Greg Hands M.P.’s response to the phase two Thames Tunnel consultation

I have represented Fulham in Parliament since 2005, as the M.P. for Hammersmith and Fulham from 2005 to 2010, and both Fulham and Chelsea since the 2010 General Election. Prior to entering Parliament, I was a Fulham Councillor for Eel Brook Ward from 1998 to 2006, and served as Leader of the Conservative Group on Hammersmith and Fulham Council. I have lived in Fulham since 1990.

Since the close of the phase one consultation last year, Thames Water has changed its preference for the Thames Tunnel main drive site in West London, and now wishes to tunnel from Fulham, on Carnwath Road Riverside. It was not considered viable during phase one and the choice of this residential site has, understandably, provoked alarm. Many hundreds of constituents have contacted me to express their opposition.

I have consistently raised the problems relating to an urban, residential site in my weekly email bulletin and through leaflets, inviting residents to respond. I have also participated in two large public meetings and numerous meetings with residents’ groups, only a minority of which involved Thames Water. In consequence, I can confidently state that the local community is overwhelmingly hostile to using Carnwath Road in this way.

Many constituents also share my apprehension that – beyond the site-specific problems – the Thames Tunnel project does not represent value-for-money in its current form, and that the costs would be loaded onto every household, many of whom will struggle to pay higher water bills.


Site-Specific Issues

Carnwath Road Riverside
Carnwath Road Riverside is in the heart of a residential area, with 15,000 homes and 2,000 businesses located within 2,000 yards of the proposed tunnelling operations. A number of businesses are located on the site itself, and would be lost, with consequences for local employment. Each of the surrounding streets is predominately residential. The site is ringed by social and private housing, including John Dwight House, Philpot Square and the Piper Building, which would directly overlook continuous, 24-hour excavation.

In addition to Thomas’s Fulham Preparatory School, there are six state schools and nurseries in the immediate area, none of which were considered in the Environmental Information Report: Hurlingham and Chelsea School, Sulivan Primary School, L’école Marie d’Orliac, Queensmill School, Twice Times Nursery School, and Sands End Pre-school. There are also several parks and open spaces, including South Park and Hurlingham Park, which are used and enjoyed by residents from nearby streets and beyond.

The intended duration of construction and tunnelling is of grave concern to those living next to the site. Besides the loss of the river path, they will have to contend with six years of noise, dust and odour during construction, and potential odour whenever the tunnel is in operation. Although these fears have been downplayed by Thames Water, its Environmental Information Report identifies both Thomas’s Fulham and local homes as subject to all three factors. Despite the plans to construct a temporary shed around the works, the 24-hour excavation and removal of spoil will inevitably have an impact in terms of dust and noise, as will the loading and unloading of heavy lorries. Contained operations on other wharves along the river have been demonstrated to have impact on neighbouring properties, even with permanent containing structures and dust-removal and dampening equipment.

The Environmental Information Report notes the ‘likely significant air quality and odour effects’ of constructing and operating the tunnel. It is the operational effects that residents find most disturbing. Once the tunnel is functioning, the report suggests that odour would be discernible for more than 125 hours in a typical year. There is no indication of the duration of these episodes, which would clearly become a feature of local life. Assurances that carbon filtration would negate any sewer odour do not appear to be borne out by Thames Water’s own research.

Of concern far beyond the immediate area around Carnwath Road are the estimated traffic movements during the six years of construction. An extrapolation from the figures provided in the Site Information Paper show that there would be more than 29,000 heavy lorry movements, transporting large machinery, pre-cast segments of tunnel lining, spoil and other materials. Lorry trips would average 31 per day for two years during main tunnelling and peak at 33 per day when the tunnel is being lined. The proposed access route uses Wandsworth Bridge Road, New King’s Road and the King’s Road, all of which are already congested and are lined with flats and houses. The road network in Fulham and Chelsea is one of the most congested in London. According to the most recent TfL data, Hammersmith and Fulham is second only to the City of London for delays, with motorists trapped in tailbacks for 66,849 hours every year. Given the existing pressure, it is astonishing that no assessment has been made by Thames Water of the impact on local traffic.

