Introduction

This campaign opposes Thames Water's TDRA scheme on environmental and social grounds. We believe that there are better and more sustainable solutions that should be given priority over TDRA.

This campaign opposes Thames Water's TDRA scheme on environmental and social grounds.

We believe that there are better and more sustainable solutions that should be given priority over TDRA.

There will be long-term environmental and ecological impacts on the River Thames water quality. There will be damage to the green spaces utilised in construction. There will be a negative change in the character of the "Arcadian Thames", an iconic and historic riverside area of the Thames around Teddington Weir.

  • The plan will abstract (remove) water from the River Thames and replace it with treated effluent sewage at a unique location where the tidal river meets the freshwater river.
  • There will be a significant impact to water quality from putting treated sewage into the River Thames. See details below.
    Green spaces are protected for a reason: for the protection of nature and for the benefits that access to nature can have on human health.
  • Trees will be chopped down, Bat roosts and badger setts will be disturbed
  • Building compounds will cause earth compaction and change the soil biome
  • Building compounds will interfere with the natural movement of mammals and birds which may damage their ability to flourish.
  • There will be air quality consequences from the significant increase in construction around Mogden arising from the change in tunnelling method.

"In addition to the potential traffic impact, it is likely the TDRA would have a substantial negative impact onthe ecology of the Metropolitan Site of Special Interest for Nature Conservation that comprises Ham Lands. While I can acknowledge Thames Water’s stated commitment to biodiversity net gain and reconstruction, this does not discount the immediate impact the temporary destruction of acres of nature reserve would have on local flora and fauna. Once mature trees are felled, they cannot be replanted, and once badger setts are destroyed, and their occupants killed or driven off, they cannot necessarily be restored. These are two specific examples of the damage this project could do to the area, but Thames Water’s own documentation cites a potential impact on a wide array of wildlife."
Sarah Olney, MP for Richmond Park. Letter to Constituents, November 2023,.

The TDRA scheme is socially flawed

To construct the tunnels, shaft, abstraction and outfall sites, Thames Water will be removing land from community use for a significant period of time, causing a high social cost.

Specifically in Ham Lands and Burnell Open Space:

  • Point 1 The Richmond / North Kingston construction areas include tunnel shafts, the outfall structure, the abstraction structures and the connection shaft to the TLT tunnel.
  • Point 2 Ham street car park / Ham Playing fields will see the construction of a 10.5 metre shaft at a constricted road junction which many people use to access the riverside. Construction of a shaft may take up to 8 months.
  • Point 3 Burnell Open space at the south of the scheme will be hoarded off for construction of the outfall structure, abstraction structure, as well as several ancillary kiosks. This could be for up to 21 months.
  • Point 4 There are several primary and secondary schools within the area of construction; students, workers and thousands of residents will be impacted by construction traffic and restricted access to the riverside.
  • Every day, there will also be a huge impact on the thousands of walkers, runners, casual river users and swimmers that use the Burnell Open space and the Thames Path National Trail towpath

Throughout residential neighbourhoods:

  • Construction will take place on roads that were never built for, and cannot sustain, continuous heavy construction traffic of the kind TDRA will require. Some of the roads in Ham Lands can barely accommodate two cars at the same time.
  • There will be issues of noise, air quality, building vibration, nighttime working, and construction traffic.
  • The densely built areas of Isleworth will suffer from a large amount of HGVs and other construction traffic around the area needed to build the new treatment facility at Mogden. Added to this will be the “significant” increase in HGV traffic needed to remove tunnel spoil from the tunnel construction on the west side of the sewage works.
  • The tunnels will be going under conservation areas with buildings that are already subject to subsidence. Many people in the areas of the conveyance route and the construction are very concerned about the impact of tunnelling under their houses and the sheer amount of construction traffic. These issues need to be addressed by Thames Water. There was no information for residents at the information events, despite Thames Water referring concerned residents to attend those meetings to get their questions answered.

We object because Thames Water Cannot be trusted with the environment 

"Whilst there is undoubtedly a need to future-proof our water supply, there is a fundamental issue around trust. Thames Water has a terrible record — regularly spilling raw sewage into our rivers and losing a quarter of its water supply every day due to leaks — whilst rewarding its executives with sky-high bonuses."
Munira Wilson, MP for Twickenham. Letter to Constituents, November 2023".

