Policy NE17 Water Neutrality

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Support with qualification
The WNS is an unproven model, to draw conclusions as to its efficacy is questionable, at best. It is likely that there will be significant additional demand for water above existing levels and offsetting this additional demand against existing supplies will prove harder, if not impossible, against existing supplies.
If the OIS fails to work, a distinct possibility, any new development in the northern area will have a negative affect on existing homeowners.
WGPC is unaware of provisions that prevent homeowners subsequently changing installed fittings or any definitive plans for rainwater capture and use within individual homes.

Portsmouth Water support this policy.

The policy should allow flexibility for the type of non-domestic buildings.

Premier support the thrust of this policy and the need to protect water neutrality through water efficient design in accordance with BREEAM or an equivalent standard. That said, the policy should allow flexibility for the type of non-domestic buildings.
Premier welcome the Council’s decision for new developments to bring forward their own offsetting schemes and taking a pragmatic approach to offsetting.

CBC Response: Policy NE17 – Water Neutrality
Crawley Borough Council (CBC) welcome the opportunity to comment on the Submission Chichester Local Plan 2021 – 2039.

The councils have been working closely together as part of the Sussex North Water Resource Zone authorities (along with Horsham District Council (HDC), West Sussex County Council, South Downs National Park Authority and Mid Sussex District Council) to address concerns raised by Natural England in relation to the additional development associated with the emerging Local Plans on the protected Habitats sites at Arun Valley (the Arun Valley Special Protection Area, Special Area of Conservation and Ramsar site).

CDC, CBC and HDC jointly commissioned consultants to prepare technical evidence to understand the most appropriate way forward and set up an extensive governance structure to manage the involvement of key partners throughout the process. This includes Natural England, Southern Water, Environment Agency, Ofwat, DEFRA and DLUHC in addition to the affected Sussex North local authorities at Chief Executive level. The aim of the joint work is to ensure water neutrality can be achieved, alone and in-combination, across the Sussex North Water Resource Zone with respect to new development, until Southern Water have implemented a strategic water supply solution(s).

CBC strongly supports the approach taken in the Chichester Local Plan Policy NE17: Water Neutrality. This approach was discussed and agreed jointly across the Sussex North local authorities and has been advised and supported by the technical evidence. The policy has been subject to a joint Sustainability Appraisal assessment undertaken iteratively alongside the development of the Local Plans draft policy by the Sussex North local authorities.

CBC’s draft Local Plan has been approved at Full Council, held on 22 February, for Publication (Regulation 19) consultation and Submission for Examination. The draft Crawley Local Plan 2024 – 2040 contains Policy SDC4: Water Neutrality which establishes the same policy requirements. The joint policy has been agreed as necessary to ensure consistency of approach across the Sussex North Water Resource Zone with respect to water neutrality.

The Water Neutrality Study evidence has confirmed, in order to achieve water neutrality, maximise development levels and maintain a viable approach, new residential development should be constructed to 85l/p/d and non-domestic buildings should achieve a score of 3 credits within the water (WAT01 Water Consumption) issue category for the BREEAM Standard or equivalent. The remaining water must then be offset by reducing water consumption elsewhere within the affected Sussex North Water Resource Zone. This approach was found to offer Offsetting opportunities which can unlock development quickly and has been costed at a viable level. It is the most likely scenario to ensure the Water Neutrality Strategy and Offsetting Scheme can be secured in a timely manner and ensure that the Local Plans are legally compliant, viable and deliverable.

CBC confirms its commitment to working jointly with Chichester District Council and the other affected authorities to secure a water offsetting scheme to support the Policy approach.

We look forward to continuing to work with you on this matter.

We are supportive of the policy requiring a maximum water consumption standard of 85 litres per person per day for development within the Sussex North Water Resource Zone. Other Local Authorities within the Sussex North Water Resource Zone are proposing the same given the need for water neutrality to avoid impacts on the Arun Valley Sites. This is a specific need given the difficulties in this area.

