Southwest Environmental Limited

Environmental Delivery Plans (EDPs)

Environmental Delivery Plans (EDPs) are new concept. SWEL have the required skill sets required to develop them. Please contact us if you would like us to provide consultancy serves to that end. Ingredients we feel that would be needed:

• Ecological (Baseline & Proposed Changes)
• Hydrological (For River & Wetland Behavior)
• Geological (Hydrogeological & Geotechnical Properties)
• GIS (For Mapping & Measurement)
• Testing (For monitoring and analysis programs)
• Options Appraisal (Broad context to aid with making to right choices)

The Planning and Infrastructure Bill (PIB) was designed to fundamentally change how the UK deals with environmental impacts. The most significant changes the Planning and Infrastructure Bill (PIB) is responsible for concern nutrients and environmental protections.

What are Environmental Delivery Plans (EDPs)?

An Environmental Delivery Plan (EDP) is a new strategic framework introduced by the UK’s Planning and Infrastructure Bill to fundamentally change how environmental harms from development are mitigated, primarily focusing on issues like nutrient neutrality.

Prepared by Natural England, EDPs are area-based, 10-year plans that set out a package of conservation measures sufficient to address the cumulative environmental impact of multiple new developments across a specific area (like a river catchment).

The core function is to allow developers to pay a Nature Restoration Levy (NRL) into a central fund, which discharges their site-specific mitigation obligations (e.g., for nutrient pollution). This pooled money is then used by Natural England to fund the large-scale, strategic nature recovery projects (like creating wetlands) outlined in the EDP, achieving a better ecological outcome—and aiming to speed up housing approval—than the current project-by-project approach.

Nature Restoration Levy (NRL)

The Nature Restoration Levy (NRL) is a key financial mechanism introduced by the UK’s Planning and Infrastructure Bill (PIB) to tackle environmental issues like nutrient neutrality and streamline the housing approval process.

The NRL is a charge payable by developers who are working in areas covered by an Environmental Delivery Plan (EDP). By paying the levy, the developer can effectively discharge their legal obligation to conduct site-specific environmental assessments and mitigation for issues covered by the EDP, which often include the nutrient impact of their new development.

The money collected from the Levy forms the Nature Restoration Fund (NRF). This fund is then used by Natural England or a designated delivery body to finance the strategic, large-scale conservation measures—such as creating wetlands or restoring riparian buffer strips—that are set out in the EDP for that entire region.

The levy is intended to replace the inefficient, project-by-project approach with a faster, coordinated system, ensuring that development contributes to strategic environmental improvement across a wider catchment area while speeding up the delivery of new homes. The levy rates are set to cover the cost of these conservation measures.

Estimated Costs to Developers (Guess Work - November 2025)

These schemes would fall under the category of Ecosystem Services. Just as nay form of development is driven by supply / demand and base cost, these schemes will be no different.

The government's stated intention is that the total cost of the NRL should be no greater than the existing cost of developers carrying out bespoke, site-specific mitigation for environmental obligations like nutrient neutrality.

The NRL system is designed to operate in a similar way to the Community Infrastructure Levy (CIL), where local authorities set rates based on the viability of development in their area, and the need for new infrastructure. The NRL will likewise be tailored to the local environmental need and the economic viability of development.

Current open market costs for offsetting one home (for nutrient neutrality) would be between £2500 and £10,000. The price depends on a number of factors:

• Calculation Method
• Water Use
• Sewage Works / Treatment Plant Efficiency
• Land Use Change
• Ability to Mitigate on Site

These prices may reduce, as the government may supply the offsets "at cost" which would remove profits margins from current figures.

These variables are likely to carry over from the current site by site system to the new system, and it very unlikely there will be set cost.

What Can We Expect: The Good, The Bad & The Ugly

This page assumes that the Planning and Infrastructure Bill (PIB) is passed and EDPs become "a thing".

The Good

"The main advantage of the Environmental Delivery Plans (EDPs) is the streamlining and acceleration of the planning and housing delivery process, particularly in areas affected by complex environmental rules like nutrient neutrality."

However, given that a site by site metric will need to be established so as to derive a NRL figure the situation will not be any more simple, the burden of the complexity is merely shifted on to regulators / local authorities.

The Bad

It is highly unlikely that the Nature Restoration Levy (NRL) will be a single, set rate for every house across the country.

The legislation is structured to ensure the levy is variable and site-specific, primarily linked to the distinct environmental needs of different geographical areas.

Cost of Mitigation: The rate must be sufficient to cover the actual and expected costs of the conservation measures (like building large-scale wetlands or habitat restoration) proposed in the EDP to counteract the pollution effects of the covered development.

Economic Viability: The Levy must also take into account the economic viability of development in that area, ensuring the cost doesn't become a barrier to housebuilding.

The Ugly

Time.

The main barriers to the current system, have been uncertainty and the time that has wasted owing to deliberation (both for LPAs and House Builders / Developers):

• 2019 - We first came across the nutrient neutrality issue at this time and although we were quick to develop a technical solution to the problem on sites where it allowed we then forced with a weight of several months whilst local planning authorities decided what to do and how to assess each site there was the release of the budget characters for nutrients and very slowly things ground forward on sites with legal issues those even more delays and in some cases developers waiting for two or three years for results for a result this created a massive amount of uncertainty in the market and really slowed everything down. There is a reasonable log of the uncertainty surround the conception of neutrient neutrality as a topic on our Phosphate Assessment Page (check out the updates section)
• 2023 - The poorly conceived amendment the habitat habitat regulation laws which were almost certainly entirely crafted by lobbyist from the housing industry (this was fairly obvious from there simplistic and over optimistic wording) caused another massive delay for numerous projects as developers waited to see whether this ill conceived coup with bear fruit. It didn't.

So fast forward to 2025 and house builders are still trying to undermine our environmental protections, and being there in the business of making houses and selling them you can see why there might do this (as at present the laws get in the way of them building the houses) but what they have overlooked is that this goes far beyond an economic argument, and just as there they have failed to simplify this process back into 2023 they have pretty much scored another art own goal with EDPs. EDPs will not simplify anything because it will shift the onus of assessment work from the developers who can afford to pay consultants to do the work. . .  on to local councils or regulators such as Natural England who are horrifically understaffed and chronically underfunded and as we've seen with the nutrient neutrality rules . . . up to this point local authorities still shouldering the effects of austerity and also very much reduced in efficiency following the increase in homeworking following the pandemic will not effectively be able to take on all of this extra work without significant extra funding and even if there is.

Time.

If and when these new rules do come in to force, there will be huge delays in getting any development passed off:

1. The governmental entities responsible for assembling these EDPs will take ages (estimate 3 years for paper work - we could help shorten that if invloved)
2. The uncertainty this wait  will have on the housing market will damage the economy.
3. The actual underlying science will not change, and things will not get simpler.

And that is before we even start to consider the practical challenges of delivering enough nutrient neutrality credit schemes to offset all of the houses we need to build. . . oh and the dire state of our sewage works and associated systems in the UK.