Welsh Government consultation on Sustainable Drainage Systems (SuDS)

Awaiting the outcome from the Welsh Governments consultation on its proposed interim non-statutory standards for Sustainable Drainage Systems (SuDS).

In early February 2015, the Welsh Government launched a consultation for interim non-statutory standards for sustainable urban drainage (SuDS) – designing, constructing, operating and maintaining surface water drainage systems. The consultation document seeks views on these proposed interim non-statutory standards for SuDS in Wales which commenced on 12/02/2015 and ended on 30/04/2015.  The Flood and Water Management Act 2010 (Schedule 3) which has not been commenced, requires new developments to include SuDS features that comply with national standards. In the absence of these standards, the Welsh Government is proposing interim standards on an advisory basis until it determines the most effective way to implement SuDS principles in new developments in the longer term.

This will enable designers, property developers, local authorities and other interested parties to both demonstrate that they have taken account of the Welsh Government’s planning advice on Development and Flood Risk and to pilot the standards, so that if necessary they can be revised before being placed on a statutory footing.

Proper maintenance of SuDS is vital to ensure that they function effectively over their design life. As such, adoption and management arrangements between local and sewerage authorities is essential during the planning stage. The interim standards will enable designers, property developers, local authorities, and other interested parties to pilot the standards, so that they can be revised before reaching statutory status.

This contrasts with the approach being taken in England, where SuDS will be implemented by local authorities through the planning system.

However the Welsh Government has struck a nerve with UK water management practitioners by elevating storing rainwater for later re-use as its number one defence against flooding, in its consultation on a proposed non-mandatory new SuDS standard for Wales.

This is a particularly far-sighted approach for a relatively high rainfall and low population density region, which compares starkly with the equivalent SuDS approach being pursued in England where harvesting rainwater as a way of addressing flood risks does not feature as a recommended approach at all.  Given the stresses on water supplies throughout much of England south of the Humber, particularly in low rainfall, high population density regions such as the South-East, this oversight borders on the perverse.

A possible explanation (the official reason given of “different priorities”, being somewhat vague), lies in the Welsh policy being the responsibility of the Department of Natural Resources which takes into account all aspects of managing rainfall, seeking to avoid both future floods and droughts, whilst meeting the water-related needs of people and the environment. In short, water is viewed as a valuable natural resource to be managed accordingly.

In a written response given by Natural Resources Wales they welcome the decision to propose interim non-statutory standards for SuDS in Wales prior to the commencement of Schedule 3 of the Flood and Water Management Act (2010). They believe this approach will allow all relevant stakeholders to test the interim nonstatutory standards where reasonably practicable, and help develop a more consistent approach to SuDS delivery across Wales hoping it will pave the way for subsequent implementation of statutory standards for SuDS in Wales.

In contrast, in England, no single agency or department of Government performs similar integrated oversight, with responsibilities being distributed across the Environment Agency, DEFRA and DECC, with DCLG balancing-off environment-based advice against, for example, the advice of the housebuilding industry.  Even within a given organisation, teams are likely to be organised on a silo-management basis, with the ‘flood team’ having no responsibility for ‘droughts’, and vice-versa.

Industry opinion:

Against this background, the results of a recent surface water management survey make interesting, possibly instructive, reading. Undertaken by the UK Sustainable Development Association, at the request of the Surface Water Management Committee of the WATEF initiative, a briefing note on rainwater management issues was sent to more than 1,000 practitioners, who were invited to submit their views via an online survey engine. Of those approached, 84 responded by the time the survey was closed, providing opinions from across a wide spectrum of roles and responsibilities.

The key conclusions to be reached from the survey would need to reflect that more than 97% of respondents were of the opinion that management of surface water needs to embrace more than simply ‘SuDS’, by taking into account both urban and rural sources of flood water, along with stresses on water supplies and other important environmental factors.

A similarly high proportion of respondents (95%) allied the above view with the need to take a strategic perspective that takes into account water-related conditions over 30 or more years, where 94% of inputs recognised that flood and drought risks are likely to be greater than now.

This in turn highlights the need to act incrementally now, by making affordable investment over strategic timescales, to build the capacity required to respond to future increased flood and drought risks. 72% of respondents are already taking this personally into account when making investment decisions. Less reassuringly, however, only 50% believed their organisation was doing likewise, a shortcoming attributed by a similar percentage to the way in which these future risks are currently being presented.

The solution to meeting future surface water management challenges was judged by over 90% of respondents to lie in taking the more integrated approach, currently exemplified in the UK only by the Welsh Government. This conclusion is reflected by respondents who collectively rated addressing this issue their top priority.

This was closely followed by the need to be more strategic in water-related planning, coupled with the need for management of surface water to extend beyond SuDS, to encompass both urban and rural settings, whilst also taking into account dealing with flood risks, stresses on water supplies and other important environmental factors.

Additional priorities:

Priorities beyond that included the need to build incrementally the capacity required to reduce future risks of floods and droughts, coupled with inclusion in national (English!) thinking of water re-use as a cost-effective tool for tackling both. Taking the EU ‘river basin’ approach to inland water management was also considered important, being placed on average joint 5th on the list of eight issues presented to the survey respondents.

Meanwhile, possibly the most difficult issue to tackle is establishing the right administrative framework for managing surface water, amidst the plethora of valid stakeholders ranging from Government, all the way down to individual home-owners at risk of flooding, and farmers at risk of droughts.

Open to debate is whether the remit of the new Flood Risk Management Authorities should therefore be broadened to include all aspects of surface water management.

Unda’s view:

Often than not, one of the biggest fears faced by local residents when a new development is proposed is the issue of increased surface water flooding.  UK standards that recognize that re-using water on site is a brilliant way of managing storm water problems from new developments.  Congratulations to the Welsh Government and its policy writers for pulling in best practice experience from the early adopters. Incorporating on-site rainwater reuse will see our drainage networks continue to cope against threats such as urban creep, population increase and intense rainfall events in the years ahead. Rainwater harvesting represents a real dual-benefit opportunity to reduce drought whilst increasing the resilience of ou  r drainage networks. It’s benefits have been widely recognized abroad: in Germany (100k systems installed in a single year) and Australia (30% of Melbourne households have rainwater harvesting).

Unda has recently learnt the Welsh Government are currently reviewing the detailed responses they received to the consultation on the draft standards with a view to publishing the outcome in October/November this year.

Background notes:

The SuDS approach to surface water drainage provides an alternative to conventional, piped drainage. It typically uses combinations of installations such as permeable paving, soakaways, green roofs, swales and ponds and can be used effectively in both rural and urban areas to support new development.

This approach can slow down the flow of water, contributing to a reduction in flood risk and protecting water quality. Reduced runoff to sewers provides additional capacity without expensive engineering work, whilst more natural systems improve water quality and the environment.

UK Rainwater Management Association:

The UK Rainwater Management Association brings together the interests of the many private-sector businesses, public-sector authorities and agencies, water utility companies, and the many other organisations engaged in avoiding future floods and droughts.

Welsh Government consultation on Sustainable Drainage Systems (SuDS)