A short summary document that signposts developers to the legislation, policy and technical information required when submitting Flood Risk Assessments and drainage strategies to the
Lead Local Flood Authority as part of a Planning Application flood.management@newcastle.gov.uk

Newcastle SuDS Guidance for Developers
1.0
Introduction
1.1 This is a general guidance document for developers that will give context to the current situation regarding the delivery of sustainable drainage systems (SuDS) in legal and policy terms, and how the delivery of SuDS fits in with the planning and adoption process. It will set out and signpost flood risk management and SuDS design principles and comment on funding and maintenance issues.
2.0
Legislation and Policy
2.1 Under the Flood and Water Management Act 2010 , Newcastle City Council (NCC) is designated as the Lead Local Flood Authority (LLFA) and employs a team to provide advice to stakeholders and deal with surface water management issues in the City.
2.2 Following a Written Statement (HCWS161) made by the Secretary of State for
Communities and Local Government, the LLFA is now a statutory consultee on planning applications for major developments in relation to surface water drainage. The LLFA will work with the Local Planning Authority (LPA) at NCC to apply the National Planning Policy
Framework (NPPF) which stipulates that planning applications must contain an assessment of flood risk and water quality, and Planning Practice Guidance that advises on how planning can take account of the risks associated with flooding in plan-making and the application process.
2.3 Other risk management authorities, as designated by the F&WM Act, that operate as key partners for the LLFA in managing flood risk are:
The Environment Agency (EA), which is responsible for managing flood risk from main rivers. In Newcastle this is the Tyne and the Ouseburn. [Note: the LLFA is responsible for managing local flood risk and will provide advice on issues concerning surface water runoff, groundwater and ordinary watercourses].
Northumbrian Water Ltd. (NWL), which is responsible for maintaining the public sewerage system and managing flood risk from it.
2.4 NCC and Gateshead Borough Council adopted their Core Strategy and Urban Core Plan in
March 2015. Policy CS17 states that “development will avoid and manage flood risk from all sources, taking into account the impact of climate change over its lifetime.”
It will achieve this by avoiding and managing flood risk to people and property; ensuring water supply and foul and surface water infrastructure are provided with adequate capacity; not adversely affecting water quality and, where possible, improving water quality; separating, minimising and controlling surface water runoff.
3.0 General Pre-Application Considerations
3.1 The LPA at NCC provide a comprehensive pre-application advice service
3.2 As flood risk and surface water management issues will influence the design of the development, it is important that they are considered in the pre-application enquiry, and at an early stage in the master planning process. The LLFA can give general advice on flood

risk issues as well as providing more detailed information on the requirements for a flood risk assessment and drainage strategy.
3.3 Developers should be aware of the aforementioned legislation and policy and are recommended to seek advice from NWL on the impact the development will have on the existing sewerage network, and the EA on flood zones and the criteria used to review flood risk assessments.
3.4 The LLFA may recommend consulting other internal bodies like Resilience Planning or
Environmental Health or external bodies like English Heritage or the Coal Authority.
4.0 Flood Risk Assessments
4.1 Newcastle City Council’s Strategic Flood Risk Assessment (SFRA) comprises relevant data, guidance and recommendations for flood risk issues at a local level. It has been used as a planning tool so the LPA can carry out Sequential and Exception testing, enabling it to select and develop sustainable site allocations at lower risk of flooding.
4.2 The SFRA, together with the EA flood zone maps, identify areas at risk of flooding from all sources. Policy CS17 builds on this with the aim of avoiding flood risk to people and property where possible and managing flood risk through location, layout and design, taking into consideration the impacts of climate change, as identified in the SFRA.
4.3 A site specific Flood Risk Assessment (FRA) will be required in flood risk areas to show that the development itself is not at risk of flooding and that there is no increase in flood risk elsewhere as a result of the development.
Validation requirements for planning applications in Tyne and Wear sets out when a FRA will be necessary (see Appendix A – National and Local Validation Requirement Notes to accompany checklists, s15). An application will require a drainage assessment for all major development to assess the suitability for SuDS.
4.4 Further guidance for developers on requirements for FRAs is available in the NPPF at para.
102 and the SFRA at 2.1.1. An Environment Agency Guidance Note on FRAs is also available.
4.5 Note LLFA checklist Form 1b for review of FRAs. [Appendix A]
5.0 Drainage Assessment
5.1 A drainage assessment will be required for major development at the pre-application stage to ensure the drainage hierarchy has been followed (CS17.4) and that the development drainage has been designed for exceedance.
5.2 An initial drainage assessment, based on the existing site characteristics, should consider the following based on the proposed development (not exhaustive):
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Modified flow routes for normal flows, overflow and exceedance
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Use of SuDS; locations and management train
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Treatment stages
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Outfall position
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Existing flood risks

