Friday, 8 August 2014

SINGAPORE HAZE - Environmental Offsets - Appenix 6


‘SINGAPORE HAZE’ - Submission to the Senate Inquiry into Environmental Offsets

Appendix 6 - a number of relevant reports

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Biodiversity offsetting will unleash a new spirit of destruction on the land

by George Monbiot   Dec 7, 2012

A place of outstanding wildlife value may be destroyed if in return someone is paid to create a habitat elsewhere.

Picture: Common nightingale (Luscinia megarhynchos): their highest concentration in the UK is found near Gillingham in north Kent, where the council is proposing to build 5,000 houses.

This post is about the dangerous new concept the government has seeded in the minds of developers and planners. The idea is called biodiversity offsetting. It involves trading places: allowing people to destroy wildlife and habitats if, in return, they pay someone to create new habitats elsewhere. In April, the UK government launched six pilot projects to test the idea, which would run for two years. Four months ago, I wrote this:

"The government warns that these offsets should be used only to compensate for 'genuinely unavoidable damage' and 'must not become a licence to destroy'; but once the principle is established and the market is functioning, for how long do you reckon that line will hold?"

The answer, it seems, is "not very long". A year and a half before the pilot projects have been completed, the new spirit of destruction is roaming the land. A place of outstanding wildlife value is now being considered for demolition, and biodiversity offsetting is being mooted as the means by which it can be justified. It's hard to believe that this scheme would still be receiving serious consideration if the mother of all excuses had not been proposed by the government.

Lodge Hill, close to Gillingham in north Kent, contains what could be the UK's highest concentration of nightingales. The species has suffered an astonishing decline in this country – over 90% in just 40 years – partly as a result of the destruction of its habitat. This site – of just 325 hectares – contains roughly 1% of the remaining population. It is one of the very few places where, on a summer's night, you can still hear the full nightingale orchestra, a sound that would once have been familiar to people across much of the country.

Medway council has proposed that the land at Lodge Hill be turned into a development of 5,000 houses. This, according to a report by the British Trust for Ornithology, could destroy the area's entire population of nightingales. Even if some birds continue to use the adjoining woods, they are extremely vulnerable to cats, as they nest close to the ground. The pets arriving with the new homes are likely to snuff out what John Clare called "the old woodland's legacy of song."

So how do you justify the unjustifiable? You commission a consultancy (the Environment Bank) to investigate the potential for offsetting: in effect moving the habitat and its nightingales somewhere else. It reported that:

"Offsetting could work in principle for nightingales in Kent – it is technically feasible but it is neither straightforward nor guaranteed"

If a site of around 500 hectares were found and stocked with suitable habitat, a similar number of nightingales might establish itself there. But no one can be sure it will work. If it doesn't, by the time we find out it will be too late: the new habitat will take at least a decade to establish, while the existing habitat will be destroyed and the houses built in just two or three years. If the experiment fails it cannot be reversed.

The report suggests two principal means by which new nightingale habitat could be created in Kent. One is to coppice existing woodland: cutting the trees at ground level so that they resprout to create the shrubby growth that nightingales use. The other is to take an area of agricultural land and either plant it with scrub or allow scrub to regenerate naturally.

This invites two obvious responses. If woods are chosen, the offsetting process would not be creating wildlife habitat, but merely changing an existing habitat into something different. Coppicing favours some species at the expense of others, particularly those which require large trees, dead wood and an undisturbed understorey. What's good for nightingales may be bad for woodpeckers.

If 500 hectares of fields – a bigger site than Lodge Hill – can be taken out of agricultural use to compensate for the destruction of the nightingales' homes, why not spare Lodge Hill and build the houses in the fields?

The prospect of offsetting in this case looks to me like the "licence to destroy" that the government warned against. Rather than compensating for "genuinely unavoidable damage" it looks as if it could be used to justify avoidable destruction: trashing a remarkable place for an unremarkable project which could be built elsewhere.

This case illustrates the danger inherent in the principle of offsetting. It makes nature as fungible as everything else. No place is valued as a place: it is broken down into a list of habitats and animals and plants, which could, in theory, be shifted somewhere else. It subjects our landscape and wildlife to the same process of commodification that has blighted everything else the corporate economy touches.

The notion of a "like for like" replacement is bogus. No two places are the same. No place that has been planned and measured and designed and planted as a wildlife habitat is the same as one that has arisen spontaneously, or that has always been there. Much of the delight of nature is that it is unscripted, spontaneous, unofficial, that it owes little or nothing to human design.

