Supp Report on P2 Consultation - Chapter 2 Need Solution Route Alignment

7/31/2019 Supp Report on P2 Consultation - Chapter 2 Need Solution Route Alignment

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

Supplementary reporton phase twoconsultation

Chapter 2 Need, solution, tunnel routeand alignment


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2 The need, solution, tunnel route and alignment

Supplementary report on phase two consultation

Thames Tunnel


List of contents

Page number

2 The need, solution, tunnel route and alignment ............................................................................................................. 2-12.1 Introduction ............................................................................................................................................................... 2-12.2 The need for the project............................................................................................................................................ 2-12.3 The solution ............................................................................................................................................................ 2-182.4 Tunnel route ........................................................................................................................................................... 2-712.5 Alignment of the Abbey Mills route ......................................................................................................................... 2-832.6 Our view of the way forward ................................................................................................................................... 2-91


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


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Supplementary report on phase two consultation 2-1


2.1 Introduction

2.1.1 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 ofthe 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. Ourresponses to the feedback comments raised by respondents are set out in the tables.

2.1.2 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.

2.1.3 Where a response contains reference to our website, go to www.thamestunnelconsultation.co.uk for further information, or to access the documents referred to.

2.1.4 The final section of this chapter sets out our initial view of the way forward, having regard to the feedback comments received.

2.2 The need for the project

2.2.1 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 seequestion 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 whoresponded 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. Itshould 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 No comments No response

Statutory consultees 2- Consumer Council for Water (CCW)

- Orange Telecom (OT)

1 18

Local authorities 4

- London Borough of Hammersmith and Fulham (LBHF)

- London Borough of Southwark (LBS)

- Royal Borough of Greenwich (RBG)

- Sevenoaks District Council (SDC)

0 13

Landowners 56 16 61

Community consultees 612 413 4,814

Petitions 0 0 9

Total 674 430 4,915
http://www.thamestunnelconsultation.co.uk/http://www.thamestunnelconsultation.co.uk/


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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 Supportive and neutral comments Respondent ID No. Our response

2.2.2 General support for the project includingthat the objective should be zero dischargeexcept in very exceptional conditions.

12544, 7003, 7012, 7174, 7175, 7217, 7249,7289, 7366, 7536, LR13417

11 Your comments are noted. The primary purpose of the proposed worksis to reduce the amount of untreated wastewater that is discharged intothe tidal Thames and improve water quality in order to meet legalrequirements. This will have benefits for residents, visitors, business andwildlife. It should be noted that it would not be cost-effective to interceptall combined sewer overflow (CSO) events that could occur as the sizeof the project would be much larger with much greater cost. The greaterproject size would have far larger impacts and the costs would beprohibitive when compared to the marginal benefits achieved. Forexample, we are reducing CSOs that occur up to 60 times per year tofour or fewer (with such residual discharges occurring in the wintermonths). Whereas if the control target was one event or fewer, theproject storage volume (or tunnel length and/or diameter) would at leastdouble. The Environment Agency has agreed that the capture of 96 percent of the current discharge in a typical year leaving four events or lessis a practical and cost-effective level of control.

2.2.3 Agree that there is a need to reduce the

amount of sewage entering the RiverThames so that limits established by theEnvironment Agency and by expertsthroughout the world are met.

See annex B of this report 721

2.2.4 The existing situation is unacceptable, inparticular in relation to the effect onLondon's reputation.

9003LO, 7198, 7231, 7404, 7528, 7744,7855, 7988, 8450, 8501, 8777, 9299,LR9275

13

2.2.5 The River Thames is a valuable Londonasset and the proposals will maintain orimprove its quality.

11683, 12008, 7108, 7124, 7128, 7458,8688, LR9491

8

2.2.6 Improving the quality of the tidal RiverThames will increase quality of life.

13363, 8538, 8685, 8813, 9012, LR9275 6

2.2.7 Improving the quality of the tidal RiverThames will improve London's image.

8231 1

2.2.8 Important to reduce pollution and clean upthe River Thames. Reasons for thisincluded in order to prevent severe risks tothe environment as well as potential healthrisks.

(LR)RBKC, 7024, 7159, 7342, 7447, 7489,7758, 7813, 8039, 8186, 8890, 9395, 9475

13

2.2.9 The existing situation will worsen if noaction is taken.

7623, 9282 2

2.2.10 Need to protect river wildlife from theeffects of combined sewer overflows.Wildlife cited included: wildlife found in theBritish channel and other British estuaries;birds; fish species including smelt; sandsmelt; salmon; dace; flounder; common

goby and bass.

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

16

2.2.11 Reducing sewage entering the RiverThames will support economic activity.

7198, 7997, 8685 3

2.2.12 Reducing sewage entering the RiverThames will encourage tourism.

7243 1

2.2.13 Need to comply with the Urban WasteWater Treatment Directive (UWWTD) andthereby avoid EU fines.

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

6


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2.2.14 Reducing the amount of sewage enteringthe River Thames will improve propertyprices along the riverfront.

7489 1

2.2.15 Reducing the amount of sewage enteringthe River Thames will bring ecologicalbenefits including in downstream MarineConservation Zones.

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

9

2.2.16 The existing situation is a health hazard tousers of the River Thames.

EA, 11631, 7198, 7251, 7457, 7747, 7801,7855, 8188, 8222, 8399, 8493, 8637, 8638,9257, 9282, LR13473

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

2.2.17 Reducing sewage entering the RiverThames will bring recreational benefits.

SDC, 7243, 7326, 8188, 9012, LR13473,LR9121, LR9154

8

2.2.18 There is a need to update and future proofour sewerage infrastructure. This willensure that population and housing growthcan be catered for.

(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

32 Agreed. The Needs reportconfirms that the existing sewerage systemdoes not have sufficient capacity to accommodate sewage and stormwater during periods of rainfall, which results in discharges into the RiverThames after as little as 2mm of rainfall. This problem will only beexacerbated by projected population growth and climate change. Oncethe storage tunnels have been developed and are in operation they willbe a strategic component of Londons infrastructure and will provideflexibility to adapt the network for future conditions, includingopportunities for the flows from new sewerage infrastructure to be

diverted to the tunnel.2.2.19 This issue should be addressed as soon as

possible to provide sufficient capacity forpopulation growth and to provide a healthyenvironment for river users and residentsliving close to the River Thames.

7046, 7198, 7251, 7287, 7312, 7574, 7684,7768, 7905, 8078, 8099, 9012, 9139

13 Work has been underway on examining the solutions to the problem ofsewage discharges to the River Thames for more than 10 years, initiallythrough the independently chaired Thames Tideway Strategic Study(TTSS) group. Given the importance of properly meeting the objectivefor the project and the complexity of the proposed solution, the evolutionof the tunnel has been rapid compared with the time taken to developother large London projects such as Crossrail, East London Lineimprovements and Thameslink 2000. The timetable for delivery of theThames Tunnel project is set out in the Timingproject information paperand is the earliest possible delivery given the construction work involved.

2.2.20 This issue should have been addressedsooner. Reasons for this included:

- given the ever-growing community.

7620, 7905, 8016, 8740 4

2.2.21 Understand why this issue needs to beaddressed.

7017, 7100, 7243, 7280, 7772, 8495, 8534,8644, 8761, 8763, 9078, 9189

12 Your comments are noted.

2.2.22 Project addresses the effects of climate

change.

