Response to Chris Binnie - FINAL

7/31/2019 Response to Chris Binnie - FINAL

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1.1 Introduction

1.1.1 In October 2011, Mr Chris Binnie gave evidence to the Thames Tunnel(Selborne) Commission. We have responded to his presentation, which isoutlined in Section 1.2 of this document.

1.1.2 From November 2011 to April 2012, Mr Binnie also provided ThamesWater with a series of documents, arguing for alternative solutions to thefull length tunnel system and commenting on the justification for theThames Tunnel. Materials submitted included a main report1, with 5addendums. The papers were sent to Defra and the Environment Agency(EA), along with a note on a different approach to mitigate low dissolvedoxygen in the tidal Thames. Our response to these submittals is given in

Sections 1.3 to 1.11 of this document.1.1.3 Mr Binnie, in producing his initial report in November 2011, did not contact

or ask for a briefing on the project from either Thames Water or theThames Tunnel project team. Such a briefing would have updated him onthe progress that has been made in the 5 years since his chairmanship ofthe Thames Tideway Strategic Studies (TTSS) came to an end, andwould have provided him with essential information countering thearguments he made in his submissions.

1.1.4 Following his submissions, the project team have briefed Mr Binnie,providing him with additional information on aspects of his suggestions

and proposals, to help further explain why the full length tunnel systemremains the most appropriate and cost effective CSO control solution forthe tidal Thames.

1.1.5 It is now understood that during a formal meeting sponsored by SimonHughes MP, in March 2012, Mr Binnie retracted his opposition to the fulllength tunnel solution. He is now calling for mitigation measures to helpappease infraction proceedings and possible fines. Our response to hisproposed mitigation measures is given in Section 1.12.

1.1.6 In a meeting with Phil Stride and David Crawford on 26 March 2012, MrBinnie suggested that it was not necessary to produce a formal response

to the arguments he has made. However, we believe it is important toavoid future revisits on similar issues and to match the effort Mr Binniehas put into his work, particularly since it has attracted significant mediaattention.

1.1.7 This report outlines the primary arguments and suggestions made by MrBinnie and our response to them. The report also includes a section onthe evidence presented to the Thames Tunnel (Selborne) Commission byMr Binnie and our rebuttal and corrections to his evidence. It also includesan additional response to his latest submission on mitigation measures, toappease EU infraction proceedings.

1 Project Justification Review, Chris Binnie, November 2011.

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1.2 Thames Tunnel (Selborne) Commission

1.1.8 The Thames Tunnel (Selborne) Commission interviewed Mr Binnie, withparticular interest in his suggestion, (at the time of giving evidence), thatthe alternative option of a Western Tunnel connecting from Acton and

extending to Heathwall, should be revisited in light of the improvements tobe delivered by the Lee Tunnel and the upgrading of the SewageTreatment Works (STWs). This Western Tunnel alternative is effectively aslight modification of the west tunnel element of the Jacobs Babtieproposal and so suffers from the same drawbacks. Principally, the CSOdischarges between Vauxhall Bridge and the Thames Barrier would beignored. This would fail to meet the requirements of the EU Urban WasteWater Treatment Directive (UWWTD).

1.1.9 The Selborne Commission also reported Mr Binnie suggested that presentestimates of projected dry weather flows are overestimated, and that

some of the environmental standards are inappropriate. The argumentassociated with projected dry weather flows is largely insignificant, asCSO discharges are caused by wet weather events. Although variation inpredicted dry weather flows may have some minor influence on theanticipated spare capacity of the existing sewerage system to receivepump-out from Binnies proposed Western Tunnel, these would beswamped by the additional flows resulting from the substantialredevelopment proposed for the area around Battersea and Heathwall.The commission did not clarify their allegations over the appropriatenessof the environmental standards.

1.1.10 The commission and Mr Binnie both seem to misinterpret and fail tounderstand the impact of the Lee Tunnel on the tidal Thames. The LeeTunnel captures the Abbey Mills discharge to the River Lee and conveysthe excess flows to Beckton STW for treatment. The effluent from thattreatment is then discharged into the tidal Thames at Beckton. The LeeTunnel does nothing to reduce any of the discharges between Acton andthe Thames Barrier.

