Written evidence submitted by Cornwall
Council
EXECUTIVE SUMMARY
Cornwall Council has considered the consultation
carefully and considers that significant clarification is required
before any new system is implemented.
The Council seeks clear definitions of systems
that are regarded as constituting Sustainable Drainage Systems
(SuDS) and that will require consideration and approval by the
SuDS Approval Body (SAB).
The Council seeks direction on a clear and consistent
funding mechanism to cover the costs of maintaining adopted SuDS.
The Council requires clarity on the scope of
the requirement for recording and maintaining a register of flood
and drainage related assets.
COMMENTS FROM
CORNWALL COUNCIL
1. SUDS
1.1 The Act requires the Lead Local Flood
Authority (LLFA), though its SAB, to adopt SUDS that drain more
than 1 property. We feel that this threshold is set too low. We
agree that it is sensible for the Local Authority to adopt strategic
SUDS, especially where these may serve more than one development
but anticipate difficulties arising with the commitment to adopt
in situations whereby each pair of houses drain to a single soakaway
and the LA has no easy access or control over its management.
1.2 We do not believe that oversized sewers
or underground attenuation chambers or devices should be included
within the definition of SUDS. These systems should be viewed
as being part of the piped sewer network and should not require
assessment and adoption by the SAB.
1.3 SUDS can only be sustainable if a self-sustaining
and robust funding mechanism is in place. We do not believe that
Defra have accurately assessed the cost implications of maintaining
adopted SUDS. We require assurances that the new National Standards
will set out a coherent approach to SUDS funding. The approach
that we favour is one based upon up-front commuted sums set at
an agreed and standard level for each type of SUDS and with calculations
based on an agreed time period, such as 25 or 50 years.
1.4 Strategic SUDS will serve a mixture
of homes, businesses, open space, highways etc plus deliver functions
over and above their primary drainage function. This could make
the charging complicated due to the broad mix of occupancy. A
clear, transparent, consistent and equitable approach must be
taken for the funding of strategic SUDS. The Act should encourage
such systems, but is in danger of creating a barrier to regeneration
if there is a lack of clarity over the funding mechanisms and
the costs involved.
1.5 Charging for the maintenance of SUDS
must be consistent from Day 1. We believe that the notion that
SUDS costs will initially be covered through savings made from
the transfer of private sewers and that another, as yet unspecified,
mechanism will eventually take over to be a diversion that only
complicates matters.
2. Asset register
2.1 We require clarity on the level of detail
that the LLFA is expected to record in its register of flood/drainage
related assets. Experience with highway drainage alone indicates
that this could become a huge task with major cost implications.
October 2010
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