EPISODE: 010 - NUTRIENT NEUTRALITY
- Piotr Bytnar BEng (Hons) MSc CEng MIStructE
- Nov 5, 2024
- 19 min read
Updated: Jun 18
BYTNAR - TALKS
EPISODE 010 - NUTRIENT NEUTRALITY
This episode is for people who want to know more about Nutrient Neutrality.
If you ask yourself questions:
What is Nutrient Neutrality?
Why should we care about Nutrient Neutrality?
What does being in the Nutrient Neutrality zone mean to my project?
How to assess projects for Nutrient Neutrality?
This episode should give you a broad idea of who, how, where and what of the Nutrient Neutrality.
This is Bytnar Talks: The Engineer Takes on Construction, Episode 10.
Hi, I'm Piotr Bytnar. Each day, I help my clients plan and design building projects through Bytnar Limited, a consulting Chartered Structural Engineers practice. My biggest passion, and the cornerstone on which I've built my business, is finding clever solutions for construction projects. I am a Chartered Structural Engineer and a budding software developer, so you can rest assured that I will strive to talk about the best practices and the use of new technologies in the industry. If you're embarking on a construction project or are involved in planning, designing, and building the world around us, you'll find this podcast useful.
This episode is about the horrors of nutrient neutrality. [Music]
Hey, hi, hello everybody! How are you? I bet you've noticed a little slip on the release calendar. Sorry about that! I could have likely accustomed you by now to the issue of a new episode every Monday morning, but it is Thursday now — so what the hell, brother? You would ask. I therefore rush with an explanation. The podcast is a new endeavour of mine that I do in my spare time to inform you, dear listener, on all aspects of architecture, engineering, and construction you may not be all that familiar with, or would like to know more about.
I was initially inclined to give it a go at the end of every week, putting some time aside on Sundays, but the preparation, recording, editing, and issuing of the podcast in combination with my busy professional and private life, however, proved Sundays to be not the best of solutions for me. I've therefore spread the process across a few days to make it more manageable. I will soon make a dedicated web page for this podcast where you will be able to subscribe to stay informed when new episodes are released, and it will also give me the confidence that if Spotify ever chooses to dislike my podcast, it will still have a platform and remain intact.
I've just delivered nine episodes on the Plan of Work, telling you more or less how all steps of the project conception, definition, delivery, and use are considered from a professional perspective. Now we are off to Episode 10. Did I just say 10? It is amazing how time flies and how quickly the numbers grow. It was just the beginning of the year when I decided to come out to you with Bytnar Talks, and it is now almost Easter, and I can quietly celebrate the release of the 10th episode. Yeah, that was a popping of a bottle of wine — that I have later on when I finish recording this episode.
Thank you all for listening. I hope you will continue to find this podcast interesting for the next 90 episodes at least. The information I (hopefully you) find helpful, and my guidance useful. Now it will only take 10 times more to achieve my goal, while the target is for at least 100 episodes — so be patient, still plenty to go.
If you have burning topics you would like to hear about, do let me know in the comments below or message me on LinkedIn. I'm also always keen to hear other voices and other perspectives, so if you are a fellow professional and would like to talk about a topic that is close to your heart — I'm here for you. I want you involved.
Alright, let's get to the interesting part. So, without further ado, let's dive into the horrors of nutrient neutrality. [Music]
I know, I know — catchy little title, right? Horrors of nutrient neutrality. But hey — whose horrors is it? I think the building industry and property developers would like you to think it is theirs. Their horror — as they cannot build and release their profits. And by that, they will tell you it is your horror — because you cannot buy an affordable house. If only, right?
But truly, it is everyone's horror — not because it stops the creation of non-sustainable developments, but because it needs to be enacted as our environment is already in dire straits. If we want our rivers to resemble such likes of the Yamuna or Ganges, we may well do nothing. But taking our position — we should do everything in our power to avoid inputting more of this bad stuff into our ecosystem.
After all, we are an educated society — or at least that is what we want to tell ourselves.
So, let's look at the whole thing from the perspective of a person who would ordinarily make money on designing those buildings — but is glad that there are some powers in the legislation that allow sensible consideration of our most vulnerable sites.
It is important to acknowledge where the whole thing is coming from before judging whether it is right or wrong. I will tell you a bit about legislation and governmental ideas surrounding it and the aim of the approach. I will then move to how it is an issue — a.k.a. explain the world around us, from the poop to the gloop — finalising with the likely future solutions.
Alright then, let’s go get on to it. [Music]
As ever, all the harm in Britain is due to the EU ambitions and their legislation — it is often an argument against the legislation that it is yet another chain we need to drop after the departure from the European Union.
