‘Nutrient neutrality’ – four years of government failure

30 Jun, 2023

‘Nutrient neutrality’ – four years of government failure

145,000 homes currently blocked

  • Rivers increasingly polluted
  • SME builders threatened despite no link between house building and river pollution
  • Builders forced to fallow farmland and trout farms to comply with rules, threatening food security
  • … and four years on there’s still no adequate solution

This month marks the fourth anniversary of Natural England’s first moratorium on house building in a clumsy attempt to address high phosphate and nitrate levels in rivers. Since then, amidst a deepening housing crisis, bans on new builds have spread to over a quarter of England’s local authority areas, affecting more than 145,000 homes.

Government’s failure to address the root causes of river pollution since 2019 is one of the main causes of a bleak housing supply outlook that could see new home construction fall to lowest levels since World War Two.

The Government’s own research clearly shows that agricultural run-off and the inaction of water companies to maintain infrastructure, resulting in them having to discharge raw sewage into our rivers, to be the overwhelming causes of the nutrient neutrality issue. It is estimated that all existing development, including residential, commercial and the rest of the built environment, contributes less than 5% towards the phosphate and nitrate loads in our rivers – meaning the occupants of any new homes built would make a negligible difference.

Despite its own evidence, Government has given water companies until 2030 to upgrade their processes and U-turned on a plan to reduce access to high nutrient fertilisers for farmers. This means the only intervention aimed at addressing river pollution has seen Natural England put a block on much-needed new homes.

New estimates published today suggest that more than 145,000 water and energy efficient new homes have already been blocked across 74 local authority areas from Cornwall to the Tees Valley and a further 41,000 fewer homes will be built each year until solutions are found. Meanwhile, planning permissions continue to be granted for new agricultural plants, including 'Intensive Poultry Units’ proven to be the principal agricultural source of nutrients.

To continue building, house builders need to demonstrate 'nutrient neutrality' but very few of the required mitigation schemes currently exist. Instead, builders have been forced into buying trout or pig farms and taking them out of use in an effort to unlock new housing sites and keep staff employed. The proposal to roll this credit-based scheme out nationally has been criticised as it would see tens of thousands of acres of valuable farmland disappear.

Under Natural England’s recommended solution, 30,176.5 acres of farmland would need to be taken out of operation for planning permission to be granted on the 142k homes currently blocked. That’s the equivalent of more than 17,000 football pitches, which is enough land for 120,000 sheep to graze or 61,000 tonnes of wheat to be produced – generating enough crop for almost 35million boxes of Weetabix.

In addition to the social impact of reduced housing supply, the disproportionate action to block new homes is having a huge economic impact. House building supports more than around 800,000 jobs, generating around £40bn in economic activity each year and contributing around £7bn per year in wider community and infrastructure benefits.

Whilst large companies can try to focus on sites outside the affected areas, the impact on small local builders who are in some cases only operating on one or a few sites is devastating.

The only way for house builders to get any return on the investment in land and material is to complete and sell a home, and deprived of that option by Natural England’s interventions, SME builders are laying off staff and having to consider their future in the sector. Allied to delays in planning and wider growing regulatory costs and requirements, the outlook for SME builders is grim.

In a recent survey 92% of SME builders were unhappy with the government’s approach to house building.

Stewart Baseley, Executive Chairman of the Home Builders Federation says: “Four years on from Natural England’s first related intervention, the only action taken by Government to address the problem has been the wholly disproportionate ban on new housing, in spite of research repeatedly identifying agricultural practices and the inaction of water companies as the overwhelming sources of the pollution killing our country’s rivers.

“Despite repeated calls for action and clear evidence that banning development will not solve the problem, successive Ministers have failed to engage or develop any effective options for addressing the root causes.

“As we face a growing housing crisis, this Government failure is more than 140,000 homes from being built and threatening to put small builders out of business.

“At a time when the country is gripped by rising house costs, a growing intergenerational divide and economic volatility, government must agree a sensible approach and take action to alleviate the impact on aspiring homeowners and home builders.

“Developers are committed to protecting natural environments and eager to be part of discussions on how to improve natural environments. New developments now demonstrate Biodiversity Net Gain and modern homes use a fraction of the energy and water of older properties.”

In its recent report, Nutrient Neutrality Solution Finding, Lichfields called for adjustments to the methodology Natural England uses to calculate how nutrient neutrality can be achieved so it accurately reflects home buildings contribution. HBF is also urging government to put a package of measures in place to support smaller home builders whose businesses are most at risk.

Visit our campaign page to find out more about the impact of nutrient neutrality restrictions on home building, and what action government could take to alleviate the risks.

Notes to Editors:

  1. Defra’s Environmental Targets Public Consultation (May 2022) stated:
  2. Water companies - ‘monitoring shows that there is still far too much phosphorus entering the water environment, and that water companies are still the largest source of this nutrient pollution’. (page 21)
  3. Agriculture - ‘Pressures from agriculture affect 40% of water bodies, causing them to not meet our ambition for near natural state, with nutrient pollution causing the most harm. Sediment run-off into water bodies from agricultural land plays a significant role in transporting nutrients, and can also inhibit navigation, block water industry infrastructure and increase flood risk’ (page 20)
  4. General - ‘Agriculture and wastewater are together the biggest sources of nutrient pollution in the water environment. Nutrients enter the water environment through run-off and leaching from agricultural land, accounting for an estimated 70% of nitrate inputs to our rivers , lakes and groundwaters, and 25% of the phosphorus load in our rivers and lakes. When wastewater has been treated it is discharged back into the water environment, however despite undergoing treatment processes, this effluent contains contaminants including phosphorus. These discharges account for 60-80% of phosphorus entering rivers nationally.’ (page 19)
  5. 140,000 estimate of homes blocked is based on survey responses of HBF members.
  6. HBF’s February 2023 Watt a Save report found new build home buyers are saving over £500 million a year in energy bills, as well as collectively reducing carbon emissions by over 500,000 tonnes.
  7. According to current calculations, the report shows a scheme in Kent for 500 homes would require 43 hectares of wetland to be constructed to achieve nutrient neutrality – the least land intensive mitigation option. Based on these figures, 12,212 hectares of farmland would need to be taken out of operation to accommodate 142,000 homes. 12,212 hectares is the equivalent of 30,176.5 acres. Based on the average football pitch being 0.714 ha, this equates to 17,103.6 football pitches; raising Sheep estimates an average of 125 sheep per 30 acres of land (4.16 per acre, so 10.29 per ha), equally 125,732sheep for 12,212ha; 61,060 tonne of wheat based on 5 tonne per hectare of wheat; 34,851012 boxes of wheat.
  8. The Home Builders Federation (HBF) is the principal representative body for private sector home builders and voice of the home building industry in England and Wales. HBF 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: hbf.co.uk

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