Thames Water Teddington Direct River Abstraction Proposal
Response from Richmond & Twickenham Friends of the Earth
11th December 2023
Richmond and Twickenham Friends of the Earth remains opposed to the Teddington DRA proposal for the reasons given in its original eight page response in March 2023. It is meaningless to consult upon details of the construction when the community, environmental groups, councillors and MPs have wholeheartedly rejected this plan and there have been no real environmental or social impact assessments of this proposal in advance of an announcement that it is the best option.
The key areas we object to are:
Environment
There will be extensive ecological damage to flora, fauna and aquatic life with destruction of wildlife habitat impacting badgers, foxes and nesting birds.
Replacing river water with treated effluent containing antibiotics, contaminants of emerging concern, PFAS, PFOS (recently found in drinking water samples in the UK – described by WHO as carcinogenic to humans) and E. coli will concentrate such pollutants as we understand that no reverse osmosis is planned for Teddington DRA.
Replacing the cool river water with warmer treated effluent will damage aquatic wildlife and increased nutrients such as phosphates and nitrogen could result in toxic algal blooms. This will be exacerbated if the sweetening flow of treated effluent is discharged all year round.
Social Impact
The process of constructing shafts and the abstraction and outfall units will restrict access to community land and amenities for years whilst subjecting nearby residents to dust, noise and air pollution and congesting the area with heavy lorries.
Local schools use Moormead for their sports activities and it is used constantly for local sports and community events – prolonged construction work here will impact the whole Twickenham and St Margarets community.
Swimmers, walkers and river users will not be able to access Burnell and Dysart Open Spaces. You will be closing an extremely busy towpath for long periods which thousands of local residents use to travel between Teddington, Ham and Kingston. You propose turning a much loved and extensively used part of the riverbank into a polluting building site.
Site Impacts
Shaft 1 – Ivybridge Retail Car Park north – dust, noise and detriment to business through loss of car parking.
Shaft 2 – Moormead and Bandy Recreation Ground Central – this is a Site of Local Importance for Nature Conservation not merely amenity grassland. The removal of trees is unacceptable. Heavy lorries across the site will compact the ground and construction could adversely affect the nearby River Crane and environs which are an important habitat. Loss of access for sport and recreation and potential danger to children and the elderly from lorries.
Shaft 3 – Ham Street Car Park – flood risk area and this site is within the Ham House Conservation Area and parts of the site are within Archaeological Priority Areas. Deciduous woodland and native hedgerows along the boundaries of the site are the habitat of bats, birds, and potentially badgers and stag beetles.
Shaft 4 – Land to the west of Riverside Drive playground – air quality, noise and vibration will affect residential properties and construction will affect access to the children’s playground and green space.
Shaft 6 – Ham Lands west of Riverside Drive – site is in Ham Lands nature reserve and within Ham Lands SINC. There could be a severe effect on local ecology as this grassland and deciduous woodland is home to many birds and animals as well as unique flora and plants. Nearby homes will be affected by noise as well as the impact on local road users.
The final sewage outfall is almost in the exact spot where many people swim in the river and is used for boating by many nearby clubs and private individuals making good bathing water quality of crucial importance.
The abstraction point and TLT Connection option 1 would be extremely damaging to the woodland at this sensitive location. We are also concerned that the abstraction plant will be larger than shown and will have ugly security fencing around it currently not shown in drawings at all. It is also not spelt out that this abstraction plant will be built on top of and will result in permanent diversion of the lower towpath by the river presumably through the woodland nearby causing more damage.
Issues with development at Mogden
This Site of Importance for Nature Conservation contains deciduous woodland priority habitat, some of which may need to be removed and for the duration of the development there will be a loss of Local Open Space.
Those living locally could be affected by air quality, noise and vibration during the works. Will the operation of the completed facility impact nearby residents too?
Lack of Trust
The Environment Agency with its lack of funding and staff does not seem to have a grasp on the frequent pollution incidents caused by water companies (as detailed in the recent Panorama programme 4th December 2023). The lax government regulation of water quality and sewage discharges and the precarious state of Thames Water’s finances does not reassure us at all.