduce costs and disruption. Alternative solution which has a shorter construction period. Need more information about proposed solutions and alternatives.

2,145

2.3.142 2.3.143

7037 13399LO, 13400LO, 13494LO, 9093LO, 9131LO, 11050, 11057, 11296, 11323, 11403, 11413, 11518, 11702, 11752, 11820, 11823, 11952, 12024, 12091, 12094, 12097, 12252, 12326, 12377, 12397, 12508, 12692, 12703, 12717, 12749, 12753, 12761, 12774, 12790, 12795, 12796, 12805, 12818, 12843, 12888, 12966, 12970, 13107, 13114, 13122, 13131, 13142, 13203, 7036, 7159, 7180, 7216, 7218, 7250, 7293, 7338, 7626, 7627, 7754, 7767, 7811, 7915, 7940, 8004, 8148, 8149, 8153, 8162, 8164, 8165, 8166, 8167, 8168, 8169, 8173, 8174, 8235, 8413, 8518, 8524, 8566, 8584, 8592, 8593, 8594, 8596, 8597, 8599, 8601, 8603, 8605, 8607, 8616, 8620, 8654, 8680, 8684, 8695, 8696, 8699, 8700, 8701, 8709, 8710, 8737, 8800, 8860, 9005, 9006, 9033, 9056, 9057, 9058, 9060, 9239, 9240, 9253, 9354, 9357, 9364, 9487 (LR)CCW, 13495LO, 7260LO, 8410LO, 8562LO, 8807LO, 8887LO, 9083LO,

1 121 We consider that we have undertaken a thorough and comprehensive consultation exercise. As part of this, we carefully considered the information we made available at our phase two consultation to ensure that consultees had sufficient information to respond to the consultation. Details on the alternative solutions considered are described and illustrated throughout the phase two consultation material. The Options project information paper provides an overview and detail is provided in the Needs report. We are confident therefore that the information we have provided is sufficient.

2.3.144

Other independent research indicates there are other appropriate solutions,

239

As set out in the Needs report, and supported by the November 2011 Ministerial Statement, a tunnel is the preferred and most cost-effective

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2 The need, solution, tunnel route and alignment Ref Alternative solutions comments which are cheaper and less disruptive. Respondent ID 9084LO, 9085LO, 9086LO, 9093LO, 9107LO, 9109LO, 9129, 9147LO, 9417LO, 9481LO, LR9271LO, 11011, 11027, 11030, 11087, 11184, 11267, 11303, 11404, 11543, 11560, 11587, 11625, 11657, 11688, 11691, 11708, 11726, 11772, 11781, 11792, 11818, 11873, 11878, 11914, 11953, 11976, 11977, 12044, 12057, 12058, 12085, 12103, 12105, 12113, 12131, 12137, 12157, 12171, 12198, 12238, 12404, 12428, 12540, 12636, 12670, 12680, 12685, 12699, 12700, 12725, 12757, 12837, 12873, 12917, 12918, 12939, 12965, 13011, 13019, 13058, 13059, 13066, 13074, 13079, 13091, 13099, 13141, 13143, 13191, 13193, 13229, 13234, 13238, 13240, 13484, 7003, 7012, 7023, 7118, 7125, 7127, 7140, 7165, 7166, 7177, 7183, 7192, 7193, 7196, 7201, 7208, 7209, 7220, 7226, 7233, 7235, 7244, 7245, 7276, 7321, 7352, 7353, 7363, 7366, 7387, 7395, 7424, 7430, 7432, 7461, 7465, 7475, 7490, 7496, 7499, 7512, 7523, 7527, 7529, 7549, 7551, 7568, 7572, 7599, 7613, 7663, 7671, 7675, 7691, 7695, 7701, 7705, 7709, 7728, 7734, 7741, 7820, 7843, 7847, 7877, 7917, 7935, 7949, 7977, 7995, 8015, 8041, 8085, 8094, 8104, 8125, 8186, 8192, 8194, 8234, 8300, 8404, 8456, 8486, 8492, 8497, 8498, 8567, 8614, 8624, 8629, 8648, 8662, 8673, 8682, 8684, 8743, 8782, 8793, 8838, 8856, 8861, 8890, 8903, 8926, 8953, 9007, 9055, 9068, 9069, 9074, 9082, 9098, 9101, 9149, 9193, 9197, 9198, 9203, 9262, 9283, 9296, 9303, 9347, 9353, 9357, 9381, 9383, 9395, 9445, 9467, 9475, 9476, 9486, 9487, 9488, 9496, 9497, LR13383, LR13446, LR13498, LR9112, LR9117, LR9277, LR9315 No. Our response way to address sewage entering the River Thames. The National Policy Statement for Waste Water, which was designated on 26 March 2012, summarises the significant amount of work undertaken to assess alternative options and clearly states that the need for the project has been demonstrated. It concludes that detailed investigations have confirmed the case for a Thames Tunnel as the preferred solution (paragraph 2.6.33). The designation of the NPS was supported by an Appraisal of sustainability Post-Adoption Statement dated March 2012 which contains further detail on the significant amount of work undertaken to establish the need for the Thames Tunnel project and assess alternative options. The report concludes that a tunnel solution remains the most appropriate and cost-effective of the solutions considered. We consider that the report from the Selbourne Commission does not begin to suggest any alternative to the Thames Tunnel project which would meet the objectives sets by the Environment Agency for the health of the river, within time scale set by the Government. There are no costings associated with the findings of the report and the principal recommended action is to undertake further studies. Our full response to the Selbourne Commission can be found on our website. The Terms of Reference of the Selbourne Commission as supplied by the London Borough of Hammersmith & Fulham state that the commission should 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. In our view, reassessing the options would include looking at alternatives and this is what the Commission did. In relation to Professor Binnie's suggestion, we understand that he has since changed his view. On 6 March 2012 he stated in Parliament in a meeting organised by Simon Hughes MP that subject to some caveats he supported the single tunnel solution.

Specific research cited included: - the Selbourne Commission sets out other equally good, far less expensive, greener and less disruptive solutions including a shorter tunnel combined with green infrastructure, which would be compliant with EU directives. The scope of the Selbourne Commission was not to find alternatives but to undertake a more fundamental review and therefore the conclusions should not be ignored. The proposals also avoid the disruption of sites in central London and call into question the UK Government's interpretation of EU standards.
- implement Professor Binnies preference

for two short tunnels. He also calls for a staged approach, initially constructing a western tunnel, and then re-examining local measures, including upgrades to sewage treatment works and green infrastructure. Need to recognise the importance of change of view; Professor Binnie is not saying the solution meets UWWTD requirements but is challenging whether the tunnel is cost excessive or disproportionate.
- Professor Binnie's new submission

entitled Costs and benefits analysis


- the Jacobs Babtie solution, which

In relation to Professor Binnie's recent submission, a full response to this can be found on our website. With regard to the Jacobs Babtie Review, this is not considered to be a viable alternative to the full-length tunnel. As set out in the Options project information paper, a shorter tunnel would not have enough

complies with the requirements of the UWWTD and can provide lesser but still

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2 The need, solution, tunnel route and alignment Ref Alternative solutions comments significant benefits at a much lower cost Respondent ID No. Our response capacity to capture a sufficient proportion of the discharges. This would lead to increased odour and septicity problems in the vicinity of the interception sites as the existing sewerage system does not have much additional capacity, which means the sewage would be stored for longer periods before it is treated. The Jacobs Babtie Report has consistently been rejected by the Government, from the Regulatory Impact Assessment in 2007 to the National Policy Statement Post -Adoption Statement in 2012. When the Final National Policy Statement (NPS) was published it was accompanied by a report setting out how the Government responded to the concerns of the Efra committee. The Chair of the Committee accepted that appropriate changes had been made in the Commons debate on the NPS on 19 March 2012. 8801LO, 11187, 11504, 11772, 11863, 13024, 7933, 8649, 8673, 8791, 8849, 8890, 8953, 9166, 9353, 9395, 9475, LR8975, LR9112, LR9315 20 A wide range of stakeholders have been involved in investigating and assessing options to address the problem of CSO discharges into the tidal Thames, over many years. The Thames Tideway Strategic Study (TTSS) included inputs from the Department for Environment, Food and Rural Affairs, Thames Water, the Environment Agency, the Greater London Authority, Defra and Ofwat (as an observer). Ofwat commissioned its own report (Jacobs Babtie report) to review the work and reports of the TTSS. The National Policy Statement for Waste Water, appraisal of sustainability post-adoption statement dated March 2012 contains further detail on the significant amount of work undertaken to establish the need for the Thames Tunnel project and assess alternative options, so we consider there would be no benefit in undertaking further reviews of options. We liaise regularly with all these bodies.

