Putting Pitt in the past – delivering SuDS
Richard Ashley, Ecofutures
As a member of the Foresight Future Flooding expert team and an adviser for the Pitt review following the 2007 floods, I have a unique perspective on tracking what has happened since flood impacts became a major topic of interest in the UK. Subsequent clarification of the causes of the 2007 floods have revealed that much of the flooding was not due to local urban drainage incapacity, but the inability of water to get into the main watercourses – managing or slowing this discharge through sustainable drainage would have undoubtedly helped. Now we know that flooding as an issue is not about where will it flood? Rather it is about when will it flood and how often? We can only be sure that for many places there will be water on the streets and in public places at least once in, as a minimum 10-20 years.
Pitt’s recommendation No.9 recommended the control of paved surfaces. Defra in their response suggested that the Water White paper set out the UK Government’s intentions for the retrofit of SuDS in England, encouraging the disconnection of downpipes, use of rain gardens and the replacement of traditional paving with permeable paving. While the Water White Paper touched on this and the need for an integrated approach to water management, the draft Water Bill, has been too focused on pseudo-competition, which will have exactly the opposite effect of delivery of water related services with greater fragmentation reducing the potential to manage the impacts of urbanisation.
‘Implementing the Pitt recommendations’ has been something of a mantra for both the coalition and the previous administration. Neither have managed it, although the Brown government did introduce the Flood and Water Management Act in 2010. Since coming to power the coalition has back-pedalled on some of the most important and far-reaching elements of Pitt and in fully implementing the Act. In particular government has dithered as regards allocating the responsibility for SuDS promoted by Pitt. With the supposed implementation date for National Standards for sustainable drainage and the associated SuDS Approval Bodies (SABs) to be functioning in unitary or county local authorities and implementation of Schedule 3 of the Act, now deferred again until 2014 (disconcertingly close to an election year). The stakeholder-led Defra SuDS advisory group appears unduly influenced by housebuilders and others, who would wish to maintain our reliance on piped drainage systems because of a misguided belief that alternatives are more expensive, despite the evident added-value and wide range of extra benefits from using SuDS instead. Admittedly, these cost reductions and multiple benefits require early consultation and innovative design – but it is possible.
A cultural change is needed to understand and accept that flooding needs to be managed and directed to places where there are the least impacts, like recreation areas, parks and even roads where necessary in order to protect people and property.
Despite my exhortations to Sir Michael Pitt in 2007 that urban water was about more than flooding; it is about water quality and also supply, the recognition that the water cycle needs to be managed as a whole is following a year of perverse weather now just beginning to become an idea in the media. The Pitt review presaged the Flood & Water Management Act’s touching belief in SuDS as a key tool in local flood risk management, yet in the more enlightened world away from England, the wider water quality improvements and aesthetic biodiversity and urban design qualities that can be enhanced using SuDS are seen to be more important than this.
Changes to planning policy in England, aimed at deregulation in the National Planning Policy Framework (NPPF), have retained significant elements of the earlier PPS25 (on Development and flood risk), aimed at limiting development on flood plains, although ambiguities related to poorly defined ‘sustainability’, and ‘growth’ mean that the NPPF as a whole is unlikely to promote true sustainable development. In addition to the new roles and responsibilities introduced by the Flood and Water Management Act and Flood Risk Regulations Local Authorities have other challenges not yet being faced, in relation to the Water Framework Directive, where water quality is the main interest and their revitalised Public Health duties under the Health and Social Care Act 2012. The poor quality of the first generation of River Basin Management Plans (with poor engagement and consultation) only served to confuse everyone as to what needed to be done to manage drainage systems better to clean up water bodies to the required standards. It’s also worth not forgetting that the Water Framework Directive is not only focussed on water quality. There is also strong reference to water resource availability – which even in 2012’s abysmal weather is relevant with around 20,000 homes imposed with a hosepipe ban in last year’s Spring. Let’s hope this isn’t forgotten in the clamour for compliance.
A way forward?
SuDS and associated with this, green infrastructure can go a long way to delivering water quantity, quality, amenity and enhance urban liveability and health all at the same time.
