Water neutrality: Position statement and response
On 14 September 2021, the Council received a Position Statement from Natural England. Information collected by Natural England shows that water abstraction for drinking water supplies is having a negative impact on the wildlife sites in the Arun Valley. They have advised that any new development that takes place must not add to this negative impact.
Anyone considering a planning application, with the exception of a householder scheme, should read the Natural England Position statement, the accompanying advice note, and our response on this page in full.
Natural England Position Statement September 2021
- Natural England's Position Statement for Applications within the Sussex North Water Supply Zone September 2021 (PDF File, 161.2 KB)
- Natural England Advice Note February 2022 (PDF File, 182.5 KB)
- Natural England FAQs for Developers March 2022 (PDF File, 306.8 KB)
- Natural England Addendum to Position Statement (Nov 2022) (PDF File, 101.6 KB)
Horsham District Council response
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.
Horsham District Council are continuing to consider and determine planning applications. As part of our decision making process an assessment of water neutrality will now be needed for many of our applications.
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 we did previous to the Position Statement, 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 Regulation 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.