Session 2010-11
Publications on the internet

To be published as HC 736-ii

House of COMMONS



Environment, Food and Rural Affairs Committee

The draft National Policy Statement on Waste Water

Tuesday 25 January 2011



Evidence heard in Public Questions 71 - 153



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Oral Evidence

Taken before the Environment, Food and Rural Affairs Committee

on Tuesday 25 January 2011

Members present:

Miss Anne McIntosh (Chair)

Thomas Docherty

George Eustice

Mrs Mary Glindon

Neil Parish


Examination of Witnesses

Witnesses: Mr Richard Aylard, External Affairs and Sustainability Director, Thames Water, and Mr Phil Stride, Head of Tideway Tunnels, Thames Water, gave evidence.

Q71 Chair : Good morning and welcome. Just for the record, Mr Aylard, could I ask you to introduce your colleague, just so that we have a record?

Richard Aylard: I’m Richard Aylard. I’m the External Affairs and Sustainability Director at Thames Water, and my colleague, Phil Stride, is the Head of the London Tideway Tunnels.

Q72 Chair : You’re both very welcome. We’re most grateful to you for being here with us today, and also for the informal briefing you gave us last week. One question I had at the outset: you gave us an indication last week of what the total cost was going to be. We understood from Ofwat afterwards that the cost projections had already gone up over what had originally been proposed. What reassurance can you give the Committee this morning that these costs-mindful of inflation and possible delays-will remain at the current projected figures?

Richard Aylard: The initial cost was given to the Government in March 2007, when Ian Pearson, the then Water Minister, announced that he wanted us to proceed with a solution. That figure was worked out on the basis of a small team of about six people doing a desktop study to see what was needed, and what the cost was likely to be. At that stage we couldn't justify spending the millions of pounds that were required to work the scheme up in detail, because we didn’t know whether we would be required to go ahead with it. Once we got the goahead from Ian Pearson, we then commissioned a large team, including international experts, of experts in funding, risk, infrastructure, planning-all the disciplines-and it was that process, over a period of more than a year, that produced the latest figure. I’m going to hand over to my colleague, Phil, to talk about exactly what’s in that number and how certain we are we can achieve it.

Phil Stride: The main thing to state is that at the period that Richard mentioned in 2006 it was a highlevel estimate looking at unit costs-for instance, the length of tunnel and number and diameter of shafts. The team of over 100 people that worked for that two years were very much able to understand the design of the project and understand all the component parts that would make up the project, so we were obviously able to provide a better estimate, understanding what all those component parts were. We’ve got a very robust risk management process that was able to consider all the risks involved in the project, and have been able to analyse how much we should allow in our estimate for those risks. On top of that, we’ve also used the HM Treasury Green Book on Optimism Bias, to include an amount of optimism bias that would normally be put into a project of this scale and complexity at this time of its development. That’s why we feel that we have, now, a robust estimate for the project, which we feel confident the project can be delivered for.

Q73 Chair : Just for the record, what does that amount to, per household and per property?

Phil Stride: £3.6 billion is the estimate for the project. We have estimated that the customer bill impact would be just over £1 per week per household on the average bill, so just over £50 per year per customer.

Q74 George Eustice: Do you think that the current Waste Water NPS-the draft one-provides a sufficiently clear framework to help decisionmakers make their decisions on key applications?

Richard Aylard: It is clear, but we think it could be clearer. It talks about need, specifically in terms of whether a project is included in either the Environment Agency’s National Environmental Plan, or a company’s asset management plan. Those aren’t primary sources, however. The real need comes from one of four drivers. First of all, there is a statutory requirement that we as a company have to meet, or it is because there is population growth that’s going to occur that we need to address. It may be, thirdly, because of ageing infrastructure that needs to be replaced, otherwise it will become more expensive to run and a poor deal for customers. The fourth thing is whether it’s to achieve a level of service that customers want, and are willing to pay for. In the two projects included in this NPS, they are clearly both legislative drivers, so we’d like to see a clear reference to what those legislative drivers are, and also the timescale within which the work has to be met. We’d like to see a clearer link established between the fact that a solution to a problem is needed, and needed urgently, or on a specific timetable, and that the identified project is the best way of addressing that need. That is there in the NPS, but we think it could be clearer, and specifically a reference to the individual legislation and the timescales, we believe, would help the Major Infrastructure Planning Unit in reaching their decisions.

Q75 George Eustice: Obviously when the NPS was originally conceived, it was in the era when we were going to have an Infrastructure Planning Commission. Do you think that the fact that that has now gone back into the Department, and the Secretary of State is making these decisions, changes the role of the NPS and its scope?

Richard Aylard: Not as far as we’re concerned. The idea that this would be a special planning procedure for nationally significant infrastructure projects, and that the Government’s policy is there for everyone to see and plan to, remains the same with the change from IPC to the Major Infrastructure Planning Unit, although of course there is parliamentary oversight added, which can only be good for democratic accountability.

Q76 George Eustice: The other thing that quite a few people have criticised is the vagueness of some of the terminology in the NPS, talking about "relevant", you shouldn't do anything that’s "unacceptable", or very subjective terminology in some places. Have you got a view there about whether that should be tightened up, perhaps, by giving clearer definitions to some of those terms?

Richard Aylard: We’d always like things to be as clear as possible. On the other hand, I can see it from the other point of view: these are things that have to be weighed in the balance by the decisionmakers. It’s very difficult to lay down absolute hard and fast rules for everything, because what they are trying to do is make judgments. We need to make the judgment as transparent as possible, give as much information as possible, but there’s a limit to how much one can direct things in general, when you’re looking at very specific local impacts.

Q77 George Eustice: But are there any where you might tighten it up? I can accept things like "reasonable" and "relevant"-that leaves an element of subjectivity in things. But the other one that's cited by some is this term, "associated development", which is used-

Richard Aylard: We don’t have very strong views on that. We think it would be helpful if it were included within the policy statement. If not, we have to apply separately for it through the Town and Country Planning system. It would be easier if it were together, but not insuperable, if that’s what we ended up with. On balance, yes, we’d like to see it there, but it’s not one of our top priority issues.

Phil Stride: In terms of clarity, going on from what Richard said, I think it would also be advantageous if there was greater clarity on the benefits that the project provided. Particularly in terms of the Thames Tunnel, for instance, being clearer about the water quality benefits, the benefits to aesthetics that we talked about previously, health to river users, and also the sustainability of the tideway of the Thames. It would be better if those benefits came out more clearly in the NPS as well. In terms of clarity, one of the comments that we struggle with on good design is "as attractive as possible", which we feel is a very subjective term and one that might lead to some debate as to what that means when we put forward a design.

Q78 Mrs Glindon: Just going on from what you said, particularly in relation to need, would you say that, from the things that you think should be included, that perhaps the criteria for proof of need isn’t as robust a basis for the IPC decisionmaking as it should be?

Richard Aylard: When you say the criteria for need, what do you mean?

Mrs Glindon: Inclusion in the asset management plan, or the National Environment Programme.

Richard Aylard: Yes. That’s a good start, to reference those, but the reason that a project is in one of those two documents lies elsewhere. In the case of really big projects, it’s usually with a statutory driver-we have to do it, by law, so it’s quite helpful to say what the law is, and what the timescale is, rather than just saying, "If it’s in the National Environmental Plan, that’s good enough." We think it could go further by referring back to where that comes from.

Q79 Mrs Glindon: Do you think that the criteria are robust enough for the IPC decisionmaking processes?

Richard Aylard: If a project is included in the National Policy Statement, that’s a pretty clear statement that the Government wants it to be done. However, if the Government can spell out more why they want it to be done, and when they want it to be done, that would help the IPC in conducting their examination. Because that’s got to be set against all the local impact statements that, of course, all the boroughs will naturally come up with.

Q80 Mrs Glindon: And the things that you’ve said. Thank you. So do you think that the NPS should give the IPC some flexibility in interpreting whether need for a project has been determined?

Richard Aylard: Not really. In fact, "No," I think, is the answer to the question. What we want to do is get a clear statement on need, so the Government should assess that. They should do their impact assessment. They should look at what the law says, and then once all that has been done and the draft NPS has been consulted on, the need therefore should be clear. What we’re trying to get away from is the previous planning situations, where an awful long time was spent discussing need before we even got on to the local impacts. If you want a streamlined process, and I think we all do, then you don’t want to have too much flexibility in there. It should be restricted to the planning issues that the IPC are supposed to be looking at, rather than the wider context of the project, which should be in the policy statement.

Q81 Chair : Looking at alternatives: perhaps your project is not the best one to choose, but in other areas, are there other alternatives that, perhaps, if they had been spelled out more fully in the National Policy Statement, would have made a better contribution to the debate?

Richard Aylard: I’ll leave Phil to come on to the Thames Tunnel in a minute, but if we look at Deephams Sewage Treatment Works, that’s the ninth largest works in England, and it treats the waste of more than 800,000 people every day. The works is very old. It’s hard to keep it working at its proper standards, and it won’t meet the new standards coming in in 2017. The range of options we have is pretty limited. We don’t have capacity in any of London’s other sewage works to take 800,000 people’s waste there, so we are faced with either redeveloping on the existing site and an adjacent site, or moving the works altogether. Therefore, the range of options is pretty limited, and they are spelled out in the NPS, although I think they could be a little bit clearer about what we actually have in mind. Our original proposals for this site were put together long before National Policy Statements were even thought of, so we will now have to have a robust site selection methodology and a proper consultation process. The point about the works at Deephams, however, is that the waste from 800,000 people converges there. If you want to build something on a different site, you are going to have to take that waste, which amounts to 200,000 tonnes of waste per day, in a pipe, and pump it somewhere else and build a new works. In terms of what alternatives you have, there isn’t a great deal, other than looking at potential adjacent sites where you could do more with what’s there. Do you want to talk about the alternatives for the Thames Tunnel?

