We support the wording that "All planning applications for major development are required to ensure that Sustainable Drainage Systems (SUDs) are used for the management of surface water unless demonstrated to be inappropriate."
Planting trees as part of sustainable drainage schemes (SuDS) can slow the flow of water and reduce surface water runoff by up to 62% compared to asphalt. Trees intercept water as it falls, which is then directly evaporated back into the atmosphere. Roots help the infiltration of water into the soil, lowering the risk of surface water flooding. Tree roots can increase infiltration rates in compacted soils by 63%, and in severely compacted soils by 153%. The soil volumes provided by tree pits within hard surfaces can retain substantial volumes of water, reducing inundation and providing slow release back into natural or engineered drainage systems.
We recommend adding explicit reference to support for natural flood management to ENV10, in line with draft policies CLC1, ENV6, ENV7 and para 7.76.
This could be in a new point f) eg
f) To produce an integrated flood management plan that maximises the use of natural flood management techniques and enhances the green and blue infrastructure network.