THE EXTENT TO WHICH SUSTAINABLE URBAN DRAINAGE SYSTEMS (SUDS) ARE
CONSIDERED IN ENVIRONMENTAL IMPACT ASSESSMENT (EIA)
by
Alexander Grimm
Thesis presented in part-fulfilment of the degree of Masters of Science in accordance with the
regulations of the University of East Anglia
School of Environmental Sciences
University of East Anglia
University Plain
Norwich
NR4 7TJ
August 2007
© 2007 M.Sc. Student
This copy of the dissertation has been supplied on condition that anyone who consults it is
understood to recognise that its copyright rests with the author and that no quotation from the
dissertation, nor any information derived therefrom, may be published without the author’s prior
written consent. Moreover, it is supplied on the understanding that it represents an internal
University document and that neither the University nor the author are responsible for the factual
of interpretative correctness of the dissertation.
1
CONTENTS
Page
CONTENTS
2
TABLES AND FIGURES
4
GLOSSARY OF TERMS
5
ACKNOWLEDGEMENTS
6
ABSTRACT
7
CHAPTER 1: INTRODUCTION
8
1.1 Types of SUDS
15
1.2 Environmental Impact Assessment and SUDS
17
1.3 Objectives and Aims
25
CHAPTER 2: METHODOLOGY
26
2.1 Part One: Review of EIS
26
2.2 Type of EISs
28
2.3 Criteria
29
2.3.1 Data analysis
31
2.3.2 Qualitative criteria
31
2.4 Part Two: Interviews
37
CHAPTER 3: RESULTS AND ANALYSIS
40
3.1 Development type
41
3.2 Part One: EIS review
42
2
Page
3.2.1 Analysis of trends over time
42
3.2.2 SUDS consideration and the influences upon them
47
3.2.2.1 Guidance documentation
48
3.2.2.2 Environment Agency consultation
50
3.2.2.3 Contamination aspects
54
CHAPTER 4: DISCUSSION
58
4.1 Barriers and drivers identified in EIS review
58
4.2 Barriers and drivers identified in interviews
60
4.3 Consideration of EISs
60
CHAPTER 5: CONCLUSIONS
69
REFERENCES
72
3
TABLES AND FIGURES
Table 1.1 – Description of SUDS type.
Table 2.1 – Criteria and relevance to research.
Table 2.2 – Criteria categorisation.
Table 3.1 – Development types and descriptions.
Table 3.2² – Number of EISs and percentages of the use of guidance documents, EA
consultation and CLA over time.
Table 3.3 – Contaminated land assessment (CLA) over time.
Table 3.4 – SUDS consideration with and without guidance and EA consultation.
Table 3.5 – Type of SUDS with and without guidance and EA consultation.
Table 3.6 – Additional good practices with and without guidance and EA consultation.
Table 3.7 – Consideration of SUDS with and without contamination of land.
Figure 3.1 – Use of guidance documentation over time.
Figure 3.2 – Guidance vs. SUDS consideration/incorporation.
Figure 3.3 – EA consultation vs. SUDS consideration.
Figure 3.4 – Contamination land assessment (CLA) vs. contamination.
4
GLOSSARY OF TERMS
CEH - Centre for Ecology and Hydrology
CIRIA - Construction Industry Research and Information Association
CLA – Contaminated land assessment
EA – Environment Agency
EIA – Environmental Impact Assessment
EIS – Environmental Impact Statement
InteREAM - Interdisciplinary Research in Environmental Assessment and Management
SUDS – Sustainable Urban Drainage Systems
5
ACKNOWLEDGEMENTS
I would like to thank Dr Mat Cashmore for his invaluable help throughout this research and
to the interviewees who gave their time to assist in the data collection process. Above all, I
would like to thank M and C, without whose support I would not be where I am now.
6
ABSTRACT
This research highlights recent trends in consideration of Sustainable Urban Drainage
Systems (SUDS) in England. In particular, it focuses on the barriers for their consideration
and ways in which they may be overcome.
With the worlds increasing urbanization, SUDS consideration in EIA is still not at a level
that necessitates its importance. Through a review of 80 EISs, interviews with five
members of different sectors associated with SUDS and literature analysis, the main
barriers to this being adoption and maintenance issues, a general lack of desire from
developers, contamination issues, a lack of communication and integration of authorities
and consideration being given at the wrong time in the EIA and design processes.
The methodology used also provided ways in which these barriers may be overcome,
including adoption and maintenance mechanisms through which financial security could be
given for the upkeep of SUDS, greater communication and integration of authorities and
strategic and legislative solutions for regulation and requirement enforcement.
7
The extent to which Sustainable Urban Drainage Systems (SUDS) are
considered in Environmental Impact Assessment (EIA)
CHAPTER 1: INTRODUCTION
During the course of the last century, the influence exerted by expanding urban
populations upon the natural environment has highlighted one of humanity’s most
pressing problems – growth within a finite system (Butler & Parkinson, 1997). More
recently, the development of mega-cities had initiated many concerns associated with the
quality of life in the urban environment (Black, 1994) and the environmental impacts upon
the outlying areas that cities rely upon to support urban life (Butler & Parkinson, 1997).
Until now humankind has lived and worked primarily in rural areas. But the world is about
to leave its rural past behind: by 2008, for the first time, more than half of the globe’s
population, 3.3 billion people, will be living in towns and cities¹. Over the next 30 years,
the population of African and Asian cities are expected to double, adding 1.7 billion
people, more than the current populations of China and the United States combined, to
the global population. The United Nations Population Fund expects the world’s urban
population to swell to almost 5 billion by 2030, 60 per cent of the world population, a
¹ this crossover date is based on the latest UN estimates, referring to the analyses of urbanization trends
(UN, 2006).
8
significant growth, when considering the present global population is 6.7 billion (UN,
2007). Other statistics show similar figures, with one stating that in 1996 there were 290
cities worldwide with population exceeding 1 million, whereas this figure is estimated to
have grown to 400 cities worldwide (Roesner, 1999). As cities have expanded and
lifestyles have changed, there has been an increasing quantity of foul water to dispose of
and, more importantly for this dissertation; the amount of surface water runoff has
increased as a result of urban expansion reducing the area of porous surfaces (Jones &
Macdonald, 2006). In Europe the last two decades has witnessed growing water stress,
both in terms of water scarcity and quality deterioration, which has prompted
municipalities to look for a more efficient use of water, including a more widespread
acceptance of water re-use practices (Bixio et al., 2006). Water is a highly regulated
component in many countries due to the importance of maintaining clean and adequate
supplies for industry, society and biodiversity (Morris et al., 2001). With population growth
of the scales mentioned, especially within urban areas, it seems essential that a move
towards sustainable development is necessary to preserve the planets resources and
reduce any detrimental effects that a growing population may have.
The widely used and accepted international definition of sustainable development as
stated by the Brundtland Commission, in what is now known as the Brundtland Report, is,
‘development which meets the needs of the present without compromising the ability of
future generations to meet their own needs’ (World Commission on Environment and
Development, 1987). Jeffrey et al. (1997) go further stating that sustainable systems are
9
those that can be adapted the changing circumstances. Globally we are not even
meeting the needs of the present let alone considering the needs of future generations.
The increasing stress we put on resources and environmental systems such as water,
land and air cannot go on forever.
Urban populations depend on natural resources for water, food, construction materials,
energy and disposal of waste. Expansion of urban areas changes land cover and causes
habitat loss and its distribution in the form of fragmentation and severance. The
environmental challenges posed by the conversion of natural and agricultural ecosystems
to urban use have important implications for the functioning of global systems. Land
cover change can also contribute to other impacts; an example of this can be seen in the
severe flooding of the Yangtze Basin, China, in 1998 and 2002, caused by a combination
of climate variability and human-induced land cover changes. Similar examples can be
seen in India, Mexico and other poor nations; these local or national problems have
significant ramifications when aggregated globally (UN, 2007).
In an attempt to remedy this issue, the Programme of Action of the International
Conference on Population and Development (1994) recommended that: ‘Governments
should increase the capacity and competence of city and municipal authorities to respond
to the need of all citizens, to safeguard the environment and to manage urban
development’ (UN, 2007).
10
Martin et al. (2006) state that due to this more intensive urbanization there has been an
increase in stormwater runoff, while Badr et al. (2004) indicates that a significant
proportion of Water Impact Assessments (WIA) and their mitigation, or alleviation, and
monitoring procedures are unsatisfactory, thereby, creating a potential problem for water
quality and quantity in urban environments.
Surface water runoff is the main carrier of contaminants, which can lead to significant
pollution of rivers, lakes, estuaries and groundwaters (Braune & Wood, 1999). Urban
surface water runoff carries not just contaminants such as metals and hydrocarbons (oils
and petrol) but also nutrients and sediment, pathogens and debris (D’Arcy et al., 1998,
Miltner et al., 2004). Steedman (1988) states that the typical result of the effect of urban
surface water runoff is that the quality of any given stream is negatively correlated with
the amount of urbanisation in its surrounding watershed.
