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Sustainable Drainage Systems (SuDS) GuidanceConsultation Report December 2016

Contents Executive summary ................................................................................................... 3

1. About the proposals ......................................................................................... 4

1.1 Introduction .................................................................................................... 4

1.2 Purpose .......................................................................................................... 4

1.3 Detailed description ........................................................................................ 5

2. About the consultation ..................................................................................... 6

2.1 Purpose .......................................................................................................... 6

2.2 Potential outcomes ......................................................................................... 6

2.3 Who we consulted .......................................................................................... 6

2.4 Dates and duration ......................................................................................... 7

2.5 What we asked ............................................................................................... 7

2.6 Methods of responding ................................................................................... 7

2.7 Consultation materials and publicity ............................................................... 7

2.8 Analysis of consultation responses ................................................................ 8

3. About the respondents ..................................................................................... 9

3.1 Number and type of respondents ................................................................... 9

3.2 What is your business position? ................................................................... 10

3.3 Do you currently use CIRIA? ........................................................................ 11

3.4 Are you directly responsible for approval of street designs? ........................ 11

3.5 How did you find out about this consultation? .............................................. 12

3.6 What do you think about the quality of this consultation? ............................. 12

4. Summary of all consultation responses ....................................................... 13

4.1 Comments on the draft document ................................................................ 13

4.2 Common themes arising from consultation .................................................. 13

4.3 Summary of stakeholder responses ............................................................. 14

5. Response to issues raised ............................................................................. 28

6. Conclusion and next steps ............................................................................ 31

Appendix A: Consultation questions .......................................................................... 31

Appendix B: Copy of the stakeholder email ............................................................... 37

Appendix C: List of 181 stakeholders by category .................................................... 38

Appendix D: Image of rainwater harvesting evaluation tool ....................................... 44

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Executive summary This document explains the processes, responses and outcomes of the consultation on the proposed document: SuDS1 in London – a guide. The guidance seeks to show how SuDS can be incorporated into London’s streets and wider public realm. It highlights potential opportunities and constraints, aiming to encourage the relevant authorities across London, including the boroughs, to consider their streetscape and the possibilities of successfully integrating SuDS.

Between 19 August and 25 September 2016, we consulted on the proposed guidance document. We received 27 responses to the consultation, containing a total of 368 individual comments.

Summary of issues raised during consultation

• Positive comments, supporting the implementation of SuDS throughout London and stating that this guidance would help support its delivery. The case studies were also commented on to be useful and well-illustrated

• Respondents stated that maintenance needed to be covered in greater detail

• The document was over 200 pages long and respondents felt that it needed to be shortened and ‘tightened up’ in order to be more usable. Respondents also stated that the guidance document needed to be clarified relative to other guidance on SuDS, street design etc.

Conclusion and next steps As a result of this consultation we have made a number of changes to the final guidance, which are detailed in Section 5.

The SuDS Guidance was presented on Thursday 17 November at the New London Architecture seminar entitled: London Sustainable Drainage Action Plan & TfL’s SuDS Guidance. Around 160 guests attended, all with a professional interest in drainage and the urban realm. The keynote speaker was Frédéric Ségur, who is Director of Trees and Landscapes at the Greater Lyon Authority. The event also saw the presentation of the London Sustainable Drainage Action Plan (LSDAP), which sets out a vision for sustainable management of London’s rainwater. The SuDS Guidance complements this high-level vision by showing how SuDS measures may be implemented on the ground.

Following this event, the guidance will be published online via the TfL Streets Toolkit webpage when the design has been fully completed.

1 SuDS – Sustainable Drainage Systems

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1. About the proposals 1.1 Introduction In October 2015, the Greater London Authority (GLA) consulted on a London Sustainable Drainage Action Plan: a long-term plan intended to inspire, facilitate and co-ordinate a step-change in how we manage rainwater in the Capital. Action number 14 requires Transport for London (TfL) to: ‘Produce guidance that includes good practice examples of sustainable drainage in the streetscape and public realm’. TfL Urban Design has engaged a consultant team to produce SuDS guidance to address this Action. The development of the guidance has been informed by a Steering Group with representatives from a broad range of organisations including TfL, GLA, London boroughs, the Environment Agency and Thames Water. From December 2015 to May 2016, versions of the draft SuDS guidance were reviewed by the Steering Group. The consultation ran from Friday 19 August to Sunday 25 September. Stakeholders were invited to view and provide comments on the draft document via an online survey. 1.2 Purpose We consulted on the draft guidance to:

• Widen the circulation of the document to any other technical specialists that were not involved in its development via the Steering Group

• Circulate the document to a wider audience in the boroughs than the technical officers who attended the Steering Group

• Obtain buy-in from the boroughs at a senior level

• Ensure that the impact of the guidance on all users has been considered

• Ensure that the guidance is as clear and usable as possible

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1.3 Detailed description

The new design guide shows how to integrate Sustainable Urban Drainage seamlessly into London’s streetscape and public realm. The proposed guide has been developed for all publicly accessible space in the Capital, including roads and streets managed by TfL and the boroughs.

The proposed guide:

• Outlines the principles of SuDS and how these principles relate to London • Identifies the components that make up a SuDS system • Illustrates how these components may be integrated into the public realm • Shows how SuDS have been applied in practice • Provides guidance on methodology and cost comparison

It is intended to use the document alongside TfL’s Streets Toolkit guidance and the Construction Industry Research and Information Association (CIRIA) SuDS Manual. The guidance should inform design options throughout London to deliver the many potential benefits of SuDS.

The document can be viewed – SuDS in London: A Guide as a single document, or as individual chapters. See Appendix A for the questions asked for each document section.

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2. About the consultation 2.1 Purpose The objectives of the consultation were:

• To give stakeholders and the public easily-understandable information about the guidance and allow them to respond

• To understand the level of support or opposition for the guidance

• To understand any issues that might affect the guidance of which we were not previously aware

• To better understand concerns and objections

• To allow respondents to make suggestions

2.2 Potential outcomes The potential outcomes of the consultation were:

• We decide the consultation raises no issues that should prevent us from proceeding with the guidance as originally planned

• We modify the guidance in response to issues raised in consultation

• We abandon the guidance as a result of issues raised in the consultation

2.3 Who we consulted The consultation was aimed at stakeholder groups – 440 individuals – ranging from business positions of Officers to Chief Executives. Names and organisations were identified from the 2014 Streetscape Guidance consultation; further names were supplied by the Steeting Group and other TfL and external stakeholders.

The list of stakeholder groups can be found in Appendix C.

• Accessibility groups in pan-London organisations and boroughs • ADUP Lot 4 • Design – LoHAC contractors • Developers • Environment groups • GLA • Government Agency • LLFA (Lead Local Flood Authority) in boroughs • London Councils (TEC) Transport and Environment • Pedestrian groups • Steering group respresentatives

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• Police and Emergency Services • Policy groups • Professional groups • Road safety groups • Royal Parks • Transport and Transport for London • Urban Design active event attendees • Utility groups

2.4 Dates and duration The consultation ran for five weeks from Friday 19 August to Sunday 25 September 2016.

2.5 What we asked We asked respondents to review each section relevant to their area of specialisation. See Appendix A for a full list of the questions in each chapter.