For information that may assist further with this policy requirement, water resources are managed locally through the Catchment Abstraction Management Strategies (CAMS). These assess how much water is available in each catchment, how much is
allocated to people and how much is needed to sustain the environment. An Abstraction Licensing Strategy is derived for each catchment and is published here: https://www.gov.uk/government/collections/water-abstraction-licensing-strategies-cams-process

Greywater recycling is likely to be needed to achieve this target, and the District may wish to talk further with relevant water companies to understand if there is funding available to assist with the delivery of such schemes.

The RSPB supports Policy NE17 and the implementation of the Water Neutrality Strategy and the associated mitigation requirements for water neutrality. The RSPB is supportive of the requirements to secure water efficient design in new development, which promotes water use reductions before looking towards the need to mitigate water use through offsetting schemes.

See attached representation.

See attached representation.

Thank you for consulting Horsham District Council on the Chichester Proposed Submission Local Plan 2021-2039. We are grateful for the opportunity to be able to comment on your emerging plan. Overall, we consider that the plan has positively sought to balance the provision of future needs with other wider objectives in a manner that contributes to achieving sustainable development. I would also take the opportunity to reaffirm Horsham District Council’s (HDC’s) commitment to continued dialogue under the Duty to Cooperate and joint working between our two councils. We have a number of comments on the Proposed Submission Chichester Local Plan 2021 to 2039 to make on individual policies which we have set out below:

Policy S1 Spatial Development Strategy

We support this policy in principle, but consider it is not justified as stands. We note the spatial distribution in the plan period is split into three areas: East – West Corridor, the Manhood Peninsula, and North Plan area (which is the only part of Chichester district which directly adjoins Horsham district). HDC acknowledges Chichester District Council’s position that it is not able to meet its entire identified local housing need of 638 dwellings per annum, given the constraints associated with the required upgrades to the strategic road network in order to facilitate growth, potential environmental constraints and wider infrastructure restrictions. It is understood that National Highways requires a cap on growth due to the limited capacity of the A27. The proposed housing supply target is therefore 575 dwellings per annum.

HDC acknowledges and welcomes that significant effort has been put into identifying development capacity in a way that reflects the principle of positive planning. Nevertheless, the NPPF and PPG set a high bar for ‘leaving no stone unturned’ in respect of meeting development needs. We support that planned growth is directed to sustainable locations where access to local services and access to transport links are easier to access than remote rural areas. It is acknowledged Chichester City is the most populous settlement in the district as well as being most sustainable. We support that growth and future development should be focussed in the East-West Corridor, and in particular in or close to the City, first and foremost. We also acknowledge wider infrastructure deficiencies will need to be addressed in strategic locations before they can accommodate more growth.

We support your continued dialogue with National Highways to support improvements to the strategic road network and note a Statement of Common Ground (SoCG) will be published and updated as part of a continuous dialogue with National Highways. The SoCG is important as part of the justification for a lower housing supply figure and should transparently demonstrate why the constraints on the A27 will not allow higher growth in the East West corridor, in order to evidence that maximum housing needs have been achieved in the City and East West Corridor. This evidence is needed for HDC to inform its own DtC position with Chichester District Council (CDC).

Chichester District is planning below the standard methodology housing target and has therefore asked HDC if it can accommodate some of Chichester’s unmet housing need. HDC has confirmed that we are not in a position to accommodate Chichester’s unmet development needs because of our own water neutrality constraint. Furthermore, the primary housing market for Horsham District is the Northern West Sussex HMA, whose development needs are substantially driven by the Gatwick sub-region, and it is this HMA that would be prioritised with respect to meeting unmet development needs.