Over the last century an increasing load on the ageing sewer infrastructure has come
with this urban expansion (Jones & Macdonald, 2006). Conventional stormwater and
urban drainage systems are designed to dispose of surface water runoff as quickly as
possible from the point at which it has fallen to a discharge point, either a watercourse or
a soakaway. This results in engineering solutions for runoff water in urban areas that
often involve the provision of large inception/relief sewers, huge storage tanks in
downstream locations and centralised sewage treatment facilities (Butler & Davies, 2000,
EA, 2007, Villarreal & Bengtsson, 2004). The use of combined sewage systems began to
11
die out in the early twentieth century, primarily because as cities expanded it became too
expensive and time consuming to construct ways in which to transport mixed foul and
‘clean’ runoff to installations on the edge of the city for treatment. However, in older urban
areas these old systems are still used (Jones & Macdonald, 2006). These traditional civil
engineering solutions have a number of adverse effects:
•
Runoff from hardstandings (paved areas) and roofing can increase the risk of
flooding downstream, as well as cause sudden rises in water levels and flow rates
in watercourses;
•
As previously stated, surface water runoff can contain contaminants such as oil,
organic matter, pathogens and toxic metals. Although often at low levels,
cumulatively they can result in poor water quality in rivers and groundwater,
affecting biodiversity, amenity value and potential water abstraction. After heavy
rain following a long dry period, the first flush is often highly polluting;
•
By diverting rainfall to piped systems, the amount of water infiltrating the ground is
reduced, depleting ground water and reducing flows in watercourses in dry
weather.
(EA, 2007)
In response to these problems, structural best management practices (BMPs) are now
commonplace for stormwater management in new suburban developments (Villarreal &
12
Bengtsson, 2004), more widely known as SUDS – Sustainable Drainage Systems (in
Scotland, Sustainable Urban Drainage Systems) (EA, 2003i, Scholz, 2006).
SUDS are defined by Warrington Borough Council (2007) as ‘a sequence of
management practices and control structures designed to drain surface water in more
sustainable fashion than in some conventional techniques.’ In lay terms, this means that
SUDS slow down the rate of flow through various controls as close to the source as
possible, thereby promoting natural infiltration, the collection of solids through
sedimentation, the uptake of nutrients and the reduction of contaminants through
vegetation uptake and bacterial action. They are therefore designed with three objectives
in mind:
•
To control the quantity and influence timing of runoff from a development;
•
To improve the quality of the runoff;
•
To enhance the nature conservation, landscape and amenity value of the site and
its surroundings.
(EA, 2003ii)
They can be designed to be multifunctional: for example, to reduce flood risk and improve
stormwater quality at the same time as providing urban green-spaces for recreation and
wildlife. In this way, stormwater has truly become a liquid asset in the suburbs (Villarreal
& Bengtsson, 2004).
13
As stated previously, implementing SUDS may lead to cost savings, for example, by
avoiding or reducing the need for:
•
Gully pots (a crude form of catchment drain);
•
Constructing or requisitioning surface water sewers;
•
Piped connections to distant outfalls.
(EA, 2003i)
SUDS include tried-and-tested techniques that are already being implemented on a
range of projects. They incorporate cost-effective techniques that are applicable to a wide
range of schemes, from small developments to major residential, leisure, commercial or
industrial operations with large areas of hardstanding and roof. They can also be
successfully retrofitted, the process of incorporation into an existing development (EA,
2003ii). However, there are some concerns over the effectiveness of SUDS. It must also
be considered that SUDS may have a potentially negative effect on the environment in
the form of mobilization of contaminants in the ground. Detailed studies in the US have
shown that pesticides can move through both topsoil and subsoil (Hallberg, 1989). When
disposed of in soakaways, it has been reported that the contaminants have appeared in
waterways 400 metres away in only two hours after disposal (ENDS, 1993).
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1.1 TYPES OF SUDS
There is a range of different types of SUDS. These have been classified in a variety of
ways in different typologies. According to the typology used by EA (2003iii), the following
six main types of SUDS can be discerned:
Permeable pavements – Construction Industry Research and Information Association
(CIRIA) (2004) describe the permeable paving, also known as porous paving, as ‘a paved
surface that allows the passage of water through voids between the paving blocks/slabs’.
Although the designs may vary greatly, the principle of permeable pavements are to
collect, treat and infiltrate freely any surface water runoff to support groundwater
recharge (Scholz & Grabowiecki, 2006). However, some designs are lined and use a lowlevel outlet to reducing the outflow of water, by storing runoff and gradually releasing it
into the environment (WERF Report, 2004). By making impermeable surfaces permeable
through the use of permeable paving, runoff is greatly reduced.
Filter Strips – This is a vegetated area of gently sloping ground designed to drain water
evenly off impermeable areas and filter out silt and other particulates (CIRIA, 2004).
Swales – A swale is a shallow vegetated channel designed to conduct and retain water,
but may also permit infiltration; the vegetation filters particulate matter. Similar to filter
strips, although larger and often fed by them (CIRIA, 2004).
15
Basins - Also known as dry ponds, these structures are empty the majority of the time
and provide temporary storage for stormwater, reduce peak flows to receiving waters,
facilitate the filtration of pollutants (deposited and incorporated into the substrate) and
encourage microbial decomposition, as well as allowing water infiltration directly into the
ground (CIRIA, 2004, EA, 2003i, Jefferies, 2003).
Ponds or Retention Ponds – These are permanently wet basins designed to retain
stormwater and permit settlement of suspended solids and biological removal of
pollutants (CIRIA, 2004). They may also contribute to visual amenity and biodiversity, and
can be fed by filter strips and swales (EA, 2003iii).
Wetlands - CIRIA (2004) regard wetlands as ponds that have a high proportion of
emergent vegetation in relation to open water. EA (2003iii) expand on this; wetlands are
a further enhancement of retention ponds and incorporate shallow areas planted with
marsh or wetland vegetation, providing a greater degree of filtering, removal of nutrients
and treatment of water pollution in its variety of forms - what Scholz and Lee (2005) refer
to as ‘ecosystem filters’.
The descriptions above are summarised in Table 1.1, as they are described in the CIRIA
glossary of terms (2004) and as typologically classified by EA (2003iii).
16
Table 1.1 – Description of SUDS type.
TYPE OF SUDS
Permeable paving
DESCRIPTION
A paved surface that allows the passage of water through
voids between the paving blocks/slabs.
Filter strip
A vegetated area of gently sloping ground designed to drain
water evenly off impermeable areas and filter out silt and
other particulates.
Swale
A shallow vegetated channel designed to conduct and
retain water, but may also permit infiltration; the vegetation
filters particulate matter.
Basin
Flow control or water treatment structure that is normally
dry.
Pond or Retention pond Permanently wet basin designed to retain stormwater and
permit settlement of suspended solids and biological
removal of pollutants or a pond where runoff is detained
(e.g. for several days) to allow settlement and biological
treatment of some pollutants.
Wetland
A pond that has a high proportion of emergent vegetation in
relation to open water.
(CIRIA, 2004)
1.2 ENVIRONMENTAL IMPACT ASSESSMENT AND SUDS
Environmental Impact Assessment (EIA) is a participatory process employed to identify
and evaluate the probable environmental consequences of development proposals in
order to facilitate informed decision-making and sustainable development (Glasson et al.,
1999). The consideration of alternatives has been described as ‘the heart of
environmental impact assessment in the US’ (CEQ, 1978 & 2003); the EU require only an
outline of the main alternatives studied by the developer and an indication of the main
reasons for this choice (EC, 2003). It could be argued that this lack of apparent
17
commitment to alternatives could have an adverse effect on the extent to which SUDS
are considered. However, for their benefits, regardless of legislative issues, use of SUDS
in urban areas is constrained by competition for limited space, social values and
associated costs and although efforts are being made, wholesale adoption of SUDS
remains a rarity (Villarreal & Bengtsson, 2004). Therefore, a focus on EIA, an area in
which SUDS can be considered for incorporation into the design of a development, is
necessary to determine both the extent of SUDS consideration and to identify any
potential barriers to their incorporation.
EIA is a systematic, cyclical process that examines the environmental consequences of
planned developments (Glasson et al., 1999) with mitigation of environmental impacts at
the heart of the process (Wood, 2003). EIA has been, and remains for the time being, a
very important tool of environmental management and is proving particularly enduring.
Originally produced to address concerns regarding the effects that major development
projects were having on the environment, the benefits associated with EIA were quickly
recognised and within 20 years had become established as a globally important
environmental decision making tool (IEMA, 2007). Environmental Impact Assessment
can, in theory, help ensure that environmental implications of new development are fully
explored before planning decisions are made; this can be done in a systematic and
transparent manner and may lead to less environmentally damaging developments and
unacceptable proposals going back to the drawing board (CPRE, 2004).
18
Although EIA has been used for nearly four decades and is used around the world in
developed and developing countries, we should still expect to see the EIA tool evolve
further in reply to new environmental expectations and concerns (IEMA, 2007, McDonald
& Brown, 1995). McDonald and Brown (1995) believe that we should be moving “beyond
EIA” to incorporate perspectives and processes, that have evolved as part of
environmental assessment, into project design, going so far as to dispose of EIA in its
use as a separate tool.
