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Water Consumption in the Horsham Area - key documents

With water consumption and the hot topic of water neutrality being a critical decision maker for new development in the Horsham area, we have been researching the findings of many water experts along with the plans and predictions of Southern Water.


See all key documentation here for reference.


Water supply options for 2030 to 2045

Southern Water

‘This map shows how we could find extra water to provide reliable water supplies for you and local businesses for 15 years from 2030. We will review these options again in five years and they may change.’


Our plans to tackle droughts Our Drought Plan: summary document. Published 2019

Southern Water

'This is our plan for what we will do in a drought. It sets out what will happen and when, and who or what will be affected.'


Draft Drought Plan 2022 Main report 31 March 2021 Version 1.0

Southern Water

'This document is Southern Water’s draft Drought Plan 2022. It has been developed in compliance with sections 39B and 39C of the Water Industry Act 1991 and follows the Drought Plan guideline issued by the Environment Agency in December 2020.'


Groundwater levels

British Geology Survey



Hydrological Outlook August 2023

Delivered in partnership with UK Centre for Ecology and Hydrology

'Following an exceptionally wet July, river flows across the UK are expected to be normal to above normal for August, and over the next three months. Groundwater levels are likely to be within the normal range across the majority of the UK, though above normal levels are expected in southern England in August, and normal to below normal groundwater levels are likely in Wales over the next three months.'


Southern Water: Draft Water Resources Management Plan 2024

Southern Water

'This is our draft Water Resource Management Plan 2024 (draft WRMP24). It sets out how we plan to maintain a high quality and reliable supply of water for customers and improve the water environment for future generations.'


The Hardham Water Resource Project

'The Hardham Water Resource Project near Arundel in West Sussex, was implemented by Southern Water under license, in full consultation with the Environment Agency and Natural England, in order to safeguard water supplies to customers in Sussex, particularly in times of drought.'






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Denne Hill Development - SRS and SAA submits objections to Horsham Council planning committee

Updated: Jul 28, 2023


 

Executive Summary

For the reasons set out in more detail in the paragraphs which follow, Stammerham Amenity Association (“SAA”) and Save Rural Southwater (“SRS”) respectfully submit that HDC Planning Committee should refuse the application no. DC/23/1178 submitted by Generator Group in relation to the land at Horsham Golf Club

(i) the application does not satisfy the relevant Horsham District Planning Framework 2015 requirements, in particular, amongst others, those contained in Policy 25 and Policy 26, which are a precondition to approval, and

(ii) the application conflicts with the current 2019 Southwater Neighbourhood Plan (2019-2031), and

(iii) the application contains no adequate demonstration of water neutrality.

On each of these grounds individually, and collectively, it is respectfully submitted the application should be refused.

 

1. Statement of interest


The Stammerham Amenity Association (“SAA”) is a local residents group which was established nearly 40 years ago, to help protect the rural quality of life in Tower Hill, Two Mile Ash, Christ’s Hospital and Denne Park. The object of the Association is to maintain and manage a forum for the discussion of matters of local interest, to consult with the Parish, District and County Councils on matters regarding any future plans for the area and to put forward a consensus opinion to the aforesaid authorities wherever appropriate.


Save Rural Southwater (“SRS”) is an informal group of local Southwater Parish and adjacent residents originally formed to co-ordinate the on-line petition opposing the proposed Berkeley Homes application whose interest in this proposal is to see the robust application of the LDPF and Southwater NP Policies.

The SAA/SRS representation is, therefore, made by and on behalf of interested parties who will be directly or indirectly, and adversely, affected by the proposed development.


2. The Generator Application

The proposed development for 800 houses is on land currently part of Horsham Golf Club No brownfield site/s are included within the proposed development area which comprises entirely of what was working farm land and woodland before it was landscaped using building spoil covered with soil into its current use as a Golf Club.


The proposed development land falls outside the Southwater built up area boundary (BUAB) and the Horsham BUAB as delineated in the Horsham District Planning Framework 2015 (HDPF 2015) meaning Countryside Policies apply. While outside the two BUAB this land falls within the area covered by the Southwater Neighbourhood plan (NP) Area, see NP Policies Map. Insert Map two meaning the application must comply with the NP.


3. Weight of the current (and emerging) District Plan and the Neighbourhood Plan

The review of the 2015 district plan is overdue. For reasons which are sensible and well-known, namely uncertainty on government housing targets and subsequently the issue of water neutrality, the review commenced in 2018 was put on hold in 2021. It is understood that work is in hand on an updated review with a view to publication of the Regulation 19 Document for consideration and consultation in the near/relatively near future.


