GREENSHANK Environmental has proposed an action plan to support rapid delivery of nutrient neutrality.
Concerned by recent Government briefings, which have indicated a new attempt to scrap nutrient neutrality requirements, the environmental consultancy says that an action plan is necessary to improve confidence for scheme providers and enable faster deployment of solutions to create liquidity of mitigation supply.
Nutrient mitigation schemes allow housing development while protecting the environment, for example thorugh the creation of nutrient credits for both nitrogen and phosphorus.
Kim Connor-Streich, the COO at Greenshank Environmental said “The suggested mechanism for removing nutrient neutrality will hit significant legal barriers. Using the Levelling Up and Regeneration Bill (LURB) to ‘forward count’ reductions in nutrient pollution due to improved wastewater treatment is not compatible with the Habitats Regulations. Amending the Habitats Regulations to allow this will have far-reaching consequences for development across the country, inevitably triggering legal challenges. A more comprehensive overhaul of the Habitats Regulations to allow forward counting will require further legislation and take time to deliver.”
The nutrient mitigation market has advanced considerably over the past two years. The industry has proposals to deliver 72,000 houses of mitigation, with more mitigation schemes being brought forward all the time.
Connor-Streich said “We believe the fastest and most sustainable resolution to nutrient neutrality is using nature-based solutions to bring forward nutrient mitigation schemes. These schemes not only discharge the requirements for nutrient neutral development but can also deliver a raft of additional benefits to biodiversity, flood risk, water quality and water quantity.”
To address the challenge and ensure continued delivery of nutrient neutrality, Greenshank Environmental have developed an action plan, which they hope will improve confidence for scheme providers. They stress that the action plan is a draft, and they welcome feedback.
The core aim of the action plan is to create liquidity of mitigation supply. To achieve this Greenshank Environmental propose six actions:
- Frameworks and standards to underpin a toolbox of mitigation methods
- Streamlined legal mechanisms to link mitigation schemes to planning permissions
- Simple nutrient mitigation sales contracts
- Councils adopt an official role in supporting the market
- Guidance on derogations and compensation to bring forward some development in the hardest hit areas
- Making key datasets available to support mitigation scheme delivery
Connor-Streich said “Delivering this action plan will support the provision of nutrient mitigation and nature recovery programmes across the public, third and private sectors.”
He said that the action plan would deliver a ratified toolbox of methods to understand nutrient mitigation potential, a simplified legal process to reduce the cost of selling nutrient mitigation, and simplified sales contracts to help realise financial benefits.
Connor-Streich said “We recognise that to garner support from all sectors, mitigation schemes need to be proposed with integrity. The integrity of mitigation schemes can be supported by aiming to deliver multiple environmental benefits aligned to wider nature recovery plans, by ensuring all interventions are nature positive, applying the precautionary principle where uncertainty arises, working to achieve betterment where possible, and by working in partnership across sectors to deliver multiple benefits.
“Although the focus of this action plan is on how the private nutrient mitigation market can be supported, the private market should not supplant public investment. By creating toolboxes and frameworks for the deployment of nature-based solutions, we see support of the market in the short-term as having long-term benefits to the delivery of nutrient mitigation and nature recovery schemes.
“Scrapping nutrient neutrality will be a lose/lose situation. Improving delivery means we can have both environmental protections and house building.”
Much more detail about the action plan can be found on the Greenshank Environmental website