Nurturing Nature, or exporting our assets?

A new report brings a significant degree of common sense to help ease the ongoing friction between planning and biodiversity.

Nurturing Nature: Policy to protect and improve biodiversity’ published recently by one of the UK’s leading think tanks, Policy Exchange, examines England’s natural environment policies and their success in protecting and enhancing important habitats and biodiversity, both at home and abroad. 

There’s a lot to be welcomed in this. Much of it is based on the view that the designation of important habitats has led to ‘ghettoisation’ – the system protects habitats on the basis of designation, leading to undesignated sites lacking protection (and potentially being lost) and designated habitats becoming ecologically isolated, and thus also threatened.

Ancient woodland is an example of this; indeed the report lists ancient woodland sites as having a low level of protection. It suggests the problem can be overcome by valuing nature more effectively. The report also recognises something we’ve talked about a lot recently – that the NPPF fails to take the opportunity to truly enhance biodiversity by maintaining the caveats set out in the planning policy statements. We’d agree; within the context that ancient woodland is irreplaceable, as such the best approach is that planning policies must strengthen its protection.

The report highlights that Government should create an easy-to-search register of compensation schemes that are effectively monitored. This is crucial to ensure that the ad-hoc approach currently being undertaken by local planning authorities (LPAs) (the report states that 41% of LPAs have used offsetting or compensation mechanisms) is properly monitored, both for successes and for lessons learned. 

We would also support the proposal that LPAs should commission Environmental Impact Assessments (EIAs) whilst developers continue to pay for the reports. Thinking about our Woods under Threat work, this approach assessing the true value of ancient woodland, and other important habitats,  would provide a far more balanced, and unbiased, outcome for all parties involved.

So yes, much to be welcomed. But we still have one major concern, which is the suggestion that: 

Money used protecting local biodiversity could in some instances lead to greater biodiversity gain if spent somewhere else, nationally or internationally (page 26).

The Trust strongly refutes this. In our view, overseas offsetting of biodiversity loss in England is not only shirking our responsibilities, and doing our environment and population a great disservice, but is fundamentally flawed. 

I don’t mean, in saying this, to dismiss in any way the vital importance of global environments. The report itself sets out the many and broad benefits ecosystem services bring (see table below): 

Provisioning services 

  • food (crops, livestock, aquaculture, fish) trees, standing vegetation, peat
  • water supply (for plants and humans)
  • medicine (e.g. aspirin comes from willow tree)
Regulating services 

  • climate (weather and stores carbon)
  • pests and disease
  • pollination
  • water quality (recharging groundwater, cycling)
  • air quality (absorbs pollutants)
  • hazard (flood protection)
  • noise 
Amenity or cultural benefits 

  • tourism
  • health, recreational and educational
  • benefits of access to greenspace
  • cultural value placed on wildlife protection
Supporting services 

  • soil formation
  • photosynthesis
  • nutrient cycling

But many of these ecosystem services are locationally specific – managing water quality and recharging aquifers needs to happen in the catchments we use; protecting pollinating insects must happen here, where the crops are grown; improving air quality through absorbing pollutants must happen where people live; and so on.  I’m back to the “think globally, act locally” message – where local people lose elements of their local environment, surely it’s not only right and just that this is properly mitigated for as locally as can be, but it’s axiomatic.

The Woodland Trust believes that all mitigation for biodiversity loss should be adopted as local as possible, and that considering mitigation on even a national scale risks being inequitable. This is why we are promoting to communities the opportunity Neighbourhood Planning offers, as well as working closely with LPAs to ensure that any local losses of biodiversity are mitigated locally.

Victoria Bankes Price, Conservation Adviser (Planning)


About Kaye Brennan

Trying vegan, staying warm. Occasional bursts of words.
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11 Responses to Nurturing Nature, or exporting our assets?

  1. Lesley says:

    Dear Kaye,

    I am not advising caution I am said it wwwas nonsense, which it is it cannt be done. This is throwing science in the bin to push for a credits scheme. You the Woodland Trust used to extol the virtues of a habitat that we are so far from understanding – are you really prepared to sit back and watch it gambled on rather than help with science? Even corporate businesses including developers are concerned at this (and one hopes for once that they will be able to provide the lobby against this – because it is becoming increasingly clear that many NGOs aren’t and why? there can only be one answer the promise of money and influence).

    I have three questions for you.

    1) Are the WT involved in the biodiversity offsetting project trials?

