2 Measuring and assessing offsets |
6. In his introduction to the Green Paper, the
Environment Secretary of State acknowledges that "the success,
or failure, of offsetting will depend on the detail of the scheme
we adopt", and
in particular the proposed "standard metric"
for measuring biodiversity gains and losses. Defra told us that
the metric had been developed by Natural England and other experts
"who have experience and who have looked at metrics internationally
and drawn on those".
7. The Government's proposed metric would quantify
the value of habitatsboth those lost in the development
and those gained through an offseton the basis of three
as low, medium or high"reflecting the rarity of the
habitat concerned and the degree to which it supports species
rarely found in other habitats."
as poor, moderate or goodbased in the pilots on Natural
England's Higher Level Stewardship 'farm environment plan' manual.
· Area, in hectares.
The distinctiveness and quality attributes of an
area would be multiplied together to provide a weighting that
would then be applied to the area involved to produce a number
of biodiversity 'units'.
The proposed metric would also have three additional factors that
would be used to adjust the final number of units. The Green Paper
does not suggest how these would be calculated or what relative
weighting these would be given. These factors are:
risk associated with habitat restoration or creation, where not
all activities would achieve the desired outcome.
· The time needed
to create the substitute habitat.
· The location
of the offset. Local authorities may have set out strategies on
where to locate offsets to create maximum environmental gain,
and a higher number of offset units would need to be provided
if they were outside these designated areas.
8. Policy Exchange told us that they supported
the inclusion of the 'risk premiums' because "habitat creation,
re-creation and translocation all have less chance of success
than maintaining existing sites".
The Wildlife Trusts believed that a new site would not immediately
support the same range of species as the old site because "there
would be nowhere for them to colonise from", and that accordingly
the new habitats should be created before they are required as
Green Paper envisages the development of such 'habitat banking',
where an offset provider would restore or recreate habitats in
anticipation that they would be able to sell the offset units
at a later date.
9. The Home Builders Federation welcomed the
simplicity of the proposed metric. They thought that it should
be kept as "simple and flexible as possible" in order
not to limit the availability of offsets or "complicate discussions
associated with planning applications". More complex metrics
would also add to the costs of offset assessments.
10. Other witnesses had concerns, however, that
the metric was overly simplistic. The Environment Bank, for example,
Having a system that looks very simple is actually
quite hard to operate. You end up making a lot of value judgments
in there, because there are not enough categories to choose from.
I think there is a middle ground of making it a bit more nuanced,
which will make it easier to operate.
The Wildlife Trusts told us:
Ecology is a complicated thing. At the moment,
the metric is too simplistic even to capture effectively some
of the value of those lower value habitats, particularly because
there is not a species component.
You also need to have more degrees of assessment
of habitat quality or habitat condition. At the moment, there
are essentially three categories. We feel that there needs to
be a lot more because there is a lot more variation in the quality
of habitat than that. That would give the developer greater guidance
about what is needed, and it would also be helpful from the perspective
of offset providers.
The Woodland Trust believed that:
In a practical realistic situation this could
work, but it has got to have enough complexity in it to be able
to value properly what you are looking at.
11. The Green Paper states that "it has
been suggested the pilot metric can be applied to a site in as
little as 20 minutes",
although no further detail is provided. The Wildlife Trusts believed
that "if biodiversity offsetting becomes a permit to undertake
a twenty minute survey, the biodiversity value of the site is
unlikely to be assessed appropriately, with habitats and species
missed, either due to the time of year or the lack of survey time
12. Some witnesses argued that the proposed metric
failed to reflect adequately particular attributes of biodiversity.
For example, it does not capture the losses or gains in terms
of 'ecosystem networks'. The RSPB saw an opportunity for putting
offsets "in strategic locations ... through a local nature
partnership ... [to] improve ecological connectivity",
but the Woodland Trust and Wildlife Trust noted that the metric
does not recognise when habitats are removed from or added to
existing ecological networks.
13. The Woodland Trust emphasised that the metric
focuses on habitats rather than species.
The Green Paper states that the Government intends to apply offsetting
to protected species, citing the case of the great crested newt,
which would allow "strategic opportunities to improve species'
conservation status" that are missed in the current case-by-case
approach. The Environment
Bank made the same point. The current system is:
based on the protection of individual animals
rather than conservation of the species; it focuses efforts and
resources on distinguishing exact impact, rather than on changing
outcomes... huge amounts of time and resources are expended discussing,
and then protecting, a few individuals of a relatively common
species. The only beneficiaries of this system are the environmental
consultants who service this industry, and the manufacturers of
equipment (e.g. newt fencing) to do the same. The overall effect
is counter-productive as developers are now increasingly reluctant
to declare when protected species are discovered at a site.
The Amphibian and Reptile Conservation Trust were
positive about the intended approach although it noted that the
application of offsetting would need to be controlled by a "strict
regulatory regime and the metrics developed would need to take
very specific account of the species concerned".
14. The metric, RSPB told us, should recognise
the local importance of particular habitats: "There needs
to be flexibility for local authorities to give relative value".
Friends of the Earth noted that the metric does not account for
the value of natural capital and ecosystem services, such as pollination
or flood mitigation.
The Aldersgate Group told us:
Biodiversity offsets can conflict with local
levels of other ecosystem services (such as recreation or regulating
surface water drainage). Offsets can be designed to take these
services into account, but doing so requires more complexity.