The whole beginning of the nutrient neutrality nightmare comes from the European Habitat and Birds Directive and is enacted within UK law in the form of the Conservation of Habitats and Species Regulations 2017 — the Habitats Regulations, otherwise. It is a legislation put in place to safeguard — underscore, no, maybe double-underscore and exclamation mark, and now slowly and in capital letters — VALUABLE HABITATS AND SPECIES.
Thanks to this law, we can identify and assign importance to some areas accordingly — creating SACs and SPAs — for the lovers of abbreviations, meaning Special Areas of Conservation and Special Protection Areas.
At the moment, there are around 31 habitat sites sparing 27 catchment areas and traversing a total of 74 out of 337 local planning authorities. Now, if the assigned area is in a dire place when it comes to the nutrients, it is assigned an "unfavourable" status, and the impact of new developments needs to be taken into consideration to ensure no more strain is added to the system. You know that phrase — "the straw that broke the camel's back" — applies here very well.
In 2018, the government published a 25-year Environment Plan which commits us to restore 75% of our 1 million hectares of terrestrial and freshwater protected sites to a favourable condition by 2042.
The plan concentrates on developing and working on:
Environmentally sustainable farming
Storm overflow discharge reduction plans (you know — those smelly little pesky things that the water companies do when we want to go out with our kids to play — very pesky here in Kent, frankly)
Planning requirements
New Strategic Water Resource Management Plans
Drought Plans
Changes to Ofwat policy (Ofwat stands for Water Services Regulation Authority)
Environment Act 2021
Environment Improvement Plan
So, who is impacted by this?
Any harmful projects proposed within the catchment area of the assigned habitat that is struggling — or, in the words of the legislature, in "unfavourable conditions" — that’s the place that is impacted, and that’s the place we need to look closer at.
The local planning authorities have been instructed, in line with the outcome of the Dutch Nitrogen Code ruling, to only approve projects if they will not have any adverse effects beyond reasonable scientific doubt.
What does it mean? Simples. Calculate the bloody thing. Calculate the bloody impact. No faffing about — just numbers, please.
Any potentially harmful developments that require planning permission, and also developments covered by permitted development rights, need to demonstrate that they will achieve nutrient neutrality in affected areas. This also applies to projects with outstanding reserved matters.
Which are potentially harmful developments? Well, these are the developments that bring more nutrients to the area. Many projects can be considered as such, but it is agriculture and sewage effluent that do most of the damage. Therefore, all of the developments concerned with increasing this activity — or the nutrients that flow from these activities — will be the ones we are concerned with here.
Since we cannot exactly say what is the amount of contribution of the above sources to the nutrient load in UK waters and to nutrient pollution, how can we judge which development is harmful and which is not?
To make things simpler, we concentrate on the most prevalent types of nutrients that cause harm. These are nitrates and phosphates.
The Environment Agency claims that agriculture is estimated to be the source of around 70% of nitrates in rivers, with sewage effluent the next most important at around 25–30%. It is old data, though, so think about it this way — it only says about the percentage of total impact. But what difference really does it make if there is more housing built in the catchment but less farm? The ratio will change, but the impact will remain.
The Environment Agency also said in past reports that the estimation of the source of phosphorus in rivers is in the area of 60 to 80% generated by sewage effluent 20 to 25% by agriculture. So you get the picture — albeit from the pre-financial crisis of early noughties data — that farms create most of the nitrates problems, and housing is mostly responsible for phosphate problems. And it's not housing per se — it's not the brick that's the problem — it's the poop that lands in the sewage treatment plant, which then discharges that back to the river.
I'm recording this podcast in Ashford, Kent, which is the borough with nearly half of its land being part of the Stour River catchment, which in turn impacts the fragile Stodmarsh wetlands. What is its impact on the development of the area? Well, according to the Local Government Association website information issued on the 9th of March 2023, around 90% of site allocations in the Local Plan — and currently around 5,800 dwellings in over 170 planning applications — have been affected. Quite a bit, isn't it?
Anyway, so why is that even an issue? We need a place to live and to grow and graze our food — and that is correct, isn't it? But, taken that we are a smart lot, we can do this without killing habitats around us, can't we?
Yes, the drive for money is great — especially where you can realise a lot of profit from your developments. But money is not enough to persuade any sensible human being to destroy the land and nature around them.
I've mentioned the two broad things we care about here — nitrates and phosphates. One mostly from agriculture, and the other from sewage. Why is this a problem? Well, both of these are considered nutrients for the growth of green stuff. When it reaches our waters and water reservoirs, it nourishes the plants within them. Nitrogen and phosphorus lead to things called eutrophication, which is a fancy way of basically saying "doping" of the system.