Accept the principle of biodiversity offsetting and you accept the idea that place means nothing. That nowhere is to be valued in its own right any more, that everything is exchangeable for everything else, and nothing can be allowed to stand in the way of the graders and degraders. That is not an idea I find easy to swallow.

Monbiot.com

SOME RELEVANT RESPONSES: 

Indicative of short sighted, modern governmental policy. It's amazing that the idea that humans can offset environmental destruction by trying to mimic nature and centuries of biotic and environmental interactions is laughable. I thought this idea had disappeared in the 70s? No consideration that the habitats of high biodiversity value are that because they have unique characteristics, (not easily reproduced) that make them suitable for supporting such diversity. Or, they've escaped centuries of development of the UK countryside and are little more than biodiversity islands. Planting a few thousand trees wont offset anything for decades, will absolve the government of all blame (in their mind) and result in considerably poorer British countryside. Look forward to seeing some ancient woodlands being ripped up, then a few thousand trees planted on a brown-field site with the cries of "Ah, but we're offsetting this development 50 miles away...".

Seriously, there is nothing in this piece with which I disagree. The scheme is a scandal and is clearly a question of convenience and money, which is no way to wildlife conservation. If you don't know what to do about it, the answer is to take the trouble to make yourself familiar with the detail and then protest in your own name and join in with the representations made by every conservation organisation, write to the government, find a credible politician who will make this a personal crusade, engage the attention of local councils, and generally make this case a cause celebre in the way that Greenpeace did with whales. Just do it!

The true unique "value" of a habitat and the biodiversity therein is always left out of the equation, whether the sums be about development or carbon. The same sort of thinking is used by those promoting big biomass projects. "We chop down this forest and burn the trees to produce energy, but don't worry we'll plant more trees thereby replacing what was lost" say the energy companies. "That makes it green and carbon neutral too". Err, it's not, see reports here. They replace old biodiverse forests which fulfil a whole host of functions, from managing water and soil cycles, to providing home to people, plants and animals that live and rely on it as an intact system, with sterile monoculture. Destroying wild places means less wilderness, more corporate management, more accounting, less diversity, less wonder. Is that really what we want? For most people the answer is a resounding no. Can we please just be smarter about this? Reduce our energy consumption, and overconsumption of so many resources. Stop allowing so many second homes and houses for investment purposes in our communities. Not allow developers to dictate policy... the list is endless. But the fight-back should start with each of us in our communities, each of which has something monstrous being planned to destroy the uniqueness of the place we call home and replace it with sterile monoculture.

We have exactly the same issue with exactly the same bird in fields next to our village in West Sussex. I counted 5 territories of singing males for the BTO nightingale survey this spring in some of the hedges threatened by development. They return faithfully to the same spots every year. Neighbouring fields and hedgerows are too heavily cut back, grazed, or disturbed to attract them. Once they're gone, they won't be back. I don't hold out much hope. One nightingale used to sing by our local rubbish tip until the Council 'improved' the land by cutting back the trees and brambles for people and their dogs to enjoy. The bird hasn't returned. Incidentally, I learned of one example of 'mitigation' nearby offered by developers, where the solution to destroying a peregrine nest site was to place a 10-foot-high metal post in the middle of a nearby field!

Excellent article George. Thank you for highlighting this. This is truly shocking, and the whole idea is based on profound ignorance of the biodiversity concept. It is not in any way, shape or form a genuine anything. It is an invitation to disingenuous justification. Where developers, the government and local authorities can assuage their guilt, with token gestures.The only thing that makes this idiocy possible, is the general lack of knowledge about biodiversity, natural history, and the basics of ecology in our society. So the damage we cause tends to be out sight, out of mind. This government is an environmental abomination. They should be prosecuted for fraud for their ‘greenest government ever’ whopping great lie.

The whole idea of offsetting is ludicrous. It basically boils down to carrying on as usual but paying. So CO2 continues to be emitted and biotopes destroyed but the perpetrators get a clean conscience and good press.