2.6 Methods of responding We provided our online consultation hub as the main method of responding, although eight respondents chose to respond via email to stengagement@tfl.gov.uk

2.7 Consultation materials and publicity The consultation was specifically aimed at those individuals and stakeholder groups that were already aware of the SuDS guidance being drafted, and those which might have an interest in contributing a response; a database of 440 email addresses.

The consultation was hosted on our hub at this link where you can see the draft guidance in one whole document or select by chapter: https://consultations.tfl.gov.uk/policy/suds-guidance

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2.8 Analysis of consultation responses The 27 responses each contained a large number of individual comments (368 in total). These were sorted by chapter and entered into a spreadsheet containing all responses. This allowed our Urban Design team to work through the comments chapter by chapter. There were three main categories of action:

1) Make alteration based upon comment

2) Discount comment and justify course of action

3) Seek advice from consultant or other third party to answer question and/or

provide further information.

This information is contained in the consultation spreadsheet that the Urban Design team used.

In addition to these step-by-step changes, we used the comments to analyse the overall guideance document. This informed major alterations regarding its length and the order of some of the chapters.

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3. About the respondents A total of 27 individuals responded from the 440 individuals targeted by email; 23 responses were received via the consultation hub and seven via direct email. The respondents who replied by email did not answer the supplementary questions, therefore please note below the total for some questions is based at 23.

Only stakeholder organisations were invited to participate. This section provides a summary on how people responded.

3.1 Number and type of respondents The total number of respondents taking part in the consultation was 27. We asked ‘in what capacity are you responding to the consultation?’ The responses received from the drop down menu are in order of the highest number. For the seven responses received by email, we were able to allocate the category based on their organisation. The 11 ‘other’ organisations are listed on the next page:

Respondents Total %

Lead Local Flood Authority (LLFA)* 12

44% Other (see list of organisations on next page) 8 30%

Individuals 4 15%

Community or voluntary organisation 3 11%

*LLFA respondents by borough

London Borough of Barnet (two)

London Borough of Camden (two)

London Borough of Enfield

London Borough of Harrow

London Borough of Hillingdon

London Borough of Southwark

London Borough of Wandsworth

Royal Borough of Kensington and Chelsea

Royal Borough of Kingston-upon-Thames

Not specified (one)

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Other organisation types (8)

Green Party

Environment Agency

Hydro International

KLH Sustainability Consultancy

KloudKeeper Limited (Research Fellow)

London Councils

Metis Consultants

Sustainable Drainage Systems Limited

3.2 What is your business position? The business positions varied within the respondents and are listed below:

Respondents Asset, Projects and Contracts Manager

Business Development Manager

Deputy Team Leader

Emergency Planning Officer

Energy and Sustainability Manager

Flood and Water Management Officer

Flood Risk Officer

Government Affairs Officer

Highway Manager (Sponsor)

Highways Design Quality Manager

Lost Effra Project Coordinator

Managing Director

Member of the London Assembly

Principal Engineer

Principal Engineer

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Principal Engineer, Structures and Watercourses

Principal Officer Green Infrastructure & Biodiversity

Principal Policy Officer (Policy & Public Affairs)

Regional Technical Manager

Senior Conservation Advisor, Gov't Affairs Officer Ldn

Senior Flood and Water Management Officer

Senior Sustainability Advisor

TfL Senior Technical Specialist - Arboriculture & Landscape. Chair of the London Tree Officers Association.

Transport Planner

Various role: Specialist including Arboriculture & Landscape, Drainage, Streetscape and Highways

Writer/Administrator

Four respondents did not provide a business position

3.3 Do you currently use CIRIA? CIRIA is the Construction Industry Research and Information Association.

The total number of respondents that answered this question through the hub was 23.

Respondents Total %

Yes 15

65%

No 6 26%

Not answered (in hub) 2 9%

3.4 Are you directly responsible for approval of street designs? The total number of respondents that answered this question through the hub was 23.

Respondents Total %

No 16 70%

Yes 6

26%

Not answered (in hub) 1 4%

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3.5 How did you find out about this consultation? The total number of respondents that answered this question through the hub was 27.

Other ways respondents heard about the consultation

Drain London (see link)

Not specified

Received link from colleague

Word of mouth

3.6 What do you think about the quality of this consultation? The total number of respondents answering this question through the hub was 23.

Response comment Total %

Good 12 52%

Very good 10 44%

Not answered 1 4%

One comment was provided: “I took the time to read through a large amount of the accompanying material, however not everyone will. I think a one page summary would be useful.”

How respondents heard Total %

Received an email from TfL 19 70%

Other (see below) 4 15%

Saw on TfL website 3 11%

Social media 1 4%

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4. Summary of all consultation responses The most efficient way to ask for stakeholder feedback on the draft SuDS guidance was to format the questions and launch as a ‘consultation’ via our website.

The collection of responses were comments given by specialists in their field to the relevant sections that they believed to be clarified, corrected, replaced or enhanced.

4.1 Comments on the draft document The draft document was broken down into seven chapters, an introduction and appendices:

• Introduction 1.0 Vision 2.0 The London Context 3.0 SuDS Components 4.0 SuDS on London’s Streets 5.0 Case Studies 6.0 Implementation 7.0 Cost Benefit

• Appendices

We asked for comments on each chapter of the draft guide, and for comments on the document in general.

All comments received were attributed to the relevant section of the document, and where possible, paragraphs numbers were referenced.

4.2 Common themes arising from consultation See below the top four issues raised by respondents for the document:

1) Length of document: There were not any calls for a longer document and many requests for it to be made considerably shorter; as much as 50% to be removed.

2) Purpose of the guidance: Respondents said this had to be stated very clearly. Its relationship with technical guidance and London planning policy had to be spelt out at the very start of the document.

3) Relevance of illustrations: Tying in with requests for a shorter document was the observation that not all of the images contributed anything to the guidance. Captions in some cases were not helpful and more could be done to make the text and images complement one another.

4) Multiple benefits: While SuDS are ostensibly concerned with drainage, they have further benefits which needed to be emphasised much more fully.

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4.3 Summary of stakeholder responses This section provides summaries of the feedback we received from stakeholders. While we sometimes have to condense detailed responses into brief summaries, the full stakeholder responses are always used for analysis purposes.