7855 1

2.2.23 Other reasons for support included:

- i t will address visual impacts of pollutionon the river and foreshore

- i t will provide a positive improvement toLondon's environment

- sewage spills for which we will have topay large fines should not be allowed

- the suggestion that the UK should have

EA, GLA, 7383, 8281, 8399, 8453, 9030,9282

8


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lower standards of cleanliness becauseof the current economic situation isunacceptable

- to improve the River Thames we aregoing to have to make sacrifices, whichincludes putting up with buildingdisruption and increases to our water bills

- the proposals will lead to improvementsin biological water quality within the RiverThames as measured in accordance withthe Water Framework Directive.

2.2.24 Not qualified to comment on this technicalmatter.

7168, 7495, 8284, 9089 4 The purpose of consultation is to explore as fully as possible what thosewith an interest in the project think about our proposals. We will haveregard to comments received from both technical and non-technicalconsultees.

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 Qualified support comments Respondent ID No. Our response

2.2.25 Agree with the need to reduce the amountof sewage entering the River Thames, but

disagree/concerned with the proposedsolution/route/proposed sites.

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

143 The need for a full-length storage tunnel solution is set out in the Needsreport, which is available on our consultation website. Both the previous

government, on 1 March 2010, and the Coalition Government, on 7September 2010, 16 November 2010 and 3 November 2011 indicatedtheir support for the project in ministerial statements and have proposedthat it should be designated as a nationally significant infrastructureproject (NSIP).

As set out in the Route and tunnel alignmentproject information paper,the Abbey Mills route remains our preferred route because: it is theshortest route; it is the least disruptive and most cost-effective option,costing 20 per cent less compared to the other two options, while stillmeeting all the required environmental objectives; it requires the leastnumber of worksites; and it requires less tunnelling at depth throughchalk in the east. Deep tunnelling through chalk is potentially moredifficult 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 selectionprocess (see our Site selection methodology paperon our website). Weconsulted and agreed the methodology prior to its use with keystakeholders including potentially directly affected local authorities andutilised a multidisciplinary approach to assess potential CSO sites andmain tunnel/connection tunnel drive options against engineering,planning, environmental, property and community considerations.

We recognise that, given the locations where we are seeking toconstruct and operate the tunnel, many of the shortlisted sites areconstrained in some way. However, based on our assessment we


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consider that on balance our preferred sites are the most suitable.

For further details on the results of the site selection process, refer to thePhase two scheme development report.

2.2.26 Agree with the need to reduce the amountof sewage entering the River Thames, butconcerned about effects that will arise fromaddressing the problem.

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

20 We have been assessing the likely significant effects that may arise as aresult of the works as part of an environmental impact assessment. Thiswill set out measures necessary to mitigate any significant adverseeffects that are identified. An Environmental statement, which recordsthe findings of the environmental impact assessment, will accompanyour DCO application.The initial environmental assessment work thathas been carried out on the project is contained within the PEIR, whichis available on our website. As part of the phase two consultation, wealso sought feedback on the potential effects arising from our proposalsand how the effects will be mitigated. Where possible, we will takefeedback comments into account as we develop our proposals.

2.2.27 The impacts associated with addressingthis problem need to be proportionate tothe benefits.

7259, 8671, 8892, 9125 4

2.2.28 The costs associated with addressing thisproblem need to be proportionate to thebenefits.

7259, 8462, 8473, 8909 4 Cost benefit analysis has already been undertaken, which showed that astorage and transfer tunnel option, combined with improvements atsewage treatment works and the Lee Tunnel had the highest netbenefits. This work informed the Ministerial Statement in March 2007and the request that we develop a tunnel solution. The Government hasundertaken further cost benefit analysis, which informed the MinisterialStatement in November 2011, in which the Secretary of Statement saidwe continue to believe that a tunnel represents the preferred solutionfor dealing with the untreated sewage that is polluting the RiverThames. As the project develops, we have been and will continue to beclosely scrutinised by the industry economic regulator Ofwat and by theDepartment for the Environment, Food and Rural Affairs (Defra).

2.2.29 London's existing sewage infrastructuredoes not have the necessary capacity.

8047 1 Agreed. The Needs reportconfirms that the existing sewage systemdoes not have sufficient capacity to accommodate sewage and stormwater during periods of rainfall, which results in frequent discharges intothe River Thames. This problem will only be exacerbated by populationand housing growth. Once the storage tunnel has been developed andis in operation it will be a strategic component of Londons infrastructureand will provide flexibility to adapt the network for future conditions,including opportunities for the flows from new sewerage infrastructure tobe diverted to the tunnel.

2.2.30 The current system is inadequate/ in needof modernisation.

7163 1

2.2.31 Qualified support subject to:

- provide clarification regarding thereasons for EU involvement

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

10 The UWWTD contains the European Unions requirements concerningthe collection, treatment and discharge of wastewater. The objective of

the Directive is to protect the environment from adverse effects ofwastewater discharges. The requirements of the UWWTD have beentransposed into domestic legislation in the Urban Waste WaterTreatment Regulations 1994.

The legal drivers for the project are set out in the Needs report. Thesederive from the UWWTD and the Water Framework Directive (WFD).The project is needed to ensure that the UK complies with therequirements of the UWWTD. It will also help to achieve the objectivesof the WFD. The European Commission (EC) is taking action againstthe UK for alleged breach of the UWWTD in respect of discharges of


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untreated sewage in the River Thames. Under article 258 of the Treatyof Lisbon, the EC has powers to take legal action when it considers thata member state is not respecting its obligations under the UWWTD. On16 June 2010, the EC launched legal proceedings before the EuropeanCourt of Justice for alleged failure to comply with obligations under theUWWTD in relation to discharges of urban wastewater into the Thames.An oral hearing was held on 10 November 2011 and on 26 January2012 the Advocate General issued an opinion which recommends that

the court should declare that the UK Government has failed to complywith requirements of the UWWTD. While the Advocate Generals opinionrecognises that the UK Government intends to install a storage andtransfer tunnel to address overflows into the River Thames, theproposed action against the Government is to be taken against previousunacceptable discharges into the River Thames. The decision of thecourt has not yet been issued, but it has the power to seek finesconsisting of a lump sum and a periodic penalty, which could amount toconsiderable sums. It is therefore necessary for action to be taken toavoid such penalties being applied for future non-compliance with theUWWTD. The need for the Thames Tunnel project has been reinforcedby the Ministerial Statement in November 2011 that said: we continueto believe that a tunnel represents the preferred solution for dealing withthe untreated sewage that is polluting the River Thames and the reportpublished by Defra on November 2011 entitled Creating a River Thames

fit for our future: A strategic and economic case for the Thames TunnelThis report concludes a tunnel solution remains the most appropriateand cost-effective of the solutions considered.