We object because TDRA is not a good solution for Londons future water needs

Thames Water claims the TDRA proposal will be safe, as they are regulated and are required to adhere to regulations dictated by the Environment Authority and other bodies.

However, campaigners are concerned that these regulations are insufficient to protect the river. And, further, that although fines may be imposed for breaches, this is not enough to protect our river.

Thames Water has indicated they do not plan to make the river worse with this scheme

"We’re committed to ensuring that water quality of the River Thames is not deteriorated as a result of the Project."
Thames Water, p.10 Teddington Direct River Abstraction and Water Recycling Project, October - December 2023.

It should be noted that the TDRA scheme would not be able to go ahead in Europe under the new, higher water quality standards. The TDRA does threaten to make us the dirty man of Europe.

We object because Thames Water cannot be trusted with customer money

Thames Water has repeatedly put profits and shareholders ahead of customers and the environment. Prosecutions of Thames Water by the Environment Agency for pollution incidents have now led to fines of £35.7m between 2017 and 2023.

In this summary report on the environmental performance of the nine water and sewerage companies operating in England from the Environment Agency, Thames Water was given a two-star rating.

Further, in reporting the total number of water pollution incidents, the EA reported that Thames Water performed "significantly below target (red)" for the EPA metric that assesses the total number of water quality pollution incidents from sewerage assets.

The impact of putting treated sewage into the River Thames

Impact on plant life of treated sewage in river water

The Environment Agency has enforced 'nutrient neutrality' for the effluent outfall. These nutrients consist mainly of Nitrogen and Phosphorus, well known to gardeners as they're added to commercial compost and fertilisers in specific amounts to promote plant growth.

The undiluted presence of these in raw sewage damages aquatic plants, causing some species to thrive and become invasive and others to die, compounding the wider river ecosystem.

This is why the Environment Agency is requiring Thames Water to filter out these nutrients to appropriate levels.  This is also why Thames Water is saying the effluent outfall ‘will not make the river any more polluted.'

Impact of chemicals in treated sewage in river water

Currently, the Environment Agency does not regulate chemicals that Thames Water is not filtering from the treated sewage going back into the water.

Thames Water has confirmed they will not be removing pharmaceuticals such as hormones, painkillers and antibiotics. They will also not be removing microplastics or emerging contaminants (also known as forever chemicals) like PFAs and PFOs. These are suspected as carcinogenic and derived from cleaning products and the manufacturing industry.

Risk of faecal contamination by putting treated sewage in river water

Currently, Thames Water is not obliged or planning to reduce the presence of bacteria, viruses and parasites from the effluent, which would include faecal contaminants such as E. coli, salmonella and coronavirus. A decision will be made in 2025 as to whether these will be reduced.

The concentration of all these contaminants when the effluent outfall is flowing at 75 million litres a day will be greatly concentrated because the abstraction plant will be removing 75 million litres of fresh river water a day and the river will be at its lowest due to drought. At this time river users will be at their peak, especially children.

Swimmers at the proposed outfall location are already suffering the effects of microbiological pollution from raw sewage spills. The effects of emerging contaminants on human and aquatic life are more unknown, though we will be producing a report compiling existing research on this to present to Thames Water in due course.

Thermal load and salinity impacted by putting sewage in river water

The natural water temperature of a river is increased when treated effluent is added. Treated effluent is warmer than river water.

The salinity (salt content) is also increased when treated effluent is added.
Increasing the temperature reduces dissolved oxygen and increases the metabolism of cool- and cold-water fish, causing them to burn energy at a faster rate and result in death when river temperature exceeds their physiological limits.

Salinity plays an important role too as it impacts growth rates and metabolism. For some fish higher salinity is beneficial but for others, it’s incredibly detrimental.

We object because Thames Waters customer and public engagement is fundamentally flawed.

Flawed Thames Water Customer Surveys.

As noted in 2023 Ofwat questioned the sufficiency and quality of information provided to customers in the draft WRMP24 and arising from that if there really is evidence that customers support the options proposed – including TDRA.

It is important to remember that the 2023 consultation was about the WRMP24 plans in general – not specifically TDRA. TDRA was presented, along with 2 other so called strategic schemes, as the must have solutions to the problems described in the WRMP plans.

