Thames Water Consultation Questions
Richmond & Twickenham Friends of the Earth response
13th March 2023
Q1. We’ve chosen to aim for the highest level of environmental improvements. This is supported by our regulators. We’ll be tracking the benefits of our work as we carry it out and will adapt our approach as we learn more. Do you have any comments on our approach?
This is a response from Richmond and Twickenham Friends of the Earth (RTFOE). We have carefully followed and considered your consultation. RTFOE does not accept that you are aiming for the highest environmental standards. On the contrary, there is much evidence that you choose profit over environment. You appear to have chosen the cheapest option over and above options that are better for the environment. You should concentrate on fixing leaks, increasing metering, diverting water from high rainfall areas, enlarging existing reservoirs and changing public behaviour to use less water.
Your plan to reduce abstraction from chalk streams “to sustainable levels” by 2050 would be too little and far too late to save chalk streams from irreversible ecological catastrophe. There are only around 200 such streams in the world, renowned for their water quality. Despite huge fines in the past, Thames Water has discharged untreated sewage into the Hogsmill, a chalk stream which feeds into the Thames near Kingston. In January this year, local councillor Mark Todd, voiced his concern that Hogsmill Sewage Treatment Works (STW) is no longer fit for purpose and described the practice of overflowing sewage as “sickening” and that “significant investment in larger storm tanks and smart sewers could solve many of the problems of sewage overflow into the Hogsmill”
Thames Water fined £4 million after catastrophic sewage blunder – GOV.UK (www.gov.uk)
We are concerned that, apart from the damage to these unique environments, water at Teddington may be polluted from such discharges and contaminants would be transferred on to the Lee valley reservoirs.
Treated effluent should be tested to a higher level to include the presence of pharmaceuticals not currently tested for, as recommended by the recent EU Drinking Water Directive. Your ‘highest level of environmental improvements’ should not mean lower standards than Europe and the USA. Of particular concern is the presence of per-and polyfluoroalkyl substances (PFAS). These “forever chemicals”, do not break down in the environment, build up in the body and may be toxic. They have been found at high levels in thousands of sites across the UK. Two of them are known to be harmful to aquatic life and human health. They are reportedly connected with kidney and testicular cancer, thyroid disease, ulcerative colitis, high cholesterol and pregnancy-induced hypertension (National Toxicology Program, U.S. Department of Health and Human Services).’PFAS have been found in samples from Hogsmill STW, upstream and downstream from the Hogsmill river and in the Teddington area.
Guidelines from the UK Drinking Water Inspectorate state drinking water must contain PFAS chemicals at no more than 100 nanograms per litre (ng/l) although they are considering reducing this to 70ng/l. To emphasise this vital point, the European standard for this health concern is 2.2.ng/l – the UK standard is 100ng/l.
RTFOE believe that Thames Water has a moral obligation to lobby the government to prevent PFAS getting into the environment in the first place. This needs your urgent attention before they become a greater issue that water companies will ultimately have to deal with. In general we feel that the Thames Water Consultation concentrates on quantities of water abstracted, with very little measurable data on water quality, protecting your proposals from valid public scrutiny.
Q2. We’ve set out our plan for reducing demand, with government interventions, to achieve 123 litres of water per person per day on average. This is above the government’s national target, but we think it’s the right approach. We’ll monitor and develop this by building on our learnings and evidence. Do you have any comments on our approach or suggestions for additional measures we could take?
Reduced demand targets should be more ambitious and be set to at least the national level of 110 litres per person per day. Ofwat (in its WRSE statement response 18 Jan 21) noted its concerns that WRSE was not aiming for this consumption level by 2050 in accordance with the Environment Agency’s National Framework. As water becomes a more finite resource, more effort should be put into changing public behaviour to lower consumption and a continued public campaign is needed to do this. The head of the Environment Agency, Sir James Bevan, said in 2019: “If by 2050 we reduced per capita consumption to 100 litres a day, leakage by 50%, and did nothing else, it would provide enough water for an additional 20 million people without taking any more from the environment.”
Reducing consumer demand would mean reduced income for TW from bill-payers, and we wonder if this is a factor in your lack of ambition to align with the government target. RTFOE believe pricing should be structured so that low-volume water users are rewarded and high users are charged more per unit, over a certain threshold, to encourage behaviour change.
