Conclusions
1. The
biodiversity offsetting 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. (Paragraph 16)
2. In any offsetting
system, the application of biodiversity assessments needs to command
respect from a range of parties—developers, local authorities,
environmental groups and local people. Transparency is essential
if biodiversity offsetting is to earn public acceptance. (Paragraph
19)
3. Offsetting provides
a means of compensating environmental loss from development only
as a last resort, after the possibility of alternative development
sites or mitigating the extent of the loss have been exhaustively
examined. (Paragraph 29)
4. A market could
encourage offset providers to offer projects of a size that facilitated
'ecosystem networks', in part prompted by potentially lower costs
from the greater economies of scale that these would allow. A
danger is that the market could produce many offsets of a similar,
lowest-cost, type rather than a mixed range of types. (Paragraph
34)
5. A mandatory, rather
than voluntary, offsetting system could help a market to develop,
which would in turn allow more environmentally and economically
viable offset projects to be brought forward. Poor uptake in the
pilots suggests that compulsion is needed, but the case for a
mandatory system has not yet been made. (Paragraph 35)
6. There are both
advantages and disadvantages in offsetting. It might be possible
to devise a better metric and more robust systems for assessing
individual offset projects, and ensure that they are only used
as a last resort under the mitigation hierarchy. But a weakness
of the Green Paper is that it does not provide a clear and evidenced
analysis of how, in its words, offsetting would deliver "biodiversity
gain" and be "quicker and more transparent, certain
and consistent". The offsetting pilots might provide that
information, but they are still underway. More fundamentally,
however, before any offsetting scheme is taken forward there needs
to be recognition that unless like-for-like habitat replacement
is required, any process will have to make ultimately subjective
'equivalence' judgements about the value of nature. (Paragraph
42)
7. The two-year offsetting
pilots have not yet run their course, nor have their results been
independently evaluated in line with commitments made by environment
ministers in 2011. It is too soon to reach a decision on offsetting
while the pilots have yet to be completed and independently evaluated.
In the meantime the Government proposals appear to place as much,
if not more, store on experience with offsetting in other countries,
notably Australia which has little in common with the environmental
landscape and development pressures of England. (Paragraph 45)
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