Its use as a more active tool, away from its previous “advice-only” status, enables it to be
used to provide environmental information to decision-makers, the public and other
stakeholders so that environmental factors can be integrated into decision-making
alongside economic, engineering and social factors (IAIA, 2007). This can be achieved
through its practical application as a design tool to incorporate mitigatory design changes
into a project while it is still being planned, before they are submitted to the relevant
decision-making body (CPRE, 2004, IEMA, 2007, McDonald & Brown, 1995,
Planningmatters, 2007).
Its importance as an environmental management tool can be seen through what it has
provided in benefits, though indirect. EIA has:
•
Involved new and beneficial players in the planning and design process including
academics, non-governmental organisations and most importantly, the public;
19
•
Encouraged fewer environmentally unsound projects to leave the drawing board;
•
Facilitated
the
responsibilities
development
in
private
of
environmental
enterprises,
policies,
government
guidelines
and
instrumentalities
and
professional organisations;
•
Stimulated the environmental education of many players in the development
process including engineers, planners, surveyors, proponents, solicitors and
perhaps most importantly, decision-makers.
(McDonald & Brown, 1995: p485)
This final point of education, as suggested by McDonald and Brown (1995), has been the
cause of a measurable improvement in the quality of environmental planning over the
years, going so far as to argue that even if EIA was ineffective in its role to advising
decision-makers or achieving the incorporation of mitigation measures, its continued
existence is more than justified through the educative and stimulative role that it plays in
environmental planning. This contributes and broadens its popularity as a tool that
planners,
decision-makers
and
communities
expect
to
reduce
any
significant
environmental impacts.
Referring back to McDonald and Brown’s (1995) theory regarding a move beyond EIA, its
past role of providing only advice to decision-makers is relatively ineffective, labelling it as
a process of analysis and criticism rather than creativity. EIA does not create solutions,
due to it being carried out too late and ending too soon, which emphasise and demand a
20
move from ‘reactive’ and ‘cure’ to ‘anticipate’ and ‘prevent’. The need for such changes to
improve the EIA process are illustrated by McDonald and Brown (1995: p487-488):
‘Currently, most formal administrative and reporting requirements for EIA
are based on its original role as a stand alone report carried out distinct
from, but in parallel with, the project design. This militates against
cooperative activity. Administrative systems must be developed that avoid
marginalization of environmental professionals from the real planning
process and encourage, not discourage, creative interaction between
environmental aspects and project design.’
In attempting to reduce this lack of connection between environmental aspects and to
incorporate EIA into the design process, as a design tool, regular meetings between
design teams and environmental assessment teams and environmental overviews of
alternatives, followed by more detailed assessment of the chosen alternative, are
valuable improvements in a move towards the anticipation of, and prevention of, adverse
environmental impacts (McDonald & Brown, 1995).
However, the widespread experience of EIA as an anticipatory environmental
management tool has generated a considerable debate over the extent to which it is
achieving its purpose. There is no doubt that EIA has made a difference to patterns of
development through design modification. The quality of decisions involving EIA has
21
improved as a result of the increased use of mitigation yet there has been growing
dissatisfaction over the fact that EIA's influence over development decisions is relatively
limited and that it appears to be falling short of its full potential (Jay et al., 2007).
Cashmore et al. (2004) describe this as “passive integration with decision processes” and
call for less attention to be paid to the issue of EIA’s influence in design and consent
decisions and more to be given to the broader institutional, political etc., context in which
decision-making occurs, regarding this as a significant means of contributing to
underlying sustainable development goals. The development of Strategic Environmental
Assessment (SEA) can be seen as one initiative to further the integration of the principles
of EIA into development planning by enabling the review of the strategic policy-, planand programme-making actions that generally set the context for EIA at the project level
(Jay et al., 2007).
As previously stated, Wood (2003) regards mitigation of environmental impact to be at
the heart of the EIA process. Like mitigation measures, the consideration of alternatives
are regarded as the heart of EIA in the United States (CEQ, 1978); it is necessary to
highlight the relationship of these two words, mitigation and alternative, in EIA, due to the
word ‘mitigation’ not actually being used in the EU EIA Directive 97/11/EC. Evidence of
their similarity can be seen in the Netherlands, where mitigation measures are called
alternatives (Wood, 2003). Therefore, because mitigation is a fundamental and integral
element of EIA, the use of the broader scoped SEA, to set the context for EIA, enables
more emphasis on the focus of improvements to EIA to be considered at the design and
22
mitigation levels, which in turn enables greater potential emphasis on sustainable
development. This is where SUDS come into their own; because SUDS have the
potential to reduce environmental impacts and are a feature in final designs, they are an
example of an aspect by which improvements in which both design and mitigation can
measured. There are definite advantages to using one aspect to assess and improve
these two mitigation and design elements of the EIA process, which is perhaps why EIA
should be the route to enable SUDS to be incorporated into urban infrastructure design.
Just as a focus on SUDS could help improve EIA, so then EIA could benefit from the use
of SUDS in both the design and mitigation processes. This would allow for greater
integration across industries, something which would reduce resource use, e.g. time, and
which is already being driven by sustainable development objectives and growing in
receptiveness (Milner et al., 2005).
Closer to home, the current Planning Policy Guidance Note 25 for England and Wales on
development and flood risk, emphasises the role of SUDS and introduces a general
presumption that they will be used. Many planning authorities will expect planning
applications to demonstrate how a more sustainable approach to drainage is to be
incorporated into development proposals and may use planning conditions to secure the
implementation of SUDS (EA, 2003ii). However, this is the view held by EA, who actively
promotes sustainable development and consideration of the environment. The
Government Office for East Midlands (2007) regards the use of SUDS as an example of
best practice, far from the ‘expectation’ that EA profess. This latter view may be a reason
23
for the quality of urban development EISs being less satisfactory than other types of
projects (Lee & Dancey, 1993), though it must be remembered Lee and Dancey’s (1993)
study was conducted nearly 15 years ago.
However, due to the differing expectations of the Government and EA regarding the
implementation of SUDS into developments through EIA, the lack of literature in this area
and the potential benefits to both, in terms of improving the EIA process and the increase
of consideration to SUDS, this study shall determine to ascertain the extent to which
SUDS are being considered in EIA.
24
1.3 OBJECTIVES AND AIMS
The primary aim of this research is to critical analyse the consideration of SUDS in the
Environmental Impact Assessments of urban infrastructure developments in England.
This is to be achieved through the following research aims:
•
Determination of the degree to which SUDS are currently considered in the
different areas of the development industry;
•
Identification of the potential barriers restricting the use of SUDS;
•
Identification of the potential ways in which these barriers may be overcome.
25
CHAPTER 2: METHODOLOGY
In framing the case for this dissertation, it has been established that little research has
been done in the area of SUDS consideration in EIA. Because of this, there are no
frameworks or methodologies, established or otherwise, that may be used as a guide or
basis for this research. When determining the extent of consideration of an aspect of
EIA, the EIS is a necessary element to focus upon due to it being a record of the
assessment process and in most cases, the only record of an assessment (Glasson et
al., 1999). The development of criteria to review EISs (to identify the extent of
consideration of SUDS and determine to what extent they are being undertaken in a
development) will be used to identify any trends that are relevant to the research aims,
in this case, potential barriers to the incorporation of SUDS in a development and ways
in which these may be overcome. The second stage of the methodology will focus on
ascertaining any influences and barriers that may not be identified in the EIS, via
literature analysis and interviews. This chapter explains the methodology and describes
in detail the methods employed.
2.1 PART ONE: REVIEW OF EISs
By looking at the output of the EIA process, the EIS, it is expected that a sound
understanding of SUDS consideration will be established, from which analyses of the
data to determine any potential trends can be made. This will be done through the
26
design of a review methodology to determine the extent to which SUDS are currently
considered in EIA. This analysis will be used to assist the second part of the
methodology.
For the EIS survey the number of EISs to be reviewed was based on several issues.
Firstly, consideration of the number of EISs produced in England was necessary to
indicate how often the potential for SUDS consideration arises; the number of EISs
produced in England in 2005 was around 460 (Barker, 2006). Secondly, analysis of the
literature to determine the number of EISs used in reviews was done to gain an
impression of the sort of numbers needed for this review. Lee, an authority on EIA, was
throughout the 1980s and 1990s a global champion of environmental assessment
(Fischer, 2005). His research involved between 40 (Lee & Dancey, 1993) and 83 (Lee &
Brown, 1992) EISs per study, although reviews of this kind assess the EISs in more
depth. Finally, the practical constraints imposed on this research limited the number of
EISs that could be reviewed; number of EISs readily available and time constraints were
the principal quandaries. It was felt that for all these reasons that the number must be
realistically achievable. The constraints of this research do not allow for such in depth
data collection therefore it was considered that with transferable and expeditious criteria,
80 EISs could be reviewed.
Due to the lack of research in this particular area, there are no methodologies previously
used that can be applied in its present form or used as a basis for this EIS review. A
27
review of this type needs criteria that can be applied to each EIS in turn, thereby
enabling fairness of assessment and ease of analysis of results. These criteria are
examined in more detail later in the chapter and will be both quantitative and qualitative,
the qualitative data acting as a guide and additional information for the discussion of the
results and key points of the review. Both the quantitative and qualitative data will be
used in the second stage of the methodology, namely, the interview stage.