The lost regeneration opportunities for the site would span more than a decade, with a permanent loss imposed by the ventilation structures, which, as planned, split the wharves along the river. The use of the protected wharves for removing some of the tunnelling spoil has been hailed as positive step by Thames Water, but this is hardly the use that the protection was intended to make possible, despite the preferability of barges to lorries. In reality, protected status has helped prevent regeneration, and the London Borough of Hammersmith and Fulham has been lobbying for its removal for many years.

Although Thames Water offer a reduced footprint requirement for a western site as explanation for why Carnwath Road was not considered during phase one, it remains unclear why Fulham was suddenly preferred to Barn Elms, other than the wish to avoid using Metropolitan Open Land. Both sites would entail the loss of the river path during construction, and the implications of using smaller barges slightly further upriver are not particularly significant. While the planning restrictions on Metropolitan Open Land have been presented as decisive, the temporary nature of the loss, with only a small permanent footprint in one corner of the space, put this in question. The costs surrounding land acquisition are also likely to be lower at Barn Elms. I have repeatedly asked Thames Water to expand on the reasoning provided in the consultation documents, but this has not been forthcoming.

It cannot be right to use a residential area when non-residential sites are available. Kirtling Street is not mentioned as an alternative in the documents and has only been subject to any serious investigation in recent weeks. The option of a longer run of tunnelling direct from Kirtling Street to Acton must be taken, if it is viable, and should have featured in the consultation process.

My remaining comments on Carnwath Road are only relevant if the considerations above are ignored, and the opinion of residents is overridden. If tunnelling proceeds at the site, it is essential to attempt to mitigate the impact on Fulham. Barge use should not limited by cost or left to contractors to determine; instead, barges should be used whenever it is technically feasible. While I believe that site traffic would still be unacceptably disruptive, if lorries are only used where absolutely unavoidable, and scheduled for non-peak, daytime hours, this would help prevent complete paralysis of the road network.

The design of the permanent structures on the site should also be revised. The impression created by the lumpen, bunker-like building is not alleviated by a reed-bed concrete relief – a traditional design would be far more in keeping. Thames Water has made much of the legacy of Bazalgette; in this respect, it should seek to emulate the structures he created. The same concern applies to the ventilation tower which, beyond any concerns about odour, is a brutal imposition to the riverbank.

Chelsea Embankment Foreshore
This is, in effect, a non-residential site, although traffic movements remain of concern to residents. I am content with the design, which is sensitive to its context, but understand that some groups are concerned about the interruption to the line of the embankment.

Cremorne Wharf Depot
I am pleased that the location has been altered, following discussions with residents and the Royal Borough of Kensington and Chelsea; access through Cremorne Gardens itself would have been detrimental to a much-valued space. However, previous concerns about disturbance, dust, odours and traffic still apply.


Strategic Issues

My greatest fear is that, at £4.1 billion, the cost of the tunnel is too large to justify the environmental benefits. Projected costs have risen massively from early estimates, and there has to be a point at which they outweigh the advantages of a cleaner river. The River Thames is already cleaner than at any point since the nineteenth century, with the GLA describing it as ‘one of the cleanest metropolitan rivers in the world’. The Environment Agency went further and lauded it as ‘the beauty queen of the planet’s waterways’ after it won the International Theiss River Prize for cleanliness in 2010.

Thames Water’s arguments about future levels of discharge arising from population growth ignore two facts: firstly, that increasing water efficiency combined with sustainable urban drainage systems can mitigate the impact on CSOs; and, secondly, that discharge into the river will be more than halved by existing work on the Lee Tunnel and sewage treatment works, including the improvements at Mogden.

The company has repeatedly cited a figure of 39 million tonnes of average annual discharges when making the case for the tunnel. This is disingenuous, applying to all discharges in the tidal Thames now, not the projected total after current work is completed. The tunnel would only capture the remaining 18 million tonnes of discharge, of which more than 95% is rainwater. Moreover, Thames Water’s counter-argument that the Lee Tunnel will not improve water quality upstream makes the failure to separate these figures even more egregious, and the failure to include Mogden in the calculations incomprehensible. It is simply a fact that the river will be cleaner throughout, and in parts much cleaner, without constructing the Thames Tunnel.

