Developers need to offset the additional nutrient pollution caused by new developments within protected areas. They cannot get planning permission without doing this. They can either purchase Nutrient Credits or create Nutrient Mitigation Schemes themselves.
Greenshank Environmental develops wetlands and other innovative schemes to provide nutrient offsets in areas affected by Nutrient Neutrality. The nutrient offsets our schemes create become nutrient credits that can be used by developers to offset the additional nutrient pollution caused by new developments within protected areas. Our expert team has been behind some of the UK’s first nutrient mitigation projects for Nutrient Neutrality, including phosphorus treatment wetlands in Herefordshire, decommissioning industrial sites, in Hampshire and taking agricultural land out of production in the Solent. We have experience advising regulators and Local Planning Authorities on the evidence and standards needed to secure nutrients credits with sufficient certainty. We will use this expertise to ensure our mitigation projects will deliver nutrient credits with certainty needed to unlock housing development.
Nutrient Neutrality is a new legal requirement within the Habitat Regulations with which developers planning new schemes must comply. This is because nutrient pollution from new building development can damage the rare ecology of protected aquatic ecosystems. Where sites protected under the Habitat regulations already have unsustainable levels of nutrient pollution, all proposals for new development are now required to show that the new scheme will not make the pollution worse. In other words, the new scheme needs to be ‘nutrient neutral’. Nutrient Neutrality for new developments is delivered by offsetting the nutrients that the new scheme will produce. A key way to do this is through offsetting schemes such as new wetlands.
Nutrient pollution is released into freshwater and coastal areas from a range of different sources, including agriculture, aquaculture, septic tanks, wastewater, urban stormwater runoff, industry and fossil fuel combustion. These nutrient sources can either be carried in water that comes from various sources on land or be deposited from the atmosphere. Although various actions that are have been taken to reduce nutrient pollution, it is still at unsustainable and damaging levels in many protected ecosystems.
27 areas of England and most of Wales have been impacted by Nutrient Neutrality. In these areas, more than 72 of the UK’s 333 Local Planning Authorities have been affected by Nutrient Neutrality and cannot consent to new development without it showing it is nutrient neutral. Over the next 5 years, the issue will more than double in scale to cover 65 areas and more than 140 Local Planning Authorities. Nutrient Neutrality hits hardest in areas where there is a lot of planned development. The areas of the UK now facing the largest challenges are:
The Derwent and Bassenthwaite Lake catchment
The Poole Harbour catchment
The River Stour and Stodmarsh catchment
The River Wye catchment (Derbyshire)
The River Camel catchment
The River Usk catchment
The River Dee catchment
The River Wye catchment
The River Towy catchment
The River Cleddau catchment
The River Teifi catchment
Most of the mitigation schemes providing nutrient offsets are based on abandoning agricultural land. By stopping farming, you remove a source of nutrients by removing fertiliser or animal manure inputs to the land. This is how development has been unlocked in The Solent region. However, this approach is not cost efficient, has big impacts on the livelihoods of farmers and is problematic at a time when food security is more important than ever.
Agricultural abandonment schemes also do not work for phosphorus as you need too much land for them to be financially viable, so this approach can only be taken in areas where nitrogen is the only nutrient of concern.
There are various mitigation options that could be delivered by different types of land management. These options include riparian buffers, engineered logjams and blocking drainage ditches, which collectively are termed as ‘catchment management solutions’. These solutions have relatively low land take, are supported by evidence and are backed by the regulator. We know this as our experts are currently writing guidance for the regulators on how these options could be deployed.
Catchment management solutions also have a range of extra environmental benefits including biodiversity improvements, natural flood management and carbon sequestration.
Wetland schemes are another potential mitigation option that can deliver nutrient offsets at scale and without a significant land take, making them both space- and cost-efficient. These solutions are also supported by a methodology from the regulator.
Credits are created on an 'offset per year basis' as they need to offset the same amount of nutrients in perpetuity.
