BG VISION FOR LONDON (and barriers to adopting a BG solution)
A vision of a Water Sensitive City has been generated for Melbourne - see video link here. There is no legitimate reason why, using current technologies, this could not be London.
An integrated BG strategy is not fiction but there is now irrefutable evidence that it has now been and is being adopted by many cities and regions around the world. Some other examples are:
- The White House and America's environmental protection agency (EPA) is placing a higher priority on stormwater and the establishment of green infrastructure to address it - Article 1, Article 2
- The District of Columbia Water and Sewer Authority has proposed suspending multimillion-dollar construction on its tunnel systems project while it explores the implementation of more environmentally friendly options - click here for article
- Copenhagen is one of the world’s leading cities for driving innovative green growth. The city is determined to drive economic development at the same time as it enhances the environment and quality of life for its residents [CAS08].
- Best Practice is demonstrated by the successful application of BG technologies for CSO control in Philadelphia. This world leading application has demonstrated what can be done, the history and the future direction for Blue-Greening and was presented in a House of Lords committee meeting in December 2012 [CAS05]. It is a greater challenge than London in terms of its implementation of a BG strategy to control Combined Sewer Overflows (CSOs). It is leading the way in the US (click Philadelphia Watersheds for link and see video “Green City, Clean Waters”) and is having an immediate impact as decentralised storage, equivalent to that provided by a tunnel, is being generated on a project by project basis, 50% of which is privately funded through incentive schemes.
- In Melbourne, Water Sensitive Urban Design (WSUD) is be used for storm water planning policy -click here for guidance
- The new wastewater discharge permit issued by the Milwaukee Metropolitan Sewerage District (MMSD) is the first in the U.S. to mandate green infrastructure. The permit requires that green infrastructure be used to capture 3.8 million L (1 million gal) of stormwater each year. MMSD has an ongoing open spaces conservation program called Greenseams, which can be used to fulfill 75% of the 3.8 million L (1 million gal). However, 25% must come from municipalities and private property owners.
- Also see New York watersheds article saving $4-6B dollars
A European research network has been established to coordinate development of blue-green technologies and methodologies (see Blue-Green Dream and the BGD Project at Imperial College). This is one example of an active research community that can help support the development of BG solutions for London over and above the methods currently being employed elsewhere in the world.
Thames Water's proposed "super sewer" tunnel (Thames Tideway Tunnel - the "Tunnel") would take money away from blue-green growth opportunities in London. A major step change is required in our approach to the adoption of blue-green technologies and methodologies in order to maximise the benefits to Londoners and eventually obviate the need for the Tunnel - discussed further in this paper. We believe that the storage delivered by the Tunnel will eventually be replaced by local storage and stormwater attenuation systems (to be proven by appropriate study). Another source of information can be found here - Expert Opinion on Clean Thames Now and Always website. Furthermore, recent evidence on this website based upon data received through a Freedom of Information request indicate that the Tunnel is not needed at all (IND14).
There are many strong views on both sides of the argument which need to be fully tested based on the evidence provided. This evidence needs to be comprehensive and open to scrutiny AND up to date. Little additional evidence to support the chosen tunnel solution has been provided since the 2005 Babtie report which requested additional work on alternatives which was not done. OFWAT originally agreed with the need for additional study - see letter to DEFRA. Currently the Thames Water propaganda machine is pitted against non-funded campaign groups who have a vision of a much better London much of what will be captured in a Blue Green movement. There is a right to reply based upon high guiding Principles [SEE04].
Thames Water need to make a good case to support their scheme and through lobbying of government agencies (EA, DEFRA, OFWAT), influencing public perceptions and heavily influencing the wider industry their strategy has been very successful to date even though failure of a system that you're responsible for seems to have been lost on some.
Where is the evidence?:
- On the magnitude of the pollution problem (critical CSO data was "not available" for the Putney SUDS study - see below)?
- Images of fish kills are extremely emotive but to what extent will the upgrade of the Mogden sewage treatments works (the perpetrator?) resolve this?
- There is no available data on the components of polluting sources when the CSOs spill, i.e. spill volumes/concentrations in each CSO and in-river against surface water run-off (e.g. oil on roads) and from upstream, i.e. three components. This necessary study was completed as part of proving the case against a tunnel solution in Philadelphia as the marginal value of the scheme to perform its function was reduced.
- Again, in Philadelphia, the question of "disproportionate costs" against a tunnel solution was overwhelming, e.g. along the lines of over $10k dollars to reduce each case of diarrhoea. This study needs to be done for London noting that rowers, for example, may be up to 10 times more resilient than other river users.
- Is the film on the river surface, perceived as a problem for river users, in fact the direct surface water run-off which circumvents the CSOs?
- Would a clean up of the tributaries flowing into the Thames and local measures for the worst polluting CSOs lead to better water quality than what the Thames Tideway Tunnel will generate and at a fraction of the cost?
- The economic case for the Tunnel needs renewed closer scrutiny and debated against the full option list of alternatives, particularly in light of recent revaluing of the current scheme [SEE03]. The tunnel scheme should be judged based on its marginal value following completion of the Lee Tunnel and sewage treatment works upgrades.
- There have been European Court arguments within the requirement of Best Technical Knowledge Not Exceeding Excessive Costs (BTKNEEC) that NEEC is compliant as it satisfies the current proposed tunnel scheme. How can NEEC be satisfied when it is attached to BTK which has not been carried out - evidence provided for on this website? [PPL02]
- The public needs to understand the costs, benefits and risks of all options in simple language. For the tunnel scheme, is an £80 increase per water bill per year in fact a 25% increase? Does it equate to (depending on net present value assumptions) £10-20k per household over the lifetime of the debt (assuming current projected project costs are delivered)? A transparent engagement with solid comprehensive evidence is required for such an important project ensuring that the opportunity to kick-start a Blue Green movement in London is not missed with all the additional benefits that may provide.