Phil Stride: In terms of the Thames Tunnel, although there is reference to the other alternatives that were considered, I think it could be clearer as to what those alternatives were and how viable they were. It could also record the fact that a significant amount of work went into evaluating those various options between 2000 and 2006, and a clarity that that information was presented to the Minister at the time, who wrote to Thames Water requesting us to proceed with the tunnel option. This again was reinforced by Caroline Spelman in September last year.

Q82 Chair : My question was a more general one in other, smaller scale schemes. I’m particularly keen on looking at sustainable drainage systems, but Water UK have been quite critical, in the sense that the assumptions underlying the National Policy Statement perhaps are overly optimistic. Is that a fair comment?

Richard Aylard: We have to first of all look at the extent to which the National Policy Statement is designed to address projects that are not nationally significant infrastructure projects. By implication, it’s a relevant policy consideration for works that are below the threshold, and it would be useful if that was spelled out. Certainly, in looking at any project, it’s always worth looking at the alternatives. Sustainable urban drainage has certainly got a very large part to play in London, in stopping the existing problem getting worse as London grows. But given how densely populated London is, and given the nature of the geology, it’s not going to play a very significant part, at least in the short and medium term, in dealing with the existing programme. You’ve got to have both a shortterm and a longerterm solution. If the NPS were pointed at smaller projects in guidance terms, as well as the nationally significant ones, that would help to make it clearer what’s to be looked at.

Q83 Neil Parish: Is the National Policy Statement strong enough on the specific sites of both Deephams and the Tunnel? Do you consider it lays out the specific needs for the project to have those sites in place, or would you prefer it to be stronger? Or am I leading you on there?

Richard Aylard: It does lay out the need for the schemes, but we then need the flexibility to, through the consultation process with local people, work out where the best sites are for actually developing the Tunnel. We need to know roughly where it needs to start, roughly where it needs to finish, and which bits we have to pick up along the way. However, exactly where those sites are is not something that should be in the policy statement. That’s a matter for us to work on with local councils and local people and put our proposals to the IPC, or its successor body, to sort out.

Q84 Neil Parish: When it comes to applying for planning permission, then, you are relatively happy with where the National Policy Statement is at the moment?

Richard Aylard: In terms of the geography, yes. It does talk about the options available at Deephams, and it talks about the potential to develop an adjacent site. Again, that could be a bit clearer, but as I was saying earlier, there aren’t too many options for Deephams, because of the fact that it’s part of a fixed network that’s been there for a very long time. We’re not going to be able to rebuild the whole thing in any costeffective way. As far as the Thames Tunnel is concerned, we know the broad route, and the individual sites are not something that should be in the Policy Statement, because it will evolve through the consultation process. Indeed, it is evolving as we speak.

Q85 Neil Parish: Is there sufficient discussion on how the IPC should balance the shortterm local impacts with longterm benefits in relation to the Tunnel and Deephams?

Richard Aylard: Again it’s a question of how much direction is to be given to the IPC, and how much they’re to be left to make their own judgments. If the whole task is about balancing Government policy for these projects with local impacts, then they need to be left the discretion to make those tradeoffs in their own way, having heard evidence from both sides. I’m not sure it’s possible to give them very much clearer direction from the outset, except in general terms: The Policy Statement could talk, as it does, about the need to make sure that anything that is proposed is sustainable. There’s a sustainability assessment in the National Policy Statement, which is helpful, and we welcome it.

Q86 Neil Parish: Okay, you’ve reinforced that. Does the Generic Impacts section of the NPS provide adequate guidance for decisionmakers on the relative weight they should give to the specific impacts of the schemes?

Richard Aylard: It certainly records what the potential impacts are, the things that the IPC should be looking at-although of course they’ll get very strong input from local councils through the local impact statements. The extent to which you can weight different factors depends very much on the individual locality. If you’ve got housing development right up to the edge of a sewage treatment works, odour is going to be a bigger factor than if you’re fortunate enough to have a barrier between you and the nearest local people. The same would apply with noise. Therefore, some of those things can be looked at through a sustainability appraisal. Otherwise they have to be interpreted in a local context, and that’s really the job of the IPC to do that when they have the input from the boroughs, which we think is very important.

Phil Stride: Definitely. Obviously that’s been done based on the level of information there is currently-or there was a while ago, when this was done. As the scheme develops you’ll be able to make those judgments in the context of more detailed information in relation to the sites. That’s why, for both projects, it’s been difficult to make a judgment at this stage.

Q87 Neil Parish: So when this goes to planning, you are relatively happy that, as far as you are concerned, the National Policy Statement will back up what you want to do?

Richard Aylard: Yes. It’s a clear statement of policy. As I say, we thought that the need could be spelled out more clearly. There are areas where the language could be tightened up, and we’re going to comment on some of those in detail in our response to Defra. But in principle, the Statement of Policy, our planning application, which will have been developed through two full stages of public consultation, and the local impact statements from the borough, give the decisionmakers what they need to weigh up the proposal.

Q88 George Eustice: What you say is entirely logical, but isn’t there a danger there that by not ascribing some kind of weight to these various factors, you will end up with a situation where there will be a great deal of variance in terms of how the NPS is interpreted locally, and that that therefore almost undermines the purpose of the NPS? Saying that you should take account of odour is not exactly a revelation to most people. A normal planning committee would do just that, without an NPS.

Richard Aylard: Yes, but I think they would give it a different weighting, depending on how close people were living to the site. They’d look at prevailing wind. There are a range of different local factors. Noise is a good one. If we’ve got people within 100 metres of a sewage works, then a noisy plant going late at night is a big problem. If we’re talking about something out in the country, we wouldn't want to spend an awful lot of money on noise suppression, because there’s noone there to hear it, or noone close enough to hear it. We have to accept that the local factors are important, but there is some pretty good guidance in there. The odour standard is one thing that we think needs to be looked at. The odour standard that’s been suggested is much tighter than is in the existing Defra guidance. Existing Defra guidance talks about the need for flexibility, depending on local circumstances. There’s a mismatch there that needs to be sorted out. For example, Mogden Sewage Works literally has housing development all around, and is right next to Tesco’s and Twickenham rugby ground. Odour is a bigger issue there than for some of our smaller, more rural sites, which are literally out in the country.

Q89 Thomas Docherty: I understand what you’re saying about smaller projects. Regarding the specifics of the two London projects that have been notified in the NPS, could you usefully have a discussion under the Generic Impacts section of the NPS about both the likely impact for the area, and what possible ameliorations would be available? My very brief reading of it is that it’s quite a dry, factual section that doesn’t put much flesh on as a discussion. Or do you think that’s better left to the planning application itself?

Richard Aylard: To be honest, it’s something that is central to the consultation process. We’ve just done a first phase consultation with local communities up and down the route of the proposed Thames Tunnel. We’ll be doing another full phase of consultation from September, all before we submit our planning application. Local impacts are being identified by that process, and they’re being addressed-in some cases we’re moving sites completely. To try and spell that out in a policy statement would be too early and too prescriptive. The NPS should state that local impacts are really important. It should give a very strong emphasis on the role of the Boroughs and their local impact statements, which I know some of the Boroughs have concerns about. I’m sure you’ll hear about those later on. We think they’re important, but they’re being addressed through the consultation process. There are big, big changes going on, and I think will do with any project of this scale.

Q90 Thomas Docherty: You’ve led me very nicely on to my next question. What impacts have been identified so far as being of particular concern from the consultations that you’ve had? There is possibly a difference here between what the local planning team is concerned about, and what the local residents, or resident groups, are concerned about.

Phil Stride: The main concerns are obviously where we’re proposing to build on open space or recreational areas. That’s been the greatest amount of pushback that we’ve had, currently, in people’s concerns. That's followed by traffic movements taking materials to site and taking materials away, potentially. People are very concerned about traffic movements. They’re also concerned about noise from the site during the construction phase, and other issues that probably aren’t as prominent as that, such as light nuisance from the sites, and certainly odour as well. In that sort of order, those are the main points that people have been concerned about.

Q91 Thomas Docherty: You’ll appreciate that we’ve had some submissions-I don’t know whether you’ve seen them yet-from some of the local groups. It’s not our job to get into the specifics of that, but could I ask a policy question? What would be your assessment of the likely cost and the impact on the project if you were to use brownfield sites-you’ve mentioned playing fields and so on before-rather than some of the greenfield sites you’re looking at?

Richard Aylard: We’re looking at very few greenfield sites.

Phil Stride: Of the 22 sites that we’ve currently identified as being required by the Thames Tunnel, only three of those construction sites are on greenfield sites, if you like.

Q92 Thomas Docherty: Can you just confirm which ones they are?

Phil Stride: I will go on to another category in a minute, but the main greenfield sites are Barn Elms in the London Borough of Richmond, King’s Stairs Gardens in the London Borough of Southwark, and King George Park, which is in Wandsworth. Those are the three sites where we propose a construction site in a park or recreational area. There are also a couple of sites where we’ve proposed an access way through a park, in two cases: one in Chelsea and one in Tower Hamlets. I think you mentioned that previously. Those are the areas where we’ve proposed to build in a park area.

Q93 Thomas Docherty: What’s the impact?