Our wetland projects will deliver nutrient offsets that are quantified as kgs of nitrogen or phosphorus removed from the environment. Each kg of nitrogen or phosphorus removed will be sold as a nutrient credit.
As credits can only be sold within a very specific catchment area, credit price is driven by local supply and demand. In the open market, in areas with high demand, but limited supply there will be significant competition which will drive the price up.
We have seen prices as high as £100,000/kg, for Phosphorus. Nitrogen credits are typically linked to agricultural offset costs, so much lower.
We would welcome the chance to speak to developers who are looking to reduce the cost of credits by co-investing in a local scheme with Greenshank.
Nutrient pollution is released into freshwater and coastal areas from a range of different sources, including agriculture, aquaculture, septic tanks, wastewater, urban stormwater runoff, industry and fossil fuel combustion. These nutrient sources can either be carried in water that comes from various sources on land or be deposited from the atmosphere. While there are various actions that have been taken to reduce nutrient pollution, it is still at unsustainable and damaging levels in many protected ecosystems.
DEFRA is launching a trial exchange platform for the purchase and sale of credits in the Solent region. This has been done to minimise the administrative burden on developers and mitigation schemes and allow greater price transparency.
While we would welcome this development, the exchange is not yet active and is only being piloted in an area where the market is most well established and, in places, saturated. As such the Solent region is not an initial target for us. We feel the majority of our sales will occur ‘off market’ as we will target areas where there is little supply and no established strategies for the generation and sale of credits, thus giving us a competitive advantage.
The organisation or people that own the dirty water our wetlands will be treating. They are the key stakeholder to get onboard in the first instance.
The relevant Local Planning Authority, who we will seek to partner with in order to ease our sale of credits within a given area.
Natural England, who are the regulator for the protected ecological sites that the nutrient offsetting is needed for and who will ultimately sign off on our wetlands. We have a close working relationship with key members of the national team at Natural England who are dealing with Nutrient Neutrality at a strategic level.
The Environment Agency will need to be engaged to obtain discharge permits for the wetlands to discharge to certain water bodies. They may also need to be engaged for other regulatory assessments.
Environmental NGOs or other relevant community groups will be engaged to manage the wetlands and meet the ‘in perpetuity’ requirements for long-term maintenance of the schemes.
A technical report will be written for each wetland. It will provide the technical / scientific information that will detail how we have calculated the amount of nutrients that each wetland will offset and this in turn will show the number of nutrient credits the wetland will generate.
Typically, agreement on the number of credits a wetland will deliver will be conservative and this will allow us to ‘top up’ our credit allocation after construction of the project.
In order to provide an estimate of the amount of nutrient offsetting that a wetland will deliver, there is a need to design the wetland in order to meet a specific design objective. This design objective will determine by how much the wetland will reduce the nutrient load in the source of polluted water that enters the wetland. The wetland design will be provided in the form of a design report that will form part of the technical report detailing how the wetland will provide nutrient offsetting for the area it will serve.
Our mitigation solutions will generate a certain number of kgs of nutrient offsetting per year. This nutrient removal will continue at a relatively consistent annual rate. This means that when we refer to a nutrient credit, i.e. one kg of removed nitrogen/phosphorus, we are actually referring to a credit/kg of nutrient offsetting happening every year for as long as the wetland is properly managed and maintained. The site-specific trusts we will establish to pay for this management and maintenance ‘in perpetuity’ will ensure that the wetlands keep delivering the required mitigation for the lifetime of a development, in line with the regulatory requirements to get a wetland scheme signed off. Developments quantify their nutrient impact in terms of kgs per year of nutrients added to the environment. This means our schemes will provide credits in a way that can easily be shown to be providing the required annual offset for a developer to use our schemes as part of their planning application.
We are partnering with developers to deliver individual schemes that enable both a significantly reduced credit cost and an opportunity to resell any unused credits.
Our credit sales will start in 2023
We assist landowners in understanding the potential of their land and then delivering nature based solutions providing nutrient credits.
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