ENW SUDS in Scotland

Engineering Natures Way
SUDS in Scotland
Experience & Opportunity
November 2013
in association with
Contents
1. Introducing SUDS in Scotland
Experience & Opportunity
3
2
2. About Engineering Natures Way
3. Key Findings
4. Survey Methodology
5. Detailed Survey Results
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1. Introducing SUDS in Scotland

Experience & Opportunity 2013
The SUDS in Scotland Experience & Opportunity survey was carried
out during September and October 2013 with practitioners involved
in the specification, design, delivery and approval of SUDS in Scotland.
It set out to investigate how successful professionals believe Scotland
has been in delivering SUDS and to what extent legislation has helped
to drive success.
2. About Engineering Natures Way

Engineering Natures Way is the knowledge-sharing initiative for
Sustainable Drainage Systems. Engineering Natures Way aims to share
news, opinion and best practice about SUDS and floods issues in the
UK, to raise awareness and stimulate debate.
The award-winning initiative began in May 2009 and has attracted a wide
community of followers to its website www.engineeringnaturesway.co.uk,
twitter feed @engnaturesway and regular e-newsletter.
The survey was designed to identify lessons learned and to examine

whether respondents believed there were any barriers to future progress.
It aimed to provide a snapshot of views based on professionals sharing
their experiences. Given that Scotland is further ahead in having a
legislative framework for SUDS in place, it was hoped the findings would
provide insights for the delivery of SUDS in England and Wales, as well as
identifying issues to address for future SUDS delivery in Scotland.
Thank You
We would like to thank all of the 151 practitioners who participated
in the survey, many of whom took the time to provide detailed
comments. We are also grateful to our supporting organisations.
The survey was conducted in association with CIWEM (The Chartered
Institution of Water and Environmental Management) and British Water.
Follow Engineering Natures Way guest bloggers for the latest SUDS comment and opinion.
3. SUDS in Scotland Experience and Opportunity. Key Findings:

How successful has SUDS delivery been in Scotland?
The overwhelming majority (96.8%) believe Scotland has successfully implemented SUDS since the
implementation of the Water Environment and Water Services (Scotland) Act (WEWS). However, very few
believe it has been completely successful.
Legislation:
84.7% agree legislative drivers have helped Scotland to make more effective progress with SUDS
than England and Wales.
Adoption and Maintenance:
Many commented, however, that authorities had been slow to adopt and maintain SUDS.
Affordability:
The majority (61.1%) believe affordability presents a barrier to SUDS design and implementation
on new developments.
Retrofit:
81.3% agree more could be done to retrofit SUDS in Scotland.

3. SUDS in Scotland Experience and Opportunity. Key Findings (continued):

Facilitating effective design and specification
Only about half of respondents were satisfied that current regulation and guidance gives practitioners
freedom to specify from a full toolbox of both natural and manufactured/proprietary SUDS features.
Water quality:
The majority agreed that the requirements for design and implementation of surface water treatment
are clearly defined by regulation and guidance in terms of an effective treatment train (77.2%) and what
constitutes a level of treatment (67.8%).
Proprietary Systems:
However the majority (65%) of those who had experience believe that SEPAs policy to classify
proprietary systems as a level of treatment only in exceptional circumstances was a barrier to design
of effective SUDS solutions.
Many comments highlighted that designers and developers felt frustrated by the limitations in
specifying proprietary systems.
3. SUDS in Scotland Experience and Opportunity. Key Findings (continued):

Optimising through-life performance, maintenance and costs
A significant majority believed regulation and guidance for SUDS maintenance and adoption was insufficiently
clear and required further clarification.
Funding:
The vast majority (77.8%) felt there was inadequate funding for the adoption and maintenance of SUDS
in Scotland.
Maintenance:
69.2% believe that proprietary SUDS features either require the same maintenance or are easier to
maintain than natural SUDS features with less than a third (30.8%) believing they are more difficult
to maintain.
Tools:
The vast majority (84.4%) would welcome further developments of The SUDS for Roads Whole Life Cost
and Whole Life Carbon Toolkit from SCOTS and the development of other industry tools to assist with
the design and costing of both proprietary and natural SUDS.
4. Survey Methodology
The survey set out to use a mixture of quantitative and qualitative
elements to:
understand the key issues for delivery of SUDS in Scotland and
identify the opportunities for, and barriers to, further adoption.
Practitioners working with SUDS in Scotland were contacted and

invited to take part in the survey. An online questionnaire comprising 17
questions was devised. The questions provided multiple choice answers
with the option for further comment if respondents wished.
examine the critical factors that have delivered successful SUDS

projects to date in Scotland and consider what more needs to
be achieved.
To encourage maximum participation and an open sharing of views,

respondents were assured that their identity would remain confidential.
Whilst requested to record their details to help build a picture of
responses, they were not obliged to do so.
test experience of, and attitudes to, SUDS delivery in relation to

water quality and the design of treatment trains.
The survey opened on 23 September 2013 and closed on 23 October 2013.
identify progress made and lessons learnt in Scotland to deliver

insights for SUDS delivery in England and Wales.
Sample who took part?

