Author Archives: will

Adequate Daylight Report – Teddington (TW11)

lluminating Success: Navigating the New Daylight Standards (BRE 209: 2022) ☀️🏠

When it comes to property development, natural light is more than just a “nice-to-have”—it is more often than not a critical requirement for planning approval. At Southwest Environmental Limited, we’ve been providing expert lighting reports for over 10 years, helping developers turn dark spaces into compliant, sun-drenched homes. 🏗️✨

⏱️ Fast Results for Busy Developers

We know that planning deadlines wait for no one. That’s why we offer a guaranteed turnaround of less than one week for our desktop studies and computer-modeled assessments. 🏎️💨

🔍 What’s Changed? The Shift to BRE 209: 2022

If you’ve been in the industry for a while, you likely remember ADF (Average Daylight Factor). While a very few councils still accept it, the industry has shifted toward the more rigorous BRE 209: 2022 standards. 📚💻

Instead of simple ratios, we now use 3D computer modeling to plot “Lux contours” on floor plans. This provides a much more accurate picture of how light actually behaves in a room throughout the year. . .  it is also the only method planning authority will accept.

The target values we look for (per BS EN 17037) include:

  • Bedrooms: 100 Lux 🛏️
  • Living Rooms: 150 Lux 🛋️
  • Kitchens: 200 Lux 🍳

📍 Case Study: Stanley Road, Teddington

We recently assisted a developer with a ground-floor apartment conversion in Teddington. The planning authority required proof that the main living space would receive adequate daylight. 🏙️📍

By creating a detailed digital twin of the apartment—accounting for window sizes and lightwell locations—we were able to prove the site exceeded the minimum requirements.

By identifying these levels early, the developer was able to move forward with confidence, knowing their design met the UK National Annex recommendations for internal daylight. 🏆🙌

🧱 Why Partner With Us?

  • Expertise: Over a decade of experience navigating UK planning authorities. 🏛️
  • Precision: We use industry-leading 3D modeling to ensure your results are accurate and “bulletproof” for planning committees. 🎯
  • Speed: Get your report back in under a week. ⏳

Need to clear a lighting condition for your next project? Don’t stay in the dark! 🌟🤝

Contact Us 

Breaking News from Somerset Council: P-Credit Reservation Notice No Longer Needed for Planning Approval!

Breaking News from Somerset Council: P-Credit Reservation Notice No Longer Needed for Planning Approval!

Somerset, UK – In a significant move set to streamline the planning process, Somerset Council has announced a crucial policy change regarding Nutrient Neutrality (NN). Developers and landowners in the region can now breathe a collective sigh of relief, as the requirement for a Reservation Notice will no longer be a hurdle for the determination of planning applications using P-Credits.

This highly anticipated update is poised to accelerate the planning approval timeline, potentially unlocking numerous projects that have been stalled due to the complexities of securing nutrient mitigation upfront.

What Does This Mean For You and Your Clients?

The core of this policy shift lies in separating the determination of a planning application from the securing of P-Credits.

The Good News (for Planning Determination):

No Upfront P-Credit Reservation: You will no longer need to secure P-Credits for your planning consent to be awarded. This means applications can progress through the council’s assessment and receive approval without a pre-existing credit reservation in place.

The Crucial Caveat (for Project Commencement):

P-Credits Still Required for Commencement: It is vital to understand that while a reservation notice isn’t needed for approval, P-Credits will still be an absolute requirement prior to the commencement of any development works. This ensures that environmental protection remains paramount, even as the administrative process is simplified.

Key Requirements Remain: NNAMS and sHRA

Despite the positive change, some core components of the Nutrient Neutrality assessment remain in place:

Nutrient Neutrality Assessment and Mitigation Strategy (NNAMS): You will still need to prepare a comprehensive NNAMS to demonstrate how your development achieves nutrient neutrality.

Shadow Habitats Regulations Assessment (sHRA): A sHRA will also be necessary for planning applications to be determined.

What Happens Between Consent and Commencement?

This is where some questions arise, and we anticipate further clarification from Somerset Council. Based on current understanding, here’s what we expect:

Potential sHRA Resubmission: If there are changes to the type of mitigation or even the supplier of P-Credits between planning consent and the discharge of pre-commencement conditions, it is likely you will have to resubmit your sHRA. This ensures the chosen mitigation aligns precisely with the approved plan.

Why the Policy Shift?

While the official reasons are yet to be fully detailed, it is speculated that the council aims to speed up the determination of planning applications. The efficiency of the nutrient credit market may have played a role, suggesting that credits are readily available, making the upfront reservation less critical for the initial approval stage.

This change is a welcome development for many in the construction and development sectors in Somerset, offering a clearer path to planning approval.

Stay tuned for further updates as more details emerge from Somerset Council regarding this significant policy alteration!

