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Is 3% to 5% Radon Dangerous?


It means that between 3% and 5% of the home in your area are above 200 Becquerels m-3 .The conclusion of this page is “if in doubt” test. Get a testing kit from UK Radon (Part of Government) and follow their instructions. Our professional advice is not to test for less than 3 months. It is quite likely to give and inaccurate result. Read on for more delicious boffin waffle:


You are reading this because Radon is dangerous. Radon is a radioactive gas, and  small percentages in the air that you are breathing can be disaster. But how small? And what does 3 to 5 % mean?

Every building contains radon but the levels are usually low. The chances of a higher level depend on the type of ground. UK Health Security Agency has published a map showing where high levels are more likely.

Above from UK Radon.It is boradley correct, but as well as the “type of ground” the type of building is very important.


The “action” level for Radon is 200 Becquerels m-3   At this point we don’t really need to understand what that means, just that is exists.

What Does 3% to 5% Mean?

It means that between 3% and 5% of the home in your area are above 200 Becquerels m-3  (the action level). The worst it could be is 30% over the level, and best is 1% or less.

So that is a bit confusing isn’t it. Is you home dangerous or not? Well really we would need to know a lot about you building before we could make a guess. Not only what radon was coming out of the ground (difficult to measure), but also how much of it leaks out (also difficult to measure).

Type of Building

Good – If the house is a modern building with a radon protection barrier, sump, and other features then chances are that you indoor air quality will be good (with regards to radon) and you will be below action level. But the bottom line is you do not know if you are safe unless you test. Perhaps the builders made some mistakes, perhaps they didn’t follow the plans, or the building inspector forgot to check. . . .

Bad – If the house is old, and maybe has a suspend timber floor, with no damp proof course, then radon can get in to the house from the ground. However, if the house also has old leaky windows and drafts coming under the door, then this may help keep radon levels lower, as they will have less chance build up. Things like positive input ventilation, or a wood burner, or a vented tumble drier can also affect air flow through the house, and affect radon levels. But the bottom line is you do not know if you are safe unless you test.

Ugly – An old house, with no damp proof course which as be subsequently upgraded to include double glazing, draft proofing and uses combustion appliances with balanced flues, will experience very little air flow, whilst allowing ground gases (including radon) in to the building. Very very much worth urgently doing some testing if you are in this situation.


The bottom line is you do not know if you are safe unless you test.

There are too many variables to predict accurately what the radon level in a house will be. All we know from the 3% to 5% bracket, is that “some” houses in your area have a problem.

Construction techniques, building age, choice of appliances, choice of heating systems, and user behaviour all play a role in radon levels. The bottom line is you do not know if you are safe unless you test.

When you do the test get you kits direct from UK radon:

They are the official government labs, and will not recommend test period of less than 90 days. Do not test for less than 90 days because of all the variables, as mentioned above, you need to measure for a long period to make sure results are representative.

Planning Consultants Bristol 


60 Day Rule for Camping & Flood Risk

60 Day Rule for Camping & Flood Risk

You have been Asked for a Flood Risk Assessment and Flood Warning Plan when you have decided to extend your 28 days camping rule, to 60 days you may be required to submit a Flood Risk Assessment and a Flood Warning Plan. We can write both of these for you.

In the last chapter on this page we offer a up a few tips if you would like to try and write you own flood risk assessment.

a picuture show camping and tents flooded in a field the water is muddy and you cannot see the gound the tops of the colourful tents are poking out of the surface of the flood water

Glastonbury 2005 – Creative Commons 2.0 – sebFlyte

The 60-day Rule

  • Introduced in July 2023, it allows landowners to use their land as a campsite for up to 60 days per calendar year for up to 50 pitches, without needing full planning permission.
  • It applies to tents, motorhomes, and campervans (but not touring caravans).
  • You must notify your local planning authority beforehand with details like dates, site plan, and waste disposal methods.

Flood Risk and the 60-day Rule

Sites in Flood Zone 2 or 3 Require Additional Consideration

Even outside Flood Zones 2 & 3, be Cautious

      • Check historical flood maps and local flood risk information.
      • Choose campsites on high ground, away from bodies of water, and avoid low-lying areas.
      • Stay updated on weather forecasts and be prepared to evacuate if necessary.


  • The 60-day rule simplifies permissions, but flood safety remains paramount.
  • Prioritize safety and choose campsites with minimal flood risk, regardless of the rule’s applicability.