A total of 151 people took part in the survey. The respondents who
made contributions covered a wide range of professional disciplines
in Scotland involved in the design, delivery and approval of SUDS
systems. The respondents represent a snapshot of SUDS activity in
Scotland based on those who were willing to respond. Those who
responded represented consulting engineers, housebuilders and
developers, local authorities, environment agency (SEPA) and
Scottish Water.
5. Detailed Survey Results

Question 1
Before we begin, please indicate which of the following
best describes your role.
In Question 1 of the survey respondents were

invited to indicate their role.
60%
47.6%
40%
19.9%
20%
6.6%
4.0%
6.0%
Other
Environment
Agency
Contractor
Local
authority
Housebuilder
and developer
Consulting engineer,
architect, specifier
0%
15.9%

Question 2
To what extent do you believe Scotland has been
successful in implementing SUDS since the implementation
of the Water Environment and Water Services (Scotland)
Act (WEWS)?
3.2%
2.4%
The overwhelming majority (96.8%) believe

Scotland has enjoyed success in implementing
SUDS since the implementation of the Water
Environment and Water Services (Scotland) Act
(WEWS). However very few believe it has been
completely successful.
49.2% believed it had been mostly successful
while 45.2% believed it had been only
somewhat successful.
More people in the local authority and
environment agency groups felt that SUDS was
somewhat rather than mostly successful.
49.2%
Only 2.4% agreed it had been completely successful.
45.2%
Completely successful
Mostly successful
Somewhat successful
Unsuccessful

Question 2: Comments
Adoption and Maintenance
issues were often cited as a
barrier to further success.
Comments also pointed to
difficulties in interaction
between local authorities
and Scottish Water.
Adoption of SUDS is still very poor.

Sewers for Scotland has failed to work
and so far only 1-2 SUDS adopted by
Scottish Water. Most SUDS currently in
place are not being properly maintained
so will fail in the long term.
There is still too much confusion for

developers, the failure of Section 7 hasnt helped
anyone and maintenance is still an unknown.
The tiny number (if any) of adopted SUDS
remains a cause for concern. There is far to go
Local Authority
before we can say that the implementation of
SUDS has been successful.
Public SUDS should be adopted by Scottish Water but this
Local Authority
rarely occurs for some reason or another. The types of public
SUDS which are acceptable in the Sewers for Scotland2 are
too
restrictive for small to mid-size developments. The whole
There remain significant issues for
approval
and adoption process is very complicated given the roles
construction phase SUDS ... Despite
and
responsibilities
of the various authorities in relation to flood
our best efforts in SEPA we are
risk,
roads,
surface
water drainage and pollution prevention.
constantly taking enforcement action
for construction phase run off issues.
Local Authority
There is also a need for post completion
In my experience there are always
phase monitoring and this should
problems associated with the
The constraints put in
include assessment of effectiveness of
interaction
of Local Authorities and
place by Scottish Water and
maintenance. There seems to be a lack
Scottish
Water
re maintenance of
the Local Council as to what
of info for this.
treatment
systems.
they are willing to adopt
Environment Agency
makes it difficult to use the
Consulting Engineer
full range of SUDS features.
Consulting Engineer
10
Questions 3 & 4
How successful do you believe Scotland has been in
implementing SUDS as a solution for (3) flood risk (4)
water quality?
3. Flood Risk
3.6%
4. Water Quality
2.8% 0.9%
3.6%
47.3% believe Scotland has been mostly

successful and 45.5% somewhat successful in
implementing SUDS as a solution for flood risk
More people (55%) believe Scotland has been
mostly successful in implement SUDS for
water quality, with 41.3% believing it has been
somewhat successful.
Some commenters pointed to the challenges in
tackling flood risk in the existing urban infrastructure.
41.3%
55.0%
47.3%
Scotlands focus on water quality was welcomed,

however some felt that there were issues to
address concerning the limited options to specify
proprietary systems as well as problems with
inadequately constructed SUDS.
45.5%
Completely successful
Somewhat successful
Mostly successful
Unsuccessful