Richard Aylard: The point is that we’ve been out and consulted. We’ve got a lot of feedback. We’re now assessing all of that. We’re looking at what local people are suggesting. In some cases it’s clear we’ll be going to entirely different sites. In other cases it’s clear we’ll be able to propose some mitigation. Exactly what we can do is still being worked through, and will be in our consultation response, which comes out at the end of March. The costs are being worked through. In general, there is always a tradeoff on costs. Communities up and down the river would like us to use the river for 100% of materials-taking the excavated material out, and bringing materials in. We can’t do 100%, because that would undoubtedly be ridiculous in terms of cost. We can, however, go a long way. Exactly how far we can go, and exactly what we can do at each site, is being worked out, and will be part of the phase two consultation. Where we’ve had to go for greenfield sites at the moment, it’s because we simply haven’t been able to identify brownfield sites that are suitable where we need them. Again, in some cases that’s being reworked, and there will be some different proposals in some areas when we come back with the second phase in September. It’s not for want of trying. We’re very clear that greenfields would be a last resort. In some cases we are currently at last resort, but we can backcheck and see if we can move things in a more positive direction.

Phil Stride: Yes. We have followed our site selection methodology, which we agreed with all the London boroughs, to the letter. It clearly states in there that we would obviously prefer to use brownfield sites. We’ve followed that, and another point in relation to cost is that the cost difference between purchasing a brownfield site and a recreational park area isn’t as great as it may appear, because although we would need 100% of the area we purchased for the construction phase of the project, we would probably only need something in the order of 15% to 20% of that area for the permanent operational site. So we would be able to sell on a large part of what we’d purchased after the scheme had been commissioned, which would obviously be netted off against the cost that we paid for it initially. So that cost differential isn’t as great as it may appear.

Q94 Neil Parish: Can I follow you up on this? There is an argument that since you first put the plan through, the recession has hit, and there could well be some brownfield sites that may be available and may be available at a competitive price. I think you are saying that you are relooking, as far as King’s Stairs Gardens is concerned, or whatever. You are still looking for alternatives, are you? Is that fair to say?

Phil Stride: The key thing is that when we went out, we were sharing our proposed scheme. We’d done a certain amount of work to be able to describe to everyone involved what we planned to do. A key part of that was that we were keen for local feedback, to understand whether there was information we’d missed, things that we hadn’t perhaps looked at that would have been possible. Certainly, in the case in point, the feedback we had from the residents of King’s Stairs Gardens was that there was a piece of land, a brownfield site, not that far from the gardens. The developers, when we’d approached them 12 months previously, had said that by the time we got to October/November 2010, they would probably be three storeys out of the ground and the residential development would be well under way, and part of our site selection methodology was that we wouldn't, as part of this scheme, knock down residential development. Where that’s occurred, we have been very proactive in understanding what that opportunity was, who was selling it, and whether there was an opportunity for Thames Water to acquire that land so that we had a brownfield site rather than a greenfield site. Certainly, whilst that situation on this particular area is commercially sensitive, we are vigorously pursuing that opportunity.

Q95 George Eustice: I wanted to get your view on the issue of how you balance out the economic costs and benefits. When we had evidence from Ofwat last week, one of the concerns they had was that, as currently drafted, the NPS envisages that the very fact that a project is listed on a project plan-business plan-signed off by Ofwat gives the impression that it’s the best value option, and they were very keen to stress that that’s not their role. They suggested that perhaps we needed more clarity and should include a requirement for applicants to demonstrate, within the NPS, that it was the most costeffective option. Have you got a view on that?

Richard Aylard: Cost comes into this in two ways. The first is the base cost of delivering the project, which is something that’s looked at for nationally significant infrastructure projects, by the Government, when they look at the legislation, and when they do the impact assessments. If you’ve got a legislative requirement, then your aim is to meet that legislative requirement at least cost, so options appraisal comes into that. That’s the first stage. That should be done before the NPS is finalised. Once the NPS is finalised, cost then comes into it when you’re looking at what might be done in terms of mitigation for local impacts-the kind of things that might otherwise have been done through a Section 106 agreement with councils, and things that might add to cost, such as particular design elements. We think because those things are local impacts they should be looked at in the discussions with the IPC, with the company’s proposals on one hand, and the local impact statements from the councils on the other. Clearly we recognise that big projects can have big impacts, and often big localised impacts, and that those need to be mitigated, and that there’s a cost to doing that. However, there is equally a reasonable limit to what that cost should be. We see it as part of the role of the IPC to establish what that cost is. In terms of whether a particular option is a costeffective way of dealing with the need, which is driven by a legislative driver in the two cases we’re talking about, we think that should be done before the NPS is finalised, rather than revisiting all of that when we get to planning.

Q96 George Eustice: So you don’t think it necessarily requires some sort of benefittocosts ratio to be-?

Richard Aylard: Not within the discussions that take place once the NPS has been finalised. That should be done before you get to that stage. I point out again that it is very difficult to talk about whether the cost is reasonable; if you have to meet a particular legislative requirement it’s a question of how cheaply that can be done effectively. The test you go through is that whatever we build has got to work, it’s got to be safe, reliable, and deliver the standards. It has to be as costeffective as possible in order to keep bills down for customers. Then there are factors like mitigation, local impacts, and design, which come into the equation as well.

Q97 George Eustice: I’m going to move on to the issue of the economic impacts on customers. As it’s currently drafted, the NPS very much looks at things through the prism of the planning system, and it’s all about impacts on the local economy and the economic benefits that might be delivered by an infrastructure improvement. As someone who represents a South West seat, I’m very conscious of the way that this can have an impact on water customers. Do you think that there needs to be a more explicit recognition of the impact on water customers? You mentioned the £50 increase in your bills. Does that need to be more explicitly recognised within the NPS?

Richard Aylard: It is in there, and I think it is something that needs to be looked at for each individual project. The nationally significant projects, as I say, tend to be driven by a legislative driver, so you haven’t got too much flexibility there. For some of the smaller projects-in fact, for all of the smaller projects where the National Policy Statement is seen as guidance-there is already a value-for-money test before anything is included in a company’s asset management plan with the regulator. It’s Ofwat’s job to make sure that bills are as high as they need to be and no higher. There are pretty strong constraints on us as a business from going around spending customers’ money that doesn’t need to be spent.

Q98 George Eustice: You don’t think there’s a danger of future conflict between the water regulator, who set the cap about what an acceptable water bill is, and the NPS, which has a slightly different focus in the economic benefits that it weighs up?

Richard Aylard: There’s always going to be that tension where you have legislative requirements that have to be met by a water company, with a system that says the costs will be borne by customers. But the existing balance in the system between Ofwat and the quality regulators, the EA and the DWI, with the Government setting policy, works as well as the system can be devised. The other question, of course, is the affordability factors, which I know the Government is looking at with the Walker Review: things like a social tariff, which we as Thames Water have been pushing, as the Chair knows, for some time, because we think there is a need to protect our least welloff customers, and I’m sure that would apply in the South West as well, although of course I don’t know that area.

George Eustice: I’m sure the Chair would rather not talk about South West Water bills again, having covered it in detail previously.

Chair : The Chair remains completely impartial.

Q99 Mrs Glindon: Just going on from that, you’ve already mentioned design and cost. Do you think that the NPS should be specifically amended to take into account the need to balance the benefits of good design with costs? If so, would you think of any principles that the NPS should include in guiding the IPC on weighing costs against benefits?

Phil Stride: The main thing on the design element is that in terms of the design of the Thames Tunnel, which I know best, as with any design, we’re trying to make sure that the project is the optimum project to deliver the scheme objectives and deliver proper value for money. That’s the key objective. In terms of the engineering aspects of it, we need to make sure it delivers the function, its functionality is right, and it delivers the output that’s required. Obviously a subset of that is aesthetics. It is just how you judge those and balance those together. Also, it could be reinforced to pick up operational issues. A design has to be functional-as a company, we need to be able to operate the plant once it is installed. It needs to be operated in a safe way and obviously it needs to be secure. There are lots of aspects of design that it could be clearer on, in terms of how you balance all those different parameters.

Q100 Thomas Docherty: There’s always a bit of a discussion about what is consultation, and what is sharing of information. Having worked for companies that used to do consultations, I understand that there can be a difference between the two. Specifically on consultation, rather than providing information to the public, how effective do you think the consultation and dialogue has been on the preparation of the NPS with the public-specifically with the London focus on the major projects?

Richard Aylard: Regarding the NPS specifically, the Government has been consulting. We’ve just put a link on our Thames Tunnel consultation website to the NPS consultation. It’s on the front page and it is flagged up, to try to direct people there. We’ve seen that you’ve had good input from London Councils, the GLA, the EA and others, but I’d be surprised if very many communities and individuals have been reached by it. I don’t know whether that was the aim or not. It may be that this is the kind of consultation that is particularly aimed at, for want of a better word, the specialists and the statutory bodies, rather than local communities. Local communities have certainly responded in their droves to our consultation on the specific project. I think we need a different level of consultation for the NPS than for the projects that are covered within it.

Q101 Thomas Docherty: I think that’s probably a fair assessment. Do you think that there are lessons, therefore, that the Government can learn, either from yourself or other organisations, about engagement with the public?

