At the beginning of August, Chichester District Council announced that an agreement had been made with the owner of Chilgrove Farm, a few miles North of Chichester Harbour, to provide nutrient ‘offsets’ on areas of its farmland via the sale of nitrate credits.
These credits, the council claims, will offset the nitrates released in the wastewater from proposed new housing developments within the catchment of the harbour, allowing the new developments to meet nutrient neutrality requirements which are currently holding them up in the planning system.
The land offered up for offsets will be taken out of agricultural production and planted with trees, so reducing the agricultural runoff into the River Lavant and providing, the council estimates, nitrate mitigation for around 688 houses.
Chichester Harbour is a large harbour formed by the conjunction of several river mouths in West Sussex, at the eastern end of the Solent. It is covered by a range of national and international conservation designations, including an Area of Outstanding Natural Beauty (AONB), a Ramsar Site, a Site of Special Scientific Interest (SSSI), a Special Area of Conservation (SAC), a Special Protection Area (SPA) and a Local Nature Reserve, among others.
Despite all this, much of the harbour habitat has been classed as being in an unfavourable and declining condition so it is important, in order to avoid further polluting the coastal ecosystems, that new developments in the catchment are at least nutrient neutral.
Nutrient offsetting schemes too good to be true?
Nutrient offsetting schemes are becoming an increasingly popular way to meet these requirements, and work on a similar basis to more familiar carbon offsets. A property developer buys credits from an offsetting scheme to compensate for the pollution they incur. If this sounds slightly suspect, it’s because it probably is.
We’ve seen recently that the much of the carbon credit market was a bubble inflated by hot air and fraud, with corporations buying offsets in meaningless schemes that do nothing to mitigate emissions and sometimes involve human rights abuses and neocolonial land grabbing, while using such schemes to brag about how green they are.
Nutrient offsetting schemes, unless subject to strict public regulation, face a similar risk of abuse. They also seem like a moral corruption of environmental sustainability; much like the sale of indulgences in the late Medieval Catholic Church, companies don’t necessarily need to ensure that their own practices are environmentally benign but can merely open their chequebooks and buy absolution. The specific case of the Chilgrove Farm scheme certainly leaves a range of unanswered questions.
Why isn’t farmland subject to nutrient neutrality requirements?
Firstly, if new property developments affecting sensitive conservation sites must be subject to nutrient neutrality regulations, why shouldn’t farmland? Farming is typically the largest single sector responsible for serious water pollution incidents, above even the water industry. Indeed, in other parts of the world it is farmland rather than housing that is the priority target for nutrient mitigation strategies.
It therefore looks like a rather absurd double standard that farms draining into Chichester Harbour are allowed to sell nutrient credits to nearby housing developments, but aren’t subject to nutrient neutrality requirements themselves.
Precisely because of this double standard, it seems likely that this kind of nutrient neutrality scheme will do nothing to actually reduce the pollution of Chichester Harbour, but will merely shift some of the pollution from one source (farmland) to another (new housing), while the authorities pat themselves on the back and the harbour remains in the same unfavourable condition.
It’s even possible that such a scheme could make the pollution in the catchment worse. Prices for nitrate credits are usually determined by obscure accounting hocus-pocus incorporating the cost of delivering the mitigation plus administrative and monitoring costs, per kilogram of nitrates mitigated. While it remains unclear what prices will be set for the Chilgrove Farm scheme, a nearby scheme run by Eastleigh Borough Council is selling nitrogen credits for £3,000 each on farmland that it manages itself.
If a farm could make more money from the sale of these credits than it currently does from payments for Catchment Sensitive Farming, then it could result in the farm intensifying production on its remaining agricultural land by increasing inputs. This could easily lead to a net increase in pollution, given that the farm itself has no nutrient neutrality obligations.
Better solutions for preventing catchment pollution
It therefore seems that this scheme will at best prevent further pollution rather than actually improving the state of the harbour, and it’s questionable whether it will even succeed on its own terms. While this may often be the only way that developers can feasibly mitigate the additional pollution that a development incurs, nutrient offsetting alone is environmentally inadequate. There are other ways in which nutrient pollution could genuinely be reduced in sensitive catchments like Chichester Harbour.
This could include, where possible, requirements for onsite green space and even wetland areas buffering new housing developments in protected areas, to act as a natural filtration system. There also needs to be greater Environment Agency enforcement of the Farming Rules for Water, while making these rules stricter within protected areas.
The elephant in the room when it comes to tackling pollution of our rivers and coasts is of course the negligence of private water companies, which for decades have failed to invest in maintaining and updating infrastructure while shareholders have gorged themselves on bill payers’ money. Taking water companies back into public ownership and reinvesting profits rather than handing them to shareholders would help to reduce this pollution across the country.
Failing any of the above, and despite the pressing need for more housing, it may be arguable that developments simply shouldn’t go ahead if they will harm ecologically sensitive and protected sites like Chichester Harbour. Time will tell whether this scheme works as advertised, but it seems clear that nutrient offsetting schemes like this provide fertile ground for greenwashing by developers.
Those concerned about genuinely reducing pollution shouldn’t be distracted by the fanfare.
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