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Water neutrality

Water Neutrality Requirements Withdrawn

On 31 October 2025, Natural England issued a Withdrawal Statement confirming that its Water Neutrality Position Statement of September 2021 has been withdrawn.

This follows agreement between Natural England, Southern Water and the Environment Agency that a reduction in the licence cap on water abstraction will ensure with sufficient certainty that development will not adversely impact the protected Arun Valley habitats. This is the primary element of interest to local authorities in making decisions regarding relevant plans or projects, as it removes the connection between abstraction and growth.

While the licence modification will address issues related to planning, growth, and abstraction, a separate package of measures is also proposed to support recovery and enhance ecological resilience at Pulborough Brooks SSSI. Natural England has advised that local authorities are not required to consider these measures when determining relevant plans or projects.

Whilst the Position Statement has now been withdrawn, it remains the case that Horsham District Council remains the competent authority under the Habitats Regulations, and therefore must be assured that the mitigation will be effective in practice and suitably secured. Given the licence change has not yet taken place (the withdrawal statement refers to March 2026), we cannot be certain that the issue is yet fully resolved. We do though recognise and welcome the statement from Natural England as a significant step forward in finally addressing water neutrality at a strategic level.

For individual applications, we will now be using the 2024/25 water efficiency savings made by Southern Water to allow all development to move forward as water neutral from 1st November 2025. These savings were previously to be used by the Sussex North Water Certification Scheme (SNWCS), and amount to some 3,240,000 litres per day. SNWCS, for the avoidance of doubt, will no longer be launched.

For applicants, this means that:

  1. No water neutrality statement is now required;
  2. No payment into SNWCS is needed to use the Southern Water capacity referred to above;
  3. No bespoke conditions or s106 obligations are required to demonstrate water neutrality.

Please note that given the area remains at significant water stress, all applications for new housing will be required by condition to comply with the Building Regulations Part G Optional Technical Standard (currently 110 l/p/d) as required by Policy 37 of the Horsham District Planning Framework. We would welcome and support any applicant who still wishes to include water efficiencies below this standard.

To ensure continued compliance with the Habitats Regulations until the licence change has taken effect, please note that officers will continue to undertake an Appropriate Assessment of your proposals as part of their overall considerations. This will ensure your development remains compliant with the Habitats Regulations, Policy 31 of the HDPF, and Paragraph 193 of the NPPF.

For applicants who have existing planning permissions with conditions and s106 obligations requiring compliance with bespoke water neutrality mitigation, we will consider applications under s.73 of the Town and Country Planning Act to remove those conditions, and any associated applications to vary or discharge any relevant s106 obligations. If your permission is for new dwellings, we will instead apply a condition requiring compliance with the Building Regulations Part G Optional Technical Standard referred to above. This is the same condition we applied to all new dwellings prior to the 2021 Position Statement.

For current applicants, please advise your case officer of how you wish to proceed. Please note that any undetermined applications that have already been heard by our Planning Committee will need to be returned to committee to amend the water neutrality requirements, therefore you may wish to conclude your application in its current form and apply separately to vary the relevant conditions and obligations. Please note that if you wish to amend your current proposals we will need to first agree an appropriate extension of time with you.

Further updates will be set out on this page in due course, as and when necessary.