11
Questions 3 & 4: Comments

Water Quality
Flood Risk
Flood Risk Management was not at the fore of SEPAs
mind when SUDS were introduced. This was a matter
for local authorities but the guidance on SUDS was not
designed with flood risk management in mind.
Local Authority
Still a reluctance to incorporate
ponds and basins in residential areas
due to perceived Health & Safety
risks, therefore SUDS are being used
more for treatment with flood risk
being managed by upsizing pipework
and use of underground tanks etc.
Local Authority
Flooding from poorly

maintained systems of under
capacity drains still and will
occur. Also, the retrofitting of
SUDS could be better funded.
We still have limited options for treating water...

through lack of acceptance from Council /
Scottish Water. Most of SUDS are seen as storing
and restricting flows by a lot of people and few
acceptable options for treating water. Reluctance to
accept hydrodynamic separators etc.
Consulting Engineer
As [water quality] was the original driver for SUDS
this has been a little more successful in application.
However the lack of adherence to the technical standards
during construction has resulted in very limited vesting.
Consulting Engineer
Most SUDS being developed are for
greenfield sites, so tend to be preserving
status quo and not addressing existing
pressures. Housebuilders and others
are developing some very poor systems
which are often marginalised within
developments, poorly constructed and
unlikely to be valued by people...
Environment Agency
Water Company
12
Question 5
Do you believe affordability has presented a barrier
to SUDS design and implementation on new
developments in Scotland?
The majority of respondents (61.1%) agree that

affordability is a barrier to SUDS design and
implementation in Scotland.
38.9%
However, most environment agency respondents

(57.1%) disagreed, and believed that affordability
was not a barrier.
Consulting Engineers were the highest group

to agree at 64.7%.
The issue of affordability prompted some strong

views and comments from respondents.
61.1%
Yes
No

13
Although a requirement, SUDS still present a
significant part of the construction costs of new
development; this can be in the form of cost
to construct the SUDS but also the land take
required reduces the developable areas.
Housebuilder
Cost to build a well integrated surface water/drainage
arrangement pays for itself in terms of avoided insurance
claims, flooding and enhances the built environment.
Water Company
The restrictions on SUDS measures

acceptable to Scottish Water and others
have frequently impinged on design. No
consideration is given to Capital Cost and
although Whole Life Cost is frequently
quoted, in the majority of instances, the
provider and maintainer are different
entities, each looking after their own
budgets. Scottish Water & local authorities
look to the maintenance costs and pay
scant heed to the cost of provision,
[Affordability] is a major issue in getting quality SUDS in

Scotland. The perceived land take puts people off, and if
they are to be created in urban situations, as they should,
they must be designed appropriate to place and as part of
an integrated landscape plan ... Engineers should insist that
they work in an integrated team, if successful and attractive
SUDS are really to happen and be maintained with a clear
landscape maintenance plan.
I dont think affordability

has been a major problem
as many SUDS options are
not that expensive.
However, as developers
want to maximise their profit,
they often dont want to let
the SUDS have the land
area that is required to
maximise treatment.
Environment Agency
Housebuilder
I believe this relates to the perception
of developers and consultants on cost.
They need to consider whole life cost
and include maintenance. There is a
lack of understanding of what SUDS
are designed to do and why they are
needed; why SUDS are beneficial.
Local Authority
Environment Agency
14
Question 6
Do you believe that more could be done to retrofit
SUDS in Scotland?
There is broad agreement amongst practitioners

from all professional disciplines that more could
be done to retrofit SUDS in Scotland.
81.3% agreed that more could be done to
retrofit SUDS.
18.7%
Many who commented believed cost could be

a barrier or that retrofit needed to be enabled
through greater funding.
Commenters highlighted the particular need to
target water quality in urban environments.
81.3%
Yes
No
Some suggested that more retrofit SUDS could

be enabled via the planning system and others
called for clear roles and responsibilities to be
established for implementing retrofit SUDS.