Richard Aylard: I suspect that there are. We’ve certainly been working very closely with the Defra officials. They came to some of our consultation exhibitions, and they’ve been talking to us about ways in which the two consultations can feed into each other. Consultation isn’t easy. First of all there is a tradeoff between starting it very early, when people say, "You haven’t even thought this through yet, so why have you come to us to consult?" or leaving it too late, and then they say, "This is all decided, it isn’t consultation." You have to find somewhere along the way to do it, and we’ve erred on the side of caution with our consultation, and started quite early. The other thing is just finding a way of reaching the individual customer, or citizen, from the Government’s perspective. People tend not to read things that come through the letterbox, whatever you put on the outside of the envelope. Even when we do radio advertising, newspapers, and television interviews, a remarkable number of people say, "This is the first I’ve heard of it." I’m afraid this is an issue where I don’t have any magic answers other than to say that Defra are working with us, and we’ll continue working with them on this.

Q102 Thomas Docherty: This was my area of specialty before I came here. There’s obviously a concern that the public will be surprised at the NPS, because it doesn’t have an engagement. I accept the point about the statutories, and that the professional consultees are being consulted. Do you think that that is a realistic danger that we face-that we’ll get to a situation in three or six months’ time where there will be something of an outcry amongst the public that they haven’t been adequately engaged and consulted in the NPS?

Richard Aylard: Personally I don’t think so, because people will still have a very real opportunity to be consulted on the individual projects within the NPS. A lot of the content of the NPS is the thing that you’d expect the boroughs and representative bodies to be making their views known on. Perhaps you’d expect some technical organisations too. I don’t think it’s the stuff of individual community groups. That’s just a personal view. Phil, would you agree with that?

Phil Stride: Richard and I have done over 200 external presentations over a period of time, so obviously that’s helped in our getting the message out about the Thames Tunnel. The key thing that I would add to that, which perhaps has surprised us over the last six months, is particularly that when we’ve gone out to do public meetings and the like, we’ve had very little pushback about the need for the project. Of the comments that people have, comments about the need for the project have been in the low percentages. The vast majority, in the 90% area, has been about the local impact of the project. Even if you take the residents at King’s Stairs Gardens, or residents of Barn Elms, they support the need for the project, but they’re just very concerned about their local park. Relating that to the NPS, the NPS is about describing the need for the project, which we’ve had very little pushback on. Hopefully that would relate to whether there would be a public outcry about the need. I don’t think there would. I think Nick Raynsford at one meeting called it "universal support" for the need for the project. In my view, having gone to many, many groups, there is heavy buyin for the need to do the project.

Q103 Chair : Just before we release you, can I ask when you expect to do the environmental impact assessment?

Richard Aylard: Work on that has started. In order to get a sensible environmental impact assessment it has to be done over more than one season, so that work is ongoing now and it will ramp up. It will be there to accompany the planning application in the middle of next year.

Phil Stride: Yes indeed, and we’ll have some initial outputs from it when we start the public consultation phase two on 5 September this year.

Q104 Chair : Is that the same for the Habitats Regulations Assessment?

Phil Stride: Yes. That work’s also ongoing.

Chair : We’re very grateful to you for being with us, and I’m sure we’ll have other opportunities to discuss this and other matters with you in future. Thank you very much.

Examination of Witnesses

Witnesses: Ms Isabel Dedring, Mayor’s Advisor on the Environment, GLA, and Cllr Catherine West, Chair, London Councils’ Transport and Environment Committee and Leader of London Borough of Islington, gave evidence.

Q105 Chair : Good morning, and welcome. Can I just for the record perhaps ask Councillor West to introduce yourself and your partner, as well?

Catherine West: I’m Councillor Catherine West. I’m the leader of Islington Council, and I’m also the Chair of the Transport and Environment Committee.

Isabel Dedring: My name’s Isabel Dedring. I’m the Mayor of London’s environmental advisor.

Q106 Chair : We’re very grateful to you both for being here. Presumably this isn’t going to be an issue in the forthcoming elections as far as you’re concerned?

Catherine West: You mean the Mayoral elections 2012?

Chair : Yes.

Catherine West: I’m not sure if it’s quite on the horizon of your average resident yet, but we’ll see.

Q107 Chair : If I could just ask you at the outset: we’ve already heard, in a previous evidence session, that the initial projected cost of the Thames Tunnel, just taking that one specific project, has increased. While it might seem a reasonable cost at the moment of £50 per customer, are you concerned that if there was a further increase for any reason, this would pose difficulties for the residents?

Catherine West: Cost is the No. 1 issue here because obviously, as Mr Eustice MP pointed out just earlier, we do have to be mindful of what people are going through in their everyday lives right now. We have a large number of London residents living on very, very low incomes indeed. In my own ward, up to 60% of children are on free school meals, and so on. That’s a household income of £16,000. So we have to be very mindful of putting another £50 on to people. It may not sound a lot per week, but it does add up. We know that people are getting into more problems with debt and so on. I’m very, very worried about the cost implications of the project. Even though, of course, we all want to tackle pollution in the Thames and we think this is the way forward, we are extremely worried about cost, and wondering whether there’s any way of inserting some form of competition in there with other providers to try and see if we can drive down the costs. Reading the paperwork quickly this morning, it seems that at the moment, it’s a little bit of a shooin for Thames Water. I wonder whether there’s any way that we can insert a way of driving down the construction costs, or other things that come online. What effort is being made within the Statement to try to push in that direction?

Q108 Chair : We’ll come on to the specific project in a moment, if we may. Could I ask you a general question as regards the fitness for purpose of the National Policy Statement for Waste Water? Generally, do you believe it is fit for purpose, and do you believe that the IPC powers are appropriate and proportionate?

Isabel Dedring: I think generally we’re supportive of the overall statement. There are a few points that we can pick up as we go through, but there is one main one that we would want to make. In the overall principles at 5.1, the statement talks about the key guiding principles for assessment. We’ve suggested in our response that there be a third one added, looking at specifically minimising disruption to local communities, given the importance of that, as we’ve just been hearing.

Q109 Chair : That’s helpful. Do you believe that the draft NPS provides decisionmakers with a sufficiently clear framework to enable them to decide on applications for a nationally significant waste water development?

Isabel Dedring: I would tend to agree with-I think it was the Chief Executive of Ofwat-who said that the greater transparency we can get, the better, in terms of clarity about what exactly the NPS is looking to consider. For example, rather than saying, "Let’s make sure the costs have been minimised," we should say, "What kind of evidence would you want to see to make sure that you’re convinced that costs are minimised?" Otherwise I think there’s a risk that some of these issues get skimmed over. I tend to think-not always in life, but in this particular instance-the more we can say about what the IPC or a successor body would be looking for in terms of adequate evidence, the better.

Catherine West: Similarly, I think anything that we can set down early on-Ofwat has a bit of an upanddown history of holding these companies to account. Sometimes they do well, other times they do less well. To completely rely on them may be leaving it in the hands of a group that’s not always had the best reputation. Particularly if you look at the leakage issues that we’ve had in London in the last couple of years, the replacing of the Victorian piping and so on, it hasn’t always been the best model of cost, and hasn’t always been the best model of consultation with residents. If that’s the track record that we’re going on, we need to be a little bit firmer with them at the statement level, so that we have some safeguards in place for residents.

Isabel Dedring: Can I just come back to the £50 point? The Mayor’s always been clear that he supports this scheme, but on the condition that it’s minimising cost and disruption for local communities as regards the cost and disruption, obviously, for all Londoners. There is a procedural issue, which is that the costs may continue to shift over the course of the project, but obviously the NPS exercise will be done at some point. Is there anything that can be put in the ruling, so to speak, from the IPC that says, "This is contingent on something," or "We’re expecting X"? I have no idea whether that’s within the remit, but that is the issue: that the costs will be said to be whatever they are, and then subsequently they may rise. A lot of other projects have shown that.

The other point I wanted to make on that was the link to water metering, which is alluded to in the NPS. However, there’s quite a lot of language in the NPS that isn’t very specific about how it actually informs the decisionmaking. It’s just statements of fact. It mentions that metering is coming forward, but with a hit like £50 on a household’s bill, certainly metering is looking at those kinds of things. Could you have a different tariff structure for lowerincome households, or people who are most affected, or a sunset period, or something like that? Again, there’s clearly a link between those two issues.

Catherine West: Just to follow up on that, obviously you’d all be aware that not everybody’s in the same position, and therefore having another look at metering would be very positive. Whether that’s within the scope of this particular exercise I'm not sure, but at some point we do have to look more closely at the fact that, while it’s a very convenient way to pay, it’s not necessarily a value-for-money way to pay for all customers. It would be good to look at that again. If we could lever that in on behalf of the consumer while we’re doing this exercise-while we’ve got them in a position that they’re listening to us-that may be a positive outcome for residents.

Q110 Chair : If there’s a major Water Bill, which we hope there will be in 2012, it’s one of the things that could be factored in. Bearing in mind that you’ve identified a number of omissions already, do you believe that the Government should formally approve the draft National Policy Statement for Waste Water as it is, or would you be minded for them to revise this draft, as they seem open to doing?

Catherine West: I’d like to see some amendments, and we can write to you in detail with those.

Chair : That would be good.

Catherine West: Of course, the other thing I haven’t mentioned yet is the question of the cost to the local authorities. There are resource implications on this particular exercise. There are a number of former councillors in the room who will appreciate that local authorities’ money doesn’t grow on trees, and we need to have the proper resourcing in there to do things properly. Local authorities are experts at consultation, and all those difficult consultation points that were made formally. We do have some best practice examples within local authorities. Some are better than others, but if we take away all the resource, they’re not going to be very good at all. We do need to look at the resource implication for local authorities.

Chair : We would, I’m sure, be grateful. We will minute that you are prepared to write to us with those details.

Catherine West: Yes.