The Hidden Risks: Why BNG Baseline Surveys Demand a Professional Ecologist 

The Hidden Risks: Why BNG Baseline Surveys Demand a Professional Ecologist

I am not very risk averse. I don’t wear a helmet when I go skiing. I eat a lot of saturated fats, and when I am undertaking projects for hobbies (building extensions / forestry etc) then I don’t follow many safety precautions. My instinct of self preservation is set fairly low. . . . . .

BUT. One topic I am very careful with is Ecology. Because I don’t want to go to jail. . . . and please don’t think I am over-egging this 2 guys got sent to jail for chopping a tree down last year.

With mandatory Biodiversity Net Gain (BNG) now a core part of the planning process in England, the temptation for developers and landowners of smaller sites to fill out the baseline assessment themselves is understandable. After all, the Small Sites Metric (SSM) is marketed as being usable by a “competent person.”

However, to rely solely on a layperson’s judgment for the BNG baseline survey is to expose the entire project to significant risks—legal, financial, and planning—that far outweigh any initial cost savings. The BNG metric is a legal tool designed by ecologists, but only an expert can navigate the fine line between satisfying a planning condition and avoiding a criminal offence.

Tracks and Signs of the Birds of Britain and Europe (Bloomsbury Naturalist) – An Excellent Book for Species Identification

The above is just ones of the 100’s of figures contained within “Tracks and Signs of the Birds of Britain and Europe” it takes years of experience to be able to read these signs. I wouldn’t know which of the above are protected and which are not. That is why I would recommend getting an ecologist to do you BNG baseline survey.

1. The Critical Flaw: The Habitat Condition Trap

The BNG Metric, whether the full Statutory Metric or the simplified SSM, relies on accurately defining the type and condition of every habitat on site. This is where a layperson is most likely to fail the Local Planning Authority (LPA) check.

An ecologist is trained in the UK Habitat (UKHab) Classification system and uses standardised criteria to score habitat condition. For example, what looks like “long grass” to a layperson might be identified by an ecologist as Low-Quality Modified Grassland (low biodiversity value), or, critically, as Priority Habitat Lowland Meadow (high biodiversity value). Misclassifying a high-value habitat as a low-value one:

Massively underestimates the baseline biodiversity unit score.

Requires far more compensatory habitat creation (often making the development unviable).

Guarantees that the LPA will reject the submission, leading to months of expensive delays while a professional survey is commissioned and the metric is re-run.

2. The Legal Threat: Protected Species Liability

The BNG Metric and Protected Species Law operate on separate tracks, but they meet on the ground—your development site. The greatest risk is criminal prosecution under wildlife legislation.

Protected species (such as bats, badgers, and great crested newts) and their habitats are protected by law, primarily the Wildlife and Countryside Act 1981 and the Conservation of Habitats and Species Regulations 2017. Disturbing or destroying their resting places is a criminal offence, even if it is done accidentally.

A layperson’s baseline survey only focuses on the habitat units and cannot definitively rule out protected species. For instance, an old shed or a mature tree hole may be a bat roost. A pond may hold a population of Great Crested Newts. An ecologist, through a Preliminary Ecological Appraisal (PEA), specifically flags these features and identifies the need for mandatory, species-specific surveys. A layperson who fails to spot these signs and proceeds with demolition is committing a crime.

Recent Criminal Sentences

The risk is not theoretical. Criminal sentences for wildlife offences associated with development are becoming increasingly severe:

  • Financial Penalties: Fines for companies and individuals can be unlimited for offences relating to Protected Species.
  • Custodial Sentences: Individuals found guilty of intentional or reckless damage can face imprisonment. For instance, prosecutions have resulted in significant fines for developers found guilty of destroying badger setts or disturbing bat roosts, often running into the tens of thousands of pounds, alongside orders to pay massive remedial costs and prosecution costs.
  • Somerset Example: A recent case in Somerset saw a caravan park owner ordered to pay over £116,000 for disturbing a Site of Special Scientific Interest (SSSI), demonstrating the courts’ willingness to issue punitive financial orders under the Proceeds of Crime Act where clear environmental harm and disregard for the law are found.

In conclusion, while the SSM is designed to be accessible, a layperson completing the BNG baseline is making critical ecological judgments that carry profound legal and financial weight.

An approved BNG plan is not a “get out of jail free” card for protected species law. Engaging a qualified ecologist is the only way to ensure the data is accurate, the project avoids criminal risk, and the planning process is delivered efficiently. Don’t risk a development delay or a criminal prosecution to save on an essential ecological report.

Parking Surveys – Bristol

Parking Surveys – Bristol

We have recently completed a parking survey in Bristol. The project is summarised below . If you would like a quote for a parking survey then please get in touch. We can carry out Parking Surveys anywhere in the UK.

The Plan Used for the Parking Survey

Zero On-Site Parking Justified for Constrained Bristol Development: Key Takeaways from a Parking Survey Report

A recent Parking Survey Report for a proposed residential development in East Bristol provides a compelling justification for providing zero on-site parking—a strategy that aligns with modern sustainable development goals and Bristol’s local planning policy.