Must have missed this concept before. First reaction was 'sounds like a load of bollocks to me'. Now, having considered the concept, I can say 'What a total load of bollocks this is'. Monbiot hits the nail on the head when he says, 'The notion of a "like for like" replacement is bogus. No two places are the same. No place that has been planned and measured and designed and planted as a wildlife habitat is the same as one that has arisen spontaneously, or that has always been there'.These animals do not just choose a place to live like we choose a new house, they are often the result of environmental factors which are imperceptible to humans. This is pure human hubris, ignorance of nature and doomed to fail - unless success is defined as getting rid of populations of animals for human gain.

This would not be my choice of a strong example to challenge the benefits or otherwise of offsetting - or built development versus nature conservation. Protection against development for the nightingale in Chattenden Woods SSSI could have been given by designating the SSSI as a Special Protection Area. That this SSSI is not an SPA is because there are certain migrants or partial migrants like the nightingale that JNCC consider generally have a wide distribution, and which rarely aggregate in large numbers. You might throw your hands up in horror at that decision, but the statutory agencies don't seem much concerned, and the usual (unholy) alliance between them and the third sector doesn't seem to operate in the case of the nightingale.However, had this been heathland and nightjar/Dartford warbler, then Medway would be ripping up their Core Strategy Development Allocation, bringing in zoning that wouldn't allow any development within 400m (the Lodge Hill revision actually moved it from 50m out to 200m) and any development within 400m - 1,500m would have required compensatory habitat creation - for people! This would have been the Suitable Accessible Natural Green Space that would have been funded by developers contributions from each house, and which supposedly would take the recreational pressure off the heathlands. Moreover, these same third sector organisations in seeking even greater heathland restoration, responded to a suggestion for compensatory tree planting in the developing policy on deforestation to open habitats in England, that it would be OK if the compensatory planting was in ........Scotland! As always, wild nature will be the loser under the nonsense systems of values we have, and our presumption that wild nature is safe within farmland or any managed land. As will be the highly likely outcome of the Govs. response to the Independent Panel on Forestry report, there will be no slackening in the pace of shrugging off responsibilities for the natural environment onto the third sector, and using European funds to pay for that. They will also go ahead with their plans of merging NE, FC and EA, cutting staff by 90% - watch this space! Here's the Govs. latest wheeze in their strategy for ash die back, becoming an "ObservaTREE" (geddit?!) Can I be an "ObservaTREE" head monitor? Is there a badge?

George - excellent article that highlights some of the potential pitfalls and deficiencies of offsetting. However, Jowwbull and MarkNFisher (above) also raise some very pertinent issues that render the arguments far less cut and dried.The unique qualities of particular areas of habitat, and the many uncertainties and time lags with habitat creation, coupled with the possible unwillingness of target species to frequent created habitat, mean that like-for-like is a tenuous concept. However, we live in times where development, destruction,modification, etc., of natural/semi-natural areas is frequent, and unless legislation on a given species or vegetation type is watertight (and sometimes, even when it does appear to be thus), such areas can be destroyed or degraded with relative administrative ease. Offsetting may seem like the thin end of the wedge, but at least it is a wedge of some sort. Yes, the existence of offsetting may provide a more traversable path for a developer in some cases, but the destruction of habitats and ecosystems has taken place, and will continue, regardless of offsetting. Offsetting does at last provide an opportunity to make developers pay for their actions at one site by undertaking a range of actions at another. How does one possibly establish equivalent biodiversity 'value' though? I can't speak for mechanisms in the UK, but Australia has been grappling with this issue for a while and has an approach called biobanking, whereby a suite of conservation actions by a company or individual will allow them to earn biodiversity 'credits' that they can then use to offset damaging actions at another site. Your nightingale example seems to indicate that the offsets would be abitrarily selected and inadequate as 'compensation' (500 ha of arable land do not equal 325 ha of coppice woodland for nightingales). However, biobanking has a specifically developed metric that scores for features such as site size, condition (e.g. plant species richness, percentage weed cover, grazing impacts), landscape context, rarity of vegetation type(s), management actions to be undertaken, etc. No metric is ideal, but it does at least provide a transparent and objective (and scientifically underpinned http://www.environment.nsw.gov.au/resources/biobanking/09476biobankingscience.pdf) assessment of what like-for-like might resemble. You were right to raise the issues with offsetting, but they are still a legitimate tool for conservationists to make some gains or at least minimise losses. This is particularly the case when they are done well (objective, transparent, quantitative) and where they raise the effective price of a development such that In many cases, it may be too expensive to continue.