There were 27 responses in total, including two anonymous and two replying as individuals. Respondents were not asked whether they supported the guidance. However, where comments were stated either way on this topic, they are included in the summary. The responses have been grouped by the categories below:

a) Consultants (two responses)

• Hydro International • Metis Consultants

b) Environmental (six responses)

• KLH Sustainability • KloudKeeper Ltd., • Sustainable Drainage Systems Ltd., • Wild London • Wildfowl and Wetlands Trust • Woodland Trust

c) Government departments (three responses)

• Environment Agency • Greater London Authority • London Councils

d) Local authorities – Lead Local Flood Authority (LLFA) (11 responses)

• London Borough of Barnet (two responses) • London Borough of Camden (two responses) • London Borough of Enfield • London Borough of Harrow • London Borough of Hillingdon • London Borough of Kingston-upon-Thames • London Borough of Southwark • London Borough of Wandsworth • Royal Borough of Kensington and Chelsea

e) Anonymous and as individuals (five responses)

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a) Consultants Hydro International – stated that in the ‘Vision’ chapter the guide makes reference to the London Sustainable Drainage and Construction Supplementary Planning Guidance minimum target of 50 per cent reduction in peak flow for retrofit or redevelopment schemes. It should be acknowledged that restricting flows to lower flow rates will sometimes result in smaller flow controls which may be more susceptible to blockage. However, replacing throttle pipes or simple orifice plate type controls with modern vortex flow controls can result in 50% reduction in flows with negligible reduction in opening size. In some cases is may even be possible to achieve 50 per cent reduction in peak flows, whilst at the same time also providing a flow control with a larger open area. In the ‘Cost Benefit’ chapter, the respondent stated that it is not entirely clear whether the costs savings shown are in relation to construction costs only or whether they are indicative of whole life cost savings including he cost of maintenance. Reference could be made to the SCOTS whole life cost tool (www.scotsnet.org.uk) as one means of estimating whole life costs of SuDS. General comments – the respondent stated that generally, the guide is very well thought out with a good balance between practical advice, reference to other sources and case studies. The introduction provides a very good, non-technical introduction that should be accessible to a wide audience including both practitioners and non- practitioners, including the general public. Metis Consultants – stated that in the ‘Vision’ chapter, the guide provides a good summary of relevant policy that drives the need for the document; on ‘The London Context’ chapter; provides a good checklist for implementation of SuDS in London, and in the ‘SuDS on London streets’ chapter; provides good examples of implementation of SUDS in a highly urbanised environment.

In the ‘Cost Benefit’ chapter, it was suggested that this section could benefit from further detail. The debate over SUDS being more cost effective that traditional drainage systems is a difficult one to have with many stakeholders. It would be useful if more detail could be provided for the cost comparison broken down into key components. It would also be helpful to see they key drivers for the wide range of cost variation on each scenario.

General comments – the respondent stated that the guidance document repeats a substantial amount of content for other documents, e.g. in chapters three and six. This could be simplified by clear cross referencing, and focussing the content on London specific issues.

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b) Environmental KLH Sustainability – stated in the ‘Introduction’ chapter that it would be more helpful to include specificity as to the policy and regulatory drivers for designing and implementing SuDS, such as examples of GLA strategies from the Sustainable Drainage Action Plan, reference to the SuDS planning policy and relevant part of the London Plan.

The respondent stated that more explanation be made as to the purpose of the guidance and how it is different from and/or relates to the Ciria SuDS manual. A request was proposed for a section on street adoption, and guidance for local authorities on how they should update their adoption guidelines, and/or for developers/estates/landowners on what to do to convince them.

General comments – the respondent stated that is not 100% clear what the purpose of the guide is and how it relates to the SuDS Manual. It was proposed that TfL should make clear how this guidance fits in with the overall constellation of SuDS guides, policies and resources already available.

KloudKeeper Ltd., and Research Fellow (SuDS Development) – suggested in the ‘Introduction’ that in the guidance there is a lack of focus on the huge opportunities presented by the appropriate design of rainwater harvesting systems. It was suggested that more emphasis is warranted to ensure developers push for great rainwater reuse, before releasing rainwater into the downstream SuDS features.

An image supported this response – please see Appendix D

General comments – the respondent stated that this report takes the whole SuDS paradigm forwards by a significant step and is excellent.

Sustainable Drainage Systems Ltd., – proposed that in the ‘Introduction’ chapter, the addition of a simple statement be included; “Sustainable Urban Drainage a means to make sustainable our water drainage and ecology system for future generations.”

In the ‘Vision’ chapter, it was suggested that innovation should not be limited to flood risk design, but encourage designers to use every possible tool from rain water harvesting to real time control to smart devices and the internet of things.

General comments – the respondent stated the guidance was very well put together, and that it is evident that lots of hard work has gone into the production of this document, which now needs every opportunity to become a standard.

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Wild London – proposed that in the ‘Introduction’ chapter the guidance mentions the importance of plant selection for biodiversity value, and asked that more inspiring images to be used in the document.

In the ‘SuDS Components’ chapter the respondent requested that a list be added that includes plant species suitable for different SuDS components that provide for wildlife and the reasons why, e.g. long flowering season, accessible nectar for particular insects, to make people understand what wildlife needs.

A similar request for also made for trees, and their suitability for different conditions, e.g. wet/dry, exposed, sunny/shady, as well as their features that are of benefit to wildlife.

General comments – the respondent stated that this document is a good practical guide to implementing SuDS, and it is valuable to have focus on highways and public realm spaces. Very thorough and covers lots of relevant ground.

Wildfowl and Wetlands Trust (WWT) – welcomed and encouraged the interest that TfL is taking in the design of good quality sustainable drainage for London’s infrastructure, in the ‘Introduction’ chapter. In addition, WWT supports the inclusion of multiple benefits such as providing habitat for wildlife and water quality within the guide, and referred TfL to their guidance document produced by WWT and RSPB which looks at how SuDS can be designed to optimise for additional benefits.

In the ‘Vision’ chapter, the respondent suggested that an additional section be added on water resources and the potential for joining up water management. On the topic of water quality, WWT requested further detail be added about why surface water run-off tends to be polluted, how those pollutants are entering the water between the rain hitting the hard surface to when it enters the sewer, and the costs of this diffuse pollution.

In chapter on ‘SuDS Components’, section ‘Management and Maintenance’, WWT stated that many developments are required to include green space and many local authorities already manage green spaces. The respondent added, these all have the opportunity to also be, or include, valuable sustainable drainage components, and WWT recommended that this connection is made in this chapter.

In the ‘Implementation’ chapter, the respondent stated that they were really pleased to see that an ecologist is seen as an important part of the SuDS design team, and recommends that the team also engages with local Catchment Based Approach group to possibly identify particular water quality issues where SuDS can be designed to help.

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General comments – the respondent welcomed the proposal of using an ecosystems approach framework. However, this recommendation should be stronger, and feed more directly into the methodology and cost comparison sections of the guide. The respondent stated that it would be valuable for the cost comparison of different scenarios to reflect not only the cost difference between a traditional and SuDS approach, but also at how the nine scenarios could optimise non-monetised benefits.

Woodland Trust – stated that trees and woodlands deliver a major contribution to resolving a range of water management issues, particularly those resulting from climate change like flooding and the water quality implications caused by extreme weather events.

