Written submission from STOPtheSHAFT Putney
& Barnes
EXECUTIVE SUMMARY
THAMES TUNNEL
STOPtheSHAFT (STS) are a community group formed in
November 2010 order to raise awareness of the proposals for the
Thames Tunnel and choice of Barn Elms as a Main Shaft Site. STS
are in favour of a cleaner Thames but believe alternative sites/strategies
offer less impact the community, wildlife and quality of life.
More than 5,000 people signed a petition against the plans. The
late nature of the group formation and subsequent activity has
shown there was very little public awareness up until recently.
Requirements on awareness activity should therefore be looked
into across the board and built into policy.
STS question validity on 1st stage consultation
by Thames Water, very little engagement or interaction with
local residents. There has been consistent lack of clarity on
the plans and impact to local people. Requirements on readiness
to go to a first or second stage consultation should be investigated.
It is not acceptable to leave all essential detail out until a
Phase 2 stage. Details around NPS requirements of minimum information
provision and methods of engagement at stages of consultation
should be enhanced and relate to information provision for issues
at a local level.
STS is concerned as to the suitability of the
proposed solution and the transparency on the needs for the project
at a local level. Given the nature of an NPS this seems an
understandable flaw for this project (the entire problem is viewed
& solution provided in totality rather than a series of localized
issue fixes which may better benefit the community and lessen
environmental impact and potentially cost to customer base). At
Barn Elms the construction will be very extensive and excessive
in relation to the local problem the CSO's contribute. In
the Putney—Hammersmith stretch of the Thames problems come
from other CSO's in the area. Impacts from legal dumping from
STW during limited capacity has also not been clarified. Ratings
methodology for CSO's in needs documents are unclear and visibility
of alternative localized solutions to remedy problems with cost/benefit
analysis has not been visible. Only a London wide solution is
proposed. This is supports need for any NPS to have a clear
weighting evaluation to Local Authority submissions plus evaluations
from independent bodies; with clear regard given to NGO's
such as RSPB, WWT, National Trust, Commons Conservators and local/national
sporting bodies alongside residential & community groups.
Of major concern to us is the provisions taken
to protect Greenfield or Metropolitan Open Land (MoL) within
the NPS and Thames Water's current site selection process. While
draft NPS provides guidance on preferring Brownfield land over
Greenbelt/MoL this needs to be considerably strengthened even
as far as precluding Greenfield land from consideration where
there are Brownfield alternatives with mandatory requirements
whenever possible that projects are specifically designed to avoid
use of Greenfield/MoL. Independent evaluation of plans is
required to ensure protection of such areas of importance. We
understand Thames Water's Site selection methods imply the
conclusions they have come to on shaft positions or sites is a
function of the way they have chosen to complete the works. If
the works were completed in a different way different conclusions
can be expected. As such, they can choose and argue that Greenfield
or MoL is the only option but the reality is that it is the only
option for the project in its current design form.
STS also have concern for the loose nature of requirements
to evaluate local economic impacts of such projects. NPS should
be stringent in requirements for impact to local economy for initial
site selection.
Visibility on costs and budget for the project
is also of concern.
OVERVIEW ON
ISSUES FOR
EFRA SELECT COMMITTEE
1. Public awareness and consultation flaws:
— Lack
of awareness achieved with community/key stakeholders from many
organisations.
— Thames
Water has not provided adequate information in its consultation.
— Many
local residents and stakeholders still unaware of the proposals.
— Fulham
residents clearly affected by the proposed developments have not
been notified.
— Information
only sent to residents within 250 metres of the selected sites—failed
to reach the majority of the community.
— leaflets
generic and did not clarify local implications.
— Assumptions
made people would have Internet access for follow up.
— Problems
with internet access.
— Lack
of clear explanation in lay terms for completion of feedback.
— Key
stakeholders using Barn Elms (local schools sports clubs) had
no engagement with Thames Water with regards to the consultation
or had any awareness of the project.
— Lack
of alternative sites provided in consultation for a number of
sites only the preferred option was presented as part of the consultation.
— Site
selection methodology questionable—no importance weighting
given to each of the criteria used to select a site.
— no
information given about alternative options or strategies that
would mean the preferred site would not need to be used.
— Lack
of independent verification.
— At
present the validity and legality of the consultation could be
challenged.
— NPS
needs much more prescriptive requirements about the consultation
process.
2. Transparency of needs/selection of solution
The entire scheme relies on one solution strategy
vs. an alternative or hybrid solutions in relation to local problem:
— Very
little consideration of sustainable solutions at suitable locations.
— Cost
of localised alternative solutions may in fact be better for smaller
local issues.
— The
need for two Putney CSO's connection is very unclear. CSO discharge
figures given by Thames Water in the Needs Report show:
— The
three worst CSO's (Abbey Mills, F and A, and Greenwich contribute
to 68% of discharges.
— The
five worst CSO's contribute to 79.3% of discharges.
— The
18 worst CSO's contribute to 98.7% of discharges.
— None
of the CSO's in Putney are included in the worst 18 CSO's.
— Most
of the polluting CSO's are in East London.
— Rating
of CSO's by EA is questionable, no tangible/verified data on local
CSO polluting impacts.
— Lack
of independent evaluation of proposed solutions/alternatives and
options for hybrid approaches and local sustainable solutions
for low impact CSOs.
— Thames
Water cited the CSO at Putney and Barn Elms as reason for Barn
Elms selection.
— Based
on this the proposed development at Barn Elms will require residents
to go through a disproportionate amount of disruption.
— Unclear
if discharge from Mogden will continue going forward.
3. Protection of Greenfield/MoL
Despite the provisions in the NPS for protection
of Greenbelt/MoL:
— Protection
of MoL or Greenfield areas not stringent enough.
— Statutory
protection of MoL should be given since such sites are easy targets
(by nature planning permission is restricted) and Brownfield sites
are inherently attractive to developers and pose problems with
prior planning consents & deterrent for costs of acquisition.
— NPS
should clearly outline that strategies for such projects should
be devised to ensure Brownfield sites are chosen from the outset
and MoL excluded from choice.
— Where
unsuitable Brownfield sites are not available sustainable options
should be weighted as higher priority/weighting (in accordance
with the government's water white paper on sustainability).
4. Evaluation of local economic impacts of
a project
This project is seen as beneficial economically to
London as a whole but immediate local impact should be fully considered
before site choices are made:
— Section
6.15.2 draft NPS Where a project is likely to have socio-economic
impacts an assessment should be undertaken—actually an assessment
of Socio economic impact and evaluation of the local economic
impacts of a proposed site choice should be mandatory before proceeding.
— For
Putney/Barnes towpath this site attracts many tourists/visitors
and if deterred from visiting then local business etc can suffer)
as a consequence.
— Impact
to Putney on reduction in rowing opportunities and business built
up around such activity should be clearly evaluated before consultation.
— Local
business supply chains for impacts to local road infrastructure
etc.
— In
the current form how would it be determined that such an local
assessment should or shouldn't be undertaken.
— Any
local Socio-economic impact should be mandatorily built into site
selection methodology.
January 2011
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