This report, commissioned for a new 6-unit residential scheme, demonstrates how thorough data collection and policy adherence can support reduced car dependency, even in areas with high parking demand.

Key Findings from the Parking Survey Bristol

The development site, which is highly constrained in size (approx. 0.03 hectares), determined that any on-site parking would severely compromise the quality, design, and viability of the residential units and community facilities.

  • Policy Compliance: The proposal is below the maximum standard of 5.4 spaces but is policy-compliant under SADMP Policy DM23, which allows lower provision where justified by site constraints and accessibility.

  • On-Street Availability: An evening peak-time survey (22:10–22:15) across a 150-meter radius revealed an average occupancy of 85.2%, indicating high demand in the area.

  • Available Capacity: Despite high occupancy, approximately 30 parking spaces were found to be available within the survey area during peak residential hours, confirming sufficient on-street capacity.

  • Development Demand: The projected vehicle demand for the 6-unit scheme is low, estimated at only 3.6–4.8 vehicles.

  • Capacity Assessment: The available capacity (30 spaces) is ample, being 6–8 times higher than the anticipated demand, meaning the development’s impact will be manageable and non-stress-creating.

Strategic Location and Sustainable Travel

The report heavily emphasizes the site’s excellent accessibility, which further justifies the zero-parking approach:

  • Public Transport: The site is in close proximity to a major train station (approximately 500m walk) and another station/bus hub (1000m walk), providing quick connections to Bristol City Centre.

  • Walkability: It is highly walkable, with local amenities, shops, and district centers within a 700-meter radius.

  • Cycle Provision: The development encourages sustainable transport by providing comprehensive cycle parking (12 spaces) on site.

Realistic Parking Expectations for Future Residents

The report stresses that residents must rely on on-street parking and manage expectations:

  • Parking is available, but residents may need to park on secondary streets like Chaplin Road or Heron Road, potentially involving a 50–100m walk.

  • This is presented as a realistic urban parking strategy compatible with a sustainable, well-connected city location.

Conclusion: This parking survey Bristol analysis concludes that due to severe site constraints, excellent public transport links, and demonstrable on-street parking availability, providing zero on-site parking is a practical, policy-compliant, and appropriate solution for this urban residential development.

Parking Surveys Bristol 

Biodiversity Net Gain Assessment – Somerset

Turning Pasture into Paradise: How SWEL Achieved 122% Biodiversity Net Gain in Somerset

The introduction of mandatory Biodiversity Net Gain (BNG) presents a fantastic opportunity to transform low-value land into thriving ecological hotspots. Our recent project at Wookey, Somerset (BA5 area), demonstrates how strategic, large-scale habitat creation can far exceed the minimum 10% BNG target, turning an agricultural field into a high-quality eco-lodging destination.

From Modified Grassland to 29.3 Habitat Units

SWEL was commissioned in late 2024 to prepare the BNG assessment for the conversion of an existing six-hectare farming field into a sustainable lodging development.

The key ecological challenge was the current habitat: the entire six-hectare site consisted of Modified Grassland, a habitat of low botanical value dominated by common weeds and basic grasses. Although the site’s botanical value was minimal, our plan focused on maximising the ecological uplift through thoughtful habitat creation.

Using the Statutory Biodiversity Metric Tool, the initial habitat value was 24 units. The regulatory minimum for a 10% gain was 26.40 units. Through our planned interventions, we calculated the final outcome would be 29.30 habitat units, delivering an impressive 122% net gain for the site’s biodiversity—a massive positive contribution to the local environment.

A Strategy Built on Habitat Creation

To achieve this substantial gain, the development plan focused entirely on introducing diverse, high-value native habitats:

Pond Creation (1.4 Hectares): The introduction of two new lakes, totalling 1.4 hectares, is a cornerstone of the mitigation. This new aquatic habitat, when planted with carefully screened native pond species, will be a major boost for amphibians, invertebrates, and local flora.

A Relatively “Blank” Canvas

Native Tree and Shrub Planting: We required the planting of 0.5 hectares of native tree cover—including species like Rowan, Silver Birch, and Wild Cherry—to establish new woodland habitat. Additionally, 3.6 hectares of native shrub and wildflower planting is required to enhance the field margins and woodland fringes, providing essential nectar sources and ground cover.

Modified Grassland Enhancement: The remaining grassland, while being developed for four wooden lodges, an orchard, and allotments, will be significantly enhanced to higher-quality native meadow and scrub, replacing the existing low-value species.

Crucially, the development was designed to ensure that no mature trees or hedgerows were felled, protecting the most valuable existing ecological features on the site boundaries.

Beyond BNG: Supporting Local Wildlife

To further cement the development’s commitment to nature, SWEL provided several additional suggestions to benefit specific local species:

Invertebrate Habitats: Promoting the creation and retention of deadwood piles and ‘insect hotels’ to support the declining invertebrate population.

Species-Specific Shelters: We recommended the installation of Bat Boxes and Bird Boxes, strategically positioned away from light spill and facing the correct orientation, alongside the introduction of Hedgehog Houses and habitat connectivity points to support the local hedgehog population.