According to Defra’s 2012 final report on delivery of Pitt, some 43 of the 92 recommendations have been implemented, with 40 implemented and ongoing, 6 on track for completion by specified dates and only 1 not completely implemented and the two others not being taken forward or not being Government’s duty. These figures are contested by various commentators, and in any case with funding cuts and the impending major reorganisation of the Environment Agency capacity for implementation has been severely constrained.
Responding to Pitt
The Pitt recommendations now need to be seen within a much wider context than simply how dealing with flooding was considered in 2008. For a start, even the populist media have begun to recognise that floods and droughts are two-sides of a single hydrological phenomenon. This was dismissed when I raised it with Pitt inquiry in 2008. 2012 demonstrated that both floods and droughts need to be considered together as part of an integrated approach to the water cycle; in a process the Australians call ‘water sensitive urban design’ (WSUD). All forms of water are potential resources either for supply or for other uses. WSUD allows for better urban design as part of water management, multi-functional land use and the opportunity for promoting and using ecosystem services (the role of WSUD has been explored as part of a project I’m chairing for CIRIA). All of these are now considered relevant by Defra in the way in which flood risk schemes are assessed as part of the sensible new arrangements for local community partnerships for funding schemes, contributing to local authority responsibilities to create sustainable communities. However, support to develop the appropriate engagement capacity in communities is required if this is to be effective. Could the Catchment Management approach be the vehicle? Support is also needed to ensure that the professionals who engage with communities for this also do it in the right way and with the correct motives. However, it’s encouraging to see synergies between the delivery of green infrastructure, sustainable drainage and better places within urban areas being exploited by Third Sector community organisations like Sustrans and Groundwork that actively involve the community in the process.
In England, the enduring focus on flood risk has obscured the need to manage runoff and water in an integrated way. This is notable in the lack of interest by many in the need to improve the quality of the runoff before it enters a receiving watercourse. Everywhere else in the world apart from England understands that surface water management systems such as SuDS are major elements in improving water body health and in improving public health and well-being. Yet The lack of relevant investment in UK science in this area and contradictory reliance on evidence means that convincing some of the more sceptical (yet powerful) stakeholders is taking longer than desired.
Cause for celebration or concern?
Despite concerns expressed in the recent SuDS: The State of the Nation survey report (around uncertainty, resources, skills and timing) it’s not all doom and gloom. It is encouraging to see some local authorities like Essex, Cambridge, Hertfordshire and London boroughs like Lambeth and Islington positively respond to local flood risk and the opportunities for SuDS delivery by developing interim guidance and pushing ahead with delivering innovative schemes. However, this is despite any regulation or legislation not because or supported by it. These authorities recognise the drivers and benefits. Let’s hope this common sense approach develops a momentum that we can celebrate and develops and evidence base to support mainstreaming sustainable drainage.
The real challenge lies in retrofitting sustainable drainage and this was never on the government’s agenda before ideals of “sustainable growth” and “de-regulation” invaded the consciousness of decision and policy makers in central government. Those local authorities developing local SuDS guidance and delivering projects on the ground need to be supported and championed and maybe localism in whatever guise will deliver the great schemes and multiple benefits some of us are screaming out for.
Supporting this ‘bang for buck’ belief Defra has introduced a strategy for co-funding of Flood Risk Management measures that requires communities to share in the costs. This new strategy sensibly recognizes the wide range of benefits beyond simply FRM alone (eg water quality, biodiversity, recreation etc). Recent reinforcement of local authorities’ role in regard to public health, the Health and Social Care Act 2012, show that many of the reinvigorated responsibilities can chime with contemporary ideas for managing water within urban areas for multi-value purposes.
Looking to the future, not only do government need to recognise the need to change their own culture, a cultural change must also be recognised by professionals and others working with water, flooding, green and grey infrastructure as well as our natural and urban environments. To deliver affordable outcomes that maximise the many values of water, a cross-disciplinary and cross-departmental approach needs to be taken, aimed at getting the best value from public and private monies. However, government appears to be more interested in ‘sustainable growth’ via fragmentation – an inevitable contradiction. Where other countries believe that sustainability and green growth are consistent and synergistic with improving approaches to managing water in our urban environments.
SuDS deliver multiple benefits and are arguably more cost effective than traditional drainage approaches. Sustainable drainage and better places to live are consistent with sustainable growth. We need to have a government with the courage of its convictions…