Agenda Item No. 5 EXECUTIVE - 19 MARCH 2015 ADOPTION OF SUSTAINABLE DRAINAGE SYSTEMS (SUDS) Executive Summary This paper sets out the background to sustainable drainage and the changes in legislation that are taking place. It sets out a proposed way forward to address the changes to ensure a flood resilient Borough and help reduce surface water flood risk to Borough residents. Reasons for Decision In light of the pending changes in legislation from 6 April 2015, a decision is sought on how to ensure drainage systems are installed and maintained on new major developments to a satisfactory standard. Recommendations The Executive is requested to: RECOMMEND to Council That i) the Council becomes the adopting authority for new Sustainable Urban Drainage Systems, with effect from 17 April 2015, in accordance with the principles detailed in paragraphs 4-9 of the report; ii) authority be delegated to the Deputy Chief Executive (or such persons as he shall nominate to act on his behalf) to take all necessary steps to enable the Council to become the Sustainable Urban Drainage Systems adopting authority in accordance with resolve (i) above; and iii) there be a formal review, by the Executive, of the Sustainable Urban Drainage Systems adoption scheme after it has been in operation for one year. This item will need to be dealt with by way of a recommendation to the Council. Background Papers: Sustainability Impact Assessment Equalities Impact Assessment Reporting Person: Douglas Spinks, Deputy Chief Executive Ext. 3440, E Mail: [email protected] Contact Person: Geoff McManus, Neighbourhood Services Manager Ext. 3707, E Mail: [email protected] Katherine Waters, Drainage and Flood Risk Engineer Ext. 3725, E Mail: [email protected] EXE15-399 1 Adoption of Sustainable Drainage Systems (SUDS) Jeni Jackson, Head of Planning Services Ext. 3020, E Mail: [email protected] Portfolio Holder: Cllr Graham Cundy E Mail: [email protected] Cllr Beryl Hunwicks E Mail: [email protected] Shadow Portfolio Holder: Cllr Ken Howard E Mail: [email protected] Cllr Liam Lyons E Mail: [email protected] Date Published: 11 March 2015 2 Adoption of Sustainable Drainage Systems (SUDS) 1.0 Introduction 1.1 Following a large area of the UK being impacted by severe flooding in 2007 the Pitt Review was released. It highlighted that the most significant feature of the 2007 flood event was the high proportion of surface water flooding compared with flooding from rivers. One of the key recommendations within the Pitt Review was for the Government to resolve the issue of which organisations should be responsible for the ownership and maintenance of sustainable drainage systems (Recommendation 20). 1.2 To address many of the recommendations within the Pitt Review, the Floods and Water Management Act 2010 was given Royal Assent on 8 April 2010. Schedule 3 of the Floods and Water Management Act was the implementation of Sustainable Drainage Approval Body (SAB), which would be responsible for the adoption and maintenance of SuDS drainage systems. Following a DCLG consultation, DCLG has announced that the implementation of the Pitt Review recommendation 20 will be through an update in the National Planning Practice Guide and not through the creation of the SAB. 1.3 This change is to take affect from 6 April 2015. Central Government to accompany the change. 1.4 For the success of sustainable drainage systems, long-term maintenance arrangements need to be assured. Therefore to ensure the future maintenance and functionality of the proposed Sustainable Drainage Systems and to help reduce the risk of surface water flooding in the future and make a more resilient Borough to flooding it is proposed Woking Borough Council becomes the adopting authority of all new SUDS Systems. 2.0 Sustainable Drainage Systems (SUDS) 2.1 Traditional Systems 2.2 The traditional method of draining excess surface water from built up areas has been through underground pipe systems. These systems are designed to convey the water away from the development as quickly as possible. 2.3 This has historically led to the degradation of rivers, wetlands and groundwater resources through pollution and resource depletion. The traditional systems have had insufficient regard to effective catchment flood control and water quality management, often leading to an increased flood risk elsewhere within the catchment. 2.4 Conventional drainage is traditionally maintained by contractors using specialist machinery to clear gullies, pipework and areas of trash and sediment accumulation. The frequency of maintenance is normally determined by routine rather than need, as conventional drainage infrastructure is out of sight. The majority of maintenance undertaken on traditional drainage systems takes place when the network surcharges and floods upstream of the failure or blockage. 2.5 What are SUDS? 2.6 SUDS are a sequence of water management systems designed to drain surface water in a manner that will provide a more sustainable approach than what has been the traditional approach; they help to reduce flood risk and improve water quality within the area. 2.7 These systems can be made up of: • Permeable surfaces; 3 New regulations are expected from Adoption of Sustainable Drainage Systems (SUDS) • Filter strips; • Filter and infiltration trenches; • Swales; • Detention basins; • Underground storage (cellular storage and sub-base storage); • Wetlands; • Ponds. 