Indeed, the water reservoir is then doped with those nutrients, allowing for an increased growth of phytoplankton — well, otherwise algae — those little green guys and plants, which then lead to algal blooms. Algal blooms are a spray — as they spread over the surface of the water, they block the sun from reaching down below the surface. And if it doesn't reach the lower levels of the water, it cannot allow photosynthesis to happen. So, the plants do not create oxygen.
That's very, very important in the water environment. When all that green stuff dies — because it's been depleted of oxygen, or there's just so much of it that it eventually dies — it falls down to the bed of the reservoir. It gets to the point where it's decomposed by clever microorganisms — which, by the way, need oxygen too — leading ultimately to the demise of the ecosystem within that body of water.
You see, nothing can survive — no animals or plants — without oxygen in the water. So, you see — too much of a good thing can kill you, and too little of the good stuff (in this case, oxygen) can too. I like to call this process from poop to the gloop.
Wait a minute — but don't we have wastewater treatment plants? Sure, we do. But as the process stands now, we cannot remove all of the nutrients from the water — at least not in a sensible way.
Let's travel through the process, shall we?
You see, water condensates in the air and drops down on the ground. Some travels to the sea, some filters into the groundwater, and some stays in the reservoirs from which we draw it to use in our houses. When you flush that water, it meets with all the flushes of the area and ends up in the wastewater treatment plant, where it is simply filtered of non-human waste solids and grits gathered along the way. Then, human waste solids in the form of sludge leave water ready for the magic of bacterial action.
But before this happens, bacteria needs air — so the effluent is aerated. The bacteria does its job, dies, and in the form of a sludge, is taken away. The remaining treated water goes through the plains of sand, filtering some more before being disinfected and released back into the water stream. The pathogens are removed — but nutrients remain.
Now, the only sensible way to remove the nutrients from the effluent is to let plants use it — somewhere much earlier than the protected habitat.
When it comes to agriculture, the mechanism is simple. The farmer spreads the fertiliser, which travels through the ground with water downstream. So, the only way to go about this is to either remove the activity from the area and/or improve how it’s done.
In any case, we load nature with extra nutrients. And if these nutrients destroy habitats of importance — we should at least not add to the burden.
Obviously, such an approach has consequences. So, for this reason, the legislation gives us a way forward in the body of nutrient neutrality.
Nutrient neutrality is just an interim situation, where we need to prove the proposed development will have no impact on the amount of nutrient added to the system.
It's basically simple adding and subtracting — what was there before, what was going to be added, any offsetting taken away from it, and adding some factors like 20% on top just to make sure it's all correct. And off you go. If you can prove that that's within reason — that's nutrient neutral — then you’re good to go. Then your development is granted. But otherwise, you cannot — legally. And you shouldn't — socially.
Housing developments are generally good to go if nutrient neutral, meaning they can deal with their own sewage or offset the impact otherwise. But within the catchment area, it is all about the balance of the local ecosystem and the amount of water circulating through it.
It would be easy to say — which is quite popular lately — "Let’s fly the sewage to Rwanda." But for one, it would cost an unreasonable amount of money. And for second, it would not improve the existing system. Not to mention that removing water from the local ecosystem may lead to droughts.
So, I leave you with the situation on the Rwanda front and your own opinion about that — but yeah, it doesn’t make sense. We need to deal with the problems where they are. Solve the problems. Find the solutions. And yeah, improve on that — rather than trying to push it somewhere else.
The current approach to nutrient neutrality sets itself on three pillars. These are: mitigation, reduction, and guidance.
So what's within the mitigation aspects of it?
Nutrient mitigation schemes can be used — which basically means buying nutrient credits. Someone else does the mitigation, and then sells you credits for it that you can use.
Local and private mitigation schemes — like local reed treatment units, reed beds, or wetlands. This sort of thing reduces pollution and the mitigation burden on new housing.
Water companies are required to improve to achieve the highest technological levels of nutrient removal by 1st April 2030 where the outflow is within an area that's unfavourable.
Water companies can use wetlands and reed beds in combination with conventional techniques — such as adding metal salts to wastewater — to remove more nutrients. But yeah, it’s much more ecological and sustainable to let nature do its thing than using metal salts.
Then, the government concentrates on providing certainty through more likely guidance:
Guidance for catchment-specific nutrient calculation to assess the size of mitigation required.
The government will publish tools for assisting in the design of wetlands for nutrient mitigation.
Publish guidance for mitigation providers on how environmental payments from biodiversity net gain and nutrient mitigation can be combined.
