Paving Front Gardens Guidance published
With less than three weeks to go before the implementation date, the British government finally got around to publishing the new 'guidance' regarding the paving of front gardens. There had been something of a growing sense of panic as it had been unofficially stated that the information would be published yesterday, 10th September 2008, but nothing had appeared on the Communities and Local Government website by mid-afternoon. However, the document entitled "Guidance on the permeable surfacing of front gardens" appeared in PDF form this morning.
The guidance does seem to have taken notice of many of the issues raised during the consultation exercise, including the concern that the original talk of 'porous paving' was too limiting and that it took no account of the various methods of draining surface water to suds installations, so-called suds-compliant pavements . The published guidance acknowledges this and even gives examples of suitable suds installations such as rain gardens and soakaways.
In essence, the guidance requires any new or re-constructed paving to front gardens to be permeable or to drain to ground, otherwise planning permission will be required for consent to construct a non-permeable structure and/or drain onto the public highway. Planning permission will require plans to be drawn and will attract a non-refundable fee of £150 with a decision expected within 8 weeks.
There remains some confusion over the ability to connect to an existing surface water system. One part of the document states that connection to a SW system "might not be permitted development" , which is not the same as saying "is not allowed". Further complication arises due to the acknowledgement that some permeable installations will incorporate an 'overflow' pipe to allow excess water to escape to the SW system. The exact statement reads,
"If the garden is already waterlogged the sub-base below the driveway will need to be drained by connecting a pipe from within the sub-base to the drains."
This, and subsequent statements in the document seem to suggest that, while direct discharge of water onto a public highway not be acceptable, indirect discharge via the sub-base would be permitted. There's a lot of manoeuvring room here for misinterpretation, of either the accidental or intentional variety. It's very noticeable that the document does not refer to directly sending water into the SW system.
The document moves on to describe a number of design solutions, including the inevitable gravel, grass paving and the 1970s style 'two strips of paving separated by gravel', before moving on to more realistic forms of permeable paving, notably concrete block permeable paving (CBPP).
This section worries me. It talks of the construction depth of a permeable pavement being only 200-250mm, which is what we currently use for conventional paving. It seems to have taken no account whatsoever of the need for a deeper-than-normal sub-base. Indeed, the Interpave guidance for permeable paving recommends a sub-base thickness of 250-350mm, plus the 110mm needed for the 60mm block and 50mm laying course. The document states that only 150mm of sub-base will be required which does not tally with the Interpave recommendations. Given that the guidance is well-established, freely available and was provided to DEFRA during the consultation, this is a either a case of wilful negligence or woeful incompetence.
The suggestion that homeowners should seek advice from "a builder" also rankles. Builders, generally speaking, are not paving specialists. They tend to be bricklayers or joiners by trade, and some of the most appalling paving installations witnessed have been perpetrated by "builders" who though they knew what they were doing, a preference for using sand and cement, rather than clean sand, for the bedding and jointing is one of their most common misunderstandings. Just as asking a roofer to wire-in your new main circuit board might not be the most appropriate option, asking a general builder for advice on a specialised paving installation is probably not the best idea. Paving is a skilled trade: we deserve recognition as craftspersons and by suggesting that general builder can speak for our trade is little short of an insult. If you want advice about paving, ask a paving specialist!
Overall, this is not as bad as it might have been, given the pitiful wording of the original proposal, but it is still vague and will create more questions than it answers. While the more clued-up modular paving installers will be able to offer workable solutions, the large number of monolithic pavement installers, particularly those in the decorative concrete industry, will be obliged to significantly expand their repertoire to include soakaways and other suds solutions . Both modular and monolithic paving will now cost more, but the document makes no mention whatsoever regarding this, which leaves the poor old contractor to explain to the customer why their driveway is now going to cost 20-50% more than was thought originally.
Nor does it define where responsibility lies. Should a non-permeable pavement be installed, who is liable: the contractor or the property owner? There's a small but troublesome number of cowboys out there that will gleefully install the usual crappy, sub-standard paving as previously while telling the homeowner that it *is* permeable because there's just sand between the bricks, and charging extra for the privilege.
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