Environment, Food and Rural Affairs CommitteeWritten evidence submitted by Howard Glenn, Project Engineer Flooding & Land Drainage

The White Paper refers to the SUDS consultation and to the new default build standards for new sewers (at Section 4.29). These standards are thorough and unequivocal giving detailed guidance to the required specifications. However they refer only to foul drainage.

The new build standard for surface water drainage contained in the SUDS consultation falls a very long way short of the quality and detail of the foul drainage standard and can only be described as aspirational.

Given that up to now there have been standards, in “Sewers for Adoption” covering both foul and surface water, where these were to be adopted by the water company, which bear considerable resemblance to the new build standard for foul drainage it seems incongruous to say the least that surface water should in future be guided by a document of principle only.

This is especially bewildering as the industry needs to come to terms with a totally new approach to surface water drainage which the country is relying on heavily to limit the effects of climate change on future flood risk.

A whole new protocol aimed at compliance with the Water Framework Directive on water quality is also newly introduced with little or no guidance to assist thousands of practitioners (and those who must appraise their work) across the country who have no previous experience of this subject.

There are CIRIA design guides and manuals available to which the new standards could have referred.

The committee is urged to prevail upon government to make the SUDS standards much more prescriptive in line with the new build standards for foul drainage.

9 January 2012

Prepared 4th July 2012