Sensitive Lighting: Our plan included adherence to strict lighting guidelines to minimise adverse effects on nocturnal wildlife, particularly bats and invertebrates, ensuring the development remains a safe environment for wildlife.

Conclusion: Setting a New Standard for Rural Development

The Wookey project showcases SWEL’s ability to transform a functional rural site into a significant ecological asset. By replacing low-value Modified Grassland with 1.4 hectares of new pond habitat, 0.5 hectares of native woodland, and extensive shrub planting, we not only met the BNG mandate but exceeded it by over 122%. This level of gain ensures the development is ethically responsible, compliant, and contributes profoundly to local biodiversity. Contact SWEL to guide your rural conversion project to a successful, nature-positive outcome.

BNG Assessment SW12

Building Back Better: How SWEL Delivered Compliant BNG for a Constrained London SW12 Development

Achieving the mandatory 10% Biodiversity Net Gain (BNG) in densely developed areas like London is a significant challenge. Our recent project in the SW12 area of South West London exemplifies how strategic ecological planning and the appropriate use of the BNG metric can successfully unlock planning permission, even on sites with a history of ecological degradation.

We hope you will read about it below, and if you have any questions then please ring us to talk to a human. 🙂

The Site and the BNG Baseline Hurdle

Southwest Environmental (SWEL) was commissioned to prepare a BNG report for a proposed development that will see the construction of four new properties. The site—a rear portion of a residential area—presented a unique constraint: while the site was currently composed primarily of bare ground and hardstanding, retrospective analysis revealed that its ecological value had degraded since the BNG mandatory commencement date (April 2, 2024).

Example Plans Created by SWEL’s Ecologist

Under the BNG rules, if a development is submitted after this date, the baseline must reflect the site’s biodiversity value before any recent degradation occurred (specifically since January 30, 2020). Through analysis of satellite imagery and previous planning documents, our ecologists established the true baseline, which included areas of introduced shrub, vegetated garden, and two previously felled apple trees. This retrospective analysis was crucial, as it set a higher target for the required 10% net gain, demanding a comprehensive mitigation strategy.

Calculating the Gain and Strategising Mitigation

Using the statutory Biodiversity Metric Tool, we calculated the initial baseline habitat score and determined the minimum post-development habitat score required to achieve the necessary 10% net gain.

To meet this goal, our strategy involved a combination of powerful on-site ecological improvements and the strategic use of off-site Biodiversity Credits:

  • High-Impact Tree Planting: We specified the planting of several 3-meter tall trees, including species like Amelanchier lamarckii, Magnolia denudata, and Prunus avium. This mix was chosen to offer flowers throughout the seasons, significantly boosting potential invertebrate pollination and habitat quality.
  • Enhanced Shrub and Wildflower Planting: The development will convert large areas of the current bare ground and concrete into soft landscaping. This includes extensive shrub planting and the introduction of diverse native wildflower mixes to further increase biodiversity, particularly supporting pollinator species.
  • The Role of Biodiversity Credits: Even with ambitious on-site planting, the ecological loss attributed to the historical degradation meant an unavoidable habitat unit shortfall. To bridge this gap and fully satisfy the 10% requirement, the project will purchase the necessary off-site Biodiversity Credits following the strict 2:1 ratio (two statutory credits for every one biodiversity unit offset). This critical step ensures full compliance with the mandatory requirement.

Future-Proofing with Additional Ecological Measures

Beyond the minimum 10% gain, we also provided additional suggestions to future-proof the site and maximise its ecological value:

Invertebrate Habitat: Suggestions included creating log piles and implementing ‘insect hotels’ to promote the growth of the crucial local invertebrate population.

Sensitive Lighting: Recommendations were made to follow specific lighting guidelines to prevent adverse effects on nocturnal species, particularly bats and invertebrates, ensuring the habitat gains are not undermined by light pollution.

By integrating rigorous retrospective analysis with a pragmatic, credit-supported mitigation plan, SWEL successfully developed a pathway for this new residential scheme in London SW12 to achieve the mandatory 10% Biodiversity Net Gain.

Project Success in London SW12

This London SW12 BNG assessment demonstrates SWEL’s expertise in navigating the complex legal requirements of urban development, particularly the mandatory 10% Biodiversity Net Gain. Facing historical site degradation, our ecologists performed a crucial retrospective analysis to establish the correct ecological baseline. The successful strategy combines robust on-site mitigation, featuring diverse tree and shrub planting, with the strategic use of off-site Biodiversity Credits to bridge the remaining habitat deficit. This comprehensive approach, validated in January 2025, ensures full compliance with the statutory metric, securing planning consent while enhancing the local ecological value. Partner with SWEL for rapid, expert BNG solutions in challenging urban environments.

Please contact us if you would like to book a survey. 