As a partner in the Sussex North Water Neutrality grouping also impacted by this constraint, CDC jointly owns the relevant evidence, and our two authorities share an ongoing commitment to work on this as our Duty to Cooperate dialogue continues. As ever, the latest position with regards to Water Neutrality and the impact on the delivery of housing and other development needs can be set out in a Statement of Common Ground (SoCG) between our two Councils.




Policy NE16 Water Management and Water Quality

We support this policy which is clear in its encouragement of efficient use of water as part of good management framework.

Policy NE17 Water Neutrality

Water neutrality is a significant issue affecting both our districts. Horsham District Council supports this policy which is derived from the joint work undertaken by Chichester District Council, Horsham District Council and Crawley Borough Council. We look forward to continued working with CDC on the development of the implementation scheme, in order to deliver the JBA Water Neutrality Assessment study. This will ensure all new development is in conformity with the Habitat Regulations and can demonstrate water neutrality.

Policy H1 Meeting Housing Needs

As outlined earlier in this response, we acknowledge that land supply in Chichester is constrained, and that CDC meeting the full housing requirement within its administrative boundary during the plan period up to 2039 would be challenging. Horsham District is not however in a position to accommodate any of Chichester District’s unmet housing need because of water neutrality and, looking forward, the need to prioritise meeting unmet needs within our primary housing market: the Northern West Sussex HMA.

Policy H2 Strategic Locations/Allocations 2021 -2039

A significant proportion of CDC’s housing supply will be delivered through strategic allocations. Loxwood (220 dwellings) is identified as a strategic allocation and will come forward through the local plan process, with some allocations anticipated to be delivered through local neighbourhood plans. Given the challenges that face Neighbourhood Planning groups in the preparation and delivery of Neighbourhood Plans, (which can potentially delay the delivery of these allocations), we support the identification of strategic sites in the Local Plan, programmed for delivery earlier in the plan period.

As the delivery of strategic allocations requires significant infrastructure planning, including cross-boundary issues relating to the road network, education, healthcare and community facilities, Horsham District Council welcomes continued dialogue with the relevant stakeholders, to ensure development at strategic locations such as Loxwood are delivered in a timely manner and adhere to sustainable development principles. We have some specific concerns relating to strategic allocation policy A15: Loxwood which we have set out under that policy.

Policy H11 Meeting Gypsies, Travellers and Travelling Showpeople’s Need.

We note your position and your requirement to provide a number of pitches and plots for the travelling community during plan period. We support your policy position for intensification of existing pitches. Horsham District can’t at this point in time accommodate any of CDC’s unmet Gypsy, Traveller and Travelling Show people requirement as we are required to first address our own shortfall, and our evidence demonstrates that this alone will be challenging.

We have a body of evidence to support our position and we will continue to share our evidence with you as our Duty to Cooperate dialogue continues over the coming months. As ever, the latest position regarding Gypsy, Traveller and Travelling Showpeople will be set out in the Duty to Cooperate Statement of Common Ground between our two Councils.

Policy A15 Loxwood

We support this policy as it will contribute to meeting Chichester District’s unmet housing need, but consider it is not justified as stands and that its effectiveness could be improved. The five villages in the north of the Plan area (Kirdford, Wisborough Green, Loxwood, Ifold and Plaistow) are classified as Service Villages in the emerging Chichester Local Plan. They provide a reasonable range of basic facilities (e.g. primary school, convenience store and post office) to meet the everyday needs of local residents, or are villages that provide fewer of these facilities but that have reasonable access to them in nearby settlements. Loxwood is the strategic site identified to accommodate 220 dwellings over the plan period.