Over 1,600 people responded to the draft WRMP24 consultation. In relation to TDRA Thames Water noted: “There were a large number of responses objecting to this scheme [TDRA]. Concerns were raised about the impact on the river and effects on public health and the ecology. There were also concerns about new infrastructure on the riverbank and the construction of an underground pipeline, alongside the disruption this would cause to the local community.”

What is interesting here is that the topics raised in responses are quite specific; impact on the river, public health and riverbank infrastructure. Specific and detailed information on these issues for TDRA was not included in the dWRMP24 consultation. Detailed information (to some extent) on TDRA was available in RAPID Gate 2 documentation. Nothing in the draft WRMP24 consultation referred people to the Gate 2 data.  This demonstrates that responses critical of TDRA especially on those topics were likely from people (and organisations) that tried to get information on and to understand the wider implications of TDRA – so the responses were of an informed public.

In May 2023 Thames Water/Verve organised a survey on the WRMP24 plans with the following objective “to ensure voices from the Thames Water catchment area, that are representative of Thames Water’s customer base, are heard and considered in refining the draft plan”.

The customer base they are referring to are the 15 million odd population in the Thames Water region. 123 people took part in the survey over 5 sessions, estimated 90 minutes in total: 1 session of the 5 related to the 3 strategic schemes in the WRMP24 plan including TDRA.

The importance of the survey to Thames Water is because “public consultations are often completed by those who are very engaged with the issues either because they are part of an organised group or because planned developments will directly impact where they live and as such, the feedback to consultations is not always representative of the general population”.

The basis of the survey was information from the consultation materials plus the concerns of what is described as the “local” community.  The consultation materials give NO information on possible alternatives (except a dismissal of Beckton reuse as too expensive). Drought issues featured heavily as an imminent threat in survey information but no information on how drought futures are developed in water resource planning or the link between levels of service and drought; no link between TDRA and river flow and usage and the environment.

Collaborating with other water companies and communicating with the EA was presented as proof that development of TDRA was the best (and only) solution. By presenting concerns as “local” Thames Water undermined the range of opposition to TDRA.  The opposition was not just local - a range of organisations responded to the consultation including for example the Kew Society and Thames21 (Kew Society response to Thames Water Consultation on proposed TDRA Scheme  //  Thames21’s response on Thames Water’s river abstraction plan at Teddington - Thames21)

A specific example of how the survey clearly points respondents in particular directions is when they are asked about the timing of the options: a slide is shown with the proposed dates when options will be in operation. TDRA is 2030. The slide states that this timing is because Thames Water needs to improve resilience by 2030 (not specifically true), that the option is needed to keep the Thames flowing (a bit dramatic), and the other options are more expensive (very simplistic). The question is then asked “Here are the timings of the plan. What are your thoughts overall about the plan?

No alternative timings are presented, no discussion of alternative options and long term future impacts and the “need” by 2030 is not explained properly.

The company that ran the survey (Verve) used their Ignite AI tool to analyse the survey results. The Ignite AI analysis tool /facility was released in 2023.

Ignite AI assessed the “sentiment” associated with the survey responses to gauge that three quarters of responses had “positive sentiment” about TDRA.

Faced with a possibility of extreme and imminent drought, with only one suitable solution and only “local” concerns against the assurances from Thames of no impact and in fact some possible benefits, it is hardly surprising that the survey results specific to TDRA show that some people are in favour of TDRA.

The Verve/Thames Water survey was in 2023. It included the following statement “Collaboration with the Environment Agency, (…) , brought a level of reassurance to participants (especially Non-Household customers) as it is seen as a trustworthy body that specialises in prioritising the environment.” In 2025 perhaps that ‘level of reassurance’ would be somewhat different as a lot of the general population would have seen “Dirty Business” by Ch4 which highlights many severe issues with the regulation of the water industry..

Thames Water use the 2023 research to justify their WRMP24 plans including TDRA: customers want it and they want it now. That same survey continues to be used to prove that “the public” wants TDRA.

In the final WRMP24 plan best value plan produced in 2024 Thames Water had this to say: “Whilst there was some sympathy to the objections being raised by local communities, overwhelmingly customers felt the benefit to water supplies outweighed any local concerns around environmental harm to this part of the river.”