2.8 SUDS Philosophy 2.9 The SUDS philosophy is simply, to mimic natural drainage. The majority of developments involve a reduction in permeable surfaces within the site that affect both the catchments and sub-catchments of an area. The natural hydrology is affected and through the installation of traditional systems (smooth pipes and conduits) the passage of water flow to the receiving watercourses results in higher peak flows and flooding. This can also cause greater erosion and damage to river banks and beds and a reduction in water quality through the transfer of pollution and sediments. 2.10 Another result of an increase in hardstanding (e.g. roads, roofs and paved surfaces) is a reduced supply of rainfall to groundwater by the interception of run-off. This in turn means less supply to springs and river network resulting in lower flows and increased likelihood of drought during dry periods. 2.11 The objective of SuDS encourages us to take account of quality, quantity and amenity as shown in figure 2-1: Quantity SUDS Amenity and biodiversity Quality Figure 2-1: Sustainable drainage objectives 4 Adoption of Sustainable Drainage Systems (SUDS) 2.12 By considering all three functions adequate and well designed systems should be provided that offer water quality treatment through natural process inherent in the system, encourage infiltration where appropriate and attenuate peak flows in addition to providing habitat and function for those using the area, including the local community and wildlife. 2.13 Sustainable drainage systems include a variety of components, each having different approaches to managing flows, volumes, water quality and providing amenity and biodiversity benefits, helping to drain the site effectively and efficiently without increasing flood risk elsewhere and may contribute to reducing flood risk downstream. 2.14 SuDS components work in several ways: they can infiltrate (soak) into the ground, convey (flow) into a watercourse (or if necessary a sewer), they can also provide storage on site and attenuate (slow down) the flows of water. 2.15 When selecting SuDS components the site opportunities and constraints need to be fully considered, it is sometimes schemes that provide a combination of approaches that provide the best results. 2.16 Benefits 2.17 Appropriately deigned, constructed and maintained SuDS systems are more sustainable than traditional drainage methods as they can mitigate many of the adverse effects on the environment of storm water runoff, for example by: Reducing runoff rates (i.e. reduces risk of downstream flooding). Reducing additional runoff volumes and runoff frequencies that can exacerbate flood risk and damage water quality of receiving waterbody. Reducing pollutant concentrations in storm water, thus protecting the quality of the receiving waterbody. Contributing to the enhanced amenity and aesthetics value of developed areas. 2.18 A SuDS approach to drainage can be implemented for all development sites, although individual site constraints may limit the potential for a solution to achieve maximum benefit for all functions. 2.19 Cost of installing SUDS 2.20 Defra commissioned a detailed study to provide an evidence base for drainage design and operational costs (WT1505), which was published in July 2013. The study looked at the cost implications of a SuDS design on a small site (8 dwellings), a medium site (32 dwellings) and a large site (210 dwellings) compared to a traditional scheme. 2.21 The cost of installing SuDS measures on all sites were dependent on ground conditions. Where the ground was not contaminated and therefore SuDS systems did not need lining and additional features for treatment, the costs were lower then the installation of traditional systems. Where the ground required systems to be lined, cost of installation was lower on medium and large sites but slightly higher on small sites. 2.22 Therefore the cost to developers for the installation of SuDS features should not be prohibitive. 5 Adoption of Sustainable Drainage Systems (SUDS) 3.0 Changes to National Planning Practice Guidance 3.1 The change announced by the Minister to address surface water drainage will occur within the National Planning Policy Guidance through the publication of the National Drainage Standards and its accompanying guidance. This change will help strengthen existing legislation and guidance to ensure flood risk is not increased through all major applications (i.e. greater than 10 dwellings, more than 1000m² or greater than 1 hectare). All major applications will need to meet these drainage standards and sustainable drainage will become a material planning consideration, which will require that the relevant detailed drainage design will need to be submitted at the planning application stage. However, this change does not address the long term inspection and maintenance of the proposed systems for the lifetime of the development. If the drainage systems are not properly maintained, the risk of failure increases and subsequently so does the risk of flooding. 