- the Efra report published by the

Environment Food and Rural Affairs Select Committee of the House of Commons on 5 April 2011. 2.3.145 An independent review of options should be undertaken.

2.3.146

Suggestions included: - involve Defra, the Greater London Authority, the London Boroughs, the Environment Agency, the Consumer Council for Water, Ofwat and Thames Water as well as independent experts
- take the experience and knowledge of

2.3.147

The project team includes a number of international experts.

international organisations such as the United Nations and the European Commission , alongside appropriate representatives from the UK 2.3.148
- publicly report to government, the Greater

London Authority and London Councils before Thames Water draws up its final plans or submits a DCO application. 2.3.149 Other comments in relation to alternative solutions included: - as part of the upgrade works to the sewage treatment plants, Thames Water GLA, LBR, LBHF, 8569LO, 8843LO, 11023, 11753, 12972, 13089, 13093, 13148, 13149, 7434, 7591, 7937, 8229, 9282, 9488, LR9398, LR9418 20

The GLA are an important stakeholder and have been fully involved in our pre-application discussions, in accordance with the Planning Act 2008 and relevant guidance. Construction work is already well underway on the sewage treatment works upgrades, which have been designed to deliver the required effluent quality and environmental enhancement at the lowest whole life cost, including energy.

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2 The need, solution, tunnel route and alignment Ref Alternative solutions comments should consider an environmentally friendly sewage treatment plant
- it is a shame that it is not practical or

Respondent ID

No.

Our response

cost-effective to implement SuDS


- a wide ranging cost-benefit study should

Your comment is noted. This is reflected in the Defra publication The Economic Case for the Thames Tunnel of November 2011. We are pleased to support the introduction of SuDs approaches where they are appropriate and cost-effective. Unfortunately, based on a detailed study, our assessment is that they cannot deliver the required benefit in a reasonable timescale.

be undertaken to investigate the potential multifunctional value and feasibility of retrofitting mainly green source control measures as an alternative to connecting certain overflows to the tunnel
- a Greater London Authority water

commissioner should be appointed to oversee a London Water Plan - The Mayor of London finds the Thames Tunnel Commissions proposal for a shorter tunnel between Acton Storm Tanks and Kirtling Street to be implemented on its own unsatisfactory. Not only would this proposal fail to address the CSOs in central and east London, but it would suffer from a considerable problem in disposing of or treating the captured combined sewage due to a lack of capacity in sewers running through central London to the main sewage treatment works in east London. The Mayor of London would be concerned that if such a proposal were implemented, it would be a relatively short period of time - perhaps ten to 20 years - before the tunnel would need to be extended to connect to the Lee Tunnel. In such circumstances, the increased disruption and further lack of suitable sites can be expected to increase costs even further. - another alternative means that would allow the tunnel to be built without needing the Chambers Wharf site

We would be interested in exploring any proposal for a water commissioner with the Greater London Authority. The Mayor of London's conclusions regarding the viability of a shorter tunnel agree with the conclusions of our work.

We consider a tunnel to be the most appropriate solution. In relation to the use of Chambers Wharf, the Greenwich connection tunnel would collect flow from three sites and have a high capacity. Other options for delivering these flows to the main tunnel have been considered but rejected because they result in hydraulic instability/unacceptable performance; require additional large diameter shafts; and/or would still not eliminate the need for a shaft near the change in ground geology near Chambers Wharf. Other alignments of the connection tunnel using

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2 The need, solution, tunnel route and alignment Ref Alternative solutions comments Respondent ID No. Our response different sites to collect flows from CSOs have been rejected following a multidisciplinary review that concluded that the preferred alignment was the most favourable. We continue to believe that a tunnel represents the best solution and welcome support for the strategic importance of reducing discharges into the River Thames.

- it is right to keep alternative methods of

achieving reduction in sewage under review; the Council continues to believe that a project to deliver improvements to the quality of the tidal River Thames is of national and local strategic and environmental importance Thames Water cannot expect a third party to provide better options as they do not have the resources to do so. Thames Water should come up with a less controversial option.

The current proposal is the result of more than ten years of study and evaluation. We would be very pleased if a less contentious solution could be found but we do not believe that one exists. While we have a preferred project, the purpose of consultation is to explore as fully as possible what those with an interest in the project think about our preference. As set out our phase two consultation material, we consider a tunnel to be the most appropriate and suitable solution.

2.4
2.4.1

Tunnel route
During the phase two consultation, respondents were invited to comment on the preference for the tunnel to follow the Abbey Mills route (see question 11 of the phase two consultation feedback form, provided in appendix M to the Main report on phase two consultation). Table 2.4.1 sets out details of the different groups who responded to confirm whether they had comments or not. Tables 2.4.2 - 2.4.5 then detail the feedback comments received in relation to our preference for the tunnel to follow the Abbey Mills route. It should be noted, that not all respondents who provided feedback comments confirmed whether they had comments or not. Table 2.4.1 Number of respondents commenting on our preference for the Abbey Mills route (Q11) Respondent type Number of respondents Comments Statutory consultees 2 - English Heritage (EH) - Orange Telecom (OT) Local authorities 2 - London Borough of Ealing (LBE) - London Borough of Hammersmith and Fulham (LBHF) Landowners Community consultees Petitions 27 237 0 34 680 0 72 4,922 9 0 15 No comments 0 No response 19

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2 The need, solution, tunnel route and alignment

Total

241

714

5,037

Supportive and neutral feedback comments


Table 2.4.2 Supportive and neutral feedback comments in relation to the preference for the Abbey Mills route Ref 2.4.2 Supportive and neutral comments General supportive. Respondent ID PLA, 7025, 7101, 7159, 7237, 7288, 7404, 7410, 7444, 7457, 7488, 7574, 7777, 7902, 7905, 7938, 8220, 8310, 8316, 8407, 8578, 8875, 8894, 9079, LR9114, LR9275, LR9447 8565 No. 27 Our response Your comments are noted.

2.4.3

Support for the long connection tunnel connecting Greenwich Pumping Station, Deptford Church Street and Earl Pumping Station to the main tunnel at Chambers Wharf. Support extension of the main tunnel to Acton Storm Tanks. The longer construction period and larger construction area would not have a more significant impact on the local area. Other supportive comments included: - it avoids the telecom switch facility - respondents welcome proposals relating to Shad Thames Pumping Station/Druid Street and Greenwich Pumping Station that eliminate the need for CSO connection tunnels to be constructed from the Southwark area - it includes the ability to utilise the Lee Tunnel - it has the least impact on the historic environment The Abbey Mills route is the most practical route. The Abbey Mills route is the most costeffective route. The Abbey Mills route is the least disruptive route. Reasons included: that it avoids the World Heritage Site in Greenwich and does not affect Sir John McDougal Gardens (which the River Thames route would do). The Abbey Mills route requires the fewest

2.4.4

(LR)LBE

2.4.5

EH, OT, 9063, 9067, LR9315

2.4.6 2.4.7 2.4.8

8632LO, 8310, 8462, 8628, 8675, 8725, 8741 GLA, 7463, 7683, 7825, 7988, LR9121, LR9315 7245, 7683, LR9121

7 7 3

Your comments are noted. This is the conclusion of our assessment.

2.4.9

7683, LR9315

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2 The need, solution, tunnel route and alignment Ref 2.4.10 2.4.11 Supportive and neutral comments work sites. The Abbey Mills route is the shortest route that captures the relevant CSOs. Not qualified to comment on this technical matter. No comment. Respondent ID GLA TH, 8410LO, 7170, 7228, 7475, 7702, 8209, 8313, 8653, 9063, 9067, LR13498 No. 1 12 Our response Agreed. While we have a preferred project, the purpose of consultation is to explore as fully as possible what those with an interest in the project think about our preference.

Qualified support
Table 2.4.3 Supportive (qualified) feedback comments in relation to the Abbey Mills route Ref 2.4.12 Qualified support comments The route should minimise the effects of construction and disruption. Respondent ID 7006, 7277, 7420, 8653, LR9280 No. 5 Our response As set out in the Route and tunnel alignment project information paper, the Abbey Mills route remains our preferred route because: it is the shortest route; it is the least disruptive and most cost-effective option, while still meeting all the required environmental objectives; it requires the least number of worksites. We will undertake our construction work in accordance with our Code of construction practice (CoCP), a draft of which was published as part our material for phase two consultation. The CoCP will include measures to minimise the effects of construction including for example noise and vibration control measures at each site that the contractor will be required to implement. We are also assessing the likely significant effects that may arise as a result of the works as part of an environmental impact assessment. This will set out measures necessary to mitigate any significant adverse effects that are identified. An Environmental statement, which records the findings of the environmental impact assessment, will accompany our DCO application. The initial environmental assessment work that has been carried out on the project is contained within the PEIR, which is available on our website. As part of the phase two consultation, we also sought feedback on the potential effects arising from our proposals and how the effects will be mitigated. Where possible, we will take feedback comments into account as we develop our proposals. The sites that we consulted on at phase two consultation have been identified through an extensive site selection process (see our Site selection methodology paper on our website). We consulted and agreed the methodology prior to its use with key stakeholders including potentially directly affected local authorities and utilised a multidisciplinary approach to assess potential CSO sites and main tunnel sites, and main tunnel/connection tunnel drive options, against engineering, planning, environmental, property and community considerations. Whether a site is brownfield or greenfield/open space was taken into account along with other considerations as set out in the Site selection methodology paper. However, given that we had a limited search area to identify suitable CSO and main tunnel sites, we did not consider it was

2.4.13

Agree with Abbey Mills route but should prioritise brownfield sites.