The Trust has produced a policy paper illustrating the benefits of trees for urban flooding – Trees in Our Towns – the roles of trees and woods in managing urban water quality and quantity. The Trust has also produced publications: Stemming the flow, and a joint Environment Agency/Forestry commission publication, Woodland for Water. The Trust suggests that these references are included in the appropriate sections of the Guide, and that the Guide includes a section (drawn from these references) on woodland management, and creation (in appropriate locations), within the wider catchment.

General comments – the respondent stated that they strongly support the principles and detailed guidance in the SuDS Design Guide. They added that the guide sensibly looks beyond the immediate street scene and into the surrounding catchment of open spaces.

c) Government Environment Agency – stated that the response was collective on behalf of colleagues in the Environment Agency London Team. In the ‘Vision’ chapter, ‘Maps’ section, the Agency suggested that the Thames Basic map would benefit from further annotation and perhaps significant towns or cities to demonstrate the size of the basin, although London boroughs are grey scaled on the image and this would not translate to those who do not immediately recognise this image.

In the ‘Case Studies’ chapter clarification was required for the figure for Salmon’s Brook. The cost stated is for the whole scheme cost, not just the SuDS, but, the respondent added, it doesn’t make it clear that there is a massive flood storage system on the river, and that was a significant part of the whole cost. The respondent requested clarification on this otherwise people will think the SuDS cost was extortionate.

General comments – the respondent stated that a number of the photographs feature more than once, and often the image is far too large given what it

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actually shows. Also the crediting and titling seems to have been done without much thought of text and size or location of the image. In addition, the respondent stated that some of the images do not relate to the text or document.

Greater London Authority – stated that private front gardens appeared to be outside of the remit of this guidance. The respondent added, that the cumulative effect of extensive paving over can have a detrimental impact on the public realm where drainage systems can be quickly overwhelmed from front garden run off and surface water flooding. The respondent stated that during heatwaves, the loss of front garden vegetation can exacerbate urban heat island effect.

The respondent stated that the Royal Horticultural society report ‘Green Grey Britain’ highlighted the extent of this, showing that half of all London’s front gardens are now paved over, marking a 36 per cent increase in the past 10 years, with five times as many front gardens with no plants compared to ten years ago.

The respondent requested that this guidance takes action that proactively discourages the paving over of front gardens to reverse this trend, for example, by showcasing good practice in de-paving.

General comments – The respondent proposed that a TfL/Mayoral website could be developed to provide practical information about front garden design options, adding, that council websites provide little more than rules on front garden planning permission.

London Councils – stated that, from the officer perspective (the respondent), that they were highly supportive of the production of the SuDS guide, and impressed by its contents. The respondent expressed that they would be keen to work with TfL to promote awareness of the final guidance to the boroughs.

d) Local authorities – Lead Local Flood Authority (LLFA) London Borough of Barnet – submitted two responses.

The first response (Asset/Projects/Contracts) stated that within the chapter on ‘Implementation’ the respondents main concern is that under current regulations, neither the LLFAs nor the Planners are informed whether the Developer has actually implemented SuDS that have been commented on, under the Statutory Consultee Role.

It was suggested to include a recommendation for the Developer to submit ‘as built’ drawings to the LLFA showing clearly what SuDS have been installed.

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This would inform the LLFAs what SuDS have been installed in their areas, and also help them to update their Asset Register.

The second response (Emergency Planning) stated that in their opinion the whole content of ‘Vision’ is excellent, and the ‘Introduction’ is well laid out and simple to read. The respondent added that it would be helpful to boroughs if a national campaign could be arranged to make it clear to the London residents how important all of these elements are in building resilience to flooding event.

General comments – the respondent stated that the guidance is a great informative document and helpful to local authority officers dipping their toes in the SuDS area, and its requirements for the resilience to surface water flooding events.

London Borough of Camden submitted two responses.

The first response (Energy and Sustainability) stated that in the ‘Introduction’ chapter it does not refer to the Drain London project, and should include/show the levels of flood risk in London determined by this work. This would provide a useful evidence based justification for the work.

In ‘The London Context’ chapter, the respondent stated that the chapter introduces, in their opinion, an unhelpful statement which seems to direct work away from the public realm/transport planners in central London and towards developers. The respondent’s suggestion to provide the ability to and importance of incorporating SuDS into the public realms in central London is promoted rather than undermined at this point in the document (page 33).

In the ‘Cost Benefit’ chapter the respondent stated that a stronger statement on the cost benefit of SuDS is needed her ideally linked to the case studies in the ‘Implementation’ chapter.

General comments – the respondent stated that the guidance is good, but doesn’t feel joined up with GLA’s Drain London modelling.

The borough’s second response (Transport Planning) stated in the ‘General comments’ section that the document acknowledges that one of the challenges will be ‘a lack of revenue raising mechanism to offset management and maintenance’, but then does not expand on this point any further. However, the respondent added, in a time of austerity etc., this is likely to be a significant obstacle when considering the installation of a scheme which involve new areas of planting. It would be useful if some case studies could address how other London authorities have addressed this issue, for example the breakdown of ongoing maintenance costs, either annually or five yearly, of schemes such as case studies four and eight in the chapter.

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London Borough of Enfield – stated that in ‘The London Context’ chapter that more information regarding working in close proximity to buried services is required. The respondent added that it would be useful to include a section that identifies common obstacles to SuDS implementation, such as lack of infiltration in clay soils, buried services etc., and describe how these can be best dealt with.

In the ‘Cost Benefit’ chapter the respondent suggested that it would also be useful, though ambitious, to attempt a future flood damages assessment for London and compare the cost/feasibility of SuDS as a solution with alternatives – this could address the question “Can we afford not to implement SuDS?”

General comments – the respondent stated that SuDS would need to be implemented on a massive scale to achieve the benefits identified in this guide. Ideally SuDS would be mandatory for all projects that have implications for drainage (including those on existing highways). The respondent suggested that a good place to start would be to make this a policy document and require highway/urban designers to consider flood risk implications for all projects or “maximise potential SuDS opportunities”.

The respondent proposed that the document was quite long, which could be off putting for some users. Therefore could be useful to provide a shorter more accessible user guide with adoptable standards and simple rules of thumb.

London Borough of Harrow – stated that in their opinion this documents needs to be a policy requirement from TfL and not just a guidance practice note. The respondent added, as highway authorities who control expenditure provided by TfL do not have the resources, skills or understanding to implement SuDS in public realm areas and public highways, and this is one reason why most SuDS projects are small and localised delivery by either LLFA or other local authority organisation, for example, Housing.

In the ‘Vision’ chapter the respondent stated that this section encapsulates everything that GI can provide, but a question is ‘does this align with all the London local authority local plan polices?’, as it does at Harrow Council.

In the ‘SuDS Components’ chapter the respondent suggested adding a paragraph on urban river restoration, as there are many opportunities to combine a SuDS scheme with urban rivers in open spaces/parks, and potentially in the public realm and public highway areas where deculverting could be undertaken.