- the Thames Tunnel project must notbecome a profit making venture

We have considered a number of options to reduce the amount ofuntreated sewage that flows into the River Thames according to thetimetable specified by Government, including sustainable urbandrainage systems (SuDS), separation of the sewerage system, andbubblers and skimmers. However, none of these options wereconsidered viable when compared with a storage and transfer tunnelsolution. We have also considered the recommendations of theSelbourne Commission and others who have suggested alternatives tothe Thames Tunnel project and we do not consider that these representviable alternatives, within the timescale specified by the Government.]The Thames Tunnel project is therefore our preferred solution since itaddresses the problem of sewage entering the River Thames in the

most cost-effective way and within the required timescale. Our responseto the Selbourne Commission can be found on our websiteConsideration of the key issues raised by the Selbourne Commission isalso dealt with in section 5 of the Waste Water National PolicyStatement, Appraisal of Sustainability Post Adoption Statement, March2011.

- confirmation that it is the mostappropriate solution

-

- if experts consider that it is necessarythen agree with proposals

- ensuring that the chosen solution is ascheap as possible

In relation to the comment that the solution should be as cheap aspossible, we consider that the Thames Tunnel project is the most cost-effective solution. This is supported by a government report entitledCreating a River Thames fit for our future: A strategic and economic


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case for the Thames Tunnel, which contains an appraisal of alternativesolutions and concludes that a tunnel solution remains the mostappropriate.

- concerns raised regarding accuracy ofstorm water flows data being resolved A combined or storm sewer discharge is a combination of foul sewageand surface water runoff. It is classified as raw sewage because it is

untreated. The proportion of foul sewage in combined sewage is highlyvariable as it will depend not only on the intensity of the rainfall but willalso change throughout the duration of the rainfall event. This proportioncan typically vary from as high as 80 per cent foul sewage to five or tenper cent. However, when it rains and creates a first flush this will pickup the pollutants and materials from streets and the sediment already inthe sewer system. This means the pollutant load can be significant atthe start of a combined sewer discharge. The end of the discharge isless polluted but still contains foul sewage from peoples homes andbusinesses. Water quality pollution statistics from combined sewerdischarges can therefore be very variable and dependent upon rainfall,how dry it has been before the discharge and the source of watercontributing to the discharge.

- the proposed works not affecting theoperation of a telecoms switch facility The proposed switch facility is not currently located within closeproximity to our preferred route or sites, and therefore we do not

anticipate that the switch facility will be affected.

- ensuring that concerns of the

community are addressedAn integral part of the pre-application process is the legal requirement

that we consult with the communities and stakeholders in the vicinity ofthe tunnel route and the sites we intend to use in constructing andoperating the project, and that we take account of all the commentsreceived in response to consultation. We also need to have regard toguidance issued by the Secretary of State in respect of the pre-application consultation requirements. The process is intended to beopen and transparent and to ensure that project promoters give carefulconsideration to consultation responses and where necessary adjusttheir proposals accordingly. We are committed to this approach.

- costs not being borne by customers. While we understand the concerns of bill payers about the implicationsfor our wastewater charges, the way in which we are regulated meansthat a standard approach is adopted across the water industry. Majorimprovements to clean up rivers and beaches are paid for by thecustomers of the relevant water companies.

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 Objections, issues and concerns Respondent ID No. Our response

2.2.32 Do not agree that there is a need to reducethe amount of sewage entering the RiverThames.

7260LO, 8278LO, 9110LO, 11030, 11226,11372, 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,

34 The needs case for the Thames Tunnel project is set out in detail in theNeeds report, which is available on our website. It is also summarisedin a non-technical form in our publications Why does London need theThames Tunnel?and Why does Londons economy need the ThamesTunnel?. The need for the project has been confirmed and reaffirmed


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LR13390, LR13446, LR9136 both by the past and present Government. This was made clear inwritten Ministerial Statements to Parliament in September 2010 andagain in November 2011. Further reinforcement of the need for theproject is contained in the documents published by Defra in November2011 Creating a River Thames fit for our future: a strategic andeconomic case for the Thames Tunneland Costs and benefits of theThames Tunnel.

The National Policy Statement (NPS) for Waste Water, which was

designated on 26 March 2012, clearly states that the need for the projecthas been demonstrated. It concludes that detailed investigations haveconfirmed the case for a Thames Tunnel as the preferred solution. Thedesignation of the NPSwas supported by an Appraisal of SustainabilityPost-Adoption Statementwhich contains further detail on the significantamount of work undertaken to establish the need for the Thames Tunnelproject and assess alternative options, on the basis of which thegovernment considers the need for the project to be established.Having regard to the extensive work that has been undertaken since2000, as detailed in the reports mentioned above, we consider that theneed for the project has been clearly demonstrated.

Reasons included:

- there will be disruption and damage tothe quality of life of local residents

during the construction period

In relation to disruption caused by construction works, we have beenassessing the likely significant effects that may arise as a result of theworks as part of an environmental impact assessment. This will set outmeasures necessary to mitigate any significant adverse effects that areidentified. An Environmental statement, which records the findings of theenvironmental impact assessment, will accompany our DCO application.The initial environmental assessment work that has been carried out onthe project is contained within the PEIR, which is available on ourwebsite. As part of the phase two consultation, we also sought feedbackon the potential effects arising from our proposals and how the effectswill be mitigated. Where possible, we will take feedback comments intoaccount as we develop our proposals.

- no problems caused by sewage eitherby smell or sight have been noticed We recognise that water quality has improved and that in some locationsalong the River Thames, there may not be visible signs of water

pollution, although overflows from CSOs can result in visible litter beingdischarged into the river. Despite the improvements that have alreadybeen achieved, there is still an urgent need to reduce discharges ofuntreated 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 intothe River Thames can lead to fish kills due to the reduced levels ofoxygen in the river; the Thames Tunnel project is therefore required tocontinue to improve water quality. Also, as population increases, thefrequency of spills will increase, because the current capacity of theexisting sewage system is put under further strain.

- it would not be needed if maintenanceof the sewer network had beenundertaken

The existing sewers are generally in a good physical condition but theircapacity is inadequate. This project will provide the additional capacityrequired.


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- query why if this is an EU requirement,the project has only just commenced Regarding the timescale for the project, as set out above, optioneeringstudies commenced in 2000. Given the importance of meeting the

environmental objectives for the project and the complexity of theproposed solution, the evolution of the tunnel has been rapid comparedwith the time taken to develop other large London projects such asCrossrail, East London Line improvements and Thameslink 2000. Thetimetable for delivery of the Thames Tunnel project is set out in theTimingproject information paperand is the earliest possible delivery

given the construction work involved.

- the River Thames is able to removesewage naturally.

Due to the tidal nature of the River Thames, sewage discharged into theriver, is moved into the Channel. Depending on where the discharge intothe River Thames occurs, this process can take several weeks or evenmonths. While the River Thames is able to remove the sewage, it cannottreat the sewage or the effects on the environment and recreationalusers of the River Thames. The Thames Tunnel project will mean thatsewage captured by the main tunnel will be treated and effects on theenvironment etc arising from the discharges avoided.

2.2.33 This is not an essential project; the casefor a tunnel has to be proved rather than

just being desirable.

12752, 12959, 7252, 7321 4

For our response, refer to first two paragraphs of response contained inparagraph 2.2.32.2.2.34 Further clarification required regarding

whether this is a wish list rather than

essential project.

12267 1

2.2.35 More information about the extent of theproblem is needed.

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

12 The response at paragraph 2.3.32also applies to the objections, issuesand concerns raised within this paragraph. You may wish to consider theresponse at paragraph 2.3.32 as well as the text below.