7146, 8202

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2 The need, solution, tunnel route and alignment Ref Qualified support comments Respondent ID No. Our response appropriate to exclude sites based on whether they were brownfield or greenfield/open space when compiling our long-list of sites. The sites that we consulted on at phase two consultation have been identified through an extensive site selection process (see our Site selection methodology paper on our website). We consulted and agreed the methodology prior to its use with key stakeholders including potentially directly affected local authorities and utilised a multidisciplinary approach to assess potential CSO sites and main tunnel/connection tunnel drive options against engineering, planning, environmental, property and community considerations. We recognise that, given the locations where we are seeking to construct and operate the tunnel, many of the shortlisted sites are constrained in some way. However, based on our assessment we consider that on balance our choices are the most suitable. For further details on the results of the site selection process, refer to the Phase two scheme development report. The Abbey Mills route would collect slightly less sewage than the other two routes although it still meets all the required environmental objectives. The spills from the Charlton CSO which could have been picked up by the two other routes, but will instead be addressed as part of the improvement works to the Crossness Sewage Treatment Works. For further information refer to the Route and alignment project information paper and Project overview. Whether a site is brownfield or greenfield/open space was taken into account along with other considerations as set out in the Site selection methodology paper. However, given that we had a limited search area to identify suitable CSO and main tunnel sites, we did not consider it was appropriate to exclude sites based on whether they were brownfield or greenfield/open space when compiling our long-list of sites. In relation to use of foreshore of the River Thames, a CSO needs to be intercepted along the line of the existing sewer that flows into the River Thames. CSO sites need to be as close to the line of the sewer as practicable so there are few options and requires a more localised approach. In order to intercept some of the CSOs, sites in the foreshore proved to be the only suitable location. Where we are proposing to use public open space or undertake works which may affect access to the riverside, we have been assessing the likely significant effects that may arise as a result of the works as part of an environmental impact assessment. This will set out measures necessary to mitigate any significant adverse effects that are identified. An Environmental statement, which records the findings of the environmental impact assessment, will accompany our DCO application. The initial environmental assessment work that has been carried out on the project is contained within the PEIR, which is available on our website. As part of the phase two consultation, we also sought feedback on the potential effects arising from our proposals and how the effects will be mitigated. Where possible, we will take feedback comments into

2.4.14

Agree with Abbey Mills route but do not agree with preferred sites.

9254LO, 7370, 7720, 7723, 7743, 7775, 7894, 8749, 8753

2.4.15

Qualified support for the Abbey Mills route, subject to: - the capacity to capture sewage is the same as a shorter tunnel

8556LO, 8801LO, 7855, 8041, 8501, 9139, 9347

- the tunnel being be built without

degrading public open space or reducing river access permanently or for a significant period of time
- brownfield sites should be prioritised if

Thames Water progresses with the Abbey Mills route

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2 The need, solution, tunnel route and alignment Ref Qualified support comments
- a route following the River Thames more

Respondent ID

No.

Our response account as we develop our proposals. We have considered three tunnel routes; our preferred the route, the Abbey Mills route, the River Thames route and Rotherhithe route. As set out in the Route and tunnel alignment project information paper and Project overview, one of the reasons that the Abbey Mills route remains our preferred route is that it is the least disruptive when compared to the other two routes that we considered. Other reasons for our selection include that it is the shortest and most cost-effective option, costing 20 per cent less compared to the other two options (including when the cost of Chambers Wharf is taken into account) while still meeting all the required environmental objectives, including reduction of overflow discharges. It also requires the least number of worksites and requires less tunnelling at depth through chalk in the east. The Site selection background technical paper sets out our preference for the horizontal alignment of the main tunnel to follow the River Thames. This document also sets out the cases in which we would need to deviate from the River Thames. We have followed these principles when developing our tunnel route/alignment. Following phase one consultation we considered the comments received along with feedback from on-going engagement and new information, and undertook further technical work. As part of this work, we reviewed the drive strategy for this section of the main tunnel. As a result of the review, we concluded that Abbey Mills Pumping Station was less suitable than Chambers Wharf as a main tunnel drive site. The reasons for this are set out in appendix R of the Phase two scheme development report. The current proposal is the refinement of five years of development of the tunnel option, and the route reflects the constraints of connecting the unsatisfactory CSOs at least cost and also minimising the potential for surface disruption by following largely the river alignment. This route we believe to be broadly optimised but the aim of consultation is to establish the detailed location and availability of the construction and shaft sites that will be necessary. We can confirm that our consultants consider the Abbey Mills route to be the most suitable.

closely may have been better but the Abbey Mills route is acceptable

- construction of the tunnel from Abbey

Mills Pumping Station not Chambers Wharf

- an independent review

- if this is the first choice of consultants

then the public should respect their knowledge of what is required.

Objections, issues and concerns


Table 2.4.4 Objections, issues and concerns in relation to the preference for the Abbey Mills route Ref 2.4.16 Objections, issues and concerns Respondent ID No. Our response As set out in the Route and tunnel alignment project information paper, the Abbey Mills route remains our preferred route because: it is the shortest route; it is the least disruptive and most cost-effective option, costing 20 per cent less compared to the other two options, while still

Do not agree that Abbey Mills is the correct 8562LO, 9083LO, 9107LO, LR9271LO, 24 route. 13214, 7187, 7301, 7336, 7804, 7846, 8299, 8402, 8488, 8504, 8680, 8734, 8779, 8861, Reasons for this included: 8890, 9137, 9193, 9475, 9488, LR9136 - the route will result in disruption for

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2 The need, solution, tunnel route and alignment Ref Objections, issues and concerns nearby communities and businesses
- Thames Water has chosen the route

Respondent ID

No.

which is simplest and most profitable

Our response meeting all the required environmental objectives; it requires the least number of worksites; and it requires less tunnelling at depth through chalk in the east. Deep tunnelling through chalk is potentially more difficult and would bring greater health and safety issues. Our preference for the Abbey Mills route is therefore based on our technical assessment of the suitability of the different routes and has not been chosen because it is the simplest or most profitable. This route will also result in the least disruption to nearby communities and businesses. The Greenwich connection tunnel would collect flow from three sites and has a high capacity. Other options for delivering these flows to the main tunnel have been considered but rejected because they result in hydraulic instability/unacceptable performance; require additional large diameter shafts; and/or would still not eliminate the need for a shaft near the change in ground geology near Chambers Wharf. Other alignments of the connection tunnel using different sites to collect flows from CSOs have been rejected following a multidisciplinary review that concluded that the preferred alignment was the most favourable. For further details refer to section 6.8 of the Phase two scheme development report.

- it requires 20 per cent of sewage flows

from Greenwich to be re-routed back via Chambers Wharf instead of going directly to Beckton Sewage Treatment Works; this requires the tunnel to needlessly go underneath residential housing, which is not cost-effective, reduces the capacity of the tunnel, requires the tunnel to be constructed in an area with no CSOs and moves the route away from the River Thames, which is contrary to the principles set out by Thames Water in relation to selection of the route.
- the choice of route is not sufficiently

evidenced
- the tunnel would capture less discharge

and has less scope for mitigation than other two routes, while having a large cost and energy requirement.

Further information on our assessment of the three tunnel routes can be found in the Project overview. The Abbey Mills route does capture slightly less discharge than the other two routes however, as set out above, this tunnel route still meets the objectives set. Our assessment of the three routes has concluded that the Abbey Mills route has the least potential for environment effects. We have been assessing the likely significant effects that may arise as a result of the works as part of an environmental impact assessment. This will set out measures necessary to mitigate any significant adverse effects that are identified. An Environmental statement, which records the findings of the environmental impact assessment, will accompany our DCO application. The initial environmental assessment work that has been carried out on the project is contained within the PEIR, which is available on our website. As part of the phase two consultation, we also sought feedback on the potential effects arising from our proposals and how the effects will be mitigated. Where possible, we will take feedback comments into account as we develop our proposals. Regarding cost, of the three route options considered, the Abbey Mills route costs the least. In relation to the comment that the Abbey Mills route would have a large energy requirement, a comprehensive energy assessment is being undertaken for the project which considers the whole life cycle of carbon embedded in the project. The conclusions of the energy assessment will be reported in our Energy statement, submitted with our DCO application. Our energy assessment is being used to identify how engineering decisions can influence carbon embedded in the project, allowing us to minimise these emissions where possible and practical.