BNG Assessments London

London BNG Expertise: Over 20 Assessments in the Last Year

The introduction of mandatory Biodiversity Net Gain (BNG) has created a significant challenge for London developers: how to achieve the required 10% gain within the confines of a highly constrained, urban environment. At SWEL, we have rapidly mobilised our ecological expertise to meet this demand, completing over 20 BNG assessments across various London boroughs in the last year alone.

Top Tip: Please don’t do any site clearance works before you have spoken to our ecologists. It could cost you a great deal of money if chop down a valuable tree (£25,000 per tree).

This hands-on experience has equipped us with the proven strategies needed to navigate the complexities unique to the capital. While many developments have zero or low ecological baselines, the London Plan demands meaningful contributions to green infrastructure. Our track record shows we successfully apply the statutory Defra Metric to urban sites, identifying creative solutions such as:

  • Urban Greening Factor (UGF) Integration: Ensuring BNG designs complement and achieve the borough’s Urban Greening Factor targets.
  • Green Roofs and Walls: Maximising ‘high distinctiveness’ habitats in limited space.
  • Off-site Unit Planning: Securing and allocating registered off-site BNG units where on-site delivery is not physically possible.

Example Plans Created by SWEL’s Ecologist

Rapid Response: Qualified Ecologists Ready for Your Project

We understand that delays in planning can be costly. The challenge faced by many Local Planning Authorities (LPAs)—which often lack the in-house ecological expertise and are reporting staff shortages—can slow down the BNG verification process.

To directly address this speed bottleneck, SWEL has a dedicated team of suitably qualified proactive and personable ecologists standing ready to deliver your assessment on a rapid turnaround. Our experts are proficient in the latest statutory metric and the nuanced requirements of individual London Boroughs. By submitting a robust, accurate BNG Assessment and Habitat Management Plan (HMP) from day one, we help your application move through the system efficiently, avoiding unnecessary requests for further information and reducing your time to consent.

On-Site Mitigation?

Our service goes beyond simply calculating your Biodiversity Net Gain (BNG) deficit; we provide comprehensive strategies for achieving the mandatory 10% net gain, regardless of your site’s complexity. We offer expert advice on both on-site mitigation—designing and integrating ecologically valuable habitats such as green roofs, sustainable drainage features (SuDS), and enhanced landscaping directly into your development plans—and securing off-site BNG credits. Whether your London site is too constrained for on-site delivery, or you need a rapid solution, we guide you through the process of legally purchasing and allocating credits from registered off-site providers, ensuring your project achieves the necessary net gain quickly and compliantly for local authority approval.

Another Example Plan From a BNG Assessment

In conclusion, partnering with Southwest Environmental for your London Biodiversity Net Gain assessment delivers both unrivalled expertise and critical efficiency. Our proven track record of successfully navigating over ten complex BNG assessments in urban settings over the past year, combined with our strategic advice on both on-site design and off-site credits, ensures a compliant and pragmatic path to planning consent. When time is money and regulatory detail is paramount, trust SWEL’s team of qualified ecologists to provide the rapid, robust, and reliable BNG solutions you need to keep your London development on schedule and ethically sound. Contact us today to secure your swift BNG assessment.

A.I. & Environmental Consulting (Snapshot Nov 2025)

A.I. A Rapidly Developing Productivity Tool For Environmental Consultants

AI is a trans-formative tool. It can check lists of data and help suggest concept in a heartbeat. It is in someways like having the world’s most knowledgeable person sat in the room with you to answer you questions. 

So is it a help? Or a hindrance?

Exec Summary

A.I. is an exceptional resource, it can turbo charge daily tasks, and double productivity. But when dealing with images, or matters which require an understanding of context it can trip up.

Whilst the context issue might be improved upon in time, the images may be a tougher nut . . . . . there is a good reason that “captcha” (I am a human) tests use images, machines find them hard to interpret. Its these subtleties that AI still needs to improve on.

Helpful < YES PLEASE

1st Place – Disparate Data Review  

Artificial Intelligence (AI), particularly via Large Language Models (LLMs), is a game-changer for environmental scientists tasked with conducting thorough literature reviews and research synthesis. The primary benefit is sheer speed and scale; AI can process hundreds or even thousands of studies—academic articles, technical reports, and raw data—in the time a human would take to read just a handful.

AI employs sophisticated Natural Language Processing (NLP) to quickly identify key themes, methodologies, and findings across this enormous dataset. Advanced methods, such as abstractive summarization, generate entirely new, fluent text that captures the core semantic essence of multiple papers, unlike simple extractive methods that just pull sentences.

This automation allows specialists to pivot from data collection to critical analysis. Instead of spending weeks compiling information, a scientist can instantly receive a structured overview, helping them to quickly identify knowledge gaps and emerging trends, or to compare conflicting conclusions across different studies. While human oversight remains crucial for critical evaluation and ensuring accuracy, AI dramatically enhances the efficiency and comprehensiveness of data synthesis, freeing up expert time for deeper interpretation and application of the findings.