15
100% Yes. Surface water separation needs more
funding, which would allow further local plan type
development as combined systems would have less
surface water contribution... Ownership and long term
responsibility needs to be looked at.
Very little has been done in terms of retrofitting

in Scotland. Tanks and oversized pipes are too
often seen as the simplest solution and the
multifunctional benefits of SUDS are overlooked.
Consulting Engineer
Consulting Engineer
There is no incentive for anyone to
retrofit SUDS at present.
Local Authority
Cost will be a barrier in this instance and

therefore only flood alleviation where the
risk is high will be implemented.
Contractor
Where development is in an area where there

are already sewer capacity and water course
quality issues, planning conditions could be
explored to do more retrofitting within the public
networks ... Scottish Water should be funded to
do more using their powers to access third party
land, and explore more retrofit options as part of
a capital investment programme.
The majority of diffuse pollution emanates from historical developments mainly

in towns and cities. Whilst there is attention being paid to flood prevention in
these areas, very little is being done regarding SUDS.
Consulting Engineer
Housebuilder
16
Question 7
Do you believe that the legislative drivers have helped
Scotland to make more effective progress with SUDS
than England and Wales?
There was strong agreement that legislation has

enabled Scotland to implement SUDS and to
progress further than its neighbours in England
and Wales.
84.7% of respondents agreed that legislation
had supported successful SUDS implementation
in Scotland.
15.3%
Commenters agreed that success through

various elements of regulation had been
achieved, but were clear that Scotland could
not rest on its laurels.
Many comments pointed out that more can
still be done, and highlighted some barriers to
further progress.
84.7%
Yes
No

17
Changes to the Sewerage (Scotland) Act,
the CAR Regulations, the SUDS for Roads
Manual and the publication of Sewers for
Scotland2 should have assisted.
Local Authority
The legislation drivers in Scotland are stringent.
Although the first UK measures were introduced into England
(Pratt, 1995- permeable paving), there has been less success
in implementation of measures. This success may also be
due to the current focus on the Hydro Nation and the
funding supplied by the Scottish Executive to run projects.
Planning requires SUDS to be implemented

as standard - this has been hugely important in
making developers/planners understand that
SUDS is part of the core of the planning of a
development footprint. BUT - the disconnect
between planning legislation and what council
roads departments are prepared to accept has
become more stark in the last 5 years - Scottish
Government policy is basically being ignored by
many council roads departments who will not
adopt SUDS for roads, or accept anything other
than asphalt surface with road gullies.
Academic
I think Scotland is ahead but I am not seeing quality
SUDS appropriate to place coming through yet.
I believe this is because the Minister for SW does not
seem to have the same remit as the Minister who
controls quality of design. The money for maintenance
must include money for more than just grass.
Consulting Engineer
A single water authority and
willing regulator and government
[have contributed to the success].
Consulting Engineer
Local Authority
18
Question 8
Do you believe current regulation and guidance
for Scotland gives practitioners freedom to specify
appropriately from a full toolbox of both natural and
manufactured/proprietary SUDS features?
Only about half of respondents were satisfied

that current regulation and guidance gives
practitioners freedom to specify appropriately
from a full toolbox of both natural and
manufactured/proprietary SUDS features.
A significant number (48.0%) felt they lacked the
freedom to specify from a full SUDS toolbox as
they would like. Amongst housebuilders and
developers the number was 80%.
Some strong views reflected a frustration with
the authorities, especially SEPA, who were
reluctant to approve proprietary SUDS systems.
Maintenance provision and adoption were also
highlighted as issues.
48.0%
52.0%
Yes
No
Some felt that a lack of consensus between

different authorities also presented a barrier and
called for greater partnership working from the
earliest stages of design.

19
Very prescriptive conditions set by SEPA on

what are SUDS. The flexibility to assess the
benefits / performance of innovative products
versus traditional SUDS is not embraced.
What are the barriers?

The key is that the tool box is chosen that is appropriate to
place ... the separation between the design professions should
not exist and it should be emphasised in these documents
otherwise there is no possibility that the engineer can
persuade the client for a greater design input.
Local Authority
SEPA is not keen on proprietary products and roads
departments do not have appropriate maintenance in place for
anything other than gullies, so there is a conflict there already.
Many steering groups etc have come up with a wide range of
SUDS (as per CIRIA guidance) - but Scottish Water, SEPA, and
roads departments all have differing views on this, and it can be
impossible to gain a consensus.
Developer
Barriers are put in place from councils, Scottish Water and