Specific comments included:

- query which CSOs are most polluting The Environment Agency has categorised the CSOs into four groups,which are based on the environmental impact and frequency ofoperation. For further information on the four categories refer to chapterfour of the Needs report. Table 4.2 of this document also lists each ofthe CSOs and which category they fall into.

- query what can be done to treateffluence at sites like Mogden SewageTreatment Works, which are likely to bemore polluting than some of the CSOs

being intercepted

The discharges from Mogden Sewage Treatment Works are physicallyseparate from the Beckton and Crossness catchments, and thereforeany discharges within the Mogden catchment are in addition to the 39million tonnes which are discharged from 57 CSOs with the Beckton and

Crossness catchments. We are upgrading Mogden Sewage TreatmentWorks to increase its treatment capacity by around 50 per cent. This willsignificantly reduce both the quantity and the number of times we needto discharge storm sewage from the sewage treatment works into theRiver Thames following heavy rain.

Our records show that over the last 13 years, Mogden SewageTreatment Works has needed to discharge in to the River Thames on

just over 1,000 days. Many of those discharges were very small, with thetotal amounting to 77.7 million tonnes of storm sewage, acknowledgingthat all storm discharges were subject to some screening and


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settlement. This represents around five per cent of the total flow arrivingat the sewage treatment works. If the current improvements we aremaking had been in place, and assuming the same weather patternswere experienced, we estimate that the sewage works would only havedischarged in to the River Thames on a total of five occasions duringthose 13 years, following exceptional amounts of rainfall with dischargestotalling around 3.3 million tonnes. In the future, we would expect flowsreaching the sewage treatment works to overflow into the River Thames

about once every two and a half years. Improvements to the sewagetreatment works will mean that even where there are discharges, themost polluting flows will have been captured for treatment.

- query what the scale of the reductionthat would be achieved and ThamesWater's confidence at achieving this

As set out in Why does London need the Thames Tunnel, the ThamesTunnel project will result in the annual number of CSO discharges fallingfrom up to 60 a year to just four or fewer. If the Thames Tunnel projectwere not implemented, the annual average volume of all CSOdischarges to the River Thames would still be 18 million cubic metresand discharges would still occur nearly 60 times in a typical year, whichis still far too high.

- this is a reaction to 'freak' flash floodsover recent years The Thames Tunnel project is not a reaction to 'freak' flash floods inrecent years. The Thames Tideway Strategic Study (TTSS) was

established in 2000 to find a solution to an identified problem, namelyimpact of intermittent discharges of storm sewage in the Thames

Tideway, and to identify objectives for improvement and proposepotential solutions having regard to costs and benefits. Based on over adecade of analysis we consider that the Thames Tunnel project isnecessary to address this problem.

- query how accurate the figure of 39mtonnes is The quoted figure of 39 million cubic metres represents the spill in atypical year. The range is from 10 million cubic metres to 90 million

cubic metres. This is based on modelling, verified by monitoring andagreed with the Environment Agency.

- on how West Putney CSO was sampled The West Putney CSO was monitored through equipment placed in theoverflow sewer.

- an explanation of the surface area ofthe river which fails EU water standards(1) as a result of current CSO eventsand (2) as a result of the proposed

modifications is required

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 anappropriate metric to consider.

- query how much infiltration has affectedcapacity Infiltration has a limited effect on discharges which are caused byrainfall.

- on the maintenance condition of thesewers. The existing sewers are generally in a good physical condition

2.2.36 Should reduce volume of wastewaterentering the sewage system to addressthis problem by means of:

8807LO, 7468, 9357, LR9278 4 The response at paragraph 2.3.32 also applies to the objections, issuesand concerns raised within this paragraph. You may wish to consider theresponse at paragraph 2.3.32 as well as the text below.

The Needs reportconcludes that the installation of water meters and


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- installing individual water meters

- building regulations to ensure that newhousing includes water meters.

other water conservation measures will not be effective since they willnot reduce foul sewage flows to a sufficient extent to counteract theimpacts of population growth. In addition, as little as 2mm of rainfall canresult in a discharge into the River Thames. The installation of watermetres would not address rainfall which flows into the combined sewagesystem.

In relation to building regulations, these only affect new residentialbuildings that are built and do not apply to new buildings which are

constructed for other purposes or to the existing building stock. Inrespect of existing development, we also cannot control the amount ofwastewater entering the sewage network. As the population grows, sowill the amount of sewage.

Since the problem of sewage discharges results from both rainfall andwastewater entering the sewage system, this intervention alone will notaddress the problem.

2.2.37 Query whether the Thames Tunnel projectis really necessary to address the problem;it appears it is being installed to address anexpected future problem.

11038, 11456, 11502, 11686, 11798, 11955,12138, 7346, 7469

9 The case for the Thames Tunnel project has been demonstratedthrough various studies undertaken since 2000. The documents relatingto the needs case including the Needs reportare available on ourwebsite. The conclusions of the Needs reporthave been reinforced bythe Governments report Creating a River Thames fit for our future: Astrategic and economic case for the Thames Tunnel, which waspublished in November 2011. We therefore consider that the ThamesTunnel project is essential to address the problem.

The Thames Tunnel project is also necessary to address an existingproblem. The Needs reportconfirms that the existing sewerage systemdoes not have sufficient capacity to accommodate sewage and stormwater during periods of rainfall, which results in discharges into the RiverThames after as little as 2mm of rainfall.

2.2.38 Water quality in the River Thames hasalready improved significantly including asrecognised by the Greater LondonAuthority, Environment Agency and theTheiss River Prize.

13397LO, 8321LO, 9131LO, 10155, 11607,12231, 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

32 We recognise that the water quality of the tidal River Thames hasimproved. This is a result of investment by many bodies includingprojects on which we have worked with the Environment Agency asrecognised by the award of the Theiss River Prize.

Despite the improvements that have already been secured, there is stillan urgent need to reduce discharges of untreated sewage into the RiverThames to ensure compliance with the UWWTD and the Urban WasteWater Treatment Regulations 1994, which transpose the UWWTD intoUK legislation. Spills from CSOs into the River Thames can lead to fish

kills due to the reduced levels of oxygen in the river. Discharges canalso result in litter entering the River Thames, which given its nature,may affect the health of recreational users of the river. The ThamesTunnel 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 putunder further strain. The case for the tunnel is documented in the Needsreport.

2.2.39 It is not clear that there is a problem with 12419, 12525, 12821, 12824, 12902, 12937, 26 The response at paragraph 2.3.38also applies to the objections, issues


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water quality. Reasons included:

- it is not clear why this problem needs tobe addressed now

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

and concerns raised within this paragraph. You may wish to consider theresponse at paragraph 2.3.38 as well as the text below.

- query the validity of the water qualitypollution statistics

A combined or storm sewer discharge is a combination of foul sewageand surface water runoff. It is classified as raw sewage because it isuntreated. The proportion of foul sewage in combined sewage is highlyvariable as it will depend upon not only the intensity of the rainfall but willalso change throughout the duration of the rainfall event. This proportioncan typically vary from as high as 80 per cent foul sewage to five or tenper cent. However, when it rains and creates a first flush this will pi ckup the pollutants and materials from streets and the sediment already inthe sewer system. This means the pollutant load can be significant atthe start of a combined sewer discharge. The end of the discharge isless polluted but still contains foul sewage from peoples homes andbusinesses. Water quality pollution statistics from combined sewerdischarges can therefore be very variable and depend on rainfall, howdry it has been before the discharge and the source of water contributingto the discharge.

