New report finds Natural England significantly overestimates the impact of new housing development on nutrient pollution

31 May, 2022

A new report by Lichfields, prepared on behalf of the Home Builders Federation (HBF), questions the amount of nutrient-related pollution that Natural England estimates is generated by new housing development, and calls for local authorities to amend their nutrient calculators to ensure their projections accurately reflect local household sizes.

Nutrient neutrality is currently one of the biggest issues facing the home building industry following the ‘Dutch N’ court ruling. This prompted Natural England to revise its guidance to local authorities advising them to undertake an appropriate assessment of all applications for housing development to guard against nutrient-related pollution. This is despite acceptance from Government that nutrients from the urban environment contribute around just 4% of the problem, with the vast majority of nutrients in the rivers coming from agriculture or failings of the water companies.

New housing schemes across large parts of 74 local authorities now having to demonstrate nutrient neutrality before building can commence or resume -the result being that an estimated 120,000 new homes are now delayed*. Natural England’s nutrient neutrality advice to local authorities includes an assumption that each new home will increase the population in the catchment by 2.4 persons.

The home building industry is keen to play their part in ensuring the environment is protected. However, analysis in this report of the initial seven catchment areas affected by the nutrients issue shows that Natural England’s default assumption significantly overestimates the likely additional population that would result from the development of new housing. The amount of mitigation required from each new development is also subsequently significantly overestimated.

The 2.4 person per dwelling assumption would indicate an annual increase in population that is over double the actual change in household population indicted by the official population and household projections – that is c.73,500 persons per annum compared to 35,250 person per annum. The critical reason for this is that calculators fail to acknowledge that most new housing caters for the existing population living in a catchment, not new people moving into the area.

The industry is keen to ensure that unnecessary barriers are not placed in the way of building new homes by demanding levels of mitigation that is not needed, especially when

new housing development has such a limited effect anyway on increasing nutrient levels with the relevant catchments, and we face an acute housing shortage that is having increasing social and economic implications.

Whilst supply has increased rapidly since 2012/13, we are still some way short of delivering the 300,000k homes a year Government estimates are needed and a growing range of constraints threaten to reverse the increases in supply – making home ownership even more of an unachievable ambition for more people.

Previous research by Lichfields on this issue demonstrates the significant economic consequences that delays to housebuilding will have on local communities, including:

  • 300,000 fewer jobs
  • 16.3bn less economic activity being generated
  • £2.7bn less investment in affordable housing

HBF is urging local authorities to amend the nutrient calculator to take account of evidence from the official household and populations projections of the net average household size in each area, rather than default to Natural England’s advice.

HBF’s Director for Cities, James Stevens, said:

The homebuilding industry is committed to protecting the natural environment, but it is clear that the current approach does not reflect the minor contribution of housing development to the issue. We are urging the Government to work with us to agree a proportionate and sustainable solution to ensure housebuilding can resume in the areas concerned. Providing desperately needed new homes delivers significant social and economic benefits for new and existing communities and solutions ned to be found.”

Gareth Williams, Senior Director at Lichfields said:

“The increasing number of local authorities now affected by this issue is having a major impact on delivery of new homes in England and Wales. The calculator methodology currently proposed by Natural England has two major failings: firstly: it fails to recognise that a significant proportion of these new homes are to meet the requirement of existing residents so have no impact on overall population and secondly; they then apply an average household size that over estimates future population. It is important that the issue of water quality is addressed but the response must target the primary causes and be proportionate in it is approach”.

*see notes to editors number 2.

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For media enquiries, or to arrange an interview, please contact Steve Turner on 020 7960 1606 or 07919 307760. Steve.turner@hbf.co.uk

Notes to editors

  1. The Home Builders Federation (HBF) is the representative body of the home building industry in England and Wales. The HBF’s member firms account for some 80% of all new homes built in England and Wales in any one year, and include companies of all sizes, ranging from multi-national, household names through regionally based businesses to small local companies: www.hbf.co.uk
  2. Nutrients: number of homes delayed - we've completed a survey of the HBF membership for the number of homes delayed by the nutrients issue in the newly affected areas (HBF represents housebuilders operating in England responsible for 80% of housing construction). This quantifies the number of homes delayed at various stages including local plan allocations, outline applications, reserved matters, discharge of planning conditions, minor material and non-material. The total number of homes delayed in the 42 new local authorities affected is 38050. Of this, 40% are at reserved matters or discharge of conditions stages. The majority of the homes delayed - 21,420 - are concentrated in the Teesmouth & Cleveland Coast catchment. Key levelling-up territory. The next area affected most is the Broads and Wensum catchments in Norfolk where some 10,490 homes are delayed. There are also 3,495 delayed in the River Eden catchment, chiefly in the Carlisle area - another target area for levelling-up. Overall, nationally, when we add the 61,296 homes delayed in the initial seven catchments (this figure is based on local authority statements), we can say with a reasonable degree of confidence that the issue is delaying about 100,000 homes.

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Steve Turner circle
HBF
Director of Communications

Steve Turner is HBF’s Director of Communications. Steve qualified as a Civil Engineer before moving into journalism and then communications. After six years as Head of Communications for some of Network Rail’s major projects Steve moved into the housing sector and joined HBF in 2008. His remit covers HBF’s media relations, marketing and general communications activity plus membership liaison. Steve is also leading on HBF’s focus on customer service and build quality.
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