General comments – the respondent stated that they would like to reinforce the point that this guidance needs to be a policy document; otherwise TfL cannot be sure that SuDS has been included or considered.

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London Borough of Hillingdon – stated that in the ‘Case Studies’ chapter that there was insufficient information of the costs elements, just the overall costs of construction are provided, when one of the key issues is the cost of maintenance and how to undertake appropriate maintenance.

In the ‘Implementation’ chapter the respondent suggested that the design process should be more focused on the practicalities of the Highways procurement process and fitting it with the planning process. The document assumes that all schemes need planning. There is no reference to the LLFA to ensure awareness of areas at risk and what should be done to manage to the flood risks. There are very few drainage engineers. Community engagement should also involve councillors.

In the ‘Cost Benefit’ chapter the respondent added that there is no information on the cost of not implementing SuDS, for example, that this risk and the risk of flooding to our Highway infrastructure will just get worse and there is not a sufficient requirement on the Utilities to solve this, so it will have to be done through Highway schemes.

General comments – the respondent asked where is the requirements that all LIP funded schemes must comply with this ‘guidance’?

Royal Borough of Kingston upon Thames – stated that in the ‘Vision’ chapter the guidance refers in two places to the London Plan’s associated Sustainable Design and Construction Supplementary Planning Guidance (SD&C SPG) ‘minimum expectation’ of a 50 per cent betterment. The respondent added, there has been much debate amongst London LLFAs, the Environment Agency, Thames Water and the GLA as the benefit of this, because it has become a target for developers to achieve, but not just the minimum but also the maximum.

The respondent strongly stated that although it may be useful to reference this requirement, the opportunity should be taken to push much more towards the need to restrict to as close to greenfield runoff rates as possible (if greenfield runoff rates themselves cannot be achieved) as per the actual London Plan Policy 5.13.

For SuDS to become the norm, the respondent added; which is what is needed to reduce the risk of surface water flooding across London, we must do all we can to push towards the aiming for greenfield runoff rates and reduce the opportunities for developers to go for bare minimum requirements which often don’t yield above ground ‘green’ SuDS features, thereby reducing the potential for all of the additional benefits which this document rightly mentions.

In ‘The London Context’ the respondent proposed that it might be worthwhile suggesting to the borough’s LLFAs are also included in early conversations,

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particularly as the LLFAs are not always sat within the borough’s Highways teams.

The respondent stated that the document provided a really good mix of case studies from across London (and wider).

General comments – the respondent stated that the guidance is very detailed and useful to demonstrate the benefits of SuDS and showing that they can be widely incorporated. The respondent suggested that TfL need to ensure that they work with boroughs to help identify opportunity locations and to push for the use of SuDS features wherever possible.

Royal Borough of Kensington & Chelsea – stated that in the ‘Vision’ chapter that it would be useful to refer to the ‘London Underground Comprehensive Review of Flood Risk’ (link is to presentation summary – Feb 2016) undertaken by TfL in 2015.

In the ‘SuDS Components’ chapter the respondent stated that in general the section provides a thorough description of the SuDS components and gives useful examples. But, what is not clear from the document is how the SUDS will be implemented from TfL and partners.

In the ‘Case Studies’ chapter the respondent commented that it is very useful to see how SuDS could be implemented, and that the ‘lesson learnt’ section is particularly interesting and useful. The respondent noted that most of the examples seem to be about SuDS in new development. One of the issues in central London is how difficult and costly it is to retrofit SuDS in existing development. Examples around retrofitting and implementing SuDS in historic environments will be very useful for most inner central London boroughs.

In the ‘Implementation’ chapter the respondent stated that it is important that the local polices are also referred to (as opposed to make a reference just to the London Plan). And it is important that anyone implementing SuDS does a thorough check of the local authority policies (Local Planning Authority and the LLFA) to reflect local conditions.

In the ‘Cost Benefit’ chapter the respondent suggested that there should be a reference to the fact that retrofitting SuDS in existing development is more expensive than in new development.

General comments – the respondent stated that the guide is a very useful document about SuDS in general. However, the lack of an action plan seems to leave the document without a clear aim or purpose. The respondent added; that the aim of document should be reinforced by clearly stating what will TfL be doing about SuDS in the near future. Will TfL use this guide to inform the SuDS it implements? Will the guide be mandatory for local authorities who want to implement SuDS in TfL roads and public space? Will TfL develop a SuDS

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action plan in the near future? It is important that this is clearly stated in the document.

London Borough of Southwark – NOTE this borough provided a comprehensive 13-page response via email, itemising requests for clarification and amendments, and detailed recommendations to be made to the draft guidance in almost every chapter. Selected comments are summarised below:

The respondent stated that in the ‘Introduction’ chapter that in general the document gets it right by taking a broad, advisory and non-prescriptive approach to considering, when SuDS might be pursued; the potential SuDS components, and what general design and other considerations are for these.

By contrast, the respondent commented that the document needs to include more detailed information about these main concerns and challenges experienced when attempting to incorporate SuDS into both new build and retro-fit highway schemes. These four points were provided and expanded upon in detail throughout the response:

• T he various environmental policy and modelling matters that will determine the viability of S uDS in the firs t ins tance

• Adoption and related legal cons iderations • T he cos t benefits of S uD S compared to conventional drainage

approaches • Maintenance requirements and regimes

The respondent commented that as the guide is quite long that it would be useful if it could provide some form of checklist for considering how to integrate SuDS into streets from an early stage.

The respondent added that the intended audience and scope of application of the document is not clear, and stated that it is important to clearly establish this distinction early on and for it to run throughout the document.

In ‘The London Context’ chapter, one of the recommendations was for the document to include greater detail about the purpose and benefits of geotechnical/geoenvironment surveys, soil resource plans, soil resource management plans, and utility surveys.

In ‘SuDS Components’ the respondent recommended that the guidance included some typical examples to demonstrate the volume of surface water which can be attenuated by the various types of SuDS, which can be done by consciously monitoring before and after surface water flows. The respondent added that LB Hammersmith & Fulham is undertaking a study of this kind.

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Within the same chapter trees were discussed. The respondent stated that several important issues are currently overlooked which were recommended to be included. Two issues included; creating attenuation or infiltration areas around trees, which would typically kill them. Whilst it can be beneficial to redirect surface water to existing tree pits from surrounding pavements, this can only safely be done without full water quantity modelling and complex ground improvements for very small quantities of water.

The second issue regarding trees stated that although the beneficial cooling impacts of tree transpiration is mentioned in the document; the respondent suggested that this virtuous cycle between trees and SuDS deserves further explanation and emphasis. In particular, it should be explained that, during hot summer months, trees will not only transpire (and so cool streets), if they are able to obtain enough water from their rooting zones to replace that which they lose via leaf surfaces etc., coordinated SuDS can help provide this.

