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Stodmarsh Moratorium...March 2022 & Beyond!

Currently in the development sector there is a growing expectation that the Stodmarsh Moratorium will be resolved and even perhaps lifted in March 2022, when the current study is completed. But we consider that we are far from a quick resolution here!

Stodmarsh Nature Reserve
Birds at Stodmarsh Nature Reserve

Compelling Reasons why resolution is not imminent!

  • The study is being undertaken to establish an understanding of the causes and effects of the nitrogen and phosphorus pollution on local streams and their "impact" on the aquatic environment.

  • The opportunity to fund the many discrete water treatment works in Kent was missed when the last funding round was closed, last year. The next available opportunity for funding is 2024, targeting implementation between 2025 to 2030 if Ofwat concedes.

  • Owing to the Kent County Council anticipated population growth, economic and housing demand by 2031, there is a staggering 24 million litres /day shortfall when compared with figures stated and allowed for in the Water Resources Management Plan provided by the Water Companies (KWSG, 2017).

  • The Stour region relies on groundwater for 72% of its water supply, which we suspect is currently being over-mined.

Kent Waste Water Treatment Works
Kent Waste Water Treatment Works (Kent Water for Sustainable Growth 2017)

But Developers can still develop sites / secure planning?

The current study in the Stour area will certainly qualify and quantify the magnitude of the prevailing water pollution problem. Worryingly there are reports from Natural England clearly stating that they are concerned about the magnitude of costs associated with the resolution of this issue. From a technical point of view, this is very difficult given the sporadic distribution of Waste Water Treatment Works (WWTW) in Kent and their respective outfalls. This is a big logistical challenge that would require significant infrastructural changes to sewer networks and a comprehensive study of the WWTW to establish which ones will be the most viable and could be upgraded and which sewer networks could be diverted. So on that basis alone even if money was not a factor we consider that it could take approximately a 3 to 4-year an investigation, study, and design period. So we could potentially target the next Ofwat, 2024 funding round, provided all the requisite criteria are met. We would however require an additional 5 years to implement the works, then finally the "Moratorium" will be lifted.

We are looking at approximately 8 to 10 years without securing planning or development, which will certainly put some developers out of business which is exactly what we all do not want to happen. The Moratorium is holding up a minimum of 40,000 homes, in planning. The cost of holding the development sites for developers can be quite steep especially if you consider bridging and equity debts.

Developers need to take a more robust and proactive approach as these prevailing water issues can be adequately resolved on a site-by-site basis using innovation and technology. If you consider that the average profit margin from developments ranges from £65,000 to £100,000 per house. Implementing a robust "Water Neutral" development would cost 5% to 10% of the profit margin to install a housing development with the following performance criteria:

  • Reduce water consumption to 80l/p/d or 85l/p/d using water-efficient fittings and greywater recycling units.

  • On brownfield sites discount the existing water use, and offset the remaining new water demand.

  • On Greenfield, sites offset the new water demand would need to be offset in existing premises within the same water resource zone or groundwater abstraction point catchment.

  • Continue ... successfully developing more sites in the area.

At Water Offsets we are proactively helping developers deliver water-neutral developments and unlocking the planning embargo to facilitate the development of more homes. Beyond progressing your developments additional benefits include reducing infrastructure costs associated with foul water installation and discharge, delivering sustainable development, and facilitating the timely award of planning and council support for large strategic sites.

Here are some examples of projects where we have successfully implemented our "Water Neutrality" strategies:

  • 5,600 strategic development sites in the south of England.

  • 200-unit eco resort from previous Golf Course use.

  • Conversion of a commercial unit to a children's nursery.

  • The list goes on...

If you have an affected site in the Stour Catchment or Sussex, Surrey, or Crawley, we will be very much obliged to help.

Kindly contact us at or to book an exclusive appointment to discuss your scheme in detail follow this link below:


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