Q111 George Eustice: I wanted to pick up on this issue of the terminology in the NPS, because quite a bit of the evidence that we’ve had says that it’s a bit too woolly in areas: terms like, "all reasonable steps", words like, "relevant". I think just now we heard another one, which was that buildings should be "as attractive as possible". Do you think that it can be tightened up in any way?

Isabel Dedring: The document feels slightly schizophrenic to me, in the sense that it’s both talking about how the works are conducted, and whether indeed the whole scope and the strategic purpose of the work is correct. It’s fine if it’s doing both of those things, but it’s not entirely clear. It seems to be trying to straddle both things. Perhaps it’s not really trying to reopen any of the strategic questions, and simply accepting the scope of the works-not whether we need a tunnel or not, for example, but whether exactly that scale and scope of activity is required. If it’s not touching that, then the point about the specificity is probably less critical, because it is not seeking to assess, for example, the depth to which alternatives were looked at-should there be more provision for demandside management, or SUDS-and prove what exactly has been looked at, and what is the evidence on which that was rejected. If that whole set of questions isn’t trying to be opened up, then in a sense I think the specificity point is less relevant. It’s almost a question for you.

Q112 George Eustice: Does it, though, undermine the purpose of the NPS? You could end up with quite a lot of variation in how it’s interpreted. It becomes a list of "motherhood and apple pie" objectives, which most planners would have at the front of their mind anyway when they assess these.

Isabel Dedring: My own view would be that it’s better to have specificity. What’s interesting is that the water industry players seem to be saying that as well. You might expect them to say, "No, we don’t want that," because they want the room to interpret it as they would like, but actually they don’t want the risk of a Committee subsequently saying, "Oh no, we meant x when we said that." There should be further elaboration, not of what the right answer is, but, "We will expect evidence to be shown that you have looked at the following things," and that would be a definition of what we would consider to be reasonable, for example.

Q113 George Eustice: Of those things, the other one that’s been picked up quite a bit is this term "associated development", which I think it talks about, and which again is a very broad term.

Isabel Dedring: I think you were asking the question earlier about the design. One concern we particularly had was that some of the comments seem to be focused on the architecture of the structure rather than the overall design of the project, and to what extent design principles have been considered. That would be another example where I would say that the overall terminology may be slightly wrong, and then the specificity isn’t there either, which would help to clarify the point.

Catherine West: I wonder if I could just make a quick comment there. You mentioned that it was schizophrenic. The other thing that is not consonant with the other big project we’re doing at the moment is emphasising the importance of localism. This does seem to be opposite to localism, doesn’t it, because it is very topdown. Your average person walking by on Westminster Bridge wouldn't know that we were talking about something that is very, very significant to them, which will have a cost impact on their budgets. I just wonder what the relationship is between current work being done on the Localism Bill, and the Neighbourhood Development Plans, and this very project. In a way, this is a good test case for how the Neighbourhood Development Plans might work. That might be a good little piece of work, to get the officers working on how these outlets would work in terms of a Neighbourhood Development Plan. If everybody in the local area suddenly said, "We do not want our park disturbed by this," what would we do? Would we stop it? Is it over? What’s the relationship between that? I wonder whether this might be a good thing to look at. As often happens with both local authority and Government work, we’re carrying on in separate but parallel universes, and I wonder whether we could try to marry them up and see what the impact would be. It’s a nice little test case. We all need this-this city needs this-but how do we get that balance right between the local and what is needed nationally, in a big infrastructure project?

Q114 George Eustice: Clearly the idea of this NPS was conceived at a time when a lot of big infrastructure planning was going to go to the IPC. I accept that the NPS was also intended for councils, so it’s definitely got a role there. Does the fact that the IPC has gone, and those responsibilities have gone back to the Secretary of State, alter what the scope and focus of the NPS should be?

Catherine West: I think we can work it together, but we need to be clear about what the parameters are. I do want to champion the role of councils here in understanding how planning works. It’s popular out there to poohpooh the work of planning done by councils, but councils are best placed. They do understand their local communities. I’d also like to speak up for the role of the local councillor, in terms of knowing who the neighbours are and who the usual suspects are, and whether the usual suspects represent one street, or a genuine feeling in the community, all those sorts of things. I feel it would be good to have that piece of work done as a test case, and to involve more councillors. The other thing about the structure of councils at the moment, as you would know, is that you’ve got slightly different planning arrangements in different local authorities. Some are quite centralised. We’ve got a quite centralised structure in Islington. Phew! In other councils, they’re very devolved down to the ward level. We do need to take that structure into account when we look at this project. We wouldn't want massive delays and court battles, and residents taking councils to court, and all this sort of thing, when we could have resolved it at this stage just by being clear. If we can clarify it at this stage, then I think we can move forward and everybody will know what system they’re at least trying to play with.

Q115 Mrs Glindon: Going on from that, and as a former Councillor myself, I think what you’ve said is very true. My question is: what representations have you received from people who live and work locally about the need for the Thames Tunnel and the Deephams Sewage Works? You’ve got some knowledge, so have you had that kind of representation?

Catherine West: The main thing is that everybody knows that there is nothing worse than seeing a dead fish in the Thames. Everybody knows something has to be done, but it’s the what, isn’t it? Currently, everybody seems to be worried about finance. That seems to be the overriding thing. The cost of the project does seem to be quite massive. We all know it’s the right thing to do, but, as is the case with a lot of the environmental projects that we’re struggling with at the moment nationally, the question is how much weight we put on the green agenda when we know that the economy is so fragile, and people’s pockets are really hurting. It’s all about that kind of balance. Nobody’s come to me to say this is a good or a bad idea, but what happened with the laying of the Victorian pipes was that nobody came to me beforehand, but as soon as there was a problem, boy did they come running. In a sense, what you want to do is set up the framework and the machinery, which is what your Committee’s trying to do now, so that when the problems arise, we’ve got a basket that holds those problems and allows them to be resolved in a way that doesn’t lead to some awful, longdrawnout legal dispute between residents, councils and so on. I know, and you would all be aware of this, that some resident groups can get some decent lawyers on board, and then you’ve got all of your lowincome groups who could never afford to do their Neighbourhood Plans, could they? We still have to resolve that one, and how we get an equitable outcome on all those questions.

Q116 Mrs Glindon: Going on from that, do you think that the case justifying the need for the Tunnel and the sewage scheme is made strongly enough for you within the NPS so that decisionmakers can rely on it when considering another planning application? Is that backup there?

Catherine West: What we need to see is a bit more of how it’s actually going to work in practice on the planning side, and also, clearly, from a local authority point of view, how the costs will be mitigated from our point of view. Our planning teams are all, at the moment, being basically reduced, and then if we have these large projects, how will we then be able to manage them? If there is suddenly a duty on local authorities to get quite involved, if we’re not being compensated financially, then your average local council planning team will have quite a lot of difficulty in responding to what might be quite a challenging set of circumstances without having the power to necessarily effect change. I don’t know if you want to add to that, Isabel?

Isabel Dedring: There’s an overall question about whether there is a need for the Tunnel overall, which I don’t think anybody’s really wanting to reopen. Then there’s the question about the costs, and the impacts of the works themselves as they’re going on. There is this middle-territory question, however, about the cost of the Tunnel itself. It’s not as if building a tunnel equals a known cost out there, and everybody knows it costs £120 or whatever it is. Particularly if Ofwat, as you were saying earlier, doesn’t think that their job is to look after best value on that question, then who is asking that question in the process? It isn’t about whether we need a tunnel, and it isn’t about just accepting the tunnel is the way it is and trying to minimise the cost to the planning authorities and the disruption to local communities. It is not totally clear to me from this document, if Ofwat isn’t playing that role, whether the IPC is supposed to play that role. Certainly our experience of the interactions between Thames Water and Ofwat is that often there’s quite a lot of commonality of view, not necessarily due to design but just because there are a lot of discussions, and new ideas aren’t always being brought into the mix. They might not provide the level of challenge that one might be looking for in certain cases. We’ve had longrunning discussions with them about demand side measures, talking to residents about even simple things like what kind of toilets people buy-those kinds of things. There is an emphasis, to a certain extent, on demandside measures, but neither Ofwat nor Thames Water have placed a huge emphasis on it in the past. That’s just one example where there isn’t necessarily pressure coming from either side on an issue like that. If they don’t think it’s in their remit to look at the best value question, there may not be pressure that you would think would be sufficient on the cost side.

Q117 Mrs Glindon: Overall, do you think it would be more helpful if the NPS could make a more comprehensive case for it, and give you more support? Do you feel that, for the decisionmakers to be able to make the decisions, there should be more in it?

Isabel Dedring: It goes back to what evidence the IPC should be equipped with to make a decision, and what level of detail they are going to be asking for. If they just say, "Tell us something about x," there’s a lot of room for interpretation there. It does go back to that point.

Q118 Chair : Can I just press you-are we talking semantics here? What’s the difference between cost-benefit analysis and value for money? When we heard from Ofwat last week, they spoke at great length about the cost-benefit analysis that they see very clearly as their role. What’s the difference between establishing value for money and undertaking a cost-benefit analysis?

Isabel Dedring: As long as the costs are lower than the benefits, that’s good, from a cost-benefit analysis standpoint, but is it the best value thing that you could have done? To me the question is, is there an even cheaper option that still delivers those benefits? We’ve had, over the years, various discussions with Thames Water and Ofwat on those kinds of subjects-not relating to the Tunnel, necessarily, but on a whole range of issues. If Ofwat were indeed saying that it’s not technically their role to look for the best-or lowestcost, let’s say-option to deliver that same benefit, then that is an issue. In other words, not, "Should we do a tunnel? The benefits are 100, the costs are 80: yes, we should," but "Could we do a tunnel for 60 instead of 80 that still delivers the same benefits?" When you start talking about the rate payer, then that starts to become relevant, because obviously a difference of £40 rather than £50 will make a difference to the rate payer.

