Since 2015, we have understood the need to reduce nutrients in the environment, as a result of development.
PO4 Ltd is the only organisation that can supply in catchment phosphate credits to offset development.
Nutrient Neutrality Principles
Special Areas of Conservation (SAC), Special Protection Areas (SPA), and Ramsar sites are some of the most important areas for wildlife in the United Kingdom. They are internationally important for their habitats and wildlife and are protected under the Conservation of Habitats and Species Regulations 2017 (the Habitats Regulations). At some of these sites, there are high levels of nitrogen and phosphorus input to the protected water environment with sound evidence that these nutrients are causing eutrophication at these designated sites. These nutrient inputs currently mostly come either from agricultural sources or from wastewater from existing housing and other development. The effects on ecology from an excessive presence of nutrients are impacting protected habitats and species.
More on The River Avon
The River Avon SAC is a habitat site with water pollution and eutrophication considered a threat to its condition.
The River Avon and its tributaries (the Nadder, Wylye, and the Bourne) are chalk rivers flowing through narrow chalk valleys that converge at Salisbury. Below Salisbury, the Avon is a large river flowing over a wide floodplain. The river branches out south of Ringwood as it flows through Hampshire to reach the estuary at Christchurch, in Dorset.
The river supports over 180 species of
plants including water crowfoot and starworts that grow in clumps on the riverbed. This diverse aquatic plant community supports an extremely rich invertebrate life, including mayfly and snails that in turn support species such as Atlantic salmon, bullhead, brook and sea lamprey. Adjacent and linked wetland on the floodplain comprises wet swamps and fen, providing habitat for the Desmoulin’s whorl snail.
Increased levels of nitrogen and phosphorus entering aquatic environments via surface water and groundwater can severely threaten these sensitive habitats and species within the SAC. The elevated levels of nutrients can cause eutrophication, leading to algal blooms, which disrupt normal ecosystem function and cause major changes in the aquatic community. These algal blooms can result in reduced levels of oxygen within the water, which in turn can lead to the death of many aquatic organisms including invertebrates and fish.
The habitats and species within the river Avon that result in designation as a SAC are referred to as ‘qualifying features’. Not all of these qualifying features will be sensitive to changes in nutrients within the River Avon. When completing an HRA involving nutrient neutrality, the Competent Authority (normally the Local Planning Authority for developments) must identify and screen out qualifying features that are not sensitive to nutrients via a Habitats Regulations Assessment. Developers will be asked to submit information to support this process. More detailed information on the qualifying features of the Habitats site has previously been provided by Natural England.
Nutrient Neutrality
Many of our most internationally important water bodies are designated as protected sites under the Conservation of Habitats and Species Regulations 2017 and termed “Habitats Sites” in the National Planning Policy Framework. Under the Habitats Regulations, competent authorities, such as local planning authorities and the Environment Agency, must assess the environmental impact of projects and plans (such as planning applications or local plans) that come forward which affect these sites.
This is one of the ways environmental impacts are considered in the planning system (other examples include Environmental Impact Assessment, Strategic Environmental Assessment and Biodiversity Net Gain). Local Planning Authorities can only approve a project if they are certain it will have no negative effect on the site’s condition.
As a result of these regulations and European case law, Natural England has previously advised a total of 32 local planning authorities where protected sites are in unfavourable condition due to excess nutrients, projects and plans should only go ahead if they will not cause additional pollution to sites. They can demonstrate this through ‘nutrient neutrality’. This means that new residential development can only happen if the nutrient load created through additional wastewater from the development is mitigated. This typically involves creating new wetlands to strip nutrients from water or creating buffer zones to revert to nature. This has had a significant negative impact on the number of homes granted planning permission in affected areas.
Following further work to understand the sources of site deterioration, Natural England has identified a further 20 protected sites that are adversely impacted by nutrient pollution. As a result, Natural England has today advised, a further 42 Local Planning Authorities that their areas are covered by this advice. Different Local Planning Authorities are affected to different degrees – some will have only a small fraction of their area affected and others will be impacted to a much larger extent.
Government support for nutrient neutrality
We recognise that delivering ‘nutrient neutrality’ under the Habitats Regulations may impose additional costs on development. For some Local Planning Authorities, the requirement for new development to be nutrient neutral will have an impact on their ability to approve some new development quickly, in particular housing.
