10Feb 2017

A place for SuDS?

Laura Grant, CIWEM

More homes and businesses are at risk from surface water flooding than from any other kind of flood and the problem is increasing with growing urbanisation and development. The Government’s own risk assessment presented compelling evidence that climate change is likely to lead to increases in heavy rainfall and significantly increase the risks from fluvial and surface water flooding by mid-century.


It is right that then, that as we look to significantly increase our housing stock, we consider if it will be resilient for years to come. It’s been two years since planning policies on sustainable drainage systems (SuDS) were changed and data on the effectiveness is sparse: There is no requirement for local authorities to report on SuDS uptake, nor monitor whether they are actually implemented or effective.


Following the Lords’ valiant efforts at seeking amendments to the Housing and Planning Act last year, there is now a requirement for the Secretary of State to carry out a review of planning legislation and planning policies for sustainable drainage in England this year.


In anticipation of this review, CIWEM and a range of partners decided to get together the evidence from professionals across the sector. Last summer we launched the Big SuDS Survey and the request was disseminated widely by a range of professional bodies. The survey generated almost 540 responses, which is believed to be the largest independent survey on SuDS in the UK to date.


We have uncovered compelling evidence that suggests action is needed to address some real problems on SuDS and surface water management:


  • 70% think current planning policy does not sufficiently encourage SuDS
  • 75% are not assessing the costs and benefits of SuDS schemes
  • 75% considered that planning authorities did not have adequate in-house expertise to consider the merits of proposals and opt-out applications
  • Only 8% think the current standards are driving high quality SuDS


Thursday 2 February CIWEM launched its latest report on sustainable drainage, reviewing the findings of the survey, at an event in the House of Lords. Members from each of the main political parties, including the Shadow Housing Minister, spoke passionately on the subject of SuDS and in support of the report’s recommendations.


The report called A place for SuDS? concludes that the main barriers to widespread SuDS uptake in England are not from cost or practicality but from policy and institutional barriers.


But we are trying to be realistic. We know the government doesn’t want to remove the automatic right to connect and we know that the government is rightly concerned about the pace and scale of house building required.


We’re not asking for reams of regulation: sorting SuDS doesn’t need to delay house-building. What’s needed is clarity on some key fundamentals.


The survey reveals a clear call for national consistency in approach. So we would like to see:


  • Policy strengthened so that discharge to the sewer system is conditional on the inclusion first of high-quality SuDS in new developments
  • To support this, we would like to see updated standards—with more consideration of the wider benefits of SuDS—amenity, biodiversity and water quality (the Welsh national standards are a good example of this)
  • But the number one priority is for a clear decision to be taken in relation to adoption and funding maintenance. Any SuDS adopting body should have a clear mechanism for raising funds to ensure their continued effective maintenance and eventual replacement


In its review, the government should also look to learn from the devolved administrations. We have outlined the different approaches in our report:  Wales has much broader standards and is looking again at enacting Schedule 3 (of the Flood and Water Management Act); Northern Ireland has ended the automatic right for new development to connect to the sewer and Scotland has had SuDS as a general requirement for some time. So England really is lagging behind.


And finally, it is not enough to just look at new developments, we need the government to look seriously at how we can retrofit SuDS into existing developments too. After all, it is in our existing streets that most people live and work, where most surface water flooding occurs and where water quality, amenity and biodiversity improvement is equally important.


What we really need is not a box ticking exercise. We want a real review that will consider updating policy and standards to ensure that everyone can benefit from the protection and amenity offered by SuDS.


CIWEM is not alone in calling for this, our findings and recommendations are supported by organisations from across the sector: the Wildfowl and Wetlands Trust (WWT), Institution of Civil Engineers (ICE), Royal Town Planning Institute (RTPI), Royal Institute of British Architects (RIBA), Institution of Environmental Sciences (IES), Landscape Institute, University of Exeter Centre for Water Systems, Susdrain, Future Water Association, Association of Drainage Authorities (ADA), Cornwall Community Flood Forum, the Construction Industry Council Champion for Flood Mitigation and Resilience, Royal Society for the Protection of Birds (RSPB), WWF, the Angling Trust, Buglife and Salmon and Trout Conservation UK.


Together we represent over a million members.


The report can be read in full at

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