Slow The Flow asked a question recently at a CMBC Cabinet meeting, with regard to the proposed Brighouse Garden Suburbs. We hope that others will help us advocate for strong Sustainable Drainage (SuDS) schemes, integrated into the master planning, as part of these major developments; here’s the link to do so (https://calderdale-consult.objective.co.uk/kse/folder/97162), the public consultation is now open and closes on 22nd September.
The question we asked was:
“Given the existing flooding issues in Calderdale, expected exacerbation of the problem due to Climate Change, the Council’s commitment to its Climate Action Plan, and the long timescales relating to these developments; can the Council provide reassurance that Sustainable Drainage Systems (SuDS) will be integrated on these sites, in order to take the opportunity afforded by their development to proactively improve the downstream flooding situation and build on our area’s reputation as leaders in these innovative, multi-beneficial techniques – and will they ensure that forthcoming ‘Schedule 3 of the Flood and Water Management Act’ legislation with regard to SuDS is applied to these sites, and that the Council will provide proper support for the enforcement of the legislation, through establishment of a sufficiently funded, skilled and supported SAB (SuDS Approval Body) to ensure good quality, robust SuDS implementation on these sites in the long term?”
The welcome response from Calderdale Council was:
“A key benefit of delivering larger scale, masterplanned development is that it enables a comprehensive approach to be taken to objectives such as Sustainable Drainage Systems. This is harder to achieve on small sites.
The Masterplans include a section on Drainage – and emphasise that the Garden Communities should implement drainage strategies that consider sustainable drainage techniques that work with the natural drainage of the sites to retain surface water within the site and manage the risk of flooding during severe storms.
In relation to the natural environment, the Design Code sets out design principles concerning the multifunctional green and blue infrastructure, including sustainable drainage, play provision and biodiversity. The Council welcome the interest of Slow the Flow and look forward to receiving their comments through the forthcoming consultation. Further to this, it is also important to highlight that we intend to bring a Sustainable Drainage SPD forward for consultation soon.
National planning policy and guidance sets a clear expectation for developers to provide sustainable drainage systems (SuDS) which include benefits for water quantity, water quality, biodiversity and amenity. Calderdale Council strongly encourages the design of multifunctional sustainable drainage systems that integrate with blue and green infrastructure. Developers are strongly encouraged to incorporate SuDS in the early stages of design. SuDS are currently required on all major developments, unless clearly demonstrated to be inappropriate.
The introduction of mandatory SuDS and the implementation of Schedule 3 to The Flood and Water Management Act 2010 represents an opportunity to mitigate the impacts of the combination of increased rainfall and reduced natural drainage.
The Department for Environment, Food and Rural Affairs (Defra) has conducted a review into the implementation of Schedule 3. The review aimed to identify how making sustainable drainage systems mandatory for most new developments would benefit and impact addressing the pressures from climate change, population increase and urbanisation. Expected benefits were reducing the risk of surface and sewer flooding, improving water quality and rainwater harvesting. It is expected that, following a public consultation, Schedule 3 will be implemented in 2024.
Under Schedule 3 the approving body will be known as a SuDS approving body (SAB) and Schedule 3 recommends that this will be the Local Authority, with the Lead Local Flood Authority (LLFA) assuming the role due to their existing responsibility for managing local flood risk and their knowledge and expertise of SuDS. The Council will continue working with Defra and other organisations to inform discussions on funding including the running costs of the SAB and long-term SuDS operation and maintenance costs.”
Please help us to let CMBC know that the flooding implications of these sites for Brighouse are high on local residents’ agendas, by responding to the consultation.