Provide advice about nutrient neutrality and support in assessing the suitability of mitigation projects through increased capacity in Natural England.
Natural England itself is developing a framework for assessing the effectiveness of different types of mitigation and an associated reference tool.
So, there are many things going on around it — but the point is, nutrient neutrality is a door, a side door if you like, to push through with your proposal in a fragile environment to allow you to build. But yes, it’s quite onerous to actually be able to — because there’s not much to choose from for actual improvement. Not many sensible things can be done to actually address this issue.
There are some ideas for change — like maybe transferring some of the wastewater. But that would impact other places, albeit not as fragile as the one we’re talking about here. But water depletion is another quite important thing to consider you know — the ecosystem uses the water. And we need to work within that ecosystem. Otherwise, we'll be taking water from one place, putting it into another — and droughts, especially here down in the southeast of England, are quite prevalent and, yeah, quite a bit of a problem. So, we're not very keen on removing that water from the ecosystem.
Some of the ideas on how to deal with this issue include pocket treatment works — like localized treatment centres or localized treatment plants — plus wetlands. But there are no guarantees of long-term, proper operation of such systems. When you do a development, and that won’t be under the remit of the local government, what is the guarantee that it will actually work for a long time? And we need to think long-term here — 100 to 120 years, at least.
There is an idea of doing NAVs — obviously, we love our abbreviations — so, New Appointments and Variations to the existing providers of services like Thames Water, Southern Water, and whatever other water companies. But these projects are difficult to fund.
It would be great if we could have a fund that actually sees sustainable growth and operation of such places as a sustainable way of generating revenue. But unfortunately, the financial market — well, it's a game of numbers. It's not a real game. We're just bystanders that observe what’s going on with that money as it goes in front of our eyes.
So, the financial market — they want quick returns. And having big projects running infrastructure? That’s not the priority. Even if we do get private money invested in these sorts of projects, most likely that money would be removed. The money would be juggled. It would be exchanged between different funds, different trusts — concentrating on returns rather than on improving the actual infrastructure and the productivity of it.
So yeah, variations and additions to our existing water companies would be great. But we need to do it with our heads on our shoulders. And most of what happens in the financial markets does not happen that way.
Another possibility is agricultural offsetting — which means taking land out of use, buying a farm, and getting rid of it. But that only addresses the nitrate issue. And when it comes to property development, most of what we’re concerned with is phosphorus rather than nitrate. Still, that’s one part of the whole equation, and it can be added to or subtracted from the actual load.
Creation of wetlands — reed wetlands, reed beds — those parts that treat the water that leaves either local or general wastewater treatment works, or routing some of the river flow through these... Well, that helps. But we must be careful in designing them so that they don’t divert water away from downstream ecosystems.
We obviously need to improve housing water efficiency. But saying that — with increased water efficiency — the amount of effluent that leaves is less, but the efficacy of it remains more or less the same.
Truth be told, we certainly need all of the stuff I just mentioned. But in reality, improving wastewater treatment works on mass and allowing excess nutrients to be digested in wetlands and reed beds is the only long-term viable solution. For this to happen, we need to wait for funding cycles to kick in and time to realise those changes. Or perhaps set up a fund that will invest sustainably to create infrastructure that is run better than it has been — and charge new development and local councils for the use.
There are some other approaches as well. Not as far back as last year, there was an attempt by the housing development lobby to get rid of nutrient neutrality. But common sense prevailed. Funny — for the amount of money in circulation from these people — how stupid their argumentation was. It seemed they thought the creation of the actual buildings was what caused the damage, not the people using their toilets later on. They argued that only about 5% of the impact — don't hang me if I'm wrong — was due to the creation of housing developments.
You see, without legislative action, the financial system will continue to prioritise profit over environmental and societal well-being — leading to detrimental consequences for both nature and future generations.
Let’s think about it for a moment. The current paradigm is constant growth, no matter what. And with it comes profit maximisation. The financial system, particularly in capitalist economies like ours, often operates under the principle of maximising profits. This drive usually leads to practices that prioritise short-term gains over long-term sustainability. Not exactly inventing the wheel here, am I?
But with that come some costs that are external to what the money is actually doing — they're called externalities. That poor pursuit of profit without regard for the environment or social impacts results in negative externalities. Here, we talk about nutrient neutrality, but the same applies to housing prices, and much more.
In economics, externalities are costs or benefits that affect parties who did not choose to incur them. In the case of the financial system, these externalities often manifest as environmental degradation, climate change, social inequality, and other forms of harm to communities and ecosystems. It seems like every day in the news, we hear reports on the damage caused by the externalities of our financial system.
