Advice note that covers nutrient neutrality, recreational impacts and the new GIRAMS subscription model

Who does it apply to?

This advice note applies to all new temporary holiday sites and caravan and camping sites, including:

  • certified sites for caravan and camping
  • exempted sites
  • temporary holiday sites, including rallies and pop-up campsites operating under the 28/60 day permitted development rules
  • any other temporary holiday sites which result in overnight accommodation 

What has changed?

Two significant changes have been introduced since 2022 that now impact the operation of caravan and camping sites, including temporary holiday sites, one at national level and one at a county-wide level.

Before the issues below arose, temporary uses of land, such as for holding caravan rallies or temporary holiday sites, were not considered likely to significantly affect a European-designated site for nature or ecological reasons. That assessment has now changed, and mitigation for those effects is needed.

The following matters now need to be considered:

Nutrient Neutrality

Natural England’s advice letter dated 16 March 2022 about nutrient pollution in the protected habitats of the River Wensum Special Area of Conservation and the Broads Special Area of Conservation and Ramsar site. Nutrient Neutrality (

Recreational impacts

Joint work by the Norfolk planning authorities and Natural England has identified that residential and tourist-related development, including caravan and camping sites, contribute to increased recreational use on internationally designated Habitat Sites, particularly European sites. Habitat Mitigation: Recreational impacts (

Both nutrient pollution and recreational impacts from caravan and camping sites have the potential for adverse impacts on European designated sites, which require assessment under the Conservation of Species and Habitats Regulations 2017 (Habitats Regs), and this will, in most cases, require those adverse impacts to be mitigated.

What does mitigation look like?

The Norfolk-wide Green Infrastructure and Recreational Impact Avoidance and Mitigation Strategy (GIRAMS) agreed between the Norfolk planning authorities and Natural England is a way to manage adverse impacts on European sites. In most cases, through payment of a mitigation tariff. The tariffs collected are used towards programmes to help manage those adverse impacts. The GIRAMS mitigation tariff to be paid depends on the development type and size. The mitigation tariff is designed to provide mitigation in perpetuity (circa 80 years).

Recreation impacts: seeking to find solutions  

North Norfolk District Council recognised that payment of a single GIRAMS payment designed for 80 years worth of mitigation was adding a significant financial burden for temporary holiday sites and caravan and camping sites, especially those that may only operate for less than five years. 

GIRAMS subscription model

North Norfolk District Council have listened to those concerns and devised a subscription model for GIRAMS mitigation, which significantly reduces the financial outlay for smaller tourism businesses while enabling necessary mitigation to be secured.


Using the 2023/24 standard tariff unit rate of £210.84 and a temporary campsite with ten standard-sized pitches. They would have been required to pay a full upfront cost of £1,405.60. 

Alternatively, using the subscription model, a 1 year subscription would cost £21.08,  approximately £2.11 per pitch . This subscription model significantly reduces the upfront GIRAMS mitigation costs.

North Norfolk District Council have shared the subscription model with all the Norfolk authorities and will be using this model from 2024 onwards. Discussions with the Caravan and Camping Club have identified a preference for subscriptions to start per calendar year, from 1 January to 31 December, rather than aligning with tax years. The Council will adopt the calendar year approach from 2024 .

The rate for GIRAMS is reviewed annually as of 1 April each year. 

Nutrient Neutrality

Natural England’s advice catches caravan and camping sites as they include overnight accommodation. However, at this time, solutions for how caravan and camping sites, especially temporary holiday sites, can address the concerns reasonably and proportionately, like has been achieved with the GIRAMS subscription model outlined above, are still being resolved.

Waste disposal, mitigation and nutrient neutrality

Understanding how waste from caravan and camping sites, including temporary holiday sites, is to be disposed of is key to resolving nutrient neutrality. 

Many organisations require sites to either have a sealed container (cess tank) underground that is emptied by tanker or direct access to main drains. If mains drainage is being used, it may be acceptable if the waste water treatment works serving the site discharge their treated water outside the nutrient neutrality catchment. If the treated wastewater is discharged within the nutrient neutrality catchment, mitigation may be required, such as purchasing credits. However, currently, no credits are available in North Norfolk.

Collecting waste from a sealed container (such as a cess tank) and disposing of it outside the nutrient neutrality catchment is currently being considered, but clarity about how this option would be secured for temporary holiday sites remains under discussion. The Council is working with the Environment Agency and Natural England to identify a resolution to this matter.

At this stage, until the establishment of mitigation solutions either via credits or on or off-site mitigation solutions or unless a temporary holiday site is found to be nutrient neutral, the local planning authority, as competent authority under the Habitats Regulations, would not be able to reasonably conclude it is satisfied that there is no reasonable doubt as to the absence of adverse effects on the integrity of European site. Unfortunately this means that some temporary holiday sites located within the nutrient neutrality catchments of the River Wensum Special Area of Conservation and the Broads Special Area of Conservation and Ramsar site may not be able to operate until mitigation solutions are progressed.

How do I know if Nutrient Neutrality requirements affect my site?

Catchment maps for Norfolk, Wensum, Bure and Yare and focussed catchment maps for the Wensum, Bure and Yare are available on the Council’s Nutrient Neutrality web page.

Mapping tool

The Council also has a mapping tool within which you can select Map Features, followed by Area Regulation, Restriction & Mgmt. You can select layers on nutrient neutrality, including foul water drainage and surface water catchments.