EFRA’s conclusions are strongly aligned with many of the key points the NFU called for as part of the consultation:
- SuDS to be considered for all developments, irrespective of the number of homes they serve or their position within the catchment;
- Greater clarity to be provided on who funds and is responsible for the long-term maintenance of SuDS;
- For tighter rules on the standards of SuDS, to ensure higher quality designs
The NFU's response to the EFRA inquiry into SuDS and reservoirs
The NFU's flooding manifesto
Wider considerations of involvement in natural flood management
However we believe that EFRA failed to put greater emphasis on requiring those responsible for the maintenance of SuDS to make retrospective changes when there is a demonstrable detrimental impact to other businesses and property within the catchment. Although there were calls for greater incentives to retrospectively fit SuDS on older properties.
The correct uptake of SuDS is vital to ensure the sustainable development of the 1million homes planned to be built by 2020. It is important that the correct policies and best practice are in place so that any new development does not have a negligible impact on flood risk to other businesses and properties in the catchment. We therefore also support calls made by EFRA to make it harder for developers to opt out of installing SuDS on cost or practicality grounds.
With regards to reservoirs, we are broadly content with the decision to make all reservoirs above the 25,000m3 threshold subject to ‘risk based’ safety rules. We welcome EFRA’s conclusions that more evidence is required to drop this figure to 10,000m3 as has been previously suggested.