Unblocking stalled social housing sites in Wales through support on phosphates and nutrient neutrality

Local Partnerships supported the Welsh Government in a programme to address phosphate-related challenges that were stalling social housing developments across Wales.

By working closely with Natural Resources Wales, Welsh Water, developers, and planning authorities, we tackled site specific issues that threatened to delay new housing projects. As a result, from an initial list of 68 sites, 902 homes, 799 affordable and 103 private, on 37 sites are now able to move forward, subject to standard planning processes. This effort plays a critical role in meeting housing needs while managing environmental impacts.

The challenge:

When phosphorus enters water bodies it triggers boosted algae growth, which consumes the oxygen within the water eventually killing off the biodiversity. Following the landmark Dutch Nitrogen Case in 2018 there has been a reassessment of how EU pollution-related legislation is interpreted with regards to nitrogen and phosphorus emissions. The case ruled that where important sites, such as Special Areas of Conservation (SAC) fail to achieve the required condition due to nutrient pollution, the potential for a new development to add to the nutrient load is “necessarily limited”.

Natural Resources Wales compared phosphorus levels surveyed in the SAC rivers against the new tighter targets. Over 60% are failing against the targets set. NRW has issued guidance and principles of nutrient neutrality.

However, when considering new housebuilding data, housing need estimates and homelessness management information it is clear that Wales needs to increase new housing development to meet housing need, alongside a collection of actions to ensure that every available existing home is used where possible. The Welsh Government’s programme for government includes a commitment to deliver 20,000 social homes for rent between 2021-2026.

River summits were held in Summer 2022 and March 2023 and an action plan to relieve pressures on SAC river catchments to support delivery of affordable housing was agreed by the wide range of sectors in attendance.  As part of the action plan two case study workshops were held, these identified the need for further work, for which Welsh Government commissioned Local Partnerships.

The solution:

Local Partnerships were commissioned to undertake a project, focussing on 68 sites which had been identified by Welsh Government as being stalled or at risk of being stalled due to phosphates issues. These 68 sites included capacity for 2229 homes (1570 affordable and 663 open market).

The work which was led by Local Partnerships included:

• an analysis of the following for each Waste Water Treatment Works in a Riverine SAC impacted by phosphates, including timescales for:
  • NRW’s review of permits;
  • Welsh Water’s sampling programme;
  • Welsh Water investment programmes and planned improvement works

• Mapping these against affordable housing sites held up due to phosphates (58 sites are currently identified).

• Using this information to identify affordable housing led schemes that fall outside of these works/improvements (or where timescales present the biggest challenge to delivery, particularly for this term of government) and undertaking targeted ‘deep dive case studies’ for agreed sites to explore potential opportunities to unlock these developments and develop a site level action plan.

• Communication to the sector: Regular communication with registered social landlords and local authorities (planning and housing) to support and improve understanding and aid appropriate planning and prioritisation.

Lessons learned:

The importance of bringing partners together. This was a complex project, involving developers (private and public), Welsh Government, NRW, Welsh Water, planning authorities, and local authorities – from both a planning and housing perspective. However, by talking to these stakeholders, at first individually, and then, where deep dives were necessary, in the round, it was possible to resolve most sites which had appeared to have been stalled.

The interest in these issues from the wider public sector family.

The impact:

We supported Welsh Government with a programme aimed to unblock social housing sites across Wales which were at risk of stalling owing to issues around phosphates in rivers arising from new development. Through close liaison with Welsh Government, Natural Resources Wales, Welsh Water, developers and planning authorities, we worked to identify and address issues on a site-by-site basis. From an original list of 68 sites, 902 homes on 37 sites across Wales are now able to proceed (subject to normal planning and development processes). This is made up of 799 affordable homes, and 103 private homes.

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