In our first briefing regarding the recent publication of the Government's Environmental Improvement Plan (EIP), the first formal update of the UK's 25-Year Environment Plan, we considered the first two goals (thriving plants and wildlife; and clean air), which aim to halt the decline in our natural world, and then improve it.
Here, we look at the next two goals in the EIP, relating to water and chemicals, and what changes we can expect to see:
Goal 3: Clean and plentiful water
Water is critical to human health, biodiversity, and relied upon by many businesses. Clean water is essential for all life; but it is a precious resource under threat from a number of sources, which threaten our natural world, as well as our economy. Many investments and projects are underway, but the EIP sets new stretching targets that will apply to water companies, industry and impact many other business, including developers.
The EIP notes that despite improvements to our water environment, we have reached a plateau due to increasing population, increased pollution risk, ageing infrastructure; and pressure on the UK's drainage system.
Nitrogen, phosphorus and sediment pollution from agriculture into the water environment are all targeted to be reduced by 40% by 2038 (against a 2018 baseline). An interim target of 10% reduction by 2028 has also been set (15% in areas with protected sites and where nutrient pollution is occurring).
Reduce demand and increase water efficiency
The EIP states that an additional 4,000 megalitres of water a day will be needed in England by 2050 to meet the future pressures on public water supply from increased population and drier conditions caused by climate change. That's hard to comprehend in itself, but the figure is put into context as water companies currently supply approximately 14,000 megalitres a day. Half will be delivered by reducing demand and half through increased supply.
A long-term target for water reduction in England (use of public water supply per head of population) has been set: 20% reduction by 2038 against a 2019/20 baseline; with interim target reductions of 9% by 31 March 2027; and 14% by 31 March 2032. The Government expects water reduction to be shared by households as well as business, which will likely mean increased expectation on housing developers to design more water-efficient homes, but will also require businesses to operate differently, abstracting less water and using different cooling technologies for example.
Abstraction licensing will also come under scrutiny: the Government estimates that it needs to reduce abstraction by 800 megalitres per day by 2027 and 1,400 megalitres daily by 2050. Reviewing abstraction licences and bringing activities into the scope of the permitting regime could result in some difficult issues for agriculture and industry generally.
A large part of the Government's strategy will rely on improving waste water infrastructure and water company performance. Most notably, the Government is requiring water companies to upgrade their wastewater treatment plants in priority catchments affected by high levels of nutrients. It is expected that this will speed up the grant of planning permission for thousands of new homes.
Last year, a Storm Overflows Discharge Reduction Plan was published, which is expected to require £56 billion of investment by 2050. In light of the sewage discharges to the sea, this is a policy that is expected to be closely examined.
To increase supply, water companies will need to investigate strategic options to move water around the UK (inter-regional water transfers) as well as storage (reservoirs). DEFRA will designate a National Policy Statement for Water Resources Infrastructure to assist in the approval of nationally strategic infrastructure projects.
What does this mean for businesses?
The EIP recognises that our need for water will increase dramatically on a national level, but that we must consume less, as individuals and as businesses. While much can be achieved by the water industry, reducing leaks and upgrading its infrastructure, many changes will need to be made by business.
In the same way our household appliances have energy ratings, they will likely soon have water ratings. Our homes will need to catch and recycle more water, as well as use less - those are challenges that the development industry will need to overcome through design. Similarly, agriculture and industry may currently rely on (generous) water abstraction rights that they will soon need to reduce, or else which will be brought into regulation. This will drive innovation as industry adapts and invests in new technologies that will reduce demand.
Goal 4: Managing exposure to chemicals and pesticides
The EIP explains that "chemicals and pesticides help us achieve many important goals, from securing cleaner water and plentiful food, to thriving industry, and more effective medicines". The dilemma is clear, however - the proper use of chemicals can be positive for humanity, but the misuse of chemicals can be extremely harmful to nature and risk our efforts to tackle climate change.
A new chemicals strategy
In the EIP, the Government pledges to publish a new Chemicals Strategy in 2023, which will set out its priorities for addressing risks from emerging chemicals of concern, such as PFAS (the 'forever chemicals') and also Endocrine Disrupting Chemicals (EDCs), which impact hormone function. In addition, the strategy will explain how Government will use regulation that is risk-based; and encourage the sustainable use of chemicals. It will also set the Government's plan to phase out the most harmful persistent pollutants.
A revised National Action Plan for the Sustainable Use of Pesticides will be published in 2023. The action plan will put integrated pest management (IPM) at its heart and establish a holistic approach to pest, weed and disease management. IPM aims to reduce reliance on chemical pesticides, for example by using crop rotation, low risk crop alternatives, and creating natural processes, such as those to help natural pest predators thrive.
The EIP recognises that chemicals and pesticides exposure is a transboundary issue. Accordingly, the Government wishes to use 'science diplomacy' and its expertise to influence global environmental policy-making.
What does this mean for businesses?
The EIP makes clear that the Government will continue to use UK REACH to evaluate and manage risks posed by chemicals, having left the EU and the European REACH Regulation. Many of the commitments in the 25-Year Environment Plan are unchanged and more detail is expected in relation to chemicals when the National Action Plan on Pesticides and the Chemicals Strategy are published.
The 25-Year Environment Plan committed to phase our persistent organic pollutants, and to reduce land-based emissions of mercury to air and water by 50% by 2030. Those commitments are unchanged. Clearly businesses who are heavy users of chemicals and agri-business using pesticides will wait for the detail of further policy this year.
For more insight into the goals of the EIP, read our first insight in this five-part bi-weekly series of briefings. Future articles will cover the other remaining goals within the EIP, comprising:
- maximise our resources, minimise our waste (goal 5);
- using resources from nature sustainably (goal 6);
- mitigating and adapting to climate change (goal 7);
- reduced risk of harm from environmental hazards (goal 8);
- enhancing biosecurity (goal 9); and
- enhancing beauty, heritage and engagement with the natural environment (goal 10).
To discuss any of the points raised here about the EIP or any related issues it raises for your business, please contact sustainability partner Ben Stansfield.
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