In Queensland in Australia the concept of biodiversity offsetting is glibly included in Environmental Impact Statements based on reports by ecologists in the employ of resource exploiting companies. No detailed and extensive research on the feasibility of offsetting what in some cases is a unique ecosystem (such as Bimblebox Nature Refuge, currently threatened by a huge opencast coal mine) is required for project approval at either state or federal levels of government. Neither are adequate follow-up monitoring procedures insisted upon to ensure compliance or success. Surely an offset should be established, and its success calculable, before permission for destruction and development of a habitat is given? That would never be a viable option for developers though, would it?

The idea that ecosystems that take centuries to develop can be recreated in a year or two shows a failure to understand what ecology is all about. Not only are the interactions between species immensely complicated, but they are usually unknown except in very broad terms. This is true of even well-studied species such as birds and mammals, but even truer of the smaller and far more numerous denizens - invertebrates, plants and fungi etc.: each with a role, but often an unknown one. It is sheer arrogance to think that a replica of an existing ecosystem can be created in a different place and in a short space of time, when knowledge is so limited. Any attempt will fail in some measure unless all the thousands of components can be (a) recognised in the old site, (b) captured, and (c) successfully introduced to the new site. And even if some semblance of the original does emerge, what guarantee is there that it is true facsimile. It simply won't be. The soil of an old woodland is heaving with life, and an utterly different thing to the sterility of an agricultural soil

The idea of "biodiversity offsetting" is not only self-evidently batsh*t crazy, but a sad example of the monetizing of the environment and wildlife, and where it leads. You don't have to be a full-on eco-warrior to realise that what's happening here is a convergence of interests between big government bureaucracy and corporate greed which, taken to to its logical conclusions, would lead to the privatisation and exploitation of every single resource and space in the world.

The stupidity of the notion of creating a habitat elsewhere, to offset the loss of habitat, is that no one has ever fully described a habitat or ecosystem, even a small one. Our knowledge is always imcomplete as natural ecosystems are so complex. Only those who see habitat and biodiversity in a very shallow way could think this would work. I think this government could do with some idiot offsetting, being they are depriving so many villages of their idiots.

The most vociferous proponents of biodiversity offsetting tend to be those with the greatest vested interest in destroying habitat coupled with the least degree of understanding about the intricate complexity of ecosystems. Essentially the ethos of such projects involves the utterly arrogant assumption that we can simply move important habitats to different locations when their existing position is of the slightest inconvenience. For a relatively recent review of the limitations of offsetting, one could do worse than examining the contents of this review:
MARON et al., 2012. Faustian bargains? Restoration realities in the context of biodiversity offset policies. Biological Conservation 155 (2012) 141–148.
http://www.lerf.esalq.usp.br/divulgacao/recomendados/artigos/maron2012.pdf

Readers concerned with the 'offsetting nature' implications of biodiversity offsets might be interested in the following Green House report. Hannis, M. and Sullivan, S. 2012 Offsetting Nature? Habitat Banking and Biodiversity Offsets in the English Land Use Planning System. Dorset: Green House. Abstract:  New planning rules, currently being piloted, allow the environmental impacts of increased development to be offset by purchasing conservation credits from habitat banks. This ‘green economy’ measure is presented as reconciling economic growth with environmental protection. Mike Hannis and Sian Sullivan explain where this controversial idea has come from, before asking what effects it might have and who stands to gain from it. They argue that by encouraging us to think that one bit of nature is much like another, biodiversity offsetting undermines the unique place-based relationships between people and nature, moving us further away from ecological sustainability.  Offsetting has been going on for the last twenty years, at least [translocation]. For example, you can rip out an ancient hedge as long as you offset it with some new planting elsewhere. Sometimes the planners don't even ask for offsetting for the destruction to go ahead. Before 'offsetting', the destruction would go ahead without any recompense. Ecological consultants work within a system where there is no sanctity of any part of the natural world eg. Trump Golfing. Yes, of course, as offsetting is now a central plank of planning/development then it can be abused for destroying anything - doesn't matter, just offset it. However, ecological science for the last thirty years has shown that translocation/offsetting rarely works satisfactorily. Anyway, with this government, nature conservation in this country is dying on its feet as well.

If they really insist on the principle of like for like replacement of habitats then they should carry out the work in the reverse order. i.e. first send in an independent team to assess what lives in the present habitat with regard to soil, bacteria, fungi, insects, worms, animals, birds, vegetation etc. Then build the new habitat as closely as possible to the existing one, transferring wildlife progressively to the new habitat. Leave it long enough to be certain that all lifeforms are thriving and migrating birds etc. are breeding and returning to the site. Only when the independent team have established that the transfer is complete and working should destruction of the existing site be considered.