1.1.11 Since the commissions report, Mr Binnie has supplied addendums to hisreview, but it is unclear if he has retracted all, or any, of his opinionspresented to the commission.

1.3 Primary Arguments

1.1.12 The documents submitted to Thames Water had various suggestions onalternative solutions that, in Mr Binnies opinion, would cost less to buildand might possibly comply with the UWWTD and meet EnvironmentAgency (EA) water quality standards.

1.1.13 Our analysis and that documented in many of the past studies, shows thatnone of the suggestions made by Mr Binnie would comply with theUWWTD or could meet the water quality standards, set by the TTSS andendorsed by the EA, for the tidal Thames. In all options proposed by Mr

Binnie the unit cost of the CSO control suggested exceeds that of theproposed Thames Tunnel.

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1.1.14 Rather than respond to the individual documents submitted, some ofwhich repeat arguments from earlier documents or provide furtherinformation, we have grouped Mr Binnies suggestions into the followingcategories and each category is addressed in individual sections:

Alternative tunnel scheme

Aesthetics, river use and health

Sustainable drainage systems (SuDS)

Cost

Models and modelling

Dry weather flow and population

Climate change and rainfall

Dissolved Oxygen and fish

Most recent mitigation scheme for avoidance of infraction fines

1.4 Alternative tunnel scheme

1.1.15 Mr Binnie suggested an alternative tunnel scheme that was partiallybased on the Jacobs Babtie twin tunnel option. The suggested alternativewould involve continuing with the Lee Tunnel, to capture discharges fromthe Abbey Mills CSO, and then building a second tunnel in the west tocapture the discharges from the larger CSOs in the west, referred to asthe Western Tunnel.

1.1.16 The Western Tunnel would control 192 unsatisfactory CSOs within thewestern reach of the Tideway. However, it would still leave 16unsatisfactory CSOs uncontrolled, which would continue to discharge intothe tidal Thames. Mr Binnie did not provide any definition of the WesternTunnel, so our evaluation is based on the western portion of the ThamesTunnel scheme presented during phase two consultation. This includedextension of the Western Tunnel to Acton Storm Tanks, controlling theActon CSO and improvements to the system and Crossness STW forcontrol of the Charlton CSO.

1.1.17 In a typical year, the Western Tunnel would continue to discharge 10

million m3 into the river, and with as many as 39 spills from theunaddressed CSOs downstream. Brixton CSO would still discharge 31times in a typical year and would continue to impact sections of thewestern reach during incoming tides.

1.1.18 The Western Tunnel does not meet the Dissolved Oxygen (DO) standardsdeveloped by the TTSS, which was to design a solution that wouldachieve the obligation set under the UWWTD to limit pollution from STWsand CSOs. The Western Tunnel would fail the Standard 1, 4mg/lthreshold and Standard 2, 3mg/l threshold set by the TTSS and approvedby the EA. Furthermore, the EA argues it is wholly inappropriate for

2 Counting of unsatisfactory CSOs matches categories 1 and 2 defined by the EA. Note that someCSOs have the same number but are two separate discharges.

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Environmental Quality Standard (EQS) to be revised and reduced to fit asolution, simply because the solution appears more convenient undershort term economic conditions, particularly as it would not meet theoriginal standards set just a few years ago.

1.1.19 The Western Tunnel has significant issues, including genuine concernsarising from pump-out capabilities, potential risk for septicity, odour andcorrosion problems. There is also the real potential risk of increased CSOspills and septicity of the sewage in the Western Tunnel, with predictedfuture population growth.

1.1.20 The significant odour issues identified with the Western Tunnel would be amajor problem along the sewers receiving pump-out: which would includethose in southern London, between Heathwall and Crossness STW.

1.1.21 The local opinions on proposed shaft locations, legacy structures anddisruption from building the scheme would remain the same in the west asthey are for the full length tunnel.

1.1.22 The commitment of almost 2 billion for only a partial control of CSOdischarges would be construed as a waste of money because dischargesfrom 16 unsatisfactory CSOs would continue and the control objectiveswould not be met. Discharges from adjacent CSOs not controlled wouldcontinue to move upstream to the western reaches during incoming tides,highlighting, again, how a partial control solution is insufficient.