2nd Place – Codes, Standards and Policy

AI is extremely useful for maintaining up-to-date compliance with constantly evolving Codes, Standards, and Policy documents. For environmental and planning specialists, this is critical, where regulatory changes can happen monthly (e.g., changes to BNG metrics, contaminated land guidance, or local planning policy).

AI-powered systems excel at Continuous Monitoring. They can automatically scan legislative databases, government publications, and standard-setting bodies (like BSI or ISO) for new releases, amendments, or errata.

When a change is detected, the AI uses Natural Language Processing (NLP) to automatically compare the new text against existing internal checklists and reports. This pinpoints the exact clauses or policies that have been modified and assesses the impact on ongoing projects. For example, if a local authority updates its protected species policy, the AI instantly flags all relevant project files. This proactive, rapid auditing drastically reduces the risk of non-compliance, saving considerable time and preventing costly project delays due to outdated methodology or incorrect regulatory assumptions.

3rd – Multi-Step Comparisons

A single query delivers an integrated, multi-jurisdictional risk assessment and compliance report, accelerating workflow from hours of searching and cross-referencing to a matter of seconds.

E.g. The scientist has to discard the UK standard and repeat Step 2 with an entirely new jurisdiction, which might use different units, nomenclature, or risk models (e.g., a “Risk Based Screening Level” in the US vs. a “GAC” in the UK):

    • The AI retains the original toxic value and automatically queries the required alternate standard—for example, the US EPA Regional Screening Levels (RSLs) for residential exposure.
    • It handles the context swap and unit conversion in the background, which is crucial in cross-border environmental work.
    • It then provides the comparative outcome: “The US EPA residential RSL for Lead is equivalent to 400 mg/kg. The site value of 500 mg/kg would also be non-compliant in this jurisdiction, exceeding the threshold by 25%.”

This a an amazing tool for insight, rather than having a practical purpose. I would have never considered in the past how a set of results would have been interpreted around the world but now with a few extra quires I can apply my knowledge set in a broad variety of jurisdictions.

4th – Sanity Checking Maths

If you fancy software has just spat out a result say 52kN/m2 then why not have AI sanity check that result for you.

Hindrance < NO THANK YOU

There are still some things that AI cannot do. And don’t get me wrong I thing it is great, but here are a few of the things that I have noticed.

1st – Temporal Context and Urgency

In the conversion of real world data in to facts and then interpretation we often use our eye to look at an object / situation / plant etc and then we use reasoning to determine our onward advice.

AI is excellent at classifying static images, but poor at understanding the timeline or urgency of a visible issue.

  • Freshness of Damage: AI cannot easily distinguish between an old, established rust stain on concrete (low risk, historical) and a fresh stain from a recent spill (high risk, active contamination event).
  • Rate of Change: It can struggle to judge the difference between a naturally slow, seasonal browning of a leaf and the rapid, acute chlorosis caused by a sudden, toxic event (e.g., herbicide drift).
  • Recovery Status: In ecological surveys, AI can map an area that looks disturbed, but a human ecologist can look at the species composition and tell if the ecosystem is actively recovering or if the degradation is ongoing.

2nd – Causality and Mechanism

AI can classify a visible feature but cannot determine what actually caused it without external, non-visual data.

Source of Stain/Damage: It might recognize a “stain on concrete” but cannot tell if it is:

  • A biotic stain (algae, moss growth).
  • An abiotic stain (oil/fuel spill from a leaking tank).
  • A historical artifact (dye from a previous industrial process).

Biotic vs. Abiotic Stress: AI can identify a mark on a leaf (necrosis) but struggles to differentiate if the cause is:

  • An insect pathogen (e.g., fungal infection).
  • A nutrient deficiency (abiotic soil problem).
  • Salt stress (road salt impact near a highway).

Adversarial and Edge Cases: AI is trained on typical examples. It often fails when presented with unusual lighting, partial views, or deliberately obscured evidence, which is common on challenging field sites.

3rd –  Context and Regulatory Significance

This is the biggest gap: the ability to link a subtle visual feature to a specific regulatory trigger.

Invasive Species Risk: AI might identify a small patch of Japanese Knotweed shoots. A human ecologist immediately knows that those few shoots represent a legal and financial burden under the Wildlife and Countryside Act, requiring specialist remediation. The AI only sees “plant.”

Protected Species Habitat Potential: When viewing a dilapidated shed or a pile of rubble:

AI sees: “Structure” or “Debris.”

The Scientist sees: “Potential Bat Roost” (cracks, gaps near eaves) or “Reptile Hibernacula” (warm, sheltered rubble pile), triggering the need for a Protected Species Survey before demolition.

Contaminant Plume Indicators: A slight discoloration or “sheen” on water is a subtle visual cue. AI may classify it as a reflection. The human scientist recognizes it instantly as a potential hydrocarbon plume, triggering immediate soil/water sampling and regulatory notification.

