How water neutrality and nutrient neutrality poses a serious risk to housing in Southern England!

Updated: Jul 26

I'm going to talk to you about water neutrality and nutrient neutrality those two big issues that are undermining development in the southwest of England, and in addition towards the end of this article I'm also going to give you a great strategy that you can use to get planning on greenfield sites without the need to offset water. Yes, you can actually build on greenfield sites without the need to offset water but for that and more keep reading.

I've got a big question for you, have you been stuck with water neutrality at the planning stage, or you can't even submit your planning application because you do not have a water neutral strategy? Are there major issues and considerations that are stifling your development or stopping a land deal from proceeding because of water neutrality? If that's the case you've come to the right place our series of blogs will provide hacks strategies and information about how you can actually achieve water neutrality.

I've worked in the development sector for the last 20 years and have been able to provide water neutral strategies in Horsham, Crawley and Sussex. I'm delighted to have worked with people like Inspired Villages, Substantial Group, Barclay Developments and so forth in these areas to deliver for them their schemes that are water neutral. Whether your site is a greenfield site or brownfield site I'll be sure to be able to find you a solution to deliver your development. My experience in the development sector has ranged from work on strategic sites up to 5,600 units all the way down to a single bungalow and each and every project is peculiar and has its own challenges and we deal with them with the same level of expertise, intrigue and interest to deliver a workable solution. In the next section we'll discuss more about how water neutrality and nutrient neutrality issues that are really undermining development and towards the end I will actually have a moment to discuss about the fact that you can actually deliver a water neutral development on a site that is in the green belt without the need for water offsets.


Water Neutrality

Now getting back to the main subject matter, water neutrality. Water neutrality is the designation that requires all new development within Horsham, Crawley and parts of West Sussex to deliver a scheme that does not increase the water demand in that area. In simple terms what that means for developers is that for each and every planning application you need to submit a water neutral strategy. The water neutral strategy would demonstrate to the council that you're not exceeding the current water demand in the entire catchment.


Which means, when you install your development you either have to offset through a previous use associated with the site or to find a way of retrofitting another site and offsetting to give you the water demand that you need. Why has this come about? In late 2018 the European court of justice dealt with two cases particularly dealing with habitats and wetlands; both cases resulted in Natural England instigating what we now have as the water neutral requirement for new developments in Horsham, Crawley and part of West Sussex. This has been a significant burden for developers as they seek to get planning for their sites and it is undermining the delivery of houses in those areas. In the next section, we'll talk about how neutral neutrality is further compounding the situation and undermining the efforts that are being made to obtain planning and deliver housing in Southwest England.


Nutrient Neutrality

We’re going to talk particularly about nutrient neutrality and how it has seriously undermined the delivery of planning consents within the Southwest of England. Now three years ago the Solent was targeted by Natural England to deliver nutrient neutrality. The major issue associated with this is that the zone that is now applicable in terms of delivering nutrient neutrality has escalated well towards the north, stretching all the way into southern Wales covering areas like Somerset and as far west as Cornwall. The geographical area has expanded significantly covering a total of 32 local planning authorities; the implication is that on an annual basis Savills estimate that up to 11,000 units are being held back from being delivered owing to this planning restriction.


Now if you consider the Solent region for instance where you have eight local planning authorities as a case study in that area. We know that planning permissions have dropped by a staggering 63%, in addition we do have a very exceptional case in Fareham for instance, where planning consents in one particular year fell to as low as 27 units. If you consider this projectile, it means that we could anticipate that in terms of water neutrality on the other hand, this could have a similar impact in terms of planning delivery and hence significantly reduce the opportunity to get planning for those affected areas.


Consequently the implication for water neutrality is that it is most likely going to extrapolate beyond just the three regions that are currently affected, that is Crawley, Horsham and West Sussex for a number of particular reasons. Firstly, there's a strong correlation between water-stressed areas and areas that are experiencing high levels of nutrient pollution. Secondly, the fact that it is quite difficult to really trace the linkage between direct and indirect causes of pollution, implies that if you have got more water within the aquatic environment there are better chances of maintaining a good water balance and better quality. Hence hot on the heels of the nutrient requirements, we anticipate that for the water neutrality requirements there is going to be a considerable expansion of this requirement in many other areas in the south of England. What else do we know about this matter? We do know that the environment agency has estimated that at the moment we are over mining our aquifers to the tune of 700 million litres per day.

This is a direct correlation to the amount, density and concentration of pollution that is being experienced in rivers that are associated with aquifers. It makes scientific sense that in those areas where there are nutrient neutrality issues a water neutrality strategy should be applied to help cope with pollution issues and as we already unsustainably over mining those catchments. There is a great expectation then that we need to reduce our very unsustainable water consumption. The implication for developers is that, going forward there is going to be this incremental requirement for them to look for solutions to find water where it's not available. Which then brings you to the consideration that for any sites that are going to go into planning in the next two to three years there should be an expectation or a proactive action by developers to actually consider water neutrality strategy as part of the master planning way before they make a planning submission.


This consideration needs to be made so that you do not undermine your own planning submission but also to make sure that there is great integrity in your infrastructure and biodiversity strategy. Because with water neutrality you can only deal with it at a great scale and do it proficiently if you consider all the other infrastructure considerations like drainage, M&E strategy, your sustainability strategy etc. All these matters need to be encapsulated and need to be really considered early on in the development cycle, particularly way before you make a planning submission and that is where we can help with our expertise of having worked on many large significant strategic sites and even on smaller sites too.


Bonus Section

Now that you've gone through this article and have had a chance to read this far, I can tell you about the bonus section that I mentioned earlier on. As I said before it is possible for you to deliver a water neutral development on a greenfield site.


There are three considerations that you need to make. The maximum number of units that you can accommodate on a greenfield site will be up to 30 units. The major consideration is that the site should be able to install a borehole on it so in terms of its location you need a yield of at least 20,000 litres per day or 20 cubic metres per day, which is sufficient to provide enough water for those 30 units. However, you need to be very stringent with your water demand for the site which means that you need to have water efficient fittings and more often than not you need to have a recycling system, particularly a grey water recycling system which will help you to reduce your water demand to about 85 litres per person per day.


The emphasis on having a recycling system is to get the buy-in from the planners that the proposed development is actually utilising water in a sensible way. That you're maximising the use of water that you've already used. For instance, a grey water recycling system allows you to reuse the water that has come from your showers, washing machines and also that has come from your sinks. The new development could use that recycled water for toilet flushing, for washing clothes again and also for irrigation or car washing. So that is the technique; if you can install a borehole, reduce the water demand to 85 litres per person per day and facilitate grey water recycling. Then you can deliver a water neutral development on a small site of up to 30 units.


I really appreciate you taking the time to read this. I hope you found this information informative. I've provided links below of all the relevant publications and materials that are relevant to what I've discussed with you today, I hope you also find that useful so if you need help with any of your sites please feel free to contact us and we'll be more than able to help you take your development. Forward so don't get stuck with water neutrality, get unstuck thank you very much.


Relevant Links:

https://www.savills.co.uk/research_articles/229130/319723-0 https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/873100/National_Framework_for_water_resources_summary.pdf https://www.planningresource.co.uk/article/1729803/natural-england-water-neutrality-advice-risks-new-housing-logjam


Contact us:

W: www.wateroffsets.co.uk

E: info@wateroffsets.co.uk

E: tapiwa@wateroffsets.co.uk

T: 01992 946 799

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