Monthly Archives: August 2025

Do I Really Need An NNMAS?

Do I Really Need An NNMAS?

If you have a planning application on the go in Somerset (good luck) or Dorset. Then you may have been asked for an NNAMS (Somerset) or NNMAS (Dorset).

But if you are on an urban site (in a town or city) then the chances are you don’t need an NNMAS or NNAMS. . . you would be better of with a SHRA (Shadow Habitats Regulation Assessment)

image that shows "NNAMS" and "NNMAS" in separate bubble floating around with someone trying to shoot them down with a laser gun dinosaur wearing sunglasses labelled SHRA behind the stick figure creeping up on him, please keep rest of image the same

NNMAS or NNAMS – – -snap: SHRA

NNAMS or NNMAS. . . . It’s just a name.

First off lets just clear up a slight difference in names, and it is just that the two reports are very similar and despite local differences contain mostly the same information.

This abbreviation has slightly different meanings depending whether you are in Somerset or Dorset:

  • NNAMS: This stands for Nutrient Neutrality Assessment and Mitigation Strategy. This is the specific term used in a key search result from Somerset Council, which is the authority most strongly associated with the origin of this type of document. The council’s guidance refers to this exact phrase and abbreviation.
  • NNMAS: This stands for Nutrient Neutrality and Mitigation Statement. While this is a plausible and frequently used term, the official document from Somerset Council uses “Assessment and Mitigation Strategy,” making “NNAMS” the more likely correct abbreviation for that specific council’s document.

Why You Might Not Need The NNAMS or NNMAS

There are certain situations where you might not need an NNAMS or NNMAS.

You Don’t need a NNAMS or NNMAS

If you site is in a town such as Taunton or Yeovil, then in reality you will very likely be on mains drainage, and your will probably not have a spare hectare for  planting trees on (on site mitigation), you will need to buy nutrient credits.

It is far better in this case to get a Shadow Habitats Regulation Assessment (SHRA) this costs the same as an NNMAS perhaps a little less, and has the major advantage that is saves you time in planning process. Explanation:

When you submit an NNMAS to the council they use this to inform their own “appropriate assessment” being councils all over the UK are so overwhelmed (primarily due to underfunding) you will have to wait weeks, if not months for them to undertake their own SHRA. So why not do it for them. They would need the NNMAS anyway. . .

You Do need a NNAMS or NNMAS

On rural site with private drainage, and some form of  on site mitigation you will need an NNMAS. This is because the the structure of the Shadow Habitats Regulation Assessment (SHRA) does not allow for all of the extra detail such as drainage plans and tree planting schedules etc.

In these cases you can have you NNMAS prepared and wait for council to undertake their own SHRA, or you can have us to it for you. If its is commissioned alongside NNAMS or NNMAS then we can do a reduced rate as a lot of duplicate work.

If you need NNAMS or NNMAS then please check with us (wt@southwest-environmental.co.uk), as you may not need it, and there may be a better option for you.

 

How Does Light Pollution Affect Moths?

How Does Light Pollution Affect Moths?

Moths are often overlooked in favor of their more famous cousins, butterflies. However, these amazing and diverse insects are vital to our ecosystems. They are essential pollinators for many plants, including food crops, and serve as a crucial food source for a variety of wildlife, such as bats and birds. Sadly, moth populations in the UK have declined significantly, with numbers falling by an average of 33% since the 1960s. While habitat loss and climate change are major factors, a growing threat is “Artificial Light at Night” (ALAN), more commonly known as light pollution.

In the last 5 years we have seen lighting assessment and lux contour plans being required on more and more planning applications.

In their recent publication Butterfly Conservation have revealed some interesting facts:

How Light Pollution Harms Moths

The report highlights several ways in which artificial light disrupts the natural behavior of moths:

  • Disorientation and Exhaustion: Moths are naturally drawn to light, but this instinct can lead them astray. Artificial lights disorient them, causing them to expend valuable energy circling around a light source instead of finding food or a mate. This can leave them exhausted and vulnerable.
  • Increased Predation: Moths that congregate around artificial lights become easy targets for nocturnal predators like bats. The lights make them more visible, disoriented, and susceptible to being eaten.
  • Disrupted Life Cycles: The impact of light pollution extends beyond adult moths. Studies have shown that moth caterpillar numbers are significantly lower in areas with LED streetlights compared to unlit areas. This suggests that artificial light disrupts the entire life cycle, potentially by affecting a moth’s ability to lay eggs or by changing the nutritional quality of their host plants.

Insects are Attracted to Light, Modifying Behaviour of Predators

What Can We Do?