"the dangerous new concept the government has seeded in the minds of developers and planners" So that’s what government has become, wholesalers and marketers of intellectually respectable justifications for a corrupt polity and in this instance incredible nonsense, nonsense that surely will be discarded and replaced with marketed rationalisations fresh and new when the old one has collapsed. Perhaps in the interests of persiflage this Trojan concept of offsetting could be applied to other areas, say for instance literature, councils could be encouraged to promote mass book burnings of selected classics and rare titles, but not to worry because even if all copies of a book disappear they will be offset because we will be encouraging writers to produce new works over there somewhere. If government policies in say the NHS cause your family to die, well don't worry about that because thats offset by our population policies and if we blockade and invade a country leading to deaths of millions of people guess what? Offsets. Offsets are not a policy but simply pernicious marketing.
 

 

6 May 2013, 6.35am AEST

Can we offset biodiversity losses?
CClive Palmer’s China First Coal Project is entering the last stages of review for its proposed coal mine in Queensland’s Bimblebox Nature Refuge. As part of the Supplementary Environmental Impact Statement…

Authors Megan Evans

PhD Candidate in Environmental Policy & Economics at Australian National University

Clive Palmer’s China First Coal Project is entering the last stages of review for its proposed coal mine in Queensland’s Bimblebox Nature Refuge. As part of the Supplementary Environmental Impact Statement (SEIS), the proposal suggests protecting about two hectares of remnant bush for every one hectare of the nature refuge that is affected by the mine. That sounds like we’re getting two for one - but biodiversity offsets aren’t that simple.

Biodiversity offsetting is an increasingly popular means to balance out the impact developments have on the environment. Just as many of us will purchase a carbon offset to compensate for the emissions we generate when we take an overseas flight, biodiversity offsetting aims for “no net loss” of biodiversity values from a development project.

Like carbon offsets, biodiversity offsetting is a controversial topic. Recent media in the UK has highlighted how contentious it can be, with the UK government’s trial of its new biodiversity offsetting scheme decried by some as “a license to trash nature”.

One of the problems for biodiversity offsetting is working out whether “no net loss” is actually being achieved. Despite the widespread and growing use of offsets, very little evidence is available to demonstrate what those offsets deliver.

A recent paper is one of few to evaluate the outcomes from a biodiversity offset. When frog habitat was destroyed during development in Sydney Olympic Park, more habitat was created as an offset. The authors monitored the population size of the vulnerable green and golden bell frog (Litoria aurea) before and after development. They found that an area of habitat 19 times larger than the habitat area affected had to be created to ensure there was a no net loss of frogs.

This is an example of an offset working. But the amount of habitat that had to be created relative to the habitat lost (known as the “offset ratio”) was 19:1 - much greater than initially expected, and this was only discovered after intensive monitoring over more than a decade.

Often, proposed offset ratios are closer to 2:1, such as what has been proposed for the loss of the 8,000 hectare Bimblebox Nature Refuge. Is this enough? We can estimate whether an offset ratio is likely to be sufficient by calculating its conservation benefit.

To do this, we need to know two things: what is the risk the offset habitat would be lost if we don’t protect it? And what is the risk of its loss if we do protect it?

We’ll assume that the risk of loss of the offset site is about 1% over the next 20 years (based on the current rate of loss of remnant vegetation in Queensland). If the offset site is protected, we assume the risk of loss is zero (although this might be a bit optimistic).

The difference between the expected area of the offset site with protection, and the expected area of the offset site without protection, must equal the impact of 8,000 ha if we are to achieve no net loss. Based on this model, about 800,000 hectares would need to be protected to offset the loss of Bimblebox Nature Refuge. That means an offset ratio closer to 100:1!

We make a number of assumptions to get this figure, like the risk of losing a patch of remnant bush if is unprotected or protected. If, for example, we had considered regrowth vegetation with its 20-year risk of loss at about 10%, this would bring the offset ratio down closer to 10:1 (although the quality of the offset would be lower).

But even with the most generous assumptions, a simple exchange of two hectares protected for every hectare destroyed is unlikely to achieve a no net loss outcome in our example. Unfortunately this illustrates that in many cases, we are pushing the limits of what can realistically be considered “offsettable”.

