The SOLAR Campaign Writes to Defra About Section 35 Application by Thames Water

Below is the letter the campaign team sent to Robbie Moore MP, the Minister for Water & Rural Growth at Defra, on December 18th 2023 in response to the Section 35 application by Thames Water.

---

To: Robbie Moore
Parliamentary Under-Secretary
DEFRA
House of Commons
London
SW1 0AA
By email to robbie.moore.mp@parliament.uk

18 December 2023

Dear Mr Moore

Teddington Direct River Abstraction scheme (DRA) – Thames Water S35 application.

We understand that Thames Water has approached you to consider this proposed water resources management scheme for an S35 order.

We strongly believe this request is inappropriate and ask that you reject it.

There are greener, cheaper and simpler schemes available to meet the need identified, and the scheme does not fulfil the criteria required to remotely reflect a scheme of national significance. Not only has Thames Water comprehensively failed to make the case for Teddington DRA as the “best value scheme” but their more recent efforts to explain its value have been so poor, that the public is now recognising this with an enormous majority of those who become aware of it completely rejecting it.

We met with Cathryn Ross and her senior team on the 1st December 2023. We explained our concerns, exampled many better alternatives, and emphasised how our very valid and reasonable questions had remained unanswered after many months of asking. It was agreed that follow-up meetings would be arranged to look into what we had said. The first of those follow-up meetings is tomorrow, with more in the early new year and a commitment from Thames Water to provide the right people from across their business to look into what we are saying. Clearly if they were so convinced of their ground, and that they had the public with them, they would not be prepared to engage in these discussions but it is very clear that they are on shaky ground across a whole series of areas.

Strategically Weak

Thames Water requires about 2 billion litres a day for the London zone. This proposed scheme has a capacity of 67mlpd but, because it is a drought resilience asset, will only actually deliver on average 9 mlpd – less than 0.5% of daily demand. It is a so-called strategic scheme that delivers a volume of water that is in the category of a rounding error in terms of daily volume.

We specifically pressed the point at our meeting with Thames Water on 1st December that schemes of scale were needed to deal both with uncertainties going forward and provide flexibility. They agreed with this, so Teddington given its insignificance in terms of daily volume can’t be a credible strategic solution.

On the treated sewage disposal side it will tip into the Thames nearly 2.5 times the volume of abstracted water because the engineering design requires it. In effect, it is a treated sewage disposal scheme, not a water supply scheme.

With better alternatives available, it is completely illogical to introduce a new abstraction facility when elsewhere in Thames Water’s plans they are lowering abstractions to help protect vulnerable areas – they became vulnerable on the basis of excess abstraction, so to argue that strategically a new scheme like this should be introduced does not stack up at all.

Finally, there is nothing in the Teddington DRA scheme that in any way links into other infrastructure developments i.e. it is a self contained very small scheme.

Operationally Flawed

We note from Thames Water’s plans that they were “caught out” by the drought impacts of 2022 and now have underway work to try and understand what happened. We understand this work is not yet complete. This area of the Thames has the longest data history of river flow anywhere in the country yet Thames Water was caught out in 2022. If the purpose of the proposed scheme is as a key resilience asset, then placing it in an area where you can’t rely on the river flows makes little sense. To compound this the River Thames Scheme (RTS) has already prompted Thames Water to do more on the flow impact in the summer periods the time they think they might need to operate it i.e . more uncertainty. This review work is also not yet complete.

Added to these issues are that the location for this scheme is exactly where the non tidal Thames meets the tidal Thames. Those that know the river understand that at times you get overtopping of the weir i.e the flow goes up the river meaning the planned sewage disposal point would be tipping treated sewage into the river that would be abstracted just upstream. Also being at the point just below where both the Hosmill and Mole rivers come in, untreated sewage outflows could come to the abstraction point – there are very recent examples of this happening. There is further risk around the build period with the flood risk associated with placing extra area into the Thames for the abstraction plant placing local areas under flood risk that does not seem to have had any focus whatsoever.

Thames Water’s answers to these issues are that fail safe systems would switch the abstraction facility off but how can you have a resiliency asset you need to switch off when you need it ? The whole point of the facility is that it must be there when you need it. This scheme can not provide that guarantee.