Q119 Chair : My understanding is that so much of this is driven by the EU Directives, in particular the EU Urban Waste Water Treatment Directive, so to a certain extent, we have to comply.

Isabel Dedring: There are many ways to deliver outcomes in general, in life. It’s for the IPC to be reassured that other alternatives to deliver that same outcome have been considered. I don’t mean alternatives to a tunnel, I mean within the context of the Tunnel. They’ve looked at alternatives in the way they’ve done it, to bring down the costs of the Tunnel. I would certainly be wanting that kind of information to be presented, to make sure that it was the lowest cost, while still delivering everything it needs to deliver, alternative on the table.

Catherine West: Just to add that in the current circumstances financially, we should be pushing our contracts much, much harder, as we are at local council level. We know that we’re getting about 15% off all of the work we commissioned. We need to push whoever it is that’s doing the deal with Thames Water, given that it seems to be almost theirs, to try to get those costs down as far as possible. In the end, as an upstanding company, they will want to look to the EU and obey all the regulations on that. The question for us is whether we can get them to really bring those costs down. I wonder whether within the statement it’s also possible to try and make some broad values around the sort of work that gets carried out in the Thames area. I know that with any large infrastructure project you should be looking at things like apprenticeships: is it providing local employment for people who live in the Thames area? You should be looking at some of the values-obviously value for money is No. 1, but some of the other things such as considerate construction practices, all those other sorts of things. That’s a long way down the line from what we’re talking about today, but if we can start already putting some values like that into it, it’s giving a signal to some of the larger construction companies that we want some other benefits. It is not just about the finished product but also, within the process, how we could give them a gold star for employing more young people-all those sorts of things that we think are desperately important here.

Q120 Neil Parish: The National Policy Statement clearly nails its colours to the mast as far as the Tunnel is concerned, saying, "This is the way to deliver the environmental benefits at a certain cost." Could the objectives of the two London schemes, i.e. the Tunnel and Deephams, be met in alternative ways, and does the National Policy Statement consider these alternatives fully?

Isabel Dedring: From what I’ve seen to date-and I’m much more conversant with the Tunnel because it is more progressed-our view is that there isn’t an alternative that involves no tunnel. But as the project has been developing over the past year, yearandahalf, the opportunity to alter the scope slightly, keep costs down, etc.-that is not a level of detail that I’ve seen. The point for this Committee is that one would want to be assured that that has all been looked at, and that that information is put on the table. Not just, "Here’s the Tunnel as it currently stands: tick ‘yes’ for yes and ‘no’ for no", but, "Here were some things that we looked at that you might ask about and here is why we have rejected them," so that there is some basis for knowing why the scheme is being put forward in the form that it is.

Q121 Neil Parish: Can I ask Councillor West in particular, because you suggest that the NPS be revised to reflect changes in the costs of the preferred option-the Thames Tunnel-which other options do you consider to be the most promising costeffective alternatives that the NPS should examine?

Catherine West: I am not an engineer, but I think, because we are in a very different climate from where we were a couple of years back, we do need to have it enunciated within the scheme what options were looked at at that point, before any of us were in our current roles, just digging back and seeing what did we look at, or did we just look at this one option? Because obviously that predict-and-provide model can sometimes be a bit problematic in terms of its price tag, and I wonder whether we should be looking at having some more evidence base within the document-a couple of paragraphs that say, "These were the different options that we looked at. They cost this much. This is a much preferred option because it is so systematic"-and just making sure that if we are going to choose the gold-plated option that we are doing it for a very good environmental reason and that we can actually sell that to our customers, in terms of people who are living in the Thames region, because they will be paying for it.

Q122 Neil Parish: Am I right in saying that at the moment you are keener on not actually looking at an alternative, but looking at ways that the Tunnel and Deephams could be delivered perhaps in a more costeffective way? Or are you also concerned that there is a need to use brownfield sites wherever possible?

Catherine West: I think we do need to re-examine some of the other options. I understand that previously, localised sewage treatment centres were looked at, and they were rejected. Isabel may have a longer memory than I in this regard, but it may well be that we need to include evidence within the statement that looks back at those and explains why they were not the right ways forward. The other thing about localised sewage outlets is that it is a simpler project, isn’t it, because only one community is affected; even though it may be sewage coming from a lot of different ways, it is slightly easier to manage. I am assuming that due diligence was done and that these options were looked at and they were eliminated for very good reasons, but that is not really reflected in the body of the report.

Q123 Neil Parish: To nail this one, you are reasonably satisfied now with where the NPS is?

Catherine West: Yes, although there could be some more caveats put into the statement; first of all that the statement includes some evidence around the other options, including the localised sewage treatment centres and those sorts of options, and that then, going on from that, given that that is where we are now, how are we going to marry that up with our new planning system and get the balance between what is a large infrastructure project that, in a sense, has to be Londonwide and has to be strategic, but also how do we not stomp on the heads of residents completely, both in terms of cost on their bills and in terms of their amenity space? Because we know that local amenity around the Thames is so important to local residents, given the lack of green space in London and the Thames area in general. So I am saying yes, but with some caveats. So if the Chair would be happy to take some amendments from us, we would be very happy to send those in. I am not sure what the process is.

Q124 Chair: We are guided by what the NPS clearly states, that they are not designed to include new, unpublished policy, so within that caveat. You are always welcome to submit, but we have to be minded by what we have been asked to do.

Catherine West: Sure. Chair, is there any way of putting supplementary guidance in there of some sort, particularly around this cost to local authorities? If I go back to London Councils and tell them I haven’t put in the case for more money for councils I’ll be beheaded, because clearly local authorities at the moment are really bruised and they are feeling sorry for themselves and any opportunity that we have to say, "Please help us with the cost," particularly big projects like this that have a European focus on them.

Chair: I am not sure it is within our remit.

Q125 Thomas Docherty: Councillor West, you made some very confident statements about the councils having their ears to the ground.

Catherine West: We do indeed. We are localists-real localists.

Thomas Docherty: So I was wondering if you could outline for us what the feedback is from your constituents; from those living and working near the proposed Thames Tunnel and Deephams scheme, and also what the planners’ view is of what are the issues of most concern to the local people.

Catherine West: Clearly, it is mainly in your local authorities that are on the river; clearly Islington is on a canal, not a river. But colleagues from across the political spectrum have raised with me, as the Chair of the Transport and Environment Committee, the impact on their local community, not just during the building phase but also from the finished product. They want assurances around the design, which Isabel has already raised; they want assurances around whether is there going to be any community gain and what they are going to get out of it as a result. Nobody has necessarily raised it, because the consultation period starts in September, I believe, and I think we need to take some more soundings then. But clearly what will happen is if we do not provide the basket around this framework that allows us to manage complaints, which allows us to manage problems, then when the problems do suddenly come, as with the Victorian piping and the leaking of two summers ago, we will be in trouble because we will not have predicted those problems at this point.

Q126 Thomas Docherty: I do not know if you heard the question I asked Thames Water earlier on about the Impacts section. Do you think that the Impacts section of the NPS could usefully include a broader discussion about the impact on the local communities and a discussion about what steps could be open to the applicant to try to tackle those impacts?

Catherine West: Definitely. I have real belief in the fact that communities can come together around challenges and I think, particularly with some of the communities who will be kicking up a real fuss, if we can get them on board very early with this need to clean up the Thames, which they all live next to, they will do it, but we have to actually articulate the arguments. That is why I believe that councils have to be at the forefront and local councillors have to be in a leadership role to really make the case for the system as a whole. If we leave out local councillors and leave out the local leadership too early, I think you risk having all sorts of problems; you even risk having some local councillors being against a particular scheme and having to use various measures to get around them and so on. But if you try to get them on board very early for the environmental benefits, I think we could be in a good position. Also, is there room for some of the things I mentioned before, to make the argument for the community around local employment, apprenticeships, living wage; all those sorts of important principles that we believe should be in play when these large infrastructure projects come in?

Q127 Thomas Docherty: They have now left, but they felt that the impacts debate should take place latterly, when there was an application coming forward.

Catherine West: Right, sure.

Thomas Docherty: Am I right in thinking that your preference is that that should be earlier in the discussion, prior to the councils getting their hands on an application?

Catherine West: My experience is that if you break bad news to people very early on and give them a long time to get used to it, you have a better outcome than if you break it to them the day before the diggers come in. But clearly that is something for us to think through when we are thinking through the impact of it. But if you can get some of your usual suspects and your local councillors on-who are sometimes the same people-then I think you are running a chance of having success. We are looking at this in a fairly negative light, but if we look at it positively as, "We want to have the cleanest river in Europe" or something like that, and if we can start trying to sell it as such and put some of the resource that Thames Water has behind that kind of an approach, then I think we are on to a winning approach, rather than thinking, "How are we going to break this news to them?" I think people are more mature and grownup in that they understand the need for it, but the question is whether we can treat them in a nonpatronising way and try to bring them up to seeing the vision of what I think could be an excellent project if we can put in safeguards for the consumer and for the local residents.

Q128 Thomas Docherty: Let me turn to the more specific situation that we have some evidence on. Again, I do not think you have seen the specific evidence, but some of the very local community groups that are opposed to schemes have a concern that, in their view, not enough weighting is given to the greenfield options. Do you think that the balance is currently about right between the weightings for green and brownfield, or do you believe that there needs to be a recalibration of the weighting when applicants are considering the cost benefits and so on of going down the route of greenfield versus brownfield?