2.2 TYPE OF EIS
Due to the nature of SUDS, some developments are more likely to incorporate them
than others. To gain an impression of SUDS consideration in developments within an
urban context, this research focuses on urban infrastructure development including
roads, railways and airfields, therefore will review those EISs that are within the remit of
this focus, specifically those in the category of development covered under the Town
and Country Planning (Environmental Impact Assessment) Regulations 1999.
In the UK there are many different legislations that are concerned with the categorisation
and implementation of new developments, the vast majority of these being urban
developments. It is for this reason that use of the EIA regulations - The Town and
Country Planning (Environmental Impact Assessment) Regulations 1999, Schedule 2, is
one of relevance in urban infrastructure development categorisation, resulting in no
need for other categorisation documents. SUDS will not be applicable or relevant in
28
some of these (e.g. offshore developments or underground mining developments). The
focus of this research is to assess the mitigation of surface water runoff from increased
impermeable surfaces from urbanization; these types of development contain a large
proportion of hardstanding, increasing runoff volumes, are among the more suitable
developments for the application of SUDS techniques and therefore the review will focus
here.
A total of 80 EISs will be reviewed, ranging from the years 2000 to 2005 all of which are
urban infrastructure developments. The sample of EISs reviewed was limited to those
available in the InteREAM library of the University of East Anglia.
2.3 CRITERIA
The criteria to be used in the review are both quantitative and qualitative. The
quantitative criteria will give data from which questions can be raised for the second
stage of the methodology. The qualitative information will not be used to gain
quantitative values through allocation of scores, but to emphasise any key points or
provide examples in the discussion, and will also be used to inform the choice and
content of interview questions during the second stage of this review.
The system for analysis has drawn on such methodology as the Environmental
Statement Review Package (Lee & Colley, 1990) with regards to the type of criteria to
29
be used in the review. It is suggested by the authors that the criteria should be well
defined and unambiguous, be capable of reasonably consistent application and serve a
distinct purpose from that of other criteria (Lee et al., 1999). The criteria were devised
from the literature review’s identification of barriers and ways in which they may be
overcome and to collect basic data to provide a baseline as to what is presently
happening. Some categories have a degree of subjectivity to them due to the slightly
qualitative nature of some of the criteria and consideration of this is taken into account in
the analysis and discussion. The determination of criteria is an iterative process and
once the criteria were identified, the methodology was piloted on five EISs and critically
appraised, with use of the literature, to identify those criteria that would be in the final
methodology.
The criteria will be divided into categories to which a number will be assigned. The
numbers given to each of the categories of the criteria are not scores, but an indication
of the level or degree to which that particular criterion may fall. Overall, the data from the
EIS review is the result of a quasi-quantitative grading system and it is for this reason
that it can be used to emphasise key points in the discussion, as qualitative data, and
also play a role in the quantitative analysis. The positive aspects of this type of grading
system are that it enables simplistic analysis of results allowing for ease of transferability
to other EISs. However, due to this methodology not being used before, there may be
issues concerning its simplicity and whether the grading could or should be less
subjective. With regards to the criteria it may be argued that it should be expanded to
30
incorporate all issues that relate to SUDS but use of these criteria will enable
identification of baseline data to determine the current extent of SUDS consideration.
The criteria, their relevance to this research and their categorisation are illustrated in
Table 2.1 and Table 2.2.
2.3.1 DATA ANALYSIS
The analysis of data resulting from Part One comes from graphs and analysis of trends
from data, which will be relayed to the interviewee in Part Two of the review and used as
examples to illustrate and emphasise key points where necessary.
2.3.2 QUALITATIVE CRITERIA
The problems of quantifying language are numerous. With regards to the use of
language in the EISs, it was felt that any necessary notes be taken that may suggest
either commitment or a lack of commitment and used as examples for discussion
purposes. These are not restricted directly to the focus of SUDS or hydrology, however
must be relevant to the review and will, like other qualitative data, be used in the
interviews and in the discussion chapter to emphasise and illustrate key points.
It will be assumed that when information is not specified for a criterion, that this area has
not been considered or work has not been done. For example, if the number of SUDS
31
has not been specified in the EIS then it is assumed that consideration has not been
given to this criterion. This might not necessarily be true and it may be that SUDS were
considered, but rejected and not described in the EIS. However, it could be argued that
consideration of all elements in an EIA should be reported in the EIS due to it being a
publicly available report.
32
Table 2.1 – Criteria and relevance to research.
CRITERION
Relevance to Research Aims
Guidance
The type of guidance documents gives an indication to the degree of commitment of SUDS
documents
implementation in an EIS. The use of guidance, compulsory or voluntary, can have an affect on
the extent to which SUDS are considered, however, not all guidance is relevant to SUDS
implementation and those guidance which are promoted by organisations concerned with
hydrology, development and/or the environment are deemed to be of most value. As a criterion,
can be used to identify current practices, potential barriers, ways to overcome them and trends.
EA consultation
Consultation with EA, that actively promotes the use of SUDS techniques, implies a heightened
commitment to the use of SUDS techniques. As a criterion, can be used to identify current
practices, potential barriers, ways to overcome them and trends.
Contaminated
EA states that soakaways must not be constructed in contaminated ground (EA letter, 2003iv),
land assessment thereby mobilising contaminants and causing potential pollution to watercourses and/or
(CLA)
groundwater. Identifies current practices, potential barriers, ways to overcome them and trends.
Constraints
The acknowledgement of constraints that determine a change in use of SUDS shows that SUDS
have been considered within the context of the project design, such as spatial or financial
constraints. Identifies potential barriers.
33
SUDS type
EA (EA, 2003iii) categorise SUDS into what it refers to as ‘general methods’. This is because
some SUDS though similar in their processes are different in name; grouping them in this way
makes analysis less complicated. These techniques incorporate all infiltration techniques and for
the purposes of this review are given a number. The numbering for the type of SUDS does not
depict a level or grade but is a number used for identification (see Table 2.2). Multiple responses
can be recorded. Identifies current practice, baseline data and trends.
Number
Identifies current practice and baseline data.
Size
Identifies current practice and baseline data.
Efficiency
Identifies current practice and baseline data.
Maintenance
Identifies current practice, baseline data, potential barriers, ways to overcome them and trends.
Additional
practice
good Due to runoff being a potential problem during construction and demolition, this criterion is
designed to determine how an EIS considers the mitigation of water quality and quantity.
Identifies current practice, potential barriers and ways to overcome them.
34
Table 2.2 – Criteria categorisation.
CRITERION
Categorisation
Guidance
0 - Guidance documents not specified.
documents
1 - Standard Government Guidance, not specifically concerned with hydrology.
2 - Relevant government Planning Policy Statements (PPS) concerned with hydrology and water
as a natural resource. Specifically, PPS 1: Delivering Sustainable Development, PPS 23:
Planning and Pollution Control and PPS 25: Development and Flood Risk.
3 - Use of Environment Agency, CIRIA or Centre for Ecology and Hydrology (CEH) Guidance.
EA consultation
0 - EA consultation not specified.
1 - EA consultation i.e. use of documents, records, reports, telephone conversations and other
correspondence.
Contaminated
0 - CLA not specified and not included in analysis due to no knowledge of contamination at site.
land assessment 1 - CLA through desktop survey only.
(CLA)
2 - Desktop and site survey.
Constraints
0 - Constraints not specified.
1 - Acknowledgement of constraints.
35
SUDS type
1 - Permeable surfaces: porous paving
2 - Filter strips and french drains
3 - Swales and soakaways
4 - Basins: dry ponds
5 - Ponds: permanent wet ponds
6 - Wetlands and reedbeds
Number of SUDS
0 - Not specified.
1 - Specified.
Size of SUDS
0 - Not specified.
1 - Specified.
Efficiency
SUDS
Maintenance
SUDS
Additional
practice
of 0 - Not specified.
1 - Specified.
of 0 - Not specified.
1 - Specified.
good 0 - Best practices not specified.
1 - Use of best practices.
2 - Evidence of Construction Environmental Management Plan (CEMP) or equivalent.
36
2.4 PART TWO: INTERVIEWS
The analysis of results from Part One of the review will raise questions that may only be
speculated upon through study of legislative requirements and the numerous and
differing policies of Statutory Authorities, Local Councils and consultants. This literature,
however, only gives a certain quantity of data and so interviews with relevant
stakeholders were deemed the best approach to enable questions both raised by the
Part One analysis and the relevant literature, to be posed. In doing this, a greater
understanding of the barriers and ways in which to overcome them can be identified with
greater confidence and a more detailed understanding.
