Tag Archives: Phospahtes

Do I Really Need An NNMAS?

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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.

 

Phosphates in Wales

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This week, we have had our first taste of the Phosphate Planning Issues arising in Wales. This relates to the trickle down from the Dutch N Ruling (2018) which has been affecting various parts of the UK, since late 2020.

The Afon Teifi, Afon Tywi (River Towy), River Wye and Afon Cleddau are located in special areas of conservation, and as such affected by the ruling.

For this our first report in Wales relating to the Phosphate situation we have encountered some key differences, between Wales and England.

Calculators

So Far only Carmarthenshire has release a budget calculator. Compared to the the calculators we have been using in Somerset and Cornwall, it is quite limited, although it is good that it can be used offline, so we can save a copy for later use, or reference! Take note Somerset and Cornwall (probably not though).

The Carmarthenshire calculator does not automatically calculate mitigation options. This leaves sizing of wetlands for example up to the applicant / agent / consultant. And we would consider this problematic, as even with agree methods (as indicated in Somerset / Cornwall Calculators) there is enough detail to contest, without added variability.

Treatment Works

Unlike the Sewage Treatment Works (STWs) we have seen in England, many of the welsch plants have no consent limit for Phosphates. They are also for the most part way over capacity, as some of them run in overflow mode (raw sewage in rivers) for 50% of the year.

This lack of consent limit is an advantage for developers and open the possibility of pre-treating waste water from mains connected sites, to provide a benefit.

Some Similar Problems

However, some things remain the same:

In Somerset and Cornwall we have had very little feedback on sites with wetlands, or sites which use extant uses to offset new uses, or that use off-site schemes. They are all in limbo, I wouldn’t mind some critique because at least that might seam as though things were moving along. I expect this to be the same in Wales.


There have been queries on other application in Wales that seek to discredit the accuracy of treatment efficiencies. We have seen this in England and Wales. Wetlands for example for a project in cornwall have been called in to question. With regards to banking coefficients yes they will vary. But so do treatment efficiencies of manufactured solutions, and phosphate concentrations of effluent, and as such I do not think it is meaningfully practical to adjust banking coefficients.


As with all things environmental science we are trying to take a non-numerical highly variable system (a human urinating in a toilet) and apply maths to the resultant processes. It cannot be done 100% accurately. So uncertainty has to be accounted for. If a study were undertaken of say 50 systems, monitoring for inputs and outputs after 5 years we might arrive a c. 95% certainty that certain banking coefficint would be met. But in these early stages some uncertainty will have to be accepted. 


In the majority of reported cases the 99% filtration rate is achieved, and we have agreed to monitor outfall in long term, so very little remainder risk here.


In summary we need someone in NRW (or NE in England) to start making decisions on this promptly. IF not all the benefit that could occur driven by the real need for clean rivers could be written out of existence by the stroke of a pen by Llywodraeth Cymru.