Greenshank criticises “unfunded commitments” under nutrient neutrality proposals

Ahead of the upcoming vote in the House of Lords on nutrient neutrality (13th September), the Home Builders Federation and the government have each released briefings to the House of Lords. Kim Connor Streich, Chief Operating Office at Greenshank Environmental, says that “these are both are full of inaccuracies and misrepresentations.”

Critically, in its briefing, the government says that housebuilders are responsible for only 5% of nutrient pollution – when reality is 36%, plus 18% from urban run-off.

Connor Streich says, “In its annual reports on progress against the targets set in the 25-Year Environment Plan, Defra identifies the major pressures that cause water bodies to fail to achieve good ecological status. The most recent progress report indicates that after the physical modification of rivers (a factor unavoidable in many urban environments), the main three drivers preventing water bodies from achieving good status are agricultural pollution from rural areas (affecting 40% of water bodies), sewage and wastewater (36%), and run-off from towns, cities and transport, referred to as urban diffuse pollution (18%).”

The government briefing also says that by changing their approach to nutrient neutrality, they estimate that this will lead to significant environmental improvements – specifically “a 69% reduction in phosphorus loads and around a 57% reduction in nitrogen loads from wastewater treatment works.”

It is not clear how these numbers have been derived. Connor Streich says “To work out the actual impact on nitrogen and phosphorus loads from wastewater treatment works upgrades requires an extensive analysis using monitoring data from water companies that is not always available. The reduction in phosphorus inputs from wastewater are also required as part of targets in the Environment Act which are aimed at tackling the already impacted water quality baseline. There has also been no analysis of whether the wastewater treatment works upgrades required through the Levelling-up and Regeneration Bill will actually result in a significant improvement to this baseline and thus remove the need for nutrient mitigation in the future. The government is intentionally muddying the waters between these two requirements.”

But Connor Streich’s particular concern is that the government is making “unfunded commitments” that may ultimately result in a failure to reduce nutrient loading, while at the same time “killing the only national Natural Capital market we have”.

In response to criticism, the government has said that it is not backtracking on its commitments to protect the environment and that the changes they are making through this package “will not lead to regression in environmental outcomes and will in fact improve the condition of the affected Habitats Sites.”

“But,” Connor Streich says, “every environmental charity, The Office for Environmental Protection and even government insiders have come out to confirm that this will have a negative impact on the environment and does amount to a regression in environmental protection.

“The total £280m pledged by the Government will pay for less than 15% of the mitigation required for the expected housing development between now and 2030.

“£140m of this is money unfunded, and the HBF have still not worked out how housebuilders will contribute to a voluntary scheme to cover this. It is impossible to see how there will not be a deterioration in environmental outcomes as a consequence of the government’s proposals.”

Connor Streich says that Greenshank Environmental is “backing a proposal to change the requirement to purchase mitigation, to a pre-occupation condition backed with a levy system if no mitigation is available. This would enable house builders to build and the environment to be protected.”

Read the Greenshank’s response to the Home Builders’ Federation briefing to the House of Lords

Read Greenshank’s response to the government briefing to the House of Lords

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