3.2 In a ministerial announcement, issued on the 18 December 2014, it was stated ‘local planning authorities should satisfy themselves that the proposed minimum standards of operation are appropriate and ensure through the use of planning conditions or planning obligations that there are clear arrangements in place for ongoing maintenance over the lifetime of the development’. 4.0 Process 4.1 The adoption of SuDS needs to start at the pre-application stage of a development to ensure the proposed system meets all adoption criteria and the future maintenance of the system is agreed upfront. 4.2 A Draft Process from Pre-Application to adoption and maintenance is included in Appendix 1. 4.3 It is important to note that the Local Planning Authority cannot make a developer agree to passing over the drainage system for Council adoption. If the Developer decides they do not wish for the system to be adopted then it may be necessary to ensure that noncompliance bonds are agreed for the lifetime of the development, details of the maintenance and management of the systems still needs to be agreed with the LPA before hand and included within an planning obligation under Section 106 of the Planning Act which would also secure step in rights and enforcement powers. This could include the ability to enforce in future against individual homeowners forming part of a residents management company or individually. 5.0 Planning 5.1 The changes in guidance will only apply to all major planning application determined after 6 April 2015. 5.2 If the Borough is to become the adoption authority for SuDS features (Thames Water will still be the adoption authority for all traditional drainage systems that do not include a SuDS feature), then the concept of SuDS drainage needs to be considered during preapplication so that it can be determined if the developer wishes for the system to be adopted and what features would be best suitable at the site to ensure flood risk is addressed appropriately. 5.3 Not all major planning applications are, or will be, subject to detailed pre application discussion. 6 Adoption of Sustainable Drainage Systems (SUDS) 5.4 The local validation list (draft in Appendix 2) would need to be updated to ensure all relevant drainage information, calculations and designs are submitted with an application to allow the drainage design to be reviewed and determined in accordance with the Drainage Standards (Appendix 3). Relevant Officers in the Planning Service would be responsible for implementing this element of the process; discussions on this have taken place at Officer level in the wider Surrey context to ensure commonality of process where possible as this will assist developers/applicants. 5.5 The Drainage and Flood Risk Engineer will have 21 days to review and respond to the planning consultation in relation to all drainage and flood risk matters; the consultation would only be triggered once the major application has been validated. If the Preapplication discussions have been carried out fully then the details and principles should have already been agreed. 5.6 To ensure the calculations and design are correct the System 1 hydraulic model of the proposed SuDS drainage network will need to be reviewed in detail by the Drainage and Flood Risk Engineer. 5.7 Supplementary Planning Document (SPD) 5.8 To help guarantee proposed SuDS drainage systems are appropriately considered at each stage of the development process and to ensure resilience to flooding for the entire Borough from all sources, it may be necessary for a SPD to be completed for Drainage and Flood Risk Management. This would help developers to produce clear and accurate Flood Risk Assessments and SuDS drainage schemes that confirm the proposed development has been suitably designed to take all flood risk sources into account and provide the appropriate mitigation measures to help safeguard the development and surrounding area from the risk of flooding. This will be a matter for consideration by the Head of Planning Services in conjunction with Members. If it was considered to be a useful tool it is unlikely to be in place earlier than 2016 given current Local Development Scheme commitments. 6.0 Construction & Inspection 6.1 It is vital that SuDS construction is supervised and inspected on completion if owners and Woking Borough Council are to avoid taking on liabilities. This will help to ensure that the specified materials are being used and that they are being placed correctly. Incorrect materials or installation should be rejected as they will adversely affect the performance, maintenance costs and ultimately the serviceable life of SuDS. 6.2 It is proposed that Building Control take on this role if Woking Borough Council is to adopt the proposed system. The developer will need to pay an inspection fee (Sum to be agreed) and agree a schedule of inspections with Woking Borough Council before construction takes place. This will facilitate the correct installation of proposed SuDS schemes as per the planning consent and submitted information. 