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Our response to Natural England’s draft Environmental Delivery Plan for Norfolk

Natural England’s consultation on the draft Environmental Delivery Plan for Norfolk closes at 9.29am on Tuesday 27 October 2026. We have a number of concerns about the EDP in its current form, and we are putting those to Natural England in our response.

 

The Environmental Delivery Plan for Norfolk has changed fundamentally since January

The January prototype set out evidenced mitigation, priced against the nutrient load each development creates. Nutrient load in, nutrient load out.

The September draft sets out compensation measures intended to counter nutrient pollution, funded by a flat charge across a maximum of 15,780 dwellings. The amount is not underpinned by nutrient balance calculations.

Several specific changes sit behind that. The charging basis has moved from nutrient impact multiplied by mitigation cost to a predetermined package divided across 15,780 dwellings. The 15 per cent improvement uplift that was explicit in January has disappeared. Septic tank upgrades have moved from a principal conservation measure to a new development control condition applying to off mains systems only. The wastewater assumptions have moved from hybrid pre and post 2030 permit limits to post 2030 only. The underlying model has moved from nutrient load in, nutrient load out to a broader ecological package.

 

No longer treating pollution at source

Nutrient pollution has to be cut at source if these rivers are to recover. That matters most in the headwaters and smaller tributaries, where the habitat measures in this plan sit well downstream of where the pollution enters.

Upgrading failing off mains systems is one of the few measures that stops pollution at the source. The September EDP draft rates it as effective, then leaves it out of the conservation programme.

 

Our main concern

The EDP appears to have moved a long way from a transparent model of nutrient load in, nutrient load out. There are serious questions around whether the current design is sufficiently targeted, proportionate and focused on the nutrient pollution it was established to address.

 

Continuing the conversation

Earlier this month we sat down with Natural England to discuss the draft, joined by the National Trust, the NFU, RSPB, the Broads Authority, Norfolk Rivers Trust, Norfolk Environmental Credits, Norfolk Wildlife Trust, and Broadland and South Norfolk councils.

It was a welcome chance to engage directly with Natural England, work through a number of questions, and hear views from across the spectrum of interested parties. We are very grateful to our partners for their support in compiling our response.

We hope these conversations and the consultation responses submitted are reviewed with an open mind, and that the EDP is amended accordingly. We look forward to continuing this engagement over the coming weeks.

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