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Industry Knowledge Alex Stephenson,

Alex has over 36 years experience in stormwater drainage design and related issues.

As well as being the UK Stormwater Director with Hydro International he is also Chairman of the SuDS focus group. He is ideally situated to keep you up to date with the industry changes and legislation.

National SuDS Standards “Could be Compromised”

“As you may well be aware, the Government are carrying out a consultation on the National Standards for Sustainable Drainage Systems, which are designed to provide a structure for the new SuDS Approving Bodies (SABs) to make judgements on the acceptability of drainage schemes for developments and redevelopments.

The considerable delay in the publication of this consultation has already put the Lead Local Flood Authorities (LLFAs) on the back foot.

It looks highly unlikely that the SAB roles will come into force as the Government originally intended in April 2012. Instead it will be October – or possibly even later, depending on the preparedness of the LLFAs for the task. Let’s not forget, the standards only apply to new development. There’s even more work to be done to move towards greater retrofitting of SuDS in our urban environments.

The National Audit Office already highlighted concerns about the readiness of local authorities in recruiting and skilling-up staff for their new roles back in October. My impression is that only about a third of LLFAs have the people they need in post so far.

While some leading lights have made excellent progress, others have been adopting a ‘wait and see’ approach. Local authorities are expressing concerns that the delay has made it difficult, if not impossible, to get agreed funding for posts in their budgets in enough time, without a definite start date.

There will

also be no ‘up front’ loading of the central Government funding promised to help get SABs underway, so any LLFAs that choose to recruit early will have to foot the bill in difficult economic times.

To do their job, the standards must drive through consistent sustainable outcomes across the land, but with such a varying picture ‘on the ground’, there is real cause for concern.

The proposal for exemptions from the standards on the grounds of “disproportionate cost” is a particular worry. The draft standards propose that ‘full compliance’ with the standards is not required where the SuDS design would be more expensive than a ‘conventional design’. But what exactly constitutes a conventional design? Experience shows that perceptions of SuDS can get very muddled.

By applying SuDS principles – as outlined in the standards - and the full toolbox of SuDS techniques, there should be very few schemes that would fall through the net, and any such schemes should be seen as the very rare exception, rather than the rule. If this clause really does deliver a ‘get out of SuDS free card’ for ill- informed developers – or even local authorities – it could compromise the whole spirit of the Act.

Proposals to enable the local planning authority to impose ‘more stringent’ requirements also raise more questions than answers, and the liberal sprinkling of ‘where practicables’ provides opportunities for caveats that we must be careful of.

To achieve their objectives, I hope the standards will show that a mix of SuDS components, natural - or used in combination with proprietary systems - can achieve the principles and requirements of the standards.

This is the

principle of Engineering Nature’s Way, which I believe offers a practical, achievable and clearly-understandable way forward.”

(see article on page 12 for more information on SuDS)

Contact Alex by:

email: Telphone: 01275 878371

“Underinvestment in flood infrastructure is unacceptable”

The Chartered Institution of Water and Environmental Management (CIWEM) believes that significant levels of underinvestment in flood infrastructure as identified by the Public Accounts Committee is unacceptable even in the current economic climate.

CIWEM welcomes the report of the Public Accounts Committee, which identifies significant underinvestment in flood risk management infrastructure. The burden borne by householders and businesses exposed to flood risk can be devastating. The risk and uncertainty generated in the minds of those who live and work in areas identified as being at risk of flooding reduces their feeling of well being and restricts their potential for growth.

Public investment in infrastructure must deliver broader benefits such that flood risk management schemes reduce the risk, enhance the environment and encourage growth. The expectation that funding for such schemes should come from a range of public and private stakeholders is appropriate but there are no single beneficiaries from such schemes and the concept of “the beneficiary pays” is not valid when, as is usual, schemes benefit the wider community. Funding generated from stakeholders should be used to increase the available budget rather than replace reduced funding provided by the Treasury. The suggestion that the funding mechanism recently introduced is “fairer” cannot be sustained when two equally valid schemes are prioritised only on their ability to generate third party income.

The concerns about ongoing flood risk at unacceptable levels are shared by the ABI and their report suggests that the areas identified at greatest risk by the Environment Agency are likely to find the level of premiums to insure against flood risk will become unaffordable, even if cover is available which will not be guaranteed beyond 2013. Where uninsured communities are affected it is often the local authorities who provide the response to flooding and subsequently reclaim their expenditure from the Treasury.

The opportunity to significantly enhance the environment adjacent to our rivers, lakes and coastline is there with clear legislative drivers, the Water Framework Directive, together with specific funding. Flood risk management schemes provide a vehicle to deliver those enhancements but can only be successful with the appropriate level of government funding. The Public Accounts Committee report indicates how the current levels are insufficient.

CIWEM Executive Director, Nick Reeves OBE, says:

“Budget cuts are part and parcel of all walks of life at present, but there are some areas which must be better protected. The report by the Public Accounts Committee highlights one such area where householders and businesses are being put at unacceptable risk through no fault of their own, because funding for flood defences is being cut. At the same time, the National Planning Policy Framework risks loosening restrictions within PPS25 on new development in flood plains, potentially putting even more people at risk of the often devastating life impacts of flooding. For such people to then be put in the position to potentially have to compete for private sector funding to protect their properties and businesses, and at the same time face the prospect of being unable to afford insurance verges on immoral, particularly when climate change threatens to bring increasingly extreme flood events in coming decades.”


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