Until the emerging local plan has been duly processed and approved, the policies contained in the current local plan remain in force and must be taken as the applicable policies against which the proposed development is to be judged. Notwithstanding any presumption in favour of sustainable development in the absence of a five year housing land supply (currently HDC only has a four-year supply), developers such as Generator Group should not be able to impose their own visions and plans for local development on District Councils and local communities who have not had the proper and prescribed opportunity to object to (or support) the emerging District Plan and who have already voted in favour of current Made Neighbourhood plan. This would constitute a fundamental infringement of the rights of the individuals in the communities affected and of proper democratic process. It is for district councils and parish councils to determine, in consultation with the residents and communities they represent, and in accordance with national, District and Parish policy, the local housing and facilities needs and requirements.


The 2015 Horsham District Plan (“district plan”) remains in force, the Southwater (2019-2031) neighbourhood plan (NP) remains in force, and in terms of what might be considered “presumptions of sustainable development” there can be no objective assessment of “sustainability” unless the proper and constitutional consultation process has been undertaken and objections (of which there were many to the draft review abandoned in 2021) properly considered and addressed as appropriate. Consequently the comments below assess the proposed development against the current District Plan and Neighbourhood Plan.


The 2019-2031 Southwater Neighbourhood Plan (“NP”) is the most recent local plan, is current and its content should be supported and respected. What would be the point of requiring parish councils to spend six-figure sums preparing such plans, if they can be “ridden roughshod over” by speculative developers.


It is unclear why HDC does not have a current five-year housing land supply, or why housebuilding in the already hugely overdeveloped district has been 147% percent of the government target requirement over the last three monitoring years. It is assumed this is a voluntary assumption of extra housing which begs the question why this been accepted by HDC. But for this overdevelopment there might there have been a five-year housing land supply?


NPPF – presumption in favour of sustainable development

The Generator application relies on the presumption in favour of sustainable development (NPPF para 11 (d)) which applies where local policies are out of date and/or no five-year housing land supply can be demonstrated.


This presumption may however be displaced where a proposed development conflicts with a neighbourhood plan (provided this meets the criteria set out in NPPF para 14 (a-d) which in the present case it does) and the adverse impacts of applying the presumption in favour would significantly and demonstrably outweigh the benefits of the development. In the context of this application, the very substantial and significant conflict with the Neighbourhood plan will very clearly outweigh whatever limited benefits the proposed development might promise to deliver.


In light of this NPPF provision, it is submitted that the Generator application should not be entitled to rely on any presumption in favour of their proposed development.


4. Grounds for objection

SAA/SRS strongly object to the proposed development on the grounds, amongst others, that it disregards and/or offends against established policies on development set out in the current district and neighbourhood plans and demonstrably fails to satisfy the water neutrality criteria.


4.1 District Plan 2015 – Strategic Policy considerations (all paragraph references below are to paragraphs/strategic policies/chapters set out in the plan)


SP4 – Settlement expansion

The proposed development falls outside the Built-Up Area Boundary identified in the 2015 Plan.


SP4.2 – Scale and Function

The level of expansion of the village of Southwater envisaged under the proposal is not appropriate to the current scale and function of the Village as required under this policy. The proposed expansion will turn the existing nuclear village centred around Lintot Square, the Parish Church and the community sports fields into a very long multi-centre ribbon development thereby fracturing the existing community nucleus.


SP4.5 – Maintaining and enhancing landscape features

The proposed development is not contained within an existing defensible boundary and will not maintain and/or enhance the landscape character features of the rural location or the Golf Club land, previous farm land, on which it will be built.


SP10.1 Rural Economic Development

The proposed development is located on what was, prior to the Golf Club, productive rural/farm land which for many hundreds of years had been used for arable and livestock grazing. The development will not contribute to sustainable farming enterprises or to the wider rural economy. In fact, it will have precisely the opposite effect.


SP15 – Housing provision

The land west of Southwater is identified in the district plan as a strategic site for around 600 homes west of Southwater within the period to 2031. Since HDPF 2015 was adopted, development permission has already been granted for 594 homes of which roughly half have been completed and around 300 are under construction or are to be constructed. The proposal for up to 800 homes is on land not previously identified in HDPF 2015 and is over and above those which have already been permitted.


SP-17 Exceptions Housing Schemes

The proposed Generator development meets none of the requirements of the policy in relation to sites in rural areas near existing settlements.


SD10 – Southwater Strategic site.

The proposed development falls outside the Strategic site identified in policy SD10.

