Environmental Delivery Plans (EDPs) are a new proposed scheme by the government to help developers “tackle” pollution when building new homes. Under the EDPs, developers effectively pay money into a Natural England kitty, which can then fund environmental protection projects.
The government calls the plans, drafted by Natural England under the Nature Restoration Fund, a “win-win approach to housebuilding and nature restoration”, which can deliver healthier wetlands and waterways alongside new housing developments.
But WildFish is concerned that the EDP scheme sets up a worrying pay-to-pollute system, one where developers can simply pay a fee to push through or speed up their development plans. The scheme will result in current environmental protections being lifted, such as developments around rivers where nutrients are a problem, after cash is paid by developers.
The government has now announced its first draft EDP under the scheme, a Nature Restoration Fund that is set to help deliver up to 15,780 new homes in Norfolk.
WildFish has reviewed the proposed Norfolk EDP and found it to be even more disappointing than anticipated.
Dr. Justin Neal, Head of Legal at WildFish, said:
“Norfolk’s chalk streams and wetlands are protected for a good reason. The Yare and Wensum, for instance, hold white clawed crayfish and lamprey. They shouldn’t be sacrificed on the altar of growth.
The EDP works on the basis that a positive outcome for these rivers and wetlands can be achieved by improving a separate issue for the river such as connectivity, wetland restoration and deer management. Whilst any improvements on the health of the rivers is a good thing, putting more sewage in a river and “compensating” through a levy is absurd.
The EDP follows a fallacy of equivalence, where it gives with one hand and takes with the other. There is a complete underestimate of sewage pollution from the thousands of new homes. The calculation only seems to consider treated sewage – not the expected untreated discharges from overwhelmed and underinvested sewage works. Additionally, the EDP happily assumes that the pressures on water demand for new homes can be dealt with elsewhere.
And to add to the sheer recklessness of the plan, the EDP effectively says that there should be no conditioning by local planning authorities to ensure that houses aren’t built or occupied until there are upgrades to sewer systems to cope with the uptick in sewage.”
The proposed Norfolk EDP is now in a consultation period, in which Natural England is inviting responses to help shape the final version. WildFish’s objection highlights the risks posed to rivers and waterways and is viewable here.
Our disappointment with this Norfolk EDP only confirms our initial concerns which Natural England have done little to address.
Earlier this year, prior to the launch of this first EDP, we asked for clarity from Natural England about issues we identified regarding the broader EDP scheme. In particular, we asked about the impact on the cross-border river Lugg and the Itchen chalk stream; the regulator was unable to answer questions about their feasibility and the removal of safeguards. Instead, it directed WildFish to its complaints process. Natural England’s further response when it came was disappointing – full of warm reassurances.
Our questions about the feasibility of the scheme highlighted the regional tensions in the proposed plan. While the levy will apply for sites in England, there will be sites including rivers that cross over into Wales, where the full weight of conservation law still applies, which raises the question as to how or why Wales would accept Natural England’s plans.
The EDP system simply turns a blind eye to half the problem of pressures from new homes and has little so far to show in way of effective solutions.
The public is being asked for their views about the draft Norfolk Environmental Delivery Plan. Follow the link below to contact Natural England and tell them that we don’t want “pay to pollute” schemes. Use our letter template to share your personalised response in less than 30 seconds.
Contact Natural England
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