1.5 Aesthetics, river use and health

1.1.23 Mr Binnie has commented on the adequacy of the EAs determination of

unsatisfactory CSOs. This critique of the EAs determination revolvesaround aesthetics, recreational use impacts and the risks to humanhealth. The EA has re-evaluated their determination of unsatisfactoryCSOs whenever new information has become available. The EA hasspecifically stated to Thames Water that no change in the determination ofunsatisfactory CSO is warranted and so there is no change to the CSOsrequired for control by the Thames Tunnel. The EA has met anddiscussed this with Mr Binnie.

1.1.24 In light of some of Mr Binnies comments the following paragraphshighlight some additional comments and observations.

1.1.25 No cost-effective and viable option for screening individual CSOs hasbeen found. Aesthetics would continue to blight the river until CSOs areadequately controlled though interception by the proposed ThamesTunnel. Individual screening at CSOs was rejected by the TTSS becauseof the costs and disruption of constructing screening equipment at most ofthe CSO locations. It would also require dispersed local facilities to handlethe screened material. This would raise neighbourhood issues associatedwith odour and the transportation and disposal of the screened material.The operation and maintenance of screening facilities is an intensiveactivity requiring dedicated staff and as such, the life cycle cost of having

up to 34 individual screening facilities would far exceed that of theproposed Thames Tunnel. The screening of CSOs, would also not

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remove the oxygen demanding pollutants found within sewage, meaningthe dissolved oxygen levels within the water would continue to beaffected. It would also be inadequate in removing the dangerouspathogens which bring human health risks to river users.

1.1.26 Chirs Binnie confines his assessment of the health risks of sewage in thetidal Thames to just the heavily used recreational areas of the tidalThames, such as the western reach above Putney Bridge and the LondonDocks. He also argues that frequent recreational users of the river areless susceptible to getting sick because they come into contact with riverwater polluted with sewage more frequently and so have built upimmunities to harmful viruses and bacteria. This argument of allowingfrequent recreational users to become ill is completely unacceptable.There is no evidence that individuals build up immunity to the harmfulviruses and bacteria found in sewage, such as Campylobacter,Salmonella and Enteroviruses. Mr Binnies unsubstantiated argument also

ignores the risks to infrequent recreational users who would not have theopportunity to build up this alleged immunity. The Thames RecreationalUsers Study by the City of London Port Health Authority and The HealthProtection Agency found that there was evidence of an elevated risk tothe health of recreational users of the upper tideway for two - four daysafter CSO discharge events. It also found that there was significantevidence of frequent contamination with potential human pathogens.Sampling carried out for this study also demonstrated that the tidalThames only met the WHO guideline standard for less than 1% of thetime.

1.1.27 The selectivity in protecting only portions of the tidal Thames from sewagedischarges is misguided. The tidal Thames has recreational and businessuses throughout its length and so all persons who could come into contactwith the river water, anywhere along the river, should be protected fromCSO discharges, as is required by the UWWTD.

1.1.28 The tidal nature of the river also makes the impact of CSO dischargescomplicated, as the pollution from a discharge is able to travel milesupstream and downstream on each tide. Controlling only a portion of theCSOs would be ineffectual as pollution from other un-controlled CSOswould be able to travel to the controlled river reach areas, on every tide.This tidal movement is also particularly pronounced during summer

months when fresh water inflows are low.

1.6 Sustainable drainage systems (SuDS)

1.1.29 Mr Binnie accepts that SuDS cannot solve the existing CSO problemsfacing the tidal Thames today within any reasonable timeframe, althoughhe believes they can still form part of the longer term strategy formanaging rainfall-runoff. We agree with this; however SuDS cannotprovide a viable or cost-effective CSO control strategy for London.

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1.7 Cost

1.1.30 Mr Binnie has put forward numerous arguments based on outdatedinformation and flawed assessments and comparisons. His mainarguments revolve around the increase in costs from TTSS estimates,

application of the best technologies without excessive costs, and thewillingness of customers to pay.

1.1.31 The primary reason for the change in overall project cost is the level ofdetail and consideration of risk and other programme costs between theTTSS and todays estimate. The TTSS cost estimates were based on avery preliminary understanding of the required scope and did not includeall of the other costs associated with such a significant project.