6.3 The inspections should be undertaken as necessary, and it should include photographs. As a minimum inspection could be expected to include the following: Pre-excavation inspection to ensure that construction runoff is being adequately dealt with on site and will not cause clogging of the SuDS components. Inspections of excavations for ponds, infiltration devices, swales, etc. 7 Adoption of Sustainable Drainage Systems (SUDS) Inspection of manufacturers details of membranes, inlets, outlets and any control structures associated with components. Confirmation of sources for materials, i.e. soil, planting lists and material specifications. Inspections during laying of any pipework. Inspections and testing during the placing of earthworks materials or filter materials. Inspection of the prepared SuDS components before planting begins. Inspection of completed planting. Final inspection before handover to Woking BC for adoption 6.4 The contractor installing the SuDS scheme should be made fully aware of the requirement for inspections, to time meetings and avoid work being undertaken that cannot be validated and impact on the future adoption of the system. 6.5 Verification that the SuDS have been constructed in accordance with the agreed design and specification will also need to be provided. Verification is likely to include documentation from the designer and contractor and appropriate inspection during construction. 7.0 Adoption 7.1 Adoption is related to someone or an organisation taking responsibility for management and maintenance of the SuDS components. Adoption should not be seen as a barrier to SuDS delivery, and should instead be seen as an opportunity to ensure that SuDS continue to deliver their benefits. To ensure this happens, adoption should be discussed early in the development process to help address the issue of long term maintenance. 7.2 The mechanism for a local authority to adopt SuDS features is for the applicant to enter into a Section 106 agreement under the Town and Country Planning Act, 1990 as part of the planning application process. 7.3 There are objectives on approving, accepting and adopting SuDS schemes when the National Standards have been implemented and local planning authorities need to be satisfied that SuDS schemes are designed and constructed appropriately to manage surface water runoff. They will also need to ensure that SuDS are to an adoptable standard. 7.4 Woking Borough Council adopting SuDS features will help improve the Borough’s resilience and resistance to flooding, address the concerns and issues with guaranteeing maintenance of the structures for the lifetime of the development and help address the issue with how to enforce lack of maintenance many years down the line when the land has been sold on. 7.5 Once adopted, the systems will need to be included onto a new service plan (Sustainable Drainage Systems maintenance and Inspection) and the Maintenance Plan to ensure their continued maintenance for the lifetime of the development. Following completion of the installation and inspection of the SuDS system, each feature will be added to a new GIS layer for future reference. 8 Adoption of Sustainable Drainage Systems (SUDS) 8.0 Maintenance 8.1 For landscape solutions the maintenance will be predominantly vegetation management. The correct choice of planting is crucial component to defining what the future vegetation maintenance will involve. Different plant selections have different maintenance requirements, some of which are more intensive than others. 8.2 Designers should provide an indication of the likely maintenance regime of their systems along with estimated costs of the maintenance. If a system requires special bespoke filters the supplier should be identified and Woking Borough Council made aware of the costs as this may affect the future adoption of the system or increase the required developer’s contribution. 8.3 Like all drainage systems, SuDS components should be inspected and maintained. This ensures efficient operation and prevents failure. Usually SuDS components are on or near the surface and most can be managed using landscape maintenance techniques. 8.4 For below-ground SuDS such as permeable paving and modular geocellular storage the manufacturer or designer should provide maintenance advice. This should include routine and long-term actions that can be incorporated into a maintenance plan. 8.5 The design process should consider the maintenance of the components (access, waste management etc.) including any corrective maintenance to repair defects or improve performance. A SuDS management plan for the maintenance of SuDS should be prepared. As part of the planning application, or if the development is an outline application shall be required as a condition of the planning consent. 8.6 Table 8-1 provides a breakdown of typical maintenance requirements. This should include an overview of the design concepts and a maintenance schedule for the scheme to ensure that it continues to function as intended. Funding for the adopter to maintain their SuDS may need to be resolved at the start of the development process to ensure that there are sufficient resources to maintain the system in the long-term. Table 8-1: Typical inspection and maintenance requirements Activity Indicative frequency Typical tasks Routine/regular maintenance Monthly (for normal care of SuDS) litter picking grass cutting inspection of inlets, outlets and control structures. Occasional maintenance Annually (dependent the design) silt control around components vegetation management around components suction sweeping of permeable paving silt removal from catchpits, soakways and cellular storage. Remedial ( Capital) maintenance As required (tasks to repair problems due to damage, vandalism or life exceedance) inlet/outlet repair erosion repairs reinstatement of edgings reinstatement following pollution Removal of silt build up. on 9 Adoption of Sustainable Drainage Systems (SUDS) Reinstatement of below ground attenuation features Reinstatement of permeable paving brickwork 8.7 Inspections 8.8 As part of the on-going management of most SuDS components there is a need for regular inspections to ensure that blockages, silt and excess litter are not adversely affecting the component or scheme. It is important that this is carried out and time is allowed for corrective action to be taken. 