- the problem is with rubbish thrown intothe River Thames which is not fromCSO discharges.

While rubbish may be thrown into the River Thames, this is not the mainsource of pollution. Our response at paragraph 2.2.32 sets out why weconsider there is a need to reduce CSO discharges.

2.2.40 Whether the project necessary given that

the frequency of overflows and volume ofthe discharge is low. Particular commentswere raised in relation to:

- the proportion of rainwater to sewage indischarges; over 95 per cent ofdischarges is considered to berainwater

- the construction of the Lee Tunnel willaddress 21 out of the 39 million tonnesof combined sewage entering the RiverThames.

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 notconsider this to be low.

Once rainwater and sewage is mixed within the sewerage system, itbecomes combined sewage and is inseparable. It is therefore classifiedas raw sewage because it is untreated. The proportion of foul sewage incombined sewage is highly variable as it will depend upon not only theintensity of the rainfall but will also change throughout the duration of therainfall event. This proportion can typically vary from as high as 80 percent foul sewage to five or ten per cent. Therefore, even if the proportionof foul sewage is relatively low it still needs to be treated.

As set out in Why does London need the Thames Tunnel, if the ThamesTunnel project is not implemented, the annual average volume of allCSO discharges to the River Thames would still be 18 million cubicmetres and discharges would still occur nearly 60 times in a typical year.This is still too high to meet the objective of securing compliance withthe UWWTD.

2.2.41 Insufficient information has been providedon the extent of the problem.

8779 1 We consider that we have undertaken a thorough and comprehensiveconsultation exercise. As part of this, we carefully considered theinformation we made available at our phase two consultation to ensurethat consultees had sufficient information to respond to the consultation.The need for the project is described and illustrated in the phase twoconsultation material including the Overflowproject information paper,which provides an overview with more detail in the Needs report. We areconfident therefore that the information we have provided is sufficient.


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In particular, the need is not so much toreduce the amount of sewage as to reducelocal concentrations and adverse effects.

We disagree that the need is not about the amount of sewage. We areunable to influence the extent of dilution that is available as this is due tofreshwater river flows and tidal movement. Hence, the need isassociated with the volume of discharges and the adverse impact thishas on the River Thames.

2.2.42 There are other more pressing issues todeal with including flooding, repairs towater supply pipes/upgrade works and thehose pipe ban. The latter could beaddressed through provision of a reservoir.

8647, 8737, LR13408 3 We have a range of duties to the environment and our customers andwe have consistently given high priority to leakage of clean water andpreventing flooding. The existing sewers are generally in a goodphysical condition but their capacity is inadequate.

We are regulated by Ofwat, who determines our priorities for futurework. A careful balance is therefore sought between maintaining existinginfrastructure and, where necessary, improving our infrastructure againstthe costs of not doing so. We are not always allowed to spend thefunding as we would like, for instance, our programme of VictorianMains Replacement works, which addresses leakage, was not fullyfunded in the 2010 price review. But this does not mean that suchimportant 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 alsoimportant. Thames Water is large enough to deal with multiple issues. Itis, however, a regulated utility and we are only allowed to spend certainamounts on Victorian Mains Replacements. With regard to the

comment relating to reservoirs. Thames Water has recently sent its draftfinal Water Resource Management Plan for the period 2010-2035 to theSecretary of State. This no longer selects a reservoir in the preferredscheme for the London Water Resources zone, but further work todefine the yield, cost, and on-going risks will be carried out for our nextplan, which is to be submitted in 2014.

2.2.43 Work will delay other necessaryimprovements.

8806LO 1

2.2.44 Need to address the amount of sewageentering the River Thames is not properlyevidenced.

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

12 The response at paragraph 2.3.32 also applies to the objections, issuesand concerns raised within this paragraph. You may wish to consider theresponse at paragraph 2.3.32 as well as the text below.

Reasons included:

- there do not appear to be valid financialor ecological reasons

Despite the improvements that have already been secured, there is stillan urgent need to reduce discharges of untreated sewage into the RiverThames to ensure compliance with the UWWTD and the Urban WasteWater Treatment Regulations 1994, which transposes the UWWTD intoUK 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 improvewater quality. Also, as population increases, the frequency of spills willincrease, because the current capacity of the existing sewage systemwill be put under further strain.

Furthermore, on 26 March 2012 the Government designated the WasteWater National Policy Statement. This reaffirms that it i s governmentpolicy for the Thames Tunnel project to be taken forwards. Paragraph2.6.34 states: "The examining authority and the decision maker shouldundertake any assessment of an application for the development of the


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Thames Tunnel on the basis that the national need for this infrastructurehas been demonstrated. The appropriate strategic alternatives to atunnel have been considered and it has been concluded that it is theonly option to address the problem of discharging unacceptable levels ofuntreated sewage into the River Thames within a reasonable time at areasonable cost."

- there is insufficient historical data whichsupports undertaking a project of this

scaleAs part of the TTSS a modelling group was established. The work ofthis 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 isagreed with the Environment Agency.

- new information has emerged; theforecasted need is therefore out of date In February 2012 Defra undertook a review of the need from a scientificperspective. Their publication Thames Tunnel Evidence Assessment

indicates that the any limited shortfalls in the evidence base could easilybe corrected and that they do not fundamentally affect the widerconclusions that support a tunnel solution. In March 2012 the WasteWater National Policy Statement that supports a tunnel solution wasdesignated by the Government following a debate in Parliament. Theneed is therefore current and has recently been reaffirmed.

- concern that Thames Water is notmeasuring full depth flows at the CSOsbut at a single manhole prior to theoverflow.

Monitoring equipment is place in the sewer beneath a manhole as isstandard practice and captures the complete flow. To place it too closeto the river would be at risk of picking up incoming tidal flow.

2.2.45 The cost of addressing this problemoutweighs the benefits. Reasons for thisincluded:

- it is a disruptive proposal

- public health, recreational and safetybenefits are negligible

- water quality has improved substantiallyover recent years.

LBHF, 7331LO, 7156, 7394, 7422, 8411,8459, 8531, 8673, LR9418

10 Cost benefit analysis has already been undertaken, which showed that astorage and transfer tunnel option, combined with improvements atsewage treatment works and the Lee Tunnel had the highest netbenefits. This work informed the Ministerial Statement in March 2007and the request that we develop a tunnel solution. The Government hasundertaken further cost benefit analysis (set out in Creating a RiverThames fit for our future: a strategic and economic case for the ThamesTunnel), which informed the Ministerial Statement in November 2011, inwhich the Secretary of Statement said: "we continue to believe that atunnel represents the preferred solution for dealing with the untreatedsewage that is polluting the River Thames . As the project develops, wehave been and will continue to be closely scrutinised by the industryeconomic regulator Ofwat and by Defra.

The disruption caused by the proposal has been raised. This wasassessed by government as part of its cost benefit analysis, where itconcluded that the tunnel represents the preferred solution. We havealso been assessing the likely significant effects that may arise as aresult of the works as part of an environmental impact assessment. Thiswill set out measures necessary to mitigate any significant adverseeffects that are identified. An Environmental statement, which recordsthe findings of the environmental impact assessment, will accompanyour DCO application.The initial environmental assessment work thathas been carried out on the project is contained within the PEIR, whichis available on our website. As part of the phase two consultation, wealso sought feedback on the potential effects arising from our proposals


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and how the effects will be mitigated. Where possible, we will takefeedback comments into account as we develop our proposals.

