Environmental Delivery Plans: what they mean for the nutrient mitigation market
The government’s first Environmental Delivery Plan (EDP) is out for consultation and has drawn significant criticism from across the natural capital sector. EFG is among those raising serious concerns about its potential impact on the private nutrient mitigation market.
What is an Environmental Delivery Plan?
EDPs were introduced under the Planning and Infrastructure Act 2025 as an alternative route for developers to meet nutrient neutrality requirements. Rather than purchasing nutrient credits from landowners through the private market, developers can pay a levy into a Nature Restoration Fund, which Natural England will use to fund conservation measures at scale.
The first EDP covers the Norfolk Broads and proposes a levy of £2,675 per dwelling. Sixteen EDPs are planned in total.
Why EFG is concerned?
The private nutrient mitigation market, in which farmers and landowners create and sell nutrient credits to developers, currently prices mitigation at between £3,500 and £9,000 per home depending on the catchment. A government-backed alternative at £2,675 risks undercutting that market significantly, deterring the farmer-led projects that are already delivering genuine, targeted nutrient reduction on the ground.
As Digby Sowerby, EFG’s Managing Director, told Farmers Weekly: the structure and design of the EDP does exactly the opposite of what it sets out to achieve. Its ambition to deliver strategic nutrient mitigation is one EFG supports, but the top-down design risks a race to the bottom in terms of both price and environmental outcomes.
EFG is not alone in its concerns. Legal experts and ecological bodies have also questioned whether the proposed measures are sufficiently targeted to deliver real nutrient reductions, and whether the levy will generate enough funding to cover the cost of the conservation measures proposed.
EFG is actively monitoring the development of all sixteen planned EDPs and will continue to represent its members’ interests as the policy evolves.
Read more here: First EDP criticised for impact on nutrient mitigation market – Farmers Weekly