A Little Help

We fully appreciate that some smaller campsite, may not make a huge amount of money, and as such we provide the below hints for writing your own Flood Risk Assessment which perfectly OK thing to do.

  • Why not use Google Gemini to Write the Bulk of the Text for You
  • Order a “Product 4” from the Environment Agency (You can do this via “Flood Map for Planning “)
  • Use the data they provide (you have to wait 20 days) to write you report.
  • Move camping areas to low risk areas.
  • Use flood risk areas for open areas or sports areas.
  • Describe what people will do if the campsite becomes flooded, and where they can shelter.
  • Read about “flash flooding” and what the dangers are, think about how you can warn people about it (sign up to flood warnings and sever weather warnings).

Lots of Help

We can do this for you if you like.

Shadow Habitat Regulation Assessment: Ashford, Kent


Do you need an SHRA (Shadow Habitat Regulation Assessment) for you planning application, in Ashford, Kent? If you do please contact us and we can quote for a cost effective and timely service.

Why Do I need and SHRA?

The nutrient neutrality issue in Ashford, Kent, revolves around protecting the water quality of the Stour catchment, which has been negatively impacted by excess nutrients like nitrogen and phosphorus. These nutrients primarily come from sources like agriculture and wastewater treatment plants.

By Alex Lockton – Own work, CC BY-SA 4.0

Here’s a breakdown of the issue:

The Problem:

  • Excess nutrients in the Stour catchment harm sensitive habitats like the internationally important Stodmarsh nature reserve, so an Shadow Habitat Regulation Assessment is needed.
  • To address this, Natural England implemented regulations requiring “nutrient neutrality” for new developments. This means any development that adds nutrients through wastewater needs to find ways to offset that impact elsewhere.

The Impact:

  • This requirement has significantly impacted building projects in Ashford, as around 90% of planned development sites fall within the affected area.
  • Many planning applications have been put on hold, hindering housing development and causing economic concerns, unless a Shadow Habitat Regulation Assessment can be provided, and then not even then!

The Controversy:

  • Local authorities like Ashford Borough Council argue that the onus shouldn’t solely fall on them to address a wider issue beyond their control.
  • They emphasize that water companies and the Environment Agency, responsible for water quality, should share the responsibility.
  • The government initially proposed changes to lessen the burden on local authorities, but these were met with opposition and not enacted.

Current Status:

  • As of October 2023, the government is working on a new bill to address the nutrient neutrality issue, aiming to shift responsibility to relevant bodies. But this was voted out, owing to being so poorly written. And as such for the time being the issue remains.
  • Ashford Borough Council continues to seek solutions for development while the new bill takes shape.

Further Resources:

The Windshield Phenomenon

A New Phrase I Wish I Didn’t Know!

I suddenly realised the other day that my children (some of whom are teenagers) have never seen a car windshield (or windscreen :-/ if you are in the UK) covered in squashed bugs. “Good” you might say what a horrible thing to show a child. But really it is very worrying that they don’t know that this used to be normal in the UK during the summer, and its absence is not a great sign with regard to the UK’s levels of biodiversity.

Shifting Baselines

Example: Imagine a child growing up in a city with smog-filled skies. They may not realize the air quality is unhealthy because it’s their “normal.” This is the essence of shifting baseline syndrome: each generation accepts the current state of the environment as the baseline, even if it’s degraded compared to the past.

Windscreens of the Past

The Windshield phenomenon, also known as the Windscreen phenomenon, refers to the observation that fewer dead insects seem to accumulate on the windshields and front bumpers of cars compared to past decades. It’s become a common anecdotal observation among drivers, particularly those who have been driving for many years.

While the phenomenon itself is quite noticeable, the reasons behind it are complex and multifaceted. Here are some of the leading explanations:

1. Decline in insect populations:

  • This is arguably the most concerning explanation. Studies across the globe have documented a significant decline in insect populations, with some estimates suggesting a drop of up to 75% in some regions since the 1990s.
  • This decline is attributed to several factors, including habitat loss and fragmentation due to deforestation and urbanization, excessive pesticide useclimate change, and light pollution.

2. Changes in driving habits and car designs:

  • Modern cars tend to be more aerodynamic and have smoother front ends, which might make it less likely for insects to hit the windshield directly.
  • Additionally, increased highway speeds and changes in driving routes may also play a role, as insects are less likely to encounter cars at certain speeds or on specific roads.

