SUDS: latest correspondence

I've just sent off a couple more letters re Sustainable Urban Drainage Systems to OFWAT and Defra. SUDS is mandatory in Ireland and Scotland - why not here? Things are moving in the right direction but far too slowly.

Photo: view across to Ruscombe

My original letter to OFWAT (see my blog on 17th April) produced a prompt reply which only now am I adding to this blog below along with my response. I've also written to Defra in response to their last letter (see also blog on 17th April) along similar lines to the letter to OFWAT and urging a lead from the Government - see also blog on 17th June for most recent moves to promote SUDS.

Dear Mr Booth,

Thank you for your email dated 17 April concerning the Ruscombe Brook and seeking Ofwat's views on the use of sustainable urban drainage systems (SUDS). SUDS can, of course, take many forms. Ofwat recognises the merits of so-called 'soft engineering' solutions to drainage problems which by attenuating surface water flow can provide a degree of flood alleviation and also yield benefits to water quality. SUDS also have the potential to improve water quality indirectly by better exposing the existence of misconnections of foul sewerage to the surface water drainage system such as those that you say have impacted on the Ruscombe Brook. There are, however, current barriers that need to be overcome before the use of SUDS can become more widespread.

In our November 2004 response to the Defra consultation 'Making Space for Water' (see home page), we acknowledged that SUDS may make a valuable contribution to a cost-effective approach to urban drainage once the various technical and legislative obstacles are tackled. A group led by the Environment Agency, including representatives of major stakeholders, is considering both the technical standards and legal issues required to underpin the future adoption of SUDS. In the Government's 2002 water strategy document, Directing the Flow (see pdf here), Defra highlight its ongoing examination of the extent and nature of urban diffuse pollution, together with the policy options for addressing it; and the scope for SUDS to manage surface water run-off.

You may be interested to learn that Defra is currently consulting on non-agricultural diffuse water pollution in England and Wales (available here). The consultation paper, to which responses are requested by 28 May 2007, identifies sewage as being a potential cause of diffuse pollution as a result of misconnections to the sewer system, sewer leakage or unintended escapes due to blockages by fat or other solid material. Stakeholders' views are invited on whether five priority areas, including sewage, are the right ones on which to focus and on the more immediately obvious mechanisms to address pollution arising from them. Some options for new legislative and voluntary mechanisms are outlined and again initial views are sought on these. Interestingly, the list includes a review of the 'right to connect' provide by s106 of the water Industry Act 1991. Defra expects this would lead to the promotion of SUDS, a reduction in overloading of sewers, improved protection of surface waters and more effective management of surface water in urban areas overall.

You may wish to submit your views on the issues based on your knowledge and experience of a local 'case study'. We understand that such mechanisms will be considered and developed for a second consultation by Defra on the basis of stakeholder endorsement of the priority areas, the emergence of sufficient supporting evidence and an assessment of the cost effectiveness of each mechanism. Defra expect this second consultation to take place towards the end of 2007. I hope this reply has been helpful.

Yours sincerely, Dr Rowena Tye, Head of Quality Enhancement

My reply:

Apologies for delay in replying - thank you for your response - unfortunately the very short time constraints meant we were unable to make a submission to the consultation paper you mention but we would be keen to input into the second stage of the Defra consultation later this year.

Another route we are pursing is to encourage Councils to insist on SUDS with new planning applications - I understand it is mandatory in Scotland and Ireland. We have already met with some planners and several SUDS experts.

Defra have suggested that "the principle obstacles to the implementation of SUDS are ones of adoption of the infrastructure by an organisation which can undertake its long-term maintenance and renewal, together with the securing of a long-term, sustainable funding regime." The fact that SUDS is nearly always cheaper should make section 106 conditions on planning applications possible. To me the problem seems to be a lack of understanding about the importance of SUDS and what is possible: many myths abound about sites not being suitable for SUDS or the cost being prohibitive.

It is frustrating that things do not seem to move despite the urgency of ensuring our water supplies and tackling climate change. I would welcome your views on why this is the case and whether there is anything a small group like the Ruscombe Brook Action Group can do to speed the process! Is there also not a more direct line that OFWAT can take re insisting on SUDS?

All the best - Philip

Click on RBAG Label below for further correspondence and info re SODS and the Ruscombe Brook Action Group.