Thames Anglers’ Conservancy
P.O. Box 863
Richard Anthony Crimp (Secretary)
13th January 2011
Thames Water Utilities Limited
As the Angling Trust Consultative for the River Thames between Staines and the Dartford Crossing (including all of the London boroughs), the Thames Anglers’ Conservancy (TAC) welcome the consultation document concerning the Tideway Tunnel.
As a concerned stakeholder in all initiatives regarding the River Thames we would like to present our view point on behalf of the TAC and its membership in its entirety. This should be viewed as a separate document to our affiliate organisations, such as Angling Trust etc.1. There is a need to significantly reduce the amount of untreated sewage entering the River Thames in London. Please give us your views about this.
The Thames Anglers’ Conservancy (TAC) would whole heartedly agree that there should be a significant reduction in the amount of untreated sewage entering the River Thames in London. The temporary consents that were given by the then Conservative Govt. - prior to privatisation in 1989 - have turned into anything but ‘temporary consents’ and the continued legality of such discharges has been/and is a blight to the City of London, subsequent Govts. but ultimately Thames Water Utilities Limited, let alone the aquaculture of the river itself. This can no longer continue, and the proposed Thames Tunnel project is an absolute necessity, if 20 years overdue in its consultation stages.
As a company it should be incumbent upon Thames Water to comply with the Urban Wastewater Treatment Directive and its obligation the Water Framework Directive.2. Taking into account all the possible solutions, please tell us whether you agree that a tunnel is the right way to meet the need, and why.
Simply put, the TAC fully concur with the conclusions of the Independent Thames Tideway Strategic Study undertaken in 2001 (completed in 2005), that the most practical and financially viable solution for London would be to intercept the Combined Sewage Overflows (CSOs) with a new tunnel system as currently proposed.
The alternative solutions would not meet the logistical, environmental and financial criteria within a City such as London and are therefore easily ruled out (as highlighted through Thames Water literature).
The Sustainable Urban Drainage System (SUDS): Logistically impossible and financially prohibitive.
Separation of the sewerage system: Once again, financially onerous and infeasible construction wise.
Bubblers and Skimmers: Would achieve little environmentally and couldn’t ever be considered as a solution.3. If you prefer another way of meeting the need, please tell us which one, and why.
Not Applicable4. Please select which route you prefer for the tunnel. (Note that any final decision on the tunnel route will involve engineering, planning, cost, public amenity and environmental considerations.)
Abbey Mills (our preferred route)River Thames
None of the above5. Please explain why have you chosen your answer to question 4.
The TAC would fully endorse the River Thames route, as it is this route will capture the greatest amount of raw untreated sewage from the CSOs. The cost of the River Thames route, whilst being more expensive than the other two proposed options, is the only route that should be seriously considered.
The River Thames route offers the greatest environmental protection for the rivers future, this regarding the three proposed routes, and is considerably better equipped to fulfil the absolute minimum requirements to enhance the aquatic ecology throughout the tideway during the first half of the 21st Century, as well as going someway to preventing possible health issues to the general populace in the immediate future (climate change considered).6. Please give us any other comments you have about the project (see part 2 to comment on specific sites).
Prior to 2007 the project cost was estimated to be approximately £1.5bn, and in a little over 3 years, we have seen the projected cost rise to over £3.5bn. It has been publicly stated that the cost to Thames Water’s 8mn plus customers will be an additional £65 per annum to pay for the sewer upgrades and a quick calculation would suggest that it will be Thames Water customers that will pay for every last rivet and bolt that makes up the tunnel’s construction? It appears that the current financing regime will burden Thames Water’s customers, as opposed to balancing the cost between the company and its customers, so detailed assurances will be pre-requisite to meet public demand.
Thames Water Utilities Limited have earned considerable profits in recent years and this would be in part due to being able to build the business with the continual status quo concerning over 20 years of ‘temporary consents’ that were issued to attract private ownership - as opposed to the utility continuing to be state owned – and it should be incumbent upon Thames Water Utilities Limited to ensure the following;
1. That all due care and consideration is given to the aquatic environment during the design and build stages. This would include a greater willingness to implement the River Thames route.
2. That Thames Water’s most vulnerable customers are protected from inflated charges and to ensure that ‘water poverty’ does not become a reality.
3. That all affected London boroughs are given full support during design and build.
4. That Thames Water seriously consider the current financing regime and fully adopt a fair and balanced costing that doesn’t see its customer’s bear the lion’s share of the expense.
5. That Thames Water guarantees that, once the project is completed, that their customer’s annual water bill will then be reduced accordingly.
The Thames Anglers’ Conservancy fully supports the need for the Thames Tideway Tunnel project to be implemented, however, the need for Thames Water to maintain the regions utility with all aspects of the environment at the very top of the list, must supersede its business concern for maximum profitability, often at the expense of its customers and the environment.