PPL05: Request for a review of the National Policy Statement for Waste Water concerning the Thames Tideway Tunnel under S.6 of the Planning Act 2008

Thamesbank and the Environmental Law Foundation have produced a request to review the NPS with new supporting evidence. For the full statement click here.

The following Annexes support the statement:

Annex 1a & Annex 1b: House of Lords Questions and Replies

Annex 2: Binnie - Measures to protect the river environment (Revision 7 - Version 31st March 2014 - latest amendments are in red). Extra material includes resilience of future conditions and EA record on fish kills. For the presentation in support of this annex see IND10.

Annex 3: Byatt - Thames Tunnel - A critique of a flawed project

Annex 4: EC legal letter

Annex 5: CDM Smith - Key questions on green infrastructure and Philadelphia

Annex 6: Binnie - Thames Tideway Tunnel - Cost and benefits analysis (Revision 4 - Version 11th February 2014). Includes evidence that there is no valid CBA submitted to the Inspectorate Panel in support of the Development Consent Application and details on how DEFRAs declared benefit of almost £4000million should actually be £180million and could well be appreciably lower.

Annex 7: Willingness to pay for Blue Green Infrastructure (Philadelphia)

Although not part of the original submission, this letter is included (link) as it forms part of the response to this process. It includes views that the Rapid Evidence Assessment (REA) used by DEFRA on SUDS is not necessarily fully comprehensive as, although it does include consideration of a large number of reports relating to the applicability of SuDS, it does not include all the evidence. In particular, important evidence set out in Annex 2 above (details given in the letter). It also refers to, amongst other things, the "aspects of fish benefit report" [IND09].

Pinsent Masons LLP on behalf of Southwark Council reference will be added here when available.

Comments

The Government now has an opportunity to reopen the consultation through the Aarhus Convention and transform London positively for generations to come. The Government must honour the precautionary principle which states that: “in order to protect the environment the precautionary approach shall be widely applied by States. Where there are threats of serious or irreversible damage, lack of full scientific certainty shall not be used as a reason for postponing cost effective measures to prevent environmental degradation”.