A London Councils Member briefing June 2011 The Thames Tunnel The construction of the Thames Tunnel to deal with the problem of sewerage overflowing into the Thames presents London boroughs with many challenges and concerns. This briefing provides an opportunity for those members who have not been previously involved with the development of the tunnel to familiarise themselves with the key issues around this project. Overview The construction of the Thames Tunnel received ministerial approval in March 2007. The proposed scheme involves a single tunnel running from west London eastwards, largely following the River Thames down to the Beckton sewage treatment works. The tunnel will take raw sewage overflowing into the river from combined sewers between Hammersmith and Beckton. Development of the tunnel aims to ensure that the UK complies with the European rules on the management of waste water treatment and discharges. The government and the European Union have set 2020 as the target date for the completion of the tunnel, and construction will take approximately seven years. While borough perspectives vary on the need for a tunnel, as opposed to other options for dealing with raw sewage overflowing into the Thames, one area of London-wide consensus has been the concern over the cost of the scheme. Cost estimates have more than doubled since the original announcement in 2007 and are now estimated at £3.6 billion. Between September 2010 and January 2011 Thames Water undertook a phase one public consultation on alternative options for the construction of the tunnel, including potential sites for tunnelling and options for routes that the tunnel could take. A report setting out Thames Water’s response to the consultation was published in March 2011. A revised design will now be developed and this will be the subject of a second round of consultation due to commence in the autumn this year. Thames Water aim to begin submitting planning applications by the middle of 2012, start construction in 2013 and complete the project by 2020. Apart from the very real concern about escalating costs, London Councils has been pressing Thames Water and the government over other issues including: • The need for Londoners, through their elected representatives, to have a stronger say in the process for granting planning consent for the project than may be afforded by the government’s preferred route – the Infrastructure Planning Commission (which is now being merged into the Major Infrastructure Planning Unit within the Planning Inspectorate); and • The need to maximise the skills and employment opportunities presented by this major scheme for Londoners, especially our young unemployed. Analysis The need for a tunnel London’s 19th century sewage network was designed to overflow at times of heavy rainfall to ensure that sewage did not back up into houses and streets. They were intended to discharge the raw sewage through Combined Sewer Overflows (CSOs) into the Thames in the event of extremely heavy rain. As London has grown and land use characteristics have changed, these overflows have occurred more frequently and now happen around 50 times a year, sometimes with significant and immediate impacts on fish and other river life. The frequency is expected to increase in the coming years with population growth and projected climate change, with overflows expected even when there is very little rain, simply because of the load on the system. Proceedings are being pursued by the European Commission against the UK for breach of the Urban Waste Water Treatment Directive (UWWTD). Two successive Secretaries of State have held the position that a full length tunnel, with additional secondary treatment at Beckton sewerage treatment works, is necessary for UK compliance with the Directive. London Councils and boroughs have considered the need for a tunnel as the most cost effective and least environmentally costly option for dealing with the combined overflows. Despite varying views and conclusions, most have now accepted that in the absence of any other strong alternative, a tunnel may be the most practical solution. In its phase one consultation report, Thames Water stated that, while it recognised that a minority of respondents have concerns about the need for the project and whether a tunnel is the most appropriate solution, it still believes that it is essential to reduce the amount of sewage entering the River Thames, and that a tunnel represents the best way to achieve this. The planned route Following the phase one consultation process, Thames Water has confirmed that the tunnel will be constructed along its preferred Abbey Mills route. The main reason for selection of this route over the alternative options is that it is considerably shorter, with fewer main construction sites. It will therefore be cheaper to construct and will have less environmental impact, while at the same time being capable of diverting a sufficient amount of overflow sewerage away from the Thames. This route is currently proposed to start at Hammersmith Pumping Station (with a smaller tunnel connecting from here to Acton Storm Tanks) and follows the river to King’s Stairs Gardens in Bermondsey, then diverting north-east under Limehouse Cut Canal to join the Lee Tunnel and Abbey Mills. The boroughs that will be affected by this route are: Ealing, Hounslow, Hammersmith and Fulham, Richmond-upon-Thames, Wandsworth, Kensington and Chelsea, The“ Abbey City of Westminster, Lambeth, City of London, Southwark, Newham, Tower Hamlets, Greenwich Mills route is and Lewisham. considerably shorter; it The Abbey Mills route has five main shaft sites, where the majority of work will take place. The will therefore five preferred main shaft sites are: be cheaper to construct and have less • Hammersmith Pumping Station (Hammersmith and Fulham) environmental “ • Barn Elms (Richmond-upon-Thames but land is owned by Wandsworth); Carnwath Road impact (Hammersmith and Fulham) has been identified as a possible alternative site • Tideway Walk (Wandsworth) • King’s Stairs Gardens (Southwark); Chambers Wharf (Southwark) has been purchased by Thames Water as a possible alternative site • Abbey Mills Pumping Station (Newham). In addition to these, there are 17 CSOs to be directly intercepted, where less work will need to be undertaken. All the construction sites are by the river, apart from Abbey Mills. The“ cost of the project will Cost add £30-£65 Thames Water has estimated the cost of its preferred route at £3.6 billion. This is a significant to London increase from the 2006 estimate of £1.5 billion, and is a result of the more detailed planning consumers’ annual water and analysis that has since gone into the project. Thames Water estimates that this is 20 per “ cent less than the cost of each of the other two route options. Thames Water is proposing that bills from 2012 the entire cost of this project will be met by its customers. This will add £30-£65 to consumers’ to 2018 annual water bills from 2012 to 2018, or just over £1 per week by 2018. This revised cost projection represents more than twice the previous cost estimate. This raises significant concerns about the more severe financial implications for water rate payers and whether this represents real value for money for customers, particularly in the current economic climate. Crucially, London Councils is also concerned about the ability of the project to be delivered within these revised projections and what arrangements will be put in place to deal with the risk of cost and time overruns. London Councils has made the case, so far unsuccessfully, for the cost of the scheme to be underwritten by central government. The emphasis in recent engagements with Thames Water and the Department for Environment, Food and Rural Affairs (Defra), however, has been to ensure that the scheme that emerges provides the best value for rate payers’ money and that the costs are well managed. Planning There is still uncertainty about how the planning applications for the Thames Tunnel will be managed. The previous Secretary of State for Defra announced his intention to direct the planning applications for the Thames Tunnel to the Infrastructure Planning Commission (IPC) – which was at the time an independent body tasked with determining planning applications for Nationally Significant Infrastructure Projects (NSIPs). However, the current government has subsequently announced the integration of the IPC into a Major Infrastructure Planning Unit (MIPU) which will be part of the Planning Inspectorate. The government has also announced that ministers will now make the final decisions on NSIPs. In spite of the Secretary of State’s statement of intent, large waste water projects such as the Thames Tunnel do not currently fall under the NSIP regime. For this to change, government has to designate them and produce a National Policy Statement (NPS) to provide the policy framework within which the IPC would be able to consider proposals. Concerns have been raised about a national body determining a scheme which is expected to create significant local impacts. Hammersmith and Fulham and Kensington and Chelsea have publicly raised strong views on this issue. There is a strong argument against taking the decision-making process out of the hands of London’s planning authorities, particularly when the scheme will be paid for by London’s residents and other Thames Water customers, and with much of the impacts very local in nature. London Councils is continuing to make the case with Defra and others that planning consent for the tunnel route should proceed through a process that provides full opportunity for the views and concerns of individual boroughs to be taken into account before decisions are made. In addition, London Councils is pressing Thames Water and others to ensure that boroughs are consulted early and fully regarding the specific environmental issues affecting each site as the planning applications for the project are being put together.