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2 The need, solution, tunnel route and alignment Ref 2.4.17 2.4.18 Objections, issues and concerns Unsure whether it is the right route Do not agree with the Abbey Mills route if the preferred sites are used. Respondent ID 7045, 8226 8304LO, 7527, 7838, 8751 No. 2 4 Our response Refer to paragraph 2.4.16 for our response to this feedback comment. In relation to our proposed sites, the sites that we consulted on at phase two consultation have been identified through an extensive site selection process (see our Site selection methodology paper on our website). We consulted and agreed the methodology prior to its use with key stakeholders including potentially directly affected local authorities and utilised a multidisciplinary approach to assess potential CSO sites and main tunnel sites, and main tunnel/connection tunnel drive options, against engineering, planning, environmental, property and community considerations. We recognise that, given the locations where we are seeking to construct and operate the tunnel, many of the shortlisted sites are constrained. However, based on our assessment we consider that, on balance, our preferred sites are the most suitable. For further details on the results of the site selection process including our assessment of shortlisted sites, refer to the Phase two scheme development report. We consider that we have undertaken a thorough and comprehensive consultation exercise. As part of this, we carefully considered the information we made available at our phase two consultation to ensure that consultees had sufficient information to respond to the consultation. Our preferred route is described and illustrated throughout the phase two consultation material including the Route and tunnel alignment project information paper, which provides an overview with more detail in the Book of plans and Project overview. We are confident therefore that the information we have provided is sufficient. With regard to feedback received at phase one consultation, these are contained in our Report on phase one consultation, which is available on our website. The Greenwich connection tunnel would collect flows from three CSOs: Earl Pumping Station CSO, Deptford Storm Relief CSO, and Greenwich Pumping Station CSO, which need to be controlled to enable compliance with the UWWTD. We have considered other options to the Greenwich connection tunnel for delivering the flows from these CSOs to the main tunnel but these have been rejected because they result in hydraulic instability/unacceptable performance; require additional large diameter shafts; and/or would still not eliminate the need for a shaft near the change in ground geology near Chambers Wharf. Other alignments of the connection tunnel using different sites to collect flows from CSOs have been rejected following a multidisciplinary review that concluded that the preferred alignment was most suitable. A 6m protection zone is to be provided around the tunnels as a buffer against future developments. 7749, 7865, 8402, 8716, 9137 5 Cost has not been the only factor considered when deciding which of the

2.4.19

Need further information on the route including:


- the reasons for the selection of the tunnel

(LR)RM, 7372, 7693, 7767, 7811, 7876, 8109, 8235, 8295, 8528, 9098

11

route; it is not sufficiently evidenced

- the details of the feedback received

during phase one consultation


- the reasons for the Greenwich connection

tunnel

- the details of any exclusion zones which

may be proposed in terms of below ground works. 2.4.20 Cost should not be the only determining

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2 The need, solution, tunnel route and alignment Ref Objections, issues and concerns factor. The risks of building one of the longest and deepest tunnels in London have not been properly assessed. Respondent ID No. Our response three routes is most appropriate. The assessment took into account engineering, environmental, property, planning and community considerations. As part of the design development process, we continue to assess the risks of undertaking the proposed works and modifying the design to ensure that any risks can be appropriately managed. Refer to paragraph 2.4.12 for our response to this feedback comment. We have carefully considered potential routes and selected our preferred route for a number of reasons: it is the shortest route; it is the least disruptive and most cost-effective option, costing 20 per cent less compared to the other two options, while still meeting all the required environmental objectives; it requires the least number of worksites; and it requires less tunnelling at depth through chalk in the east. Deep tunnelling through chalk is potentially more difficult and would bring greater health and safety issues. A number of variations to the Abbey Mills route have been considered as described in the Engineering options report. The local alignment of the tunnel along the Abbey Mills route has been optimised to balance a range of factors including the environmental effect of the main tunnel. We have been assessing the likely significant effects that may arise as a result of the works as part of an environmental impact assessment. This will set out measures necessary to mitigate any significant adverse effects that are identified. An Environmental statement, which records the findings of the environmental impact assessment, will accompany our DCO application. Intrusion under private land has been minimised as far as possible but in some places other constraints such as other buildings with deep foundations and the tightness of bends in the main tunnel that can physically be constructed make this impossible to avoid.

2.4.21 2.4.22

Concerned about disruption arising from the construction of this tunnel route. Suggested modifications to the Abbey Mills route included: - variations to Abbey Mills route should always be considered if they improve the environmental impact of the tunnel

7420 8410LO, 8571LO, 8632LO, 9083LO, 9084LO, 9085LO, 9086LO, 9092LO, 9093LO, 9107LO, 9147LO, 9254LO, LR9271LO, LR9272LO, 7370, 7477, 7496, 7695, 7761, 7767, 7804, 7917, 8076, 8218, 8234, 8407, 8432, 8456, 8538, 8557, 8646, 8649, 8673, 8849, 8890, 8953, 9063, 9067, 9091, 9098, 9149, 9161, 9353, 9357, 9395, 9475, 9488, 9496, 9497, LR13473, LR13498, LR8975, LR9315, LR9341

1 54

- the extension to Acton Storm Tanks

should follow the route of the old sewer which runs under the allotments on the piece of land between Abinger Road and Emlyn Road and not encroach under the private gardens of houses in either street
- the Greenwich long connection tunnel

should be driven from Greenwich Pumping Station or Deptford (Convoys Wharf) to Limehouse, which would avoid using Chambers Wharf. Thames Water has already suggested several sites in Limehouse including Ropemakers Field and King Edward Memorial Park, both of which could be used to connect the long connection tunnel to the main tunnel. Other suggested sites included Bekesbourne Street and Russia Dock woodland.
- a more direct route from Greenwich

The Greenwich connection tunnel would collect flow from three sites and have a high capacity. Other options like these suggestions such as driving to Limehouse from Greenwich Pumping Station have been considered but rejected because they result in hydraulic instability/unacceptable performance; require additional large diameter shafts; and/or would still not eliminate the need for a shaft near the change in ground geology near Chambers Wharf.

Pumping Station to Abbey Mills Pumping

Extending the Greenwich connection tunnel all the way to Abbey Mills Pumping Station would increase the of the connection tunnel by over

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2 The need, solution, tunnel route and alignment Ref Objections, issues and concerns Station should be explored; this would reduce the number of major sites required which is in line with requests from Ofwat and the Environment Agency
- query whether it is possible for the tunnel

Respondent ID

No.

Our response 2km, would not eliminate the need for a shaft nearer to the change in ground conditions, and would introduce unacceptable hydraulic conditions. These options are therefore not considered suitable. In the vicinity of the Limehouse Marina the main tunnel deliberately passes beneath the river as far as possible to minimise the interaction with private property. The route of the main tunnel between the river and the Limehouse Cut threads between buildings which potentially have deep foundations.

route to go to Abbey Mills Pumping Station via Limehouse Marina


- continue an under river construction

process which is feasible from Hammersmith Pumping Station, through Chambers Wharf to an area adjacent to Limehouse Basin, in order to provide a short branch from the riverbed to a branch at Limehouse Cut onwards to Abbey Mills Pumping Station
- the route should cross to the northern

side of the River Thames around Southwark; this would be more environmentally appropriate since it is a less built-up area with existing industrial uses
- find an alternative route for the

Greenwich connection tunnel or alternative localised solutions for the Deptford Storm Relief and Greenwich Pumping Station CSOs
- utilise a tunnel from Greenwich Pumping

Refer to paragraph 2.4.19 to our response to finding an alternative route for the Greenwich connection tunnel. With regards to localised solution for Deptford Storm Relief and Greenwich Pumping Station CSOs refer to our responses at paragraph 2.3.94. Tunnelling directly from Greenwich Pumping Station to Beckton Sewage Treatment Works would result in a connection tunnel more than twice as long as the current proposal which connects to the main tunnel at Chambers Wharf. The local CSOs to be intercepted need to connect to the main tunnel. Therefore, the tunnel route needs to connect to CSOs at Barn Elms, Deptford Church Street and King Edward Memorial Park Foreshore. In relation to Carnwath Road Riverside and Chambers Wharf, the geology in which the tunnel is being constructed changes at these locations and therefore a main tunnel site is needed. The sites on which we consulted at phase two consultation have been identified through an extensive site selection process (see our Site selection methodology paper on our website). We consulted and agreed the methodology prior to its use with key stakeholders including potentially directly affected local authorities and utilised a multidisciplinary approach to assess potential CSO sites and main tunnel/connection tunnel drive options against engineering, planning, environmental, property and community considerations. Where

