Homes on hold: it’s time for urgent action

Hayley Macnamara, Policy Lead, Community Housing Cymru

How can Wales meet its urgent need for affordable homes while also tackling the growing challenge of protecting its environment?

That’s the dilemma facing local authorities and housing developers after new conservation advice from Natural Resources Wales (NRW) has brought the construction of much-needed affordable homes to an abrupt halt. The issue? Nitrogen pollution from agriculture and sewage.

While housing developments do contribute to nutrient levels through sewage, most of the pollution actually comes from elsewhere.

Back in July, NRW updated its guidance requiring new housing developments in certain areas to prove they won’t increase nitrogen levels, a concept known as nutrient neutrality. This follows concerning condition assessments that revealed that some marine Special Areas of Conservation (SACs) like Pembrokeshire, Carmarthen Bay and Estuaries and Cemlyn Bay are suffering due to high levels of Dissolved Inorganic Nitrogen (DIN).

Too much nitrogen in our waters can trigger harmful algal blooms, reduce oxygen, and harm fish and other aquatic life. It’s a real problem, but so is the deepening housing crisis.

This isn’t the first time we’ve seen something like this. In 2021, similar advice issued on phosphate pollution brought hundreds of affordable homes in Wales to a standstill. Now, marine nitrate requirements are creating a fresh wave of delays.

Stark

The impact is immediate and stark. At least 889 affordable homes already in the planning process are now frozen, with another 664 homes hanging in the balance. Local authorities like Pembrokeshire, Carmarthenshire, and Swansea are particularly affected, including major projects like a 91-home development in Narberth, a 98-home development in Swansea, and a 67-home development in Pembrokeshire now on hold or facing significant delays.

These delays couldn’t come at a worse time.

Wales is in the grip of a housing crisis. House prices have rocketed, private rents keep rising, and the number of people stuck on waiting lists or living in temporary accommodation is at an all-time high. Shelter Cymru estimates over 94,000 households are currently waiting for social housing, that’s one in every 14 households in Wales.

This issue is particularly pronounced in rural areas, where the scarcity of affordable housing has long hindered individuals from remaining in their communities to live and work. Providing affordable housing in rural areas presents a complex web of challenges that differ significantly from those in urban settings, lengthening the development process.

Without urgent action, the gap between housing need and delivery is only going to grow.

Nitrogen

So where’s all this nitrogen coming from?

The NRW condition assessments highlight that agricultural runoff, especially from fertilisers and animal waste, is a main driver of nitrogen pollution.

The Control of Agriculture Pollution Regulations (CoAPR), introduced in 2021, aimed to curb agricultural pollution. However, a Welsh Government impact assessment suggests that these regulations will result in only a minimal reduction in nitrates and phosphorus.

WWF reports that many farmers and growers are already taking action to drive nitrogen use down and efficiency up, but much more can be achieved if financial and technological support is available, and if there is a level regulatory playing field that is fair to those taking action and holds those who pollute to account.

UK government reports and scientific studies consistently show that housing contributes a small fraction of the overall nitrogen load. In England, a four-year moratorium on housebuilding has blocked over 145,000 homes.

The housing sector understands and shares concerns about the quality of our natural habitats and takes its environmental responsibilities seriously. However, many in the industry feel the current planning restrictions are a blunt instrument, stopping vital homes from being built while in comparison, the bigger polluters are largely unchallenged.

Economic repercussions

Beyond housing, the new guidance is having severe economic repercussions. Construction companies and suppliers are feeling the impact of stalled projects and mounting uncertainty in an already fragile supply chain.

A major concern is the uncertainty surrounding a solution. NRW has indicated that this issue cannot be resolved quickly, as necessary mitigation measures are primarily agricultural and will take considerable time. We also note that there is currently no holistic plan to tackle the problem. Crucially, Local Planning Authorities (LPAs) are currently awaiting essential tools, like a revised nutrient calculator, to perform the required assessments.

And while mitigation strategies are in the works, most of them involve changes in farming practices that will take years to implement.

This situation starkly highlights the growing conflict between vital environmental protection and the urgent need for affordable housing, both strategic priorities for the Welsh Government. This is now not just a pollution problem, it is a social justice issue.

It prompts us to ask: How can we ensure that ambitious environmental goals and the critical delivery of affordable housing work together harmoniously?

Interim exemption

To address this challenge, Community Housing Cymru, the representative body for housing associations in Wales, has formally asked the Welsh Government to consider an interim exemption for affordable housing. The idea is simple: let the most urgently needed developments go ahead while long-term solutions are put in place.

It’s a call for striking a balance between protecting our environment and providing homes for people who desperately need them.

Last week, First Minister Eluned Morgan announced a new taskforce, bringing together government, local authorities, and Natural Resources Wales (NRW) to find practical solutions so housing developments can move forward.

It’s crucial that housing associations and developers are actively involved and kept informed throughout this process to safeguard projects nearing completion.

The role of agriculture in this action plan remains to be seen. We urgently need a holistic review of water pollution, focusing on its sources, and crucially, the necessary mitigations and solutions. Without this, there is a significant risk that this will be a recurring issue, degrading the environment and impeding future housebuilding efforts.

This isn’t a problem for one sector; it’s a shared challenge demanding collective ownership and collaborative action- from government, regulators, farmers, water companies, planners and developers alike.

We must work together to find sustainable solutions that protect Wales’s natural environment without sacrificing the fundamental right to a home.