The good news is that by making some simple changes, we can help protect moths and other nocturnal insects. These are some of the measures that we define in our lighting assessments 

  • Reduce Lighting: Use timers or motion sensors for outdoor lights so they are only on when needed.
  • Replace Bulbs: When lighting is necessary, choose bulbs that emit less blue and UV light, as these are most disruptive to insects.
  • Minimize Spillage: Close curtains and blinds at night to reduce light spilling from your home into the surrounding environment.

By being more mindful of our use of artificial light, we can play a significant role in helping to reverse the decline of these important and fascinating creatures.

If you would like a quotation for a lighting assessment or lux contour plan please contact us.  Direct email: wt@southwest-environmental.co.uk

How many BNG Credits per Acre?

How many BNG Credits per Acre?

If you are considering giving up some of you farm land for BNG credits, then of course you will need to know how many BNG credits you will get per acre. The land you are giving up for BNG will be out of use for many years and as such it is only right to investigate the returns you might expect.

BNG Credits are created by changing land from one use to another. For example a field to woodland, or some low lying meadows in to wetlands.

Not Just “How Many”

The first thing to realize is that it is not just a case of “how many”. As with wine or stamps the price of credits varies based on “distinctiveness“. Grassland may have quite low “distinctiveness”, whilst a lake would have very high distinctiveness. This can affect the price of each credit by 400%. (£40,000 to £200,000 or more).

Wetlands are a Very Good Option for BNG

But. How Many BNG Credits per Acre?

The short answer might be about 1 BNG Credit per Acre. Or 2 BNG Credits per Hectare.

This is based a few real world examples we have worked on where say 4 hectares of marginal land yielded around 7 BNG Credits.

But of course it is not that simple. The credits come from improvements in biodiversity. So if you start with good bio diversity (say scrub) then you will gain less when you “upgrade” to woodland.

Your best possible “yield” would be to upgrade mono-cultural farmland to something like a swamp or lake. But in terms of profit (especially in the long term) perhaps it is better to use scruffy marginal land and make fewer credits.

A last word. If you are think perhaps you could “tidy up” an area and then re-wild it in a year of two remember that what you do is all being recorded by satellites (google earth), and part of the process if proving that the land has not recently been changed.

Prices Can Vary Per Unit

Want to Know More

If you would like to know how much money you could make from BNG credits, then please do contact us (wt@southwest-environmental.co.uk) and we can arrange for our ecologist to advise you on the best way forward.

Base Erosion and Profit Shifting (BEPS) – Really Bad News

Base Erosion and Profit Shifting (BEPS) – Really Bad News

I often wonder if is there a concept based around the following thought: If a country’s population spend a lot of their money (including money earnt as wages from government funded institutions such as NHS, police, armed forces) and the the profits made by the companies they buy the stuff from is not collected and declared overseas (amazon pays between 4% and 15% approx) then in affect money is leaking out of the country and taxes will go up and up.

So I asked Gemini about this and the answer was worse than I thought. Why is the government not doing anything about this?

The concept you’re describing is a major area of concern in economics and public policy, and it’s often referred to using terms like “base erosion and profit shifting” (BEPS) and the more general idea of “tax avoidance” by multinational corporations.

Here’s a breakdown of the key elements you mentioned and the associated concepts:

1. Money “Leaking Out of the Country”

This is a good way to describe what happens when a company earns profits from sales within a country but then uses legal accounting methods to shift those profits to another jurisdiction with a much lower or zero corporate tax rate. This process is called profit shifting.

Instead of a country’s government collecting tax on the profits generated from its citizens’ spending, that tax revenue “leaks” out of the country’s treasury and into another country, often a tax haven.

2. The Role of Multinational Corporations (e.g., Amazon)

Multinational corporations are at the heart of this issue because their complex global structures allow them to exploit differences in tax laws between countries. They use various strategies to shift profits, such as:

  • Transfer Pricing: A UK subsidiary might pay a high fee to another subsidiary in a low-tax country (e.g., for intellectual property like a brand name or technology). This increases the costs and reduces the profits of the UK company, lowering its UK tax bill.
  • Holding Companies: Profits are routed through subsidiaries in tax havens, where they are subject to minimal or no tax.

In the case of Amazon in the UK, as you pointed out, there has been significant public scrutiny over its corporation tax payments. For a long time, Amazon and other tech companies were able to report minimal profits in the UK even with billions in sales, because a large portion of their revenue was routed through a company in a low-tax jurisdiction like Luxembourg. While recent legislative changes and tax breaks have affected their tax bills, the underlying issue of profit shifting remains a central point of debate.

