The Thames Tideway Tunnel Project Preparatory Works Notice

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Dear Department for Environment, Food and Rural Affairs,

Please reply to the following questions and requests for information.

1. Following the issue on 4th June 2014 by the Secretary of State of The Thames Tideway Tunnel Project Preparatory Works Notice, please provide a breakdown of the £1.4Bn the Secretary of State permits or requires Thames Water to spend including acquisition of land.

2. The National Audit Office publication “Thames Tideway Tunnel: early review of potential risks to value for money”
of October 2013 was not made public until June 2014. Why did Defra or the coalition government delay publication?

3. The reports and recommendations of the IPC Inspectors (PINS) examination report and recommendations were due to be issued to the Secretary of State on 16th June 2014, 12 days after the issue of The Thames Tideway Tunnel Project Preparatory Works Notice. The issue of the above notice implies that the Secretary of State has preempted those reports and recommendations and intends to ignore them. Please therefore confirm that the reports and recommendations will be released into the public domain forthwith. Please forward a copy.

4. Regarding the government's estimated cost of the Thames Tideway Tunnel, Inflation from May 2011 to May 2014 was 7.16%. Therefore £4.2BN (at May 2011 prices) = £4.5Bn (at May 2014 prices). The Building Cost Information Service indicates a larger percentage increase with inflation of Utilities contract tenders rising 4.2% in the previous 12 months alone. Similarly, the Thames Water announced £70-80 bill increase (TW 2013 estimate at 2011 prices) becomes £75 -86. CPI for the same period was 128/119.5 i.e. 7.2%.
Does Defra not agree that they should announce these inflation adjusted figures to the public?

5. “As at 31 December 2013, Thames Water had spent an estimated £0.5 billion on the project.” Ref: National Audit Office publication “Thames Tideway Tunnel: early review of potential risks to value for money” - 2nd June 2014. This publication states £0.7-1.2 benefit for each £ spent. Prof. Binnie’s recalculation using the government's methodology results in a £0.04 benefit for each £1.00 spent. To arrive at the government's claim of a £0.7-1.20 benefit, is it not the case that the whole of the UK population was considered a beneficiary? If the whole of the UK population is considered a beneficiary, why are only Thames Water bill payers required to pay for the TTT and not the whole of the UK population?

6. Please provide:-
(i) a breakdown of the £0.5Bn costs to December 2013 referred to in the NAO publication
(ii) confirmation of who in Defra audited those costs or if they have been audited by Ofwat and
(iii)please provide up to date costs.

7. There is evidence to suggest and it has been proposed that the government are in "Regulatory Capture"; as defined by Nobel laureate economist George Stigler. What rebuttal does the government have to this proposal?

8. Thames Water have stated that both their 5.5 million domestic bill payers and their business customers would pay for the Thames Tideway Tunnel whereas regulator, Ofwat, stated in a FoI response that only domestic customers would pay. Who is right?

9. Is not complicity by the Secretary of State in authorising novation of USA based CH2M Hill as Thames Tideway Tunnel Project Manager, without competition, illegal under European and International Law? Is it not also counter to government policy to promote British businesses? Two substantial, competent, British, designers and project managers of international repute that come to mind are Arup and Mott Macdonald. Why were they and others not deemed capable by the Secretary of State of fulfilling that function?

10. In view of government policy to promote British businesses, why has the government accepted that only two British companies out of the 18 invited to tender for the tunnel contracts by Thames Water complies with that policy?

11. The government has told the British public that Thames Water would have no involvement with financing, design, specification or delivery of the Thames Tideway Tunnel project however; we now know that through issue of the 4th June notices that Thames Water have a one third stake (£1.4Bn of £4.2Bn) in the project. What explanation does the government have for misleading the British public?
We also now know that the government are requiring Thames Water to procure a financier for this project. Please explain how that des not constitute involvement with financing the project?

