Environment, Food and Rural Affairs CommitteeWritten evidence submitted by London Borough of Hammersmith and Fulham

1. Does the White Paper set out the right principles for customers and the water and sewerage industry for taking forward reform of the market for water supply?

A key way of reducing demand not covered with in the report, both for water supply and sewage disposal, particularly in London where the surface water and foul sewage is “combined”, is to make better use of rain water. The promotion of rain water harvesting in order to use rain water for non-potable functions both reduces the cost and need for water abstraction as well as reducing the impact on the sewerage system.

A copy of Professor Colin Green’s paper attached exemplifies how the economics of such an approach might work. A key to his report is how to encourage, or possibly to enforce via planning, is the retrofitting of existing properties.

2. Are the proposals to protect and enhance water resources, for example on abstraction regime reform, likely to be fully effective?

The management of water is vital to the economy and well being of the population at large. The council strongly supports best practice for the use of water through the promotion of efficient household use of water and through metering. However there needs to be a more strategic plan to manage water more efficiently over the longer term.

The historic position in London, which has evolved over the last two centuries, of combining rainfall run-off with foul sewage, needs to change.

The current scenario in London in terms of water management is completely unacceptable. On the one hand there are plans to construct the Thames Tideway Tunnel to deliver a mixture of valuable fresh rain water and foul sewage to Beckton for treatment to put the treated effluent back into the Thames and on the other hand there are proposals to construct a desalination plant to provide potable water.

This extreme waste of rain water, at an obscene financial cost, cannot be right. The current approach will increase water bills putting many people into water poverty.

The council support the programme that includes demand management to significantly reduce water use through both best practice for water usage and metering. However the long term strategic approach must be to take some of the surface water out of the system and to use it more efficiently particularly as many of the household tasks do not require potable water. Such an approach reduces costs for both water and sewage treatment and must be sensible.

The council welcomes the intention to consult on a national strategy on urban diffuse pollution in 2012 …encouraging the introduction of drainage systems that reduce flood risk and the amount of pollution running off our roads and industrial estates and into our streams and rivers, as wells as relieving pressure on our sewers. We also welcome the proposal to consult on national standards and new approval system for sustainable drainage.

3. How best can the White Paper’s aims to promote water efficiency and the use of sustainable drainage be implemented?

The implications for the London boroughs in respect of their new duties under the Flood and Water Management Act as a Lead Local Flood Authority is to manage flood risk.

These new duties apply to the London boroughs individually and any joined up thinking has been initially led by the Greater London Authority through the Drain London group. This group oversaw the development of each borough’s Preliminary Flood Risk Assessment and their Draft Surface Water Management plan but the group has now passed the lead back to the boroughs to manage individually—albeit that clusters of authorities are meeting on a local catchment basis.

The Greater London Authority (GLA) has taken a lead on Flooding matters but they are not a Lead Local Flood authority, this is delegated under the Flood and Water management Act to the London boroughs. Additionally unlike in planning, where there is a London Plan overseen by the GLA and the Mayor of London, there is no similar process for Water management.

There is no joined up thinking in relation to governance and accountability for water management. The council considers that the GLA have a role to play here and that the appointment of a Water Commissioner similar to other major world cities, particularly in the United States who would have overall responsibility for water quality and natural resources would be appropriate to ensure that the whole water cycle is properly managed

The impact of London’s combined sewerage system in time of rainfall gives rise to the combined sewer overflow problem. Part of the solution to this problem, in the longer term needs to look at water management and how this sits along side development in the capital. Better use of rain water and sustainable drainage provides benefits not only for avoiding river pollutions by limiting overflows but also by reducing water demand.

An explanation of the current disjointed arrangement and how London might benefit from having a Water Plan, much like the London Plan for planning matters, overseen by a new role of Water Commissioner might be structured is set out in the attachment below. The Commissioner could promote water efficiencies via SuDs or other measures, within new and existing developments as well as the co-ordination of works associated with surface water management plans.

4. Do you support the White Paper’s proposals on affordability of water bills for householders?

The cost of water bills in London and throughout the Thames region will be grossly affected by the construction of the proposed Thames Tideway Tunnel scheme.

The estimated cost of the Thames Tunnel scheme has increased from £1.7 billion in 2006 to £4.1 billion today and the council understands that the cost of this scheme will add around £80 to £100 in perpetuity to the average annual water bill throughout the Thames Water region. Whilst Thames Water’s bills are lower than the national average, these increased charges will fall to some of the most vulnerable who can least afford to pay such an increase.

The Urban Waste Water Treatment Directive (UWWTD) states that the design, construction and maintenance of collecting systems should be undertaken in accordance with the use of Best Technical Knowledge Not Entailing Excessive Cost (BTKNEEC) to limit pollution of receiving waters.

The Thames Tideway Strategic Study (TTSS) proposed three solutions to meet the requirements of the Directive; sewage treatment works upgrades (cost £0.7 billion); the Lee Tunnel, Abbey Mills to Beckton (cost £0.6 billion) both of which are already being constructed, and the Thames Tideway Tunnel. The upper Tideway (in the West) has seven of the 10 most polluting Combined Sewer Overflows (CSO). One of the remaining other three is Abbey Mills which is being dealt with by the Lee tunnel.

The upper Tideway has a small tidal cubature so has limited ability to dilute any CSO discharge. In Professor Chris Binnie’s view (he Chaired the TTSS review in 2005) only the West tunnel, starting at Acton and finishing at about Heathwall, would solve the issues in this section. The West tunnel might cost about £1.9 billion. Connecting this tunnel with the Lee tunnel in the East (TW’s current proposal for a single tunnel solution) would cost a further £2.2 billion. The Lee and West tunnels, at a combined cost of about £2.5 billion, reduce spill by a quoted 72%.

With these localised solutions, much of the benefit of the full tunnel could be achieved by the Lee and West tunnels. The full tunnel would cost an extra £2.2 billion for another quoted 22% of spill reduction. Surely this extra expenditure amounts to “excessive cost” under the UWWTD or “disproportionate cost” under the Water Framework Directive?


5. Does the White Paper omit any key issues where further policy action is required to ensure sustainable, reliable and cost-effective water supplies?

As outlined in the responses to questions 1 to 4 the key issues that need to be addressed are summarised below:

(1)to make better use of rain water to reduce water and sewerage demand;

(2)particularly in areas where there is “combined drainage” to take surface water out of the equation via measure such as SuDs and “rain water harvesting”;

(3)to encourage improved and more joined up water management which, in London might be via a Water Management Plan overseen by a Water Commissioner to assist with planning, existing and new development and co-ordination of the roles of Lead Local Flood Authorities within the catchment; and

(4)to encourage government to opt for a more cost effective solution to the Thames Tideway Tunnel where the objectives for the original scheme can be met for almost half the cost saving water charge payers, and possibly tax payers if the costs overrun, £40-£50 pa

22 January 2012

Prepared 4th July 2012