Interviews will be conducted with the following stakeholders: statutory consultees;
decision-makers (County Council); and consultants (private consultancy firms). The
range of the stakeholders is hoped to give differing views in which exploration of areas
and issues that may concern that sector can be discussed to compliment the analysis of
Part One of the methodology. Five interviews are to be conducted with employees in
these different sectors, all having experience with SUDS. To avoid confusion and for
confidentiality purposes, the in sectors in which they are employed have been
generalised and the interviewees allocated a letter, as seen below:
•
Interviewee A – Consultant
•
Interviewee B – Consultant
37
•
Interviewee C – Statutory Consultant
•
Interviewee D – Water Company
•
Interviewee E – County Council Member
In accordance with Saunders et al. (2007), it is determined that this review falls into the
exploratory study status, where it is considered as a valuable means to finding out ‘what
is happening; to seek new insights; to ask questions and to assess phenomena in a new
light’ (Robson, 2002: 59). Its great advantage is that it is flexible and adaptable to
change and for this reason, the unstructured interview is the most frequent type of
technique to use for exploratory studies and consists of an informal interview to explore
in depth an area of interest. Its lack of predetermined questions enables the interviewee
the opportunity to talk freely about events, behaviour and beliefs in relation to the topic
(Saunders et al., 2007). However, due to this research having definate topic areas,
semi-structure interviews will be conducted so that the interviewees are guided through
the discussion, but can also be diverted where necessary into other areas of interest.
Interviews will be carried out via telephone and will hold the format of a discussion. Prior
to these interviews, background research into the organisation, Council or consultancy
firm will be carried out to determine, where feasible, an organisations stance on SUDS
use and to further mould any questions to direct discussion into the desired areas.
Contact with the interviewee will also be made prior to the interview and the general
topic of discussion and a list of the discussion topics made available. This will enable the
38
interviewee to be aware of the content of the discussion and save potential
embarrassment prior to the start of the interview. It must be remembered that semistructured interviews can give rise to psychological stress (Sewell, 1999) that can
influence their responses.
The interviews will be recorded, where possible, and notes will be taken for all
interviews. The data from the interviews will be analysed using what Kvale (1996) terms
ad hoc meaning generation. This most frequent form of interview analysis uses a
number of different approaches and techniques instead of one standard method. Such
methods employed in the analysis of these interviews will be what Miles and Huberman
(1994) term noting pattern, clustering and counting, all of which are used to determine
how much information there is and its categorisation. By transcribing the recordings and
using the methods described above, the interviews may be discussed with the data from
Part One of the review to identify barriers and ways in which they may be overcome.
Interview data will not be included in the results chapter but will be used, where
applicable, to highlight key points in the research, give insight into the future of SUDS
and where and how the main bodies responsible for their implementation are directing
their efforts. There is however a drawback of this technique of interview analysis and
that is the use of only one analyst. Kvale (1996) states that by using several analysts for
interpretation of the same interviews, a certain control of haphazard or biased
subjectivity is possible.
39
CHAPTER 3: RESULTS AND ANALYSIS
Analysis of the results of the EIS review will determine any trends that may influence the
extent to which SUDS are considered in EIA. The principles areas of focus will be on the
extent of SUDS consideration when applied to the following variables: time, use of
guidance documents, level of EA consultation and contamination issues.
A total of 80 urban infrastructure development EISs were reviewed to determine the
extent to which SUDS are considered. 10 different type of development where reviewed,
all within the remit of urban infrastructure developments. 40 EISs (50%) made mention
of SUDS within the development and of this number, 9 (23%) mentioned how many
SUDS were to be incorporated, 17 (43%) provided information relating to the expected
efficiency of the considered SUDS and only 5 (13%) gave consideration to the
monitoring and maintenance of the SUDS if the development was implemented. Design
constraints that may influence the consideration of SUDS, either positively or negatively,
numbered only 6 (7.5%) of the total 80 EISs reviewed.
More encouragingly, 67 (84%) EISs used some sort of guidance documentation, while
58 (73%) conducted consultations with EA. Regarding CLAs, 44 (55%) EISs undertook
both a desktop and site survey, 13 (16%) undertook a desktop survey only and 23 (29%)
had no provision concerning CLA. The type of SUDS most considered were types 3 and
40
5, swales and wet ponds, respectively, totalling 58% of all SUDS considered in the EISs
where either swales or wet ponds.
3.1 DEVELOPMENT TYPE
All EISs reviewed were urban infrastructure development. Table 3.1 summarises the
development types, how many were reviewed and a description of them, as stated by
the Town and Country Planning (Environmental Impact Assessment) (England and
Wales) Regulations 1999.
Table 3.1 – Development types and descriptions.
Development
Type
2.1c
2.2a
2.10a
Total
number
3
3
3
2.10b
48
2.10c
2
2.10d
2.10eii
2.10f
2.11b
2.12a
2
7
10
1
1
Description
Intensive livestock installations; exceeds 500 m²
Quarries, open-cast mining and peat extraction
Industrial estate development projects; exceeds
0.5 hectares
Urban development projects, including shopping
centres, car parks, sports stadiums, leisure
centres and multiplex cinemas; exceeds 0.5
hectares
Construction of intermodal trans-shipment
facilities
Construction of railways; exceeds 1 hectare
Construction of airfields; exceeds 1 hectare
Construction of roads; exceeds 1 hectare
Installations for the disposal of waste
Ski-runs, ski-lifts and cable-cars and associated
development
41
3.2 PART ONE: EIS REVIEW
The raw data from the EIS review was analysed to determine any potential relationship
between variables. The results below identify any potential trends, or lack thereof, that
will be used in Part Two of the methodology (see Chapter 2: Methodology). Part One will
attempt to identify any trends over time and the effects that guidance, EA consultation
and contamination aspects may have on SUDS, which help illustrate the extent of their
consideration in the reviewed EISs.
3.2.1 ANALYSIS OF TRENDS OVER TIME
The number of EISs reviewed differs with each year. The analysis of any trends over
time compares the potential influences of time on the main criteria, use of guidance
documents, EA consultation and contamination aspects, type of SUDS, additional
indicators of good practices and monitoring/maintenance with the year of the particular
EIS. The results of the EIS review can be seen in Table 3.2.
42
Table 3.2² – Number of EISs and percentages of the use of guidance documents, EA
consultation and CLA over time.
Year
2000
2001
2002
2003
2004
2005
TOTAL
Total
number
EISs
4
7
6
23
34
6
80
Guidance
of documents
used
2 (50%)
3 (43%)
5 (83%)
19 (83%)
32 (94%)
6 (100%)
67 (84%)
EA
consultation
undertaken
2 (50%)
3 (43%)
5 (83%)
18 (78%)
26 (76%)
4 (67%)
58 (73%)
Contaminated
land assessment
undertaken
2 (50%)
2 (29%)
3 (50%)
17 (74%)
30 (88%)
3 (50%)
57 (71%)
Use of guidance documentation increases greatly from 2001 to 2002, almost doubling
the number of EISs that use it from 3 to 5, however these numbers are small. The use of
guidance documents in the later years is more encouraging, most notably the year 2004,
where 32 of the 34 EISs reviewed used some form of guidance documentation (94%).
This trend is similar to that of EA consultation, where there is a large increase in EA
consultation undertaken from 2001 to 2002. The years 2003 and 2004 show more
encouraging figures of 18 (78%) and 26 (76%) EISs undertaking EA consultation,
²The ‘average percentages’ for the criteria in the table using ‘year’ as a variable differ to that of the ‘total
averages’ of all EISs, as seen by the figures at the start of this chapter . The ‘average percentages’ are
not included in table 1, only the ‘total averages’. The ‘total averages’ are the figures by which the rest of
the analyses are based upon.
43
respectively, due to the higher numbers of EIS reviewed in these years. CLA once again
shows similar trends of an increase in their undertaking over time, until 2005. This may
be due to the small number of EISs reviewed in this year; a look at the figures for the
years 2003 and 2004 show a better representation of the review that suggest an
increase of CLAs over time.
More in depth analysis of the use of guidance documents can be seen in Figure 3.1.
Figure 3.1 illustrates the use of guidance documents from 2000 to 2005. The main
aspects to focus on are the decrease in guidance documents category 0 (no use of
guidance) to zero by 2005 and the increase of guidance notes category 3 (use of EA,
CIRIA or CEH guidance) from 2002 through to 2005. The years 2000 and 2001 show the
same categories of guidance documents used in the EISs and similar numbers. The
most noticeable difference between these years and all later years is the drop in EISs
using no guidance notes and the large increase in the use of category 3 guidance
documents.
44
Figure 3.1 – Use of guidance documentation over time.
Guidance
Category 0 - No
guidance used
Category 1 Standard Government
Guidance, not
specifically
concerned with
hydrology
Category 2 - Relevant
government
PPG/PPS concerned
with hydrology
Category 3 - Use of
EA, CIRIA or CEH
guidance
Year vs Guidance Documents
0.60
Mean Proportions
0.50
0.40
0.30
0.20
0.10
0.00
2000
2001
2002
2003
2004
2005
Year
Analysis of the use of EA consultation shows there is a steady increase in use of
consultation through the period from 2000 to 2004, however in 2005 this trend drops
slightly from 26 in 34 EISs (76%) to 4 in 6 EISs (67%) consulting EA. This could be due,
in part, to the much smaller numbers of EIS reviewed compared to the years 2003 and
2004, where 18 (78%) and 26 (76%) EISs show evidence of EA consultation.