Q3. Measures to reduce demand for water make up over 50% of our forecast shortfall by 2050. Some of the activity is untested and not within our direct control. Do you think this is the right approach? Should we plan for additional new sources of water in case these measures don’t deliver the water we’ve forecast?
Reducing leaks by 16% in your plan by 2030 translates to only 100Ml per day. (p20) This is not good enough as there would remain an extraordinarily high 500Ml per day of leaks in 2030. We do not believe you should start with the most cost-effective interventions of customer and network leaks (p20), but you should prioritise the biggest leaks. (Thames Water WRMP brochure ) Your plans don’t seem to meet your targets.
More meters can only be good – as Thames Water has installed 700,000 in the last 7 years, a target of 300,000 over the next 7 years is less than challenging. Installation of a smart meter could result in a 13% consumption reduction per property. More human resources are needed to deal swiftly with leaks and be more proactive in replacing very old pipes. This should include winter readiness actions and more contingency planning for freeze-thaw events which cause leaks and as noted in your Leakage Performance Document, employ no-dig technology to fix leaks and prevent water loss on customers’ properties faster.
Steps to support customers to use water wisely need to be disclosed – what campaigns have you done each year? Have they changed behaviour/consumption? How are you measuring whether these campaigns are successful? We agree with Temporary Use Bans for hosepipes and non-essential use. These should be brought in earlier (for example in the 2022 drought), to increase the 10% saving. We also favour another independent body (such as the Environment Agency) advising water companies on appropriate trigger points for bans.
Q4. A new reservoir is an integral part of our best value plan for the South East. Do you have any comments on the size of a new reservoir?
Q5. Do you have any comments on the new water source options included in our draft plan?
Teddington DRA
RTFOE object to the planned water abstraction and effluent transfer into the Thames at Teddington weir because we believe it will be detrimental to the ecology of the river and the wider environment, and because there are less-damaging alternatives which you are not prioritising.
You are telling us that the proposed scheme size would extract and replace a maximum of 75 million litres/day (Ml/d), but you are also assessing impacts for 100 Ml/d and the new tertiary treatment plant at Mogden STW will be capable of treating 100Ml/d. Thus, we are concerned that in the future the extraction rate might be as much as 100Ml/d, which would exacerbate both known and unknown risks.
The potential temperature rise is one of the most concerning aspects for the biodiversity of that stretch of the river, which with the 75Ml/day scheme could be as much as 1.1C, and 1.5C if the abstraction rate was 100Ml/d.
You have admitted that the flow between the abstraction point and the effluent discharge point will be reduced: this flow could become very low indeed at times of drought. You say that the DRA will be operational between July and November, when the river ecosystems are already likely to be stressed with ever-rising temperatures as climate-warming increases and volume/flow reduces. This is exactly when replacing cool, fresh water with warm, saline, water will cause most damage to the aquatic wildlife.
Although the effluent will undergo a tertiary treatment before discharge, and you say nutrients would be “treated to standard”, it is bound to still contain certain levels of nutrients such as phosphates and nitrogen, and pollutants in the form of chemicals. This will add to the pollution burden that the freshwater Thames already carries, at a place where it is physically ill-equipped to deal with it, because of the barrier formed by lock and weir.
Together, the rise in temperature, reduced flow, and additional phosphorus and nitrogen, will lower the threshold for toxic algal blooms. These can prevent sunlight reaching lower depths, severely impacting aquatic plants and hence the whole food chain. The decomposition of the algae can then cause catastrophic oxygen depletion, with potential to cause a mass die-off event, including fish.
Some insects, such as caddisflies, are very sensitive to such changes, and form the base of many food chains. You have admitted that the impact on invertebrates cannot be predicted accurately, and that there are water quality issues regarding fish. You gloss over the fact that the 25% “sweetening flow” will mean a significant amount of effluent being discharged all the time.
This is also a spot much-used for a variety of recreational activities involving the river, so the scheme would pose an increased risk to human health as well as wildlife. On your own admission, the risks to human health need further assessment.
Although the predicted levels of some Water Framework Directive chemicals would be reduced to “below standard”, 3 new ones would be above standard, and 11 would continue to be “above standard”. That last point gives an indication of the already polluted state of the Thames.
