Last week I attended a Policy Panel at Ebley Mill that looked at what we would keep from our Local Plan while we develop the LDF. Various issues were raised - one I have a particular interest in is SUDs (see Label below for some of the previous discussions).
Photo: me crossing Ruscombe Brook - one of the sites we would like to see some SUDs measures applied
I have since that meeting been following up on this particular issue as there is a proposed deletion of Policy NE15 of the Local Plan which covers SUDs. For interest of SUDs fans and I know there are several regular readers of this blog I will cover the issue in some detail...
The Council notes that the issue is covered in both PPS23 and PPS25. In the case of PPS23 this states in appendix A that ‘the need to make suitable provision for the drainage of surface water’ is a planning consideration. It further states in paragraph 1.31 of Annex 1 Developers should be encouraged where appropriate to incorporate into their proposals SUDS that are able to absorb at source, the run-off from various types of development, including car parks, buildings, paved areas and roads, or to store water for non drinking water use or enabling it to be released more slowly. This will help to reduce the impact of diffuse pollution from that run-off and flooding, as well as providing a contribution to local amenity and biodiversity. All SUDS must comply with the requirements of the Groundwater Directive. In PPS25 the matter is mentioned in more detail and Annex F relates specifically to Managing Surface Water and paragraphs F3 to F14 issue guidance on the provision of SUDS. Paragraph F8 is very similar to Policy NE15 of the Local Plan in that it states ‘Local Authorities should promote the use of SUDS for the management of run-off’.
This would seem to me that we are moving from our Local Plan that says we should incorporate SUDs to a situation in PPS23 where developers should be encouraged to provide SUDs where appropriate. PPS25 is perhaps a little stronger saying we should promote SUDs, but this still doesn't seem to be as strong as the requirement in our Local Plan policy? I am told the difference is negligible but I will still be working to see this area is tightened up when it comes to the LDF.
I am, for example, still hearing about Planning Applications in this District being approved where SUDs has not even been considered. The Council does seem interested to see more SUDs and I know this is not always a straight forward area. There are several large developments where SUDS has been a leading consideration like Hunts Grove, Union Street Dursley, Grange Farm Leonard Stanley and Stroud College. As part of SUDS philosophy the Council is also requiring the provision of water butts with every new house.
I am also keen to see Stroud follow Woking Borough's example in terms of pre-planning application guidance - in Woking this covers SUDs, renewables and a couple of other key areas. They have produced a good leaflet which has some great simple advice that seems to be helping to educate developers and more - and indeed leading to greater use of renewables, SUDs etc. We'll see! I will be emailing examples of the Woking leaflets to Officers and councillors.