Does this mean that there will not be a maintenance period or 1 in 100 year flood event prior to adoption? SuDS 22. Once constructed in accordance with the approved design, an approving body must presume that a drainage system is functioning in accordance with the approved design unless there is evidence to demonstrate that it is not.

Laura Waiting for a specific event to occur prior to adoption, would probably mean that most SuDS would never be adopted in the short/medium term. 1 in 30 or 1 in 100, are really design parameters, not test criteria.

Hi Kevin, Thanks for you comments. I was of the understanding there would be a 12 month maintenance period OR a 1 in 30 yr/ 1 in 100 yr storm to test the system? I understand that the 1 in 100 yr/ 30 yr no longer stands. Does this mean that there will be no maintenance period at all now? Thanks, Laura

Laura Neither the original consultation draft nor current standards have included a maintenance period or test criteria prior to adoption. I personally think that any construction works being offered for adoption should be the subject of a maintenance period (as with both sewer and highway adoption), so we'll have to wait and see if anything is forthcoming.

Hi Kevin, Many thanks - I also agree with your personal view and hence find it odd that they have not included a maintenance period of some form in the near-final draft. Thanks again, Laura

My understanding is that any maintenance period will have to be a condition on the approval. Steve

Steve That is a possibility, but it hasn't been approved by Defra's lawyers as far as I know.

I have been looking at the draft National Standards and I have some questions. 1) There does not seem to be any reference to “Low Rainfall”. In the National Standards that went out for consultation in December 2011 there was the following paragraph:- “ B2. Low Rainfall, There must be no discharge to a surface water body or sewer that results from the first 5mm of any rainfall event.” 2) Water Quality, an important part of the “SuDS Triangle” is dealt with by the single and quite vague paragraph as follows:- “SuDS 13. The drainage system must be designed and constructed so surface water discharged does not adversely impact the water quality of receiving water bodies, both during construction and when operational.” In the National Standards that went out for consultation in December 2011 there was a whole section on water quality and effective treatment, making use of an environment that incorporates and supports plants, for example. The number of treatments expected in a treatment train could be established from tables that were provided. There does not appear to be any mention of water quality in relation to ground water either. 3) Once again the “Affordability” clause appears to be writ large across these standards in SuDS 25. What I would like to know is where there is “conventional” drainage within a new development, introduced as the cheaper option; will the water companies be adopting this drainage as part of the section 104 agreement? Is it me or is this document getting smaller and smaller? I feel that our task as the SAB, of introducing truly sustainable drainage that is effective, attractive and fit for purpose, is going to be even more difficult now.

Hi Mark With ref to your point 3. Whether a part of the SuDS is constructed in a conventional or SuDS manner does not have any bearing on who adopts it. The Act states that the SAB will adopt the approved system and that the SAB has to approve the drainage system. Therefore WaSCs cannot adopt any part of the SuDS.

I have to disagree with Brian on this. Sch 3 17(5) states that the system must be a sustainable drainage system as defined by regulation made by the Minister for there to be a duty to adopt. It may be that the regulations will state that everything is considered to be sustainable drainage system but I do not believe that was the original intetion of the Act. Steve

Hi All, The Scope of the Standards states that "These standards should be applied in the light of the circumstances of the particular development , and taking account of viability." I think that this may lead to differences in opinion particularly between developers and SABs and is perhaps too vague, does anyone else anticipate any issues? Stuart

Hi Steve That is the intention. The SAB will adopt the entire system.

All Don't forget that the Standards are also supported by guidance: Each Standard has an objective(s). Followed by definitions if appropriate. Then there is explanatory guidance which sets out how the objective(s) is met. And then usually a compliance assssment which the SAB can use to see if the objective(s) are met based upon the information submitted. (We are looking at collating the compliance assessments into one part of the document together with their Standard, so that a SAB can easily see if the submission complies in all respects). If the Standard has a "reasonably practicable" in it, then there will be criteria for this as well. So reading the Standards in isolation doesn't present the whole picture. Kevin

Kevin, I note that in guidance I have vieved "reasonably practicable" has been defined but unfortunately in some cases this definition relies on "viability". This in itself needs to be defined or it must be specified upon whose opinion or what evidence and measures this relies on, Regards Stuart

Harry,Please can you provide a link to enable feedback to Defra on this latest draft.

Peter As I understand it, the draft National Standards are not up for discussion. Harry's initial post does mention "belt and braces" consultation alongside formal notification to the EU and I'm not sure how that works. It was the guidance to accompany the draft National Standards that Defra put out on 3 Feb that required feedback by 17 Feb. This was to go to the SuDS Mailbox, SUDS@defra.gsi.gov.uk , though the deadline has now passed. Dave

Dave, Many thanks for the clarification, a number of people in LLFAs (potential SABs) were asking as they could not find anything on the Defra website and wanted to provide their feedback. Best regards, Peter

Dave What guidance was issued on 3rd Feb? I must have missed that. Steve

Hi Peter, Many thanks for bringing that to our attention. Could you please send any comments on the National Standards to the Defra SuDS mailbox ( SUDS@defra.gsi.gov.uk ). I will update the description of the Standards to make this clear. Best wishes, Harry

Hi Harry, You are welcome and thank you. Kind Regards, Peter