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Confusion over Suds definition scuppers sustainable development

A veil of confusion and mystery still surrounds the new sustainable drainage systems (Suds) regime implemented by the Flood & Water Management Act, making it difficult to have useful and productive discussions on the subject.

The problem was evidenced by the recent revelation that the government wants to give developers a get-out clause to prevent their projects falling down on the basis that their Suds are unsatisfactory (NCE 13 October).

But the problem goes further than that; Suds are a facet of civil engineering with as much jargon as any other. As none of the terms are authoritatively defined and words are used differently by diff erent parties, the subject is ripe for misunderstandings.

Perhaps most common is the idea that the term Suds only applies to swales and ponds, green roofs and complicated landscape gardening set-ups. Suds are commonly aligned with so-called green and blue (more natural) infrastructure and thought of in opposition to grey (more heavily engineered) infrastructure — but of course underground storage pipes and concrete tanks are types of Suds too, so long as they are standalone systems that do not connect to the sewer network.

“Traditional drainage” is the term often used in knowledgeable circles to describe a non-Suds drainage system. But that is misleading too, because Suds are not necessarily non-traditional.

Ponds, swales, storage tanks and the like have been constructed for surface water drainage purposes for decades, long before the term “Suds” gained currency.

Moreover, attempts to change the perception that drainage is an add-on to the built environment, rather than being a crucial part of its design, have spawned new buzzphrases including “water sensitive urban design” and “ecosystems services”, which do little to make things clearer to outsiders. Where’s the harm in a few misunderstandings?

The trouble starts when those who are not necessarily versed in the intricacies of Suds — particularly developers and other project clients — narrowly decide they are unattractive, green ditches that take up a lot of space and do nothing for 99% of the time; or that they are green roofs and water treatment installations that are complicated and costly; or that they are non-traditional infrastructure that is newfangled and unreliable.

But what Suds specialists rail against most is the failure of developers to understand that early incorporation of Suds into designs maximises the chance of them being cost-effective, unobtrusive and amenable. It is the failure to do this that leaves developers in a situation where they cannot retrospectively make good Suds work.

This is the point at which many will want to approach their local Suds Approving Body (SAB) and agree an alternative drainage arrangement, as per the Department for Environment, Food and Rural Affairs’ (Defra) proposed waiver system.

But what Defra is proposing could create a self-fulfilling prophecy. The more opportunities developers have to avoid building Suds, the less likely that they will fi nd a cost-effective way of doing so.

And yet, in this bleak economic climate it is hard to argue with Peter Brett Associates partner and British Property Federation adviser Ben Mitchell’s assertion that much-needed housing and economic development should not management.

Anecdotal evidence suggests the public might agree with him: Defra coastal erosion risk management policy officer Paul Barrett told a Chartered Institution of Water and Environmental Management (Ciwem) conference last week about an unnamed coastal area whose local council won a competitive Defra grant for flood and erosion risk management.

Residents reacted to the news by asking the council to spend the money on socioeconomic issues and regeneration instead. They simply felt those problems were more deep-seated and urgent than the threat from the coastline.

The question of whether Suds objectives should dictate whether a development goes ahead is a delicate one, and the much delayed and still to be published national standards will have to strike a delicate balance.

Everything will depend on the wording used in the standards, and the nitty gritty details of when and how Defra will allow developers to sidestep those standards.

It could produce a system that undercuts the Flood & Water Management Act and allows many developers to carry on ignoring Suds as usual, or it could create a genuinely stringent set of standards that lets developers shirk their Suds obligations in only the most extreme situations.

However, Defra has failed to confirm when it will publish its Suds standards or indeed what they will contain.

What is certain is that the lack of solid detail about what the government is planning to say in the soon to be published Suds standards is only creating greater apprehension among champions of development and Suds alike.

For all the confusing terminology and misconceptions that surround Suds, Defra’s continued mysterious silence is the most perplexing thing of all.

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