1.1.32 The technologies being applied and the extent of the CSO controlachieved will not lead to excessive costs. Simply, the problem is large andso a major programme is required to achieve the level of control that is

appropriate. The level of control is balanced between a larger scheme thatmeets the requirements, or a smaller scheme that does not. The level ofcontrol achieved by the scheme is appropriate and is supported by theassessments made by the Environmental Agency.

1.1.33 Cost and benefits have been reviewed and independently determined byDefra who continue to support the economic and environmental case forthe programme.

1.1.34 The ability and willingness for customers to pay for the scheme wasevaluated by Defra and was found to be not excessive, particularly whencompared to other water customers in England.

1.1.1 Mr Binnie appears to recognise in his most recent materials that theThames Tunnel is required and so submits options to help mitigateagainst fines from infraction proceedings until construction has beencompleted.

1.8 Models and modelling

1.1.2 Mr Binnie rightly points out the risks in basing decisions on models andmodelling. We agree, and have developed a suite of modelling tools thatadequately show comparisons between different options and scheme

performance. The models that have been developed and those used arethe best available. They continue to be improved and re-verified and areentirely fit for purpose.

1.9 Dry weather flow and population

1.1.3 Mr Binnie made extensive comments on population growth, changes towater use profiles and reduction of flows into the sewerage systembecause of improvements to the water system. This is primarily becauseof the Victorian Mains Replacement programme. All of these issues areroutinely considered in the Thames Tunnel project and the effects ofchange in these have been included in determining the sensitivity of thesystem and control of CSO discharges.

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1.1.4 However, the primary driver in CSO discharges is rainfall and any changein population or water use will have little impact on the number andvolume of CSO discharges.

1.1.5 Future population projections have been updated to reflect the changefrom the original values estimated during TTSS and with the latest, 2010projections. Projections to 2020 and the baseline for evaluating theThames Tunnel, continue to show an increase in population served byBeckton and Crossness STW catchments of approximately 17%.Similarly, any reduction in water use from new and existing customers willhave more of an effect on the actual amount of sewage generated and sowould likely impact on the STWs more. Although individual reduction inwater use is likely, this will be more than offset by the growth in populationleading to higher sewage flows. To reiterate, CSO discharges are causedby rainfall and so any reduction in water use, when combined withincreased population, would not reduce the magnitude of the CSO

problem.

1.10 Climate change and rainfall

1.1.6 Mr Binnie requested additional information on how Thames Water hasevaluated climate change impacts on the scheme. He also made varioussuggestions on how to approach climate change evaluation.

1.1.7 Such information and analysis were discussed with him and the generalconclusions were:

a. Changes in rainfall patterns will lead to warmer and wetter winters and

warmer and drier summers.b. CSO discharges will be marginally increased by winter rainfall change

in the typical year, with one additional event occurring. This is with aconservative assumption of no further improvements made to theSTW capacity, or any catchment changes, through SuDS, whichwould help reduce the impact change.

c. Warmer but drier summers will result in little change in CSOdischarges, as CSO control during summer storm events is alreadyhigh. Increased summer river temperatures will make the river moresusceptible to discharges, meaning the control of CSOs will be even

more necessary in the future.d. The Thames Tunnel is capable of adapting to such changes and is a

robust solution.

e. Because of the uncertainties of predictions, the proposed tunnelsolution has been evaluated against a wide range of potentialscenarios to gauge how it would respond to change. The assessmenthas demonstrated that the proposed tunnel solution is very resilient tothe potential changes due to climate change and growth. However itmust be stressed that CSO discharges are a problem which isoccurring today, with current rainfall and temperatures, and so they

are a problem that needs to be tackled today.

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1.11 Dissolved Oxygen (DO) and fish

1.1.8 It is very disappointing that the Chairman of the TTSS has chosen torebuke the EA on applying DO standards, since these were set throughsubstantial study and discussion by the TTSS. Mr Binnie asserts he is not

a fishery expert, but goes on to judge the work of such experts, theagency responsible for environmental protection, and the suitability of thestandards set for protecting the fishery and habitat of the river.

1.1.9 One of Mr Binnies recommendations was for a review of the water qualitystandards used to evaluate the benefits of the Thames Tunnel and otherTideway Improvements. The EA has responded to this recommendationby reiterating the basis for setting the TTSS DO standards and lookinginto whether these standards do need to be further reviewed or revised.

