Our Comments here are also of relevance to section 5 d. Nature Based Solutions

Sustainable Urban Drainage and Integrated Urban Wastewater Management Plans

Widespread adoption of blue-green infrastructure in towns and cities would take pressure off the combined sewer and storm sewer networks, contribute to climate resilience and also generate capacity for compact growth as set out in the National Planning Framework. To maximise the capacity of existing collection systems for foul water, the discharge of additional surface water to combined (foul and surface water) sewers is not permitted by UE. The removal of stormwater from combined sewers using Sustainable Urban Drainage Systems and Green-Blue Infrastructure in new developments, and retrofitted in existing developed areas, is strongly encouraged and is particularly relevant to the achievement of compact growth objectives.

We welcome inclusion of Uisce Eireann as a partner to action F4 “Engage regularly with neighbouring Local Authorities and other relevant organisations, on regional flood management issues, and support the ongoing implementation of flood forecasting systems”.

We welcome commitments in the Climate Action Plan for “Implementation of Sustainable Drainage Systems (SuDS) / Surface Water Management in South Dublin, and the Improved Maintenance of SuDS and the Stormwater, Surface Water, and Road Gully Networks including” e.g.

F8 Drive the implementation of SuDS in SDCC Capital projects, including new builds, retrofits etc, and monitor the level of implementation.
F9 Promote and encourage community involvement in the retrofit of SuDS or development of natural flood management measures, in existing housing / developments / local area
F10 Identify 4 No Demonstration Sites or Pilot schemes to monitor different SuDs projects, demonstrating how to combine SuDS/flood attenuation systems with existing land uses.
F11 Promote and encourage the implementation of SuDS to external Developers – ensure implementation of SuDS in Planning applications in line with SDCC SuDS Guidance.

We would welcome in particular consideration of the following recent DHPLG and Transports guidance:

Nature-based Solutions to the Management of Rainwater and Surface Water Runoff in Urban Areas – Best Practice Interim Guidance Document
National (Infrastructure) Guidelines and Standards Group recent NGSG Circular 1 of 2023, and
DMURS Advice Note 5 Road and Street Drainage using Nature Based Solutions Greening and Nature-based SuDS for Active Travel Schemes - National Transport
Guidance for Urban watercourses by Inland Fisheries Ireland.

We would also like to highlight that the recast Urban Wastewater Treatment Directive (UWWTD), as proposed, includes requirements for the preparation of Integrated Urban Wastewater Management Plans (IUWWMPs) for all agglomerations above 100,000p.e. by 2030 and for selected agglomerations between 10,000 and 100,000p.e. based on risk by 2035. IUWWMPs must include both wastewater and urban runoff drainage systems and therefore in the context of Ireland they will need to be integrated plans for assets owned by Uisce Éireann (wastewater network) and the Local Authorities (storm water network). The recast UWWTD includes obligations for the reduction of pollution load from both wastewater and storm water systems (Storm Water Overflows (SWOs) and Urban Runoff respectively). If adopted, the new UWWTD will require collaboration between UÉ and LAs on integrated drainage planning, but due to the earlier delivery date for larger agglomerations will require earlier collaboration between UÉ and City Las such as South Dublin County Council.

We would therefore welcome inclusion of a commitment to explore strategic collaboration between South Dublin County Council and UÉ on Integrated Drainage Planning in the Climate Action Plan.

South Dublin County Council Draft Climate Action Plan 2024-2029 - Submissions

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