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ID sylw: 108080

Derbyniwyd: 07/03/2025

Ymatebydd: Seven Homes

Asiant : Pegasus Group

This policy is broadly supported, although the Councils are reminded that whilst Paragraph 181 of the NPPF encourages the incorporation of sustainable drainage systems, it also recognises that this is unnecessary where there is clear evidence that this would be inappropriate. As such, the policy must make clear that there may be instances in which exceptions can be made, with SUDS not delivered providing that there is a clear justification for this, in line with the NPPF.

Furthermore, the policy should be amended to allow for more flexibility, for example, below- ground SUDS features may be suitable in some instances, and there may be sites and schemes where it is not possible to achieve a site-wide dispersal of SUDS, as currently stipulated in the draft policy. It is noted that the NPPF provides no such requirements for SUDS.

No justification from the Council has been provided for this policy. This may have been omitted in error, but it is imperative for the emerging policy to be fully justified to be found sound. It is considered that the policy can be adequately justified, subject to the amendments recommended above.