SEPA on what represents green sustainable drainage systems
(generally manufactured), there are a number of systems
available that are not deemed green although they can clean
water more efficiently than approved green systems.
Housebuilder
SEPA are very reluctant
to approve any non
natural suds, their motto
seems to be if it doesnt
have grass forget about it.
There is a prejudice in SEPA

against proprietary systems.
Housebuilder
Housebuilder
Consulting Engineer
Manufactured/proprietary
SUDS features are not
currently favoured.
Drainage Authority
SEPA dont fully recognise proprietary SUDS, insisting upon natural SUDS. They need to
be more flexible if research is available to back up proprietary claims, especially in industrial
development as 3-stage cleaning naturally is very onerous for most sites.
Consulting Engineer
20
Questions 9 & 10
Do you believe the requirements for design and
implementation of surface water treatment are clearly
defined by regulation and guidance in Scotland in
terms of (9) what constitutes an effective treatment
train and (10) what constitutes a level of treatment?
9. Treatment Train
10. Level of Treatment
22.8%
32.2%
Most people agreed that regulation and

guidance clearly defines requirements for design
and implementation of surface water treatment.
With 77.2% of all respondents in agreement
concerning the treatment train and 67.8% for
levels of treatment.
Nevertheless, the question attracted a large
number of comments. Some referred to a lack of
clarity in the definition of what a level of treatment
actually is. Some suggested that interpretations
may vary, or that there may be a lack of awareness.
Some felt that there was too much guidance and
some of it was ill defined.
77.2%
Yes
No
67.8%
Yes
No

21
Questions 9 & 10: Comments

The SUDS guidance refers to levels of treatment without
defining what a level of treatment actually is. One SUDS
element can be twice as effective as another, but both are
regarded as one level of treatment. A treatment train comprises
various SUDS elements linked to deliver the required number of
levels of treatment without regard to the effectiveness of each
element. Research at Heriot-Watt University has determined a
significant reduction in the cost effectiveness of subsequent
elements in the treatment train after the first one.
Housebuilder
For some reason SEPA exclude proprietary systems as
constituting a level of treatment, even though documented
evidence can be provided to prove their effectiveness.
Housebuilder
Generally accepted levels of treatment are as
per CIRIA guidance - but there needs to be more
research done on what this level of treatment
actually achieves and how flexible the definition
could be depending on site conditions.
The regulations are clear. There is too much

guidance and no one appears to refer to it. It needs
to be clear and simple and broadly the same across
the country. There is little or no maintenance
and no incentive to do so. There is no clear way
of determining when maintenance is required.
SEPA should have a lead role to determine the
effectiveness or otherwise of SUDS systems. SEPAs
role is currently ill-defined.
Local Authority
There is sufficient information provided

out there (CIRIA, SUDS for Roads, Sewers for
Scotland etc) for someone to determine what
constitutes an appropriate level of treatment
in a SUDS treatment train, provided that
they know what they are doing and spend
a bit of time investigating the site specific
conditions and going through the guidance...
Unfortunately there is no one design for
say a filter trench that constitutes a level
of treatment for every situation, but the
guidance to do this is there.
There is still a lot of

interpretation made on the
guidance and regulations
available. Sewers for Scotland
contradicts the SUDS manual.
Environment Agency
Consulting Engineer
Consulting Engineer
22
Question 11
Currently SEPAs Regulatory Method on SUDS
(WAT-RM-08 v5) states that proprietary systems may
only be classified as a level of treatment in exceptional
circumstances. In your experience has this been a
barrier to the design of effective SUDS solutions?
The majority (65%) of those with experience

believe that SEPAs regulatory method to classify
proprietary systems as a level of treatment only
in exceptional circumstances was a barrier to
design of effective SUDS solutions.
40.0%
Some comments expressed their frustration with

the situation and pointed to projects where they
had specified proprietary features even though
they were not accepted as a level of treatment.
38.9%
Yes
However 71.4% of environment agency

respondents disagreed.
Some speculated that SEPAs reluctance may be

due to a lack of confidence in the commitment
by the owner/operator to the maintenance of
proprietary systems or called for more case study
evidence of their performance.
No
No experience
21.1%

23
There are very few proprietary products

Ive seen submitted as SUDS. A lot of the
technology lacks effective case studies.
Environment Agency
Sites with limited space,
conventional road and
footpath arrangements
and small numbers would
easily benefit from Vortex
Separators etc. Instead they
are forced to install ponds,
filter strips and so on which
can be totally inappropriate
to the specific location.
When I design or use these systems

its normally ... for an additional level of
treatment. If the owner/operator does not
clean them to the manufacturers spec,
they do not perform this single level ... so I
can see SEPAs point. Again, Scottish Water
or the local authority need to improve
here but they need the funding to do so.
Consulting Engineer
All treatment benefits the environment. SEPA has been

reluctant to value road gullies, grit busters, downstream
defenders etc on the grounds that they may not be
maintained. That, however, also applies equally to
natural systems. In my experience, systems that can be
maintained routinely alongside gully cleaning operations
for example are more sustainable.
Local Authority
Housebuilder
SEPAs view is that they are only a method of pre-treatment and
do not constitute a level of treatment in the treatment train.
Problems occur when the consultant is