Station to Beckton Sewage Treatment Works; the tunnel would be shorter and avoid residential areas because it could follow the route of the River Thames - avoid the area around Barn Elms, Carnwath Road Riverside, Chambers Wharf, King Edward Memorial Park and Deptford Church Street

- Thames Water should make use of its own industrial sites to change the current route

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2 The need, solution, tunnel route and alignment Ref Objections, issues and concerns Respondent ID No. Our response appropriate, we have sought to use land that we own already. For further details on the results of the site selection process, refer to the Phase two scheme development report. The Greenway is an existing foul sewer which already utilised to full capacity. 7435, 7804, 7932, 8209, 8673, 8732 6 As set out in the Route and tunnel alignment project information paper, the Abbey Mills route remains our preferred route because: it is the shortest route; it is the least disruptive and most cost-effective option, costing 20 per cent less compared to the other two options, while still meeting all the required environmental objectives; it requires the least number of worksites; and it requires less tunnelling at depth through chalk in the east. Deep tunnelling through chalk is potentially more difficult and would bring greater health and safety issues. A site is needed at Barn Elms in order to intercept the West Putney Storm Relief CSO. Regarding main tunnel sites, we need a main tunnel drive site between Hammersmith Bridge and Battersea Bridge. Our preferred site for these works is Carnwath Road Riverside. Refer to Phase two scheme development report for further details. The tunnel passes from Blackfriars Bridge to Chambers Wharf, through the Shad Thames area, under the River Thames. In terms of works to the Shad Thames Pumping Station CSO, no interception sites are proposed. The Shad Thames Pumping Station CSO will be controlled by means of modifications in the area around the existing pumping station. New information or feedback from phase two consultation could lead to route modifications. Should this be necessary, we would consider whether our changes would affect the nature of the comments received from the public at phase two consultation, and where appropriate undertake further targeted consultation. We consider that undertaking consultation with local authorities and statutory consultees is effectively an independent review since these bodies are able to provide specialist technical feedback. Phase one consultation was undertaken between 9 September 2010 and 14 January 2011. We publicised our phase one consultation in accordance with our SOCC; methods included an advertisement in the London Evening Standard and local newspapers, sending letters to over 173,000 properties, holding exhibitions in the vicinity of preferred and shortlisted sites and provision of written material at exhibitions, on our website, at local libraries and town halls and on request. 2,866 individuals and organisations responded to phase one consultation, the findings of which are contained in our Report on phase one consultation which is available on our website. It should be noted that at phase two consultation we continued to seek feedback on our preferred tunnel route and therefore we do not consider that respondents who were not aware of phase one consultation have been disadvantaged in any way.

- The route should follow the Greenway.

2.4.23

Other issues, concerns and objections raised included: - it seems that a compromise route has been chosen rather than one that gives best long-term solution -

- would the Abbey Mills route still work if

the tunnel were constructed at Barn Elms

- concern about the route in the Shad

Thames area

- any modifications to the Abbey Mills route

should be subject to independent review

- we are not aware of phase one

consultation/so have no information or opinion on the proposed routes.

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2 The need, solution, tunnel route and alignment

Alternative routes
Table 2.4.5 Objections, issues and concerns in relation to the preference for the Abbey Mills route Ref 2.4.24 Alternative routes comments Need further information on alternative routes. Respondent ID 8949LO, 7265, 7627, 8235, 8402, 8528 No. 6 Our response The alternative routes were first described in the phase one consultation. Our Route - Development of the tunnel route document described the alignments considered in general terms and more detail was provided in other phase one consultation material, including our Project overview. The material produced at phase one consultation remained available during phase two consultation. We carefully considered the information we made available at our phase two consultation to ensure that consultees had sufficient information to respond to the consultation. Our preferred and shortlisted routes are described and illustrated throughout the phase two consultation material. The Route and tunnel alignment project information paper provides an overview and detail is provided in the Maps and the Book of plans. More information can also be found in detailed technical reports, such as the Project overview. We are confident therefore that the information we have provided is sufficient. In order to capture as much of the overflow as possible, we have to intercept the CSOs as near to the River Thames as possible because many have major junctions near the points at which they currently discharge into the river. This is the reason for our preference for the tunnel to follow the river for most of the route, particularly in west London. Our choice of sites for the project is very much driven by the location of the sewers that currently overflow during and after rainfall. So we do not have complete flexibility in selecting locations. There are a number of locations in west London where it is essential to intercept overflows in order to meet the objectives of the project. We are seeking to mitigate any significant effects of the construction and operation of the project. As set out in the Route and tunnel alignment project information paper, one of the reasons that the Abbey Mills route remains our preferred route is that it is the least disruptive when compared to the other two routes that we considered. Other reasons for our selection included that it is the shortest and most cost-effective option, costing 20 per cent less compared to the other two options (including when the cost of Chambers Wharf is taken into account) while still meeting all the required environmental objectives, including reduction of overflow discharges. It also requires the least number of worksites and requires less tunnelling at depth through chalk in the east. A site in the area around Chambers Wharf would be required regardless of the route used. This is because the geology changes in this area and in order to increase productivity and minimise construction risk, we would need to change the tunnel boring machine (TBM) here.

2.4.25

Query what other options were not considered in west and central London.

7050

2.4.26

Preference for River Thames route. Reasons included: - the River Thames route causes least disruption at surface level - the cost of a long tunnel to Beckton Sewage Treatment Works is less than the cost of opening up a major site at Chambers Wharf - it would provide extra capacity and obviate the need for the Greenwich connection tunnel and tunnel up to Abbey Mills Pumping Station, thus avoiding the need for the Chambers Wharf site. Preference for the Rotherhithe route. Other routes should be considered and

8556LO, LR9271LO, 7646, 8234, 8337, 8455, 8557, 8566, 8716, 8890, 9063, 9067, 9149, 9161, 9395, 9475, 9488, LR13498, LR8975, LR9471

20

2.4.27 2.4.28

8556LO, 7265, 7749 8887LO, LR9274LO, 7194, 7370, 7627,

3 14

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2 The need, solution, tunnel route and alignment Ref Alternative routes comments investigated. Suggestions included: - a route should be found whereby no main tunnel drive sites are located in densely populated residential areas/the impact on residents and businesses is minimised - a route which is less damaging to the environment - a route which avoids parks/green spaces/the River Thames foreshore - a route which avoids the risk of disruption to buildings - a shorter route - a cheaper route. Do not agree with any of the routes. Preference for the River Thames route because it would capture the most untreated sewage. This route offers the greatest environmental protection for the future of the River Thames. It would enhance the aquatic ecology throughout the tideway for the next 50 years and assist in preventing possible health issues affecting London's population. Do not agree with any of the routes. Preference for another solution. Respondent ID 8480, 8496, 8504, 8684, 8734, 8943, 9063, 9097, 9493 No. Our response

2.4.29 2.4.30

7233, 8782 8455, 8893, 9149

2 3 The only additional CSO that would be captured by the River Thames route would be at Charlton. The extension of Crossness Sewage Treatment Works together with some system changes will reduce the number and volume of overflows from the Charlton CSO to an acceptable level without the need for interception as part of this project.

