15 Jan 2014
SuDS Delays: Have We Lost Sight of our Founding Principles?
It seems almost unbelievable. Yet another SuDS delay. Six years after 2007 floods that prompted ‘urgent action’ and right in the midst of more severe storms and floods, the Government has confirmed it will not meet its target of implementing SuDS regulations in England and Wales. Furthermore we are still no clearer as to when – or possibly even if – we will have new National Standards.
Environment Minister Dan Rogerson was at pains to stress in parliament (see Hansard 6/1/13) that he remains committed to introducing the legislation ‘at the earliest opportunity’. However according to an article over the weekend by the BBC’s Roger Harrabin, the Government is ‘in turmoil’, even suggesting that the proposals are ‘postponed indefinitely’.
Yet more uncertainty will cause frustration first for local authorities needing to fund and staff the SuDS Approving Bodies getting ready to implement the new rules. But it’s also a concern for everyone in the industry when these regulations have been subject to so many delays.
Rogerson stated: “..we are working with developers and local government to develop the processes, standards and guidance that are an integral part of a new SUDS approvals and adoption regime, rather than just imposing them. That takes time, but it is time well spent if the end result is an approach that is fair to all parties and successful from the outset because local government and developers are fully prepared to take on their respective new responsibilities.”
It’s true that Defra has been working hard to consult with all stakeholders to find satisfactory agreement on the detail of National Standards and accompanying design guidance. I have been a member in the “Task and Finish” groups set up to facilitate the consultation.
Recent press coverage suggests that housebuilders and developers are worried about the costs of space-hungry above-ground ‘natural’ features such as ponds, wetlands and swales. There are also questions surrounding the proper funding for local authorities to maintain SuDS effectively.
Why is it that these issues should catch the interest of the media now? Surely they have been recognised in our industry from the start? Housebuilders have been putting in perfectly good SuDS schemes for the past 10 years or more.
So what has changed? I have been involved in promoting and lobbying for SuDS for more than 30 years. I believe a significant contributory factor has to be the way in which the definition and interpretation of SuDS has shifted over the years.
The key principles of SuDS are to mimic natural drainage paths and processes and to deal with rainwater at source. The SuDS ‘triangle’ of Quantity, Quality and Amenity is a good guide, but not each of the three elements is achieved in every case, depending on the site conditions.
There is a desperate need to build more housing in the UK at the moment. I know from speaking to many housebuilders that the requirement for ‘amenity’ and for ‘green’ features presents in some cases the need to give up space that could otherwise be used for development. However, there are exemplary housing schemes – including those on this website – that have shown it is possible to achieve excellence, often by combining natural and manufactured features.
We simply have to go back to these first principles and get real about SuDS. We must accept that one of the first aims of sustainable surface water management is to treat pollution whilst stopping surface water being conveyed large distances via combined sewers and ending up at wastewater treatment works. This may not necessarily always mean above ground features.
Yes, let us aim for amenity value where possible, but if not commercially viable, then let us accept that good compromises can be reached by using the full SuDS toolbox – using both natural and proprietary features to meet SuDS principles. Innovative technologies – many developed and well-proven by UK companies – are available to reduce the amount of space needed for surface water drainage features, whilst still providing at-source attenuation/infiltration and treatment. Developing such solutions could also be more appropriate for encouraging water re-use and recycling.
A more pragmatic approach is simply going to be essential if we are to achieve the widespread retrofitting of more sustainable drainage features.
Remember, the new legislation applies only in England and Wales. The rules in Scotland have been in place for many years. The recent Engineering Nature’s Way survey in Scotland provides some valuable experiences for the rest of the UK to learn from, especially in terms of engineering choices available and the need to be clear on future maintenance regimes. For more information read the story and download the report.