In the ‘Case Studies’ chapter, the respondent stated that the guide provides some fairly limited information about the comparative cost of SuDS to other approaches. However, the respondent added, that the level of information provided is not sufficient to allow objective assessment or change views.

Within the same chapter, the respondent added that the document does not provide much advice on maintenance, and in their experience, this is one of they key concerns that is limiting the uptake of SuDS by Highway authorities and others. Recommendations were made to include some dedicated maintenance case studies of SuDS that have been in place for a while.

The respondent suggested including these additional references to the Appendix chapter of the document:

• Islington Council’s ‘Promoting Sustainable Drainage Systems: Design Guidance for Islington’

• CIRIA (2016), CIRIA 737 ‘Structural and Geotechnial Design of Modular Geocellular Drainage Systems’

• BSE (2014), PAS 128:2014 ‘Specification for underground utility detection, verification and location’

• DEFRA (2009), ‘Construction Code of Practice for the Sustainable Use of Soils on Construction Sites’

• Urban, James (2008), ‘Up by Roots’

London Borough of Wandsworth – stated that in the ‘Introduction’ chapter a hierarchy flow chart diagram would be useful for the purposes of considering SuDS in development. This could also include the need for water flow analysis of a site for use by DM officers for major sites.

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In ‘The London Context’ chapter the respondent requested that the document needs to clarify that much of London cannot use soakaways due to clay soils.

In the ‘SuDS Components’ chapter the respondent stated that it would be useful if the document provided some more detailed drawings of permeable parking bays and rain gardens, which are most likely to be used by LB Wandsworth, on borough roads.

In the ‘Cost Benefit’ chapter the respondent requested a section on what are the cost benefits for developers; negotiation and convincing applicants that its is worth their while. This could cover impacts on viability appraisals where affordable housing is being proposed on mixed-use developments.

The respondent asked if there could be some commentary on SuDS’s quick wins and/or the most cost effective.

e) Anonymous/Individual responses Anonymous – stated that most of the technical information is included in CIRIA C753 (The SuDS Manual 2015), and pointed out that the chapter on ‘Implementation’ in the guide opened with this statement; “Much of the detail can be found in the CIRIA SuDS Guidance, from which the design process diagram has been adapted.”

When making reference to the Appendix, the respondent asked why is TfL funding and publishing this document, when the information exists in better form from other sources?

General comments – the respondent stated that the document is far too long, not focused on its purpose, doesn’t provide technical information on minimums or best practice, overstates the importance of TfL within this field, and provides repetitive case studies.

Anonymous – stated in the general comments section only that lots of the proposed changes in this scheme provide opportunities for employment with regards to construction and maintenance. The respondent went on to say that this is a positive economic benefit that should not be understated, however, they added; this also requires a commitment to long-term investment.

Individual – commented that in three chapters, ‘The London Context’, ‘SuDS Components’, and ‘SuDS on London’s Streets’, that the document should cover the chapter better.

Individual – stated that they thought the ‘Introduction’ chapter is clear on purpose, but perhaps could emphasise some for the recent flood events that have impacted the UK.

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In the ‘Case Studies’ chapter, the respondent proposed two case studies to be considered for the document; Queen Elizabeth Olympic Park; a great example of SuDS and landscape in a new city park where a combination of swales and attenuation protects 5000 properties from flooding.

The other case study to consider is that of Sheffield ‘grey to green’; where a retrofitted urban SuDS schemes is highly ambitious, and one of the largest in the UK.

General comments – the respondent stated that the document was a generally very good guide targeted at a non-technical audience and emphasised benefits.

Individual – the respondent stated they are the Chair of the London Tree Officers Association, and suggested that the purpose of the document is not clear, that there seems to be no call or need for it, and that London does not require a standalone document.

General comments – the respondent suggested that more emphasis should be placed on maintenance and the information within the chapter should be revised. The respondent added that he understood TfL specialists managing arboriculture, landscape, streetscape and drainage, all believe this document to be of little or no value. He hoped that these specialist opinions by those responsible for leading on SuDS will be given appropriate weighting in the final analysis of this draft document.

The consultation received an email response from GroundWork eight days after the consultation date closed, and therefore its contents were not included in the overall number of responses.

The respondent from GroundWork commented that as they manage one of the projects featured in the ‘Case Study’ chapter, the Queen Caroline Estate, they would like to provide updated photographs.

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5. Response to issues raised We have summarised below the changes made to each chapter as a result of comments received during the consultation.

Overall The greatest numbers of changes took place in the Introduction and Chapters 1 and 2. This was primarily to address requests for a clearer narrative and to remove duplication and repetition. Chapters 4-7 did not receive such extensive rearrangement; however they were edited extensively based upon comments received.

The majority of respondents expressed support of the guidance and are keen to see it used. There were suggestions that the guidance should be made mandatory through policy stating that as guidance document, this is not enough. This request is beyond the scope of this guidance.

Introduction The Introduction section has been reduced in length from five pages to three. The opening page was edited to emphasise the purpose of the guidance. It clarified the relationship with other public realm and SuDS-related guidance. Some of the material previously located in Chapter 1 was relocated to this section, as it was felt to be more relevant. The section ‘Who is the Guidance for?’ was moved from fifth to second place, recognising the importance of clarifying this issue at the very start.

Further emphasis was provided with regard to the relationship between surface water, SuDS and the design of the urban realm; this is in many ways the raison d’etre of the guidance. The final section of the Introduction section ‘VI Structure of the Guidance’ was re-edited to reflect the considerable changes in the chapters’ contents that had taken place following the consultation and subsequent re-edit.

Chapter 1 - Vision Section 1 ‘Planning for the future’ was rewritten completely in order to provide a strong, clear message regarding the need for SuDS. Again, this addressed the comments that questioned the purpose and relevant of the guidance. The guidance should be used alongside the London Sustainability Action Plan; this point was made more clearly.

This chapter was similarly shortened from 14 pages to nine, and was partly achieved by relocating introductory text to the preceding chapter and moving London-specific material into Chapter 2. This means that Chapter 1 now focuses solely on planning for

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SuDS, with the London-specific content addressed in Chapter 2. It also allowed the chapter to emphasise that SuDS are not solely about drainage; they also have multiple benefits.

In response to the comments centred on the London Sustainable Drainage and Construction SPG and its requirement for a minimum 50 per cent attenuation, this part of 1.1 was rewritten to highlight the desire to deliver greenfield rates, where possible. Further information was provided to relate this to the aims of the London Sustainable Drainage Action Plan.

Chapter 2 – The London Context Throughout the consultation comments, respondents had expressed reservations concerning the relevance of this document specifically for London. This chapter was revised to contain all of the London-specific information which was previously distributed throughout all chapters.

Despite receiving extra material from the Chapter 1, this chapter was shortened from 16 pages to 12. This was achieved through a combination of text editing, using smaller images and removal of photographs which did not provide useful information. Maps and diagrams were retained and placed closer to corresponding text. The map of the Thames River Basin is now annotated to aid orientation.

