Chichester Local Plan 2021 - 2039: Proposed Submission

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.