unwilling to fully accept the principles of
SUDS at the outset, such as when too many
properties have been squeezed into a site
without first taking into account the SUDS
footprint. I would not classify this as a barrier,
but it does refocus minds on the basic SUDS
principles. Ultimately if standard SUDS are
not appropriate for justifiable reasons, SEPA
will not prevent development unless we have
strong reasons to do so.
Environment Agency
In some situations, a proprietary system is
the only feasible option. Surely this is better
than no treatment at all. I have worked on
projects where a Downstream Defender
has been specified, though SEPA did not
accept it provided any treatment.
Consulting Engineer
Consulting Engineer
24
Question 12
Do you believe there is adequate funding available for
the adoption and maintenance of SUDS in Scotland?
22.2%
The overwhelming majority (77.8%) believed funding

for adoption and maintenance was inadequate.
Agreement was high amongst all respondent
groups and 100% in the housebuilder and
developer group.
Comments suggested that both Scottish Water and
local authorities could do considerably more to
adopt SUDS and that responsibility for maintenance
of SUDS could be falling between the two bodies.
Some felt that more funding for local authorities
would help to resolve the difficulties currently
being experienced.
Yes
77.8%
No
However, not all were in agreement, with some

environment agency respondents suggesting that
SUDS can be adopted if properly designed and that
a lack of understanding amongst local authorities
made them overly concerned about maintenance.

25

Scottish Water is making inroads into this area,
but council roads depts. are almost universally
ignoring the issue, and are certainly not changing
their approach to allow the adoption of SUDS.
Councils are reluctant/cautious to enter

into Section 7 agreements; reluctant to
resolve legacy SUDS issues.
Water Company
Consulting Engineer
There are no ponds in
Scotland formally adopted
by Scottish Water.
Consulting Engineer
In my experience Scottish Water are not proactive in any way in adopting fully functioning
SUDS which have been constructed in accordance
with the approved design.
Consulting Engineer
Ownership of maintenance is falling between local council

& Scottish Water. Provision of funding would assist in one of
the public bodies taking on the responsibility.
Scottish Water should be adopting

more and a wider variety of features.
Consulting Engineer
26
The adoption and maintenance costs are not

considered to be any greater than those associated
with conventional below ground pipe systems.
It is known that local authorities are concerned by
maintenance costs, but I believe this is to be an
overreaction based on limited knowledge.
Developer
Water Company
Government funding is available to all public
bodies as part of their settlement agreement.
Ensuring that priority is placed on SUDS against
competing activities and ring fencing these
monies is more the issue.
Drainage Authority
If designed properly, they will be

adopted and maintained by either the
local authority or Scottish Water.
Environment Agency
Questions 13 & 14
How clear do you believe regulation and guidance
for SUDS in Scotland is for (13) maintenance and
(14) adoption?
13. Maintenance
Many respondents believe that more needs to be

done to maintain and adopt SUDS in Scotland.
14. Adoption
5.4%
2.2%
20.7%
30.8%
The majority of respondents believe that

regulation and guidance for SUDS in Scotland
needs to be clarified for both maintenance and
adoption.
30.7%
34.8%
Some very strong opinions were expressed that

responsibility for adopting SUDS features was
being resisted or was falling between the roles
of Scottish Water and local authorities.
Designers and developers referred to their
experiences and the frustrations they felt.
39.1%
36.3%
Very clear
Sufficiently clear
Not clear enough
Needs further clarication

27
Question 13 (Maintenance): Comments
The available guidance is not all in one place and what

there is, is too unwieldy for all but the most interested
to get their heads around ... Many systems are not the
responsibility of any organisation to maintain.
Consulting Engineer
There is no detailed guidance available

on the maintenance regimes for the
various SUDS measures. There is no
mandatory schedule available either.
Housebuilder
There seems to be a lack of clear guidance about vegetation

maintenance - a manual created for contractors explaining the
various aspects, including the vegetation, would be helpful as
would regulation that insisted that the landscape drawing done for
a scheme clearly indicates which parts of the landscape are part of
the functional SUDS scheme and which is amenity landscape.
There is a set of maintenance regimes published

for many of the SUDS solutions, but there is little
evidence that this maintenance is actually carried
out. Even in private areas (supermarket car parks for
example) a maintenance regime is not evident.
Consulting Engineer
Local Authority
The guidance is sufficiently

clear but, in my experience,
it is rarely carried out.
Consulting Engineer
28
The need for comprehensive
solutions adopted in perpetuity by
a reliable authority has not been
established in practice.
Drainage Authority
Generally sufficiently clear but only for simple one

system locations e.g. SUDS pond. Where there are more
integrated SUDS systems installed then complications
can arise. Through partnership and commitment to
succeed these can be addressed.
Water Company
Question 14 (Adoption): Comments