The use of the Verve survey and the attitude shown by Thames Water to people that respond to consultations is incredibly condescending. Thames Water essentially dismiss people that respond to consultations by implying that “very engaged” people somehow do not represent the general population. Yet they are happy that 123 people informed by partial information in a survey are in fact representative of the Thames Water population.

Engaged people look for answers, look at information, look for evidence of best value, of future proofing, they may not accept simplistic dramatizing of drought; engaged people will see “local” as in fact the wider environment and ecology of the river Thames and the Thames Path and the health of all river users.

There was and continues to be a lack of information provided to by Thames Water to the public and their own customers; there remains a lack of credible investigation of alternatives to TDRA and a very biased presentation of contextual information on drought and drought planning and best value interpretation. Ofwat made a good point in 2023 and it remains a good point which must be addressed

A NOTE on other research around water resource planning

Thames Water refer to a whole range of surveys and research as evidence of support for the WRMP24 which promotes TDRA.

A lot of research shows that customers strongly favour solutions that focus on demand reduction first, favour solutions that are long term, and want solutions that include environmental benefits and human benefits.

As an example of a statement that should give pause to anyone thinking that TDRA represents what customers want is the following from Water Resource South East (WRSE) in 2020/2021.

“Customers recognise that a pragmatic mix of options are required …. Leakage reduction, demand measures, and new supply sources are not seen as substitutes. Rather it is the timing and ordering of options that matters most to customers. First, companies must get their “own house in order” by reducing leakage and helping customers to save water. After this, the right supply options for customers are ones that are reliable, avoid environmental harm, and provide wider benefits including enhanced local amenity and recreation opportunities”.

Everything in that statement represents what TDRA is not; It is being rushed to a Thames Water timeline instead of focusing first (financially and otherwise) on leakage reduction and smart meter installation. it is not reliable in drought and climate changes to river flow; it will add 75mld of treated sewage to a new location in the river Thames adding to the pollution load; it has no local amenity benefits nor recreation opportunities.

TDRA is money, effort and time wasted instead of reassessing the best water supply options for London and the south east.

bluetits at abstraction point

Swimmers at the proposed abstraction (removal) location on the river.

The Blue Tit swimmers in the River Thames.

The Blue Tit swimmers in the River Thames.

Link to a video walkthrough on Facebook of the areas that will be impacted by the TDRA on Burnell Open Space and Park Gate Woods. (Video courtesy of B O'Dea.)

Link to a video walkthrough on X / Twitter of the areas impacted by the TDRA on Park Gate Woods. (Video courtesy B O'Dea.)

Location of the discharge site along the riverside

Proposed outfall site near Burnell Open Space

Park runners in Burnell Open Space. Every weekend, around 350 Park Run participants join a 5K Park Run starting on Burnell Avenue and continue towards Teddington Lock along the tow path, returning back along the river and finishing at the YMCA Hawker Center. Under new TDRA plans this run would become impossible.

River from the Burnell Open Space

Every day, thousands of people use this stretch of the River Thames for recreation.

During the march against the TDRA in the summer of 2023, many joined our protest.

IN CONCLUSION

TDRA is poor value for money, has no convincing validation through the best value model, sets a low environmental bar, is a non-resilient and non-scalable asset, has operational risks that simply are not worth taking, is based on flawed and outdated customer research and shows a lack of any credible social and health impact assessment.

Since the initial 'Best Value' appraisal was carried out there have been significant changes to the TDRA proposals yet there has been no commitment to revisit the best value calculations.

Thames Water’s process has paid lip service to the many better and greener alternatives to solve the challenge identified.

You can rightly ask why if this is so bad is Thames Water pursuing it? We too have scratched our heads over this one. Our only conclusion is because it offers access to enhancement funding as a new asset and that means their regulatory assets go up and they can justify increased borrowing and charging the customer more.

Ham Lands from Maddy Shah Scott on Vimeo.

A film about Ham Lands

This video was created by local Kingston resident Maddy, a final-year student at Manchester University. She created this video as part of her university work. Her focus was to showcase the biodiversity and importance of Ham Lands and how destructive the Thames Water Teddington River Abstraction Scheme would be.

Learn how Ham Lands was created — on gravel pits filled with topsoil (and seeds) from all over London — and why it matters to save the area from any disruption.