Chapter 9 – Conserving and Enhancing the Natural and Built Environment (Water quality)

There are already significant capacity issues with the existing local wastewater treatment facilities. The proposed development would massively increase the demand for wastewater treatment and disposal. This aspect has not been adequately addressed in the proposal.


Policy 24 – Environmental protection

The proposed development will add significantly to pollutant emissions, noise air and light pollution on the proposed site where currently, by virtue of its use as a Golf course , little such pollution factors exist.


Policy 25 – District Character and Natural Environment

Para 9.18 expressly recognises that the undeveloped nature of rural areas must be protected. The proposed Generator development is located in a rural area outside the existing district and NP BUABs.


The proposed development entails carpeting large tracts of ‘golf course land / which is home to a wide variety of wildlife species, a number of which are protected, with houses, roads, retail and retail space and totally fails to meet any of the applicable criteria set out in Policy 25. In particular it does not, and simply cannot:


“protect, conserve and enhance the rural land on which the development is proposed” (per requirement 1),


“Maintain and protect green infrastructure” (per requirement 2),


“Maintain and enhance biodiversity, safeguard existing species or provide net gains in biodiversity” (per requirement 3).


Policy 26 – Countryside protection

The opening paragraph of the Policy reads;


“Outside built-up area boundaries, the rural character and undeveloped nature of the countryside will be protected against inappropriate development. Any proposal must be essential to its countryside location, and in addition meet one of the following criteria:”

The “essential” requirement is a precondition which must be met by any proposal and the present proposal falls very far short of evidencing that it is “essential”.


Policy 26 goes on to stipulate that to be considered acceptable “development must not lead to a significant increase in the overall level of activity in the countryside, and it must protect and/or conserve and/or enhance the key features and characteristics of the landscape character area in which it is located, including”


“…the areas ecological qualities…the pattern of woodlands and fields, hedgerows, trees, waterbodies…”


The proposed development demonstrably fails these tests on all counts.


Policy 27 – Settlement Coalescence

The proposed development will lead to significant coalescence between the village of Southwater and the town of Horsham and will generate urbanising effects including new roads/roundabouts, development along road corridors and a very significant increase in road movements contrary to Policy 27.


Policy 31 – Biodiversity

Policy 31 seeks to ensure no biodiversity loss. The proposed development is located on what was large tracts of rural/farm land and adjacent to woodlands, hedges and treelines, currently home to a wide variety of wildlife, aquatic life, bird life, flora and fauna. Species include deer, foxes, rabbits, hedgehogs, herons, wild duck and geese, moorhens, birds of prey, rooks, nesting birds, bats, and great crested newts, frogs and other amphibians, ancient woodlands, trees and hedgerows. The loss of this habitat to development will render it largely if not entirely devoid of all such irreplaceable biodiversity.


4.2 Southwater NP 2019-2031 – Core Principles considerations (All paragraph references below are to paragraphs/strategic policies/chapters set out in the Southwater neighbourhood Plan 2019-2031)


SNP1.1.a -The proposed development offends the core principle that the village will remain a single centre settlement centralised in/around Lintot square.

SNP1.1.b - The proposed development falls substantially outside the Built Up Area Boundary identified in the Plan

SNP1.3. - The proposed development offends the core principle that the unique and separate identities of Southwater village, Christs Hospital and Tower Hill will be maintained and will result in unacceptable coalescence of these separate communities and further coalescence with Horsham.

SNP2.2 - The proposed development offends the core principle that only the land west of Southwater is allocated for the provision of 422-450 new residential units.

SNP4. - The proposed development offends the core principle of “keeping our roads moving”. It will substantially increase the number of vehicle entering and leaving the proposed site and lead to an increase congestion on the B2237 in the vicinity of the Hop Oast Roundabout.


4.3 “Water Neutrality”

The Natural England position is very clear. “Water neutrality” means that any development that is built must not use more water than is currently being used. Southwater is within what has been identified as the most water supply stressed area in the country, and that is before the additional demand from developments already approved and under construction in the district comes on line. The proposed development is sited exclusively on land which is regularly irrigated and the applicant is relying on offsetting the current water use (borehole supply) drilling further bore holes, and grey water recycling coupled with fitting water flow restrictors to all the proposed properties. By these means they assert they can achieve water neutrality. There is clearly a lot more work to be done and evidence gathered on the actual quantities of water bore holes can deliver and the medium to long term sustainability of such supply.


However the real issue here is the stated ability to comply at all let alone in perpetuity with the target consumption of 85 litres per person per day (PPPD) a figure which Generator state they will monitor in perpetuity. The target consumption they state will be reached by installation of flow restriction devices on the new properties.