1.1.10 The EA believes that there is no valid reason to relax the standards,because:

a. In setting the standards, the EA has taken into account the nature ofthe tidal Thames and have not sought to set the bar unnecessarilyhigh.

b. The standards have been derived in a scientifically robust anddefensible way that has been peer-reviewed by independent experts /consultants.

c. Mr Binnies criticism of employing the needs of a particular species,such as salmon, is a misinterpretation of using such species, amongstothers, as an indicator species to represent the river ecology as a

whole. The standards are appropriate to protect other sensitive andvulnerable fish species and to protect the overall ecological health ofthe Thames Tideway.

1.1.11 As is the case with all environmental quality standards (EQS), includingthose used for design and compliance purposes: environmental needs,the nature of the water body and objectives all determine the standardsset.

1.1.12 The EA has responded to Mr Binnie by saying that it is whollyinappropriate to suggest that EQS should be revised or adjusted to fit theengineering solution, simply because the solution does not meet the

required standards. The TTSS DO standards were set using the bestavailable knowledge on the effects on the rivers ecology of extendedperiods of low DO and the tolerance of fish to hypoxia and, in the EAsview; these standards remain entirely valid today.

1.1.13 The standards set can only be met by the control of the unsatisfactoryCSOs achieved by the Thames Tunnel.

1.12 Mitigation scheme to avoid infraction fines

1.1.14 Mr Binnie produced a note, in April 2012, outlining a suggestion formitigation of low DO in the river while the Thames Tunnel is implementedand to avoid fines from the European Commission because of infraction in

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relation to the UWWTD. This note was prepared by him on the basis thatthe Thames Tunnel is a committed project.

1.1.15 He states that it is likely that infraction fines will be imposed with anestimated fine as high as 1.5bn. We cannot give an opinion on thevalidity of the value of potential fines, nor whether any fine would beimposed given the commitments being made to control CSOs.

1.1.16 He states that standards for ecology, aesthetics, and health impact wouldbe achieved by completion of the Thames Tunnel, but that interimmeasures could be implemented to help reduce the environmental impactof non-compliance, until the Thames Tunnel is operational.

1.1.17 He proposed an in-river fixed bubbler system to raise the oxygen levels inthe River Thames, so that the dissolved oxygen sags, that would fail thestandards without the Thames Tunnel, would be mitigated. He alsoproposes works to minimise the effect of the litter in the river, primarilyvortices, floating booms and skimmers, and also measures to reduce thehealth impact. His estimated cost for these measures was about 60million.

1.1.18 We do not agree that the spending of, at least, 60million is good valuefor money or that his use of vortices and booms etc to reduce litter areviable options. The EA reached a similar conclusion in response to thismitigation plan and we agree with their analysis. We have outlined belowour observations on the practicality and effectiveness of this mitigationplan, by contrasting characteristics of Cardiff Bay (referred to by MrBinnie) and the Thames Tunnel and then by considering a number ofaspects of the Tideway.

1.1.19 Cardiff Bay: Mr Binnie mentions in various documents the diffuse airsystem that is installed at Cardiff Bay and whether this type of systemcould assist with dealing with low DO problems in the tidal Thames. Onexamination of the details of the Cardiff Bay system, it is difficult to findany similarity, whatever, with the tidal Thames. The main reasons for thisbeing:

a. Cardiff Bay has a completely different hydrodynamics. It is primarilyan enclosed bay compared to the tidal estuary hydrodynamics of thetidal Thames.

b. The Cardiff Bay system was primarily designed and operated toprevent stratification of water in the bay. Very little oxygen istransferred to the water from the diffusers, which are used to movewater around.

c. A CSO improvement scheme was carried out prior to theimpoundment. Some CSOs remain but the design criteria for theimprovement was to allow for only 3 spills per bathing season.

d. The DO standard that is applied to Cardiff Bay is for a minimum of5mg/l to be maintained

1.1.20 Oxygenation of the tidal Thames: Various forms of oxygenation/aeration

have been practised on the tidal Thames for over 40 years, ranging frommechanical aerators and mobile oxygenation craft, to the direct injection

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of hydrogen peroxide. There is considerable experience and expertise onthis subject within the EA and Thames Water. Delegations from all overthe world have visited London in order to gain knowledge of oxygenationtechniques on the Thames Tideway. Knowledge of the measures appliedhelps produce a thorough understanding of oxygenation and it is not a

viable or effective solution to the impact of CSO discharges.

