A new report by Lichfields and Stantec prepared on behalf of the HBF has been published today examining the potential for house builders to achieve nutrient neutrality via the Government’s preferred approach of nature-based solutions.
Background to the nutrient neutrality issue
The nutrient neutrality embargo is delaying an estimated 120,000 homes, and so long as the restrictions continue, HBF has calculated that we could see a fall in housing completions of up to 41,000 homes a year across the 74 local authorities affected.
The Government’s intended programme of improvements to wastewater treatment works (WWTW) to meet the current technically achievable limit (TAL) which is intended to have statutory effect from 1 April 2030, could help to reduce the volume of land required in nature-based solutions to offset the nutrients generated by the occupants of new homes. The Government estimates that this programme of work could reduce phosphorus loads by 75% and nitrogen by 55% although the total benefit will vary between catchments.
The Government’s plan to improve the performance of wastewater treatment works has been cautiously welcomed by HBF. However, the volume of mitigation that needs to provided between now and 2030 is still considerable. This remains a particular problem for SME housebuilders with delayed schemes who would have expected to have a build-out programme that concluded well before 2030. Furthermore, SME housebuilders will benefit much less likely from the planned statutory improvements to wastewater treatment works because the Government has exempted WWTW serving a population equivalent of fewer than 2,000 from the improvements. Since many SMEs will build in more rural locations, they will fail to benefit from the intended improvements.
In the meantime, all housebuilders are struggling to procure solutions. The market in trading farmland to convert to nature-based solutions is still in its infancy, and only the Solent catchment – one catchment out of the 27 affected - has an effective system of credits in place (with sufficient credits to sustain housebuilding for the next five years). The effectiveness and reach of Natural England’s nutrient mitigation scheme is unknown, but we do know that it will only provide in the next year credits in one catchment – the Teesmouth and Cleveland Coast catchment.
Urgent help from Government is needed to help maintain housebuilding for the next seven years.
Key report findings
The report examines how the Government could assist the industry by reviewing the science underpinning Natural England’s approach to assessing the volume of nutrients produced by the future occupants of homes. The report argues that Natural England should revise its occupancy assumptions to reflect more accurate local data and only require house builders to mitigate at the current permit level for those people who will be inhabiting new homes prior to 2030 when the WWTW improvements are hoped to take effect.
Based on a number of scenarios the report shows that the volume of land required for mitigation through nature-based solutions should reduce significantly, making the achievement of nutrient neutrality more feasible especially for medium and larger sized developments.
If these changes are made by Natural England this would help to reduce significantly the burden on house builders to resolve the nutrient problem. These changes would be both proportionate and appropriately precautionary given the tiny contribution that new housing makes to the problem of river pollution. It would also reduce the amount of farmland that needs to be taken out of food production – an important consideration given the spiralling cost of food. Lastly it would enable Natural England’s limited resources to be targeted far more effectively, including providing assistance to SMEs in areas that will lose-out on the planned improvements to WWTW in 2030.
Media line
HBF issued the following comment to media following publication of the report:
It is widely accepted that the ban on new housing is disproportionate and unnecessary and does nothing to tackle the main causes of the nutrients issue. The new report identifies more balanced and speedier solutions that would end the socially and economically damaging ban.
Next steps
The report has been shared with key stakeholders including Ministers, officials, MPs and the media.
As always, HBF will keep members updated on this issue through the usual channels.
James Stevens
Director for Cities
