8 Jul 2013
Defra have clearly indicated that schedule 3 will be implemented in April 2014 and as promised there will be six months notice. The language initially used was “we will” however the language has started to change to “we aim”. Within the Defra’s response to the EFRA Parliamentary Group the phrase “…” was used six times, so what are we to make of this will it wont it?
There are Local Authority colleagues who are dedicating and committing a lot of their time and resource in helping Defra determine the in’s and out’s of the detail of what as SAB’s local authorities will be implementing, requesting, enforcing, charging, approving, rejecting amongst the day to day pressures of work with politicians, residents, businesses raising questions, seeking clarification. Alongside Local Authority representatives there are NGO’s, consultants, designers, producers, fabricators all large and small who it can be argued some have a vested interest in getting something in as soon as possible, though they realise how important it is to get this right to ensure a sustainable and world leading industry.
It is well documented that there are authorities in England who are and have been for some years doing what schedule 3 will require, with what seems to be from the outside very few issues and a generally accepted level of what is required and expected.
As a family we are shortly moving out of London, we have now for some time been traipsing to lots of different developments across the south east and east of England. Of all the developments I was “encouraged” to visit 99% of them had SuDS within the envelope of the development, in fact the house we are moving to is on one of the very few developments which didn’t have visible SuDS, though as it turns out all surface water is disposed of via soak-aways. When I have questioned the developers as to why they have included SuDS, expecting a response of “because we have to” or “the Local authority insisted, don’t know why” I have found their response to be almost a why not approach, I have to accept that there is obviously a level of the local authority or Environment Agency requesting the SuDS, but the message I have been getting is one of this is what we do, not what we have to do.
From a Lambeth perspective I have to admit it is a little hit and miss though I have had some very positive conversations with developers around the implementation of SuDS. There have been some pre-applications where SuDS have been incorporated from the outset, the cynic in me says that this is only lip service and it is almost the fashionable thing to do. There is an example of what appears to be a management train with three treatment stages, though when the detail is examined it seems it is only cosmetic. So should I be demanding more, should I be demanding they comply to x, y, z, or should I be pragmatic and take the view SuDS are being considered and it’s a step in the right direction? I am torn, though what is important it is becoming part of the language of developments and is not a dirty word.
So what is the point of this blog? What am I getting at? My view is that the Local Authority colleagues who are working so hard should be rewarded for their commitment, time and effort, with Defra not pushing for target dates which may not be sensibly achievable with the risk of such high quality work being sacrificed for either political gain or watered down to appease a minority. We should not end up with “powers”, guidance and processes which in the long run will neither deliver the benefits which are without question needed or the required designs to effectively manage this problem which we cant wish away, it’s here and we have to deal with it.
SuDS are being delivered across the UK, within developments, within the public realm and all being done so without any major issues, concerns or problems. SuDS are being constructed they are being maintained we are not dealing with something new or unexpected, but for all to move forward can we please ensure it is something we can all work to, and as the Flood and Water management Act would like us to, in partnership with the onus being on delivering solutions which protect the most vulnerable in society and importantly protect the communities we all work and live in.