Many organisations have either contrived to avoid
adopting SUDS or have failed to adopt and maintain such
systems through negligence and/or insufficient funding /
prioritisation. There is no apparent penalty for the latter.
I only had one site where I was tasked with taking the
SUDS through the actual adoption process. Scottish Waters
SUDS inspector seemed determined not to adopt, despite
the common perception that it was one of the most well
constructed SUDS features. Goalposts were continually
moved, despite all parties determination to finalise.
Consulting Engineer
Section 7 of the Sewerage Scotland Act
requires agreement between authorities and
experience shows that the Local Authorities
are unwilling to take on extra spending.
Consulting Engineer
Scottish Water is
attempting to pass at least
some of the responsibility
onto local authority
roads. There is no clear
guidance on this.
Local Authority
Each stakeholder (SEPA, Councils and Scottish Water)
has their own views on adoption/responsibility and these
do not align with each other. For this reason developers
are left in limbo trying to satisfy all stakeholders, which
is impossible, and finding that ultimately getting anyone
to accept adoption responsibility for the constructed
features is an uphill struggle.
Consulting Engineer
Housebuilder
29
Question 15
In terms of maintenance of SUDS features do you
believe that proprietary systems such as vortex
separators are:
35%
34.6%
34.6%
34%
33%
32%
31%
30.8%
Some comments revealed that respondents

needed more information about maintenance
regimes for proprietary features. Some had a
concern that underground systems might be
forgotten about by the owners. However, some
also pointed to disadvantages of maintaining
natural SUDS features.
Amongst those most familiar with the
maintenance regimes of proprietary features,
comments appeared to support them for their
ease of maintenance and predictable regimes.
30%
29%
28%
The majority (69.2%) believe that proprietary SUDS

features either require the same maintenance or
are easier to maintain than natural SUDS features
with less than a third (30.8%) believing they are
more difficult to maintain.
More difficult
to maintain than
natural SUDS
features
Require the same

maintenance as
natural SUDS
features
Are easier
to maintain than
natural SUDS
features

30

Although levels of silt build-up etc cant be easily
seen in a separator, nobody is really looking for it in
a natural SUDS feature. I think that once the initial
months of monitoring are completed, the silt amounts
can be quantified and a programme of regular
maintenance set up to suit. No grass to cut, no debris
to clear etc. One squad/gully sucker, job done.
A vortex separator is only another type of system; it isnt

overly complex and is easily accessed/maintained. In my
opinion it is far more easy to maintain a vortex separator
with its direct access than some private stone systems. The
principles for each are similar, but the more complex one is
easier to maintain as consideration has gone into it through
manufacturing and design.
The question is not relevant

unless we are speaking
about a constrained,
exceptional site.
Environment Agency
Contractor
Consulting Engineer
They can be integrated into existing maintenance regimes. The fact that
they are few in number has not helped ensure that they are successfully
integrated into maintenance regimes however.
These can be maintained by emptying using a gulley sucker

which, under normal circumstances, would be doing the
rounds anyway. Soft SUDS can require access by plant,
drained down; filter material excavated which is a much more
intensive operation.
Housebuilder
Local Authority
They are contained and easily accessed (although vortex
separators are not classed as a level of treatment by SEPA).
Project experience. Natural SUDS features

sometimes dont work as anticipated.
Contractor
Consulting Engineer
Special teams are required to maintain these items.
Consulting Engineer
Natural SUDS are more preferable. Buried systems

have more onerous maintenance issues and indeed in
some cases are likely to require significant upheaval to
allow adequate maintenance to be provided.
Local Authority
31
Question 16
The SUDS for Roads Whole Life Cost and Whole Life
Carbon Toolkit from SCOTS is available to support
costing of SUDS in Scotland. Would you welcome
further developments to the tool to help with costing?
Many people commented that an expansion

of the tool to include more measures or SUDS
features would be welcome.
Responses indicated that the tool is currently
being reviewed and improved.
16.0%
32
Yes
84.0%
No

