I was very interested in the last line on page 17 i.e. " Cost – two Miller Homes projects incorporating SuDS have resulted in extra over drainage costs of £1158/dwelling and £2700+/dwelling respectively". This seems to be contradictary to the advise I am getting from people like Defra which is saying that SuDs schemes should provide a lower overall cost. The trouble is most of us just don't have enough information to be able to do a like for like comparison. The other thing is in the cases mentioned, were SuDs initially considered or were they a later "bolt on". I think there just isn't enough relaible information but the problem I see is that in these difficult times and a (understandable) Government desire to improve the economy and encourage construction, will such broad, possibly over simple, statements influence the future of SAB etc. Interesting (?) times ahead. Paul Ambrose I

Useful upload. Thanks. Colleagues in the office were just the other day discussing the extent to which the development industry is aware of the Act and its implications for them. While this was presented at the HBF technical conference that tends to be attended primarily by the highways and drainage engineers and not the planners or finance people in the house building companies. Hopefully those who attended will be spreading the word within their companies. There's certainly a lot of pressure on us from developers to do things (particularly re: SuDS) that the Act currently doesn't require / allow us to do yet. The more understanding there is out there the better.

Useful reference document. Consultants are starting to see queries coming in from both sides (and we are all as confused about the current situation as others are). Developers are planning ahead and informed LLFA's are trying to get resource in post. With regards the new resources in post personal plea to those recruiting into LLFA, this SAB duties are not a junior post. These need experienced staff, near or chartered level. There is a cost to this!! The Welsh Govt are currently consulting on the proposed Adoption Arrangements and Mandatory Build Standards. http://wales.gov.uk/consultations/environmentandcountryside/adoptionarrangements/?lang=en&ts=4 + With regards +£1,000/dwelling extra we should not be suprised at that. Consider that probably includes loss of developable land, and also related SUDS works in comparison with traditional pipe drainage etc.

This presentation is extremely useful but I would like to suggest a few improvements. The MBS does not require that drain runs are under the floor slab to the front. It just requires that they end in accessible areas. For detached or semi detached they could go round the property, for other properties they could go to rear access areas. The Welsh MBS says that sewers should be in the highway as preference rather than in front gardens. The example MBS layout does not show this. It should actually be very similar to the homezone layout. “R.3. As far as practicable, sewers and lateral drains should be laid in highways or public open space. Where this is not practicable sewers and lateral drains with a nominal diameter of 150 mm or less may be laid in …” “R.11. When in a highway, the outside of the sewer should be in the vehicle carriageway (not footway) and be at least 1.0 m from the kerb line. The outside of manholes should be at least 0.5 m from the kerb line.” Note that the test is of practicability not cost. The example MBS layouts show conventional piped surface water drainage. This would now not be the preferred solution. They should be amended to show SUDS solutions. There are widely different viewpoints on whether there are any extra costs of SUDS. The presentation claims two examples of extra cost. It would be good if these could be audited by a third party to confirm that they are equal comparisons. The WaSC will only be involved in defining limiting surface water runoff rates in the minority of cases where the discharge is to a public sewer. In this situation the greenfield runoff to sewer is, by definition, deemed to be zero; so the WaSC will have to use other appropriate methods to determine the permissible discharge. Slide 16 is misleading as it is titled the SUDS management train but describes something completely different. The requirement for residents to be made aware of restrictions on extensions, building etc will apply both to SUDS and to foul sewers. Is this possibly best dealt with by a charge on the property at the land registry.

An interesting summary of some of the issues we could face if legislation as envisaged is passed. a few comments on the slides:- Slide 6 - An assumption that SAB approval will come after planning consent, we need to get the maesaage out that the reverse is probably the better option Slide 11 - In my area virtually all SW goes to soakaway with no impact on land take, so the site context will be key. Assumption that SW system is designed as an afterthought rather than as an integral part of the design, new skills required for developers? Slide 14 - The last bullet point is mischievious, the hierarchy of assessment would allow conventional systems if other options not practicable, referred to on a later slide Slide 17 - I agree with other comments, independant confirmation is required that costs are compared on a like for like basis Slide 18 - Interesting summary of skills required for an SAB, I wonder if Defra have factored them in when working out the cost to LLFA's of an SAB Slide 21 - Pressure on the Planning Authority to justify policies, do they have the right skills? Interesting proposal for SuDS Advice Maps. However it will all be academic if SAB's are ditched in order for DCLG to get it's planning reforms through.

There seems to be an assumption that kitchens and bathrooms have to be at the back of houses and that surface water has to be put into pipes. Get over that and the cost issue evaporates. So does the need for ponds