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schemes, lack of maintenance and lower benefits. While there’s understandable pressure
to build as many houses as possible, high-quality SuDS are an essential element to creating a resilient housing stock. Good SuDS will help us cope with more intense rainfall, long-term drought, reduce flooding risk, and make the places where people live both more pleasant and more biodiverse. Research by the team at CIWEM and Enabling Smart Water Communities identified that if high-quality SuDS were delivered consistently across around 1.3 million new homes, they could generate £247m per year in water, environmental and amenity benefits. Of course, no one is claiming that the situation is perfect in Wales. A Welsh Government review has found opportunities for improved training, enhanced implementation across Highways projects and a more consistent approach to pre-application processes. Other improvements could include better data collection, clearer guidance and even greater sharing of lessons learnt and best practice.
One of the benefits of going second is that England could make Schedule 3 work better right from the start, enabling the development of an easier-to-use model for everyone involved, from housebuilders to planners to those responsible for the long- term maintenance of SuDS. We could also look at spreading the
At the moment however, it’s not been applied in England, despite having been available for a decade and a half. In Wales, however, the situation is
different and Schedule 3 has been part of the planning process since 2019. It’s transformed the conversation because everyone knows that high standards on SuDS are a mandatory part of the planning process. Developers come to the table accepting that it’s part of every application, local authorities are developing expertise in effective design and cross-country committees are starting to share best practice, boosting standards across the board. In England, by contrast, SuDS standards
are effectively voluntary and applied in piecemeal fashion due to a range of factors. Implementation is generally focused on flood prevention, rather than the wider benefits of biodiversity, water retention and amenity that good quality
schemes deliver. This will change with the advent of Policy 8 in the new National Planning Policy Framework, published in August this year, which says that SuDS must now be designed and delivered in accordance with the National Standards for SuDS, but there is still a risk of inconsistent design, and ongoing maintenance is still not assured. In practice, this means that standards will still vary between local authority areas and housebuilders with some of the latter happy to include them and others vociferous in pushing back. The publication of two new national SuDS Strategy Templates is intended to reduce that inconsistency, but we will wait and see how that goes. This mixed bag also applies to
construction and maintenance, with responsibility often split between councils, developers and water companies. This approach often leads to inadequate
costs of building and maintaining these schemes across their full lifecycle, making the process more equitable for all. At the moment, the cost of SuDS installation falls primarily on the developers while responsibility for long-term maintenance often passes to local authorities, private companies or other asset owners. Separation between costs and benefits
creates misaligned incentives: developers are incentivised to minimise upfront cost, while those responsible for maintaining the assets may have had little influence during the design stage, which has huge consequences. So, while SuDS may not be topmost
in anyone’s minds as the government wrestles with trying to achieve the magic 1.5m new homes, it’s an essential part of developing sustainable housing that should not be overlooked In order to keep our homes safe, we need
Schedule 3 in England, not just in Wales.
https://www.britishwater.co.uk/
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