From:
Tom Scott-Heagerty <[email-masked]>

Sent: 05 January 2026 12:41

To: Julia Pound <[email-masked]>

Subject: RE: Land Management Plan

Hi Julia, Happy New Year. And thank you for contacting the Responsible Body to
obtain more detailed information on how the scheme will be monitored and enforced. It would be helpful to share this additional information with the relevant LPAs, as it provides further context rega     

CGBANNERINDICATOR

Hi Julia,

Happy New Year. And thank you for contacting the Responsible Body to obtain more detailed information on how the scheme will be monitored and enforced. It
would be helpful to share this additional information with the relevant LPAs, as it provides further context regarding the duties of the Responsible Body in relation to the nutrient mitigation scheme at the Hinxhill Estate.

Having reviewed the information provided, I am satisfied with the proposed land management plan for the Hinxhill Estate nutrient mitigation scheme.

Many thanks,

Tom

Tom Scott-Heagerty

Senior Officer - Sustainable Development

Sussex and Kent Area Team

Teville Gate House, 25 Railway Approach,

Worthing, West Sussex, BN11 1URM

: (+44) 791 9659 298

http://www.gov.uk/natural-england

From:
Charles Sheldon <[email-masked]>

Sent: 19 December 2025 10:31

Subject: RE: Land Management Plan

Hi Julia,

Many thanks for passing this on. Happy to discuss further as required.

We think about enforcement in terms of three broad layers (from ‘softer’ to ‘harder’), which in turn is the structure of the reporting that
we provide back into the Secretary of State annually. Notes on that specifically in relation to the Hinxhill fertiliser and grazing points below this email.

If it’s useful for us to speak to Tom directly, then happy to do that. However, in general I’d comment that in practical terms this is one
of the less demanding compliance and enforcement roles we have taken on. The actions are clearly defined and cost/benefit for the estate is not attractive given the scale of potential enforcement liabilities.

Kind regards,

Charlie

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Hinxhill Monitoring and Enforcement Notes

Layer 1: Governance and Engagement

We have engaged with this project because Hinxhill have demonstrated they are a professional and robust counterparty who have always acted
in good faith in the long period we have worked with them. The governance structure for the project will build on that relationship, with our teams being on site in person every year to sit with the estate team talk through the practicalities of the scheme
and educate new team members on the restrictions (i.e. making specific allowance for the inevitable turnover of the team over time). We will time our site visits to the relevant parts of the year (e.g. when fertiliser and grazing planning decisions are being
taken in the normal farming cycle).

The estate are specifically obliged to introduce us to new key team members, and to display simple explanatory materials at the key operational
locations. We will be validating this when we are on site each year. These mechanisms are central to managing the critical risks over long time periods, which is not so much that parties deliberately breach, but that the scheme obligations get forgotten or
overlooked.

Layer 2: Data Collection and Verification

There a pragmatic and robust set of procedures for evidence gathering that will be employed at this scheme. The estate will provide regular
geo-located photography of the site and activities. They will provide the paperwork relating to fertiliser application and to grazing activities. For any grazing conducted positive evidence will be required demonstrating compliance with the stocking cap. Failure
to provide any of these materials to schedule or materials that contradict information collected from our site visits would be red flags that result in escalation.

Our site visits will collect independent data both in terms of photography and drone footage and environmental review (relevant FISC-certified
personnel from our team will attend to review grassland outcomes). In addition we will conduct independent soil sampling at a reasonable frequency.

The overall effect of this data will be that it is very low risk that breaches go unidentified. To take one example, if over time the soil
nutrient levels and grass species mix is not trending in the expected direction this would be a major red flag and we would increase site visit activity and enforcement as required.

Layer 3: Threat of Enforcement

The covenant grants broad and severe enforcement rights. For example, deliberate and obvious breach would result in us triggering our step
in rights and interfering on the ground in estate activities (alongside associated legal challenges). This is the core of our role and we hold appropriate financial reserves to rapidly mobilise in this scenario, as well as substantial internal legal and litigation
expertise.

We of course hope that enforcement activity will never be required. However, our responsibility is to demonstrate to the Secretary of State
that we acting forcefully in the interests of nature delivery. The consequences to the landowner of a breach are substantially higher than the benefit of the breaches discussed in this case.

Charles Sheldon

Delivery Director

HF Environmental

www.hfenvironmental.com

07476394547