Tuesday 6 March 2012

Simon Hughes MP's response to the Thames Tunnel Phase 2 consultation

Essential reading for those interested in the issue, I have copied the response from Mr Hughes' own web site, although I have removed the part of it in which he considers the possibility of the review panel finding that the full Thames Tunnel is the best approach, which I hope it won't, but we'll have to wait and see...
By the way, strangely enough, the link with the information about the Thames Water own's study on alternatives to the super sewer is no longer valid (I wonder why), so if someone reads this (hope is the last thing I will lose) and wants to find out more about it, then use google and good luck with it...

February 13, 2012 1:00 PM
Simon Hughes, MP for Bermondsey and Old Southwark, this week submitted his response to the Thames Tunnel Phase 2 consultation, in which he proposes an independent review of whether a long tunnel remains the best approach to meet the environmental objectives that have been defined for the Thames.
Consultation Response from Simon Hughes MP
  1. 1. Justification for the tunnel
1.1 I welcome the opportunity to respond to Thames Water's Phase Two consultation and I refer you to my submission to Thames Water's Phase One consultation.
1.2 As then, I make this reply as a resident of Bermondsey and as the Member of Parliament since 1983 for the northern part of the borough of Southwark - which runs from the Oxo Tower just upstream of Blackfriars Bridge to just downstream of Greenland dock.
1.3 I strongly agree we need significantly to reduce the amount of untreated sewage entering the river Thames. Under EU law, the UK is required to end the release of raw sewage into UK waterways by 2020. I am aware that the problem arises along the Thames when there is heavy rainfall: the existing Victorian sewer system cannot cope and so the rainwater mixes with the sewer and uses the overflows into the Thames. The UK must comply with EU law and the EU Urban Waste Water Treatment Directive (UWWTD), as well as the UK's urban waste water treatment regulations. It is embarrassing that we are the subject of infraction proceedings initiated by the EU authorities because of our national failure to comply with our legal obligations. The population of London will continue to grow and thus the amount of sewage will increase. As a Member of Parliament for nearly 29 years for a constituency which includes a significant part of the south bank of the Thames, I know how unpleasant it is for untreated sewage to be released into the river and for the debris from time to time to appear on the foreshore.
1.4 When I made my submission to the Phase One consultation, I worked from the basis that the Thames Tideway Strategic Study (TTSS), the previous Labour government and both Labour and Conservative administrations at City Hall had been supportive of Thames Water's plans for a full length storage and transfer tunnel. In my previous submission I said that I was aware that there are arguments that it would be better to seek Sustainable Urban Drainage Systems (SuDs), and I requested Thames Water to carry out a final assessment of the alternatives to a tunnel before proceeding with the full length tunnel option. I also noted that constituents of mine are concerned that alternatives should be considered one last time in case they provided an environmentally preferable option. I note that Thames Water did produce a substantive report on alternatives as part of their preliminary environmental information report series which was published 2 November 2011 and is available on their website.
1.5 Since Thames Water launched their Phase Two consultation, I have met with representatives of Thames Water, the Save King's Stairs Gardens Action Group, the Save Your Riverside Action Group, and many other constituents at both public and community meetings and in smaller groups, as well as attending the Thames Tunnel Now launch event at Parliament. I have heard the breadth of support and opposition to the plans for a full tunnel. Although I agree with the central argument of the Thames Tunnel Now campaign that action is urgently needed to clean up the Thames, it is not clear to me that all the members who are affiliated to the campaign have carefully considered any or all alternatives to the full tunnel. Out of the 15 groups which make up the Thames Tunnel Now campaign, Thames Water partially funds at least three of these groups: Thames 21, Rowers against Sewage and the River Thames Society.
1.6 I am now clear that, since the end of the first round of consultations in 2011, the arguments for a review of the full tunnel proposal and possible alternatives have substantially increased. There has been a growing amount of opposition against the full tunnel from my constituents and other constituents in greater London. As a London and Southwark Member of Parliament, I should give the views of residents in our local communities and the views of other locally elected representatives proper weight - and I will therefore do so.
1.7 When Thames Water went out to their first consultation, I was already aware of the Jacob Babtie report commissioned by the water regulator (Ofwat) and published in 2006, which raised serious concerns about the validity of a full length tunnel and argued that a shorter tunnel for the west of London should be explored. However, the evidence which has tipped the balance for me, from clarity that the full tunnel is the right solution to the view that there is a much more evenly balanced argument, is the succession of reports published over the last 12 months raising questions over the full tunnel. These began with the Fourth Report of the House of Commons Environment, Food and Rural Affairs Committee (the EFRA report) dated 30th March 2011. Paragraph 65 of this report says:
"The brief sections in the National Policy Statement (NPS) on the replacement of the Deephams Sewerage Works and the Thames Tunnel are not sufficient to prove the need for these large-scale projects, in particular the multi-billion pound Thames Tunnel project which will have impacts over a period of years on the lives and livelihoods of people working locally. Nor do the sections on the alternative approaches sufficiently address all of the potential objections for achieving desired outcomes such as improved water quality. We recommend above that site-specific material is not included in the main NPS but it is important that Defra ensures that wherever such information is used it is complete."
Paragraph 66 says:
