Where should any new habitat go?
The fundamental principle underpinning the concept of biodiversity offsetting is that when a planning decision is made that involves loss of habitat, there will be compensatory habitat created or restored somewhere else.
But (putting aside the questionable planning decision-making process) one of the key questions as a result of this decision is; what determines where that habitat is created or restored?
If we start at the extremes: habitat loss in the UK should not be offset overseas. Just because the Government has committed to supporting biodiversity in the UK Overseas Territories does not mean that we should be replacing trees lost in Kent by planting a new wood in St Helena. We have been reassured by Defra that offsetting internationally has been taken off the table, but of course we are not complacent so we are still lobbying on this point and others.
But how close to the original site is acceptable, and what factors should be taken into account?
The consultation asks the question in the following way, with our response at this stage below:
- Do you think there should be constraints on where offsets can be located? If so what constraints do you think should be put in place?
Any offsetting should be as local to the original as possible (including within developments themselves). Access to natural spaces is a key issue for the Woodland Trust, we believe that everyone should be able to access woodland within easy reach of their homes for all the benefits that it delivers both physically and mentally. We developed the Woodland Access Standard to both measure that deficit, and to look at the potential to address the problem. The metric, the mechanism by which the amount of habitat to be created is calculated, should use ‘localness’ as one of the key factors when determining offset scale i.e. increased distance from original damage should incur a penalty and more habitat required to be created.
But there are possibly two opposing forces in action here; what is best for people and what is best for biodiversity.
The Labour Government initiated an independent review of England’s wildlife sites and ecological network chaired by Professor Sir John Lawton, which was continued when the coalition came to power. ‘Making Space for Nature‘ was the final report which looked at how to increase the value of our existing conservation efforts. It identified a number of measures which were helpfully shortened to “More, Bigger, Better and Joined”. Fundamentally the report argued that we could no longer rely on the network of protected sites within England to save biodiversity for the future and that we needed to be much more strategic in our approach to achieve a coherent and resilient ecological network, capable of responding to the challenges of the future.
Again, the Green Paper asks a question re Making Space for Nature:
- Do you agree an offsetting system should apply a strategic approach to generate net ecological gain in line with ‘Making Space for Nature’? If so, at what level should the strategy be set and who by? How should the system ensure compliance with the strategy?
Using the principles identified in Making Space for Nature should be a key part of delivering a functioning offsets scheme.
This would require the use of biodiversity opportunity maps and the recently developed Local Nature Partnerships to provide strategic guidance on what the area needs and where. Again, as with localness, the metric, which calculates amount of compensatory habitat, should play it’s part here with less habitat required to be created if Lawton principles are followed.
But this hasn’t really addressed the dichotomy between how to deliver the best outcome for people and wildlife.
The Government’s own strategy on biodiversity, Biodiversity 2020: A strategy for England’s wildlife and ecosystem services, identifies both issues and sets priority actions for both. Interestingly, the Green Paper on Biodiversity Offsetting does not refer to the Government’s Biodiversity Strategy (“A vision for England; …our biodiversity will be valued, conserved, restored, managed sustainably and be more resilient and able to adapt to change…”) but that’s an ongoing argument for another day.
However, the Biodiversity Strategy does identify a ‘priority action’ for planning which may answer some of these issues:
Planning and development
Priority action 3.4: Through reforms of the planning system, take a strategic approach to planning for nature within and across local areas. This approach will guide development to the best locations, encourage greener design and enable development to enhance natural networks. We will retain the protection and improvement of the natural environment as core objectives of the planning system.
The answer is in Local and Neighbourhood Plans, getting the spatial planning right in the first place so that applications can be judged against the right priorities and making sure that Local Nature Partnerships map are an integral part of the process. We all have a part to play in this process, democracy is both a blessing and a curse!
You can tell Defra what you define as ‘local’ through our campaign (there are several opportunities to get involved, including saying “No” to the principle of offsetting entirely) as part of the Green Paper consultation.
I will return to more of the key issues and explain some of the risks and opportunities we see in the proposed scheme in further blogs, in particular:
- Management and compensation packages in an offsetting scheme
In the meantime you can find further information about the consultation, and our concerns, here. We all have until November 7th to get our responses in! Please add to the debate below – but do make sure you tell Defra what you think too!
Frances Winder, Conservation Policy Adviser