Many thanks to all of you who took part in our recent Offsetting campaign! Over 900 Trust supporters had their say about plans for a scheme in England through one or more of our 4 campaign options, and, to make doubly sure Defra listened we referenced and attached your comments from the ‘Offset This’ action and the ‘Just say No’ action in appendices within the Trust’s formal submission.
Our question about whether a habitat should be replaced on a ‘like for like’ basis (e.g. a forest for a forest, not a wetland) saw 94.5% agreeing ‘Yes’ – mostly those who disagreed did so on the basis that they felt a habitat simply cannot be recreated elsewhere. 276 people said a clear “No!” to the principle of a scheme, and we (anonymously) shared the personal views given as part of this, plus the 258 responses the ‘Offset This’ action which asked what people ‘value’. We also included the chart below, created from the 586 responses we received, to show people’s preferences of where a habitat should be sited:
Even though we were not aiming for length our response ended up being 20 pages long, plus many pages of appendices. We thought you would like to read the summary we included:
“Development has long been recognised as one of the major threats to biodiversity with continuous efforts to include awareness of such environmental implications in development control policy. For example, the National Planning Policy Framework clearly states:
“planning permission should be refused for development resulting in the loss or deterioration of irreplaceable habitats, including ancient woodland and the loss of aged or veteran trees found outside ancient woodland, unless the need for, and benefits of, the development in that location clearly outweigh the loss”.
Despite successive biodiversity and sustainable development guidance to protect irreplaceable habitats there are currently 384 ancient woods under threat in England. There are a number of potential reasons for this anomaly but a key issue is the lack of understanding of the value of habitats and species.
If done properly, we believe biodiversity offsetting has a role to play in improving the recognition of the importance and value of green space for both people and wildlife. However, we firmly believe that compensation must be considered only as a very last resort – only once the potential to avoid any environmental damage, and to mitigate any damage, have been given full and proper consideration. We also firmly believe that irreplaceable habitats, like ancient woodland, can never be replicated or created elsewhere and therefore should not be considered within the scope of offsetting proposals.
The Woodland Trust believes that for any offsetting scheme to be effective there are a number of principles that need to be enshrined within the scheme:
The mitigation hierarchy must be followed – all planning proposals should undertake a clear and recognisable assessment of the full impacts of the development on the environment and take steps to use the mitigation hierarchy to avoid and reduce impacts wherever possible.
Only those projects where it is agreed by all parties that there is a residual environmental impact that cannot be mitigated in any other way should then be requested to submit an offsetting assessment.
Any offsetting scheme should apply to all development including Highways and major infrastructure projects.
Consideration of an offer of off-site compensation should not be part of the decision-making process – an application should be judged on the balance of need and benefit against the environmental damage caused.
Offsetting should be part of a nationally recognised scheme with scientifically based metrics that take account of the value of both species and habitats. However, the opportunity should remain to vary local targeting of both donor and receptor sites in the light of biodiversity knowledge. Local Nature Partnerships (LNPs) could have a key role to play setting local priorities within a national framework.
Any metric to value the biodiversity lost must build-in a realistic evaluation of social equity for both biodiversity and people – a robust, national metric for ecological and social considerations should include cumulative impacts and environmental limits; the limited experience of metrics from the pilots is one key reason why the pilots should be completed and evaluated before any wider roll-out of an offsetting system.
Any offsetting site should be as local to the original as possible (including within developments themselves), so that planning policy supports the Government’s policy of maintaining the interaction of people with nature.
Offsetting should be part of a regulatory framework that delivers scientifically valid evaluation and monitoring
Receptor sites and their management must be agreed for a minimum of 25 years but preferably in perpetuity.
So what happens next?
Defra has told us that it received 316 responses to its online survey, on top of written responses to the Green Paper like ours which many NGOs and others will have submitted. Now it is up to Defra to analyse every response received and assess the answers to the questions they asked. We understand the intention is to produce a short synopsis report in December.
Owen Paterson, the Secretary of State, has said that he is looking for an opportunity to take a fully worked-up Biodiversity Offsetting Bill to Parliament in May next year for the Queen’s Speech. The Bill will probably be quite light on detail, so whilst we tackle the issues that are going through the Parliamentary process – e.g. ‘mandatory’ versus ‘voluntary’? – we will also be lobbying Defra to get the right details included in any guidance – e.g. ‘what goes in the metric’?
Thank you again for your input to this important debate and to the proposed scheme. Your views and responses to our campaign and to the official survey have added real depth to the questions a potential scheme poses, and given both us and the Government a clear indiction of how people feel these changes might impact on their lives. We have really appreciated your time and efforts. Watch this space for an update in December!
Frances Winder, Conservation Policy Adviser
 Department for Communities and Local Government (March 2012) National Planning Policy Framework (NPPF) para 118 (CD 3.1)