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Letter: Water issue means the housebuilding target must be reduced

3rd December 2021

Letter published in the West Sussex Gazette,    1 December 2021


Water issue means the housebuilding target must be reduced

In compliance with advice from Natural England, Horsham District Council (HDC) commissioned the ‘Horsham Local Plan Habitats Regulations Assessment’ (HRA), the Executive Summary of which was published as a stand-alone document in June 2021, followed by the full assessment in July.

The purpose of the Assessment was to assess the impact of ‘the development proposed in the emerging Horsham Local Plan’, including at least 18,700 new dwellings and 111,700m2 of employment space.

In respect of ‘Water Neutrality, the Assessment found that –

  1. a) achieving total water neutrality was not feasible, because it would ‘require an unprecedented restriction on water use in new-build homes, together with a very high level of retrofitting’ of existing homes with water-efficient fittings, and
  2. b) the best level of water neutrality that could be achieved was 45%.

What the environmental impact would be in consequence, and the number of new-builds for which total water neutrality could be achieved, are neither assessed nor considered in the Assessment. Assessments are needed.

Unfortunately, although questions were asked and concerns expressed about water supply at the HDC Cabinet meeting held 15 July to consider the Horsham District Local Plan Regulation 19 draft, no mention was made either of the requirement for ‘water neutrality’ or the findings of the HRA Assessment.

The Government’s ‘Guidance Housing and Economic Needs Assessment’, which ‘Guides councils in how to assess housing needs’ states that ‘There is an expectation that the standard method will be used and that any other method will be used only in exceptional circumstances.’

The urgent need for water neutrality is an exceptional circumstance, which warrants a lower housing target to enable ‘water neutrality’ to be achieved. That target needs to be assessed and HDC’s target reduced accordingly.

Yours faithfully,

Dr R F Smith

Trustee CPRE Sussex

The transcript of Horsham District Council Cabinet Meeting, held 15 July, can be accessed at: Transcript of Horsham District Council Cabinet meeting 15 July 2021 – CPRE Sussex