EDP: Environmental Delivery Plan, or Environmental Destruction Plan?

The government is due to launch the first of their Environmental Destruction Plans (EDPs) in November this year, but what will they involve?

MHCLG has given Natural England a mandate to solve a problem that has already been solved in a catchment that has one of the best functioning nutrient markets in the country (Norfolk). With this lofty goal in mind, how are they looking to ensure the first Environmental Delivery Plan (EDP) does the "Delivery" bit?

Removing the Obligation to Actually Deliver

The current market ensures that, on a 1:1 basis, mitigation tackles additional nutrient loads from sewage that will impact rivers and wetlands already impacted by historic underinvestment in sewage infrastructure and poor regulation of agriculture. Signals are now suggesting the government intends to remove this link and just do 'some nice nature stuff that should probably help'. This nice stuff will apparently be able to meet the EDP's "Overall Improvement Test". By doing this, they cleverly avoid creating any obligations that they can be held to account on. I believe they are currently tendering (at taxpayers' expense) to define a suite of measures that 'could probably help' but they will stop short of requiring these measures to actually quantify the level of mitigation. The existing measures which have to quantify mitigation delivered to show this 1:1 offset will probably fall by the wayside if the end goal is to ensure no quantifiable benefit can be evidenced.

Pricing Mitigation to Fail

Ensure that the pricing charged to developers is slightly under the cost of actually securing sufficient mitigation/"doing nice stuff". If the price charged to developers already makes delivering Conservation Measures marginal, what about the inevitable cost for admin, legal fees, tech, bureaucratic bloat.

Making the Taxpayer Fund the Gap

Where the market funds the cost of mitigating now (and schemes are delivered before the mitigation is needed, i.e., it actually mitigates impact), Defra has admitted in emails (seen via FOI) that EDPs will not get sufficient developer funds to deliver the Conservation Measures ahead of when they are required, so taxpayer money will be needed to fund initial delivery. And then it is recognised that cost recovery may not actually pay back all the taxpayer money that is put in. So, MHCLG/Defra/Natural England are looking to go from a system that currently costs the taxpayer nothing to mitigate impacts on rivers from sewage pollution prior to it occurring to system that allows impacts to occur and maybe go uncompensated for while costing the taxpayer money.

EDP = Environmental Delivery Plan or Environmental Destruction Plan?

The uncertainty emanating from EDPs has put at least seven nature restoration schemes being put 'on ice'. These would have been funded by the existing Norfolk nutrient mitigation market, with clear, quantified amounts of mitigation removed. These schemes would also have increased competition and help to contribute to already declining cost of nutrient mitigation to developers.

Note: this is purely conjecture, and no sane politician would try and push through such ill-conceived measures that cost the taxpayer more, destroy nature and kneecap one of only three natural capital markets at the point when it is finally functioning despite all the headwinds from previous ineffective attempts to kill it off. Would they???