Recommendations
8. 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
ancient woodlands. (Paragraph 16)
9. 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.
(Paragraph 19)
10. Any offsetting
scheme should take account of reduced public access to the biodiversity
being lost with development. Distant offsets might be contemplated,
especially if they benefit ecosystem networks and if the public
has little or no access to the development site. Where local people's
enjoyment of habitats and wildlife would be directly affected,
on the other hand, offsetting decisions should be considered at
the lowest planning authority level possible. This would have
the additional benefit of allowing that authority to be able to
give full weight to both the loss and the gain under its jurisdiction.
(Paragraph 25)
11. Any biodiversity
offsetting system must emphasise the continued primacy of the
'mitigation hierarchy', and the Government should make clear under
such a system that the National Planning Policy Framework commitment
to the hierarchy will not be weakened or bypassed. (Paragraph
29)
12. The Government
should task Natural England to monitor any offsetting scheme introduced
to ensure a balance of habitat types are covered in the offsets,
so that overall they are broadly similar to the habitats that
are lost, and provide Natural England with the resources that
such monitoring would need. If necessary, the weighting factors
applied in the offset metrics should be adjusted to ensure that
such a balance is delivered. (Paragraph 34)
13. More analysis
of the pilots should be undertaken once they have been concluded,
specifically to test how uptake might be expected to vary according
to the design of the schemes. (Paragraph 35)
14. [Unless like-for-like
habitat replacement is required, any offsetting process will have
to make ultimately subjective 'equivalence' judgements about the
value of nature.] That concern should prompt the Government to
develop a system where offsetting 'risk factors' are initially
given very high weightings which can only be reduced when experience
of offsetting in practice provides confidence that the environment
has not been harmed overall. (Paragraph 42)
15. The Government
should allow the offsetting pilots to run their course and then
be evaluated in a genuinely independent way. If that evaluation
indicates clear advantages in introducing an offsetting scheme,
at that point the Government should bring forward revised proposals
that reflect the concerns that we have raised in this Report.
(Paragraph 45)
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