The nearby settlement of Billingshurst, in Horsham District, is considered to be the nearest main settlement to the villages identified above. Given the limited facilities available / or to be provided as part of the Loxwood allocation, it is considered that new residents are likely to be reliant at least some key facilities in Billingshurst, potentially including the GP surgery, the railway station (and rail user car park), The Weald secondary school and sixth form, the library and the retail and community facilities, including the leisure centre. Within Horsham District, there are potential proposals for strategic scale extensions to Billingshurst / new settlements relatively close to Billingshurst. Whilst no decisions have been made with respect to our local plan, housing growth delivered through our own local plan will create potential impacts on existing infrastructure which is already under significant pressure. We therefore require clear evidence that potential cumulative impacts on settlements in HDC have been considered as part of the proposed allocations. We would ask that CDC works collaboratively with HDC and other stakeholders to ensure future pressures on infrastructure in Horsham District is appropriately addressed. Consequently, we seek further clarification in Policy A15: Loxwood to emphasise the importance of collaborative working between stakeholders to mitigate against the potential cumulative impact of development.

I do hope these comments are helpful. I would like to emphasise that they are made in anticipation of further constructive dialogue between our authorities, and with an expectation that matters on which we have flagged concern can be readily addressed, and quite possibly eliminated through our Duty to Cooperate discussions. Should you require any further detail or information in regard to this response please don’t hesitate to contact a member of my Strategic Planning team.

For the avoidance of doubt, it is respectfully suggested that the title of the draft Policy be amended to ‘Water Neutrality within the Sussex North Water Resource Zone’.

See attachment.

Recommend Part 1a and 1b should be under heading ‘Water Efficient Design’. Part 1a should also confirm whether this includes external water use or not. Point 3 of the policy should outline what is expected from an offsetting scheme.

See attached representation.

See attachment.

We would suggest the following:

4. Where an alternative water supply is to be provided, the statement will need to demonstrate that no water is utilised from sources that supply the Sussex North WRZ. The wider acceptability of and certainty of delivery for alternative water supplies will be considered on a case-by-case basis.

Adding this wording will make apparent to developers seeking alternative supply as an AEOI avoidance measure, what will required of them by the Habitats Regulations in line with the People Over Wind ruling. This will have the benefit of ensuring this policy requirement does not unintentionally encourage a proliferation of developers seeking inappropriate water supply solutions while also giving your authority more confidence to reject such inappropriate proposals at an early stage, which should save your authority and developers time and resources.

Summary of advice
While we have raised some queries and recommended some further modifications to certain policies we do not find the Plan unsound on any grounds relating to our remit.
Natural England has reviewed the Proposed Submission Local Plan and accompanying appendices together with the Habitats Regulations Assessment (HRA) and Sustainability Appraisal (SA). Our detailed comments on the policies and site allocations are provided as follows:
• Annex 1 - Chapter 2 – Vision and Strategic Objectives
• Annex 2 - Chapter 4 – Climate Change and the Natural Environment
• Annex 3 - Chapter 5 (Housing) and Chapter 6 – (Place-making, Health and Well-being)
• Annex 4 - Chapter 7 (Employment and Economy) and Chapter 8 (Transport and
Accessibility)
• Annex 5 - Chaper 10 – Strategic and Area Based Policies
Please note that we have not provided comments on all policies but those which have most influence on environmental issues. Natural England has no comment to make on the policies not covered in this response. Other than confirming that we have referred to it when considering our advice on specific policies and site allocations Natural England has no general comments to make on the SA.
Unfortunately due to unforeseen resourcing issues while we have reviewed the associated HRA we are not in a position to provide detailed comment on it as part of this response. We will rectify this as soon as possible and can confirm that we have seen nothing in it that raises any major concerns.
The Plan has many positive aspects including standalone policies on Green Infrastructure (GI) and
wildlife corridors and an incredibly extensive suite of natural environment policies more generally.
We are hugely appreciative of the opportunity that we were given to work with you on shaping key policies post-Regulation 18. However, we believe that the plan needs to go further in it’s recognition of coastal squeeze as a key issue for the district, should include policy hooks for the forthcoming Local Nature Recovery Strategy (LNRS) and make up to date references to both the Environment Act (2021) and the Environmental Improvement Plan (EIP, 2023). Given how recent the publication of the EIP is we would be happy to discuss with your authority how this could best be achieved but
we believe given the wealth of natural capital within Chichester District it is vitally important that this latest iteration of the Local Plan is set in its full policy and legislative context.
We have suggested a significant number of amendments and additions to both policies and
supporting text throughout the Plan. In our view these could all be taken forward as minor modifications but if they were all acted upon they would leave the Plan much stronger and more coherent in delivering for the natural environment, one of the three central tenets of genuinely
sustainable development as set out in the National Planning Policy Framework (NPPF 2021,
paragraph 8c).