Scottish Water are

currently altering the tool.
Water Company
We have undertaken an appraisal of the tool and

identified improvements / better assumptions and have
been developing this tool for our use.
Update would be useful and it should

include more measures/options.
Consulting Engineer
Anything which helps develop the understanding
of the benefits of SUDS for those building,
installing and maintaining SUDS. Should have
reference to construction phase aspects.
Drainage Authority
Full range of SUDS, including
proprietary features. More realistic
costs and more councils to use it.
Consulting Engineer
Environment Agency
33
Question 17
Would you welcome the introduction of further industry
tools to assist with costing and/or design of both
proprietary and natural SUDS?
14.0%
An overwhelming majority (86%) would welcome

further industry tools to aid costing and/or design
of SUDS features.
Comments suggested that costing models based
on actual, real-life examples would be useful.
Some suggested that any tool should also rate
the effectiveness of SUDS features.
Yes
86.0%
No

34

More robust costings of all measures
including the ability to assess the benefits
not just in flooding and water quality benefit
terms e.g. social and economic benefits.
More detailed costing

models using actual
incurred costs.
Water Company
Drainage Authority
More education for

Councils / SW so that a
wider range of SUDS will be
available to designers.
Consulting Engineer
I would like to see details of the effectiveness of SUDS elements rated and developments
required to meet a target level using SUDS measures which reach that target, rather than
simply talking about levels of treatment which are unspecified. In general, most developers
will have a fairly good idea of the cost of provision which I believe is likely to be more accurate
than any guidance, particularly as costs can vary from time to time and area to area.
Realistic costing assessments - that can

be supported by real life examples.
Water Company
More tools (free) for the design

of both natural and proprietary.
Housebuilder
Investigation of effectiveness of proprietary
systems and some are better than others.
Environment Agency
Consulting Engineer
35
Engineering Natures Way is the

initiative of Hydro International
Published by:
Hydro International plc
Stormwater Division
Shearwater House
Clevedon Hall Estate
Victoria Road
Clevedon BS21 7RD
Tel: 01275 337977
Fax: 01275 874979
Visit: www.engineeringnaturesway.co.uk
@engnaturesway
Hydro International November 2013

ENW SUDS in Scotland

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Engineering Natures Way

2. About Engineering Natures Way

5. Detailed Survey Results

Visit the Engineering Natures Way Website for information on

1. Introducing SUDS in Scotland

2. About Engineering Natures Way

The survey was designed to identify lessons learned and to examine

3. SUDS in Scotland Experience and Opportunity. Key Findings:

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3. SUDS in Scotland Experience and Opportunity. Key Findings (continued):

3. SUDS in Scotland Experience and Opportunity. Key Findings (continued):

Practitioners working with SUDS in Scotland were contacted and

examine the critical factors that have delivered successful SUDS

To encourage maximum participation and an open sharing of views,

test experience of, and attitudes to, SUDS delivery in relation to

The survey opened on 23 September 2013 and closed on 23 October 2013.

identify progress made and lessons learnt in Scotland to deliver

Sample who took part?

5. Detailed Survey Results

In Question 1 of the survey respondents were

Visit the Engineering Natures Way Website for information on

The overwhelming majority (96.8%) believe

Only 2.4% agreed it had been completely successful.

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Adoption of SUDS is still very poor.

There is still too much confusion for

47.3% believe Scotland has been mostly

Scotlands focus on water quality was welcomed,

Visit the Engineering Natures Way Website for information on

Questions 3 & 4: Comments

Flooding from poorly

We still have limited options for treating water...

The majority of respondents (61.1%) agree that

However, most environment agency respondents

Consulting Engineers were the highest group

The issue of affordability prompted some strong

Visit the Engineering Natures Way Website for information on

The restrictions on SUDS measures

[Affordability] is a major issue in getting quality SUDS in

I dont think affordability

There is broad agreement amongst practitioners

Many who commented believed cost could be

Some suggested that more retrofit SUDS could

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Very little has been done in terms of retrofitting

Cost will be a barrier in this instance and

Where development is in an area where there

The majority of diffuse pollution emanates from historical developments mainly

There was strong agreement that legislation has

Commenters agreed that success through

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Planning requires SUDS to be implemented

Only about half of respondents were satisfied

Some felt that a lack of consensus between

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Very prescriptive conditions set by SEPA on

What are the barriers?

Barriers are put in place from councils, Scottish Water and

There is a prejudice in SEPA

10. Level of Treatment

Most people agreed that regulation and

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Questions 9 & 10: Comments

The regulations are clear. There is too much

1. Introducing SUDS in Scotland

examine the critical factors that have delivered successful SUDS

test experience of, and attitudes to, SUDS delivery in relation to

identify progress made and lessons learnt in Scotland to deliver