Joint Statement – Save West of Ifield and Ifield Society – October 13 2021

Natural England’s Directive on ‘Water Neutrality’


The recent Natural England directive on ‘water neutrality’ [above] – in which housing developments must not add to the amount of water being used in the Sussex North Water Supply Zone – has the full force of law behind it. Developers may well attempt to challenge this in the courts, but the law is very clear and this directive overrides all other planning directives of other agencies.

Sussex North Water Supply Zone

The local councils of Horsham & Crawley (both within the Water Supply Zone) now have little choice but to abandon or pause large development plans, such as the West of Ifield, Adversane and Buck Barn strategic site options. These developments would significantly add to the amount of water being used, as well as further threaten endangered species such as the Little Whirlpool Ramshorn snail and the Greater Thorn-tipped Longhorn beetle.

Both councils have announced to the effect that they “will be pausing some planning application decision-making until we have fully considered this matter”.  But surely this raises much bigger questions around Horsham’s Local Plan? Does it really make sense to try to sign-off the current draft Plan in November, when it contains several large developments which are no longer viable? 


The Sussex North Water Supply Zone gets all its water from the Rivers Arun & Rother at Southern Water’s Hardham Water Supply Works.

Any expansion in water extraction from the Arun/Rother will adversely affect the RAMSAR and SSSI areas of the Arun Valley, such as Pulborough Wildbrooks – the natural habitat of the protected Little Whirlpool Ramshorn snail (Anisus vorticulus). This rare snail is only found in three places in the UK, one of which is the RAMSAR site on the Wildbrooks. The snail itself might appear insignificant, but it is seen as a lead indicator of trouble for other species.

Little Whirlpool Ramshorn snail (Anisus vorticulus)

Any expansion in water extraction will also adversely affect the ancient Non-RAMSAR areas such as the Parish Brooks, West of Ifield – the natural habitat of the endangered Longhorn beetles (Pogonocherus hispidulus).

Greater Thorn-tipped Longhorn beetle (Pogonocherus hispidulus)

Developers such as Homes England will find it very difficult to prove their development is ‘water neutral’ –  not adding to the amount of water being used in the Sussex North Water Supply Zone – and that they are not endangering rare species.

For further information on this News Release, please contact:

Fenella Maitland-Smith

Save West of Ifield

Tel:  07786060640

Email:  Fenella.ms@gmail.com

Richard W. Symonds

The Ifield Society

Tel: 07540 309592 [Text only]

Email; richardsy5@aol.com


Water neutrality and its planning implications

On 14 September 2021 Horsham District Council received a ‘Position Statement’ from Natural England on “Mitigation of water usage”, which can be viewed here.

This statement sets out concerns that development in Horsham District, parts of Chichester District and Crawley Borough are increasing the demand for water, which is thought to be harming internationally protected species in the Arun Valley, with the potential threat of extinction of some species.

The advice from Natural England is that in order for development to proceed, it be ‘water neutral’.  What this means is that new development should not increase the rate of water abstraction from our water supply site in Hardham above existing levels.

This means Horsham District Council is now unable to determine current planning applications positively unless it can be shown that they are water neutral. Whilst this is not expected to impact most smaller scale householder applications, all other proposals will need to be able to demonstrate water neutrality in order to allow the Council to comply with our legal duties.

This is a new and evolving issue for the Council and it will keep its dedicated webpages updated on this subject.

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