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Government Sustainable Drainage (SuDS) Review published (finally!)

Government Sustainable Drainage (SuDS) Review published (finally!)

23rd August 2018

The Government have issued a report on the use of sustainable drainage systems (SuDS) in new developments: there more and better quality SuDS, but maintenance and monitoring remain concerns. 

The report examines how national planning policies for sustainable drainage systems are reflected in local plans and the uptake of these systems across a range of housing and commercial developments in England. The report has been long-awaited by many in the sector after being started in 2016, but the publication had been delayed by the ministerial changes in MHCLG. The main recommendations from the SuDS review were:

  • There needs to be improved knowledge and understanding of SuDS, particularly for developers to appreciate the multiple benefits of SuDS. Understanding among small locally-based developers was of particular concern.
  • More certainty needed for adoption of SuDS maintenance measures (revised NPPF says that a decision should be taken to make someone responsible for maintenance).
  • SuDS should be prioritised for all developments, unless there are clear reasons not to do so (as in the new revised NPPF).

Sustainable drainage (SuDS) for new housing developments was one of the main features on WSBF's Bricks & Water report. Recommendation 5 was 'green infrastructure, not concrete infrastructure'. We also showed how LPAs and LLFAs are struggling in some areas to ensure that high quality SuDS are included in new developments, and suggested that whilst the local council were best placed to adopt the maintenance of SuDS feature, where they were unable or unwilling to take on this responsibility it should fall to the local water and sewerage company. This arrangement received near-universal approval from those we consulted.  

National planning policy for SuDS was strengthened in April 2015 to make SuDS a requirement in all new major developments. The recently published new National Planning Policy Framework (NPPF) sets out the policy approach for preventing inappropriate development in areas at risk of flooding. The NPPF expects local planning authorities, when determining planning applications, to ensure that sustainable drainage is prioritised in areas at risk of flooding, conserve and enhance biodiversity, and, adopt strategies to mitigate and adapt to climate change.

Main highlights from the report:

SuDS survey of local plans

  • 80% of local plans (90% of emerging contained polices that SuDS should be prioritised in areas at risk of flooding)
  • 81% of local plans (90% adopted) stated that SuDS are to be provided in all new developments. 
  • Only 33% (60% emerging) have clear arrangements for adoption and long term SuDS maintenance
  • 70% (75% emerging) plans do not have a monitoring or reporting system for SuDS deployment. 

Almost all LPAs stated that they do not monitor the uptake of SuDS, citing resource implications. Management companies were generally favoured by developers for maintenance, though one third of LPA officials were unsure of the extent to which SuDS were adopted as agreed but no one could give an example of where a SuDS system had failed. MHCLG found no evidence that adoption by management companies is problematic.

How prevalent are SuDS?

SuDS uptake is high and increasing: 87% of applications featured SuDS, and most of the rest were ‘often described in such a way that could be interpreted as sustainable.’ 70% of these had unclear adoption protocols for SuDS maintenance.

A broad range of SuDS technologies and features were found to have been proposed across those planning applications analysed. These included ponds and attenuation basins, green roofs, permeable paving, tanks, swales and soakaways and frequently involved combinations of one or more of these components. Under half of LPAs detailed which SuDS components were deemed acceptable, but underground storage tanks and other engineered solutions were viewed unfavourably by the LPA.

Only 5% of major developments and 10% of developments in flood risk areas explicitly excluded SuDS. LPAs said that the reasons (land-take and not economical) cited by developers against SuDS inclusion were not justified.

Do local authorities collaborate?

60% of LPAs collaborate with their neighbours on SuDS and flooding-related guidance. Only 50% also collaborate with the LLFA. Half also collaborated with the local water and sewerage company on flood risk or drainage.

Only one quarter of LLFAs thought that applicants had a good understanding of SuDS policies, with many concerned about the lack of detail in applications. Generally, no formal mechanisms appeared to exist to monitor the extent to which the PLA followed LLFA advice.

Budgets stretched

Over 40% of LLFAs suggested that their time, expertise and resources were under pressure with regard to assessing planning applications.

Removing the right to connect?

MHCLG found that the right to connect was not a key determinant of whether SuDS features featured in development proposals.

Read full report: MHCLG