With any major development, the proponent must detail in its Environmental Impact Statement how threatened environmental values contained within the project area (in this case, within Bimblebox) are to be avoided, mitigated, rehabilitated or offset. The total sum of offsets required by State and Federal policies for individual environmental values, such as the black-throated finch and the koala, may provide a very large offset area when combined. But without calculating the conservation benefit of offsets like we have here, its not clear whether it will be enough to achieve no net loss.

If the China First Coal Project goes ahead, it will be the first time an entire protected area is lost to development in Australia, so there’s currently no policy that requires an offset for a protected area in its own right. Based on our example, a 2:1 offset would likely not achieve the “no net loss” standard for the loss of Bimblebox Nature Refuge.

Ultimately, governments can revoke the protected status of any conservation area, and compensation isn’t necessarily required. The question is whether the Australian public considers the loss of publicly-funded conservation areas to be a fair exchange for the benefits provided by a development. But to make this judgement, we need to fully understand and acknowledge the limitations of biodiversity offsetting. Otherwise, we may unknowingly accept an exchange that could result in the loss of effectively irreplaceable biodiversity.

3 comments

As an ecologist working in private industry for the last 25 years, the simple answer to the headline question is "NO". The concept is very sound and should work, but..........A loss is a loss and there is a increasing body of anecdotal and published evidence (eg., Hayes and Morrison-Saunders 2007, Bekesy et al. 2010) showing that offsets are often of less ecological value, not managed or badly managed, and tend not to offset the local and regional loss of biodiversity (it is often the case that offsets are just areas of scrub that would not have been cleared anyway - therefore only contribute to a net loss in biodiversity). There are some attempts to reduce the corruption of the offsetting process but for every attempt to fix the problem seems to result in a means to circumvent it. If there is finger pointing to be done, I would suggest we ALL stand in front of the mirror and point

The creation of the Bimblebox Nature Refuge, an island of uncleared biodiversity, surrounded by a sea of cleared paddocks, was supported by both Federal and State governments. lt represents an important exercise in habitat protection, its unique environmental attributes co-existing sustainably with low key beef production .
Now, the State seems ambivalent about its destruction. Why?
How will (or can) the State replace the underground waters that may be reduced, contaminated, or lost altogether, by landholders adjacent to the mine, who have no actual mining on their land?
Even if Bimblebox is 'saved' from Palmer's mine, surrounding mines will surely suck the groundwater from beneath, effectively emasculating it.
Mining poses many critical questions. Perhaps the biggest is, why does everyone expect, and accept, that mining (which is, despite its supposed vital role, self-limiting and ultimately unsustainable) should trump all other dealings with land.
Because the bulk of our money supply is created into existence as a debt to the private banks, and the money to pay the interest on those debts must come mainly from loans to be made in the future, exporting goods is seen as a good thing. Although we appear to be exporting coal, we are also, in effect, 'importing' debt free Australian dollars. A small percentage of these dollars, left over after the overseas investors have taken their cut, can be spent into our local economy.
This is the miner's carrot to the government donkey.
The obscene haste to exploit our mineral resources is seen by politicians and others as a quick (albeit temporary ) fix for our artificial shortage of money, the very 'lubricant' that all modern economies rely on to function. Not tackling this crucial problem has made our environment, and our planet, the victim.
 

Any potential Sea Grass loss from the Yarwun 3TL proposal, should be considered as WHA biodiversity values , which will require 'offsetting' under the EPBC EOP 2012, so far , sea grass offsets such as replanting are proving unsustainable. The tenure of the sea bed is the question, who owns the seabed in the narrows? Can a simple protective covenant ensure that the dugongs and turtles which utilise the 'lost seagrass meadow' , be enough?,  A requirement should be that 3TL acquire a suitable offset ratio area and spend 5 years monitoring the 'net biodiversity gains' from that offset ,to scientifically prove that the offset has worked , BEFORE any EPBC 1999 approval is given. Approvals should not be given for merely 'legally securing' offsets, on the contrary , offsets should be proven viable , BEFORE approvals are given. Only then should dredging occur, not before or during the 5 years , only after it is categorically proven that the MNES values have not been compromised. Given that it is highly likely that Greg Hunt will be the NEW Federal Environment Minister , it is likely that the project will be given the 'tick and flick EI assessment protocol'.