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Watercourses running through the site
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Flow rates and source control
5.3 Discussions with the LLFA should then enable the developer to produce the outline drainage assessment.
This should include (not exhaustive):

A FRA
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Drainage layout
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Infiltration testing and an estimate of storage volume
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Detailed SuDS information including integration with masterplan, source control, storage locations, size of SuDS, amenity value, etc.
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Flow controls
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Consideration of maintenance liability
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Water quality implications
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Landscape integration
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Surface water management during the construction phase
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Phasing plan
It is important that the FRA is based on final ground levels, so runoff post-development can be assessed. A Microdrainage design would be recommended.
5.4 Non-statutory technical standards for sustainable drainage systems gives details on flood risk outside and inside the development, peak flow control, volume control, water quality, structural integrity and construction in accordance with Paragraph 5 of Schedule 3
(National Standards) to the Flood and Water Management Act 2010.
5.5 The detailed drainage assessment should include:
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A detailed FRA and drainage assessment
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Detailed design and layout
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Specification of materials
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Detailed modelling
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Detailed design of inlets and outlets and flow controls
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Construction details and planning
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SuDS management plan
6.0 Further SuDS Guidance
6.1 Following Government-led Consultation on Sustainable Drainage Systems and subsequent
Written Statement HCWS 161 it has been decided that SuDS will be most effectively delivered through strengthening planning policy to make LLFAs statutory consultees on planning applications in relation to surface water drainage.
6.2 Further changes to statutory consultee arrangements for the planning application process gives further guidance and states that the Government will be producing out a New
Burdens Assessment that will establish the payment required for LLFAs to carry out the role of statutory consultee, which took effect from 06 April 2015.

6.3 Policy CS17.1 sets out the priority for the incorporation of SuDS into new developments to manage and minimise surface water. Employed and managed correctly SuDS can bring benefits to water quality, green space and natural habitats.
6.4 The CIRIA SuDS Manual (697) provides best practice guidance on the planning, design, construction, operation and maintenance of SuDS to facilitate their effective implementation within developments. More information on SuDS is available at www.susdrain.org
.
6.5 The Newcastle Gateshead Surface Water Management Plan provided the technical basis on which the Core Strategy was founded. It considers flood risk from surface runoff, groundwater and ordinary watercourses and the interaction with flooding from main rivers and sewers. It provides guidance on SuDS and how they might be used in new developments to manage risks.
6.6 The LLFA is working to produce some local standards for SuDS to supplement National
Standards. Local standards will adhere to key principles:
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Considering SuDs as early in the planning process as possible
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Integrating SuDS with public spaces
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Managing rainfall above ground and at source
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Follow natural drainage routes and rates
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Designing for water scarcity
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Enhancing biodiversity
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Linking SuDS to future Blue Green infrastructure
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Ensuring SuDS design is maintainable
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Taking a precautionary approach
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Having regard to the historic environment
7.0 Maintenance and Adoption of SUDS
7.1 The Government consultation paper (see 6.1) sets out many of the options available to maintain SuDS over the lifetime of a development. This guidance proposes that it is for the
developer to decide from a range of options which include use of service management companies, agreements with NWL or NCC or by transferring responsibility to householders.
7.2 The LLFA is investigating the possibility of setting up a service management company
(SMC) to deal with SuDS in open space or the public realm. The developer would maintain
SuDS for an agreed period before the SMC took over responsibility, funded by a service charge on householders.
7.3 NCC could adopt SuDS in open space or the public realm, following a maintenance period, where design and construction standards meet a standard to be agreed and set out in a future Supplementary Planning Document.
7.4 SuDS in the public highway will be adopted under s38 Highways Act, 1980.

8.0 Water Quality
8.1 The Water Framework Directive (WFD) sets out the need to protect and improve the water environment with the emphasis to do more than just maintain the quality of waterways but to also protect and enhance. It applies to all surface water bodies, including rivers, streams, lakes, estuaries and canals, coastal waters, and all groundwater bodies. The LLFA will assess water quality for ordinary watercourses and the EA will deal with main rivers.
8.2 SuDS can improve water quality directly by increasing the filtration of pollutants, and thereby support the objectives of the WFD. Developments should consider the water quality from surface water drainage in tackling urban diffuse pollution. Surface water runoff that discharges into any watercourse must incorporate pollution control measures to reduce potential for diffuse pollution and sedimentation to ensure that there is not detrimental impact on the water environment. SuDs and Green Infrastructure can help to prevent pollution by filtration of surface water run-off, improving the water quality of watercourses.
8.3 If an Environmental Impact Assessment (EIA) is required for the development this will need to include an assessment of impacts on river bodies of the development. If an EIA not required for development then a separate WFD compliance assessment will be required.
8.4 Other useful reference documents to use regarding water quality are:
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River Basin Management Plans are useful for water quality actions a scheme can deliver.
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Biodiversity Action Plan
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EA Vision for the Ouseburn (currently in draft)