Thoughts on biodiversity offsetting

The idea of a biodiversity offsetting system in England was announced in the Government’s Natural Environment White Paper - a 50-year vision for the natural environment published in 2011.

What is biodiversity offsetting?

Biodiversity offsetting is a proposed approach to compensate for habitats and species lost to development in one area, with the creation, enhancement or restoration of habitat in another.  Under this system any negative impacts on the natural environment would then be compensated for, or ‘offset’ by developers.

A complex situation....

Biodiversity offsetting is a simple phrase for what is in reality a very complex idea.

There are elements that are immediately problematic for any conservationist - some habitats have evolved over millennia and are irreplaceable; the phrase offsetting itself is in danger of greenwashing the facts ('nature damage compensation' would be more accurate); ecosystems are dynamic - many animals range over a network of habitats and this is difficult to plan and design for in human terms.

However there is no escaping that there is a serious problem that needs addressing somehow.  Nature is being damaged and lost and will continue to be if as a society we are unable to find increasingly better ways of creating the built environment that we need (houses, schools, transport links).  

Wildlife Trusts are often at the front line - in 2012-13 we responded to more than 6,000 planning applications (and reviewed many thousands more) and hundreds of Development Plans.  As a result we managed to achieve better outcomes for nature in more than 3,300 of these cases.

We have fought against damaging development proposals throughout our history.  At the moment we are leading a campaign against a motorway extension across the Gwent Levels, we are part of a wider group of organsiations challenging the environmental impact of HS2 and we've been working with the Campaign for Better Transport and other charities to oppose damaging new roadbuilding plans.

In many places nature is losing out and habitat lost through development (photo Kieron Huston)Major new developments often have to be mitigated for through creation of new habitats but many people will be familiar with the 'death by a thousand cuts' scenario as hedges, trees, parks, green spaces continue to disappear without any measures to counterbalance this loss.

At present the majority of Local Planning Authorities fail to secure off-site compensation with long-term management commitments for habitat loss through development.  The State of Nature report is further evidence that more, and different, action is urgently needed.

Biodiversity offsetting is not the only solution but the scale and nature of the problem means it is worth at least considering, with necessary caution and as part of a wider set of approaches.  As a charity which has the protection and enhancement of nature at its heart, we will react strongly if we feel that the natural environment is being undermined through any proposed process.  Offsetting, of different kinds, is already in practice in some countries and it will be important to look at examples of where it has worked and, critically, where it has not worked, overseas as part of considering any proposed approach in the UK.

Our society and economy will need to change fundamentally to address the root causes of nature's decline (and the need to even consider biodiversity offsetting in the first place).  It is likely that in the future conservation will need to be much more integrated into how we live and behave as a society if nature is going to truly recover in the way we need it to.  As a response to this, The Wildlife Trusts have been broadening the way we work to include working with health care providers, planners and economists - we need to find a place for nature everywhere and we need everyone to realise their responsibility for nature.

Compensation and the mitigation hierarchy

Some habitats are irreplaceable

We believe that the bare minimum objective of any compensation mechanism like biodiversity offsetting system should be to achieve 'no net loss' for biodiversity through the planning system but with an emphasis on achieving a net gain.  At present the majority of Local Planning Authorities fail to secure off-site compensation with long term-management commitments for habitat loss through development.  On this basis biodiversity offsetting could have a role for compensating for unavoidable harm to some habitats but there are several potential pitfalls.  

The replacement of one habitat with another is extremely complex and direct like-for-like replacement is nigh on impossible. Additionally there are some habitats like ancient woodland which are simply irreplaceable, so:

1. The starting point for any development proposal should be to avoid damage to important wildlife sites and to accept that irreplaceable habitats should not be developed.

2. Next, it is important to ensure that nature is designed into new development in a meaningful way to mitigate damage.

3. Only then - and as a final measure - should any compensation measure (such as offsetting) be considered to compensate for damage that cannot be avoided or mitigated.

4. If compensation cannot be achieved, for example because a damaged habitat cannot be created elsewhere, then the development should not go ahead as planned

Compensation should be a last resort measure and should only be used to compensate for unavoidable damage.  In the case of theoretical biodiversity offsetting, offsets should be used near the impact and  targeted locally in strategic areas.  Care should also be taken not to deprive communities of valuable local greenspace - replacing lost habitat in Cornwall with new habitat in Cumbria is simply not acceptable.

A question at the centre of the offsetting debate is whether Local Planning Authorities are sufficiently well guided to be able to objectively judge whether a development is actually of sufficient importance to outweigh the biodiversity that would be lost.  This would require strong central guidance on this decision-making process.  Any proposed offsetting scheme would also require substantial improvements to several areas of the current planning system such as Local Planning Authorities with in house/independent expert ecologists, well resourced Local Record Centres and statutory involvement in planning responses.

The Wildlife Trusts would not support a system that expected planners to be able to use a metric to make judgements in isolation from independent ecological input.  We need a system that works better to conserve wildlife, and do not support a core purpose of offsetting being to make the planning process quicker and cheaper for developers.

Purpose

Any biodiversity offsetting scheme should have a clear purpose, set within a framework for delivering ecological networks.  The Wildlife Trusts believe Government needs to set out a vision to create a National Ecological Network for England, which should be informed by ecological network strategies produced by Local Nature Partnerships (or other similar strategic partnerships of a broad range of local organisations, businesses and people who aim to help bring about improvements in their local natural environment).  Within these strategies, ecological network maps would show the existing natural assets (our statutory and non-statutory sites and priority habitats) and important areas for re-establishing strategic footholds for nature eg buffers around protected sites and Nature Improvement Areas (NIAs) across the length and breadth of England.

Offsetting pilot schemes

In April 2012, Defra initiated six biodiversity offsetting pilots to test this approach over a two year period.  The pilots are led by local authorities and a range of partners were asked to take part including developers and wildlife organisations including The Wildlife Trusts.  Wildlife Trusts are contributing local knowledge about ecological networks and wildlife for some of the pilot schemes.  The lessons learned from these pilots will be critical in informing the design of any offsetting scheme and we believe that being involved and sharing our knowledge will help to influence any outcomes positively for nature.

What happens next?

The Government published a Green Paper on biodiversity offsetting in September 2013.  We believe the decision to publish this before the results of the pilots in 2014 are available was not the right decision.  Proposals for any biodiversity offsetting scheme should be based on scientific evidence and The Wildlife Trusts will await the evidence from the pilot schemes in 2014.

This has been put together with help of planning officers at Wildlife Trusts.

Tell us what you think

Biodiversity offsetting is a new idea and we're still finding out about it. Use the comment field below to let us know what you think.

Comments

    I am concerned to read about such a complex issue as this, and I do agree with the comments posted under the heading of 'When could it be appropriate to use biodiversity offsetting'. I hope that our Wildlife Trusts, and other conservation organisations, are able to pull all of the resources together needed to provide a proactive response; possibly by identifying potential areas for development by local authorities so that cases can be built against development. I am not an expert in this area by any means but I am concerned that local authorities will pull out the 'deadline' card for a response if they realise that they might not get their own way with development plans.

    Friday 10th January 2014
    by

Post a comment

I am concerned to read about such a complex issue as this, and I do agree with the comments posted under the heading of 'When could it be appropriate to use biodiversity offsetting'. I hope that our Wildlife Trusts, and other conservation organisations, are able to pull all of the resources together needed to provide a proactive response; possibly by identifying potential areas for development by local authorities so that cases can be built against development. I am not an expert in this area by any means but I am concerned that local authorities will pull out the 'deadline' card for a response if they realise that they might not get their own way with development plans.

Friday 10th January 2014
by