Water Neutrality in Horsham District
Horsham District is situated in an area of serious water stress, as identified by the Environment Agency Water Stressed Areas Classification.
Horsham District is supplied with water by Southern Water from its Sussex North Water Resource Zone. This supply is sourced from abstraction points in the Arun Valley, which includes locations such as Amberley Wild Brooks Site of Special Scientific Interest (SSSI), Pulborough Brooks SSSI and Arun Valley Special Protection Area/Special Area of Conservation and Ramsar site.
On 14 September 2021, the council received a Position Statement from Natural England. The Natural England position is that it cannot be concluded that the existing abstraction within the Sussex North Water Supply Zone is not having an impact on the Arun Valley sites. It advises that development within this zone must not add to this impact.
We have been working with Southern Water, Natural England and the Environment Agency on the matter of Water Neutrality as part of our local plan evidence base.
The Position Statement is a new material consideration and the consequence of this is that Horsham District Council is unable to determine current planning applications positively unless it can be demonstrated they are ‘water neutral’ and/or that they do not result in a significant effect.
Having considered this matter we can continue to determine most planning applications for householder development, some very minor schemes and certificates under Parts 1 and 2 of the Town and Country Planning (General Permitted Development) Order 2015 (as amended) as they will not have a significant effect either individually or cumulatively on the Arun Valley sites.
All other types of permitted development, including prior approvals, will likely need to seek approval under Section 77 of the Habitats Regulations to seek to demonstrate the proposal does not have a significant effect.
In the case of all other development, where an increase in water consumption is likely, we will require the application to be accompanied by a water neutrality statement setting out the strategy for achieving water neutrality within the development. Water neutrality can be achieved by developers building significant water efficiency measures into new development and by providing offsetting measures to reduce water consumption from existing development.
If an application cannot demonstrate water neutrality is reasonably achievable this will mean the development will not meet the requirements of section 63 of the Habitats Regulations, and the application could not be determined positively.
As this is a recent and very significant matter, we will allow time for water neutrality strategies to be produced and submitted by developers where the issue of water neutrality is the only outstanding matter preventing the grant, or recommendation of grant, of planning permission.
Consideration should be given to Water Neutrality ahead of the submission of any new planning application. The requirement for a Water Neutrality Statement to support planning applications will likely become a requirement for our local list after a period of consultation