The government is clear that this can only be an interim solution. We must act to address the sources of pollution and tighten up the associated regulatory frameworks to prevent further harm to protected sites. We are committed to taking action to reduce the mitigation burden for communities to get the homes they need.
The government is committed to sustainable development and building the homes the country needs for the future, whilst addressing the sources of pollution to restore our protected sites. We have developed a package of support to ensure that developers and local planning authorities can achieve nutrient neutrality.
NE - Addressing nutrient pollution at the source
The 25-Year Environment Plan commits us to restore 75% of our one million hectares of terrestrial and freshwater protected sites to favourable conditions by 2042, and to return at least three-quarters of our waters, to as close to their natural state as soon as practicable.
We have launched our Environment Act 2021 environmental targets consultation. This includes proposals for legally binding long-term targets to directly address nutrient pollution in the water environment from agriculture and wastewater:
reduce nitrogen, phosphorus and sediment contribution from agriculture in the water environment by at least 40% by 2037 (against a 2018 baseline)
reduce phosphorus loadings from treated wastewater by 80% by 2037 (against a 2020 baseline)
To meet these goals, the government is committed to taking action to reduce nutrient pollution.
The River Avon
The River Avon Nutrient Management Plan for phosphorus has been produced to help reduce and manage phosphorus levels in the Hampshire Avon Special Area of Conservation (SAC), in accordance with international obligations, principally in the EU Habitats, Wild Birds and Water Framework Directives. It will also aid development and change, in the Hampshire Avon catchment by ensuring the amount of phosphorus in the river does not increase and conflict, with the conservation objectives for the SAC.
The Nutrient Management Plan has 2 primary objectives and several sub-objectives:
To achieve compliance with the requirements of the Habitats Directive, in particular:
To establish conservation measures to avoid deterioration within the River Avon SAC.
To achieve the ambitious reduction targets and in the longer term to support the
achievement of Favourable Conservation Status.
To facilitate development without affecting the integrity of the River Avon SAC.
To achieve compliance with the Water Framework Directive through the delivery of the ‘protected area’ standards
This NMP is concerned primarily with managing levels of phosphorus (a chemical within the river which is a nutrient causing a form of pollution and posing the most significant threat to the site’s qualifying features). The effects of nitrogen and other pollutants are addressed in the Diffuse Water Pollution Plan (published in 2015) for the Avon catchment.
The NMP is made up of the plan and 4 supporting Annexes. The main NMP and Annex 1 are aimed primarily at those involved with implementing the plan and key decision makers affected by it; it sets out why the NMP is required and how it will inform and influence decision-making.
Annexes 2 and 3 are currently being drafted and are Supplementary Planning Document and Evidence and Monitoring Plan, respectively.
Annexe 4 provides the key technical evidence and supporting information supporting key recommendations put forward in the plan.
RIVER AVON SPECIAL AREA OF CONSERVATION NUTRIENT MANAGEMENT PLAN FOR PHOSPHORUS
Phosphorus in the Hampshire Avon Special Area of Conservation Technical Report Final
PO4 Ltd
Is a joint venture collaboration between Pennyfarthing Homes Limited, a 40-year-old multi homes developer, building quality houses in Hampshire, Dorset and Wiltshire and a local estate, The Bickton Estate which has been in the same family since 1750. We are the first company to obtain an s106 planning agreement for offsetting Phosphates in the UK within a river catchment area. Our credits are available for use in The River Avon catchment from just north of Fordingbridge to the sea at Christchurch.
We achieved this by removing in perpetuity a significant agricultural venture that was responsible for adding 100’s kilograms of phosphates into the river Avon, working with Natural England, The Environment Agency and The New Forest District Council (NFDC) we closed the farm and obtained an s106 with NFDC, which in its own right is a competent body.
Our Phosphates credits will allow the continuation of development in the NFDC, East Dorset, and BCP Council planning areas, allowing housing allocated in the local plan to be realised.
Natural England remarked that this is a gold standard Nutrient Neutrality scheme equivalent to the removal of a medium-sized wastewater treatment plant.
The farm will be rewilded over the next few years and returned to nature for future generations to enjoy.