See attachment for representations on paragraphs/policies.

See attachment.

Summary of advice
While we have raised some queries and recommended some further modifications to certain policies we do not find the Plan unsound on any grounds relating to our remit.
Natural England has reviewed the Proposed Submission Local Plan and accompanying appendices together with the Habitats Regulations Assessment (HRA) and Sustainability Appraisal (SA). Our detailed comments on the policies and site allocations are provided as follows:
• Annex 1 - Chapter 2 – Vision and Strategic Objectives
• Annex 2 - Chapter 4 – Climate Change and the Natural Environment
• Annex 3 - Chapter 5 (Housing) and Chapter 6 – (Place-making, Health and Well-being)
• Annex 4 - Chapter 7 (Employment and Economy) and Chapter 8 (Transport and
Accessibility)
• Annex 5 - Chaper 10 – Strategic and Area Based Policies
Please note that we have not provided comments on all policies but those which have most influence on environmental issues. Natural England has no comment to make on the policies not covered in this response. Other than confirming that we have referred to it when considering our advice on specific policies and site allocations Natural England has no general comments to make on the SA.
Unfortunately due to unforeseen resourcing issues while we have reviewed the associated HRA we are not in a position to provide detailed comment on it as part of this response. We will rectify this as soon as possible and can confirm that we have seen nothing in it that raises any major concerns.
The Plan has many positive aspects including standalone policies on Green Infrastructure (GI) and
wildlife corridors and an incredibly extensive suite of natural environment policies more generally.
We are hugely appreciative of the opportunity that we were given to work with you on shaping key policies post-Regulation 18. However, we believe that the plan needs to go further in it’s recognition of coastal squeeze as a key issue for the district, should include policy hooks for the forthcoming Local Nature Recovery Strategy (LNRS) and make up to date references to both the Environment Act (2021) and the Environmental Improvement Plan (EIP, 2023). Given how recent the publication of the EIP is we would be happy to discuss with your authority how this could best be achieved but
we believe given the wealth of natural capital within Chichester District it is vitally important that this latest iteration of the Local Plan is set in its full policy and legislative context.
We have suggested a significant number of amendments and additions to both policies and
supporting text throughout the Plan. In our view these could all be taken forward as minor modifications but if they were all acted upon they would leave the Plan much stronger and more coherent in delivering for the natural environment, one of the three central tenets of genuinely
sustainable development as set out in the National Planning Policy Framework (NPPF 2021,
paragraph 8c).

See attachment for representations on paragraphs/policies.

Premier support the thrust of this policy and the need to protect water neutrality through water efficient design in accordance with BREEAM or an equivalent standard. That said, the policy should allow flexibility for the type of non-domestic buildings.
Premier welcome the Council’s decision for new developments to bring forward their own offsetting schemes and taking a pragmatic approach to offsetting.

Support with qualification
The WNS is an unproven model, to draw conclusions as to its efficacy is questionable, at best. It is likely that there will be significant additional demand for water above existing levels and offsetting this additional demand against existing supplies will prove harder, if not impossible, against existing supplies.
If the OIS fails to work, a distinct possibility, any new development in the northern area will have a negative affect on existing homeowners.
WGPC is unaware of provisions that prevent homeowners subsequently changing installed fittings or any definitive plans for rainwater capture and use within individual homes.

See attached representation.