Letter to OFWAT and another to Minister re SUDS and Ruscombe Brook

I enclose a copy of a letter to reply to the Minister re SUDS and to OFWAT - it does seem strange to me that SUDS - an answer to so many of our problems - is not being pushed from all angles. I'm hoping that we can get some momentum going on this nationally as well as locally. At the moment very little seems to be happenning.

Photo: Spring at Randwick School

Letter to Minister:

Atten: Jennifer Offord, Joss Wallace and Ian Pearson Thank you for your email in response to issues I raised regarding SUDS (copy enclosed at foot of this blog). I am pleased to hear that the SUDS Working Group is on-going. I thought that the group had stopped meeting. Could you let me know when they have met? I have to say that I am disappointed that you are unable to let me know when a final report might be available. While you note that Defra see this as a matter of urgency I can see no evidence of this. The last report was July 2004 and there is not even an estimated date for the final report. Furthermore that Interim report did not go far enough in making use of the advantages of SUDS, for example insisting on SUDS to developers. SUDS is a well tried and tested cost-effective approach. I fail to see why any delay is necessary. As noted in my previous email this is a critical issue in terms of climate change. SUDS as you note is by no means a panacea for all current flooding problems in urban areas, however in most cases it offers huge advantages over other systems. As all forecasts indicate we must expect considerably more flooding in the future. Furthermore it is not just flooding but sewage and pollution that SUDS can manage. Indeed with proper installation they can manage industrial pollution in addition to household sewage. SUDS also reduce energy used to pump water and treat sewage and in the case of reed beds SUDS can provide a biomass crop. I have been concerned to read that we may have grossly underestimated the dangers of the thousands of repeated outflows of sewage into our waterways. If this proves to be the case then this gives even greater urgency to the need to develop SUDS. Your suggestion that stronger personal responsibility is fine but I would urge you to examine how effective this approach is. I don't believe we cannot afford to wait for people to be educated and then possibly take responsibility. Legislation and incentives are needed to promote more sustainable approaches. The latest UN Intergovernmental Panel on Climate Change report confirms again that the disastrous effects of climate change are already happening and will accelerate significantly without major policy changes. Michael Meacher, former Environment Minister, has said: "What we, and the government, need to get our minds around is that we are at war: at war against climate catastrophe, presenting us a far greater threat towards our survival than 1939." I despair at the lack of urgency on climate change which is verging on the criminal. I do not use the word 'criminal' lightly: the average Somali is about 100 times more likely to die from events caused by climate change than the average American, despite emitting roughly 16,000 times less carbon. We must cut emissions. The fact that we still do not insist on a countrywide SUDS approach is deeply depressing. I hope very much that you will express the urgency of this matter to the Ministers involved. I look forward to hearing more re the SUDS Working Group. Yours sincerely, Cllr Philip Booth, Secretary of the Ruscombe Brook Action Group

Letter to OFWAT:

I write on behalf of the Ruscombe Brook Action Group, a community group based near Stroud. I enclose an article below that spells out some of what we have been doing (Blog ed: click in Labels to find article). One of our key aims is to tackle the problems we have faced along the brook, particularly the number of incidents of sewage escaping into the brook. We have particular concerns about the health risks that these incidents entail.

We have been working with local Councils, Severn Trent Water, British Waterways and others to develop solutions. Severn Trent have replaced some pipes and plan some relining. We also have agreement to proceed with a scoping exercise to look at what possible solutions will bring about the water quality improvements we desire. Water experts, Water 21 have offered to undertake this exercise in conjunction with us. I undertsand you have had some correspondence with them.

One approach that looks particularly promising would be SUDS/reed beds. However this tried, tested and cost-effective approach seems to be restricted by current practice, policies or legislation. One issue is that there seem to be few if any real opportunities for competition, specifically in regards to guaranteeing consumer preferences for safe and economically viable methods of sewerage.

We have written to the Ministers: the most recent email from them is enclosed below. The answer is in our view unsatisfactory. While they note that Defra see this as a matter of urgency we can see no evidence of this. The Interim report on SUDS was July 2004 and there is not even an estimated date for the final report. Furthermore that Interim report did not go far enough in making use of the advantages of SUDS, for example insisting on SUDS to developers.

I am writing to seek assurances that you have no objections to a SUDS scheme for the Ruscombe Brook. Indeed we would welcome your support in ensuring that the community can proceed with this approach if that is seen as best following the scoping exercise.

Philip Booth, Secretary of the Ruscombe Brook Action Group,

Letter from Minister:

Dear Mr Booth

SUSTAINABLE URBAN DRAINAGE SYSTEMS

Thank you for your follow up email of 25 October to Joss Wallace and Ian Pearson regarding sustainable urban drainage systems. I have been asked to reply.

The Interim Code of Practice was produced by the National Sustainable Drainage Working Group which continues to support the development of Sustainable Urban Drainage Systems (SUDS) through the production of technical and other guidance. The Group is made up from a wide range of stakeholders and government feels that it has undertaken sound work and continues to perform a very useful function in respect of consultation on SUDS policy development.

It is fair to say that SUDS require a different approach to that traditionally taken by the construction industry, regulators and the bodies responsible for managing infrastructure and this is an area which is under detailed consideration by government with the aim of securing more widespread implementation of SUDS infrastructure. This is an important piece of work which has complexity, not least through its linkages to other work streams relating to flood management and it is not possible to state at this stage when it will be finalised. It is however viewed as having urgency within Defra.

I think it should be stated that SUDS is not be seen as a panacea for all current flooding problems in urban areas and these will need to continue to be addressed through the existing industry structures i.e. water and sewerage company in relation to sewer flooding and local authorities or Environment Agency in relation to flooding from watercourses. However, by way of example, were a water and sewerage company is dealing with a sewer flooding problem within an existing urban area through the promotion of new capital works, it is at liberty to consider the removal of surface water from its piped system into a SUDS system.

Your final comments regarding the need for advice for householders and others about the problems of impermeable paving and the importance of surface water separation are noted. Government continues to work with the water industry on public information on a wide range of issues and would wish to see that a greater awareness leads to stronger personal responsibility in these matters.

I hope that this letter addresses your concerns.

Yours sincerely, Jennifer Offord, Customer Contact Unit