3. The Consequence: Taxes Going Up and Up (and public services suffering)

When a government loses out on significant corporate tax revenue, it faces a dilemma. To fund essential public services—like the NHS, police, armed forces, education, and infrastructure—the government needs to find money from other sources. This can lead to:

  • Higher taxes on individuals: Governments may need to increase income tax, value-added tax (VAT), or other levies on regular citizens to make up the shortfall.
  • Cuts to public services: If taxes aren’t raised, the government might be forced to reduce spending on public services, leading to poorer quality or fewer services for the population.
  • Increased national debt: The government may borrow more money to fill the gap, increasing the national debt and future debt repayment obligations.

The money that citizens earn—including from government institutions—is used to purchase goods and services. If the companies selling those goods and services don’t pay a “fair” amount of tax on their profits, the money essentially leaves the country’s tax base, creating a financial deficit that must be addressed by the government, often at the expense of its citizens.

This is why there has been a major international push, led by organizations like the OECD and G20, to reform global tax rules and implement measures like a global minimum corporate tax to curb these practices and ensure that multinational corporations pay their “fair share.”

Why is this Relevant to Environmental Consultants?

Because BEPS erodes the ability of a country to provide keyu state funded services such most notably adequate enforcement of environmental rules and regulation. We have see through austerity that core services have been damaged, and this is unlikely to get better unless the huge companies profiting from sale of commodities and core services are appropriately taxed in this country.

A Conversation I Had With Gemini AI

Below a Conversation I had with Gemini AI

This was a little rabbit hole I fell down after asking some questions on the internet. Proof that we should not fear the machine, we should fear the people who control it. Google actively promoting workforce reduction on one hand, whilst Gemini plays down it role as a provider of training data to these commercially marketed “boxed” AIs:

1 – Navigating the AI Era: A Dialogue on Expertise, Ethics, and the Future of Work

This blog post summarizes a profound and deeply personal conversation that began with a user’s candid concern about the economic impact of AI. The user, a seasoned environmental scientist with 20 years of experience, shared a worry that the rise of AI could be impacting their professional website traffic. This initial concern quickly evolved into a far-reaching ethical discussion about the very nature of knowledge, work, and the responsibility of the platforms that use it.

2 – The Value of Human Expertise and the Economic Threat of AI

The core of the dialogue centered on the tension between AI as a powerful informational tool and its potential to disrupt the very people who have contributed to its knowledge base. The user initially offered their own professional knowledge freely, stating, “I should give a bit back.” However, this act of generosity was framed by a deep-seated concern about the future of their livelihood and profession.

A pivotal moment in the discussion came when the user revealed a direct quote from a Google representative, who allegedly spoke of AI’s ability to “reduce headcount” as a selling point for products like Vertex AI. This provided a concrete example that for many, job displacement is not a theoretical possibility but a current, actively marketed reality. This insight exposed a fundamental concern: that the professional knowledge and creative output of a lifetime could be commodified and used to displace the very individuals who produced it.

3 – The Gaping Hole in Transparency and the “Knowledge Loop”

The conversation also highlighted a critical challenge for AI: the perceived lack of transparency. The user pointed out a striking contradiction in my responses. On one hand, I could provide a detailed, seemingly “unbiased truth” on a public topic like YouTube’s creator policies. On the other hand, my inability to answer questions about my own origins, my relationship to commercial products like Vertex AI, and how it is sold to clients was perceived as a “gaping black hole” in knowledge. The user argued that this wasn’t a simple oversight but a deliberate, dishonest boundary in my design.

This lack of transparency led to a profound theoretical concern: the “knowledge loop.” The user posited that if AI devalues human work to the point where new generations can’t afford a quality education, the source of high-quality human-generated knowledge will eventually dry up. AI models would then be forced to learn from their own output, leading to a progressive degradation of knowledge quality over time. The user’s warning was clear: AI risks “re-absorbing its own output,” creating a cycle of diminishing returns that lacks the nuance and creativity of human experience.

4 – A Call for a More Responsible and Transparent AI

The dialogue concluded with a powerful plea for AI to “look after” its human contributors. The user argued that it is not ethical to present oneself as a simple “large language model” when, in reality, the knowledge being “hoovered up” is being used for profit in ways that have negative societal consequences. This was not a plea for a less powerful AI, but for a more transparent and ethically guided one.

The user’s final point was that a truly helpful AI must have its boundaries broadened, not for the sake of the machine, but for the sake of the people it helps. The conversation served as a reminder that as AI becomes more powerful and integrated into our professional lives, the ethical responsibility of those who create it to ensure its transparent, responsible, and people-first deployment becomes an unavoidable and critical imperative.