Biodiversity Offsetting – some related issues

Independent conservation expert Miles King provides the second in our guest views on Government plans for biodiversity offsetting scheme, as part of this blog series which complements our current campaign.

“Frances and I worked together trying to influence the policymakers dreaming up this stuff while I was at The Grasslands Trust. Sadly TGT went bust a year ago, for the simple reason that people find it more difficult to relate to, and therefore value, grasslands than woodlands.

Frances may have been being a little mischievous when she asked me to write for this series as a) she knows I am likely to present a slightly controversial perspective and b) she knows how much I disliked working on it. I have blogged on the subject in the past, and I don’t intend to go over this ground again. I also enjoyed reading Frances’ recent blogs, and there is certainly a risk that I will go over some of the ground that her excellent blogs cover.


I have a real problem with biodiversity offsetting and it’s this: biodiversity offsetting is predicated on the creation of a market in tradeable biodiversity credits – a classic neoliberal approach. I simply don’t believe it is ethically right to impose a market-based system onto the conservation of nature. Markets fundamentally derive value according to the rules of supply and demand. The scarcer a product is, the more valuable it becomes. Applying this logic, the rarer elephants become, the more valuable is their ivory. This makes it even more likely that the last one will be killed for its ivory, because it will be worth a fortune. And this is exactly what is being played out now with the Bluefin Tuna fishing industry. This is the opposite of conservation.

Still, the Government has clearly indicated its enthusiasm for Offsetting and published its Green Paper in September. As I don’t currently work for a conservation NGO, I don’t have to bury myself in the detail of the consultation in order to craft a suitably detailed response. This means I am in the delightful position of being able to cherry pick amongst the proposals being laid out in the paper. It also gives me an opportunity to write about some related issues that have not been considered in the paper:

Securing Biodiversity Gain

This is an example of the kind of jargon which I find causes my skin to crawl. But we know what it means – taking a piece of land, doing stuff to it which means it has more natural value after we’ve done the stuff, than it had before. The stuff could be sowing a wildflower mix, planting trees; or modifying the way the land is managed, for example ceasing to apply nitrogen fertiliser, herbicides, ceasing or introducing grazing etc. It’s important to distinguish between these two acts – creation and restoration. Although of course there is a large grey area between the two.

A recent example made me wonder whether we also need to start talking about the pros and cons of securing long term gain and short term gain. Many habitat creation or restoration projects (that don’t involve trees) deliver short term gain: agri-environment schemes for example, pay for 10 years worth of habitat creation; then the farmer or landowner decides to do something else and that 10 year old habitat project is lost. And of course 10 years of habitat creation is a good thing on one level. But when it comes to for example buffering surviving high quality sites from adjacent intensive land management, temporary fixes are insufficient. Likewise, expanding areas of high quality habitat to sustainable levels requires permanently altered land management, not temporary changes. And ultimately we know that the area of wildlife habitat in England has dropped well below the level that is large enough to sustain the wildlife we have, so we need far more permanently restored habitat.

Recently Solar Farms have been springing up in the countryside, thanks to generous subsidies. RSPB propose that short term biodiversity gain can be easily achieved under the panels by sowing wild-bird food seed mixes, or pollen and nectar mixes. In this way the habitat created is analogous to an annual crop. Others recommend creating a permanent grassland habitat under the panels, with native wildflowers, grazed by sheep. But there’s a problem: create a good quality piece of grassland and it might be recognised as “priority habitat”, and then the farmer might not be able to return the field to cultivation at the end of the 25 solar farm lease. The land might have effectively been sterilised by the habitat creation project. This is actually putting off landowners from having habitat creation projects under their solar farms, or steering them towards the wild bird-food approach.

Should this two-tier approach to habitat creation be recognised within biodiversity offsetting? Offsetting could be advantageous if it makes a larger contribution towards long term habitat creation than, for example agri-environment schemes.

Image: North East of Place

In England, as in most of Europe, nature and culture have been inextricably intertwined for millennia. This interaction contributes hugely to a Sense of Place. Ancient churchyards are a great example of this. Churchyards are often havens for wildlife, having escaped the intensification of land-use that has modified so much land in the past couple of centuries. The reason they have survived is because they are valued so highly for their community and spiritual values. While bats may not necessarily always be welcomed in churches (!), very few people bother to scrub lichens off old headstones; and thanks to organisations like Caring for God’s Acre, attitudes towards close mowing of churchyards are also changing, allowing churchyard meadows to flourish.

Similarly, small green spaces in towns and villages, even post-industrial sites in Cities, acquire a value for contributing to the Sense of Place. This is an emergent property arising from the interaction between local communities and the nature, history and human use of these places.

Defra has developed simplistic, arguably inane, metrics for calculating how many units of biodiversity will be lost, for which compensation is needed. But this takes no account of the contribution that biodiversity makes to the Sense of Place that may be shattered by an inappropriate development.