2.4.31

7996LO, 9107LO, 7233, 7669, 8557

Analysis has been undertaken since 2000, to investigate and assess strategic alternatives to addressing the problem of CSO discharges into the tidal Thames. The National Policy Statement for Waste Water, which was designated on 26 March 2012, summarises the significant amount of work undertaken to assess alternative options and clearly states that the need for the project has been demonstrated. It concludes that detailed investigations have confirmed the case for a tunnel as the preferred solution (paragraph 2.6.33). The designation of the NPS was supported by an Appraisal of Sustainability Post-Adoption Statement dated March 2012 which contains further detail on the significant amount of work undertaken to establish the need for the Thames Tunnel project and assess alternative options. The report concludes that a tunnel solution remains the most appropriate and cost-effective of the solutions considered. As set out in the Route and tunnel alignment project information paper, one of the reasons that the Abbey Mills route remains our preferred route is that it is the least disruptive when compared to the other two routes. Other reasons for our selection include that it is the shortest and most cost-effective option, costing 20 per cent less than the other two options (including when the cost of Chambers Wharf is taken into account), while still meeting all the required environmental objectives. It also requires the least number of worksites and requires less tunnelling at depth through chalk in the east. In relation to the need to add to the

2.4.32

Other comments received in relation to alternative routes included: - query which route is the best and can be added to over time as necessary - a route should be selected that uses Thames Waters own industrial sites - alternative routes will not substantially affect the scale and extent of the

GLA, 13108, 7767, 8402, 8673

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2 The need, solution, tunnel route and alignment Ref Alternative routes comments worksites needed, which is where public concern is focused - The Mayor of London encourages Thames Water and others to continue to consider alternatives, especially those that have the potential to reduce costs and disruption. Respondent ID No. Our response tunnel over time, as the design of life of the tunnel is 120 years, we propose a long-term solution to the problem of CSO discharges. In relation to use of our own sites, the sites on which we have consulted at phase two consultation have been identified through an extensive site selection process (see our Site selection methodology paper on our website). We consulted and agreed the methodology prior to its use with key stakeholders including potentially directly affected local authorities and utilised a multidisciplinary approach to assess potential CSO sites and main tunnel/connection tunnel drive options against engineering, planning, environmental, property and community considerations. Where appropriate we have sought to use land that we already own. For further details on the results of the site selection process, refer to the Phase two scheme development report. Using either of the other two tunnel routes would require additional construction sites in order to build the tunnel between Southwark and Beckton Sewage Treatment Works. Alternatives have been studied as part of the design development process including considering feedback raised at phase one and phase two consultations. Our proposals have therefore been optimised to address numerous, at times, competing factors.

2.5
2.5.1

Alignment of the Abbey Mills route


During the phase two consultation, respondents were invited to comment on the alignment of the Abbey Mills route (see question 12 of the phase two consultation feedback form, provided in appendix M to the Main report on phase two consultation). Table 2.5.1 sets out details of the different groups who responded to confirm whether they had comments or not. Tables 2.5.2 - 2.5.4 then detail the feedback comments received in relation to the alignment of the Abbey Mills route. Respondents also provided comments on the tunnelling options and drive strategy presented at phase two consultation. It should be noted, that not all respondents who provided feedback comments confirmed whether they had comments or not. Table 2.5.1 Number of respondents commenting on the proposed alignment of the Abbey Mills route (Q12) Respondent type Number of respondents Comments Statutory consultees Local authority 0 2 - London Borough of Hammersmith and Fulham (LBHF) - London Borough of Tower Hamlets (LBTH) Landowners Community consultees Petitions Total 21 150 0 173 46 734 0 780 66 4,955 9 5,062 No comments No response 0 0 17 15

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2 The need, solution, tunnel route and alignment

Supportive and neutral feedback comments


Table 2.5.2 Supportive and neutral feedback comments in relation to the alignment of the Abbey Mills route Ref 2.5.2 2.5.3 Supportive and neutral comments Agree with proposed tunnel alignment because it is the least disruptive. Agree with drive strategy for the tunnel. In particular, the proposal to use Greenwich Pumping Station as a drive site for the Greenwich connection tunnel as opposed to a site in Southwark. Other supportive comments included supporting the proposed drive strategy for the construction of the Frogmore connection tunnel. Not qualified to comment on this technical matter. No comment. Respondent ID 7404, 7410, 7445, 7574, 7777, 7905, 7988 PLA, 9063, 9067 No. 7 3 Our response Your comments are noted.

2.5.4

9126LO, 7383, 8978

2.5.5 2.5.6

8410LO, 7012, 7249, 7527, 7702, 8313, LR13498

The purpose of consultation is to explore as fully as possible what those with an interest in the project think about our proposals. We will have regard to comments received from both technical and non-technical consultees.

Qualified support
Table 2.5.3 Supportive (qualified) feedback comments in relation to the alignment of the Abbey Mills route Ref 2.5.7 Qualified support comments Tunnel alignment should minimise effects of construction on local residents; concern that at King George's Park it will affect residents. Respondent ID 7006 No. 1 Our response We have been assessing the likely significant effects that may arise as a result of the works as part of an environmental impact assessment. This will set out measures necessary to mitigate any significant adverse effects that are identified. An Environmental statement, which records the findings of the environmental impact assessment, will accompany our DCO application. The initial environmental assessment work that has been carried out on the project is contained within the PEIR, which is available on our website. As part of the phase two consultation, we also sought feedback on the potential effects arising from our proposals and how the effects will be mitigated. Where possible, we will take feedback comments into account as we develop our proposals. The tunnel alignment from King Georges Park to the River Thames is tightly constrained by existing infrastructure such as buildings with deep foundations and potential future developments including other tunnels. The potential effects on residents have been taken very seriously and the alignment follows roads as far as possible for this reason. As set out in the Route and tunnel alignment project information paper, the Abbey Mills route remains our preferred route because: it is the shortest route; it is the least disruptive and most cost-effective option, costing 20 per cent less than the other two options, while still meeting all the required environmental objectives; it requires the least number of worksites; and it requires less tunnelling at depth through chalk in the east. Deep tunnelling through chalk is potentially more difficult and

2.5.8

Unsure whether the tunnel alignment is correct.

7045

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2 The need, solution, tunnel route and alignment Ref Qualified support comments Respondent ID No. Our response would bring greater health and safety issues.

Objections, issues and concerns


Table 2.5.4 Objections, issues and concerns in relation to the alignment of the Abbey Mills route Ref 2.5.9 Objections, issues and concerns Do not agree that the Abbey Mills route is the correct alignment. Respondent ID No. Our response As set out in the Route and tunnel alignment project information paper, the Abbey Mills route remains our preferred route because: it is the shortest route; it is the least disruptive and most cost-effective option, costing 20 per cent less than the other two options, while still meeting all the required environmental objectives; it requires the least number of worksites; and it requires less tunnelling at depth through chalk in the east. Deep tunnelling through chalk is potentially more difficult and would bring greater health and safety issues. The tunnel alignment is being designed to avoid residents as far as possible within the other constraints such as the need to connect to the existing sewer system, the tightness of bends that can be physically constructed by tunnel boring machines of this size, existing or planned underground developments, known sensitive structures and monuments, health and safety during construction and maintenance. The tunnel joins the CSO sites which were identified through an extensive site selection process as set out in the Site selection methodology paper that is available on our website. This methodology was agreed with key stakeholders, including potentially directly affected local authorities, prior to its use. The Site selection methodology paper explains how environmental, planning, engineering, property and community considerations were taken into account in selecting our preferred sites for the scheme. The two specific areas mentioned form an interesting contrast. The alignment through Riverview Gardens has been selected to avoid the foundation anchors of the Hammersmith Bridge and the majority of property in the area. A change from King Edward Memorial Park Foreshore to Heckford Street would mean the main tunnel would need to divert inland and require an additional connection tunnel. This would result in tunnel running under more residential properties. 8226 (LR)RM, 13469, 7030, 7767, 7811, 7876, 8235, 8528, 9237 1 9 Refer to our paragraph 2.4.16 for our response to this feedback comment. We have carefully considered the information we made available at our phase two consultation to ensure that consultees had sufficient information to respond to the consultation. Our preferred route is described and illustrated throughout the phase two consultation material including the Route and tunnel alignment project information paper

Tunnel alignment (LR)LBTH, 8303LO, 8504, 8890, 8983, 9097 6

Reasons included: - the alignment affects too many residents

- the alignment is located underneath part

of Riverview Gardens
- the alignment should allow for Heckford

Street to be developed instead of the site at King Edward Memorial Park Foreshore.