3. Observer bias:

  • It’s possible that the Windshield phenomenon is partly due to our own perception. As people become aware of the decline in insect populations, they might be more likely to notice the absence of insects on their windshields, even if the actual number hasn’t changed significantly. However, I would have thought a long drive in the summer would yield a few casualties, so driving from Devon to Scotland without killing a single bug. . .  that is a bit of a coincidence.

The implications of the Windshield phenomenon are worrisome:

  • Insects play crucial roles in ecosystems as pollinators, decomposers, and prey for other animals. A significant decline in their populations could have cascading effects on entire ecosystems, impacting food webs and potentially even affecting human food security.

Therefore, it’s important to take the Windshield phenomenon seriously and investigate the causes behind it further.

More research is needed to understand the full extent of the decline in insect populations and to develop effective conservation strategies.

Here are some additional things to keep in mind:

  • The Windshield phenomenon is not a definitive indicator of insect decline on its own. More comprehensive studies are needed to confirm the trends and their underlying causes.
  • While the phenomenon might be partly due to observer bias, it’s still a valuable observation that raises awareness about the potential threat to insect populations.
  • Conservation efforts focused on protecting insect habitats, reducing pesticide use, and mitigating climate change are crucial to addressing the broader issue of insect decline.

Remember, even small changes in our individual habits, like choosing organic produce and opting for sustainable gardening practices, can contribute to a healthier planet for insects and ourselves.

How Can Sewage Companies Increase Biodiversity?

Perhaps – But What is Being Done at the Moment is not Enough.

Sewage companies, even though dealing with the not-so-glamorous side of our lives, can play a surprisingly crucial role in boosting biodiversity. But the light touch methods used at present will not outway the harm that outdated, and badly run assets causes. Here are some ways sewage companies claim to help at present:

1. Investing in advanced treatment technologies:

  • Membrane bioreactors (MBRs): These sophisticated systems use membranes to filter out even the tiniest contaminants, producing cleaner effluent that’s safer for aquatic life.
  • Nutrient removal technologies: Excess nutrients like nitrogen and phosphorus from sewage can trigger harmful algal blooms, upsetting the ecosystem. Advanced treatment methods like biological nutrient removal can help control these nutrients.
  • Microbial fuel cells: These innovative systems harness the power of microbes to generate electricity from wastewater, potentially turning waste into a resource and reducing reliance on fossil fuels. This may seam slightly detached from bio diversity, but resource used and climate change are both reducing biodiversity.

2. Minimizing pollution at the source:

  • Public education and outreach: Raising awareness about responsible disposal of pharmaceuticals, personal care products, and other harmful substances can significantly reduce their presence in wastewater.
  • Collaboration with industries: Partnering with industries to pretreat their wastewater before it enters the municipal system can significantly lessen the load on treatment plants and protect aquatic ecosystems.
  • Investing in leak detection and repair: Leaky pipes and sewers allow untreated wastewater to escape into the environment, contaminating water sources and harming biodiversity. Regular inspections and proactive repairs can minimize these leaks.
  • Elimination Combined Sewer Overflows: Combined sewer overflows (CSOs) can have a significant and negative impact on the environment, public health, and infrastructure.

3. Creating and restoring natural habitats:

  • Wetlands construction: Wetlands act as natural filters, removing pollutants and providing habitat for diverse species. Sewage companies can create or restore wetlands near treatment plants to enhance biodiversity.
  • Riparian buffer zones: Planting trees and shrubs along riverbanks helps stabilize the soil, prevents erosion, and creates valuable habitat for birds, insects, and other wildlife.
  • Fish stocking programs: In some cases, carefully planned fish stocking programs can help restore fish populations in rivers impacted by past sewage discharges.

4. Embracing circular economy principles:

  • Resource recovery: Sewage sludge, a byproduct of treatment, can be treated and turned into fertilizer or renewable energy sources, reducing reliance on virgin resources and minimizing waste.
  • Water reuse: Treated wastewater can be used for irrigation, industrial processes, or even toilet flushing, reducing pressure on freshwater resources.

By implementing these strategies, sewage companies can transform their operations from potential threats to biodiversity into valuable contributors to a healthier planet. Remember, a thriving ecosystem not only benefits the environment but also leads to cleaner water, improved public health, and a more resilient future for all.