1.1.21 The essential points to consider regarding the use of these methods relateto the nature of the river, the laws of physical chemistry and the impact ofCSO discharges on the river, each of which is explained below.

1.1.22 Physical nature of the river - The tidal nature of the River Thames resultsin the formation of relatively shallow, narrow channels at low water,particularly in the upper reaches of the river. Structures would need to beconfined to these channels, or they would be exposed at low water. Thetidal Thames is a working river and the installation of any structures on thebed of the river would be very vulnerable, especially at low water, when it

is not uncommon for craft to ground.

1.1.23 The tidal Thames is also a very silty river, and even if this is taken intoaccount in the design of a diffuser system, it would still present a veryhostile environment requiring considerable maintenance.

1.1.24 Physical chemistry - The physical chemistry that relates to the ability tooxygenate water is fairly straightforward. Two of the most relevant factorsare the time of exposure of the gas bubble to the liquid, which for adiffuser system is proportional to the depth of the water column; and thedeficit of oxygen in the water column.

1.1.25 In order to allow transfer of oxygen between the diffused air and the waterbody, there needs to be sufficient contact time. It is generally recognisedthat, for any reasonable degree of efficiency, this would require manymetres of water depth. Available depth varies throughout the RiverThames according to location and the tidal state, but there is very littledepth for much of the time in the upper reaches. It is not possible tocompensate for this lack of depth by the provision of large quantities ofdiffusers across the width of the river because of the factors mentionedabove.

1.1.26 The transfer of oxygen from a gas bubble to the water body is proportionalto the deficit of oxygen in the water body. This is the reason why oxygen,

rather than air, is used when there is a need to oxygenate rapidly,because the driving force for oxygen transfer is up to 5 times greater thanfor air. Such a fixed oxygenation system as proposed by Mr Binnie wouldbe most ineffective and impractical to implement for the tidal Thames

1.1.27 DO sags in the Thames Tideway - Depending on the nature of the rainfalland the temperature and flow in the river, DO sags can occur in differentlocations. An effective oxygenation system must be able to respondspeedily to these different conditions. When a volume of water has lowDO and a sag forms, this volume of water will move back and forth withthe tide, with a net seaward movement that varies according to river flow

and location. A common example to consider is the rapid formation of asag in the upper reaches, when DO can drop more than 6 mg/l in a single

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tide. Under these conditions, oxygen must be supplied to the shallowestreaches of the river within just a few hours. After a few tides, the sag willmove away from these reaches, but the oxygen will still be dropping. It willthen be necessary to continue to supply large quantities of oxygen to adifferent part of the river. This process will continue for many days,

possibly over a 40 km stretch of river. A diffused air system would need tobe installed for the whole of this distance, but at any one time, only asmall proportion of it would be situated in the right location to treat the sagas it moves with the tide and slowly progresses downriver.

1.1.28 Under these conditions, for any oxygenation technique to be effective, itmust be fast, efficient and mobile, or must be able to supply very largequantities of oxygen instantaneously at a fixed point. Neither of theserequirements can be met by a diffused air system and a large fleet ofboats, used only intermittently, would be inefficient.

1.1.29 Skimmer boats - It is estimated that 10,000 tonnes of sewage debris is

discharged by the CSOs every year. In addition to the sewage componentof the discharges, the CSOs are also responsible for discharging a vastquantity of general litter and debris that is washed from the streets ofLondon.

1.1.30 The sewage debris creates offensive conditions in the river and on theforeshore. In an attempt to provide some mitigation to the problem, twospecialised craft have been deployed on the tidal Thames since 2009.These craft have the ability to skim small quantities of floating materialfrom the surface of the river. In terms of the tonnage of material removedfrom the river by this method, it is of no significance compared to the

amount entering the river, but the craft do remove some of the mostvisible material at targeted and sensitive locations. It is considered thatthis method can never play a major part in removing sufficiently largequantities of the offending material from the tidal Thames, or substantiallyreduce the overall aesthetic problem.

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Documents

Response to Chris Binnie - FINAL