To: Angela Rayner MP, Secretary of State for the Department of Housing, Communities and Local Government

Improve the implementation of SUDs in new housing estates in the UK

We believe that the National Planning Policy Framework (NPPF) is not specific/strict enough about the implementation of Sustainable Urban Drainage (SUDs) across the UK. Ineffective use of SUDs and building housing in high flood risk areas has led to high amounts of flooding in areas that have not done so before. We conducted an interview with someone living in central Oxfordshire who said: "East Hanney got a new housing development built up. I’ve never known East Hanney to flood out by the La Fontana restaurant. I’ve never known Hanney Road to flood. However, they got a new estate and now it floods regularly." They also stated that local councils are simply using the NPPF "like a tick box so they’ll do the bare minimum that they need to do" in order to reduce costs.

As a solution, we would like the Department of Housing, Communities, and Local Government to alter the NPPF to have local councils implement at least three different kinds of SUDs in each new build estate - so instead of just a water retention basin we would also have green roofs and permeable paving - and have a bare minimum standard quality of the SUDs implemented - including improving ones already present in housing estates. 

Why is this important?

This misuse of the NPPF is actually increasing costs for local councils, considering repairs and removing water after floods. In the short term, SUDs are "very expensive to implement and it’s very expensive to maintain" but in the long run they "can be and are of a great biological benefit and to a benefit of mitigating the risk of excess water runoff and pollutants into the water system." Not only that but "the other economic problem is if we’re flooding the fields and we’re using them as a runoff and we’re using them as an effective land barrier, that is affecting farmers’ ability to produce crop. So then you have a downturn, although it may be small, a downturn in GDP." The picture painted by this is that the council, due to the laxity of the NPPF, choose a high-long term cost over high short-term cost out of what appears to be laziness. There is also a social impact, as closed roads will affect people's ability to travel to and from work and to visit friends and family, causing the councils to be further "flooded" with complaints.

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