8.9 Routine inspections should be carried out once a month for most components, although some, such as infiltration devices, require less frequent visits. 8.10 This recurring attendance ensures monitoring of the drainage system, a rapid response to problems and “ownership” of the SuDS components. The inspections should be recorded on the maintenance record. 8.11 Waste management 8.12 SuDS generate waste - they are designed to intercept silt and allow the natural breakdown of organic pollutants. Regular maintenance of SuDS, including occasional removal of silt and vegetation that gathers in SuDS, is required to ensure long term performance. Good SuDS design and the use of source control and SuDS management should help to reduce and manage the accumulation of silt. This helps prevent the silt building up in the waterbodies including rivers. 8.13 Removal of silt from surface water runoff is important because a large proportion of pollutants are attached to silt particles. If the silt is removed then most of the pollution will be dealt with. Thus retention of silt in the SuDS is one of the prime objectives and should not be seen as a problem. If siltation is occurring the SuDS is doing its job correctly, whether it is a swale, a pond, a permeable pavement or a geo-cellular tank system. 8.14 Cost of Maintaining SuDS 8.15 The cost of maintaining the adopted SuDS will be through developer’s contributions secured through legal agreement on each major planning application and in addition to the CIL together with any affordable housing requirement. The maintenance costs can be calculated for each scheme using the Whole Life Cost Calculator (developed by the SuDS working party and Halcrow) and this cost, can then be used to determine the developers contribution for us to adopt the SuDS System. This calculator puts in each feature (select from Swale, Permeable Paving, Bio-retention, ponds, wetlands, Filter strips and Basins) and calculates the cost of maintenance for the lifetime of the development including, annual maintenance, periodic maintenance and capital maintenance (major refurbishment). 9.0 Designation 9.1 All adopted SuDS features will be designated under Schedule 1 of the Floods and Water Management Act 2010. If the developer decides that the site should not be adopted, the information will be sent to Surrey County Council as Lead Local Flood Authority to ensure the features are designated. 10 Adoption of Sustainable Drainage Systems (SUDS) 9.2 The designation means that the structure that performs a flood risk management function can not be removed without prior consent of the designating authority. 10.0 Implications Financial 10.1 It is the intention that adoption is self financing by application of appropriate maintenance and management fees. 10.2 To ensure the submitted SuDS designs have been carried out in accordance with the SuDS Standards, are adoptable and do not increase flood risk it would be necessary to check the submitted modelling, therefore it will be necessary to purchase the software Microdrainage (industry standard drainage modelling software) and hardware to run it. This cost implication is approximately £15k. 10.3 The regulatory work required to meet the new legal requirements is in addition to existing work carried out in the Planning Service, by Council Solicitors in making agreements under Section 106 and by the Drainage and Flood Risk Engineer and the time taken for this will be monitored. There will be additional work for Building Control which should not take away from the main fee paying work carried out by that team. Human Resource/Training and Development 10.4 Officers will require sufficient authorisations to allow flexibility to put in place resources and budgets dependent on number and scale of upcoming applications. 10.5 Officers in the Planning Service (including Building Control) will be putting in place new procedures and processes to implement this legislative change. Officers will require training and there will be continued professional development in relation to this area of expertise which will be met through the Council’s training budget. Community Safety 10.6 No community safety issues arising from this report. Risk Management 10.7 This will be a new responsibility for the Council and as such there are inherent risks. These risks primarily relate to the identification of the most appropriate, sustainable and effective solution in individual developments and the potential ongoing funding liabilities. In order to minimise the Council’s exposure to such risks, a formal review, by the Executive, of the adopted scheme will be undertaken after it has been in operation for one year. This will enable any necessary amendments to be made to the scheme in the light of experience. 