Were the existing state of the river from Hammersmith, past Fulham, to Chelsea of serious concern, a case might still be made; however, the most frequent users of the Thames Path rarely witness anything of note. It is not true to suggest that London’s international reputation is being damaged by the current level of water quality. Anglers, rowers and sailors will experience personal benefits from the tunnel, but others are unlikely to notice any change. Fish kills, perhaps the most visible of effects, will be substantially reduced beforehand by the Mogden STW project.

There is certainly an environmental gain from intercepting CSO discharges, but it must be judged against the impact on water bills. Combined water and sewerage charges are regressive, hitting the poorest in society hardest. Bills are already forecast to increase by £70-80 per year, which is significant in the context of the rising cost-of-living; similar increases in energy costs have caused widespread concern about fuel poverty. In response to such fears, Thames Water argues that bills will only rise towards the national average, ignoring both the higher cost-of-living in London and the South East and the potential for bills to rise by more than forecast. The recent Ministerial Statement warned that ‘relatively small changes in the cost of capital for the project could have a significant impact on bills’, which was not reflected in consultation documents.

The Treasury has been forced to introduce a £50 annual rebate for South West Water customers from 2013/14 because of the unacceptable impact on customers of its sewerage charges. Were the costs of the Thames Tunnel to rise further, Thames Water’s sewerage charges could, in time, exceed the rebated level of sewerage bills in the South West. This possibility is strengthened by the underlying trends: before any Thames Tunnel costs have been apportioned to bills, households face an 11% hike in sewerage charges in 2012/13, more than double the rate of inflation.

The tunnel’s alleged boost to London’s infrastructure has been overstated. Post-construction, the project does not generate any economic growth or employment, but it would permanently reduce households’ disposable income. Limited benefits during the period of construction are also entirely outweighed by this cost. In contrast to projects like HS2, which is projected to create 20,000 jobs in west London during the first stage alone and stimulate growth across the north of England, the Thames Tunnel will not provide any compensating economic gain.

None of these considerations support a ‘do nothing’ stance, because any level of discharge is regrettable. Rather, I do not believe that alternatives to a full-length tunnel have been properly considered; a belief which has been strengthened by the work of the Selborne Commission and the independent water expert Professor Chris Binnie, who chaired the original Thames Tideway Strategic Study Group. Although both operate largely on the premise that EU requirements should be met in full now, irrespective of a cost-benefit analysis or the environmental case, neither is persuaded of the need for a full-tunnel solution. The Selborne Commission concluded that the so-called Babtie option of a shorter, western tunnel was a viable alternative. It also brought to attention the massive disparity between the sums Thames Water has spent pursuing a tunnel solution and what it has spent investigating sustainable urban drainage systems.

There has been a noticeable failure to engage with the European Commission, either by Thames Water or, perhaps more pertinently, the Environment Agency. The Urban Waste Water Treatment Directive obligates a reduction in discharges, not their elimination. With discharges set to more than halve without further action, and yet no discussion having occurred about the level of reduction needed to meet EU requirements, the suspicion of ‘gold plating’ must be strong. It is not enough for Thames Water to say it is using internationally recognised standards: at issue is what standard would avoid enforcement action from the Commission, and the Commission does not appear to have been asked.

It follows that there is an argument for continuing to monitor water quality before making a final decision, in order to determine the impact of the Lee Tunnel and the upgrades to Mogden and other STWs. Extrapolating from the current data relies heavily on assumptions about how this work, which is already underway, will affect the river once it is complete.

Finally, I am worried that the strategic issues surrounding the justification for the Thames Tunnel might not fall within the remit of the Infrastructure Planning Commission. Neither of the consultation phases so far has adequately considered these strategic questions. As I elaborate below, there is an expectation among residents that the planning process (in the form of the IPC or its successor) will address the need for the project, and this expectation could be confounded.


