Climate committee chair warns of ‘ineffectual’ SuDS policy

SuDS scheme on a housing development

Professor Lord Krebs, chair of the Committee on Climate Change’s sub-committee on adaptation has warned of the risk of an “ineffectual policy” on sustainable drainage systems (SuDS) being introduced in April 2015. A requirement for SuDS is set to be brought in for all developments of 10 properties or more.

In a letter to the Secretary of State for the Environment, Liz Truss, on the proposed changes to the planning system to increase the use SuDS, Lord Krebs makes three key recommendations for improving the policy:

  1. Withdraw the automatic right to connect to connect new developments to public sewers
    Professor Krebs writes, “Developers retain the automatic right to connect new homes to the sewers regardless of their capacity, six years after the Pitt Review recommended it be removed. Whilst this remains developers are likely to want to exercise it. Removing the right, or making it qualified or conditional will be important to tip the balance in favour of more sustainable approaches.”
  1. Make Lead Local Flood Authorities (LLFAs) and water companies statutory consultees
    Professor Krebs writes, “My committee supports in principle the proposal that LLFA’s become statutory consultees on the new development in relation to surface water management. This should provide planning officers with the technical advice they need to properly scrutinise applications from a surface water planning perspective, assuming LLFAs will be appropriately funded for this role. However, it is arguably more important that water and wastewater companies are consulted on applications where surface water may be an issue. We understand that your preference here is to amend planning guidance to recommend that the local planning authority invite water companies to comment. Subject to costs and benefits there may be a case to strengthen this, so that water and wastewater companies have a duty to consider the drainage implications of a new development.”
  1. Collect the data needed to monitor and evaluate the policy
    Professor Krebs writes, “At present there is no ongoing monitoring of the uptake of SuDS in new development. This will make it difficult to assess whether your proposal is having the desired impact. Alongside introducing the new regime in April, you should set out how the uptake of SuDS will be assessed and what additional steps should be taken if deployment remains low.”

He adds: “It will also be important to monitor the effectiveness of SuDS in managing run-off and to assess the proportion of surface water which is being managed through these schemes. This would allow you to reconsider your decision to exempt minor development, should the evidence suggest it necessary.”

Professor Lord Krebs concludes: “Without these steps there is a risk that an ineffectual policy is introduced without the ability to detect its impact, nor sufficient evidence to justify a stronger intervention should it be required.”

Managing vulnerability to surface water flooding will be a key part of the Committee on Climate Change Adaptation sub-committee’s report to Parliament in June 2015.

Read the full letter…


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