Biodiversity Offsetting – Thank you, everyone

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”.[1]

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

[1] Department for Communities and Local Government (March 2012) National Planning Policy Framework (NPPF) para 118 (CD 3.1)


About Kaye Brennan

Trying vegan, staying warm. Occasional bursts of words.
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8 Responses to Biodiversity Offsetting – Thank you, everyone

  1. Pingback: Legislation would enable all of us to do more. | Woodland Matters

  2. Pingback: Biodiversity Offsetting

  3. Jacquie Cox says:

    “MPs demand delay in biodiversity offsetting – ENDS

    By Simon Evans
    12 November 2013 12:40 GMT

    DEFRA should wait before introducing a system of biodiversity offsetting in England, according to a committee of MPs.

    Offsetting compensates for damage caused during development through nature improvements elsewhere. In September DEFRA said it wanted to bring in a voluntary national scheme for England. It planned to finalise the policy by the end of 2013.

    This would be premature, says the House of Commons Environmental Audit Committee (EAC). Offsetting is being tested in six pilots and these will not finish until April 2014.

    The pilots “should be allowed to run their course” and then independently evaluated, EAC’s report says. DEFRA should only proceed with offsetting if this evaluation finds them to have been beneficial, the MPs add.

    At a 6 November meeting in parliament environment secretary Owen Paterson appeared to play down the pilots’ relevance. He said “I’m not sure they are going to really reflect what would happen if we had a full system up and running.”

    Paterson refused to say if he would wait for the pilots to finish before forging ahead. But he admitted to ENDS that his department would be hard pushed to publish a white paper by the end of this year, as had been planned.

    Delay had become inevitable. DEFRA’s offsetting impact assessment was rated “not fit for purpose” by the government’s Regulatory Policy Committee (RPC) in an opinion published on 30 October.

    The opinion said DEFRA should explain why it preferred a voluntary approach to offsetting when all other policy options including ‘do nothing’ would have higher societal benefits.

    The opinion also said the impact assessment should draw on evidence from the offsetting pilots. The RPC told ENDS that without evidence from the pilots “DEFRA will need to ensure the impact assessment is supported by a strong alternative evidence base.”

    The RPC cannot block policies but its “red” opinion will influence the progress of offsets through cabinet. The RPC told ENDS that DEFRA should submit a revised impact assessment to address the concerns raised “prior to final policy clearance”.

    The EAC criticises the substance of DEFRA’s offsetting plans as well as the timing. Running through the green paper is a lack of “clear and evidenced analysis” on how the scheme will achieve its aims, the MPs say.

    They call the proposed metric for measuring biodiversity damage “simplistic”.

    DEFRA’s green paper says that the metric “can be applied to a site in as little as 20 minutes”. EAC committee chair Joan Walley says it “appears to be little more than a 20 minute box-ticking exercise that is simply not adequate”.

    The EAC says rigorous environmental protection should be the priority for the metric, not its speed of application. It would like the system to account for the importance of ecological networks, the presence of protected species and the impossibility of replacing certain habitats such as ancient woodland.

    Environmental consultant Jo Treweek was one of the architects of the DEFRA metric. She told ENDS earlier this year that it should have been ground tested and refined as part of the pilots.

    The EAC says offsetting metric assessments should be audited by local planning authorities and the details published. It thinks this transparency and independent validation would help to earn public trust in the scheme.

    Councils should be allowed to recover the cost of this and other offsetting work from developers, the EAC says. If not, the Treasury should provide extra funds.

    Natural England should be asked to monitor the supply of offsets to make sure a good balance of habitats is being provided. Again, this should be adequately funded.”

  4. Reblogged this on Women in Planning – London and commented:
    Interesting blog too follow!

  5. Ash says:

    Is it possible that the Defra synopsis report in December could be written in such a way as to please everyone, but leaving out or concealing the more onerous elements of a full report? Peter is right, everyone needs to be vigilant! Politicians of all brands, for that is what they have become (here today, gone tomorrow), can only see as far as the next election.

  6. Arb Guy says:

    In response to Rwthless comments, not all areas still have an abundance of brownfield sites available. I know that in the area i work, the Local Planning Authority had their Local Development Plan knocked back by the Planning Inpectorate because they were only allocating land for development within settlement limits and on brownfield sites. Unfortunately central governments population growth figures dictates that the LPA have to find land for 10,000 more houses here and this can’t be accomodated on brown field land or within settlement limits. Hence green field land will be allocated for housing. Its unfortunate, as we can’t afford to lose quality agricultural land, but if the Local Planning Authority is to get its development plan approved it must provide sufficient land. I here you say why have a development plan? Well we need development plans, with sound and objective policy’s on green infrastructure, trees & woodlands, etc to prevent poor and bad development happening. You need local planning policies to do this. To prevent the loss of woodland and important trees, including ancients and veterens, your LPA needs to employ and take heed of their tree officers and other specialist environment staff when looking at land to include in the development plan. I’m a LPA tree officer and i’m advising our planning policy team on what can’t be developed because of tree issues. If your LPA is going through this process at the moment, enquire whether they have specialist tree people advising on the suitability of sites to be included in your development plan and to make sure adequate tree and green infrastructure policies are included in the development plan. If their not doing that, you need to ask questions.

  7. Rwthless says:

    From discussions with a family member who was also related to a major developer, one may hope that Local Authorities will now stop offering Green Belt and ancient woodland areas for development where large amounts of brownfield sites are readily available.

    The quality of work coming from Defra for many years has maintained a consistently low standard, but under the present minister, they have undercut this standard. They are supposed to be planning land use for many years to come, but are accepting appeals from scallywags and carpet baggers.

  8. Peter Kyte says:

    We will need to very vigilant with the final outcome of the offset strategy, especially with Owen Paterson, who appears to put financial growth before any other consideration.

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