10.8 There is a risk to performance in relation to major applications arising from this new legal requirement and the fact that the SUDS schemes will have to be secured through a legal agreement. Current practice to instruct legal following Planning Committee may need to change to reduce this risk or alternatively model agreements with standard clauses to enable applicants to submit Unilateral Undertakings could reduce this risk. The Council will have to ensure performance on major planning applications remains above 50% of applications determined within 13 weeks to avoid being designated a standards authority. 11 Adoption of Sustainable Drainage Systems (SUDS) Sustainability 10.9 Aim to achieve sustainable drainage solutions for the benefit of the whole Borough. Equalities 10.10 No new equalities issues arise from this report. 11.0 Consultations 11.1 The Portfolio Holders have been consulted. 11.2 On-going liaison with Surrey County Council as Lead Local Flood Authority has taken place on the principles of the proposal. REPORT ENDS EXE15-399 12 Adoption of Sustainable Drainage Systems (SUDS) APPENDIX 1 DRAFT PLANNING PROCESS 13 Adoption of Sustainable Drainage Systems (SUDS) APPENDIX 2 DRAFT VALIDATION LIST 14 Adoption of Sustainable Drainage Systems (SUDS) APPENDIX 3 DRAFT NATIONAL SUDS STANDARDS 15 Equality Impact Assessment The purpose of this assessment is to improve the work of the Council by making sure that it does not discriminate against any individual or group and that, where possible, it promotes equality. The Council has a legal duty to comply with equalities legislation and this template enables you to consider the impact (positive or negative) a strategy, policy, project or service may have upon the protected groups. Negative impact? Good relations Advance equality Eliminate discriminatio n Positive impact? No specific impact Men X Women X Gender Gender Reassignment Race X White X Mixed/Multiple ethnic groups X Asian/Asian British X Black/African/Caribbean/ Black British X Gypsies / travellers X Other ethnic group X 16 What will the impact be? If the impact is negative how can it be mitigated? (action) THIS SECTION NEEDS TO BE COMPLETED AS EVIDENCE OF WHAT THE POSITIVE IMPACT IS OR WHAT ACTIONS ARE BEING TAKEN TO MITIGATE ANY NEGATIVE IMPACTS The recommendations have no specific impact Negative impact? Good relations Advance equality Eliminate discriminatio n Positive impact? No specific impact Physical x Sensory X Learning Difficulties X Mental Health X Lesbian, gay men, bisexual X Older people (50+) x Younger people (16 - 25) X Faith Groups X What will the impact be? If the impact is negative how can it be mitigated? (action) THIS SECTION NEEDS TO BE COMPLETED AS EVIDENCE OF WHAT THE POSITIVE IMPACT IS OR WHAT ACTIONS ARE BEING TAKEN TO MITIGATE ANY NEGATIVE IMPACTS Disability Sexual Orientation Age Religion or Belief Pregnancy & maternity X Marriage & Civil Partnership X Socio-economic Background X The purpose of the Equality Impact Assessment is to improve the work of the Council by making sure it does not discriminate against any individual or group and that, where possible, it promotes equality. The assessment is quick and straightforward to undertake but it is an important step to make sure that individuals and teams think carefully about the likely impact of their work on people in Woking and take action to improve strategies, policies, services and projects, where appropriate. Further details and guidance on completing the form are available. 17 Sustainability Impact Assessment Officers preparing a committee report are required to complete a Sustainability Impact Assessment. Sustainability is one of the Council’s ‘cross-cutting themes’ and the Council has made a corporate commitment to address the social, economic and environmental effects of activities across Business Units. The purpose of this Impact Assessment is to record any positive or negative impacts this decision, project or programme is likely to have on each of the Council’s Sustainability Themes. For assistance with completing the Impact Assessment, please refer to the instructions below. Further details and guidance on completing the form are available. Theme (Potential impacts of the project) Use of energy, water, minerals and materials Positive Impact Negative Impact No specific impact X X Waste generation / sustainable waste management Pollution to air, land and water X Factors that contribute to Climate Change X Protection of and access to the natural environment X X Travel choices that do not rely on the car A strong, diverse and sustainable local economy X Meet local needs locally X Opportunities for education and information X Provision of appropriate and sustainable housing X Personal safety and reduced fear of crime X Equality in health and good health X Access to cultural and leisure facilities X Social inclusion / engage and consult communities X Equal opportunities for the whole community X Contribute to Woking’s pride of place X 18 What will the impact be? If the impact is negative, how can it be mitigated? (action)
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