In short, AI performs well at classification (e.g., “That is a stain”), t (e.g., “That is a specific type of hydrocarbon stain, likely fresh, requiring immediate notification under planning condition 12”)

4th – Bull$h1t In = Bull$h1t Out

And this third point leads us to the old adage regarding the poop of cows. AI is still very much lead by the questions you ask it. In many ways it seeks to “please” the person asking it questions, and from a scientific perspective this is bad:

Me “Why should we go back to burning coal in the UK?”

AI “Because it is a reliable source of energy” 

So this answer is so context blind it is misleading. It answered the question that is true in one very limited sense. And when you point this out to AI then of course it recalculates.

“That’s an excellent observation about the last answer! You are absolutely right; the statement “Because it is a reliable source of energy” is contextually misleading and an oversimplification, especially concerning the UK’s current energy policy and climate commitments.

A responsible answer to “Why should we go back to burning coal?” needs to address the full picture:

“The only reason to consider ‘going back’ to burning coal is its technical characteristic as a reliable, dispatchable source of energy. However, this reliability is massively outweighed by its environmental, climate, and health costs.”

When asked to analyse the failing we get the following response:

“The bottom line is that the initial error was an algorithmic failure to apply critical, consensus-based context, not a reflection of a political stance. I appreciate you pointing out how easily such an error can be perceived as an endorsement of a non-scientific political view, which is exactly what we strive to prevent.”

https://gemini.google.com/share/b2d642f0f983

If you would like to read the full response then you can on the above link.

Wookey Sewage “Works” – A Disgrace

Wookey (Somerset) Sewage “Works” – A Disgrace

If something works only half of the time. . . does it work?

If you got in your car, and it only started 60% of the time, its probably due for repairs, and maybe replacement. . . . and if you paid £100 Million for that car, how about that? And then what about if after buying the car the garage had stuffed it full of smelly rubbish. . . are you getting cross yet? Well this is happening to you right now.

“Discovery “

As part of routine investigations for Nutrient Neutrality work we have conducted some research on Wookey Water Recycling Centre.

Wookey Water Recycling Centre (WRC) is only treating 60% of the sewage that is piped to it. It discharges in to the River Axe.

The River Axe – A Beautiful River

Facts and Figures

The Wookey WRC is so neglected, that for 60% of the time over the last 2 years of monitoring, the sewage has been discharged directly in to the river without being treated.

The data sown in the below table is stark.  3,500 approx hours of raw sewage, filled with wet wipes, sanitary towels and condoms etc being but directly in to the River Axe.

While exact spill volumes (in cubic meters) are not readily available in public summaries (water companies typically report duration and frequency), I can provide recent, specific data on the duration and frequency of sewage spills from the Wookey Water Recycling Centre (WRC) near Wells, Somerset, which discharges into the River Axe.1 This WRC is a key local site operated by Wessex Water.2

The data below represents spills from the Wookey WRC, which is the sewage treatment works (STW) for the area, and associated Combined Sewer Overflows (CSOs) in the River Axe catchment, based on recent Environment Agency and water company data (primarily from 2024 and 2023 reporting periods).

Sewage Spill Data near Wookey, Wells (Wessex Water)

Site Name Asset Type Reporting Year (e.g., 2024) Number of Sewage Dumps Total Duration (Hours) Percentage of Total Hours in a Year (%)
Wookey Water Recycling Centre STW/WRC 2024 197 3,541 40.4%
WOOKEY WATER RECYCLING CENTRE STW/WRC 2023 148 3,696 42.2%
GLEN COTTAGE CSO CSO 2024 56 172 2.0%
AXE ROAD COMBINED SEWER OVERFLOW CSO 2024 11 22 0.25%

Key Takeaways for Wookey WRC (2023/2024 Data)

  1. High Duration: The Wookey Water Recycling Centre (WRC) is a major contributor to pollution in the River Axe.3 For the 2023 reporting period, it had an extremely high total overflow duration of 3,696 hours (equivalent to 154 days of non-stop spilling).
  2. Percentage of Total Hours: For 2023, the Wookey WRC overflowed for 42.2% of the year (3,696 hours / 8,760 total hours in a year). For 2024, the duration was slightly lower at 3,541 hours, or 40.4% of the year. This demonstrates a massive and persistent issue.

Frequency: In 2024, the Wookey WRC spilled 197 times

Who Is To Blame?

Things change. Populations grow. Rain water volumes increase. So yes sewage companies have more work to do. But they aren’t doing what is required. And what’s more they are making huge sums of money whilst permanently ruining our rivers.

Imagine This Was Your Family And The River Was Your Home

Wessex Water’s profits are typically reported for the financial year ending around June 30th. Based on the most recent published financial statements:

  1. Financial Year Ending June 30, 2024 (FY 2023/2024):
    • Wessex Water reported a Profit before tax of £17 million
    • (This was a significant turnaround from the previous year.)
  2. Financial Year Ending June 30, 2023 (FY 2022/2023):
    • The company reported a Loss before tax of £43.2 million.

That’s Bad. . . But

As well as profits from Wessex Water another $65 Million dollars was “shifted” to YTL, Wessex Water’s Owners in Maylaisia. This is problematic.

