CONSTRUCTION EMPLOYERS FEDERATION THE VOICE OF THE INDUSTRY
Sustainable Drainage Systems policy must be fit for purpose A WELL-INTENTIONED POLICY SUPPORTED BY THE SECTOR HAS THE BEST OPPORTUNITY TO SUCCEED AMID OUR NEWBUILD HOUSING CRISIS, ACCORDING TO CEF…
As the Water, Sustainable Drainage and Flood Management Bill continues its legislative path through the Northern Ireland Assembly, a key component – Sustainable Drainage Systems (SuDS) in New Housing Developments – has also been subject to a separate Department for Infrastructure (DfI) consultation. Through engagement with homebuilders, several key items have been identified as requiring further detailed consultation as part of the policy design process. We believe that. areas for focus should include: • ‘Who’ should be the SuDS approval body: Notwithstanding the good intentions of the Storm Water Management Group, the timescales of its processes with respect to the existing soft SuDS pilots were too long. We have suggested that an appropriately-resourced DfI Rivers may be a suitable option. • The importance of design guidance for developers and how this will be embraced by all planning authorities: While open to pilots in different council areas, homebuilders cannot be in a scenario where each planning authority takes a completely different approach to soft SuDS and DfI’s powers with respect to the enforceability of any guidance. An essential element to this will be how planning authorities will treat designated SuDS areas during construction. These could be appropriately used as a silt management pit to comply with any
SuDS on sites: Due to the proposed schedule of uplifts in building regulations, the Department of Finance has requested that property- level SuDS are not advanced at this stage. We would ask that that matter is fully clarified. • Importance of retrofitting: Reflecting on the Infrastructure Minister’s three-pronged approach, we again reinforce the point that mandatory soft SuDS on new housing developments will do little to resolve our housing crisis as it relates to wastewater capacity. What does offer more potential is the retrofitting of existing assets which we understand is a proposed part of NI Water’s PC28 plan as well as being included as an initial £15m allocation from the Public Sector Transformation Fund. We look forward to such retrofitting proposals being advanced. Initial co-design with DfI officials on the SuDS proposals has been very welcome – it will be important that this is seen through to a successful outcome for all.
land now for development in three+ years. The proposed timescales for soft SuDS implementation contained within the current guidance consultation are suggestive of a crossover and homebuilders need clarity now on timescales. • Crucial that SuDS count as open space: On any major site, approximately two acres of land would need to be set aside for features such as ponds. With 10% of development land normally set aside for open space on major developments, it is vital that such features are included as open space so that we do not unduly further curtail housing development. • Application and maintenance costs: Linked to the purchase of sites is also their viability. Work must be expedited on what DfI believes these costs would look like and whether their preference for a Welsh-type model is likely to proceed. It is absolutely vital that policies around maintenance and adoption are clear and robust at the very outset. • Clarity around extent of soft
agreed management plan. • Need for clarity on policy
implementation timelines: Many homebuilders will be looking to buy
For more information on the Construction Employers Federation, T: +44 (0)28 9087 7143 - E: mail@cefni.co.uk Visit: www.cefni.co.uk
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