Wednesday 29 July 2020

Can ecological compensation schemes achieve “No Net Loss”? Scientists say NO

Earlier this month, the Secretary of State for Environment, Food and Rural Affairs gave a speech:
When we destroy nature, we undermine our very foundations. Every country faces a choice as they map out their recovery - store up problems by sticking with the status quo, or get back on our feet by building back better and greener. In our own country, nature has been in decline for decades.
If we are to protect species and habitats and also deliver biodiversity net gain, we need to properly understand the science to inform these crucial decisions. And we should ask ourselves whether the current processes are as effective or efficient as they could be.
Later this autumn we will be launching a new consultation on changing our approach to environmental assessment and mitigation in the planning system. If we can front-load ecological considerations in the planning development process, we can protect more of what is precious.
Many are concerned that "changing our approach to environmental assessment and mitigation in the planning system" means that we are heading towards a "deregulatory race to the bottom". They can hardly be blamed for thinking that, given Boris Johnson's recent claim:
Newt-counting delays are a massive drag on the prosperity of this country.

Needless to say, neither BBC News nor the Local Government Association were able to find any evidence that wildlife surveys were delaying development. Craig Bennett, head of the Wildlife Trusts, said "the PM's speech was pure fiction".

Given their concerns, 18 charities have now called for "locally accountable and democratic" planning rather than further deregulation.

The letter says: “Further deregulation of the planning system would erode the foundations of any green and just recovery long before the first brick is laid. Nowhere else in the world is such a deregulatory race to the bottom being considered.
“It would be completely out of touch with the public mood, when two thirds of people reported wanting to see greater protection and investment in local green spaces after lockdown. This surge of appreciation for quality local green spaces is just one indicator of the increased appetite for action to tackle the housing, climate and nature crises head on.”
Crispin Truman, chief executive of the Campaign to Protect Rural England, said: “Environmental impact assessments are the foundations for this, protecting not only vulnerable wildlife and nature but landscapes, our built heritage and our health.”
As it stands, the NPPF says:
170. Planning policies and decisions should contribute to and enhance the natural and local environment by: ... d) minimising impacts on and providing net gains for biodiversity, including by establishing coherent ecological networks that are more resilient to current and future pressures;
Only 12 months ago, updated Planning Practice Guidance on the natural environment was issued, with much reference to biodiversity net gain:
The National Planning Policy Framework encourages net gains for biodiversity to be sought through planning policies and decisions. Biodiversity net gain delivers measurable improvements for biodiversity by creating or enhancing habitats in association with development. Biodiversity net gain can be achieved on-site, off-site or through a combination of on-site and off-site measures. It may help local authorities to meet their duty under Section 40 of the Natural Environment and Rural Communities Act 2006.
Indeed, new biodiversity net gain duties were introduced for councils and developers:

The government's response to a consultation on biodiversity net gain proposals outlines a number of new requirements for local authorities and applicants in an effort to make sure future development improves the natural environment.
The guidance suggests that measures to achieve net gain may involve creating new habitats, enhancing existing habitats, providing green roofs, green walls, street trees or sustainable drainage systems. But it makes clear that the policy does not override existing protection for designated habitats. Councils also "need to ensure that habitat improvement will be a genuine additional benefit, and go further than measures already required to implement a compensation strategy", it adds.
Net gains for biodiversity sounds great, doesn’t it? Who could disagree with that?

But let’s see how net gains for biodiversity works in practice. Let’s look, for example, at a planning application for a sand and gravel quarry in East Devon; let’s look at Aggregate Industries' planning application to quarry Straitgate Farm:

The last time anything of substance happened with this application was in 2017. In that year, Devon County Council issued a Regulation 22 request to the company, asking a range of questions, including:
The MPA requests in tabular form an ecological balance sheet clearly setting out losses and gains of habitats (and a clear timetable for gains to be implemented) in the context of issues the issues raised in this Reg 22 request. The information submitted is confusing, particularly in the light of requests made by the airport. 4.5
Through its ecology consultants, the company responded:
The Biodiversity Impact Assessment is summarised in Table 2-1 and Table 2-2. Based on the Phase 1 Habitat Survey, and the proposed development footprint, the application site represents 130.06 biodiversity units before development, and 183.96 after development; a net gain of 53.90 biodiversity units. 2.15
Amazing stuff. As if by magic, a net gain for biodiversity is conjured up.

Clearly it's all bonkers. Many will rightly wonder how something as invasive and damaging as a quarry can achieve a net gain for biodiversity. Many will rightly wonder how such a net gain can be calculated with such certainty and such precision, and to two decimal places too.

It’s all smoke and mirrors. As we wrote in our response at the time:
Quite how ripping out 1.5km of ancient hedgerow up to 4m wide - habitat for EPS dormice and bats, felling 6 mature oak trees, removing 6000m2 of advance planting objected to by the airport, not restoring for 10-12 years, and replacing natural history hundreds of years old with saplings and tree tubes, can show a net biodiversity gain defies logic and common sense. 74
But it’s not just us who questions the jiggery-pokery of ecological compensation schemes. Scientists, including from the Universities of Oxford and Cambridge, have recently published a paper:
Sonter, L.J., Simmonds, J.S., Watson, J.E.M. et al. Local conditions and policy design determine whether ecological compensation can achieve No Net Loss goals. Nat Commun 11, 2072 (2020).
It's worth noting the Introduction:
Halting biodiversity loss and securing ecosystem services are fundamental challenges facing humanity. While industrial development is often important for pursuing economic goals, it places immense pressure on ecosystems. In response, many nations have adopted ecological compensation policies to address the negative impacts of development projects, often in an attempt to achieve “No Net Loss” (NNL) of biodiversity and other related goals, such as securing the provision of ecosystem services valued by local people. These policies invoke the “mitigation hierarchy”, where biodiversity losses from development are first avoided wherever possible, then minimised and remediated and, finally, offset to generate commensurate biodiversity gains elsewhere. Hundreds of compensation policies exist worldwide, including corporate standards and requirements set by financial institutions; yet, their contribution to conservation goals remains uncertain at global, national and even local scales. Indeed, some compensation policies appear to facilitate ongoing biodiversity losses and cause further damage to ecosystem services.
The paper examined the effectiveness of different forms of ecological compensation schemes for developments such as palm oil plantations or mines in achieving "No Net Loss" of biodiversity. It found that, no scheme achieved no net loss:
We use spatial simulation models to quantify potential net impacts of alternative compensation policies on biodiversity (indicated by native vegetation) and two ecosystem services (carbon storage, sediment retention) across four case studies (in Australia, Brazil, Indonesia, Mozambique). No policy achieves NNL of biodiversity in any case study.

That’s something to bear in mind when consultants working for Aggregate Industries – reading tea leaves or whatever other mumbo-jumbo – claim:
the application site represents 130.06 biodiversity units before development, and 183.96 after development; a net gain of 53.90 biodiversity units.
But, to be fair, it’s not just Aggregate Industries; all developers are at it. No wonder our planet's in a mess.

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