But – The Damage is Far Worse

Sewage, a byproduct of our daily lives, poses a significant challenge to the UK’s precious biodiversity. While modern wastewater treatment facilities significantly reduce pollution, the issue remains complex, with various factors influencing the impact on different ecosystems.

Negative Effects:

  • Nutrient Overload: Excess nutrients like nitrogen and phosphorus from sewage can trigger algal blooms, depleting oxygen levels and harming aquatic life. Imagine vast stretches of water covered in thick, green scum, suffocating fish and other organisms.
Image of Algae bloom caused by sewage pollutionAlgae bloom caused by sewage pollution
  • Toxic Chemicals: Sewage can contain pharmaceuticals, personal care products, and industrial pollutants that are harmful to wildlife. These chemicals can disrupt hormones, impair reproduction, and even cause deformities in animals.
  • Habitat Degradation: Untreated sewage spills or overflows can contaminate rivers, streams, and coastal areas, damaging sensitive ecosystems like coral reefs and seagrass meadows. These vital habitats provide food and shelter for countless species, and their loss has cascading effects throughout the food chain.
  • Spread of Disease: Sewage can carry bacteria, viruses, and parasites that can sicken fish, birds, and other wildlife. This can lead to outbreaks of disease and population decline, disrupting the delicate balance of ecosystems.
  • Plastics: Our ubiquitous companions in modern life, unfortunately find their way into our sewage systems, posing a significant and often hidden threat to aquatic ecosystems and potentially even human health. Everyday plastic items like disposable cups, plastic bags.

What Areas of UK have the Worst Air Quality?

Top 4 Worst Areas for Air Quality in the UK

Air quality in the United Kingdom varies across different regions and cities. According to the Department for Environment, Food and Rural Affairs (DEFRA), the following areas in the UK have the worst air quality:

  • Greater London: Greater London has consistently high levels of nitrogen dioxide (NO2) pollution, mainly due to road traffic emissions. In 2022, 16 out of the 20 local authorities in Greater London exceeded the annual legal limit for NO2.

image shows various shapes that represent the particles and organisms being discussed the virus is the smallest and the PM10 particle is the biggest

PM2.5 PM10 Relative Sizes

  • South Wales: South Wales has high levels of particulate matter (PM) pollution, mainly due to emissions from industrial processes and power plants. In 2022, four out of the five local authorities in South Wales exceeded the annual legal limit for PM10.

  • West Midlands: The West Midlands has high levels of NO2 pollution, mainly due to road traffic emissions. In 2022, four out of the seven local authorities in the West Midlands exceeded the annual legal limit for NO2.

  • Glasgow: Glasgow has high levels of NO2 pollution, mainly due to road traffic emissions. In 2022, Glasgow exceeded the annual legal limit for NO2.

Are these Always the Worst Places for Air Quality?

It is important to note that air quality can vary significantly within these areas, and there may be pockets of clean air even in areas with generally poor air quality. Additionally, air quality can vary from day to day depending on weather conditions and traffic levels.

Where can I find our more about Air Quality?

Here are some resources that you can use to find information about air quality in your area:

Southwest Environmental Limited: Your One-Stop Shop for Flood Risk Assessments

Flood Risk Professionals

Flooding is a natural disaster that can cause significant damage to your property. It can also lead to business interruption and loss of income. That’s why it’s important to have a flood risk assessment in place to protect yourself from the financial and emotional costs of flooding.

a man is cycling along a flooded street in england, the water is brown and about 10cm deep, he is not looking hwere he is going and behind him there is a row of shop one is painted yellow with the words cartridge world written on the sign, the buildings in the background look quite old maybe 100 years old of more

Image: johnda CC BY-SA 2.0

Southwest Environmental Limited is a leading provider of flood risk assessments in Somerset. We have a team of experienced professionals who can help you assess your flood risk and develop a plan to mitigate it. We offer a range of services, including:

  • Flood hazard mapping: We can use our advanced mapping technology to identify areas that are at risk of flooding.
  • Flood risk assessment: We will assess your property’s vulnerability to flooding and identify potential risks.
  • Flood mitigation planning: We will develop a plan to reduce your flood risk, such as installing flood barriers or making changes to your property’s drainage system.

Why Choose Southwest Environmental Limited?

