CGW0012

Written evidence submitted by Sustainable Nitrogen Alliance

Initially founded by the Soil Association, Plantlife and WWF in 2021, the Sustainable Nitrogen Alliance is a group of organisations and scientists looking to communicate and cooperate with the Government to reduce the multitude of damaging impacts resulting from excessive nitrogen use and pollution - both in the UK and through the UK’s global footprint. We are advocating for an integrated, system-thinking approach across government to reducing wasted nitrogen resources, which requires cross-government working to achieve policy co-benefits and to minimise trade-offs.

Summary

1. Nitrogen pollution significantly impacts on air quality, water quality, public health, the climate, ecosystems, soil health and biodiversity. These impacts are interrelated because nitrogen cycles constantly through the environment in different forms, meaning policies to reduce nitrogen-related harms caused by one mechanism often impact nitrogen released by other mechanisms. For example, reducing farm fertiliser use to tackle eutrophication of rivers also reduces airborne nitrogen emissions in the form of ammonia (which damages public health and biodiversity) and nitrous oxide (which is a potent greenhouse gas).

2. Several government departments have responsibility to tackle nitrogen-related issues, including the Department of Health and Social Care (DHSC), Department for Environment, Farming and Rural affairs (Defra), Department for Transport (DfT), Department for Levelling Up, Housing and Communities (DLUHC) and Department for Energy Security and Net Zero (DESNZ).

3. Improving nitrogen use efficiency is also of importance to the HM Treasury and the Cabinet Office because there are significant potential financial gains from reducing nitrogen lost to the environment. In the UK, the societal and environmental cost of nitrogen pollution is estimated at £10.9 billion per year, while in the EU the value of wasted nitrogen is estimated to be equivalent to a third of the CAP budget.[1]

4. Cross-government working is needed to ensure better collaboration between relevant departments in order to take a systematic approach to the use  and management of nitrogen, achieving co-benefits and minimising trade-offs. Similar to the cross-departmental Net Zero strategy, a cross-departmental Nitrogen Strategy would enable departments to work collaboratively to achieve nitrogen reduction targets.

Introduction

5. Nitrogen flows through the environment in different forms, with a variety of mechanisms by which reactive nitrogen is lost to the environment as a pollutant. Humans have more than doubled the amount of reactive nitrogen in the world since pre-industrial times, causing mass-imbalance of the nitrogen cycle.[2] Much of this imbalance is due to the invention of the Haber-Bosch process used to create nitrogen fertiliser, producing nitrous oxide emissions (a potent greenhouse gas) during manufacturing and contributing to pollution of the environment during application. Other significant ways in which nitrogen impacts on the environment are burning fossil fuels, including vehicle emissions, the domestic burning of wood, energy conversion and industrial processes.[3] Much work has been done to reduce emissions from industrial processes, but other areas are lacking progression.

6. Across the UK, nitrogen pollution is a significant driver of the poor state of waterbodies and a key contributor to poor air quality, while nitrous oxide is a greenhouse gas contributing to the depletion of the stratospheric ozone layer, and nitrogen deposition is leading to acidification and eutrophication of soils and natural terrestrial ecosystems, and the associated loss of species – these impacts are all interrelated. Recent modelling has shown that ammonia and nitrogen oxide emissions reductions of 50% are required to restore 75% of UK sensitive habitats to favourable condition.[4]

7. Reducing nitrogen lost to the environment is within the remit of several government departments and other statutory bodies, including the DHSC, Defra, DfT, DLUHC and the DESNZ as well as the HM Treasury, the Cabinet Office, the Environment Agency and Natural England. Thus, effective action requires an integrated, cross-government approach across all relevant departments, using systems-thinking to manage the inherent complexity of the nitrogen cycle.

8. The government has demonstrated its ability to implement cross-government working through the Net Zero strategy. The same level of ambition and implementation needs to be applied to tackle the nitrogen crisis in order to reduce harms to the environment and human health. Mitigating the negative externalities would also result in considerable financial savings through reducing wasted nitrogen and its consequential pollution.

Why does tackling nitrogen require cross-government working?

9. Since the Environment Audit Committee’s Eleventh Report: ‘UK Progress on Reducing Nitrogen Pollution in 2018’, the Government has made little progress on nitrogen reduction. In England, targets have been set within the Environment Act; namely a 40% reduction in nitrogen pollution from agriculture to water by 2038, and air concentration and exposure targets for nitrogen oxides and PM2.5. Despite publishing a Clean Air Strategy in 2019 with specific commitments to reduce ammonia emissions from agriculture, the Government has not delivered any of the commitments to date.
   
10. The UK has also made an international commitment to reduce the negative impact of pollution from all sources by 2030, to levels that are not harmful to biodiversity and ecosystem functions and services including by reducing excess nutrients lost to the environment by at least half (Kunming-Montreal Global Biodiversity Framework, Target 7).
    