45
2000 and 2005 figures in Table 3.3 show identical CLA proportions; half had no form of
CLA (category 0), and half had an on-site contaminated land audit (category 2). The
interesting area are the middle years, from 2001 to 2004, in which there is an almost
direct relationship between categories 0 and 2; as the number of EISs conducting no
CLA decreases, those doing both desktop and on-site surveys increases in a fashion
similar to inverse proportion. There seems to be a direct jump in EISs conducting no
contamination assessment to EISs conducting both desktop and on site surveys, with no
gradation through category 1, as seen in bold in Table 3.3. There is no discernable trend
in terms of increase or decrease of CLA over time, except a slight in crease in CLA
category 2; the only trend is the consistency of the low CLA category 1 figures
throughout the years.
Table 3.3 – Contaminated land assessment (CLA) over time.
Year
CLA category 0:
No CLA undertaken
2000
2001
2002
2003
2004
2005
2 (50%)
5 (71%)
3 (50%)
6 (26%)
4 (12%)
3 (50%)
CLA category 1: CLA
through
desktop
survey only
0 (0%)
0 (0%)
1 (17%)
5 (22%)
7 (21%)
0 (0%)
CLA category 2:
Desktop and site
survey
2 (50%)
2 (29%)
2 (33%)
12 (52%)
23 (67%)
3 (50%)
46
All categories of additional good practice show slight variations from year to year, both
increases and decreases, but their erratic nature show that there were no trends evident
in the relationship between the use of additional good practices over time.
Other analysis included the type of SUDS used over time. This did not show any trends,
only that types 3 and 5, swales and wet ponds were considered more than the other 4
types of SUDS.
3.2.2 SUDS CONSIDERATION AND THE INFLUENCES UPON THIS
This stage of analysis focuses on the effects that guidance documents, EA consultation
and contamination aspects may have on the SUDS criteria that illustrate the extent of
SUDS incorporation into EISs. The extent to which SUDS are considered in this
research, depends on which categories each of criteria in the EIS meets. For example, if
an EIS considers SUDS then further analysis into this area can be done to determine
number, size, type or monitoring/maintenance, however, that is not to say that without
consideration of SUDS there is no more analysis. This ‘absence’ of SUDS is also useful
in the determination of trends and gives a more thorough analysis than if consideration
were given in all EISs enabling trends in EISs where SUDS are not considered.
47
In this section the focus will be on the how the presence or absence of guidance
documentation, EA consultation and contamination may affect the use of SUDS before
attempting to determine whether a relationship between them exists.
3.2.2.1 GUIDANCE DOCUMENTATION
The relationships between use of guidance documents and SUDS incorporation looks at
how guidance may affect the type of SUDS considered and the procedures followed on
contamination assessment and additional good practice.
An initial grouping of guidance and SUDS consideration reveals immediately and
conclusively that there is a definite relationship between the two. The analysis of
guidance documents relationship to consideration of SUDS show that with the use of
guidance, 44% of EISs considered SUDS and 40% did not consider SUDS. This is
compared to the EISs that did not use guidance; those which considered SUDS
amounted to just 6% and those which did not, 10%.
When the data for SUDS type are amalgamated for each of the guidance categories
using only EISs that used guidance documents, the results show a greater consideration
of swales and wet ponds. Swales were considered in half of the EISs (20) that
considered SUDS (50%) and wet ponds in 22 EISs (56%). Conversely, of the 40 EISs
that mention incorporation of SUDS, only 6 (15%) included neither swales nor wet ponds
48
in their consideration. It should be mentioned that this was not the trend when guidance
was not used. In this case the most popular type of SUDS were wet ponds, at 44%.
Wetlands were not considered at all and swales were considered equally with as the
others at 14%. This may mean that there is no trend between the use of guidance
documents and the type of SUDS considered. Analysis of this trend will be expanded
upon in the discussion along with the analysed interview data.
Figure 3.2 shows the consideration of SUDS in EISs according to the type of guidance
used. Overall, there is an increase in the number of SUDS consideration from category 0
to 3, suggesting that guidance increases the consideration and incorporation of SUDS
into EISs. However, categories 1 and 2 do not support this trend and other factors may
be influential in determining the extent to which SUDS are considered.
The analysis of guidance documents against additional good practice reveal trends
suggesting that the higher the category of guidance documentation the greater the
number of EISs incorporating additional good practices.
Additional good practices,
category 0 (no best practices) decreases from 66% to 17% from guidance category 0
(no guidance) to 3 (use of EA, CIRIA or CEH guidance), whereas additional good
practices, category 1 (use of best practice) increases from 32% to 85% through
categories 0 to 3.
49
Figure 3.2 – Guidance vs. SUDS consideration/incorporation.
0.80
Guidance vs SUDS incorporation
SUDS
Category 0 - SUDS
not considered
Category 1 - SUDS
considered
Mean Proportion
0.60
0.40
0.20
0.00
Category 0 - No
use of guidance
Category 1 Standard
Government
Guidance, not
specifically
concerned with
hydrology
Category 2 Relevant
government
PPG/PPS
concerned with
hydrology
Category 3 - Use
of EA, CIRIA or
CEH guidance
Guidance
3.2.2.2 ENVIRONMENT AGENCY CONSULTATION
The results of the analyses for identifying how the use of differing levels of EA
consultation may influence SUDS incorporation and consideration in EIA show similar
trends as that of the use of guidance documentation.
50
The use of EA consultation shows the same trend to the guidance document criteria
when analysing the number of EISs that consider SUDS to those that do not consider
SUDS. The analysis of EA consultations relationship to consideration of SUDS show
that with the use of EA consultation, 39% of EISs considered SUDS and 34% did not
consider SUDS. This is compared to the EISs that did not use EA consultation; those
that considered SUDS amounted to just 11% and those which did not, 16%. This is
shown more clearly in Table 3.4.
Table 3.4 – SUDS consideration with and without guidance and EA consultation.
With guidance documents
No guidance documents
SUDS considered
35 (44%)
5 (6%)
No SUDS considered
32 (40%)
8 (10%)
With EA consultation
No EA consultation
31 (39%)
9 (11%)
27 (34%)
13 (16%)
As with guidance documents, the same trend exists between EA consultation and type
of SUDS considered. Where no EA consultation was undertaken SUDS types 3 and 5,
swales and wet ponds, were considered more often that the other 4 types, while use of
EA consultation show that swales and wet ponds were considered at, 51% and 55%,
respectively. Similar to guidance documents trends, swales or wet ponds were
considered in all but 5 of the 31EISs (16%) that had consulted EA when considering
51
SUDS. Table 3.5 shows the similarities between EA consultation and guidance when
determining type of SUDS, the relevant figures highlighted in bold.
Table 3.5 – Type of SUDS with and without guidance and EA consultation.
Guidance
used
No guidance
used
Undertaking
of
EA
consultation
No
EA
consultation
undertaken
Average
total (%)
Porous
paving(1)
10 (13%)
Filter
strips (2)
9 (11%)
Swales
(3)
23 (29%)
Dry
ponds(4)
7 (9%)
Wet
ponds (5)
22 (27%)
Wetland
(6)
9 (11%)
11 (14%)
11 (14%)
11 (14%)
11 (14%)
36 (44%)
0 (0%)
9 (11%)
9 (11%)
20 (26%)
9 (11%)
22 (28%)
11 (14%)
17 (20%)
11 (14%)
26 (33%)
0 (0%)
26 (33%)
0 (0%)
47 (15%)
40 (10%)
80 (20%)
27 (7%)
106
(27%)
20 (5%)
Figure 3.3 shows the consideration of SUDS in EISs with and without EA consultation.
Overall, there is an increase in the number of SUDS consideration with EA consultation,
from 23% to 77%, suggesting that their consultation increases the consideration and
incorporation of SUDS into EISs. This suggests that EA consultation encourages SUDS
incorporation in developments as well as their absence of incorporation due to other
variables. As with guidance documents, EA consultations influence on SUDS
consideration may have other factors that influence their implementation in design.
52
Figure 3.3 – EA consultation vs. SUDS consideration.
EA consultation vs SUDS consideration
1.40
SUDS
Category 0 - SUDS
not considered
Category 1 - SUDS
considered
Mean Proportion
1.20
1.00
0.80
0.60
0.40
0.20
0.00
Category 0 - No EA
Category 1 - EA
consultation undertaken
consultation undertaken
EA_Consultation
The analysis of EA consultation against additional good practices reveal trends that
suggest EA consultation increases the number of EISs incorporating additional good
practices. Additional good practices, category 0 (no best practices) decreases from 45%
to 33% from EA consultation category 0 (no consultation) to 3 (consultation), whereas
additional good practices, category 1 (use of best practice) increases from 55% to 62%
through 0 to 3. Additional good practice category 3 (use of CEMP or equivalent) shows a
rise from 0%, with no consultation, to 5%, with consultation. There is not an obvious
53
trend here, although it strengthens the case for the potential relationship between
guidance documents and best practice. A comparison between the relationships
between guidance document and EA consultation with additional good practice can be
seen in Table 3.6.
