EMTF second phase research: Opportunities for UK business that value and / or Protect
Nature.
IEMA comments on EMTF DISCUSSION PAPER Opportunity 1: Biodiversity Offsetting
The following evidence and comments are not made either ‘for or against’ the opportunity but are
provided as relevant constructive information. This feedback is partly based on engagement with
IEMA members1 (environment and sustainability practitioners) during 2012 through initial workshops
and webinars concerning valuation of the natural environment. It also draws on IEMA work from
other topics with relevant learning outcomes and IEMA responses to Defra consultation (2011) and
the APPG Biodiversity (2012)
1. The EMTF discussion paper sets out some strong scenarios in relation to scale of potential
benefit, which if correct could significantly contribute to ‘Lawton’ context of re-establishing
ecological networks. Clearly a central requirement in any such market development is
confidence. In this regard, some real and direct parallels can be drawn to early stages of
carbon offsetting and where our members helped confirm understanding around critical
issues that limited early market uptake2. It is clear that a number of similar concerns exist
today as factors that may limit the growth of biodiversity offsetting and will need to be
addressed in any future formal scheme and associated structures.
2. A significant difference between carbon and biodiversity offsetting is the relative ease of
carbon measurement in contrast to the (even) more challenging task of trying to assess
biodiversity ‘equivalence’. Although voluntary carbon offsetting standards appear to have
improved with a subsequently more mature and accepted market, some stakeholders will
not immediately accept carbon offsetting as directly equivalent. It is clear that this
‘stakeholder doubt’ will be even stronger in biodiversity offsetting (especially if an ex-ante
approach is followed). In this context and also to address additionality and other concerns,
we would advocate that biodiversity offsetting is not advanced just on an equivalence basis
and a ‘net gain’ principle should be the schemes overall aim (potentially set at a ratio of 2:1).
3. IEMA submitted earlier evidence on biodiversity offsetting to both Defra and also to the
APPG Biodiversity (copies available on request). Within our responses we stressed the
importance of the mitigation hierarchy approach and need for confidence on issues such as
additionality, permanence, protection to local wildlife sites, doubts over funding levels, etc.
We do not see any significant market materialising unless confidence is ‘built in’ on these and
other issues from the outset.
4. Lack of opportunity for valuing the natural environment (through fiscal or working value) is
being recognised by practitioners as a barrier to progress in some situations3. Interest does
exist from many practitioners we have engaged (through workshops and webinars) in a
robust and credible approach to biodiversity offsetting that will follow the mitigation
hierarchy, contribute to ‘net gain’ and address key concerns.
1
www.iema.net - IEMA is the largest environmental professional body with over 15,000 members.
IEMA - GHG Management and Reporting: Special Report – September 2010. - IEMA GHG Report 4.10.10.pdf Appendix 1 q30 set out practitioner responses on key issues that had “limited the take up of carbon offsetting by
organisations”. Parallels exist to current context for biodiversity offsetting (similar issues limiting potential).
3 Workshop write up – July 2012 - http://www.iema.net/readingroom/articles/natural-environment-workshop
2
5.
Skills, training, resources and capacity are important considerations in the development of
any formal offset scheme. IEMA members are active across the process from Impact
Assessment of development sites through to offset sourcing and commissioning, offset
project development and planning consent and monitoring. In the context of any potential
scale up (e.g. under a mandatory or formal scheme) IEMA and other stakeholders have
raised concerns about skills capacity for biodiversity offsetting. This skills / capacity need is
not limited to assessment but is across the full process (i.e. from creating effective offset
projects through to skills and capacity within planning departments).
6. The discussion paper outlines the potential for a biodiversity offset system to be an effective
hub (box in the middle) around which other ecosystem services might be valued and traded.
IEMA is interested in connections that can be made between PES type schemes. There
appears to be current opportunity for investigating synergy with the woodland carbon code
and potentially with some ‘catchment based’ PES schemes with water quality outcomes. We
are not however confident that biodiversity offsetting will or should be the central hub. The
opportunity may instead be for other PES schemes to adjust and to ensure that stacked
biodiversity components can be sold on as legitimate additional offsets (whilst ensuring
further net gain in a Lawton context). We do agree that this area of wider PES synergy
should be investigated.
Further comments / questions •
•
Is it realistic to expect sellers of land to absorb costs of offsets rather than developers?
Possibly with time this will work through but in early initial stages this seems unlikely? The
Defra Impact Assessment also provides some information on this issue with indication of
some costs on developers in the early stages.
We would question the assertion that there will be significant increase in (on site) net
developable area (NDA). If a mitigation hierarchy approach continues then on site
mitigation and enhancement will continue to draw on the NDA.
Nick Blyth, Policy and Practice Lead IEMA.
December 2012