- What is the carbon cost of the Tunnel compared to other schemes? [SEE05]
- A BG strategy could also help many other areas such as urban heat island effects and air pollution. The latter may result in fines for London in addition to those awaited from the EU Court for the Urban Waste Water Treatment Directive (UWWTD) infringement. Air pollution is linked to one in five deaths in London every year. How can Blue-Greening help its air quality strategy? More joined up thinking is needed.
- Supporting the need for joined up thinking, to what extent does the innovative use of current technologies associated with Blue-Greening meet the "challenge of future cities?" [GAI09, video]. "The challenge area is the integration of city systems - to think of a city in all its complexity as a system of systems." What are the opportunities? How many of the ideals of "Linked London", e.g. increased employment, would be satisfied through Blue-Greening [GAI10, p3]?
- If BG has already generated 32,000 jobs and an industry of 2,400 firms with $7.4B of sales in the metropolitan region of Philadelpia [SEE02], what is its potential for London? 100,000+ jobs? Most of these will be local and many will be low skill requirements with benefits directly related to the efforts of the individual Boroughs.
- London Clay is only a design issue [SAT04].
- Generally, the evidence produced to support the Thames Tideway Tunnel scheme is incomplete and out of date. Defra published two reports in November 2011. The costs and benefits case in "Thames Tunnel costs and benefits" is quite different to a more recent study (see above) and therefore needs revisiting with a similar resolution / transparency of data and inclusion of BG solutions similar to those shown successfully applied elsewhere. The "Thames Tunnel strategic and economic case" report would seem to be "out of step" with the current global thinking on the issues and contains evidence which is in serious need of revision in order to support the decision making process effectively. Legal issues aside (which will be argued in due course), the technical data on Page 10 supporting a case against SUDS (one of many BG elements) is incorrect - see evidence produced in this website. Appropriate BG studies have not been done for London so it is not known how these conclusions have been reached.
In addition to the above evidential based omissions and requirements for revision, the BGIET believe that the Thames Water pre-application consultation process is seriously flawed in the following areas:
- Promoting a product for their shareholders benefit instead of gaining consent from the public using full information to improve their monopoly utility service (Article 1, Article 2)
- Independence of study
- Provision of access to data (e.g modelling) and information required for effective third party review. Engineering data usually belongs at least in part to the person who pays. There is a question as to what constitutes "commercially sensitive" data on a taxpayers' project delivered from a monopoly position.
- Interpretation of the EU Urban Waste Water Treatment Directive 91/271 EEC in particular of assessing BTKNEEC [PPL02] and the meaning of environment, i.e. not limited to pollution
- Response to objections and Selborne Commission findings requesting further work
- Due diligence to the changing economic models to include the increased availability of technologies such as ecosystem services.
Ultimately, we believe, the linear approach to resolving issues needs to be replaced with a holistic approach utilizing symbiosis of its components parts. This approach would potentially maximize resilience and efficient use of resources (water, energy and finance) as part of a truly sustainable long-term flexible solution with an ability to adapt to changes in climate and the political/commercial landscape. “"Economic growth and sustainability are inter-dependent, you cannot have one without the other, and greening investment is the pre-requisite to realizing both goals." – see report from Davos.
The work to support an alternative BG strategy has not been done. The author of the study on SUDS for Putney used by Thames Water to support the tunnel approach, Professor Richard Ashley, is now a member of our BGIET. He presented at a House of Lords committee meeting in December 2012 how this SUDS study was very limited in time and budget and heavily controlled by Thames Water in terms of inputs through to interpretations (many of which were incorrect in the Thames Water Needs Report, key section Appendix E). SUDS is also only one component of an integrated BG strategy. He summarized:
- The tunnel cannot bring the multi-benefits/multi-value now demanded of flood and coastal management schemes, nor by the Localism Act
- Seen in this light, London is NOT TOO DENSE to do this (but it will not be an overnight task)
- The tunnel will not help with reducing the flood risk
- Nor with the water stress
- It is not flexible and hence, by Defra’s own definition, not resilient – it will in future become a ‘sunk cost’
- We can get so much more from maximising the value we get from the stormwater in London and alternatives will deliver immediate benefits unlike the tunnel
The Thames Tideway Tunnel is not projected to be completed until at least 2023. It is common ground that time and funding projections of such projects are severely inadequate. A BG strategy is essentially low tech but is backed up by modelling analysis and proven evidence in the above and many more case studies. The relative risks of each approach needs airing as part of a comprehensive study.
The provision of adequate foul water (non-storm water) storage infrastructure is the responsibility of Thames Water. It is understood that the current system is close to capacity. It is not understood how much of the current requirements for the system are related to leakage and ground water pumping or how much of this capacity shortage will be relieved due to water demand conservation measures and new technologies in the coming years. There are also many other factors influencing system performance. The tolerances of each component that impact the system performance can and should be modelled to guide the policy and decision making processes for current and future designs [MOD01]. Tolerances of the models need to be linked to their interpretations, e.g. water quality is notoriously difficult to predict.
The BGIET propose that, with the above arguments, the current Thames Tideway Tunnel scheme will be shown to be a poor solution for Londoners and our global technical reputation if BG solutions are not appropriately considered as part of the whole package. It is not the responsibility of Londoners to produce Best Technical Knowledge alternatives to the Tunnel but is an omission in the Thames Water pre-application consultation process not to have equally set the Tunnel in the context of its alternatives for Londoners to make an informed choice.