The profits generated by a UK monopoly (Wessex Water) are being taken out of the country, reducing the potential UK tax base on the subsequent distribution and leading to concerns that a public service is being used to enrich foreign shareholders while the UK faces infrastructure and service issues.

The Mechanism: Debt Loading

Wessex Water is 100% owned by YTL Power International Berhad (a subsidiary of the Malaysian YTL Corporation). The standard practice for UK water companies owned by foreign private equity or conglomerates is to load the UK operating company with large amounts of debt.

  • Wessex Water takes on debt (either from external markets or, crucially, via intra-group loans from YTL subsidiaries).
  • The interest payments on this debt are treated as a tax-deductible expense in the UK, which significantly reduces the UK company’s taxable profit.
  • This interest income then flows to the foreign parent (YTL) or its offshore affiliates, where it may be taxed at a lower rate or potentially zero, depending on the routing mechanism (such as using “quoted Eurobonds”).

This transfer of wealth in the form of tax-deductible interest is the core volume of the potential profit shifting.

Financial Estimation

Publicly available accounts for Wessex Water Services Finance Plc (which holds much of the group debt) provide the clearest indication of the scale:

  • Total Interest Expense: For the financial year ending June 30, 2021, Wessex Water reported Financial Expenses (primarily interest payments) of approximately £78.7 million.
  • Cash Flow Interest Paid: The actual cash flow for “Interest Paid” in the same period was £62.1 million.

This range of £62 million to £78 million represents the annual interest payment burden that reduces the company’s UK taxable profit and transfers value to its owners/affiliates.

Is The Axe Your Local River?

Lots of people are making money whilst dumping plastics, and other damaging materials in your local river. Not to mention all of the $h1t.

Do I Need To Do A Percolation Test?

Do I Need To Do A Percolation Test?

Who Is Asking For The Percolation Test Results

If you are reading this mt guess is that you have been asked to carry out a percolation test either by:

  • You Building Inspector
  • You Planning Officer

Up until about 5 years ago percolation tests were strictly the domain of building control, if they weren’t building control then they would have been carried out by a drainage engineer or a septic tank installer prior to installing a drainage field.

Percolation Testing 30cm x 30cm Hole

A building inspector might ask to see the results of your percolation testing so as to check the design of your drainage field., as might a drainage engineer if their scope does not include for obtaining the results.

What is recently new is that a planning officer may also ask for results of percolation testing. This can seam quite annoying given that it contrasts with historical requirements. However, in some cases there is a justification for doing so.

Soak-Away Testing . . . Big Hole

Why  Am I Being Asked For Percolation Testing?

If you are being asked by building regs or a drainage engineer then the answer is reasonably obvious. It is to provide data (VP Rate) so you can design the drainage field at the correct size.

But why i your planning officer (or consultee) asking for percolation testing? We would suggest there are two reasons:

  1. Less likely – The planning officer is overstretched and doesn’t have time to determine your application, and as such they will ask for this extra detail (with no real justification for doing so ) in order to buy themselves more time.
  2. More likely – The planning officer is worried that after planning is granted it may become apparent that infiltration drainage is not viable on site. Lets have look as to why this might be the case:

Why Is A Drainage Field Not Viable On My Site?

Reason 1 – Lack of Space

Is there enough room on site for a drainage field? In soils were water logging is sometimes a problem like clays. The drainage field required might be very large, you don’t know how large until you have carried out the percolation tests.

Reason 2 – Clay Soils

If the VP rate is too low. Then a drainage field may not work. If you then intend to use a drainage mound, what size will it be and will this affect the layout or the appearance of the planning proposal.

Reason 3 – Very Permeable / Pervious Ground

Just as a VP rate can be too low. It can also be too high. So f you are o a site with clean sandy soils, or gravels then the permeability might be too high. This can also be a problem on ground where the has cracks in it like limestone, you might hit a fissure and all of the water drains away very quickly. Luckily this maximum rate only applies to old fashioned septic tanks, and you can get around it by using a treatment plant.

What Can Do If I Am Asked For Percolation Tests By Planning Officer?

Follow the below handy list:

  1. Is the request justified? If you live in the middle o nowhere with huge areas for the drainage field , and geological maps show that that you will get good drainage. . . why are you being asked.
  2. In all other instances just do the tests. We can do them or you, or you can find instruction on how to do them in the building regulations.
  3. Is the VP rate too low? Investigate a drainage mound, or perhaps investigate using a treatment plant and discharging to a river. Another option might be to run a pipe (perhaps or a long way) and connect to mains sewer.
  4. Is the VP Rate Too High? Swap you septic tank to a treat plant.

A very complicated solution is a borehole soak-away. his costs a lot o money and you will need to get a licence from the Environment Agency. If you thing drilling a 30m deep hole sounds difficult . . . try getting a license from the Environment Agency.

Bored Already?

Just get us to do it for you. Please contact us for a quotation.