  • We are experienced: We have been providing flood risk assessments for over 15 years.
  • We are qualified: Our team of professionals is qualified to assess flood risk.
  • We are affordable: We offer competitive rates for our services.

Contact us today to schedule a flood risk assessment.

Don’t wait until it’s too late. Protect your property from flood damage with a flood risk assessment from Southwest Environmental Limited.

Are there Nutrient Credits Available in Somerset?

Yes, there are nutrient credits available in Somerset. Nutrient credits are a way for developers to offset the negative impact of phosphate emissions from their projects. This is important because phosphates can harm the environment, especially in sensitive areas like the Somerset Levels and Moors.

The cost of nutrient credits varies depending on a number of factors, including the location of the project and the amount of phosphate that needs to be offset. However, you can expect to pay around £55,000 per kg of phosphorus.

If you are a developer considering purchasing nutrient credits in Somerset, you should contact a number of different companies to get quotes. You should also make sure that the company you choose is reputable and has a good track record of delivering nutrient credits.

Here are some of the benefits of using nutrient credits in Somerset:

  • They can help you to get your project approved by the planning authority.
  • They can help you to avoid delays to your project.
  • They can help you to protect the environment.

If you are considering using nutrient credits in Somerset, I recommend that you do your research and choose a reputable company. Nutrient credits can be a valuable tool for developers who want to protect the environment and get their projects approved.

What Pollution is in the Air in London?

5 Mains Pollutants in the Air in London

The main sources of air pollution in London are road transport and domestic and commercial heating systems.This leads to a lowering of Air Quality.  These sources emit a variety of pollutants, including:

  • Nitrogen dioxide (NO2): NO2 is a reddish-brown gas that is produced when fossil fuels are burned. It is a major irritant to the lungs and can cause respiratory problems such as asthma, bronchitis, and pneumonia.
  • Particulate matter (PM): PM is a mixture of solid particles and liquid droplets found in the air. It can come from a variety of sources, including car exhaust, wood burning, and construction dust. PM can cause a variety of health problems, including heart disease, stroke, and lung cancer.
  • Ozone (O3): O3 is a gas that is formed when sunlight reacts with NO2 and other pollutants. It is a powerful irritant to the lungs and can cause respiratory problems such as asthma and bronchitis.
  • Sulfur dioxide (SO2): SO2 is a colorless gas that is produced when fossil fuels are burned. It is a major irritant to the lungs and can cause respiratory problems such as asthma and bronchitis.
  • Volatile organic compounds (VOCs): VOCs are a large group of chemicals that are released into the air from a variety of sources, including cars, factories, and paints. Some VOCs are known to be carcinogenic.

Lesser Know Pollutants in the Air in London

In addition to these main pollutants, air in London can also be contaminated with other pollutants such as carbon monoxide, lead, and mercury.

In addition to “chemicals” there is also a wide variety of plastic origin particle mater (POPP), this can come from laundry fibres and car tires.

a map showing air quality in central london yellow and green area are shown as being less polluted whilst red and purple areas are over the safe AQO limit, areas next to big ben and parliament square show as being above air quality objective

London Air Quality Network » Annual Pollution Maps

The levels of air pollution in London vary depending on the location and the time of year. Central London is generally the most polluted area, as it has the highest concentration of vehicles and other sources of pollution. Air pollution levels are also higher during the winter months, when people are more likely to burn wood for heating.

The Mayor of London has set a target of achieving world-class air quality by 2030. To achieve this goal, the city is implementing a variety of measures, including:

  • Reducing traffic emissions: The city is investing in public transportation, cycling infrastructure, and electric vehicles. ULEZs can also help reduce emissions from vehicles.
  • Improving energy efficiency: The city is helping businesses and residents to reduce their energy consumption, which will help to reduce air pollution emissions from heating and power generation. These schemes although available in theory are often difficult to apply for for, and they are not suitable for all people. For example swapping a gas boiler for a heat pump is only possible if your house is well insulated.
  • Planting trees and green spaces: Trees and other plants can help to filter air pollution and improve air quality. Some people even take it upon themselves to plant trees in their local neighbourhoods.

The city is also working with other cities and countries to share best practices and reduce air pollution on a global scale.

If you require an Air Quality Assessment in London or Bristol, or anywhere in the UK we are happy to help. Please contact us.

