Water resources in the central area of the South Downs National Park
Part of the South Downs National Park (and surrounding area) falls within the Sussex North Water Resource (Supply) Zone. This includes parts of the Chichester, Horsham and Arun areas of the SDNP.
The Sussex North Water Resource (Supply) Zone is shown in dark blue on the Southern Water Supply Area map.
This area is served by groundwater abstraction near Pulborough. This has the potential to impact upon the Arun Valley, a Special Area Conservation (SAC), Special Protection Area (SPA) and Ramsar site. The hydrology (water quantity and its movement) of the area is essential to maintaining the habitat upon which the designation features/species rely on.
In September 2021, the Authority received advice 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 developments within this zone must not add to this impact.
Anyone considering submitting planning applications in the affected area is advised to read the following documents from Natural England in full:
- Position statement on Water Neutrality from Natural England (Sept 2021)
- Natural England Advice Note on Water Neutrality (February 2022)
- Natural England’s Frequently Asked Questions for Developers (March 2022)
All development proposals within the Sussex North Water Resource (Supply) Zone that consume mains water are potentially impacted by the Natural England Position Statement.
Development proposals that would lead to a material increase in water demand will need to demonstrate ‘water neutrality’. This means that there would be no increase in water consumption, demonstrated by a combination of water efficiency, water recycling and offsetting measures. This should be demonstrated in a water budget, showing the baseline and proposed water consumption and mitigation measures proposed. This must be submitted as part of the application.
Planning permission will be refused for development that would materially increase water use in that part of the National Park within the Sussex North Water Resource (Supply) Zone unless the planning application can demonstrate water neutrality.
The table below provides additional advice on different types of planning applications.
Type of development or application | Guidance on water neutrality |
Householder Applications (excluding annexes and swimming pools) including those defined under Schedule 2, Part 1 of the Town and Country Planning (General Permitted Development) (England) Order 2015 (as amended) Applications for Advertisement Consent. Applications for Tree Works. Full and Prior Approval applications for Telecommunications Infrastructure, including those defined under Schedule 2, Part 16 of the Town and Country Planning (General Permitted Development) (England) Order 2015 (as amended). Minor developments where there is no water usage (e.g. surface car parks/hardstanding, works to footpaths, shopfronts, recladding). Applications for Development comprising Minor Operations as defined under Schedule 2, Part 2 of the Town and Country Planning (General Permitted Development) (England) Order 2015 (as amended). Applications for Non-Material Amendments involving no increased water usage. Applications for variation of conditions involving no increased water usage. |
Most applications excluded from requirement to demonstrate water neutrality. DM officers should work with applicants to secure maximum water efficiency measures possible (SD2, SD17, SD48). |
Permitted Development | Some types of permitted development, including prior approvals, may also need to seek approval under Section 77 of the Habitats Regulations to demonstrate the proposal does not have an adverse effect |
All other types of development | 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. |
Reserved matters | Applications (that are not excluded by above criteria) relating to outline permissions granted prior to the NE position statement will be required to address water neutrality. |
Applications with pending Section106 Legal Agreements | Applications (that are not excluded by above criteria) with pending Section 106 Legal Agreements will be required to address water neutrality. |
It should be noted that water neutrality is a rapidly changing area of concern. The guidance above is a working model that may be subject to change. All rights are reserved as the local planning authority and as the competent authority to consider this matter on a case-by-case basis. |
Going forward, the SDNPA are working jointly with other affected Local Planning Authorities on a study and strategy to achieve a strategic solution for development on this matter across the Sussex North Water Resource (Supply) Zone.
The Water Neutrality Part C Mitigation Strategy
The SDNPA has been working with other affected local planning authorities on a study and strategy to deliver a strategic solution to ensure development across the Sussex North Water Supply Zone is water neutral. For more information and to view the completed studies, visit the Crawley Borough Council website.
The Water Neutrality Part C Mitigation strategy outlines a strategy to achieve water neutrality within the Sussex North Water Resource Zone, throughout the timeframe covered by the Local Plans of the relevant authorities. This includes recommending a policy approach with regards to water efficiency standards in new development and setting out principles for an offsetting scheme, which together would allow water neutrality to be met by growth identified in Local Plans. The strategy has been endorsed by Natural England.
It should be noted that the Natural England Position Statement continues to apply, and planning applications remain subject to water neutrality requirements