15. Witnesses were also concerned about the Government's
proposal to allow offsetting to be applied to ancient woodland
and Sites of Special Scientific Interest.
The chair of the Natural Capital Committee told us in May that:
There are some areas where offsetting is not
appropriate. You can't replace a bit of ancient woodland with
like or better, because there isn't any ancient woodland you can
invent without waiting 1,000 years for it to get to the state
you want it to.
RSPB believed that the metric would need to reflect
that: "There are some habitats that are nationally important,
such as ancient woodland and heathland, which should have a minimum
score, and that should essentially be the highest score".
16. The biodiversity metric described in the
Green Paper is overly simplistic. The speed with which the metric
can be applied to sites (the Government estimates 20 minutes)
should not be the priority. The priority should be ensuring rigorous
protection of the environment. If biodiversity offsetting
is introduced, its metric for calculating environmental losses
and gains must reflect the full complexity of habitats, including
particular species, local habitat significance, ecosystem services
provided and 'ecosystem network' connectivity. For some sites,
for example sites of special scientific interest, the weightings
in the metric must fully reflect their value as national, as well
as local, assets. For developments not of national
significance, offsetting would not be appropriate where environmental
loss is irreplaceable within a reasonable timeframe, such as with
17. The Green Paper sets out a range of options
for who should be responsible for offsetting assessments: planning
authorities could be responsible for ensuring the robustness of
assessments, a national body could have responsibility for undertaking
the assessments, and "suitably qualified individuals"
could become accredited assessors.
In our separate inquiry on Well-being, Dieter Helm cautioned that:
It is really rather important to be clear that
those assessments are genuinely independent of the interests of
the parties. The country is not awash with environmental expertise
to do such things. They are costly to do, and, of course, the
whole credibility of any offsetting regime will depend not only
on whether those assessments are done correctly but on whether
they are seen to be done correctly.
In a similar vein, Policy Exchange told us it was
imperative that assessors were experienced, qualified and independent
professionals, and that "without this requirement, a biodiversity
offset system will not be consistent, reputable and trusted by
the public or green NGOs".
18. The Field Studies Council expressed concerns
about a lack of such skills and expertise, including those needed
"to ensure that any mitigation or offsetting is adequate
The Country Land and Business Association, on the other hand,
favoured a light touch approach, suggesting that a developer be
able to present a short statement to the planning authority setting
out how it had complied with the 'mitigation hierarchy' (paragraph
27). But the RSPB
calculated that less than 30% of local authorities have any "ecological
expertise, .... [and] if it is not addressed, it would be a bit
of a disaster to introduce more offsetting".
The Wildlife Trusts told us
A planning officer sitting in a local planning
authority without in-house ecological expertise cannot work their
way through a series of tables and come to a reasoned judgment
on the ecological impact. At every level, you also have to have
significant ecological expertise in the system.
Buglife highlighted a different potential problem,
of inadequate data on species and habitats needed to assess offsetting
19. In any offsetting system, the application
of biodiversity assessments needs to command respect from a range
of partiesdevelopers, local authorities, environmental
groups and local people. Transparency is essential if biodiversity
offsetting is to earn public acceptance. If the Government
introduces a biodiversity scheme, it must set out clear protocols
for how the assessment should be done, require local planning
authorities to audit and validate assessment (if they do not themselves
carry them out), and publish details of how assessments are applied
in each individual case. With competing demands on financially
constrained local authorities, the Government must allow them
to recover the full costs of their offsetting work from developers,
or else make the required funds available from the Treasury.
9 Biodiversity Offsetting in England Green Paper, op
cit, p1 Back
Biodiversity Offsetting in England Green Paper, op cit, p9 Back
Biodiversity Offsetting in England Green Paper, op cit, p10 Back
Policy Exchange (BIO 010) para14 Back
Wildlife Trusts (BIO 020) para 4.3 Back
Biodiversity Offsetting in England Green Paper, op cit , para 54. See also Exploring potential Demand for and Supply of Habitat Banking in the EU and appropriate design elements for a Habitat Banking Scheme
(European Commission, 2013). Back
Home Builder's Federation (BIO 021) para 14 Back
Biodiversity Offsetting in England Green Paper, op cit, para 25 Back
Wildlife Trusts (BIO 020) para 6 Back
Qq10, 26 Back
Biodiversity Offsetting in England Green Paper, op cit , para
Biodiversity Offsetting in England Green Paper, op cit , para
Environment Bank (BIO 012) paras 23 and 24 Back
Amphibian and Reptile Conservation Trust (BIO 005) para 1.7 Back
Friends of the Earth (BIO 003) para 4. See also Economic Valuation of the Benefits of Ecosystem Services delivered by the UK Biodiversity Action Plan
(Defra, 2011) Back
Aldersgate Group (BIO 023) Back
Biodiversity Offsetting in England Green Paper, op cit , para
Oral evidence taken on 9 May 2013, HC (2013-14) 59, Q48 Back
Biodiversity Offsetting in England Green Paper, op cit, para 59 Back
Oral evidence taken on 9 May 2013, HC (2013-14) 59, Q 50 Back
Policy Exchange (BIO 010 ) para 8 Back
Field Studies Council (BIO 017) para 5 Back
Country Land and Business Association (BIO 019) response to Q6 Back
Buglife (BIO 018) para 1.4 Back