Critique of Michael Gove’s Nutrient Neutrality Announcement

Critique of Michael Gove’s Nutrient Neutrality Announcement

Below you will find commentary of government plans to reform nutrient neutrality laws. Comments are

  • bulleted

Nutrient Neutrality Announcement

Over 100,000 homes held up due to defective EU laws will be unblocked between now and 2030, delivering an estimated £18 billion boost to the economy, the government has announced today (29 August 2023).

  • Comment: Not all of the nutrient sensitive sites are European sites, some such as SSSIs are international.

Currently, legacy EU laws on nutrient neutrality are blocking the delivery of new homes, including cases where planning permission has already been granted. Nutrients entering our rivers are a real problem, but the contribution made by new homes is very small. These laws which originate from Brussels put a block on new homes in certain areas – taking away control over what is built, and when, from local people.

  • Comment: One house will make a small contribution. 100,000 homes will make a lkare contribution.

Through an amendment to the Levelling Up and Regeneration Bill, the government will do away with this red tape and allow for the delivery of more than 100,000 new homes desperately needed by local communities. Thanks to the government’s action, it is expected that developers could begin construction on these homes in a matter of months.

  • Comment: This is presented as though the whole of society will benefit from this reform. One of the main obstacles to people buying new homes is high interest rates, and high living costs. This is nothing to do with nutrients.

The move comes alongside new environmental measures that will tackle pollution at source and restore habitats. This includes significantly expanding investment in and evolving the Nutrient Mitigation Scheme run by Natural England, doubling investment to £280 million to ensure it is sufficient to offset the very small amount of additional nutrient discharge attributable to up to 100,000 homes between now and 2030.

  • Comment: On a rural waste treatment works around 700m2 of wetland is required to offset 1 home. To offset 100,000 new homes we will require 70,000,000m2.  Wetland at very best case costs around £4 per m2 to buy land and create. And as such the this extra £140 million is around half the amount required.

Natural England will work with local authorities, the private sector and others to tackle nutrient pollution and work towards the long-term health and resilience of the river systems. The government intends to work with the house building industry to ensure that larger developers make an appropriate and fair contribution to this scheme over the coming years, and is discussing the right structure and approach with the Home Builders Federation.

  • Comment: Natural England have had 3 years to do this already and have not delivered. I am writing this from a small developers perspective because that is who we deal with. But Natural England have taken in some case 3 years to make a decision on some the sites we are working on, which is too slow. This may because of the liabilities that arise from breach of ecological laws.

The government will then accelerate work on full site restoration through further work on new Protected Site Strategies, which Natural England will draw up in partnership with local communities to set protected sites on the path to recovery in the most affected catchments with the highest housing demand.

Secretary of State for Levelling Up, Housing and Communities, Michael Gove MP said:

We are committed to building the homes this country needs and to enhancing our environment. The way EU rules have been applied has held us back. These changes will provide a multi-billion pound boost for the UK economy and see us build more than 100,000 new homes.

Protecting the environment is paramount which is why the measures we’re announcing today will allow us to go further to protect and restore our precious waterways whilst still building the much-needed homes this country needs.

We will work closely with environmental agencies and councils as we deliver these changes.

  • Comment: Not all of this is EU law. Some is international. The phosphate credit market (of which are we are part) will also provide a multi billion pound boost to the economy. These credits scheme also benefit farmers, smaller developers and homeowners, who are often eligible for free septic tank upgrades, or 6 figure sums from changing the way their farm operates. An open phosphate credit market spreads wealth around.

Secretary of State for Environment, Food and Rural Affairs, Thérèse Coffey said:

These new plans will cut nutrients and help support England’s precious habitats whilst unlocking the new homes that local communities need.

We are going to tackle the key causes of nutrients at source with over £200 million of funding to reduce run off from agriculture and plans to upgrade waste water treatment works through conventional upgrades, catchment approaches and nature-based solutions.

  • Comment: This sounds like a tax payer funded bail out of water companies. With taxpayer money going to water companies so they can upgrade their water works. They should have course made less profit and done this work years ago.

This builds on the key commitments made in our 5-year strategy – our Environmental Improvement Plan – as well as our Plan for Water which brings forward more investment, stronger regulation and tougher enforcement to protect our rivers.

