The problems with nutrient neutrality are not its existence, but the time taken to navigate an imperfect system. Here we outline a plan for a Nutrient Levy Contribution System. Through this system, developers will pay a levy charge at the point of receiving full planning permission. Levy payments will be pooled in Catchment Nutrient Mitigation Funds. These funds will enable the strategic procurement of nutrient mitigation to meet the needs of new development in each ‘nutrient sensitive’ catchment area. Payment of the levy will discharge a developer’s requirements in relation to nutrients, removing the delays associated with developers procuring nutrient mitigation themselves.
The proposed levy system incorporates marketplace dynamics and a method to ensure onsite mitigation is prioritised. The levy system will also allow for more strategic allocation of resources to nutrient mitigation schemes, with the potential to derive greater additional benefits from the deployment of these schemes. Our proposals incorporate more robust mechanisms for monitoring, reporting and verification of mitigation schemes and safeguards should mitigation schemes underperform due to factors outside of the control of mitigation scheme providers.
We believe that together, the proposals outlined below will result in a nutrient neutrality system that works for developers, mitigation scheme providers and, critically, will drive better environmental protection. Furthermore, if new catchments are impacted by nutrient neutrality, the Nutrient Levy Contribution System will provide an immediate response to ensure housebuilding can continue while ensuring that the environment is protected in the long-term.
Nutrient neutrality is already facilitating the delivery of thousands of more sustainable new houses, but the current nutrient neutrality system could be improved. Improvements to the system should allow housebuilding to happen more quickly, with reduced costs and risk for developers, while still delivering environmental improvements. Below we outline the key friction points in the current nutrient neutrality system.
The requirement to secure mitigation prior to receiving planning permission
Geographical disparities in mitigation requirements
Monitoring, reporting and verification, and enforcement
We believe that any legislative efforts from Government in relation to nutrient neutrality should be focussed on reforming the system to speed up housebuilding while still protecting the environment. New legislation should also futureproof against the expansion of nutrient neutrality should new areas be designated as ‘nutrient sensitive’.
A levy-based nutrient neutrality system would provide the most comprehensive approach to delivering nutrient neutral development in a way that works for housebuilders and the environment. Below we outline how a Nutrient Levy Contribution System could operate.
Governance body requirements
Overarching governance body requirements
Practical requirements for the governance body
The requirements for housing developers
Collection of developer contributions
Disbursement of developer contributions
 The Thame Basin Heaths Special Protection Area mitigation scheme provides an existing example of very similar system that facilitates the provision of mitigation from recreational impacts from residential development. See: https://www.bracknell-forest.gov.uk/planning-and-building-control/planning/planning-policy/supplementary-planning-documents/thames-basin-heaths-special-protection-area-supplementary-planning-document
 A calculator that standardises calculations of the mitigation potential from SuDS is in development by an industry expert.
In N & P catchments, we are forecasting an oversupply of N. In these instances, Natural England are not obligated to purchase the total amount of both nutrients produced by a mitigation scheme. If Natural England are buying both N & P, but the combined purchase value is lower than the equivalent value for selling P only, then P only pricing will apply.
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