With the momentum around responsibility for mandating SuDS in new developments having moved to local planning departments, bypassing the Flood and Water Management Act, there is now the clear potential for the emergence of a piecemeal approach.
The wider surface-water retention and run-off issues affecting a region could be sidelined in favour of local concerns, even resulting in SuDS installations being counterproductive.
On 12th September Defra announced a consultation across industry which called for views on an alternative approach to the one envisaged in the Flood and Water Management Act 2010, stating The Government has listened, and in response now wishes to consult on delivering sustainable drainage systems through changes to the current planning regime.
The consultation states that the method would use the National Planning Policy Framework, which both means the change will only cover developments of 10 houses or more, and decision-making will rest with local planning departments. The new arrangements are due to come into force in spring 2015.
By nature, local planning looks at local needs when it comes to new development, and not at the wider context. SuDS has to be holistic rather than site-specific to work properly, looking at the crucial ramifications downstream of new installations. Moving the problem onto someone elses patch could result in a nightmare scenario, when more joined-up thinking might have mitigated this risk.
The new consultation also leaves the future role of SuDS Approval Boards (SABs), which were being set up locally as required by the Flood Act 2010, mired in confusion. Maintenance requirements and responsibilities also still require clarification So who owns the new asset, and should therefore maintain it? The issue of adoption is crucial, but its purely down to how the local authority enforces it, and could leave the taxpayer with huge maintenance costs.
The bottom line is nobody is making local planners think holistically, and the proof will be in the pudding,
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