RTFOE are also very concerned about chemicals that are not currently tested for, which are already in the river water, and will remain in the effluent, particularly PFAS (‘forever chemicals’), and pharmaceuticals, many of which are endocrine disruptors with the potential to cause very significant adverse effects on invertebrates and fish. Many chemicals are considered safe for wildlife at low levels, and you state that many of the impacts will be “minor” or “negligible”. However, there is growing concern regarding the cumulative impact on organisms (and humans) of being subjected to a “cocktail” of pollutants. There is no evidence that you have factored this into your modelling.
We are concerned to note that “if in future the UK water quality regulations were to be heightened in line with recent USEPA guidance, compliance will be very challenging for most of the UK new and existing water treatment works.” (p19 Final-G2-report—LWR.pdf (thameswater.co.uk)
Thames Water states “Reducing abstractions from the environment is the single biggest driver for investment in our draft plan” (Thames Water WRMP brochure, p11) Your proposal for the Teddington DRA water recycling scheme flies in the face of this statement.
Severn to Thames Transfer (STT)
There will be a need to transfer water from wetter parts of the country to the drier south-east, and STT is one option that should be considered. We think that the proposal to complete the restoration of the Cotswold Canals to provide a means of water transfer sounds like a better idea than a pipeline as it would provide both environmental and amenity benefits and has the support of the Cotswold Canals Trust.
South East Strategic Reservoir Option (SESRO)
RTFOE do not feel that it is appropriate for us to comment on large developments which may significantly impact other communities. However, we do wonder if existing reservoirs are being used to their full capacity and whether there are opportunities to deepen these or raise the embankments.
Thames Water is keen to invest in large-scale engineering projects to deal with projected shortfalls but RTFOE would prefer to see large scale investment in innovative technology to deal with and prevent leaks.
Q6. Do you think our draft plan represents the best value plan for you, your community and the environment?
We are outraged that so much water is being wasted through leaks and yet you are proposing a new project for extracting more water.
RTFOE does not consider the plan represents best value for our community or environment. “Best value” in monetary terms should not be the highest priority. There are many concerns about the ecology of the river and its biodiversity.
From a community aspect, the development will affect swimmers using the river, walkers who use the tow path as well as residents whose view of the river will be significantly altered.
Q7. Do you have any other comments on our draft plan?
Much of the draft plan appears to be a money saving exercise taking the most expedient route rather than routes which are better for river, environment and community. Linking the CEO’s bonus to significant reduction in the level of leaks and sewage overflows would make a clear indication to the public that Thames Water has public interests at heart.
The Teddington DRA scheme seemed to be presented at the consultation as a fait accompli, based on cost. To date 12,500 people have signed a petition against this plan so there are strong community objections for justifiable reasons. There was no mention of the 25% ‘sweetening flow’ of effluent that may continue at Teddington, at non-drought times, to avoid stagnant and biological growth within the pipes/tunnels.
There has also been emphasis placed on the scheme at Teddington and very little attention brought to the alternative site at Walton. We are concerned that the very high number of objections to DRA at Teddington may cause Thames Water to select the alternative Walton site instead, even though the very same objections would be consistent with an alternative site, particularly upstream of Teddington Weir.
As well as giving low attention to the question of water quality/pollution and concentrating more on quantities, nowhere in your consultation brochure do you provide clear statistical indication of CO2 emissions resulting from the different scenarios (for example, Teddington abstraction scheme versus reducing demand, reducing leaks, etc.). Also, your population projection chart (p12) does not give any statistical data on your three growth scenarios (though these are given on a different page) rendering any measure of scrutiny of the chart ineffective. Each of these omissions make it impossible for the public to objectively weigh up the advantages and disadvantages of any of your proposed schemes.
The Marine Conservation Society said recently that 9.4 trillion microfibres are released every week from clothes washed in the UK and 63% of shrimp in the North Sea contain synthetic fibres. These microfibres are entering the food chain and polluting the seas. The MCS would like to see microfibre filters in all new washing machines by 2025. Perhaps you could apply more pressure on government to do this? Stop Ocean Threads | What you can do | Marine Conservation Society (mcsuk.org)
Although this is a forum on Thames Water’s Water Resources Management Plan, RTFOE feel it cannot go without comment that TW’s record on sewage leaks is appalling and cannot go on unchecked. It is time for you to take responsibility for this grave practice that is ecologically catastrophic and take meaningful action before our rivers and river life are lost irretrievably.