The breakdown of daily consumption pppd submitted with the application make for very interesting reading and merit closer review. And they raise two very fundamental questions, namely how the unfortunate occupants of these properties could be expected to get anywhere close to meeting these absurd targets and secondly how these could possibly be monitored and enforced in perpetuity.


Looking at the proposed consumption targets these rely on ridiculously understated estimates of wc use pppd. The bath allowance is absurd, allowing just 15 lites pppd (less than 3 ins in a standard sized bath) and the shower allowance is well below industry consumption data.

But the real absurdity of these targets is that they are just that. Like road speed limits, they will be more observed in the breach, but unlike speed limits there will be no penalty or sanction for overconsumption. People will use whatever amount of water they want, it will just take longer to fill their sinks, basins and wc cisterns or wash their car/s. Generator state that they will install smart meters and that these will be monitored in perpetuity (by whom is not stated) “to ensure that the 85l/p/d …is met.)” The right to water is a basic human right. When Generator sell the new properties will they make it clear to their purchasers and enshrine in their contracts that their water consumption will be limited to what is by any standards an unsustainably low daily figure? What penalties will they impose for overconsumption and what legal right do they have to do so?


By way of illustration, SRS recently undertook a comparative water consumption exercise based on water use data from two double occupancy houses in Southwater, one a new Broadacres house with mains supply and flow restrictor devices fitted and the other an older property with no flow restrictors. The two occupants of each property spend roughly 10 weeks away each year. The occupants of the new house do not bath because it takes too long to fill but shower instead. The occupants of the older house have one bath and one shower daily between them. The Southern Water daily usage data reveals that both houses are using around 400 litres pd or c.200 litres pppd. Which raises the fundamental question what reliance if any can be placed on flow restrictors in reducing water use. But no doubt HDC Planning, who appear to endorse and promote this figure, has carried out its own analysis on this and it would be interesting to know what the results of this exercise have revealed on consumption behaviour.


And finally, what is to stop the occupiers from removing the flow restrictors which we understand is a simple plumbing task, commonplace we understand in recently completed developments in the district.


The application makes no sustainable case on water neutrality compliance.


SNP 7.2 Formal/Informal Sports Area

This policy identifies Denne Park Recreational Area (including golf course, driving range and HFC ground as being a ‘Formal/Informal Sports Area’. In SNP 7.3 it states this area should not be built on unless ‘The resulting loss from the proposed development would be replaced by equivalent or better provision in terms of quantity and quality in a suitable location.


The application fails to consider or address this policy.


5. Summary

The GENERATOR proposed application has the undesirable and dangerous potential to usurp the fundamental and crucial roles of the District Council and Parish Council to objectively consider, consult upon and set realistic and sustainable local development targets.


Large scale developments in this area, such as that proposed, fly in the face of the Government’s flagship “levelling up” policy.


For the above reasons, amongst many others, outlined in the Executive Summary and in the paragraphs above, it is submitted that the application should be refused.

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Where did the water go?

Updated: Jul 27, 2023


Fantastic article in the County Times by Andrew Bardot, Southwater resident.


Protect our communities

Water Neutrality, a term unheard of before 2021, is a fundamental fact of life impacting on every resident within Sussex North Water Resource Zone (SNWRZ), extending from Crawley through Horsham, Billingshurst, Pulborough and to Chichester.


And this week we had a very stark reminder of the real scale of the problems faced by all the local districts when the water supply is turned off within the SNWRZ.


The plain and simple face is that there has been and continues to be maasive over development in West Sussex, largely driven by three factors:

(i) by a misguided government desire to stimulate uneeeded growth in the South East rather than in other regions of the country which need and would benefit from economic and social growth.

(ii) by the housebuilding sector, a major-donor to the political parties and which generates huge profits from building in the south east.

(iii) by the speculative land owners/investors who acquire viable rural land and seek to generate huge profits from selling this for development.


The SNWRZ is already the most water stressed region in the country. SRS has said it many times, our district does not need and cannot sustain this development.


We challenged the Tory plans in their draft updated District plan to licence further large scale development around Southwater, they listened and withdrew their plan.


It remains to be seen how their recently elected Lib Dem successors, who in their pre campaign encouragingly openly attacked the Tory housing plan and vowed to protect green spaces, will tackle this vital challenge.


Our communities look to and place trust in our newly elected representatives to recognise the rapid destruction of our district through over-development and to act decisively to protect the future of our communities.


Andrew Bardot, Save Rural Southwater.

Two Mile Ash road, Southwater


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