    2) Are the WT receiving any form on income from biodiversity offsetting?

    3) Do you hope to?

    And Kaye, this debate is not ‘part of the process of engaging or inspiring people, communities and wider society at all’, you are mixing up your cliches or do you just copy and paste? I look forward to hearing your answers.

    Lesley Jones

    • Kaye Brennan says:

      Lesley, Thanks again for your questions and comments. We are not currently involved directly in any of the six biodiversity offset pilots, and currently do not receive any funds from biodiversity offsetting. As mentioned in our earlier reply, we are looking carefully at how the biodiversity offsetting process is developing, as are many other organisations – it is not possible to say, just yet, if this will become an important area of activity for us.

  2. Lesley says:

    Dear Victoria, Thank you for the comprehensive reply I was seeking.

    I understand fully the legal instruments at work with regards our natural environment and I am concerned at the use of wording which suggest a lack of trust towards an established and fair legal system. ‘Percieved’ & ‘open to interpretation’ suggest a general ambigiouty towards legal status and in doing so lessen such status as determined within the common law system, one of much envy globally, and one that allows for an judgement according to place and the actors in that place. Trying to install statutory instrument instead would deter people from planting trees in the first place and furthermore disconnect people with what we desperately need them to reconnect with.

    With regards biodiversity offsetting I believe we are yet to see the true protest against this very silly nonsense, (and it is nonsense), and anyone involved will have their fingers burnt much more badly than those who have become involved in carbon offsetting and the unethical practice now leaching out with regards this.

    How anyone can dare assess any biodiversity anywhere in such a way when we are so far from understanding the complexities is wrong.

    And in your reply you use other examples of very fragile ecosystems ignoring the simple fact that all nature everywhere in the UK is valuable. I am not happy at your direction and understand the wider mounting criticism with regards the direction you are taking, which does seem to parry far too closely with many think tanks & Defra’s more extreme and frankly landscape fascist ideas.

    • Kaye Brennan says:

      Lesley – Victoria is away today, she has asked me to send her thanks over again for your views, and post a further reply on her behalf:
      The area of biodiversity offsetting is still emerging and it is too early to tell how effectively it will work in practice, but I think you are right to advise caution. We do recognise the value and importance of all natural habitats and also understand your concern over the risk of one habitat being traded for another. For us to be effective in delivering our objectives we have to find ways of working effectively with others in a complex environment. As to our overall direction of travel, we remain committed to our principles of protecting, restoring and enhancing ancient and native woodland and creating new native woods to help deliver protection and resilience through better habitat networks – such networks include woodland as one of many components. In doing this we seek to engage and inspire people, communities and wider society – this debate is all part of that process.

  3. Lesley says:

    Thank you for your response Victoria, but I remain confused.

    The Habitats Directive, which still stands, is absolutely explicit in its language and definition of what ancient woodland even referring to the UK within the text! Thus I really don’t understand your position at all, you are clamouring for extra protection yet stating this isn’t a good thing, do you imply we should be throughing the habitats directive in the bin, turn away from Europe and concentrate on specific and new legislation for Ancient woodland (and then some). There is some twisted logic in this because we can then introduce better protection for all trees – particularly hedgerow trees and urban trees which face huge threats but I cannot see any of your link allies being in favour of this.

    You also fail to answer my concerns with regards ‘mitigation’ which I think we can assume you mean ‘biodiversity offsetting’. Where do the Woodland Trust stand on this issue? Because whilst you quite rightly announced the absurdity of Justine Greens relocation of ancient woodland and are very opposed to exporting biodiversity you seem to be in favour of biodiversity offsetting in a particular location. Can I assume what you mean is that any other type of habitat is less important than ancient woodland and thus can be traded to create new woodland?

    • victoriabankesprice says:

      Lesley, you’re right – we are clamouring for extra protection but we aren’t saying that all designation is bad just that this is a flawed system that can be improved. Recognising that it’s flawed doesn’t mean that the Habitats Directive should be dismissed.
      As you will be aware, the EU Habitats Directive is implemented in the UK through the Conservation of Habitats and Species Regulations 2010, whereby sites are identified as containing either the habitats or species listed under the various annexes on the EU Habitats Directive and designated as Special Areas of Conservation (SAC). All SACs must first be Sites of Special Scientific Interest (SSSI) and like SSSIs they are a representative sample of the habitat, not every example of the habitat that occurs. Unfortunately, this can lead to a perceived designation hierarchy where developers seek to claim that SACs are better than SSSIs which in turn are better than Local Wildlife Sites… Undesignated sites (including ancient woodland) are thus portrayed as unvalued and open to development. Whilst the NPPF does say that any development that threatens ancient woodland must clearly show both need and benefit, these are qualitative and therefore always open to interpretation – we have found (with similar wording under the old PPS9) that this wording does not stop ancient woodland being destroyed in reality.

