As planners our raison d’etre is to balance the social economic and environmental aspects of development. It is the golden thread running through our profession. Nowhere has this come more to the fore than the current battle over nutrient pollution and the Government's aspiration to deliver 300,000 homes per year.
Housing delivery was over 80,000 short of that target in 2020/21, and dealing with nutrient pollution is threatening that ambition even further. Our latest research indicates that the total number of homes delivered in affected areas could fall by 50-70%. Prior to the recent news that another 42 authorities would be affected, this would amount to around 11,000 homes per year. A stark reminder of the scale of the issue, if one were required.
Over the last decade the environmental agenda has rightly gained momentum with some commentators questioning whether it has ascended beyond the social and economic aspects of planning. The Prime Minister himself has called into question the 'newt-counting delays', shorthand for environmental issues slowing the delivery of housing.
There is no doubt that we are in the midst of a paradigm shift with the Environment Act and increasing importance of the Natural Capital agenda.
Nutrient Pollution
The Government has recently announced a tripartite initiative (financial, legislative and practical) of measures to address the moratoriums on planning applications. It did this on the same day that it announced 42 LPAs would be blighted by the nutrient pollution moratorium. Viewed positively, this was an attempt by Government to coordinate solutions. Importantly, this was in fact the first formal recognition of the issue by Government even though the issue has been raging for the last four years.
Breaking down the initiatives; what is actually being proposed?
Practical Support
The Government is proposing 100K to support cross local authority work. While this is an encouraging step, unfortunately, £100k will not go very far in this day and age in hiring more staff. Especially at a time when many local planning authorities do not have the resources to staff a planning department fully.
It is also encouraging that the Planning Advisory Service has been tasked with helping to try and spread knowledge and help the newly affected authorities get up to speed with the issue. I would encourage the formation of a nationwide task force of key players from across the industry to share best practice so new LPAs are not starting from scratch. This needs central coordination and commitment from all the key stakeholders from DEFRA, NE, EA, etc.
Financial
The main way of addressing the issue will be capital investment in Waste Water Treatment Works. However, this is not an overnight solution and will need to be factored into the company price review period. We are likely to be looking at least a few years until the price review results in tangible benefits.
Legislative Improvements
Perhaps the most interesting could be a change to the Habitat Regulations. The Government has suggested that:
‘our proposals would aim to create a more strategic approach that sits alongside measures that better target the impacts from primary contributors to nutrient pollution at protected sites and provides up front solutions’
This appears to be a more proactive approach to the environment so that issues are addressed pre-emptively and do not hold up planning applications. A win-win for housing and the environment.
Conclusion
Undoubtedly, one of the key ways to look at Nutrients is the disruption it brings to the market and the opportunity it provides to help commercialise nature based solutions in the truest sense of natural capital (i.e. attributing value to the environment).
The latest guidance alludes to this:
…‘nature-based solutions’, allowing planning permissions to be granted’
This move to nature based solutions and offsetting will provide opportunities for selling credits for a range of natural capital aspects such as carbon sequestration, biodiversity net gain and nutrient pollution. This all links in with the recent Green Paper consultation. It is also a reminder that housing only adds a relatively small proportion to the issue and that other polluters such as agriculture have a role to play.
There will also be more of a role of planning for nature based solutions through strategic planning. This is especially the case when it comes to aspects such as nutrient pollution which follows river catchments and therefore requires cross-boundary solutions. Much the same way as we need to consider other types of infrastructure (e.g. road and rail) to facilitate development, nature based solutions will require the same approach. There will be more of an emphasis on private landowners and developers to work together to find nature based solutions, particularly in the short term while Councils gear up tackling the issue at a strategic level.