As a responsible organisation, we need to ensure that pollution in theRiver Thames is at an acceptable level. We do not consider that thepublic health, recreational and safety benefits which will be derived fromthe Thames Tunnel project are negligible. Furthermore, the recreationaland public health benefits were considered by the Environment Agencywhen identifying the CSOs that need to be intercepted. For further

details on the benefits of the Thames Tunnel project, refer to the Needsreport.

In relation to water quality, we recognise it has improved over recentyears. Despite the improvements that have already been achieved,there is still an urgent need to reduce discharges of untreated sewageinto the River Thames to ensure compliance with the UWWTD and theUrban Waste Water Treatment Regulations 1994, which transpose theUWWTD into UK legislation. Spills from CSOs into the River Thamescan lead to fish kills due to the reduced levels of oxygen in the river.Discharges can also result in litter entering the River Thames, whichgiven its nature, may affect the health of recreational users of the river.The Thames Tunnel project is therefore required to continue to improvewater quality. Also, as population increases, the frequency of spills willincrease, because the current capacity of the existing sewage systemwill be put under further strain.

2.2.46 The need can be addressed throughexisting projects such as upgrade works tothe sewage treatment works includingMogden Sewage Treatment Works and theconstruction of the Lee Tunnel. Inparticular, in the recent EU court case, theresolution mostly related to dischargesfrom the sewage treatment works and notthe CSOs.

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

19 The TTSS established in 2000, led to three proposals being proposed toaddress discharges into the Crossness and Beckton catchments. Theseinclude: upgrades to sewage treatment works; the Lee Tunnel; and theThames Tunnel project. Without these interventions, annual CSOdischarges into the River Thames would reach 70 million cubic metres ina typical year by 2020. If the Thames Tunnel project is not constructed,the annual average volume of all CSO discharges to the River Thameswould remain at 18 million cubic metres, which is too high. Furtherinformation is available in the Needs reportand Why does London needthe Thames Tunnel.

Infraction proceedings relate to discharges of wastewater from CSOsinto the River Thames in respect of the Beckton and Crossnesscatchments. The European Commission has proceeded with infractionproceedings against the UK Government with respect to this matter. Thedecision of the court has not yet been issued, but it has the power toseek fines consisting of a lump sum and a periodic penalty, which couldamount to considerable sums. It is therefore necessary for action to betaken to avoid such penalties being applied for future non-compliancewith the UWWTD.

In relation to Mogden Sewage Treatment Works, the discharges arephysically separate from the Beckton and Crossness catchments, andtherefore any discharges within the Mogden catchment are in addition tothe 39 million tonnes which are discharged from the 57 CSOs. We areupgrading Mogden Sewage Treatment Works to increase its treatment


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capacity by approximately 50 per cent. This will significantly reduce boththe quantity and frequency of storm sewage discharges from thesewage treatment works into the River Thames following heavy rain.

Our records show that over the last 13 years, Mogden SewageTreatment Works has needed to discharge in to the River Thames on

just over 1,000 days. Many of those discharges were very small, with thetotal amounting to 77.7 million tonnes of storm sewage, acknowledgingthat all storm discharges were subject to some screening and

settlement. This represents around five per cent of the total flow arrivingat the sewage treatment works. If the current improvements we aremaking had been in place, and assuming the same weather patternswere experienced, we estimate that the sewage works would only havedischarged in to the River Thames on a total of five occasions duringthose 13 years, following exceptional amounts of rainfall with dischargestotalling around 3.3 million tonnes.

In the future, we would expect flows reaching the sewage treatmentworks to overflow into the River Thames approximately once every twoand a half years. Improvements to the sewage treatment works willmean that even where there are discharges, the most polluting flows willhave been captured for treatment.

2.2.47 The relationship of the project to theUWWTD is not fully understood.

12458 1 The UWWTD contains the European Unions requirements concerningthe collection, treatment and discharge of wastewater. The requirementsof the UWWTD have been transposed into domestic legislation by theUrban Waste Water Treatment Regulations 1994. In terms of the tidalThames and River Lee, compliance with the UWWTD requires thatsewage (domestic, industrial and rainwater run-off) is collected andconveyed to plants for secondary treatment, overflows are reduced andmeasures taken to limit pollution of the tidal Thames and the River Leefrom CSOs.

The European Commission (EC) is taking action against the UK foralleged breach of the UWWTD in respect of discharges of untreatedsewage into the River Thames. Under article 258 of the Treaty ofLisbon, the EC has powers to take legal action when it considers that amember state is not respecting its obligations under the UWWTD. TheEC issued a reasoned opinion on 26 January 2012 about the significantrepeated discharges of untreated sewage into the River Thames. On 16June 2010 the EC launched legal proceedings before the EuropeanCourt of Justice for alleged failure to comply with obligations under theUWWTD in relation to discharges of urban wastewater into the Thames.An oral hearing was held on 10 November 2011 and, on 26 January2012, the Advocate General issued an opinion which recommends thatthe court should declare that the UK Government has failed to complywith requirements of the UWWTD.

While the Advocate Generals opinion recognises that the UKGovernment intends to install a storage and transfer tunnel to addressoverflows into the River Thames, the proposed action against theGovernment is to be taken against previous unacceptable discharges

2.2.48 The European Commission, rather thanscientific need, is driving the project.

12696, 13048, 7277, 7637, 8779, 8820,8861

7

2.2.49 The only real justification for reducing theamount of sewage entering the RiverThames is to avoid regulatory fines fromthe EU. Concern that there have not beendiscussions with the EC about whether theproposed action is sufficient to meet theUWWTD and Water Framework Directive.

7208, 7209, 7843, 8472, 9446 5

2.2.50 We should ignore the requirements of theUWWTD.

8887LO, 7497, 9186 3


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into the River Thames. The decision of the court has not yet beenissued, but it has the power to seek fines consisting of a lump sum and aperiodic penalty, which could amount to considerable sums. It istherefore necessary for action to be taken to avoid such penalties beingapplied for future non-compliance with the UWWTD.

In November 2011, the Secretary of State for Environment, Food andRural Affairs, in a written Ministerial Statement, said: "the need toupgrade the sewerage system in London which in places is running out

of capacity even in dry weather, and for a solution to the resultingenvironmental challenges in the Thames Tideway remains persuasive. Iwill today place in the Libraries of both Houses a paper Creating a RiverThames fit for our futuresummarising the strategic and economic casefor the Thames Tunnel project. This builds on the impact assessmentproduced in 2007. It explains why we continue to believe that a tunnelrepresents the preferred solution for dealing with the untreated sewagethat is polluting the River Thames . Some of the issues identified in thisdocument include the scientific justification based on research fromrelevant academics, for example the impact on fisheries.

