This CIEEM briefing sets out the Institute’s overarching position on the first draft Environmental Delivery Plan (EDP). It is intended to help members prepare their own consultation responses.
EDPs are a new mechanism under the Planning and Infrastructure Act 2025. They allow developers to pay a levy in place of meeting certain habitat and species protections, with the money funding conservation measures that should “materially outweigh” the impacts. This first draft covers nutrient pollution from up to 15,780 homes in Norfolk, affecting the Norfolk Broads SAC, River Wensum SAC and Broadland Ramsar site. It will be the template for future EDPs.
CIEEM welcomes more strategic, landscape-scale approaches to nature recovery and the broad nature recovery benefits of the proposed measures. It does not think the draft will work as written, for three main reasons:
- It risks failing to prevent nutrient pollution
- It risks irreversible harm to irreplaceable habitats
- It undermines nature markets and underfunds recovery
CIEEM is asking Government to:
- add upfront measures that cut pollution at source;
- assess impacts on individual species and irreplaceable habitats;
- increase the levy;
- add measurable monitoring metrics with trigger thresholds; and
- make the EDP part of a whole-systems catchment approach.
CIEEM asks all members to respond to the consultation, sharing their own experience and expertise.
The consultation closes at 9:29am on Tuesday 27 October 2026.
The consultation can be found at: https://consultations.defra.gov.uk/consultation-on-a-new-environmental-delivery-plan