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Sustainable Drainage Systems Consultation

Date: 24/10/2014

POS  considers that using established consent regimes to deliver the SAB role is a welcome development. The planning system should consider sustainable drainage as the default drainage option and changes to paragraph 103 of the NPPF should be made to establish this. Approved Document H of the Building Regulations should be updated to set out National Standards for detailed design of SuDS and Lead Local Flood Authorities (LLFA should carry out enforcement duties in line with their other enforcement roles in the Flood and Water Management Act 2010.

Overall it is considered helpful for the developer not to have a completely separate and new regulatory system, the proposed process would be simpler and lead to less confusion. It is a good idea in theory to have a single point of contact however the society is concerned that considering staff turnover, career development and budget cuts that this will not work in practice. 

In general terms the draft standards include significant caveats such as "where reasonably possible" to ensure that the measures aren't so onerous as to prevent development. As the need for sustainable drainage would be a material planning consideration other considerations, such as the presumption in favour of sustainable development, would carry out this role effectively, so the caveats should be removed. 



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