Table 3.6 – Additional good practices with and without guidance and EA consultation.
Best
practice
category 0
No Guidance
62%
With Guidance
31%
No EA consultation
45%
With EA consultation 33%
Best
practice Best
practice
category1
category 2
38%
0%
65%
4%
55%
0%
62%
5%
3.2.2.3 CONTAMINATION ASPECTS
The results of the analysis for identifying how criteria, concerned with aspects of
contamination (contamination land assessment and presence of contamination), may
influence SUDS incorporation and consideration in EIA are illustrated below.
The presence or absence of contamination and consideration of SUDS can be seen in
Table 3.7. The relevance of these results, the questions is raises, together with the
analysis of the interviews will be explored in the discussion.
54
Table 3.7 – Consideration of SUDS with and without contamination of land.
Contamination
with SUDS
16%
Contamination
without SUDS
38%
No contamination No contamination
with SUDS
without SUDS
25%
21%
When analysing the data to determine a relationship between contamination of land and
type of SUDS considered, the same trends as previously seen give added weight to the
use of particular SUDS type and are discussed in the next chapter. SUDS types 3 and 5,
swales and wet ponds, are considered in 28% and 32% of EISs, respectively, regardless
of contamination presence or absence. As with EA consultation and guidance analyses,
swales and wet ponds are considered in most EISs that consider SUDS. Those that did
not consider either swales or wet ponds are 12% where no contamination is present and
17% where contamination is present.
The relationship between CLAs and presence of contamination shows that where there
is only a desk survey conducted for a CLA only 33% of EISs are identified as having
contamination. This is very different to those EISs that have both desk and on site
surveys, where 67% of EISs were found have contaminated land (see Figure 3.4).
55
Figure 3.4 – Contamination land assessment (CLA) vs. contamination.
1.20
Contaminated Land Assessment vs Contamination
Mean Proportion
1.00
Contamination
Category 0 Absence of
contamination
Category 1 Presence of
contamination
0.80
0.60
0.40
0.20
0.00
Category 1 - Desk survey Category 2 - Desk and on
conducted
site surveys conducted
Contaminated Land Assessment
COMMITMENT IN LANGUAGE
The EISs that show most commitment use different language. Instead of using phrases
and words such as ‘could’, ‘where feasible’, ‘[SUDS] are being discussed’ or ‘ground
conditions may be suitable’, they use more direct and assertive language: ’purest
example of SUDS’, ‘principles of sustainability applied at all stages’, ‘[SUDS] will form an
integral part’, ‘will be designed’ or ‘will incorporate SUDS’. This positivity is inspiring,
especially in the face of such guidance as seen in the Department of Transport Traffic
56
Analysis Guidance (TAG) (2003) that states the use of mitigation solely for the purpose
of reducing impacts of highway drainage on surface water quality is unnecessary.
It can be said that after reviewing and taking notes of the 80 EISs that only 6 (less than
8%) were regarded as good by the author, in terms of the extent of their consideration of
SUDS.
57
CHAPTER 4: DISCUSSION
This discussion will use the trends analysed from the results, the interview transcripts,
extracts of the EISs taken during the review and the literature in an attempt to critical
analyse the consideration of SUDS in the Environmental Impact Assessments (EIA) of
urban infrastructure developments in England. Discussion of trends in the EIS review will
further highlight the current practices and consideration of SUDS in the EIA process.
This will allow for the illustration of drivers that assist in the implementation of SUDS
and, with the interview data, help identify areas that act as barriers towards SUDS
consideration and implementation. Through the analysis of the procured research data,
ways in which any barriers may be overcome will be suggested as a remedy to any
inadequate elements of current practice.
4.1 BARRIERS AND DRIVERS IN THE EIS REVIEW
The analysis seen in the previous chapter show that there are positive trends over time
identifiable from the EIS review. The level of guidance documentation, the use of
consultation with the Environment Agency and number of CLAs increase from the period
of 2000 to 2005. The increase in these variable factors also appear to promote the
consideration of SUDS however, no one factor is the main reason for the increase in
their consideration; they appear to be influencing and complimenting one another.
58
The use of guidance documents and EA consultation showed the same trends, namely
the increase in SUDS consideration, yet consideration should be applied to EISs where
SUDS were apparently not considered. Because SUDS are not incorporated into a
design it does not mean they were not considered; the EA (2003i, 2003ii, 2003iv) state
that where land contamination occurs, infiltration systems, like SUDS, should not be
incorporated. This decreases the risk of mobilising any contaminants and potentially
polluting groundwater and watercourses and it is due to this contamination issue that
more SUDS are not incorporated into new developments. From the data analysis the
use of guidance documents and EA consultation show a far greater percentage of EISs
that appear to consider SUDS. Some EISs give examples of where contamination has
constrained the use of SUDS, giving further support to the analysed data that show a
link between these factors.
But the issue of contamination, in this case, is slightly ambiguous. The degree to which
the CLA is conducted seems to determine greatly the discovery of contamination
presence. CLAs conducted using only desk surveys show considerably less sites with
contamination than CLAs that had both desk and on-site surveys. This may be due to a
desk survey showing no contamination; therefore no on-site survey is needed. However,
this is not specified in the EISs and the fact that some of the ‘desk only surveys’ detect
contamination and a vastly greater percentage of surveys conducting on-site survey
detect contamination suggest that some sites that shown no contamination from the
desk survey may, in fact, be contaminated.
59
This research is concerned with the consideration of SUDS and although SUDS may not
be implemented due to contamination on a site, its consideration is paramount to
determine the best possible solution at a development. If guidance documents, EA
consultations and CLAs influence SUDS consideration it shows that these criteria are
definite drivers for their consideration into new developments. However, because use of
guidance documents and EA consultation seem to influence CLA it can be said that they
are the more influential drivers for SUDS consideration. But it must be remembered that
the degree to which a CLA is undertaken may have an influence on how much
contamination is found and that CLA may be influential not only in SUDS consideration
but their implementation too, more so, in some respects, than guidance documentation
and EA consultation.
4.2 BARRIERS AND DRIVERS IDENTIFIED IN INTERVIEWS
The information gathered from the interviews helped identify several barriers and ways
in which they could be overcome, however, when discussing current practices some
discrepancies occurred.
As an aspect of EIA, SUDS are considered separately and both recommended and
required for consideration by the Environment Agency. In instances where a published
assessment (an EIS) is required, the EA need to have specific information in relation to
60
how to deal with surface water and dealing with it at source is imperative, which is
becoming easier with more widespread technologies and better integration of SUDS
techniques. This is not evident from the EIS review, where two types of SUDS were
considered, swales and wet ponds. Interviewee A states that these SUDS are more
commonly suggested and implemented due to swales being cheap and working well and
wet ponds have an aesthetic appeal which can enhance a development and are lowtech solutions. Interviewee C gives another view that developers prefer not to have a
large grassed ditch in which litter may collect on their development. Based on the
literature and the conducted interviews it seems likely that both arguments are correct;
some developers may want open spaces to sell properties at a premium while other
want to use all available space without the implementation of SUDS. This would
therefore mean that aesthetics could be regarded as a barrier to SUDS implementation,
depending on the developer; there have been cases of developers using contamination
as a get out clause so as not to consider SUDS in the design (Interviewee C). Perhaps a
more strategic approach is then required to overcome this. At present, consideration of
SUDS is being carried out at the project level (Interviewee D), but if this is also
dependant on other factors, for example the desire of SUDS implementation by the
developer, then this suggests that all strategy is forgotten and SUDS consideration may,
in some cases, rely upon human preferences, as opposed to the EIA process.
Currently, EA are involved in promoting the use of SUDS within the strategic flood risk
assessments of local authorities on a project specific basis and will object to any
61
development greater than one hectare that does not have a SUDS scheme implemented
on them; this includes retrofitting and the inclusion of historic sites drainage into new
developments or the extensions of existing ones. Encouragement from EA is evident
through comments from Interviewee E who states that SUDS are now being considered
from the very start of a development proposal. This is something which is seen as a
barrier to the implementation of mitigation measures, yet one which can be overcome,
as seen in chapter one where CPRE (2004) state that EIA, in theory, can help ensure
environmental implications of a new development can be fully explored before planning
decisions are made.
Interviewee D states that although not a statutory consultee, Water Companies are often
consulted. They too request the implementation of SUDS as part of mitigation measures
for potential flood risk and promote their use where technically feasible. Once resisted,
SUDS are now seen as part of high performing environmental housing and are evident
in the growing appetite for their implementation. This is where the first discrepancy lies.
This appetite for inclusion of SUDS in housing is contradicted by an Interviewee B who
states the opposite, that there is not much desire, specifically in commercial and
residential developments, to incorporate SUDS; it is instead being driven by its
incorporation into policy. This is supported by both Interviewees A and C.