Isabel Dedring: I think we are quite comfortable that Thames Water have done the best they can at this stage and they are, as they were saying earlier, considering moving those sites that are getting some of the biggest reaction. So, given that they have not yet come down one way or the other, it feels like three out of 22 sites are generating some of the problems and that is quite a low number and that might go down further. I think we have so far been quite confident, while not minimising the concerns that local residents have. Just to add, I would probably echo most of the points that Thames Water were making earlier about the typical comments we are getting expressing people’s concerns. One thing that they did not mention was that mature trees is a big issue for a lot of people, as well as the ongoing odour-not the impact of the works, which a lot of people raised, but also concerns about odour on an ongoing basis. Generally I would just go back to the point I was making earlier that we think that the whole issue of local impacts needs to be raised up in the statement; as drafted it does not sufficiently pick up that point. The amendment I suggested earlier, which is in our submission, is one way to pick it up, but basically the NPS would be strengthened if it required that they take all reasonable measures, not just consider a lot of these issues.

Q129 Neil Parish: In the NPS, have they made the proven case for the need for the infrastructure? You have the conclusion in Ofwat’s asset management plan and the Environment Agency National Environment Programme. Is that adequate proof when it comes to you acting as a planning authority?

Catherine West: There will be guidance eventually, but I think provided the guidance is strong enough-because as I mentioned before, there are some examples where Ofwat has done very well and there are other examples where there has been a perceived weakness there, and I think, in relation to something that has a lot of risks inherent in it as a large infrastructure project, it would be worth nailing down a bit more what we would do if it suddenly blows out in terms of cost-both cost to the bill payer and cost to the local authorities-just so that we bottom that one out a bit more in the guidance. I accept that the statement per se may not be in a state to alter it particularly, but I think when we come to writing the guidance that sits underneath the implementation plan, it may be worth including a bit more detail, just to strengthen it.

Q130 Neil Parish: Should the NPS give the planning decisionmakers, including the local authorities, flexibility in interpreting whether the need for the project has been determined, or would that make it very difficult for you as planning authorities?

Catherine West: I think the role of the statement is really broadly to say yes to the project in terms of that seems to be the option that it is leaning towards. Even though the other options are not really discussed in it fully, I think, in a way, once it is handed down at planning authority level it will be very difficult then if aspects of it get turned down. Within that, though, clearly we do have to wait until the consultation begins in September, and if there are certain sites within the 22 that are clearly not going to work, we need to have the flexibility in the statement to prevent the whole project from being binned, to make it possible to then adapt without our being charged for it. So what I wouldn’t like to see is Thames Water turning round and saying, "Well, we have done our figures on this option and we will have to include those costs in our final analysis", etc. I think where we need to protect the ratepayer is to say that there are certain things that are still a risk at the moment and that Thames Water needs to carry that risk, not that we get charged for this big piece of work that happens and at the last minute it all gets turned down and we end up having to foot the bill.

Q131 Neil Parish: Yes, I can understand. In a previous life, I spent quite a long time on a planning committee and I would think it was necessary for the local authority to determine exactly where the sewage treatment points are, where the manholes are-for want of a different expression-and so on, but surely you would not want to actually be having to justify the overall environment project locally, because otherwise surely that would put you in an almost impossible situation, wouldn’t it?

Catherine West: That’s right. I think in a way that is the debate that we are having now. We are getting to the stage where it is difficult to turn back and therefore that strategic level does need to be decided-taking on board views from the amenities group and all the various groups who will have raised it with the Mayor and with London Councils. We know that there are certain groups who are dead against it, thinking it is a bit like a hammer to crack a nut, but having decided it-and I think that is what this process will do; it will decide it-we move on to what the mitigating factors are at planning level and so on. So then we are talking about the how to, not the substance of the actual application itself.

Q132 Neil Parish: That’s right. Whether it is built on a brownfield site or not-those types of things-but not whether it is built at all, I would have thought.

Catherine West: That’s right. But within that, I think we do also have to have an argument around community benefit. I think we need to be arguing constantly, "We know this isn’t very nice for you as residents, but do you know that we are getting these other things out of this for the local community, and do you know that we are trying to achieve the best value for money and that this is where your bill will be capped at, more or less?" and trying to keep some of the other parameters of the budget very, very tight.

Isabel Dedring: But just to go back to the earlier point again, the NPS is pretty clear that this is not about should there be a tunnel or not, so it represents a pretty major change to this document if one were to reopen that question. Then there are the local planning issues and minimising the impacts from the site. But to give you an example of that middle territory question that might fall within the remit of the NPS-although again, I think it is not totally clear whether it purports to cover that-the Deephams proposal, if you look at the population numbers for the catchment area that we are projecting in the London plan, it is roughly ten times the number that Deephams are assuming in terms of the growth in population. So they are providing for a 15,000plus person growth in population and we are projecting, in that same catchment area, a growth more than 10 times that. So that is a strategic question about the scope of the project-not, "Should you be doing it at all?" but, "Have you designed it right? Should it be substantially bigger in scale and scope?" That is clearly not going to be a natural locus for local authorities, but equally not for the in principle question of whether it is happening or not. It seems to me somebody has to pick those kinds of questions up. We are happy to talk to Thames about those kinds of issues or to the IPC or whoever, but fundamentally, that is that middle territory of what I would see the IPC’s remit as being, if nobody else is going to do it.

Q133 Neil Parish: That’s right. So you are arguing that they are not actually taking future development into consideration enough?

Isabel Dedring: That is just one example in that particular instance, but you can imagine other similar strategic questions that are about, "Have you considered alternatives sufficiently?" The point you were making earlier, not about the alternatives to a tunnel, but alternatives in the context of the Tunnel project that might affect the scale and scope of the work, so that-I am making this up-you might need 18 sites rather than 22, or that bit of the Tunnel you do not need because actually you have found an alternative that is cheaper. Again, if Ofwat does not think that that is their role, and clearly it is not the local authority’s role in terms of minimising disruption and looking at the sites on a casebycase basis, that could be a natural locus for the IPC via the NPS.

Q134 Mrs Glindon: Just going on to wider planning and development strategies, do you think it is reasonable that the IPC has automatic primacy over other local plans and strategies?

Catherine West: I think they have to have reference to them. I think we get back to how we manage these parallel universes of what is happening in terms of the Localism Bill and the discussions that are happening around that. For example, what is the impact of the Neighbourhood Development Plan if there is nothing in there about a large sewerage work unit that will be built there in the next five years? I think we do have to have some way of integrating those two processes, because at the moment it does feel as though there are two processes that are not very integrated and I think if we are genuinely localist, we will be wanting to look at what the individual local authority’s plan is and how that plan for each local authority integrates with the strategic statement and the strategic planning guidance coming from the Secretary of State. I understand that the IPC is still in some situation of flux and that that has not necessarily been resolved yet, but whatever it ends up being finally, what is the relationship between that and our local core strategies and so on?

Q135 Mrs Glindon: That should be specified, that link between the local and planning-

Catherine West: Definitely. I think if we can specify it quite soon, even though we might not necessarily get it exactly right, at least we will have some sort of a framework. I think the worst thing in these documents and in these policies is not to have the framework that later local authorities can rely on for legal counsel and so on. If things are left open, I think that leads to a long series of delays and it can be very difficult for local authorities and residents to come to a conclusion on something, whereas with something that they do not like but which at least is clear, you have a way of working forward. I think it is where it is not clear that we will be calling for clarification of the various bodies’ roles.

Q136 Neil Parish: Ms Dedring, your written evidence refers to Defra’s consultation on the NPS as a "token consultation". What should Defra have done to further engage the London public in their consultation on the NPS rather than on the specific London projects?

Isabel Dedring: I think this goes back to the point that you were making earlier. It would be a stretch for most members of the public to even know the NPS was being dreamt of and progressed unless you were a very dedicated activist. It happens that in London we have the Tunnel and therefore we do have a few people who are aware of it, just because the Tunnel is quite an emotive issue in local communities. But certainly not everyone affected knows that this is happening. They may well know that the Tunnel consultation is happening, but not the NPS consultation. When we do consultations, we are trying all kinds of innovative ways to reach out to the population as a whole, which is of mixed impact because sometimes people just don’t care and there is no way that you can force them to care. But I do think that there are a variety of things that you can do. We have recently put out a draft adaptation strategy and we use a Twitterstyle website where people can log their views-you don’t have to do that; you can do it another way-but it is something that tells people, "You don’t have to read this gigantic document. Here is a onepage summary of it, or a five-page summary of it, and you can just offer your views on that summary." So I do think some kind of attempt to reach out to people would probably be useful, because understandably, people are not naturally going to understand the implication of this for their everyday lives.

Q137 Neil Parish: Have you been trying to communicate with Londoners to put more of an impact into the NPS consultation? Have you put anything out in your newspapers? What have you done directly?

Isabel Dedring: We haven’t ourselves; as it is not our consultation, there is not very much that we can do about it. We can encourage Defra to think about whether there are other things they could do. Obviously we talked to our stakeholders in the boroughs about it; that ship may have sailed, though.

Q138 Thomas Docherty: Have you spoken either verbally or in writing to Defra about how you feel they are consulting?

Isabel Dedring: We are in pretty close contact with Defra on lots of different things, including on this. My understanding was that at this stage it is possibly too late for anybody to form a view on it. A separate question of, "In the course of the IPC’s investigation under the NPS should they be voluntarily soliciting input from the public?" is probably a more relevant question, because people won’t understand the implication of some of the language in here, but they will understand it when an actual case is going through in practice.