The Consultation Process

I remain disappointed at Thames Water’s failure to properly notify me when Carnwath Road was first identified as a site, in the period between the phase one and two consultations. Since then, communications with me have improved, but the same cannot be said for Thames Water’s customers. The information that the company has provided with 2011/12 water bills was inadequate and ambiguous, with no reference to the enormous impact the project would have on future bills, or the opportunity for customers to have their say during the anticipated phase two consultation.  Indeed, the mention of the project and its impact on bills was buried deep inside the Thames Water brochure accompanying the bills, when it should have been the most prominent item.

The phase two process has been undermined by serious shortcomings, although I do appreciate the way senior Thames Water representatives have made themselves available for meetings with me. The fragmented nature of the phase two documents makes it difficult to judge an individual site, as the technical information is spread across a number of reports and appendices that are difficult to isolate online. I doubt whether many constituents have been able to navigate much beyond the Site Information Paper for Carnwath Road, which is limited in scope.

Elsewhere on the website, the consultation form compounds this problem by asking respondents to judge the adequacy of Thames Water’s documentation, rather than asking simple questions about whether they agree or disagree with particular aspects of the plans. This abstract approach confused many constituents, who have found the simplified form produced by residents’ groups and the landowners to be much clearer. It should not be necessary for outside groups to have to intervene to make the official consultation comprehensible, and I hope that responses via the simplified form are given equal weight.

The environmental case for a tunnel is consistently misrepresented, particularly in the summary documents. Anyone reading them would naturally assume that the tunnel would collect 39 million tonnes of raw sewage, not 18 million tonnes of discharge, of which more than 95 per cent would be rainwater. They would also assume that discharges into the Thames are set to get worse, not more than halve. Moreover, when following the prompts on the Thames Water consultation website, it is not even possible to discuss the strategic case for tunnel without first choosing individual sites about which to comment and then answering a series of site-specific questions. This is a serious deterrent to anyone who is principally concerned about whether a tunnel is the right option.

In comparison to the phase one consultation, which was extended, residents living near Carnwath Road have had considerably less time to organise and present their case than campaigners for Barn Elms. This is relevant as the viability of tunnelling to Acton from Kirtling Street was not explored by Thames Water and is still being investigated. That such an obvious alternative was not considered is, in itself, a cause of unease. Nor are any of the potential alternatives to a full tunnel presented in the phase two consultation literature, despite the questions in part two of the website form.

A major concern is that the planning context for the consultation is unclear. It is impossible for respondents to know how the consultation will be judged by the IPC, or whether certain issues will be examined later. Many constituents have naturally assumed that strategic questions will be addressed by the IPC, when they will be able to make full representations, perhaps with a greater chance of success than when responding to an organisation that is promoting its own scheme. Yet if the provisions of the draft National Policy Statement for Waste Water are carried into the final document, this might not be the case. In the absence of even the Government’s response to the Select Committee report on the draft NPS in March 2011, the role that the IPC will be expected to fulfil is wholly uncertain.

Further doubts about the framework provided by the Planning Act 2008 result from the absence of a Section 14 order designating the Thames Tunnel as a Nationally Significant Infrastructure Project. Without an order, the IPC cannot accept a planning application, and I understand that it has already rejected a number of attempts by Thames Water to serve notice of an application. Under the terms of the draft order published last year, the IPC might be given retrospective powers to deem the phase two consultation to qualify as a pre-application consultation. Attempts to grant retrospective powers are often legally problematic and no order has yet been tabled for consideration by Parliament. Respondents to Thames Water’s phase two consultation cannot, at this stage, know how their answers may be judged, or for what purposes. This must put the potential use of the consultation by the IPC in question.

Finally, I repeat my concern at the failure to engage sewerage customers outside the areas that would be affected by construction. Fourteen million people would be forced to pay for the tunnel, across a significant swathe of the country. While it might not be a planning consideration, they are surely entitled to be consulted before receiving higher bills. Instead, Thames Water seems to have delegated its fundamental duty to customers to Ofwat.



Regarding both the fundamental parameters of the Thames Tunnel project and the major site earmarked for my constituency, I implore Thames Water to think again: using Carnwath Road would be a disaster for residents in Fulham, Chelsea and beyond.


Greg Hands M.P.

Greg Hands M.P.
Member of Parliament for Chelsea and Fulham