2.2.51 Not aware of phase one consultation. 7361, 7383 2 Phase one consultation was undertaken between 9 September 2010and 14 January 2011. We publicised our phase one consultation inaccordance with our Statement of community consultation (SOCC);methods included an advertisement in the London Evening Standardand local newspapers, sending letters to over 173,000 properties,

holding exhibitions in the vicinity of preferred and shortlisted sites andprovision of written material at exhibitions, on our website, at locallibraries and town halls and on request. 2,866 individuals andorganisations responded to phase one consultation, the findings fromwhich are contained in our Report on phase one consultation.

Where new sites have been brought forward at phase two consultationthere is still the opportunity to comment on all the matters raised inphase one consultation. Therefore we do not consider that respondentswho were not aware of phase one consultation have beendisadvantaged in any way.

2.2.52 Commented on the need for the project atphase one consultation.

9109LO, 7157, 7339, 8728, LR9114 5 Your comment is noted. Comments submitted as part of phase oneconsultation have been taken into account. Refer to our Report onphase one consultationfor further details.

2.2.53 Other issues, concerns and objections

raised included:

- query whether heavy fines would beimposed. The scale of any potentialpenalties to the UK and the likelihood offines being applied in the current fiscalenvironment appear overstated.

-

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

9467

7 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 theseriousness and duration of the breach, as well as the size of thecountry involved. Fines are calculated using equations that consider theduration and seriousness of the infringement and the individualMember States capacity to pay. The maximum daily penalty paymentthat could currently be imposed on the UK is 620,000 per day. Theminimum size of a lump sum payment that could currently be imposedon 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.

- Thames Water is deliberately Providing a balanced analysis in our consultation material was


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misinforming the public of the need fortheir preferred solution

imperative and we do not agree that the material was inaccurate ormisleading. All the material presented contained necessary informationfor consultees to understand our proposals and make their own

judgements.

- the desired standards which the projectis being measured against have notbeen justified

Environmental objectives were developed in the TTSS. For furtherdetails of how the objectives were established refer to the TTSS, whichis on our website.

- do not agree that London's internationalreputation is being damaged by currentlevel of water quality

It is the view of government, as stated for example in the publicationCreating a River Thames fit for our future: A strategic and economiccase for the Thames TunnelNovember 2011, that there is an adversereputational impact on London as a result of the discharges to theThames. It states that building the Thames Tunnel project will ensurethat the UKs capital remains a flourishing tourist destination that isattractive for business, protecting the Londons reputation around theworld.

- it is the rate of discharge and highestsingle event volume of discharge,adjusted for population growth andglobal warming event predictions thatshould be used in the projects designassessment.

Future predications of discharges are adjusted for population growth andclimate change.

2.3 The solution2.3.1 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 twoconsultation). 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 commentsreceived 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 hadcomments 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 RiverThames (Q10)

Respondent type Number of respondents

Comments No comments No response

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)

1

- EnvironmentAgency (EA)

11


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- 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)

1

- OlympicDeliveryAuthorityPlanningDecisions

Team (ODAPDT)

9

Landowners 52 22 59

Community consultees 2,785 506 2,548

Petitions 1

- 256 signatories

0 8

Total 2,854 530 2,635

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 entersthe tidal River Thames


2.3.2 The tunnel is the right solution, in particularbecause alternatives are not viable.

See annex B of this report 771 We agree. Analysis has already been undertaken as part of the ThamesTideway Strategic Study (TTSS) and subsequent studies, which showedthat a storage and transfer tunnel option, combined with improvementsat sewage treatment works, had the highest net benefits includingimprovements to water quality and other environmental benefits, that itwill cause less disruption than other alternatives investigated and offers

a long-term solution to the problem. This work informed the MinisterialStatement in March 2007 and the request that we develop a tunnelsolution. The Government has also recently published a report entitledCreating a River Thames fit for our future: A strategic and economiccase for the Thames Tunnel. This report provides an update to the 2007regulatory impact assessment and takes into account data that hasemerged since that time and concludes that a tunnel solution remainsthe most appropriate and cost-effective of the solutions considered.

The National Policy Statement (NPS) for Waste Water, which was

2.3.3 The tunnel is the most practical andreasonable solution.

LBW, 7147, 7264, 7290, 7735, LR13473 6

2.3.4 The tunnel would be less disruptive than

installing a separate sewage system.

7761, 8450 2

2.3.5 The tunnel offers a long-term solution. 7777, 8098, 8399, 8541 4

2.3.6 The tunnel is the most sensible solution. 7445 1

2.3.7 The tunnel is the most effective andefficient solution. In light of this, theLondon Plan also expresses specificsupport for the principle of the ThamesTunnel project.

GLA, 11591, 7198, 7530, 7800, 7801,7855, 8188, 8399, 8741, 9282

11


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on safeguarded wharves

- respondents welcome any interventionby the Government that reduces thepotential financial impact on ThamesWaters customers via the WaterIndustry (Financial Assistance) Bill

- it is least disruptive to the fabric of thecity.

- the cost of the Thames Tunnel project,and the time for development andcommissioning, is dwarfed by thepotential cost, disruption and time forimplementation of other options whichhave been examined.

- respondents realise that to improve theRiver Thames we are all going to haveto make sacrifices including putting upwith building disruption and increases incustomer water bills

- respondents agree with the conclusionsof the TTSS that the most practical andfinancially viable solution for Londonwould be to intercept the CSOs with anew tunnel system as currentlyproposed

- the alternative solutions would not meetthe logistical, environmental andfinancial criteria and are therefore easilyruled out

- respondents recognise in particular thatthe North East Storm Relief at KingEdward Memorial Park is an importantsource of storm flows and certainlyneeds to be intercepted.

- it will enhance the long-term image fortourism, employment, all residences andbusinesses which operate on or near the

River Thames.2.3.21 Not qualified to comment on this technical

matter.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 thosewith an interest in the project think about our proposals. We will haveregard to comments received from both technical and non-technicalconsultees.


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8104, 8111, 8313, 8496, 9063, 9067, 9089

2.3.22 No comment. NERL, HA, (LR)DoC, ODA PDT, SDC,LBH, LBWF

7

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 entersthe tidal River Thames


2.3.23 Agree that a tunnel is the right solution butdo not agree with use of greenfield sites toconstruct and operate the project.

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

46 The sites that we consulted on at phase two consultation have beenidentified through an extensive site selection process (see our Siteselection methodology paperon our website). We consulted and agreedthe methodology prior to its use with key stakeholders includingpotentially directly affected local authorities and utilised amultidisciplinary approach to assess potential CSO sites and maintunnel sites, and main tunnel/connection tunnel drive options, againstengineering, planning, environmental, property and communityconsiderations.

Whether a site is brownfield or greenfield/open space was taken intoaccount along with other considerations as set out in the Site selectionmethodology paper. However, given that we had a limited search area toidentify suitable CSO and main tunnel sites, we did not consider it was

appropriate to exclude sites based on whether they were brownfield orgreenfield/open space when compiling our long-list of sites.

2.3.24 Agree that a tunnel is the right solution butworks should take place on brownfieldsites.

13494LO, 13476, 7744, 7842, 7884, 7886,8202, 8792, 9137, 9166, 9339, 9365

12

2.3.25 Agree that a tunnel is the right solution butdo not agree with the preferred sites/siteselection.

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

57 The sites that we consulted on at phase two consultation have beenidentified through an extensive site selection process (see our Siteselection methodology paperon our website). We consulted and agreedthe methodology prior to its use with key stakeholders includingpotentially directly affected local authorities and utilised amultidisciplinary approach to assess potential CSO sites and maintunnel sites, and main tunnel/connection tunnel drive options, againstengineering, planning, environmental, property and communityconsiderations.

