Earlier this week, I submitted written representations to the Thames Tideway Tunnel planning examination - a copy of which is below.
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Thames Tideway Tunnel application (ref: WW010001): Written Representation SH3
Introduction and background
I write further to my representations of 28th May and 28th August. (I shall call these SH1 and SH2 ). I am and have been the Member of Parliament for the constituency comprising the northern part of the LB of Southwark for over 30 years, and lived in Bermondsey for longer. The boundary of my constituency is half way between the banks of the Thames from just upstream of Blackfriars Bridge to just downstream of Greenland Dock, and includes the Blackfriars Bridge foreshore, Shad Thames and Chambers Wharf and the parts of Southwark immediately adjacent to Earl Pumping Station. I am also Chair of Governors of St James' CoE Primary School in Bermondsey and a member of St James' Church.
I specifically associate myself with and adopt the arguments made by LB Southwark, Councillor Al-Samerai, and the Save Your Riverside campaign, and in particular ask that the ExA insist on full transparency by Thames Water as argued by Save Your Riverside.
I disagree with this application because I believe that the tunnel, the planned tunnel route, and the proposed drive site are not justified as the best, most environmentally suitable or cost effective solution to the problems flowing from sewage discharges into the Thames. I am very sympathetic to the arguments put by Lord Berkeley in his question for short debate in the House of Lords on 24th October this year, believe the arguments he put on that date still need to be further addressed and that an opportunity should be given at the most appropriate time for evidence and argument on these issues. I still cannot see any part of the inquiry timetable which allows consideration of the financial implications of this tunnel for Thames Water customers, council tax payers and UK taxpayers. Prospective increases in customers' bills and liabilities of Thames Water shareholders and of the UK Treasury and taxpayers are highly relevant considerations for deciding the merit of this application. The cost benefit of the tunnel is highly relevant to the application also. The cost of this project is very significant and has significant financial, practical and policy considerations. The financial issues are of significant importance and could have far reaching implications. These issues should be given separate attention at an IS hearing.
I wish to question whether the applications are made on an adequate statutory or other legal basis given the apparent absence of reasonable alternative tunnel routes or proper justification of the selected route and the failure to carry out a proper Strategic Environment Assessment (SEA), and whether the draft DCO includes powers greater than those required for the project. I believe that the application is legally flawed because of this failure adequately to identify and consider reasonable alternative tunnel routes and/or properly to justify the selected route, and to carry out a proper Strategic Environmental Assessment, and would ask for the opportunity to put this case too during the examination. For initial legal justification for this request, I refer to the relevant parts of the representation made by London Borough of Southwark on 28th May 2013 paragraphs 1, 1.1 and 1.2 on page 3 and points 1.0 to 1.9 on pages 8 and 9.
Site selection - Chambers Wharf
I first request that the ExA examine carefully whether there is a need for a Bermondsey worksite or whether one longer drive section between Kirtling Street and Abbey Mills might be possible as an alternative.
The original plans from the applicant were to drill from the direction of Abbey Mills towards King's Stairs Gardens. Since the initial proposals, the applicant has changed its proposals so that King's Stairs Gardens is no longer the preferred drilling site in Bermondsey; the preferred site is now Chambers Wharf. (Both of these sites are in my constituency). In addition, in the latest proposals, the applicant has also fundamentally changed its proposals for the direction of drilling. The applicant should be required to publish all documents and other information relating to these two very important decisions. It is vital that all interested parties are given opportunities to challenge and question the arguments, facts and figures with which the applicant justifies its choice of site and change of proposals. I call on the ExA to require a full public disclosure from the applicant of all the relevant documentation used for their decision. I also note the criticisms made by Save Your Riverside and other groups of the methodology used by Thames Water for site selection, and share their concerns that Thames Water did not think it was necessary to apply any form of scoring, quantitative assessment or the use of weightings in their methodology.
The proposed Chambers Wharf site is listed as a brownfield site, but it is close to a large number of residential properties as well as a number of schools. The proposals will cause considerable disruption over a period of seven years to a large number of residents, and also to significant numbers of children and young people attending and visiting local schools. In addition, I am concerned that Thames Water has stated that during the first three years of construction, the Chambers Wharf site will be operational for 24 hours a day and for seven days a week. Given the type of work that will take place at the site - including heavy industrial operations with a high level of noise and air pollution - I believe that this is an unacceptably high burden for local residents to shoulder.
I would also like to highlight the impact the site will have on traffic levels in the immediate area. The area surrounding the site, particularly Bevington Street, includes many small and residential roads. Thames Water has stated that there will be approximately 65,000 lorry movements during construction. This could prove to be a level of construction traffic too great to be sustained by the local road system. I also note the significant road safety issues that arise from the proximity of the site to a number of schools. If this site is to be used, then I propose that all or very nearly all of the movements of material should take place by river, using larger barges where necessary.
The main concern of the majority of my constituents has been the use of Chambers Wharf as a drive site. My constituents and I feel this issue should be central to the inquiry and that there are persuasive reasons to reverse the direction of drive for the tunnel so that it would be driven from Abbey Mills. Abbey Mills is already an operational site, located on industrial land, with no similar amount of residential property or number of schools nearby. By changing the drive site the applicant would reduce considerably the impact on local residents.
I would like to pray in aid the site visit I made to Abbey Mills earlier this year with Councillor Eliza Mann, representatives of the Save Your Riverside campaign and representatives from Thames Water when we investigated Abbey Mills as an alternative drive site. During the visit we learned that the site could be used without affecting the timeframe for the construction of the tunnel and that it could be adequately equipped to deal with the large volumes of spoil that would result from it being the main drive site.
I note that Thames Water's key objection to using Abbey Mills as the drive site seems to be the difficulty which this could cause for the transport of materials along the River Lee given the river's course and tidal conditions, and the potential impact on the timeframe for the tunnel's construction. I understand, however, that 1000 tonnes a day are currently being removed along the River Lee by barge, and that the Pell Frischmann report on the use of the Lee for transporting materials from the Abbey Mills site by barge concluded that this was a feasible option.
In addition, I would also join the Save Your Riverside campaign in proposing that a new shaft which is being constructed at the Abbey Mills site for use in the construction of the Lee Tunnel (shaft G) could also be used for the construction of the Thames Tideway Tunnel. In the evidence they have gathered, Save Your Riverside conclude that shaft G could be easily utilised to allow Abbey Mills to become the drive site for the tunnel (and the launch of a tunnel boring machine) without any further delay to the tunnel's construction, and could compensate for any delays that could result from the use of the River Lee as a main transport route.
I am very pleased to see that an IS hearing has been arranged to discuss 'the rationale for the selection of worksites and drive strategies matters'.
I believe that the use of Chambers Wharf as the drive site for the Thames Tunnel would place an unacceptably high burden on local residents, particularly in relation to traffic and road safety, and noise and air pollution. Given the significant new evidence that has been gathered since the decision to adopt Chambers Wharf as the main operational site, all other alternatives, including Abbey Mills, should be fully considered by the inquiry. An alternative main site or main drive site is likely to provide a better deal for local residents and a better deal for the environment, at limited financial and regulatory cost to Thames Water.
I look forward to participating further in the inquiry over the coming weeks.