12. The government has already committed Thames Water customers to paying costs of £0.5Bn on the TTT proposal (to the end of 2013). Thames Water's estimate is that bill payers will pay an extra £70-80 a year at 2011 prices for the TTT. Adjusted for inflation, those figures are £75-86 a year at today's prices. The NAO publication presumes that payment will be over 50 or 100 years. Is the government not being disingenuous in confirming the cost of the TTT as £4.2Bn at 2011 prices when 5.5 million bill payers paying an extra average £80 a year for 50 years = £22Bn or £44Bn over 100 years (excluding inflation and operating and maintenance costs of the tunnel)? Since the government estimate of HS2 cost equates to this sum, please confirm the government's definition of value for money and if the government considers the cost and benefit of the TTT to be proportionate in terms of National Infrastructure?

13. Since the TTT is not defined as a sewer but as a detention tank, designed to detain about 1.5 million m3 of water until the sewage treatment works can cope with flows, the cost of creation of that detention capacity is, according the government, £4.2Bn divided by 1.5 million which is £2,800 per m3. Independent costing indicates a cost of an intensive green roof with 150mm of growing medium (soil) as a fraction of the TT cost. Please provide the governments comparative costs for other forms of detention in £ per m3.

14. The Secretary of State has delayed for 4 years instigation and implementation of the Sustainable Drainage Regulations. The effect of instigation and implementation of the Sustainable Drainage Regulations is to reduce the number and quantities of discharges from Thames Water's sewers to the Thames Tideway. Please confirm the government's estimate of those reductions over the next 10, 20 and 30 years years.

15. In view of reductions of the number of discharges and the quantities of those discharges that will result from the instigation and implementation of the Sustainable Drainage Regulations, please provide a copy of the governments calculations of when those discharges will reach an average of 4 a year; as the Environment Agency require.

16. In view of those reductions and the fact the fixed diameter tunnel will remain the same whatever the flows, the relative cost per m3 of water detained will increase over time. Does the government not therefore consider that the tunnel is not in fact a resilient solution as claimed?

16. In view of the fact that the TTT will become redundant before the NAO assumption of a 50-100 year useful life/payment period, please confirm the government's estimate of the cost for demolition and decommissioning of the TTT at today's cost.

17. Under provisions within the EU Water Framework Directive, the UK is required to achieve a "good" status for surface waters. Please confirm that before the TTT, the water quality in the Tideway is "moderate" and if after commissioning of the TTT the water quality will remain "moderate".

18. Please confirm Defra's strategy, programme and estimated cost for surface waters to reach "good" status in the Thames Tideway.

Yours faithfully,

Roland Gilmore

Helpline, Defra (CCU), Department for Environment, Food and Rural Affairs

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mrs k waite left an annotation ()

Dear Mr Gilmore

In response to your request for information surrounding the construction costs of the Thames Tideway tunnel project you may be intrigued to learn that one of the contractors involved in this project Imtech/Meica Plc have been exposed by Ofwat as being involved in corruption and despite being personally aware of these matters there CEO Mrs Cathryn Ross has chosen to conceal these matters from the police !
Regards Mr Lewis.

Ryland-Jones, Philip (Defra), Department for Environment, Food and Rural Affairs

1 Attachment

Dear Mr Gilmore

I attach a letter acknowledging your request of 3 July for information
relating to the Thames Tideway Tunnel project.

<<140715 acknowledgement letter.pdf>>

Yours sincerely

Philip Ryland-Jones
Thames Tideway Tunnel Team
Water & Flood Risk Management
Defra
Area 3D, Nobel House
17 Smith Square
London SW1P 3JR
Tel: +44 (0)20 7238 1591
 

Department for Environment, Food and Rural Affairs (Defra)

This email and any attachments is intended for the named recipient only.
If you have received it in error you have no authority to use, disclose,
store or copy any of its contents and you should destroy it and inform the
sender.
Whilst this email and associated attachments will have been checked for
known viruses whilst within Defra systems we can accept no responsibility
once it has left our systems.
Communications on Defra's computer systems may be monitored and/or
recorded to secure the effective operation of the system and for other
lawful purposes.

Ryland-Jones, Philip (Defra), Department for Environment, Food and Rural Affairs

1 Attachment

Dear Mr Gilmore

I attach for information a letter notifying you that an extension is
necessary to the deadline for responding to your EIR information request:

<<140731 deadline extension - EIRs.pdf>>

As mentioned in the letter, I will endeavour to provide you with a
response to your request as soon as possible.