"We recommend that Defra include in any justification of new waste water infrastructure projects full information as to how they will help to meet national and European environmental requirements. The Department should also provide more detail on the potential alternative methods of achieving environmental outcomes such as improved water quality, which new infrastructure is designed to achieve."
The conclusions of the report:
1) The draft NPS should not have been published for consultation or scrutiny until more complete. This NPS should not be designated until those deficiencies are corrected, and;
2) Given the importance of delivering waste water and water quality objections we recommend that it be subject to a debate on the floor of the House of Commons on an amendable motion prior to designation.
1.8 Next in time came the Thames Tunnel Commission report (the Selborne Report) in October 2011 which recommended the reconsideration of the full tunnel.
1.9 In December 2011, Professor Chris Binnie produced a personal review of the Tunnel proposal which supports the option put forward in the Jacob Babtie report for a shorter tunnel in the west of London with additional complementary measures.
1.10 Most recently, in February 2012, the government published their NPS for Waste Water. Information about the Thames Tunnel contained in the annex at A.1.3 and the assessment of the need for new waste water infrastructure including the Thames Tunnel is assessed in sections 2.5 and 2.6. I am aware that the conclusion reached in the NPS in paragraph 2.6.33 and 2.6.34 is that the government considers that detailed investigations have confirmed the case for the Thames Tunnel as the preferred solution, that the appropriate strategic alternatives to the tunnel have been considered and that 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.
1.11 In spite of this most recent conclusion by the government, it is my judgement that there are growing doubts about the full tunnel proposal on environmental grounds, and increasing concern about the costs of the full tunnel. The costs are now projected to be higher than ever and therefore to have a greater long-term impact on the budgets of all Thames Water ratepayers, not just my constituents in Southwark but throughout greater London and beyond.
1.12 At the time of the TTSS recommendation, the estimated cost of the Thames tunnel was £1.7bn. Thames Water now estimates that the full tunnel will cost £4.1bn at 2011 prices, and this excludes the cost of the Lee tunnel which is due to be completed in 2015 at a cost of £635m.
1.13 Costs have seen a significant increase even in the short time since the Phase One consultation in 2010/11 at which time Thames Water estimated the cost of its preferred route at £3.6bn at 2008 prices. At this price, it was estimated that Thames Water ratepayers would have to pay an additional £60-£65 on their annual water bills from 2012. Revised modelling which puts the total cost of the full tunnel at £4.1bn sees ratepayers' bills increasing by an additional £70-£80 annually.
1.14 Concerns among Thames Water ratepayers have been further compounded by the financial history of Macquarie Bank which is the majority owner of Thames Water and which appear to be driven by maximising profit rather than keeping costs to a minimum. The announcement in December 2011 that Abu Dhabi Investment Authority had acquired 9.9 per cent of Thames Water from a consortium of investors led by Macquarie Bank and the sale in January 2012 of an 8.68 per cent share in Kemble Water, the holding company that owns Thames Water, to the China Investment Corporation has added to these concerns. The fact that
Thames Water like many other water providers is now in effect private utility monopoly causes further worries about the additional charges ratepayers will pay; this worry is not greatly mitigated by the regulatory powers of Ofwat to approve charges and charge increases. Public accountability of private water companies is clearly less effective than of the public water companies of previous periods.
1.15 Given that the full tunnel is such a large and increasingly expensive project, it is even more vital now that the decision to go ahead is evidence-based. I believe that it is in the public interest, for supporters, opponents and agnostics, that an immediate and speedy review takes place independent of the parties which have a direct interest or direct responsibility.
1.16 It can be argued that the reviews by Ofwat, the Selborne Commission, Thames Water and others are coloured by the interests of those who commissioned them. For example, the Selborne Commission was commissioned by six London boroughs, all of whom are potentially adversely affected by works arising from the tunnel if the project goes ahead.
1.17 There is much experience of tunnelling and the financing of tunnelling elsewhere in the world and the decisions about the Thames Tunnel should be informed by this. In order to capture this experience and knowledge, international organisations such as the United Nations and the European Commission, alongside appropriate representatives from the UK, should be asked to take part in an independent review.
1.18 I now therefore propose that a review panel be set up urgently which will publicly report to government, parliament, the GLA and London councils before Thames Water draw up their final plans or submit any planning application.
1.19 Among other material, the review panel should specially consider the EFRA report, the Selborne report and the Project Justification Review by Professor Chris Binnie as well as the National Policy Statement for Waste Water published on 9th February 2012.
1.20 I propose that the United Nations Environment Programme (UNEP), the European Commission (Environment Directorate-General), the Environment Agency, the GLA, the Local Government Association, London Councils, the Consumer Council for Water, Water UK and each of the three major political parties be asked to nominate representatives.
1.21 I propose that, initially, the National Audit Office be asked to fund the review. Other independent funding agencies could be approached. In additional and as necessary, Thames Water and other supporters of the full tunnel and opponents of the full tunnel could also be asked to contribute.
1.22 I will now work hard to persuade the government to accept the benefit of a limited pause for an independent review and to persuade those in City Hall and London councils to come to the same conclusion.
1.23 I will also keep an active watching brief on all business that comes before the House of Commons to make sure ministers continue to be regularly questioned and the finances of the project fully probed.



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