Life with SuDS – a view from a Lead Local Flood Authority
David Edwards, Shropshire Council
Having now recovered from the shock of the (Flood and Water Management Act 2010) Schedule 3 U-turn, I can take stock of where we are in terms of the delivery, or not, of SuDS through new development.
It has been accepted for some time in Shropshire that a reasonable level of information, regarding the management of surface water, is required as part of all development proposals. Shropshire’s Surface Water Management: Interim Guidance for Developers document caused quite a stir when it was adopted years ago, but quickly became accepted as the norm by developers. However without down playing it too much, managing surface water alone is what it has achieved and it has not gone beyond this to deliver multi-functional SuDS as a general rule.
It was always the intention to replace the interim guidance with a Local SuDS Handbook. This joint piece of work with Staffordshire was delayed, however, pending government’s decision on the SAB role and the production, by government, of regulatory guidance on SuDS. I have to say I viewed the ministerial statement, in place of the expected SAB role, as a significant obstacle to the successful delivery of SuDS as part of all new development. As a result, the ‘step change’ in the requirements for the design and laying-out of development sites has still not happened.
There is no question that development sites in Shropshire adequately manage surface water and local flood risk. However, due to the lack of this step change, drainage is still generally viewed as ‘one of the last issues to be dealt with’ and many of the other benefits that can be delivered through appropriate consideration of SuDS are near impossible to retrofit without increased cost. Cue oversized pipes, tanks, ‘bomb crater’ ponds and tweaking of levels to achieve appropriate exceedance routes.
I’m perhaps painting a doom and gloom picture of SuDS in Shropshire. It is not all bad. On some sites we have been able to achieve early dialogue with developers in order to deliver elements of the SuDS management train. Benefits to water quality and biodiversity have been the result, with more schemes in the pipeline, so to speak.
The previously named Shropshire and Staffordshire SuDS Handbook has now been expanded to cover the areas of an additional seven LLFAs and will be known as the Local SuDS Handbook in each area. This will give greater certainty to regional developers on what is to be required and when it should be considered and demonstrated. In Shropshire, the handbook will underpin the requirements of the relevant local planning policies and so will give more clout when it comes to objecting to planning applications which are lacking, SuDS consideration wise. Upon adoption of the handbook there will, no doubt, be many objections from the LLFA in its consultee role.
Of course, the handbook will also assist with the elephant in the room that is the security of long term SuDS maintenance. Whilst it has been possible, on a small handful of sites, to adopt SuDS features as demonstrators, the wholesale adoption of SuDS under the current legislative framework is not an option and is highly unlikely to be any time soon. We will, therefore, continue to work with developer’s management companies and hope for the best.
So, although the severe watering down of the national approach to SuDS delivery has set us back I hope that, once in place, the Local SuDS Handbook will bring about the step change to the order of development that is needed and result in the consideration of SuDS from the outset. Moving on, I’d like to think that in 5 years’ time I will look back on the adoption of the Local SuDS Handbook as I do now on the moment that our Interim Guidance document was put in place. We have a few sites that we can use as case studies and I hope that as word gets round that we are serious about SuDS more developers will start to consider them as a matter of course.