We recognise that, given the locations where we are seeking toconstruct and operate the tunnel, many of the shortlisted sites areconstrained. However, based on our assessment we consider that, onbalance, our preferred sites are the most suitable.

For further details on the results of the site selection process, refer to thePhase two scheme development report.

2.3.26 Unsure whether the tunnel is the correctsolution, but do not agree with preferredsites.

11285, 11390, 11509, 11898, 12020,12256, 13136, 13205, 7143, 7544

10

2.3.27 Agree that a tunnel is the right solution butdo not agree with the tunnelroute/alignment.

8303LO, 13469, 7496 3 As set out in the Route and tunnel alignment project information paper,the Abbey Mills route remains our preferred route because: it is theshortest route; it is the least disruptive and most cost-effective option,costing 20 per cent less compared to the other two options, while stillmeeting all the required environmental objectives; it requires the leastnumber of worksites; and it requires less tunnelling at depth throughchalk in the east. Deep tunnelling through chalk is potentially more


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difficult and would bring greater health and safety issues.

2.3.28 Agree that a tunnel is the right solution butconcerned about the impact of the projectduring construction.

7799LO, 8277LO, 7556, 7768, 8655, 9337 6 We have been assessing the likely significant effects that may arise as aresult of the works as part of an environmental impact assessment. Thiswill set out measures necessary to mitigate any significant adverseeffects that are identified. An Environmental statement, which recordsthe findings of the environmental impact assessment, will accompanyour DCO application.The initial environmental assessment work thathas been carried out on the project is contained within the PEIR, which

is available on our website. As part of the phase two consultation, wealso sought feedback on the potential effects arising from our proposalsand how the effects will be mitigated. Where possible, we will takefeedback comments into account as we develop our proposals.

The programming of works at all sites will be configured to minimise theduration of works and associated disruption to the local area wherepossible. The length of the construction period as set out in theconsultation documents was the period assessed in the PEIRthat workswould be underway and it is hoped that in many cases there will beperiods during which there will be no activity or less intensive activity onsome sites.

2.3.29 Agree that a tunnel is the right solution butthe project should seek to minimise theimpact on the environment.

13115, 7137, 7223, 8502, 8720, 9079 6

2.3.30 Agree that a tunnel is the right solution butduring construction the project shouldavoid/seek to minimise the impact on

residents/residential areas.

11335, 11583, 11697, 12466, 12871,13070, 13126, 7006, 7135, 7137, 7241,7477, 7518, 7661, 7881, 7971, 8026,

8521, 8747, 8759, 8966, 9012, 9125, 9488

24 We recognise that the construction of the Thames Tunnel project mayresult in some disruption. We have been assessing the likely significanteffects that may arise as a result of the works as part of an

environmental impact assessment. This will set out measuresnecessary to mitigate any significant adverse effects that are identified.An Environmental statement, which records the findings of theenvironmental impact assessment, will accompany our DCO application.The initial environmental assessment work that has been carried out onthe project is contained within the PEIR, which is available on ourwebsite. As part of the phase two consultation, we also sought feedbackon the potential effects arising from our proposals and how the effectswill be mitigated. Where possible, we will take feedback comments intoaccount as we develop our proposals.

2.3.31 Should avoid residential areas. 11275, 13054, 13055, 7846, 8857, 8884 6

2.3.32 Agree that a tunnel is the right solution butworks should not affect communityfacilities.

8759 1

2.3.33 The tunnel must deliver long-term benefitsincluding recreational benefits.

7784, 7842, 9031 3 Cost benefit analysis has already been undertaken, which showed that astorage and transfer tunnel option, combined with improvements atsewage treatment works and the Lee Tunnel had the highest netbenefits. One the benefits if improved water quality which will alsobenefit recreational users of the River Thames. This and other work,

including the conclusions of the TTSS, informed the MinisterialStatement in March 2007 and the request that we develop a tunnelsolution. The Government has since undertaken further cost benefitanalysis, which informed the Ministerial Statement in November 2011, inwhich the Secretary of Statement said: "we continue to believe that atunnel represents the preferred solution for dealing with the untreatedsewage that is polluting the River Thames." As the project develops, wehave been and will continue to be closely scrutinised by the industryeconomic regulator Ofwat and by Defra.

In relation to recreational benefits, the proposed works will secure long-


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term benefits in terms of the water quali ty of the tidal River Thames andthereby reduce the risk of harm to river users.

2.3.34 The tunnel must achieve a high standard ofdesign.

13070, 7690 2 As set out in the Design project information paper, we want our designsto be of high quality and provide value to the local community, while alsohaving regard to cost. We aim to ensure that the designs respect eachsite's individual location and setting, while recognising the commonfunction 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 Designdevelopment reportalso sets out the process we have followed toachieve good design.

2.3.35 The tunnel must employ local people. LR9154 1 We estimate that the tunnel would directly employ about 4,250 people inconstruction and related sectors, as well as providing further secondaryemployment. We actively support the Crossrail Tunnelling andUnderground Construction Academy, which is currently training andgaining employment for 70 apprentices a year. As set out in ourpublication Why Does Londons Economy Need the Thames Tunne ltheThames Tunnel procurement process will aim to deliverbusinessopportunities for small and medium sized enterprises as well as utilisinglocal products, services and labour through the supply chain wherepossible. Any such targets will be subject to market sounding to ensuretheir commercial viability and compliance with EU regulations. We aimto meet a target on employing in excess of 20 per cent local labour.

2.3.36 In addition to the tunnel, othercomplementary measures need to beintroduced including sewer improvements,drain clearance, measures to reduce hardsurfaces including residents concretingover their gardens.

11660, 12070, 7160, 8029 4 In addition to the Thames Tunnel project, other improvement works arebeing undertaken to address overflows within other parts Beckton andCrossness catchments. These comprise primarily of the Lee Tunnel andimprovements to sewage treatment works.

We are also working with the Environment Agency, Greater LondonAuthority and other stakeholders on complementary measures. We areinvolved in the formulation of local development plans in which we pressfor policies that reduce water use and encourage the development ofSuDS. We hold education campaigns such as the bin it, dont block itcampaign to encourage customers to reduce waste flushed down toiletsas well as reducing cooking far poured down sinks.

We fully support the use of SuDS in new developments but the scale ofthe problem is such that SuDS cannot address the issue withoutmassive land take and excessive cost.

We have investigated the feasibility of separating the sewerage systeminto two systems: one for foul sewage and another for storm sewage.This was considered as one alternative by the TTSS and more recentlyreported in the Needs report(appendix D). Separating the combinedsystem would involve building a second pipe and making sure that allconnections from buildings and roads are connected into the correctsystem.

Construction of a separated system would be extremely disruptivethroughout London and would entail digging deep trenches in most

2.3.37 In addition to the tunnel, other supportinginitiatives should be introduced includingsustainable urban drainage systems(SuDS), improved filtration on CSOs,education initiatives and separation ofsewers. Thames Water should develop aSuDS strategy to become the fourth part ofthe London Tideway Improvement Works.

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

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Documents

Supp Report on P2 Consultation - Chapter 2 Need Solution Route Alignment