This is why Horsham local plan has been declared ‘toast’ and how it involves a rare snail
Horsham’s local plan and its large housing targets has been declared ‘toast’ in light of pressure on water supply for new developments.
July’s draft plan considered a total of 19,860 homes would be deliverable across the 17-year period, some of which have already been granted permission.
But this had to be delayed at the last minute to take into account new government requirements around producing a 30-year vision.
The local plan had been due to come back to councillors in November, but a further delay is now on the cards due to a position statement issued by Natural England on water neutrality.
This relates to the Sussex North Water Supply (WRZ) Zone which covers most of Crawley, the Horsham district and the northern half of the Chichester district.
Essentially it describes concerns that the current rate of water abstraction, the process of taking water from surface or underground sources, is having an impact on protected sites in the Arun Valley.
Natural England has advised that developments within this zone must not add to this impact.
The councils involved must resolve the matter in partnership through local plans and put policies in place to ensure water use is offset for all new developments.
While smaller householder applications may still be allowed in the meantime, other large scale schemes could be put on hold until a strategy is developed - that is unless they can demonstrate water neutrality.
Tiny aquatic snail under threat
Neither Natural England nor Southern Water have responded to approaches for comment by this newspaper.
But Jonathan Chowen, a former cabinet member at Horsham District Council who has raised the issue of water supply at previous meetings, explained how this was all down to the Little Whirlpool Ramshorn Snail ‘which is on the verge of extinction and their many friends’.
According to the Back from the Brink project, the tiny aquatic snail is one of the rarest, most restricted and most vulnerable freshwater molluscs in Britain.
Its website describes how it has very particular requirements and needs unpolluted, chalky waters such as marshland ditches with just the right vegetation.
Once found in about 15 sites in the South East it is now largely restricted to just three.
Mr Chowen suggested it would be technically very difficult to achieve water neutrality, especially as Southern Water in its Target 100 initiative already proposes to include all the obvious mitigation measures.
He said: “There is significant concerns regarding the current Southern Water abstraction at Hardham and further increases to serve planned new development.
“While a strategy is evolving Natural England advise that planning applications should await completion of new strategies which will not on evidence be a quick fix.
“I think this issue for us in Sussex Area North which includes the whole of Horsham district will require a total reassessment of our current and future developments as it seems from Natural England we don’t have a sustainable and secure water supply for current let alone any greater number of homes.
“It’s actually against the law to damage important habitat sites.
“So back to the drawing board, working with our parish and neighbourhood councils and their local plans to see if we can still manage modest small scale development to meet our own local home grown demand for new and affordable homes that support some of our economic needs.
“The current controversial local plan with its very high building numbers in my opinion is now ‘toast’.”
‘Review and reduce housing targets’
Roger Smith, from the Campaign to Protect Rural England’s Sussex branch, argued that with huge and unprecedented housing targets now in prospect and with development sites being imposed on the Chichester and Horsham districts that have not been allocated in local plans ‘ensuring that consequent increases in the demand for water can be met without causing irrecoverable harm to nature is essential’.
He added: “Whether the additional quantities of potable water that will be needed in consequence of the huge and unprecedented standard-method-calculated housing targets for Horsham and Chichester districts can be sourced without damaging the natural environment needs now to be determined, as a matter of urgency.
“Whether the consumption-control measures, advised by Natural England, which ultimately depend on the compliance of residents, would constrain abstraction sufficiently to prevent environmental harm needs to be assessed.
“In the meantime, housing targets and forward delivery-rates should be subject to review and reduced, and the allocation of strategic sites put on hold and the need for them reconsidered.
“This is essential because the standard method does not take in to account the environmental impact of development. This damaging omission needs to be addressed by the Government as a matter of urgency.”
Developments will have to prove water neutrality
Horsham District Council says it 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.
The council can continue to determine most planning applications for householder development, some very minor schemes and certificates.
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, the council 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.
Paul Clarke, leader of Horsham District Council, said: “The full implications of the Natural England communication still needs to be understood and its implications clarified for all, including householders, developers and our residents, both in the short and longer term.
“It is clear the water mitigation issue may impact our ability to deliver development in the future and we will need to consider this as part of our work on the local plan.
“We will continue to work together with our neighbouring councils, parishes and other stakeholders to better understand what we can and will do.”
Natural England ‘thoroughly undertaking its job’
Horsham MP Jeremy Quin said: “I welcome the fact that Natural England is undertaking thoroughly the job the Government has established it to do.
“Biodiversity matters and the actions of our generation must fully take into account the impact on all who follow. Every species has a role in our complex eco-system.
“Horsham District Council I know will take this very seriously, as they must.
“While HDC’s decisions on the Local Plan are paused, work continues through regular contact with ministers as to how they will put into effect the Prime Minister’s clear concern that we cannot alter forever the character of our rural areas in Southern England.
“These discussions have never stopped since the Government chose not to proceed with the ‘housing algorithm’ which if implemented would have significantly increased local building activity.
“I am very conscious of the widespread concerns on the rate of local building expansion. I look forward to the Government bringing forward its plans, on which I continue to be actively engaged on behalf of my constituents.”
Meanwhile a joint statement from Save West of Ifield and the Ifield Society said: “The recent Natural England directive on ‘water neutrality’ – in which housing developments must not add to the amount of water being used in the Sussex North Water Supply Zone – has the full force of law behind it.
“Developers may well attempt to challenge this in the courts, but the law is very clear and this directive overrides all other planning directives of other agencies.
“The local councils of Horsham and Crawley (both within the Water Supply Zone) now have little choice but to abandon or pause large development plans, such as the West of Ifield, Adversane and Buck Barn strategic site options.
“These developments would significantly add to the amount of water being used, as well as further threaten endangered species such as the Little Whirlpool Ramshorn snail and the Lesser Thorn-tipped Longhorn beetle.”
For more information on the current situation visit the council’s website.
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