EnvirEn Ltd reposted this
⚔️⚔️WAR ON SUDS⚔️⚔️ Over the last two weeks, informal advice has been issued in the southwest stating that where SuDS are used to treat phosphorus and nitrogen they must be considered as mitigation. The implications this has are significant. This means that a developments unmitigated nutrient budget attracts the 20% precautionary before accomodating SuDS leading to vastly higher nutrient budgets 🌊 Why is this being done? It seems clear that Natural England are only too aware that their nutrient concentrations for surface water runoff are far too high. Post 2030 the vast majority of a developments nutrient will be down to surface water runoff in the vast majority of circumstances and in this way the regulator can have their cake and eat it 🍰 with the redevelopment of brownfield land still attracting the higher land use value for the existing land use whilst reducing the post development nutrient load concentrations and using SuDS as the tool to achieve this 🔧 This approach is non-sensical as the management and maintenance requirements for SuDS features as per CIRIA C808 and CIRIA C815 are no more onerous than the requirements in CIRIA C753. The latter maintenance requirements being par for the course as part of development and secured under condition 📜 What can developers do? Choose a consultant that has a firm understanding of SuDS such that reductions can be accommodated correctly with the appropriate calculations for treatment trains and the correct review of the necessary risk scoring. At Enviren we already have a minium of five pages in each report exclusively for SuDS to ensure such measures are now accepted without contest. We are also the only consultancy operating in the field (that we are aware of) that gives appropriate weight to Source Control and Interception and through such interventions nutrient budgets can usually be reduced by at least 30% and in the vast, vast majority of circumstances achieve nutrient neutrality onsite 🏠
I was hoping that that would be the case.
Director at EnvirEn Ltd
2moFollowing persistent badgering and providing evidence to the contrary this has been successfully overturned! Things can continue as normal and in a logical manner, separate post to follow; however, SuDS do need to form part of the AA and should be slotted in the mitigation stage of the HRA despite being in Stage 3! In other words the proposals cannot be screened out if fully neutral.