On the other hand, we have regulatory failure. Seeing all that money and all those finances, the only way to influence that money to do the right thing at the right time is through regulations. As much as I like growth — and just got that capitalist spark in me — regulations are needed in these circumstances.
What money can do without regulation is pretty bleak. You see, without effective legislation and oversight, there are fewer constraints on the behaviour of financial institutions and corporations. Why would there be any? This lack of oversight leads to unchecked exploitation of resources and communities.
Here, nutrient neutrality — and the protective habitat legislation — are exactly that kind of control. That unchecked exploitation can go quite far, and it’s purely because the financial world prioritises short-term gains over long-term sustainability.
This leads us to systemic risk. Overlooking environmental and social considerations in financial decision-making contributes to systemic risk within the economy. We can keep growing, see the facade of growth — but in fact, it’s all artificially pumped, and we’re just heading toward a wall with increasing speed, face forward. And I think soon enough, our noses will send a message to our brains — "Hello, here’s the wall."
Everything is interconnected. You cannot remove one part from another. Although money and the financial system is a driving force in our society and economy — it’s all interconnected. The systems are interconnected. The financial system is intricately connected to ecological systems and social well-being. Environmental degradation can have far-reaching impacts on economies and societies.
So be aware. You can push it as far as you want and then deal with consequences. But maybe, we can think about them now — and avoid the bad ones.
Long-term sustainability is crucial here. Failing to address the environmental and social impacts of the financial system undermines the prospects for long-term sustainability and resilience. Sustainable development requires balancing economic, environmental, and social objectives to ensure the well-being of current and future generations — not just the wild race that currently transpires.
We are at a point where there is a need for urgent legislative actions to steer the financial system towards more sustainable and equitable practices. By implementing regulations that incentivise responsible behaviour and penalise harmful practices, governments can help mitigate the negative impacts of profit-driven finance and foster a more sustainable and resilient economy for the future.
So to sum up, really — I’ll be quite quick here:
The sources of excess nutrients are site-specific, but mainly come from wastewater treatment works and agricultural pollution. When you develop in the catchment areas of fragile environments, you need to think about the impact of your proposal. More people staying overnight means more sewage — means bigger impact.
If your proposal is permitted development but increases the number of people living in the area, you will still fall under the consideration of nutrient neutrality.
There are some schemes being made to help with offsetting some of the additional load — like the Wetland Mitigation Framework, which is a £30 million nutrient mitigation scheme. There is the mandate for water companies to upgrade wastewater treatment works. There are environmental improvement plans.
But I think it’s most apparent to say that if the country won’t use the stick in the form of legislation, we will soon be swamped by the effluent of our financial system — which turns money for the sake of profit, with no regard for nature or the future.
We will always seem to be like those algae — we like the nutrients, we have more, we grow — then we die, and kill the lake with us.
So, that would sum it up. Let’s go to a few more words from me, shall we?
There are plenty of aspects to consider when it comes to sustainability and the environment — especially when it comes to the biggest influencer of them all: big money.
What I mean by that is our financial market. The only way to directly influence this money is through legislation. And I think it’s good to put as many obstacles in the way as possible. Perhaps, if the investments become difficult, they will start investing in making the world a better place for starters. Finding and researching solutions to our problems — rather than just using all there is for profit.
Money is just a number in your ledger. A healthy ecosystem is the most expensive asset we have. After all, you cannot buy it. You can only keep it in balance — and hope nature will do the rest.
As much as I’d love to be running around site in my hi-vis jacket and hard hat, cashing in for the design and advice, I’d rather consult on sites that are more sustainable.
At Bytnar, we think in terms of SQuEN principles — Sustainability, Quality, Improvement, and Need. Any given project needs at least three of these qualities to be considered worthwhile in our office.
I’ll leave you with that. Keep high standards — and carry on making the world a better place.
Thank you again for listening. Please voice your opinions — I’m waiting for you on LinkedIn and I want to hear from you.
Toodloo!
Piotr Bytnar BEng (Hons) MSc CEng MIStructE
Chartered Structural Engineer who deals with the Architecture of buildings. His Master's Studies led him to an in-depth understanding of risk and contract arrangements in construction as well as specialist knowledge in soil mechanics.
He and his team help homeowners and property developers to design and deliver construction projects reducing waste in time and the cost. He believes that the construction project is an iterative process that can be well managed and it is best managed if all the aspects of the project definition and management are dealt with in-house or coordinated by one organisation. His team works to all stages of RIBA and ISTRUCTE stages of work and enables contractors to deliver projects on-site providing risk evaluations, methodologies for execution of works and temporary works designs.
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