Andrew Griffith MP for Arundel and South Downs and Jeremy Quin, the MP for Horsham, have responded to the proposed Local Plan published by Horsham District Council on Friday, 1st December.
Jeremy Quin stated:
“Residents will be shocked by the proposed Plan. While quite rightly, and unsurprisingly, inappropriate sites such as Buck Barn and Adversane have been rejected, for many communities impacted by new building this Plan was not what they had been led to expect.
I am also sceptical about infrastructure promises being made. Having fought hard to secure Bohunt Horsham I know how important it is to get all the facts right and I am all too aware of Plan promises – such as a new school at Wickhurst Green – which sound good on announcement but are not delivered in practice.
Most immediately I hope the Council will test the conclusion of the Liberal Democrat administration on Water Neutrality.
The Plan confirms that Water Neutrality is an issue that the Inspectorate will be bound to take into consideration in determining housebuilding numbers.
The Government have confirmed* that under Building Regulations new houses are set maximum consumption rates of 125 litres a day per person. A more stringent optional technical standard can reduce this to 110 litres per day.
While a Local Authority can propose a lower figure this needs to be tested by the Inspector.
Why has HDC settled on 85 litres per person of mains water per day? This is equivalent to no more than one shower per day for each resident: what about drinking water, loo flushing, the washing machine? Even with extensive use of “grey” water how will this work in practice? This lower number generates far more housing and is much lower than even the more stringent proposals being considered by the Government.**
Pilots conducted by Crawley Borough Council demonstrated that the average per capita consumption per day of houses tested was 135 litres***. After the introduction of flow regulators this was reduced on properties that were part of the pilot by an average of 31 litres to 104 litres per day. But where is the evidence base that 85 litres per day per person (a reduction of 37 per cent from the Crawley starting-point) is deliverable at a time when demand for water is expected to increase?
HDC have huge resources at their disposal to thoroughly test these assumptions: residents and the Inspector will need to see the evidence.
The Liberal Democrats nationally are demanding a massive increase in house-building but Horsham should not be made the victim of these policies.”
Andrew Griffith MP added:
“The local Members of Parliament were not consulted upon this plan in advance, so I am just working through the detail and will want to listen to the communities that I represent – many of whom have had their own neighbourhood plans held up by Horsham District Council.
Nationally, the Lib Dems have the highest house-building target of any Party and I don’t want to see them risk precious environments for nature like the Arun valley wild brooks because they are trying to cut corners on what a properly water-neutral home looks like.”
Notes for Editors:
*Response issued on 30th November 2023 by Lee Rowley MP (Housing Minister) to named-date Written Parliamentary Question tabled to Secretary of State DHLUC by Rt Hon Jeremy Quin MP (see below)
Question:
To ask the Secretary of State for Levelling Up, Housing and Communities, with reference to the mandatory national water standard of 125 litres per person per day for new homes, which local authorities have utilised the provision allowing 110 litres per person per day for new homes in water-stressed areas; and which body's authority is required for permission to be granted for that lower level of 110 litres to be used. (3872)
Tabled on: 27 November 2023
This question was grouped with the following question(s) for answer:
- To ask the Secretary of State for Levelling Up, Housing and Communities, with reference to his Department's Written Statement entitled Planning Update, published on 25 March 2015, UIN HCWS488, whether it remains his Department's policy that local planning authorities should not set in their emerging Local Plans any additional technical standards or requirements relating to the construction, internal layout or performance of new dwellings. (3873)
Tabled on: 27 November 2023 - To ask the Secretary of State for Levelling Up, Housing and Communities, what guidance his Department provides on what (a) enforcement and (b) monitoring powers local authorities hold when they require target water utilisation rates to be met for properties that are retrofitted. (3874)
Tabled on: 27 November 2023
Answer:
Lee Rowley:
Under Building Regulations, requirements for water efficiency in new dwellings set maximum consumption rates of 125 litres per person per day. A more stringent optional technical standard for new dwellings sets a maximum consumption of 110 litres per person per day, which can be set out in local plans as a policy expectation (and secured by planning condition) where there is evidence this is needed. Data on the number of authorities which have utilised the provision allowing 110 litres per person per day for new homes in water-stressed areas is not held centrally. A variation, allowing the lower ceiling of 110l/p/d to be used, could be proposed by a Local Planning Authority as part of its local plan, which would then be tested during an Inspector’s examination of local plans. Local authorities can prosecute and fine a builder, installer and contractor for non-adherence to Building Regulations, at the point of delivery, including by removing the work or transferring it to the local authority.
The Government is aware of issues relating to the water efficiency standards required of new developments and the challenges posed to developers and local planning authorities. The Government has committed to a legally binding water demand target to reduce demand by 20% by 2038. Defra wrote to local authorities last year to encourage them to implement the optional technical standard of 110 litres per person per day and published ‘water positive’ guidance for developers that supports tighter efficiency. We are working with Defra, Natural England and the Environment Agency to deliver commitments in the Environmental Improvement Plan 2023 which include reviewing water efficiency, water reuse and drainage standards set out in Building Regulations and which will facilitate future housing delivery. We will consider a new standard for new homes in England of 105 litres per person per day and 100 litres per person per day where there is a clear local need, such as in areas of serious water stress.
The answer was submitted on 30 Nov 2023 at 18:00.
** The Government says in the future it will consider “a new standard for new homes….of 105 litres …and 100 litres per person per day where there is a clear local need, such as in areas of serious water stress.” [Extract from WPQ above]
***Email from Crawley Borough Council to Rt Hon Jeremy Quin MP dated 28th November 2023
“In developing this scheme CBC undertook detailed piloting of the scheme to develop the evidence base across all property types. This demonstrated that within Crawley the average per capita consumption per day was 135 litres. After the introduction of the flow regulator this reduced by an average of 31 litres per person per day, a reduction of 23%.
The flow regulator can only be removed by a qualified plumber as it is plumbed directly into the cold water feed entering the property. As these have only been installed within Crawley Homes properties, tampering with these devices would be a breach of the tenancy agreement. Inspections of the flow regulators will form part of the ongoing schedule of maintenance on properties moving forward.”