2.5.10 2.5.11

The alignment is incorrect as the wrong route has been selected. More information is needed on the alignment including:

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2 The need, solution, tunnel route and alignment Ref Objections, issues and concerns Respondent ID No. Our response which provides an overview with detail in the Book of plans. We are confident therefore that the information we have provided is sufficient. We have been assessing the likely significant effects that may arise as a result of the works as part of an environmental impact assessment. This will set out measures necessary to mitigate any significant adverse effects that are identified. An Environmental statement, which records the findings of the environmental impact assessment, will accompany our DCO application. The initial environmental assessment work that has been carried out on the project is contained within the PEIR, which is available on our website. As part of the phase two consultation, we also sought feedback on the potential effects arising from our proposals and how the effects will be mitigated. Where possible, we will take feedback comments into account as we develop our proposals. In relation to acquisition of land, it is likely that we will need to acquire sub-soil rights to construct the tunnel. Subsoil is the part of the land which is below its natural surface. Further details on this can be found in A guide to the Thames Tunnel compensation programme, which can be found on our website. The main tunnel will be underneath the middle of the River Thames, approximately 40m from the nearest buildings. Refer to the Settlement project information paper for details of how we propose to avoid damage to buildings. A 6m protection zone is to be provided around the tunnels as a buffer against future developments. Information on the tunnelling process is contained within the Build project information paper and the Site selection background technical paper. The roof of the main tunnel is approximately 28m deep at Riverview Gardens. 9374LO, 9484LO, 13469, 8983, 9237, 9486 6 We have assessed the potential ground settlement/ movement potentially caused by our proposed tunnelling works along the entire route. Where possible we have chosen an alignment that avoids potential building settlement. We will engage with all relevant infrastructure owners for all structures which we pass under, or close to, and which might be affected by settlement. Mitigation measures and monitoring requirements will be set out in our CoCP that will accompany our DCO application. Refer to the Settlement project information paper for details of how we propose to avoid damage to buildings. Landowners may have a statutory entitlement to claim compensation for the diminution on the value of their property due to the construction of the tunnel. In addition to the statutory process we have published an exceptional hardship procedure which sets out how we will assess claims from householders who contend that they are suffering exceptional hardship as a result of being unable to sell their property because it is potentially impacted by the currently published Thames

- the precise route and depth of the tunnel; details of potential vibration during construction and operation around Stamford Brook; whether there is a requirement to purchase land; and possible compensation available

- the route in relation to Riverside Court

and Thames Water's plans to avoid damage to this building


- exclusion zones for below ground works - the tunnelling process

- the depth of the tunnel under Riverview

Gardens. 2.5.12 Concern about the effect on buildings and above and below ground infrastructure including:
- proximity of drop shaft to the building

adjacent to the Cremorne Wharf Depot site


- Riverview Gardens - river wall near Putney Bridge and St

Mary's Church. 2.5.13 Need to minimise possible settlement, subsidence, damage and construction effects associated with tunnelling under residential properties. Need to minimise possible settlement to 7119LO, 8569LO, 7444, 8086 4

2.5.14

9090

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2 The need, solution, tunnel route and alignment Ref Objections, issues and concerns old and sensitive structures. Concerned about effects of vibration and settlement arising from construction and the effect on the value of property. Respondent ID No. Our response Tunnel project proposals. We have also published A guide to the Thames Tunnel compensation programme which sets out details of compensation that would be available during construction arising from damage or loss, for required protection measures, and for compulsory purchase. The Site selection background technical paper provides information that underpins the site selection process in terms of background and engineering requirements of the Thames Tunnel project. While to support the creation of the preferred list of main tunnel sites, as set out in Site selection methodology paper, this involves further investigation of the suitability of sites and the production of an Engineering options report: Abbey Mills route. This engineering document identifies the factors related to the drive strategies and the feasible main tunnel drive options based on the available final shortlist of main tunnel sites, which are grouped into geographical zones. The optioneering workshops: (i) identify the preferred main tunnel sites by type (eg reception or drive) within each zone and (ii) compares drive options and the sites these options would use to reach a conclusion on the overall preferred drive strategy and main tunnel sites. The main comparisons and reasons for the selected drive strategy are set out in section 6.6. of the Phase two scheme development report. The Build project information paper, Route and tunnel alignment project information paper and the site information papers describe the tunnel construction process in relatively simple terms but significant in-depth study and analysis has been undertaken. The reasons for the selected drive strategy are given in Section 6.6 of the Phase two scheme development report. The main tunnel from Acton Storm Tanks to Abbey Mills Pumping Station is 22 km long; it is normal for the tunnel to be split into sections for a number of reasons including ground conditions, commercial, programme, safety, and technical issues. This means that several TBMs would be used to complete the work. During our preparation we have consulted specialist consultants and TBM suppliers and have worked out our proposals taking account of their advice for an efficient, safe, and cost-effective strategy. We have specifically consulted experts about proposals for convertible TBMs, TBM docking, TBM abandonment etc, and compared those options to our current proposals. The clear outcome from these studies was that some of the options that had been suggested are not feasible, and of those that are, the current proposal presented at phase two consultation is the best option. Bearing in mind the large internal diameter of our tunnel, the disadvantages of the discounted options include: - the need to form caverns beyond the protection of tunnel shields in poor, saturated ground using ground treatments such as freezing - the need to convert the TBMs handling and processing facilities for the excavated material: earth pressure balance TBMs handle

Tunnelling options and drive strategy 2.5.15 2.5.16 Do not agree that Thames Water has chosen the best drive strategy. 8303LO 1 1

More information is needed on the 8295 proposed drive strategy. Further clarification required regarding why there are three main tunnel sites and in particular why Barn Elms is being considered.

2.5.17

Longer tunnel drive phases should be used from Abbey Mills Pumping Station to Kirtling Street and from Kirtling Street to Acton Storm Tanks. This would obviate the need for main tunnel sites at Carnwath Road Riverside and Chambers Wharf. Longer drive phases could be achieved by: - using different types of tunnel boring machines (TBMs) by changing the cutting heads - using a hybrid cutting head/custommade hybrid TBM - using docking TBMs, like in Tokyo or Storebaelt - do not change the TBM; although it is noted that a machine may break down more often if used in unsuitable soil - two TBMs should meet under the river and be dismantled - leaving the TBMs buried underground at the conclusion of their operation - in light of these options, the argument that three TBMs are required due to

8303LO, 8410LO, 8556LO, 8571LO, 8632LO, 8801LO, 9092LO, 9093LO, 9105LO, 9107LO, 9254LO, 9400LO, 9417LO, 9481LO, 11904, 13108, 13240, 7767, 8091, 8140, 8218, 8234, 8401, 8417, 8430, 8568, 8649, 8673, 8680, 8750, 8753, 8774, 8849, 8857, 8890, 8891, 8953, 9063, 9067, 9149, 9155, 9161, 9303, 9357, 9385, 9387, 9395, 9461, 9475, 9488, 9496, 9497, LR13498, LR8975, LR9112, LR9343, LR9418, LR9471

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2 The need, solution, tunnel route and alignment Ref Objections, issues and concerns geology changes becomes otiose - it is appreciated that there are issues regarding the safety of workers, which must be a paramount consideration, but there are precedents for these solutions which were undertaken without endangering the workforce. The resultant community benefits would be worth investing time in these options/procuring bespoke TBMs. This approach would also eliminate sites, the cost of which could be spent on TBMs. Respondent ID No. Our response excavated paste by means of a screw and a conveyor and slurry TBMs handle slurry by means of slurry pipes and liquid separation plant. There is no precedent for this. - the need to dismantle the innards of the TBMs using flame cutting in hazardous confined conditions - the need for unusual heavy lifting operations underground in confined conditions Under The Construction (Design and Management) Regulations 2007 the designers obligations are, insofar as reasonably practicable, to avoid foreseeable risks to the health and safety of any person carrying out construction work. The designer must also eliminate hazards where possible and reduce risks from any remaining hazards. In addition, our studies have demonstrated that Abbey Mills Pumping Station is not suitable as a main tunnel drive site because transporting material to and from the site by the River Lee would be very difficult to achieve and is highly undesirable when material needs to be transported daily over a two to three year period. This level of barge movements would be required if Abbey Mills Pumping Station were to be used as a main tunnel drive site, given the volume of excavated material that would be produced. Given the constraints to using the River Lee to transport materials, we would need to use the residential roads to access the site. This, combined with our findings regarding the need to use a slurry TBM to drive any significant distance in chalk, means Chambers Wharf is more suitable as a drive site for the tunnel to Abbey Mills Pumping Station. We have also considered and rejected a long main tunnel drive between our proposed sites at Kirtling Street and Acton Storm Tanks. The difficulties with this strategy can be summarised as follows: 1. Risk of tunnel machine failure under properties in Chiswick 2. Risk of long tunnel construction to tunnelling personnel 3. Risk of long tunnel maintenance - it is 12km between main access points which breaches the 9km Health and Safety Executive limit for operational access 4. A 1.65m step in the vertical alignment of the tunnel is required at a shaft location in order to avoid other tunnels 5. A single tunnel would take approximately 18 months longer to construct. The conclusions of our studies will be documented in the Engineering options report, which will be submitted with our DCO application. Thames Water has a responsibility to deliver a commercially secure and cost-effective project, so the commercial conditions and competitiveness are a concern to many parties and not unfounded.

Comments relating to constructing the tunnel from Kirtling Street straight through to Acton Storm Tanks included: - the concern about uncompetitive bids due to the fact that two thirds of the tunnel contract would be allocated at a

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2 The need, solution, tunnel route and alignment Ref Objections, issues and concerns single site are unfounded
- having two drives from one site would

Respondent ID

No.