11. However, nitrogen pollution continues with habitats deteriorating,[5] the ecological health of rivers decreasing,[6] urban air quality remaining below WHO recommended levels,[7] ammonia emissions changing little in recent decades and nitrous oxide emissions from sources other than industry processes remaining persistently high.2
    
12. Achieving these environmental targets requires greater, more effective action than we are currently seeing, starting with a coherent cross-departmental review of legislation. The current regulatory framework for controlling nitrogen overuse and waste is piecemeal. Key existing regulations include EU-transposed legislation (the Nitrates Directive, the Water Framework Directive, Cross Compliance, and the Habitats Directive), as well as national legislation (Farming Rules for Water, the National Emission Ceiling Regulations, the Air Quality Standards Regulations, the Environment Act, the Silage, Slurry and Agricultural Fuel Oil Regulations, Environmental Impact Assessment, and Environmental Permitting Regulations).
    
13. One of the most significant pieces of legislation regulating nitrogen is the Nitrates Directive which introduced nitrate vulnerable zones (NVZs); designated areas where limits were imposed on the nitrogen fertiliser (inorganic and organic) applied to land. Since 2000, at least 55% of the UK has been designated as a NVZ, but there has been no substantial change found in the pattern of nitrate pollution from 2017 to 2021.[8] The 2021 River Basin Management Plan, published by the Environment Agency, identified that the NVZ programme has been effective at making a modest reduction in nitrate leaching, but the measures are not sufficiently robust to improve failing groundwater bodies. Instead, it suggests substantial changes to farming practices such as widespread use of cover crops and applying nitrogen at below the economic rate, but there are insufficient mechanisms available to effectively put these in place.[9]

14. The Environment Agency finding that NVZs are not sufficient to improve groundwater status came over four years ago, yet this contrasts the message currently conveyed by Defra and other government bodies. Cross-government working would require the relevant departments to consider this evidence from the Environment Agency, and encourage collaboration between government agencies, government departments and local authorities to implement agreed recommendations.

15. For example, nitrogen budgets at the catchment level could be used to reward farmers for applying nitrogen at below the economic rate, by creating a nitrate trading scheme within the catchment. Including all relevant stakeholders, such as housebuilders, water companies, local authorities and NGOs would share responsibility between polluters to reduce nitrogen pollution, with added benefits of enabling local authorities to achieve air quality targets through reduced ammonia emissions.
    

Calling for a cross-government approach to nitrogen

16. Mass imbalance of the nitrogen system means policies to reduce nitrogen pollution through one mechanism may increase nitrogen lost to the environment through another, known as pollution swapping. To mitigate this risk, policies must account for the impact that one policy may have on other issues by taking an integrated approach to policy design and implementation.
    
17. Where the source of nitrogen pollution may be under the jurisdiction of one government department, the impacts may be managed by another. For example, to tackle the contribution of agricultural ammonia pollution to poor air quality, the DHSC needs to work collaboratively with Defra to reduce pollution from farming with the benefits accruing to the National Health Service.
    
18. Moreover, this integrated approach must cover local as well as central government, as local authorities have a crucial role to play in reducing the impacts of nitrogen-related harms. Local authorities have a role in reducing nitrogen pollution through the planning system, for example by granting more power to local authorities to control air pollution from agriculture through planning decisions on new farm infrastructure such as intensive livestock units, or enabling local authorities to make progress on net zero strategies by reducing nitrous oxide emissions from agriculture and reducing nitrogen dioxide emissions from transport and other sources.
    

The case for a Nitrogen Strategy

19. As evidenced above, current legislation to deal with the nitrogen crisis is piecemeal. Introducing a Nitrogen Strategy which puts emphasis on cross-government working to co-design policies would create a legal framework for government departments and local authorities to collaborate in order to meet nitrogen reduction targets. This could be informed by a national nitrogen balance sheet which would indicate where the biggest nitrogen losses are across the environment and the economy, and how these nitrogen flows are interlinked. 

20. A cross-government body focused on nitrogen would be able to coordinate these relationships and help oversee the nitrogen reduction plans, and ensure they are in line with the government commitment to halve nitrogen waste by 2030. An arms-length body, along the lines of the OEP or JNCC, could be charged with evidencing targets and setting out pathways to achieving them in ways that account for synergies and trade-offs between actions tackling different nitrogen pollutants and between them and related environmental concerns such as other greenhouse gases and phosphates.
    
21. Taking a holistic approach to nitrogen use could reduce government expenditure across departments. A cross-government nitrogen taskforce could be accountable to the Cabinet Office or HM Treasury which have responsibility for monitoring the spend and delivery of department objectives.

Conclusion

22. The continuing negative impact of nitrogen on human health, the climate and the natural environment is partly due to the siloed departmental approach that government takes to nitrogen-related issues. Introducing a cross-departmental Nitrogen Strategy would aid the government to effectively and efficiently reduce the amount of nitrogen lost to the environment, by requiring all relevant departments and agencies to collaborate to produce integrated policies which consider sources and impacts in unison. The benefits of tackling nitrogen as a system would be widespread across the economy, the environment and public health, which is why the issue needs to be tackled across government, rather than under a single department’s jurisdiction.

November 2023

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