An increasing number of Local Planning Authorities are seeking to incorporate SuDS into new developments.
However, despite representations made by HBF, legal problems (relating to adoption and long-term maintenance) have prevented widespread take-up.
Recently, the National SUDS working group published a consultation draft of their Framework for Sustainable Drainage Systems in England and Wales. The contributors to the report include various Government departments and Water UK.
The aim of the consultation is to provide an opportunity for comment, particularly on difficult matters that have been hampering the general acceptance of SUDS in England and Wales, such as agreements relating to SUDS adoption and maintenance.
HBF intends to respond and is seeking Member comments on the draft.
HBF members have experienced serious problems with the adoption of SUDS.
HBF has consistently represented that housebuilders do not see themselves as facilities managers and providers of long-term estate or services management and are consequently reluctant to install SUDS if they are unlikely to be adopted.
HBF (and others) have questioned the wisdom of creating a new system of small independent private drainage companies, contending that the drainage of roads, buildings and public areas should remain within the responsibility of larger public enterprises. This view is shared by the Environment Agency.
Although the new Part H amendment has moved some way towards facilitating SuDS, the latest Sewers for Adoption (5th Edition) makes little reference to SUDS and the general experience of members is that Sewerage Undertakers are against these systems.
The 'problems' appear to be on the increase, but as ever, evidence is patchy (and anecdotal). HBF has facilitated a number of presentations about SuDS at regional meetings and members have given some direct negative feedback to presenters on these occasions. HBF will need to assemble further evidence to enable the industry to press the case.
HBF is supportive of SuDS, but takes the position that implementation cannot be insisted upon by planners until such time as underpinning legislation, including procedures for adoption, is put in place. HBF presents papers at Water Industry Conferences (and like events) promoting this viewpoint and represents this position to planning authorities that are keen to develop policies in this area. This work is ongoing.
HBF made (largely) positive comments about SuDS during the review of Building Regulations Part H, Sewers for Adoption Edition 5 (SfA5) and PPG25 (Development and Flood Risk). Again, HBFs support was qualified by the need to ensure that the adoption problem is solved before planners, building control officers and others seek to demand SuDS on site. HBF and Water UK have established a Standing Committee to review SfA5 problems, through which SuDS-related problems can be passed on to water and sewerage company representatives.
HBF were members of CIRIA RP 555, which prepared the current national SuDS guidance document. This is a largely technical document, but flawed in that, despite HBFs best efforts, the legal issues surrounding SuDS were not addressed. HBF still attends a number of SuDS-related research projects, usually as steering group members.
HBF are corresponding members of the National SuDS Working Group convened by EA to address the problems of low levels of SuDS take-up, which includes a sub-group tasked with finding a solution to the adoption problem. HBF previously sat on a multi-stakeholder WG, chaired by Geoff Mance at EA (and involving John Hobson who was, at that time at DTLR) who were similarly briefed by Ministers to deal with this issue. The only useful outcome from this series of meetings was the establishment of the current WG to take this forward! It is to be noted that EA are confident that some good progress will be made this time and HBF are in regular contact with this group.
HBF have assisted The Greenbelt Company to develop a proposal for private management and maintenance of SuDS schemes. However EA are not supportive of the concept of private management of drainage schemes, because of the concerns about long-term viability of such arrangements. Essentially, this is in line with HBFs view that developers, owners (including private management companies) should not be left with this sort of liability and that agencies such as Sewerage Undertakers, Highways Authorities and like bodies must ultimately be the custodians of such systems.
The SuDS Framework consultation document has now been issued this can be found on the http://www.environment-agency.gov.uk/commondata/105385/suds_book.pdf(Environment Agencys website)