Water Neutrality - gone down the plug hole?

Following several press releases (and a Guardian leaked comment from Rachel Reeves on 7 Oct) on 31 Oct Natural England (NE) issued a statement to withdraw their Sep ‘21 Position Statement that they could not be sure that abstraction of ground water at Hardham was not harming the Arun valley protected sites. The basis for this withdrawal seems to be a very recent report ‘Hardham Basin Environment Study’ commissioned by Southern Water (which has not been released to HDC) and an agreement between NE, SW, DEFRA, & EA (together with RSPB re changes at Pulborough Brooks) comprising:

• No additional abstraction pressure – Southern Water will volunteer a groundwater abstraction licence reduction from 16 → 13 Ml/d (average over the year) and 30 → 27 Ml/d (peak).

• On-site water level management – RSPB will manage sluices to maintain suitable water depths and prevent further deterioration of site features.
• Monitoring of site features – Southern Water will continue building a scientific baseline of site conditions, providing assurance that the agreed measures are effective.
• Ecological resilience measures– A package of actions (e.g. reprofiling/desilting ditches, removing invasive species) to improve site resilience and ensure the licence complies with the Habitats Regulations.

There is an apparent conflict between this new, and as yet unseen by this author,  HBES report and NE's own report of May this year (Condition review: Arun Valley Sites - Freshwater-dependent features,  Natural England Research Report NERR143) which said of the 'Floodplain sites, Ramsar and SSSIs' that 'The predominant water-dependent habitats; the ditches, wet grassland, swamp and wetland habitats are in Unfavourable Declining condition across all three sites'. 

As the competent authority under the Habitats Regulations, HDC will apply the precautionary principle and will be using the 2024/25 water efficiency savings made by Southern Water to allow all development to move forward as water neutral from 1st November 2025. These savings were previously to be used by the Sussex North Water Certification Scheme (SNWCS) which now won’t be going ahead.

For interest, here's the annual reported leakage data for SW as a whole

and SW's quarterly abstraction from Hardham over the same period

PS: The observant will note that, despite broadly increasing leaks, the Hardham abstraction volume appears to be slowly declining over the last 5 years or so (ever since SW were told by NE that they were abstracting too much).  The answer lies in an additional abstraction point in the Arun, downstream from Hardham, which is used to balance the demand (provided there's enough water coming over the Hardham weir).