Alongside the amendments tabled to the Levelling Up and Regeneration Bill, which is currently in the House of Lords, the government has announced a series of new environmental measures to restore our protected sites, including a commitment to offset the very small amount of additional nutrients attributable to up to 100,000 new homes. Beyond the immediate action that will be driven by Natural England’s Nutrient Mitigation Scheme, this package includes:

Committing to further work on developing Protected Sites Strategies in the catchments most impacted by nutrient neutrality and with the most acute housing pressures. These bespoke plans will help identify specific action needed to restore habitats and species in specific areas. The aim is to agree and implement tangible actions to reduce pollution at source, through nature-based solutions such as wetlands and new innovations.

Reducing nutrients entering the water from new development with new laws expected to drive significant investment from water companies to upgrade wastewater treatment works to the highest technical standards by 2030. The next water company investment cycle will be among the biggest and most ambitious ever.

  • Comment: Who is paying for those upgrades. And how will it impact on water bills.

Conducting at least 4,000, inspections on farms each year – making sure that slurry and other sources of nutrients are being handled in a way that minimises pollution of the water environment.

Reducing nutrient run off into our rivers from farms – supporting our farmers by investing £200 million in grants for improved slurry storage infrastructure and precision spreading equipment. This makes a further £166 million available for new investment into slurry infrastructure.

  • Comment: This is already implemented. But it is difficult to get planning permission for improved slurry storage owing to the calculation methodologies employed in assessing their impact.

Investing £25 million to drive innovation to help farmers manage plant and soil nutrients. This will increase resilience, reduce input costs and improve productivity as part of a more circular economy for nutrients. The effective use of waste has the potential to create new revenue streams. We will also consult this year on modernising our fertiliser product standards to drive increased use of organic and recycled nutrients.

Introducing from 2024 payment premiums into our environmental land management schemes. This will accelerate take up of certain high priority options, including those that provide benefits for water quality.

Publishing a River Wye action plan this autumn to tackle the unique issues in Herefordshire.

Ensuring new homes built do not place undue stress on already stressed local water networks by consulting this year on new requirements where needed for Sustainable Drainage Solutions to reduce pressure on storm overflows from new homes and flood risk.

All of this builds on our Plan for Water, which sets out measures to transform and integrate our water system, address sources of pollution and boost our water supplies through more investment, stronger regulation, and tougher enforcement.

Our nutrient reduction plan will also help deliver on our legal target to reduce nutrient runoff from agriculture by at least 40% by 2038, and by 15% in nutrient neutrality catchments by 2028, and to reduce phosphorus loadings from wastewater by 80% by 2038, and by 50% by 2028.

  • Comment: How will this be delivered without increasing dependency on food imports.

The government has a strong record on housebuilding, with more than 2.2 million homes delivered since 2010. The Secretary of State for Housing recently set out his long-term plan to go even further and unlock more development across the country.

Changes to nutrient neutrality rules and wider planning reforms will allow the government to go even further towards its target of delivering one million homes this Parliament.

The environmental measures announced today lead on from the government’s Plan for Water published in April which set out actions to address all sources of water pollution, including through accelerating £2.2 billion of water company infrastructure investment to prevent storm overflow discharges and improve drought resilience, and unlimited fines for environmental polluters.

  • Comment: Who is paying for these upgrades. Do this shift financial burden from house builders and water companies on to tax paper / bill payer.

The current EU-derived regulations have required Natural England to issue guidance to 62 local authority areas that new development must be ‘nutrient neutral’ in their area, including Somerset, Norfolk, Teesside, Kent, Wiltshire and the Solent. This has blocked or delayed new development – including around a large number of homes that already have planning permission and local communities have already said they want.

The amendment today will remove this requirement, allowing Natural England greater freedom to develop catchment-specific solutions to the causes of nutrient pollution in partnership with each community, supported by government and private investment.

  • Comment: Natural England already have that ability.

SWEL’s Opinion

The problem with nutrient neutrality is not the law, or the lack of solutions. The problem stems from:

  1. Lack of staff in Councils and Natural England
  2. Lack of effective decision making by Councils and Natural England

We have been offering solutions, for over 3 years. However, there has been little urgency on the part of planning officials and natural england to approve these, or to provide advice. In situation where we have found a way through, it has taken years to do so.

Some ideas, that might work:

  1. Doubling staffing levels of National England
  2. Doubling Staffing Levels in Planning Offices
  3. Pay Natural England extra money for each home passed off.
  4. Leave the rules as they are.