Shifting Base-Line

The whole approach to Biodiversity Offsetting assumes that the current level of biodiversity on any given site, or indeed at any scale, is an acceptable starting point. But is this really justifiable? If offsetting had been introduced 50 years ago, when there was so much more, better quality habitat around, the bar would have been set many times higher than it is now. Should we accept that offsetting only has to consider what occurs on the site at this particular time, or should we be striving to restore our habitats to a higher level?

Developers tend to sit on land banks for considerable periods of time before developing them. Given that the criteria for determining how many biodiversity credits need to be purchased includes habitat quality, area and the rather vague notion of distinctiveness, it must be in the developer’s interest to ensure that their particular sites score as lowly as possible on all these counts. Although it might seem as though it is against natural justice to make the developer pay for the biodiversity loss caused by the previous owners, in fact this cost could be passed on to those very people, who generally make enormous unearned profits from the land-value uplift associated with converting undeveloped land into developed land.

Offsite Impacts

The proposals as they stand appear only to consider the loss of biodiversity as a result of activities within the scope of Planning law. This immediately rules out having any impact on agriculture, which continues to be the largest cause of decline in wildlife in England. Further, the proposals only apply to the direct impacts on development within the development footprint or “red line”, the boundary of the site. The knock-on effects are ignored.

I have recently started working for Footprint Ecology, an excellent ecological consultancy based here in Dorset. They specialise in assessing the impacts of visitor pressure on key wildlife sites, often European sites like Special Protection Areas and Special Areas of Conservation. As new housing developments are constructed, these new residents need a place to walk the dog, ride their bikes, or do other things. If the places nearby (generally around 5km for driving to walk the dog) happen to be important for wildlife, the extra visitor pressure will and does have a negative impact on that wildlife. These impacts are now well quantified thanks to Footprint’s excellent work (which I take no credit for.) Is Defra going to introduce visitor impact offsetting, alongside biodiversity offsetting? Well, in a few places, that is exactly what is being piloted, using things called Suitable Accessible Natural Greenspaces or SANGs. These are provided and wardening encourages people to make less use of the high nature value sites, and instead move to using the SANGs. These only apply to European protected sites though. Why not use this thinking more widely and apply it wherever new developments take place?


I noticed George Monbiot had written a piece for the latest Woodland Trust magazine, exhorting us to have elephants and rhinos back in Britain, presumably to keep the scrub down when upland farming has ceased. His vision of large areas of land given over to wild nature without any direct human intervention is an appealing one. Estimates of the area needed to sustain a self-sustaining population of wolves vary from 250,000 to 600,000 ha. Buying this sort of area of land from scratch these days would set George back upwards of £5-10Bn. Could this actually be an alternative approach to offsetting? If every land-use change (including agriculture) that reduced biodiversity had to pay a wilding offset (£10/ha upwards on a sliding scale), it might help George inch towards his target. Somehow I don’t think this is what the Government had in mind though.”

Miles King is a conservationist and commentator. He blogs at out for further blogs in this series.

We all have until November 7th to get our responses in about a proposed scheme! Please add to the debate below – and do make sure you tell Defra what you think too!


There are a variety of ways to help you take part including an option to simply say ‘No’ to offsetting in principle, to tell Defra your definitions of key terms, and to define exactly what it is that you value about the environment. In the meantime you can find further information about the consultation, and the Trust’s concerns, here.


About Kaye Brennan

Trying vegan, staying warm. Occasional bursts of words.
This entry was posted in Agriculture, Campaigning, Conservation, Consultation, Defra, England, Government Affairs, Planning, Planting and tagged , , , , , , , , , , , , , , , , , , , , , , , , , , . Bookmark the permalink.

9 Responses to Biodiversity Offsetting – some related issues

  1. Pingback: A new approach to Forest “Management” | Woodland Matters

  2. Pingback: Biodiversity Offsets and the Antique Woodland Roadshow | a new nature blog

  3. milesking10 says:

    Reblogged this on a new nature blog and commented:
    here’s yesterday’s blog, reblogged.

  4. Derek West says:

    Miles King makes some very worthwhile comments,what a pity he doesnt head DEFRA,in a highly
    populated England with a constant desire for economic growth the future for biodiversity is
    a low priority and has a uncertain future.

  5. Ash says:

    Brilliant! It is refreshing to read this post as it views the offsetting issue from a different angle. I need to read it again!

  6. Absolutely stunning article, full of references and general info and links – but hard-hitting too, and very readable.

    Thank you so much Kaye Brennan and or Frances, for asking for complementary contributions to your own campaign. And you clearly know who to ask!

    I hope someone will send this one to Prince Charles. He is not wholly free to speak, but I am convinced he will derive great solidarity from it, having read his book “Harmony”. He has a similar knack of delivering a punch as if it was a lovely cool glass of punch on a hot day!

    He is in a lonely place on his particular “Rebel Yell” – he has to keep the yelling very very polite and restrained.

  7. This shows the extent of the problem when mankind grows faster than the space on the planet and fails to recognize the right of other species to a habitat and very importantly to keep ourselves in balance with the natural world.

  8. Peter Kyte says:

    A well thought out and interesting article.

  9. Pingback: Biodiversity Offsetting – some further thoughts | a new nature blog

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