Sections 2.9 to 2.13 inclusive were suggested for removal by some respondents. While this was felt to be excessive, these sections were all shortened, based upon comments received. Section 2.8 ‘Retrofitting’ was strengthened to reflect the fact that most SuDS opportunities in London’s streets will occur in already-existing environments.

Chapter 3 – SuDS Components Unlike the preceding chapters, the basic structure of Chapter 3 did not change. It was, however, reduced in length from 45 to 34 pages. This was achieved by removing those case studies which duplicated the same SuDS techniques. The word count was also reduced via editing.

Clarifications and corrections were received for various SuDS components, particularly trees and tree pits. Better links were also made between the London context and the limitations on SuDS components (e.g. infiltration being difficult with clay soils).

Respondents stated that there was not enough information in Chapter 3 on maintenance. This section has been doubled in length, with further information given on the specific maintenance needs for SuDS components. The wording of the maintenance chapter was also reviewed by Steering Group members from the GLA and CIRIA in order to emphasise this aspect more fully.

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Chapter 4 – SuDS on London’s Streets The main change to Chapter 4 has been the removal of all narrative on the Streets Types matrix. Respondents suggested that this was irrelevant to SuDS components and was therefore a distraction from the guidance’s purpose. The introductory page was edited accordingly.

Some images contained annotations to streetscape features (e.g. bollards) that had nothing to do with SuDS. These were considered to be a distraction and were removed.

The fifth street scenario was removed to address comments which stated that this section was repetitive. Chapter 4 was repeatedly stated by the respondents as the most useful chapter of the guidance, and so we chose to retain the remaining eight street scenarios. Annotations on the street scenarios were edited, and references to non-SUDS features were deleted.

Chapter 5 – Case studies As with the short case studies in Chapter 3, these were reduced in number from 30 to 24, thereby reducing the chapter length by 20 per cent. Respondents had commented on the useful ness of this section, so advice was sought from LoDEG and CIRIA Steering Group members when deciding which case studies to keep or discard.

Case-by-case clarification and amendments were provided by people that were familiar with the case studies and this has helped to improve the accuracy of information.

Chapter 6 – Implementation This chapter remained largely unchanged, but the text was refined. As a result of the consultation, this chapter now makes reference to local planning policies as well as the London Plan.

Chapter 7 – Cost benefit As with the preceding chapter, this was left largely unchanged. Respondents requested more detail on cost comparisons. This section remained largely unchanged because it is intended as general guidance and cost comparisons will vary considerably from one site to the next.

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6. Conclusion and next steps As a result of this consultation we have made a number of changes to the final guidance, which are detailed in Section 5.

The SuDS Guidance was presented on Thursday 17 November at the New London Architecture seminar entitled: London Sustainable Drainage Action Plan & TfL’s SuDS Guidance. Around 160 guests attended, all with a professional interest in drainage and the urban realm. The keynote speaker was Frédéric Ségur, who is Director of Trees and Landscapes at the Greater Lyon Authority. The event also saw the presentation of the London Sustainable Drainage Action Plan (LSDAP), which sets out a vision for sustainable management of London’s rainwater. The SuDS Guidance complements this high-level vision by showing how SuDS measures may be implemented on the ground.

Following this event, the guidance will be published online via the TfL Streets Toolkit webpage when the design has been fully completed.

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Appendix A: Consultation questions Questions about our proposals

For each chapter of the guidance document, there is a section to provide comments. Please ensure that all comments are provided in the relevant sections of the survey.

Introduction • Do you have any comments on the Introduction? If yes, please specify the

paragraph number(s) and/or figure title(s). [Free text comment box] The Introduction includes the following sections:

I. Background II. Policy justification III. Surface water and SuDS IV. What are SuDS? V. Who is the Guidance for? VI. How should I use the Guidance? VII. Structure of guidance

1.0 Vision • Do you have any comments on Chapter 1.0: “Vision”? If yes, please specify the

paragraph number(s) and/or figure title(s). [Free text comment box] Chapter 1.0 includes the following sections:

1.1 Planning for the future 1.2 How should London’s water resources be managed 1.3 Building in resilience 1.4 What rainfall events do I need to plan for in London? 1.5 How should I approach the implementation of SuDS in London? 1.6 Principles of SuDS design

1.6.1 Water quantity 1.6.2 Water quality 1.6.3 Amenity 1.6.4 Biodiversity

1.7 SuDS Components and the SUDS Management Train

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2.0 The London Context • Do you have any comments on Chapter 2.0 “The London Context? If yes,

please specify the paragraph number(s) and/or figure title(s). [Free text comment box] Chapter 2.0 includes the following sections:

2.1 What is unique about London? 2.2 London’s geological conditions 2.3 London’s chalk aquifer 2.4 London’s soils 2.5 Contamination 2.6 Streetscapes of London 2.7 Townscape 2.8 London’s Green Infrastructure 2.9 Archaeology 2.10 Working with London’s utilities 2.11 Who do I contact? 2.12 Inclusive design 2.13 Crime and disorder 2.14 Bringing it all together

3.0 SuDS Components

• Do you have any comments on Chapter 3.0 “SuDS Components”? If yes, please specify the paragraph number(s) and/or figure title(s). [Free text comment box] Chapter 3.0 includes the following sections:

3.1 What is appropriate for London? 3.2 Structures 3.3 Infiltration systems 3.4 Filter strips 3.5 Filter drains 3.6 Wet swales and dry swales 3.7 Rills, runnels and channel systems 3.8 Bioretention systems 3.9 Trees 3.10 Permeable paving 3.11 Attenuation and storage 3.12 Detention basins 3.13 Ponds and wetlands 3.14 Management and maintenance

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4.0 SuDS on London’s Streets • Do you have any comments on Chapter 4.0 “SuDS on London’s Streets”? If

yes, please specify the paragraph number(s) and/or figure title(s). [Free text comment box] Chapter 4.0 includes the following sections:

4.1 Movement and place 4.2 Street scenarios 1-9 – double page image for each scenario.

5.0 Case Studies

• Do you have any comments on Chapter 5.0 “Case Studies”? If yes, please specify the case study, paragraph and figure title(s). Direct knowledge of individual case studies is particularly welcome. [Free text comment box] Chapter 5.0 includes the following case studies: London under 500m²

5.1 Priory Common 85 m² 5.2 Dale Court 90m² 5.3 Museum of London 100m² 5.4 Upminster Bridge swale 400 m² 5.5 Kenmont Gardens 435m²

London under 2000m² 5.6 Central Hill 640m² 5.7 Derbyshire Street 765m² 5.8 Renfrew Close 900m² 5.9 Islington Town Hall 1000m² 5.10 Rectory Gardens 1000m² 5.11 Hollickwood School 1100 m² 5.12 Talgarth Road 1200m² 5.13 Mile End Green Bridge 2000m²