However, this appetite or desire that Interviewee D refers to is compounded by what all
interviewees regard as one of the largest barriers to SUDS implementation in new
62
developments: adoption and maintenance, not a political or technical barrier, but one of
practicality. Interviewee A believes that adoption at present is so problematic due to
planners and developers do not give enough attention at the initial stages, they do not
consider the implications of SUDS and do not talk to the potential adoptive authority
quickly enough. While, both Councils and Water Companies are not always keen to
adopt SUDS (the Water Companies concern themselves with management of pipes and
water treatment works) they do not want a private company to adopt them either due to
security reasons. If the company goes bankrupt the SUDS will be left unmaintained,
something which Interviewee C says developers use to avoid consideration of SUDS.
Presently, the cost of maintenance is something that cannot be calculated at the
moment and so looking at the long term, no one can envisage how much they will cost
to maintain. Interviewee B states that all SUDS schemes implemented by their
consultancy have been adopted by local authorities and a contributing sum paid by the
developer to assess and maintain them, although no figure was given.
Interviewee A suggests to overcome this barrier would be the use of regulations that tie
the developer into maintenance issues much more strongly and can produce a
mechanism to recover money for maintenance. Interviewee B suggests that what is
needed is a more coherent dialogue between authorities to ensure there is a procedure
by which SUDS are assessed on a site-specific basis (something which the EA are
currently involved in). Assessment of a best adoption procedure for the management of
the SUDS will then reduce the likelihood of the taxpayer being charged. Interviewee C
63
expands on this, stating that if the local authorities or the Water Companies were made
to adopt SUDS then there would be a mechanism in place for their adoption and
maintenance, however, for a solution such as this it must surely come from central
government, something which may take a long time. One interviewee disagrees,
suggesting adoption should not be on the principle of ‘one size fits all’, but of what is
right in that specific context; one organisation may prefer adoption of a particular type of
SUDS, something that can be identified through close communication.
This idea of communication amongst all authorities is held, to some degree, by all
interviewees. This need for a change in thinking and to integrate thinking and
communication, must come at the right time in the spatial planning process, the earlier
the better, to avoid what Interviewee D calls implementation of ‘tactical SUDS’ for
cosmetic purposes that are not efficient at managing large surface water issues. At
present there is no legislation to force SUDS to be put in at the planning stage of a
development and Interviewee A believes that Councils have to define which SUDS they
will adopt and which the Water Companies will adopt, however although Interviewee A
believes this to be a straightforward solution, they understand that local authorities do
not have the resources. This barrier gives rise to a suggestion for financial mechanisms
to be implemented that allow others to adopt SUDS, such as the Wildlife Trust or private
companies, something which Interviewee A also regards as implausible due to reasons
of financial security, as previously stated.
64
Interviewee D goes further suggesting that what is needed is an incorporation of
authorities and organisations with the goal of implementing a SUDS scheme on such a
scale that it incorporates all developments of a specified area, a landscaped SUDS
scheme, which will be able to cope with large storms and will be much more economical
viable to maintain, as seen in Milton Keynes. There are other benefits for such SUDS
schemes: nature reserves, wildlife value and amenity value. These landscaped SUDS
are developed through water cycle studies that determine where water comes from and
how it can be managed. By planning SUDS at a more strategic level the solution will be
more strategic and therefore more robust (Interviewee D); but while water cycle studies
are being implemented in several Councils covered by the interviewed Water Company,
the emphasis is currently on flood risk, however there is an appetite and a political will to
build large scale SUDS (Interviewee D).
Communication between authorities would reduce the restrictive effect of another barrier
that was raised during the interviews, the issue of common practice. EA and adopting
authorities do not have a common practice on the best way to resolve the issue of
surface water drainage resulting in conflicting views in spite of Central Government
having a common view. This, once again, can be solved through greater communication
to ensure best common practice is used.
It must be remembered that the EIS is not the final word on the final design of a
development and consideration of SUDS within them does not necessarily mean they
65
will be implemented in the development. When asked how many SUDS that are
considered in an EIS make it into the final development, the interviewees gave varied
answers. While most could not give a figure, two interviewees had very different
responses. Interviewee C stated that as constraints mount up SUDS are one of the first
things to be omitted from the design whereas Interviewee B adamantly stated that 100%
of SUDS in an EIS are implemented into the final development. This was followed with
the statement that ‘if it can be achieved, it must be achieved. It’s a government
requirement and you’ll find that EA will object to every planning application if that [SUDS
scheme] is not tried in the first instance.’ EA appear to be both a significant driver and a
way to overcoming the lack of consideration of SUDS as is evident through their current
practices of involving themselves with County Councils and their stiffening regulations.
This is further supported by Interviewee C’s statement that the EA have never gone to
appeal with a developer due to a SUDS scheme. This suggests that a satisfactory
solution between the developer and the EA is reached. This may be due to the
regulations imposed on developers, an increase in communication, or both; whatever
the case, it is not without its constant conflicts and battles (Interviewee C).
4.3 CONSIDERATION OF EISs
The data from the EIS review includes the use of language providing an impression of
the degree of commitment that is given to SUDS inclusion in a development. Due to the
subjectivity of language and the problems in quantifying it (Sloman, 1969) it is only
66
discussed here to illustrate how language can influence the degree of commitment
through consideration or mention of SUDS.
Where one EIS states ‘drainage will be controlled through specific design elements’,
implying the use of SUDS, there was no mention of SUDS. This may be due to
consideration being focused on groundwater and their contamination or risk of flooding
as is the case in on EIS where the lack of adverse impacts of flooding cause the EIS to
have no mention of SUDS or runoff. This absence of consideration of SUDS is by no
means common (15% of the EISs reviewed had no mention of SUDS and some did not
have a hydrology or drainage section, while others were extremely vague in their details
of SUDS), however, a lot of positive considerations were identified. The understanding
that dilution of pollution can have a negative impact on biodiversity is apparent, where
one EIS states the need to keep ‘clean’ runoff from roofs separate; another states that
SUDS may cause erosion of a cliff-face while others use SUDS technologies already
present at a site. Yet the majority of EISs rejected the implementation of SUDS on
contamination issues. When considering the implications of contamination it seems
there is some benefit for the developer, in that they do not have to consider SUDS. In
most cases this appears to be legitimate, one EIS stating that contamination may
become mobilised and run directly into the nearby Nature Reserve and continues by
stating the benefits of hardstanding impermeable surface as removing potential
contamination pathways that presently exist. Use of contamination in this way has been
used by developers in the past, as has been discussed earlier in the chapter, and this
67
barrier, alongside the others identified, are all reflected in the inadequacy of
consideration given to SUDS as illustrated in this research.
68
CHAPTER 5: CONCLUSION
The aim of this research was to determine the extent to which SUDS are considered in
EIA. This was done by identifying the state of current practice, barriers for the
implementation of SUDS and ways in which these barriers may be over come. The EIS
review showed that with the use of guidance documentation and/or EA consultation
SUDS were considered to a greater extent, however, not always incorporated within the
development (as stated by the EIS) due to other factors such as presence of
contamination at the site. It is supposed that the greater the degree of guidance and/or
EA consultation the more thorough the EIA is in areas such as contamination. Yet in
EISs where sites are contaminated and possibly unsuitable for SUDS, this is seldom
mentioned; whereas some EIS make absolutely no mention of hydrological baseline
data or potential environmental impacts, this begs the question ‘were SUDS actually
considered?’ This may be a fault in the way an EIS is produced and as a publicly
available document that is open for appeal; they should be made comprehensive
(Glasson et al., 1999).
The main barriers to SUDS consideration and ultimately, implementation identified
through this research are adoption, maintenance, developers and lack of communication
at the wrong stages of the EIA process. To overcome the adoption and maintenance
barriers there needs to be what one interviewee calls best adoption procedures and
mechanisms to enable money to be recovered from developers and authorities to pay
69
for the maintenance of SUDS. Greater integration and communication between all
authorities and stronger regulations that tie the developer into maintenance issues also
need to be implemented, however, these procedures would have to come from central
government, something that could take many years. What makes this more difficult is
the present focus on flood risk and not on water quality.
The lack of desire of some developers also reduces the consideration given to SUDS.
Some developers use contamination issues as a get out clause, either to use all
available space on a site or to save them the difficulties of adoption and maintenance.
However, this is not always the case and in many instances developers implement
SUDS for aesthetic reasons and are happy to pay a sum for their future maintenance.
Yet the sum that should be paid is difficult to calculate and adds to the reasons why
adoption and maintenance can be so problematic.
In current practice there is still some struggle between the Environment Agency and the
developers, something which could be overcome by looking at a more strategic solution
such as large scale SUDS that incorporate all developments, such as is seen in Milton
Keynes. Strategic solutions and relevant legislation from central government would
enforce requirements and regulations to be met by the developer, and met at the correct
time of the EIA and design processes thereby increasing consideration of SUDS. Yet
this solution does not look at SUDS implementation on a site-specific basis, something
that the Interviewee C necessitates.
70
There appears to by some disagreement in the ways to best overcome these barriers,
however one thing is clear. With the growing appetite and political will towards SUDS
consideration and other associated aspects of the hydrological environment there is a
need for more communication and integration at both the higher strategic level (to
enable ease of adoption and maintenance) and at the correct times in the EIA and
planning processes by all authorities: statutory consultees, developers, Water
Companies, consultants, NGOs and private companies.
71
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