Unlocking England’s Economic Recovery: The Unintended Costs of Natural England’s Nutrient Neutrality Advice


Unlocking England’s Economic Recovery

The Unintended Costs of Natural England’s Nutrient Neutrality Advice

10 Mar 2022
Natural England’s decision to introduce advice on achieving nitrate and phosphate neutrality is significantly impacting developments across the country. The guidance stems from a European Court of Justice judgment on the “Dutch N” case in November 2018, which set new environmental standards for developers to protect sensitive habitats within EU Member States.
The guidance has meant that thousands of planning applications for residential developments are currently ‘on hold’ in some 31 local authorities – with no realistic route to permission. Many of the temporary mitigation measures put in place by several innovative local authorities are not working effectively. This is disrupting the development pipeline of housebuilders across the country, from SMEs to large corporates. This is impacting the supply of housing, including vital affordable housing, and has a knock-on effect on businesses throughout the supply chain. Many local authorities will fail their five-year housing land supply across many local authorities.
In this context, Lichfields has been commissioned by the Nitrates and Phosphates Strategy Group (NPSG)– a consortium of house builders and others with interests in the development industry (see Annex 1) – to assess the potential scale of the economic impacts of Natural England’s guidance. NPSG, and many more like this group, comprise significant parts of local economies, and view this guidance as stunting economic growth during a fragile period of recovery in the wake of the pandemic. The NPSG is currently working with stakeholders on a new policy approach that will better protect the natural environment while unlocking housing delivery.
This study considers a range of economic benefits that house building generates, and will be potentially lost or delayed due to this current constraint to housing delivery. The primary sources used in this study are based on a review of planning data and published monitoring records from each local authority within the affected catchment areas, including local plans, neighbourhood plans, brownfield registers, technical housing need and supply evidence, fiveyear land supply statements, planning application registers and monitoring reports.