Best Value Assessment Unsound

The Teddington DRA scheme has emerged as Thames Water’s “preferred best value scheme”. Despite months of requests and Thames Water putting on information and consultation events, they have still failed to provide answers to repeated, and very specific, questions around “ show us your workings”. These questions were first asked of Thames Water over 9 months ago at their very first information event. They are claiming the right solution is based on a whole host of factors as well as cost. As the public becomes aware of the nature of this scheme, the importance of ensuring they are provided with the right information on which to make fair judgement is paramount. To date the result of Thames Water’s efforts has been to accelerate the public disquiet about this scheme.

Some examples of why the public feel so aggrieved about what is being proposed;

No Social Impact Work

There is nothing published on this at all. One of the most highly used set of open green spaces and river for leisure activities anywhere in London and not a shred of work has been done and so not published to indicate the impact of this scheme, yet Thames Water makes great play in its revised draft WRMP 24 about how crucial such an area is to their thinking.

Land and Water Environment Assessment Unclear

From the Gate 2 RAPID decision on this scheme we understand Thames Water still has to address the 12 serious concerns expressed by the Environment Agency due for submission by the end of December 2023. Thames Water has yet to publish the precise standards for water quality it proposes to work to but has already been clear that it does not plan to deal with the emerging forever chemicals with what is proposed for Teddington.

This is like conducting a live experiment on the Thames. The long term impacts of these substances are starting to be understood and other countries are already moving to deal with them. The idea that a “strategic scheme” does not do this is both short sighted and irresponsible particularly where there are many practical and greener alternatives that could be deployed. On the land destruction proposed , it is simply not necessary given the alternatives that Thames Water has committed to us they are willing to discuss and have now confirmed dates in January 2024 with the right people from across Thames Water.

Customer Research Conclusions Inaccurate and Only Thematic

Thames Water claims its choice of Teddington DRA is based on solid customer research but it is not. The research conducted is thematic about water supply and demand and only one small study talked about scheme specific options and this did not offer those surveyed any choice other than preferred schemes. This item of research was qualitative not quantitative and clearly led the witness in terms of saying, in effect, “ all you see is all there is”. Thames Water’s best research base is the information events they have held specifically on the scheme and this has shown that the scheme is not supported and is opposed by an absolutely enormous majority. If Thames Water believes it is anything different then let them publish their data and show exactly who supports what it proposed. From the thousands of pages of work that has been done there is not
a shred of evidence that anybody does. This is reinforced by RAPID actually pointing this out in their Gate 2 report.

Public Consultation Woeful

RAPID’s Gate 2 final report made it clear to Thames Water that they had to improve public consultation. This was based on the large volume of poor feedback they had received about the scheme. Thames Water has attempted to do more but their real problem is the basis of the scheme is so weak that they simply continue to drive up opposition. Some 30,000 people have now signed the petition opposing this scheme and over 60 local businesses, associations and all manner of other organisations have signed a statement of opposition to the scheme. This will continue to grow because the alternatives are just so much better.

Alternatives

We have talked to Thames Water about 15 alternative schemes all of which appear much better value and or lower cost. Some simply make better use of existing assets and some show that alternative larger schemes like Beckton recycling/ Mogden recycling or canal transfer schemes are much more fit for purpose in terms of scale and resilience. The point about cost of alternatives is key and the associated cost of future debt for building new assets like Teddington from a customer perspective. Thames Water has confirmed this scheme alone would add up to £4 per household to their bills – that’s some £750m over the planned asset lifetime. This is an eye watering level for what is to be delivered and must be challenged.

Thames Water is only very slowly coming to the table to discuss the full details of this scheme with the public. Teddington DRA is not a strategic scheme in terms of approach and it is not a nationally significant scheme given its minimal scale of impact. There are much better alternatives that are greener and cheaper and the current proposals have major environmental and operational resilience risks that are fundamental issues that can’t be sensibly mitigated.

We ask that you reject this request for S35 and direct Thames Water to look again at how they meet the need with a better solution that would provide an example of how they are looking to move the water industry forward, rather than a subscale scheme that is simply not fit for purpose and has no support from the public.

Yours sincerely

Ian McNuff

For and on behalf of SOLAR