      With regards to mitigation and biodiversity offsetting – these are two separate things. Where it is not possible to stop losses, we want to see woodland loss mitigated for. Under the current planning system, there is no reliable mechanism to enable work to be done to mitigate the environmental damage of a development on other land, if a developer does not have enough scope to do this on-site. Whilst too much development is being given permission that results in biodiversity loss, we believe the use of ‘biodiversity offsetting’ may enable some development to achieve biodiversity gain (or at the very least be biodiversity neutral). It is early days for this new approach and it’s being trialled in 6 areas across England. The Trust is involved in assessing its benefits – however, we do have some concerns. We believe that no irreplaceable habitat should be part of the equation; this includes ancient woodland but also (for example) peat bogs, raised mires or limestone pavement. Offsetting is likely to include a mechanism to represent the value of habitats and the difficulty in recreating them. And as my blog says, that locality and appropriateness should be a consideration – there is no equity in removing 20 ha of 100 year old water meadow in Worcestershire and replacing it with 20ha of tree planting in Northumberland.

      Please don’t assume that we consider other types of habitat to be less important than ancient woodland and that they can be traded for new woodland – ancient woodland cannot be replaced and new planting does not make up for its loss. However, the Woodland Trust is a conservation charity established to champion the habitats associated with woodlands, so ancient woodland in particular, as a rare and precious habitat, will always receive special attention.

  4. Lesley says:

    I am baffled – on the one hand you agree with the analysis of the ‘ghettoisation’ of designated land, yet on the other complain of a lack of protection for the one habitat which is assuredly more protected under the NPPF than any other – woodland? Has the UK withdrawn from the legislative EU Habitats Directive? NO, but perhaps the use of the more international word ‘forest’ within the text of the EUHD has confused you. Myself am confused by this awful term ‘ghettoisation’ which in itself is a term which should be challenged – it is the fragmentation of landscapes caused through designation (and subsequent funding disparity) that is wrong and needs to be redressed as the ELC (another legislative document ratified by the UK) states. The Policy Exchange document is heavily flawed, from beginning to end and what really concerns me about the Woodland Trust and the direction it is heading is in regards the manipulation of wording to promote biodiversity offsetting by using the word ‘mitigation’. You do not want to see these funds send abroad but are happy to sit with ecosystem services acting as a benchmark value to offset from on home territory, when it is and has been pointed out frequently that it is an insurance value to help prevent – and in the case of trees such a value existed before the UKNEA by way of the Capital Asset Value for Amenity Trees (CAVAT) which can and is being used at this moment in time as an insurance paid by those who damage trees to enable new planting – a little something the LPAs can use to help bolster their diminishing budgets for tree planting which means felling dangerous trees to avoid litigation but having no funds to replace them.

    • victoriabankesprice says:

      Many thanks for your interesting response Lesley. You made a very good point regarding the problems associated with habitat designations. We totally agree with you that relying on designation alone is a flawed approach. However in our experience no one has come up with a better system of protecting our irreplaceable habitats. As the population and pressure on space and resources continues to grow so will the pressures upon the environment. As such as the UK’s leading woodland charity we would like to see ancient woodland offered the increased protection that a formal designation brings. Sadly through past experience with PPS9 we believe that the wording on ancient woodland protection in the NPPF is very much open to interpretation, as such we will continue to push for the increased protection of ancient woodland.

  5. Sugel says:

    Planning Policy Statement 9: Biodiversity and Geological Diversity highlights the importance of Ancient Woodland, advising that “once lost it cannot be recreated”. In addition to requiring local planning authorities to identify ancient woodland, it states that planning permission should not be granted “for any development that would result in its loss or deterioration unless the need for, and benefits of, the development in that location outweigh the loss of woodland habitat”.

  6. Ed Burton says:

    Completely agree, it is impossible to mitigate for the loss of these habitats. Where woodland is lost it should be replanted as close to the original site as possible. The community and local ecosystems will not benefit from any overseas planting and most of all how can we monitor it? Will we even know it has been planted?

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