Comment

Representation ID: 46201

Received: 11/10/2021

Respondent: Vulcan Property II Limited

Agent: Maddox Planning

Paragraph 169 of the Framework states that ‘Major developments should incorporate sustainable drainage systems unless there is clear evidence that this would be inappropriate’. The draft text to Policy CC6 states that ‘All new developments should incorporate SuDS and all development proposals should provide details of adoption, ongoing maintenance, and management of SuDS’. The proposed requirement that all new development incorporate SuDS is inconsistent with the Framework and should be amended to meet the test of soundness. The Framework (paragraph 167 (c) ) requirement that development proposed in an area at risk of flooding incorporate sustainable drainage systems is also subject to a caveat ‘…unless there is clear evidence that this would be inappropriate’. This should be reflected in the draft development plan policy.