This page was updated on 21/07/23. Prior version included the draft copy of the letter.
For the pdf version you can download below or read the web version beneath
The Rt Hon Rishi Sunak MP
10 Downing Street
20 July 2023
Dear Prime Minister,
Recent briefings suggest that the Government is mounting a fresh attack on nutrient neutrality. As stakeholders engaged in solving the nutrient neutrality crisis, we are writing to tell you why these proposals are not the right approach.
We recognise the impact that nutrient neutrality has had on the house building sector, but the current approach is working. We demonstrate below that it is delivering tangible economic and environmental benefits while freeing up housing delivery. Trying to scrap nutrient neutrality would only serve to make the situation worse, for the following reasons:
Lose-lose for house builders and the environment
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. Attempting a ‘quick fix’ for house builders at the expense of the environment will become mired in court cases and simultaneously deter investment in nutrient mitigation. House builders will be left with no way through the nutrient neutrality crisis.
A huge amount of work has been done to create a nutrient mitigation market within three years. The nature-based mitigation solutions this market is now delivering are:
To remove nutrient neutrality now is to neglect these benefits. It is to neglect a huge drive by Government to address nutrient neutrality the right way, enabling new housing while protecting the environment: a win-win.
Mitigation markets benefit house builders and the environment
A huge amount of public money has been spent producing new policies and guidance to aid the response to nutrient neutrality. We know that at least £5.3m in public funds has been spent on consultancy services and nutrient trading platform pilot projects.
The Government response to nutrient neutrality has also expended a huge amount of resource at Natural England, the Environment Agency and Defra. In Appendix 1 we list some of the policy papers, position statements and guidance that will have resulted in considerable public spending on public sector staff time.
Government has also committed significant budget allocations as part of their response:
This allocation of funding has instilled confidence in the nutrient mitigation market, resulting in thousands of homes worth of mitigation being brought forward – as shown in the table below.
A host of companies are now operating to bring nutrient mitigation schemes to market across all the catchments with development stalled due to nutrient neutrality. Vague announcements on plans to scrap nutrient neutrality will only deter mitigation from being brought forward.
The Government will be undermining its own credibility
The protection of our water environment has never been higher on the public agenda. Nutrient neutrality is a result of years of inaction on water pollution; a recognition that we cannot allow the continued deterioration of precious environmental resources. At a time when people are falling ill from swimming in water polluted with raw sewage while water companies pay dividends to foreign owners, there is a clarion call for action to restore our environment.
This Government has given very clear signals that nutrient neutrality is now part of environmental policy. It has been referenced in the Environmental Improvement Plan; has had funding allocated in the 2023 Spring Budget; and is referenced in the Nature Markets Framework as a key market from which other nature markets can learn. Six months ago you, the Prime Minister, pledged to halve nutrient pollution. A U-turn would destroy your credibility and set a damaging precedent for the UK’s position on nature markets.
This is not the reason housebuilding is stalling
The Home Builders Federation recently wrote to you explaining that the main barrier to housing delivery is the planning process, exacerbated by other factors such as high costs, skill shortages and interest rates. Nutrient mitigation is already freeing up delivery of thousands of homes. Home builders of all sizes have purchased nutrient mitigation and the costs have been accepted in the market as viable. Developers are budgeting for these costs and the costs will only drop as mitigation supply increases. Economic development and environmental protections do not need to be trade-offs in a zero-sum game.
A plan of action to solve the nutrient neutrality crisis, the right way
The economic impact of nutrient neutrality stems from a historic lack of clear leadership on the issue. The best resolution is the fastest resolution, which is also an environmental resolution. We request the Government’s support to resolve the nutrient neutrality crisis through the following three steps:
We implore you not to turn your back on three years of progress that will not only help tackle nutrient neutrality, but also the wider issue of pollution in our protected waters.
The signatories to this letter are committed to working together to resolve the nutrient neutrality crisis, the right way.
Dr Gabriel Connor-Streich
Greenshank Environmental Limited
Green Agri Land Limited
Wildlife and Countryside Link
The National Trust
CPRE, The countryside charity
Chartered Institution of Water and Environmental Management
Institution of Royal Engineers
People’s Trust for Endangered Species
British Ecological Society
Bat Conservation Trust
Campaign for National Parks
Nature Friendly Farming Network
Kent Wildlife Trust
Eden Rivers Trust
Real Wild Estates Ltd
Five Rivers Limited
Tony Langridge Consulting Limited
Andrews Wildlife Consultants Ltd
Water Design Engineers Limited
Bowler Oakfield Estates Limited
Lloyd Bore Limited
Doddington Farms LLP
Geo‑Environmental Services Limited
Environmental Farmers Group
Meon Springs Limited
Environmental Trading Platform Limited
Nutrient Neutral Ltd
K.S. Coles Farms
Heaton Farms Ltd
Roke Manor Limited
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