Recommendation 191

This requirement is stalling developments across the country. 245 Developments which had planning permission in place before advice such as water neutrality was issued must now undertake additional assessments and source mitigation before they can commence development. The owners of these sites face all the challenges in availability and costs that we outline above regarding mitigation schemes, compounded by the fact that this will have not been factored into the initial viability assessments of the sites. 246 The retrospective application of these requirements creates uncertainty for developers and therefore impacts on market confidence and future investment. 247