Q139 Chair: Could I just return to be specific about what your role is? Obviously the planning application now will go to the IPC, but do you have a role at the preapplication stage?

Catherine West: As London Councils?

Chair: Yes.

Catherine West: Not necessarily as a body; I think it is individual councils-individual planning applications. Therefore, we do have diverging views within the 32 London boroughs, as one would clearly expect, but clearly a lot of the West London boroughs feel very strongly about some of the sites that have been chosen. I think, once again, it comes back to that very early consultation and deciding whether that can actually, with a lot of political work at local level, go ahead. But I think it is about getting on board some of those difficult sites quite early and working very hard at winning the argument. I think that is possibly where local authorities and local councillors are best placed, rather than necessarily Defra, which is quite removed in terms of the detail. Just trying to think through the actual process, if this September, for example, when Thames Water begins its consultation, it is very clear that it is just going to be wildly unpopular on some of those sites, the question is whether they can quickly adapt for some of those. It may be, as we have said before, that some of the sites are not as controversial and they can go ahead.

Q140 Chair: Can I just stop you there? If you do not have a role, I am just intrigued as to where you think the additional costs are coming from.

Catherine West: Yes. We will have a role, once people start writing to us as local councillors about disruption and so on.

Q141 Chair: But that is what we are expected to do as locally elected representatives, whatever level of government we serve in.

Catherine West: Yes, sure. I think the local authority will have some role there, in terms of assisting just in the way it does with the laying of the Victorian pipes; we have to close roads, we have to make sure the signs are all being done well, make sure nobody is falling down any holes, that the contractors are doing the right thing, health and safety, making sure that, within a particular site, other options can be used. Let’s say it is a park: where and what kind of other facility will the residents use if they are used to using that site? They will certainly rely on the local authority; they won’t be writing to Defra to ask them, "Could you please give us another playground?" It will be the local council. I am not sure if I am answering your question correctly, but I think that there will definitely be implications for our planning departments, just in site mitigation terms.

Q142 Neil Parish: Yes, I imagine that when it comes down to a local application then naturally it will go to the borough and they-

Chair: No, it goes to the IPC.

Isabel Dedring: I think the local impact reports that the local authorities need to prepare, one might well imagine that a very wellresourced local authority with a very strong planning team might prepare an excellent one and then the neighbouring borough, who do not have such good resources-and we see this all the time across London when we see some of the strategic planning applications-will prepare something quite weak and those residents will then feel that their views have not been adequately represented. Doing that exercise properly is quite resourceintensive, so I think anything the NPS could give a steer about, "Local impact report equals please do the following," or, "We would like to see x," but I think that is where the concern also comes from in terms of the cost of simply running that exercise.

Catherine West: We actually have to pay human beings to sit down at a computer and write that, because if you were going to pay a consultant to do that, that would cost a couple of hundred pounds a day, probably.

Chair: To do what?

Catherine West: To write up a local impact plan or a local impact assessment. So expecting the local council to do that is yet another burden.

Chair: And you’re required to do that under these procedures?

Catherine West: Yes. So that would be another burden on the council.

Q143 Chair: Can you give us an idea of what resources you think the London boroughs would need to assess the local impact of the two sitespecific projects?

Catherine West: I think it is different according to each site, but clearly where there are a number of residents who use a particular site on a daily basis for recreational purposes that is going to have more of an impact, because I don’t think you can write an impact statement without actually asking people what they feel the impact will be.

Q144 Chair: But this will already have been done in the environmental impact assessment.

Catherine West: By?

Chair: By the company, which you will presumably-

Catherine West: By Thames Water?

Chair: Which will be a public document.

Catherine West: Sure. I just feel that if you bypass local authorities too much, you are going to have problems, because local authorities and councillors, as all the former councillors know, can actually be helpful in this process. So what I think we should be working towards is working in partnership with the local authority so that we can join up resources as much as possible.

Isabel Dedring: My understanding-it may be the blind leading the blind here-is that the local authorities submit local impact reports to the IPC and that is the only vehicle whereby Mr Smith, or whoever, feels that they get input into this process, because it is not soliciting the views of the individual. They might write in, but that is the only mechanism whereby that is going to happen in the IPC exercise. Obviously, people may have expressed their views to Thames during that process, but if you want robust input from local communities in the IPC exercise, it is going to come through the boroughs and that is the only vehicle whereby people can input their views.

Q145 Thomas Docherty: I am slightly confused here; perhaps you could clarify. Are you seeing this role effectively as a consultee and this is what you are doing, or is it as the scrutiny body for a planning application? It strikes me that yes, if you are the scrutiny body, then you absolutely have to write these reports and in fact you have the planning application fee normally to cover it. But if you are saying that you are effectively acting as a consultee and then making reports, with the best will in the world I do not see why you should get paid extra to do that, because no one else gets paid a fee to write a consultation report.

Catherine West: It depends on what we mean by resident involvement. If we just want a bureaucrat to sit down and write the report on behalf of the local authority, which just states how the local authority might be affected by x, y, or z, then I think the costs might be minimal. If you want to get residents onside, get them to believe in this, get them to actually join with this and be part of this scheme, get them to get on board and suggest ways that it can be done well, get them not to hate Thames Water and to actually welcome it, then I think you have to involve local authorities.

Q146 Chair: Can we just be clear on the whole premise? I am only in London when I am required to be in London, but it would strike me, if I was a resident along the route, bearing in mind that the surface water flooding and the sewage outfall into the Thames is quite a recent phenomenon and the evidence that we have heard is that the Victorian pipes are standing up quite well, that there is a real need for this. If I was living along that route, I would actually be quite keen on it, so you can discuss the various options, but if you are writing a local impact report and this will go to the IPC, then presumably it is much less imposition than doing a full planning application, so the costs surely must be minimal.

Catherine West: Sure. I think you have to compare the experience of your average person who passes through London, who wants to know that the right thing is being done by the green agenda, with that of somebody who takes their child to the local park every single day and whose park will be taken away from them for five years, but they have no way of complaining to their local council because their local council has absolutely no power on the question at all, that is where the rubber hits the road. That is what we mean by real consultation. I think people who have sat on planning committees will understand the passion that these sorts of planning decisions evoke.

Q147 Chair: During the passage of the Planning Act, when all these issues were debated, did you make this point?

Catherine West: Well, of course that is currently being debated through the Localism Bill, because-

Q148 Chair: No, no, all these powers stem from the 2008 Planning Act. So did you make these points at the time?

Catherine West: No, because I was the leader of the Opposition then, Anne, so I didn’t.

Q149 Chair: But I am talking about your predecessor and "the councils".

Catherine West: Local councils. I can find out for you and write to you about that.

Q150 Thomas Docherty: I am trying to get my head round here-forgive me, but it sounds as if what the local authorities are now advocating is that they want an extra role in this process that is not in the Act that effectively, if I understand correctly, would be an advocate, or a champion, for the project, rather than doing a scrutiny role of inputting on the environmental impact.

Catherine West: I think any large infrastructure project works best when you get people onside. And so I think the statement should contain some sort of value statement about what the role of the local authority is. Because the other situation you could get-if it is scrutinising, scrutinising could be quite an oppositional point of view. So if you want Hammersmith and Fulham Council, for example, to suddenly be against this, then maintain the scrutiny; if you want them to be partners, where they see the environmental impact as quite serious if we don’t do anything about it, then I think you should write into the statement that you want local authorities to be partners in this project. I think that is what we see again and again with the GLA, where they have a strategic role but they know that without the actual co-operation of boroughs, they are not going to get their strategic view through. It depends on how you structure it.

Q151 Neil Parish: I can see exactly where you are coming from, because you are a local release valve, if you like, for pressure. But if you do an impact assessment and you could just send that in in writing to the IPC, what then would happen to it? It’s not like some sort of planning appeal; you don’t make any sort of representation after that, do you? Is that how it is envisaged?

Catherine West: My understanding of the statement to date is that that has not actually been bottomed out yet, but I think this process has been very helpful in just highlighting the fact that we have not really got a clear sense of where the local authority, which is the planning authority, sits in relation to the strategic view. Indeed, the IPC itself is currently being reformulated, isn’t it? So I think in a way, we have to see those processes as parallel, but definitely look in detail at where some of the difficult sites might be and see what we can do there.

Q152 Chair: If I could just ask you one last question, what improvements do you think will be required to enable London boroughs to work more effectively with the IPC and project developers on specific new infrastructure projects, like Thames Tunnel?

Catherine West: I would make a strong case for trying to bring local authorities on very early in the piece; not create enemies of them by just saying, "You just have a scrutiny role that has no power" but trying to bring them on very early on in the piece as a co-operative partner. I am sure that the GLA would agree that that is normally the way to go forward if possible in the first instance, because we are friends today but often not necessarily on every single point. Secondly, you should be openminded about the resource issue, because I think with the resource issue it is very much about: you could ask Thames Water as part of its costs to put a small part aside for compensating the local authority for various roles that it has to do. You don’t have to call it a fee, but you could talk about a co-operative approach so that you are actually doing it together: the London Borough of X with Thames Water; they are doing it together; it is joint. My own view is that you get a much better approach if you try to do it collectively than if you try to do it separately.

Isabel Dedring: Just to clarify, the GLA is a strange creature so we do not technically fall under a local authority. So we might well voluntarily input something to the process ourselves, but this is more the boroughs, not us.

Chair: That is helpful. I think horses and bolted and Bill spring to mind, but we are very grateful to you for being with us and contributing to this inquiry. Thank you very much indeed.