Your sincerely

Philip Ryland-Jones
Thames Tideway Tunnel Team
Water & Flood Risk Management
Defra
Area 3D, Nobel House
17 Smith Square
London SW1P 3JR
Tel: +44 (0)20 7238 1591
 

Department for Environment, Food and Rural Affairs (Defra)

This email and any attachments is intended for the named recipient only.
If you have received it in error you have no authority to use, disclose,
store or copy any of its contents and you should destroy it and inform the
sender.
Whilst this email and associated attachments will have been checked for
known viruses whilst within Defra systems we can accept no responsibility
once it has left our systems.
Communications on Defra's computer systems may be monitored and/or
recorded to secure the effective operation of the system and for other
lawful purposes.

Dear Ryland-Jones, Philip (Defra),

Since all of my questions are basic questions that should have been asked by the EA before now and that the answers should be the drivers for decisions made by politicians and the Secretary of State, I am disappointed with your bewildering response and statement that means you do not have the answers to hand. Do you really have no answers to any of the questions asked?

Here is a quote from your own Environment Agency 2009 report titled "Transforming wastewater treatment to reduce carbon emissions" signed by the Director of Evidence, Miranda Kavanagh.

"Options to offset this increase [of carbon emissions] over the long–term do exist. Improved operational efficiencies, reducing the reliance on end of pipe solutions and minimising pumping and treatment of surface water runoff are part of suite of strategies which need to be considered.”

I find it truly deplorable that the EA ignores its own evidence and considered advice concerning efficiency opportunities and modern technologies by preferring out-dated Roman technology solutions (gravity drainage) with Victorian technology (pumps) that exacerbate climate change; preferring treatment of rainwater run-off when other, sustainable, less costly solutions are available and being put into practice throughout the developed and developing world. There are many more examples within EA, academic and other publications that illustrate why the Project Preparatory Works Notice is ill-judged, defies common sense, is indicative of Regulatory Capture of Defra and results in the creation of grounds for Thames Water to sue the government for compensation in the event that the Thames Tideway Tunnel proposal does not proceed. That is not an additional question but a reflection on the illogical management practiced within Defra.

I find your excuse for not responding within 20 days unreasonable.

Yours sincerely,

Roland Gilmore

Dear Ryland-Jones, Philip (Defra),

It is now 11 days after the extended day you said you needed to respond to my questions and many weeks after the date to provide the information requested.

The information requested should all be in your possession as prerequisites to making determinations and judgements.

In view of the fact that responses are now long overdue, I request an internal review within Defra that I trust will lead to a swift response. If I do not receive a substantial reply within the next three days, I will have no alternative but to make a complaint to the Information Commissioner.

Yours sincerely,

Roland Gilmore

Information Requests (DEFRA), Department for Environment, Food and Rural Affairs

1 Attachment

Dear Mr Gilmore,

Please see the attached response to your request for information, with
apologies for the lateness.  This was due to the time it has taken to get
the correct information together and handle your response accurately.

You also made a request for an internal review, please confirm whether you
would like to pursue that.

Yours sincerely,

Amanda Roper

Defra FOIA and EIRs Team

<<20140910 TTT Preparatory Works Notice 6725.pdf>>

Department for Environment, Food and Rural Affairs (Defra)

This email and any attachments is intended for the named recipient only.
If you have received it in error you have no authority to use, disclose,
store or copy any of its contents and you should destroy it and inform the
sender.
Whilst this email and associated attachments will have been checked for
known viruses whilst within Defra systems we can accept no responsibility
once it has left our systems.
Communications on Defra's computer systems may be monitored and/or
recorded to secure the effective operation of the system and for other
lawful purposes.

Roland Gilmore left an annotation ()

Regarding my question 13, the detention capacity of the Thames Tideway Tunnel has subsequently been confirmed as 1.24 million cubic metres.
This increases the cost for creation of tunnel detention space to £3,500 per cubic metre. Every green infrastructure measure costs less than this and have multiple additional benefits that Ofwat and Defra have not costed or considered.
In view of the evidence, the refusal of the government to reconsider the National Policy Statement on Waste Water is indefensible as is Ofwat's refusal to protect the public interest.