Our response Kirtling Street has already been identified as a preferred site for use as a double drive site.

mean a substantial reduction in site acquisition and shaft drilling costs, and would enable Thames Water to better utilise the existing wharf at Kirtling Street with barges
- an emergency spiral stairwell could be

included along the 12km length of tunnel, alternatively, the CSO connection points could be used as emergency exits for workers
- considering the whole life risk of requiring

The connection tunnels and shafts of the project will all be utilised for emergency access as appropriate. However, the costs and disruption associated with selecting a new construction site solely for a spiral access staircase is not justified. In our assessment, considering the scale of risks at different stages such as construction, operation and maintenance , our proposals are the lowest whole life risk option for both construction operatives and third parties

additional construction sites and the associated increase in risk to receptors, the risks of constructing shorter tunnels with more sites outweigh the risks of constructing a longer tunnel with fewer sites
- weighed against the financial savings of

not needing to acquire a second main drive site, the costs of buying a new TBM are relatively insubstantial; a different emphasis on longevity would be placed on a machine that is required to drive 12km than one required to drive 6km

Comparing the cost of a TBM and a main drive site is not appropriate. The logic behind the drive strategy and site selection are set out in Engineering options report and chapter 6 of Phase two scheme development report. The cost of the TBM has not been considered a main driver and a successful contractor will need to spend sufficient money to procure a suitable tunnel boring machine for the risks and conditions that will be encountered. A more expensive TBM would not change the commercial risk of having a single contract for such a large portion of the tunnel. The ventilation facilities are arranged to minimise the release of untreated air from the tunnel system and approximately 99 per cent of the time during the average year, air released from the tunnel will be treated and will not have any odours, which meets the Environment Agencys odour criteria. There are a few factors driving the vertical alignment at the west end of the scheme. These include the NG tunnel, two of our own existing tunnels, the need for satisfactory hydraulic performance, and the need to maintain a reasonable clearance under the buildings through Chiswick to Acton. There is no need for further study. We have sufficient information to inform the selection of our preferred scheme.

- the ventilation strategy could be made to

work over a longer distance in order to mitigate the currently expected odour releases at Carnwath Road Riverside
- the National Grid (NG) tunnel will not be a

gravity system. It has not yet been built so, depending on the stage it is at, talks with NG may permit an alteration to that design and remove the need for this site
- concerns raised by Thames Water can be

addressed by undertaking further studies and assessments. Therefore, any decision to proceed on the basis of a lack of further information in relation to the feasibility of this option is premature
- a full cost analysis of avoiding Carnwath

As set out above, the cost is not the deciding factor as a more expensive

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2 The need, solution, tunnel route and alignment Ref Objections, issues and concerns Road Riverside as opposed to driving Kirtling Street to Acton Storm Tanks should be undertaken. If the two drives were to be undertaken consecutively, even if the machine is changed at Carnwath Road Riverside, there would be no need to remove spoil at Carnwath Road Riverside. The spoil could continue along the main tunnel to Kirtling Street where it could be loaded onto larger barges than could be accommodated at Carnwath Road Riverside, thereby avoiding transhipment before entering the estuary of the River Thames. This would also reduce the area required at Carnwath Road, and avoid acquisition of the Carnwath Road Industrial Estate. Respondent ID No. Our response TBM will not substantially change the risks we need to address.

A longer tunnel drive introduces other health and safety issues as the logistics chain lengthens. For example, the tunnel segments used to construct the tunnel lining are transported from the tunnel drive shaft to the face of the tunnel by locomotives on temporary track fixed to the floor of the tunnel. Any work underground brings with it an increased risk of accidents, but the use of locomotives carrying very heavy concrete segments through tunnels is recognised within the industry as a hazardous activity. Doubling the length of the tunnel drive would significantly increase the number of locomotive miles necessary to build the tunnel and therefore increase the risk of causing a serious injury to a person working in the tunnel. We take our responsibility to health and safety very seriously. Wherever possible we seek to minimise and design out health and safety risks, in this case by ensuring tunnel drive lengths are not excessive. Where it is not possible to design out risks, mitigations such as the introduction of an intermediate shaft as described above can be used to reduce risks to acceptable levels. We estimate that a single tunnel drive to Acton Storm Tanks would take approximately 18 months longer to construct than using either Barn Elms or Carnwath Road Riverside as a drive site. This is because the option to use either Barn Elms or Carnwath Road Riverside uses two TBMs working at the same time to construct this 12km length of tunnel. A single drive from Nine Elms to Acton Storm Tanks would take longer with only one TBM working to construct the 12km tunnel. It would also take longer to construct the drive shaft at Nine Elms, which extends into the Lambeth Beds beneath the London Clay. We have consulted with TBM manufacturers and other experts with knowledge of the Channel Tunnel project. In addition we have considered the performance of TBMs on other more recent projects through similar ground such as the Jubilee Line, the Channel Tunnel Rail Link, the Docklands Light Railway and the Thames Water Ring Main. We are confident in our tunnelling strategy. While there is overlap in the ground suitable for slurry TBMs and earth pressure balance TBMs, there is clear evidence that slurry machines are most suitable in chalk and earth pressure balance machines are most suitable in clay. The sites on which we have consulted were identified through an extensive site selection process as set out in the Site selection methodology paper that is available on our website. This methodology was agreed with key stakeholders, including potentially directly affected local authorities, prior to its use. The Site selection methodology paper explains how environmental, planning, engineering, property and community considerations were taken into account in selecting our preferred sites for the scheme. The reasons for the selected drive strategy are given in Section 6.6 of the Phase two scheme development

Query what evidence there is from the construction of the Channel Tunnel in relation to the need to change TBMs.

Concern that there may be tunnelling options that make better use of the land available and reduce the impacts on local residents that Thames Water has not considered.

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2 The need, solution, tunnel route and alignment Ref Objections, issues and concerns Respondent ID No. Our response report. The tunnel will inevitably be broken into a number of sections for a number of reasons including ground conditions, commercial, programme, safety, and technical issues. We do not consider that an independent review is necessary. To supplement the expertise of our in-house design team we have specifically consulted external experts and TBM manufacturers to inform our tunnelling strategy decisions. As part of that process we have considered options and associated risks to develop the optimum scheme, taking account of a diverse range of factors. The logic behind the chosen drive strategy is explained in chapter 6 of Phase two scheme development report. 7215 7712LO 1 1 We have no interest in tunnelling companies. As set out in the Route and tunnel alignment project information paper, the main tunnel will start at a depth of 25m at Acton Storm Tanks and finish at a depth of approximately 60m at Abbey Mills Pumping Station. This means that for most of the tunnels length it will be significantly deeper than other tunnels in London, avoiding London underground lines, road tunnels and major utility tunnels. The depth of the tunnel means that, although it will run underneath some properties, the risk of any potential effects from tunnelling works is low. The Frogmore connection tunnel is shallower approximately 20m deep. However, expected settlement is proportional to the diameter of the tunnel and this tunnel is small compared to the main tunnel, so effects will be proportionally smaller. The Settlement project information paper provides further information on how we are designing the tunnel to protect against the effects of settlement and how we will be identifying any buildings that need any protective measures. We will engage with all relevant infrastructure owners to assess the potential impacts of our proposed works. As part of this, we will assess the potential ground settlement/movement from our proposed tunnelling works on all structures that we would pass under or close to. Mitigation measures and monitoring requirements will be set out in our CoCP. We will be engaging with all relevant infrastructure owners to assess the potential effects of our proposed works. As part of this, we will be assessing the potential ground settlement/movement from our proposed tunnelling works on all structures that we would pass under or close to. Mitigation measures and monitoring requirements will be set out in our CoCP.

An independent review of drive options should be undertaken.

2.5.18 2.5.19

Query whether Thames Water has an interest in tunnelling companies. Concern about the depth of the tunnel and associated impacts especially about the impact on properties if the tunnel is only 20m below ground level.

2.5.20

Other issues, concerns and objections GLA, 7646, 8086, 8614, 8774, 8983, LR9275 included detailed comments on the interface between the tunnel alignment and Transport for London assets.

2.6
2.6.1

Our view of the way forward


We recognise that some respondents have concerns about the need for the project and whether a tunnel is the most appropriate solution. We have given careful consideration to these comments and reviewed the detailed evidence contained in the Needs report. We still believe that it is essential to reduce the amount of sewage entering the River Thames and that a tunnel represents the best way to achieve this.

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2 The need, solution, tunnel route and alignment 2.6.2 2.6.3 Some of the concerns raised included detailed comments on the design and construction of the tunnel. These will, insofar as possible, be taken into account as the design of the tunnel progresses. We recognise that some respondents have concerns about our preference for the Abbey Mills route and its alignment and prefer alternative routes. Having considered all comments received, we still consider that Abbey Mills remains the most appropriate route and we therefore intend to pursue this option. As the design of the tunnel progresses, we will continue to refine its alignment and will discuss this further with the relevant stakeholders.

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