London over 0.2ha 5.14 Queen Caroline Estate 0.23ha 5.15 Australia Road 0.26ha 5.16 Crown Woods Way 0.26ha 5.17 Hackbridge 0.27ha 5.18 Goldhawk Road 0.27ha 5.19 Firs Farm 0.48ha 5.20 Salmons Brook 0.77ha 5.21 Richmond Park 1ha 5.22 Coulsdon Bypass 34ha 5.23 Dagenham SIP 142ha 5.24 LuL depot roof, Middlesex 125m²

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National & International

5.25 Clay Farm, Cambridge 109ha 5.26 Alnarp, Sweden 0.37ha 5.27 Benthemplein, Netherlands 0.95ha 5.28 Rue Garibaldi, Lyon, France 15ha 5.29 Bo01, Malmo, Sweden 85ha 5.30 Augustenborg, Sweden 320ha

6.0 Implementation

• Do you have any comments on Chapter 6.0: “Implementation”? If yes, please specify the paragraph number(s) and/or figure title(s). [Free text comment box]

7.0 Cost Benefit

• Do you have any comments on Chapter 7.0: “Cost Benefit”? If yes, please specify the paragraph number(s) and/or figure title(s). [Free text comment box] Chapter 7.0 includes the following sections:

7.1 Cost Benefit 7.2 Methodology 7.3 Design life 7.4 Cost comparison 7.5 Best value

Appendix

• Do you have any comments on the Appendix? If yes, please specify the paragraph number(s) and/or figure number(s). [Free text comment box] As a guide, the Appendix includes the following sections:

o Further information o Glossary

General Comments

• Do you have any general comments on Transport for London’s SuDS Guidance document? [Free text comment box]

Questions about the respondent

Your role

• In what capacity are you responding to the consultation? drop down boxes o [As a representative of a Lead Local Flood Authority (LLFA) / o As a representative of a community or voluntary organisation / o As an individual] o Other (please state)

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• If responding on behalf of an LLFA, business, community or other organisation, please provide us with the name. [Free text comment box]

• Do you currently use CIRIA SuDS Guidance? [yes / no] drop down boxes • Are you directly responsible for approval of street designs? [yes / no] drop down

boxes

About you

• Name • Organisation • Position • E-mail address • Telephone number • How did you hear about the consultation?

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Appendix B: Copy of the stakeholder email

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Appendix C: List of 181 stakeholders by category

Accessibility/Healthcare Access in London Action on Disability and Work UK Action on Hearing Loss (RNID) Age UK London Ann Frye Aspire ATOC Centre for Accessible Environments Community Transport Association Connect Croydon mobility forum Disabled Go Disabled Motoring UK Dogs for Good Dyslexia Action Friends of Capital Transport Greater London Forum for Older People Hammersmith & Fulham Disability Forum Harrow Macular Disease Society Hearing Dogs UK Hillingdon mobility forum Hounslow mobility forum Inclusion London Independent Disability Advisory Group Innovision Islington mobility forum Joint Committee on Mobility for Disabled People (JCMD) Kensington & Chelsea mobility forum Leonard Cheshire Disability London Visual Impairment Forum Mencap MS Society NHS London National Autistic Society National Pensioners Forum PAMELA Pan-London Dementia Alliance Parkinson's UK RNIB

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Royal London Society for Blind People Scope Sutton mobility forum The Association of Guide Dogs for the Blind Thomas Pocklington Trust Tower Hamlets mobility forum Trailblazers, Muscular Dystrophy UK Transport for All Vision 2020 Wandsworth mobility forum Wheels for Wellbeing Whizz-Kidz

Business groups Association of Town Centre Management Better Bankside Department for Communities and Local Government Team London Bridge

Cycling and Pedestrian Cycling UK London Cycling Campaign Living Streets Action Group

Developers Ballymore Barratt London Bellway Homes Berkeley Group British Land Land Securities Lend Lease London Highways Engineering Group (LoHEG) London Legacy Development Corporation London Transport Asset Management Board (LoTAMB) St. James

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Public Realm Design 5th Studio Adams and Sutherland Assemble Studio Burns + Nice East Architecture Landscape Urban Design Erect Architecture Hassell Kinnear Landscape Architects Ltd LDA Design Limited Metropolitan Projects We Made That LLP Witherford Watson Mann Architects

London Highways Alliance (LoHAC) AECOM Colas Volker Highways URS Conway AECOM EM Highways-LOHAC Ringway Jacobs Siemens plc Cubic Transportation Systems (ITMS) Limited Telent Technology Services Limited

Other Asset Management Network Rail Thames Water

Environmental & Amenity Friends of the Earth Groundwork London Historic England London Wildlife Trust National Trust National Trust - London Thames21 Roadpeace Sustrans

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London Boroughs (variously covering planning, drainage, sustainability, engineering, highways asset management, project management and contingency planning) City of London City of Westminster London Borough of Barking and Dagenham London Borough of Barnet London Borough of Bexley London Borough of Brent London Borough of Bromley London Borough of Camden London Borough of Croydon London Borough of Ealing London Borough of Enfield London Borough of Hackney London Borough of Hammersmith and Fulham London Borough of Haringey London Borough of Harrow London Borough of Havering London Borough of Hillingdon London Borough of Hounslow London Borough of Islington London Borough of Kingston London Borough of Lambeth London Borough of Lewisham London Borough of Merton London Borough of Newham London Borough of Redbridge London Borough of Richmond London Borough of Southwark London Borough of Sutton London Borough of Tower Hamlets London Borough of Waltham Forest London Borough of Wandsworth Royal Borough of Greenwich Royal Borough of Kensington and Chelsea

Policy/Government departments/other authorities LoTAG LoDEG member Transport and Environment Committee

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Emergency services London Ambulance Service London Fire and Emergency Authority Metropolitan Police Port of London Authority Traffic Management Police

Government All Party Parliamentary Cycling Group Department for Communities and Local Government Department for Transport Environment Agency GLA Design Coordination Group London Councils Local Government Association London Climate Change Partnership London European Partnership for Transport

Technical/specialist expertise Building Research Establishment Chartered Institute of Highways and Transportation Chartered Institute of Logistics and Transport CIRIA Institute of Civil Engineers Landscape Institute London Tree Officers Association New London Architecture Royal Institute of Chartered Surveyors Royal Town Planning Institute Urban Design Group The Royal Parks Urban Design London

SuDS Steering Group

Environment Agency GLA Development, Enterprise & Environment LB Hammersmith and Fulham RB Greenwich

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TfL Surface: Health, Safety & Environment TfL London Underground TfL: Planning TfL: Strategy and Outcome Planning TfL: Surface Highways Client TfL: Surface Highways Client Asset Management TfL: Surface Highways Operations - South TfL :Surface Highways Operations Asset Mg’t TfL: Urban Design Thames Water

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Appendix D: Image of rainwater harvesting evaluation tool

As referenced in stakeholder response from KloudKeeper Ltd.,

End of consultation report.

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