The Environmental Policy Forum (EPF) has written to the Secretaries of State at Defra and DLUCH expressing concern over proposed legal changes to how ‘nutrient neutrality’ requirements for development projects work in England. In this short blog Ben Goodwin, IEMA’s Director of Policy and Public Affairs, discusses the nature of the concerns that have been put to government.

As set out last week, we believe that amendments tabled to the Levelling-up and Regeneration Bill, which would remove the requirement for many development projects to deliver ‘nutrient neutrality’ in currently protected areas, will lead to the pollution of rivers and streams across England.

The EPF letter focuses on three key reasons as to why the proposed amendments are inappropriate.

  • A regression in law: The proposed amendments threaten objectives for water quality and the condition of protected wildlife sites, which amount to a regression in law. It’s vital to note that this regression in law comes at a time of a decline in nature and a water quality crisis. As required by the Environment Act, this regression in law would require an admission that the Levelling up and Regeneration Bill would reduce the level of environmental protection provided for by any existing environmental law. That it is not an amendment to the Environment Act seems irrelevant in terms of practical outcomes.
  • Incoherent policy undermining delivery: The proposed amendments reflect incoherent policy, as they undermine the delivery of various welcome government commitments and announcements. For example, the long-term environmental targets set down by the Environment Act 2021, the Environmental Policy Principles Statement, and the UK’s commitment to the Kunming-Montreal Global Biodiversity Framework, to protect at least 30 percent of our land and sea for nature by 2030.
  • An urgent need to consult the experts: The proposed amendments have been tabled despite insufficient consultation with the experts – those with the knowledge and experience of delivering the current nutrient neutrality requirements. This lack of consultation is reflected in the clear opposition of the Office for Environmental Protection, the independent body the government established to hold it to account.

The Levelling-up and Regeneration Bill is currently at its report stage in the House of Lords and will go back to the House of Commons for further consideration in due course. During the remaining stages of the Bill’s passage through Parliament, IEMA will continue to vocalise our opposition to proposals and amendments that will be regressive for the natural environment.

The EPF is a by-invitation-only membership group established to provide the opportunity for collaboration, learning, dialogue, and debate amongst professionals across the environmental disciplines. The forum is currently constituted of 13 member bodies, including IEMA.

The forum works together to influence environmental policy and its formulation by ensuring that environmental sustainability is high on policy agendas. Through regular meetings, workshops, and electronic media, the forum leads on the production of policy papers in order to influence environmental policy and its formulation.

Photo of Ben goodwin
Ben Goodwin

Director of Policy and Public Affairs, IEMA, IEMA

Ben is Director of Policy and Public Affairs at IEMA. In this capacity he looks after the delivery of IEMAs core policy, practice and public affairs activities across a range of environmental and sustainability issues. Prior to joining the organisation Ben worked in several similar policy roles at organisations including the Institution of Civil Engineers and the Renewable Energy Association.


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