Read more: http://www.brisbanetimes.com.au/federal-politics/can-we-offset-biodiversity-losses-20130507-2j49t.html#ixzz2xsoGmDpy
 

 

6 June 2013, 2.29pm AEST

Biodiversity offsets could be locking in species decline

In a recent interview, the Opposition environment spokesperson Greg Hunt promised to reverse biodiversity decline in five years if the Coalition wins the forthcoming election.

Is this goal achievable? Not the way we’re going. Our investment in enhancing biodiversity is not keeping pace with the factors driving biodiversity declines.

We continue to lose biodiversity by clearing vegetation for mining, urban development and farm management. Queensland’s rate of clearing alone has recently averaged about 100,000 hectares each year, and looks set to increase. Even our national parks have come under attack.

Is it possible to continue to clear land, but also stop biodiversity decline? In theory, perhaps. This is the apparent promise of biodiversity offsetting, an increasingly popular policy approach. But are our current offset policies really designed to halt declines? We argue the answer is no.

No net loss compared to what?

In Australia, the federal government and all state governments have biodiversity offset policies either in place, or in development. Offsetting is done by trading a biodiversity loss in one location with an equivalent gain in another. Biodiversity offset policies usually aim to achieve “no net loss” of biodiversity.

To what extent can biodiversity offsets contribute to halting biodiversity decline? As usual, the devil is in the detail.

Leaving aside the vexed issue of how we actually measure biodiversity, let’s consider what is actually meant by “no net loss” of biodiversity.

The crucial question here is, “no net loss compared to what?” Most people probably imagine that the answer is no net loss of biodiversity compared to what was there before the impact. But this is not usually the case.

Instead, the real intention of most biodiversity offset policies is to achieve no net loss compared to what would have happened in the absence of the impact and the offset. This is often referred to as the counterfactual.

Calculating the compensation

We can see why this definition of “no net loss” emerges if we consider the two ways that offsetting can be done.

First, gains can be achieved through improving existing habitat, or creating habitat from scratch. For example, we could create new wetland habitat for a threatened frog to compensate for a development that destroys its current wetland habitat.

Although there are many limitations to such restoration offsets, they can neutralise damage to some elements of biodiversity.

Threatened native grasslands to the west of Melbourne, a place where offsets require ongoing biodiversity declines to work Ryan Chisholm

Second, we can protect existing habitat as an offset. This is known as an “averted loss” offset, and is the more commonly-used approach.

The assumption here is that protecting against clearing or degradation results in a gain for biodiversity compared to what would have happened without the protection. Calculating this gain requires choosing some sort of “business as usual” rate of decline, based on data on vegetation clearing or degradation of habitat quality.

The gain then occurs because the offset results in better outcomes than would have occurred under the counterfactual “business as usual” scenario. This gain, together with the loss from an impact, provides the “no net loss” outcome.

One of the challenges with this approach is in estimating the counterfactual. It is often (unfortunately) a reasonable assumption that biodiversity will continue to decline. The problem arises when estimating what that rate of decline might be. Since we do very little biodiversity monitoring in Australia, there can be considerable uncertainty around the “business as usual” baseline to which we might compare our offset outcome.

But there are is another important consequence of averted loss offsetting that might not be immediately obvious.

Averted loss offsets only work if biodiversity keeps declining

The crucial point about averted loss offsetting is that it can entrench the baseline rate of decline. That is because the gains from the offset and the losses from the impact are only required to add up to the decline that would otherwise have occurred.

So without additional conservation actions, this approach to offsetting simply ensures current declines continue, at the same rate. This outcome is not a policy failure — it is the way the policy is designed to work.

Allowing this type of averted loss offsetting is therefore an admission that ongoing decline is the norm for our biodiversity. Worryingly, policies structured this way could also provide a perverse incentive to ensure declines continue. This is because without declines, offsets based on “protection” are not possible.

For example, part of the disquiet around increasing protection of vegetation, such as through the Wild Rivers declarations on Cape York, is linked to the potential loss of opportunity to sell offset “credits”. The less of our vegetation we protect, the easier it is to find offsets.

So biodiversity offsets policies that rely heavily on “averted loss” offsetting cannot in themselves reverse declines; they are not designed to. Whether it is fair to expect developers to be responsible not only for negating their impact, but also contributing to improving the lot of biodiversity, is debateable. But we should be aware that offsets are not a panacea. At best, our averted loss offsets will achieve a continuing decline of biodiversity.

At worst, they may provide an incentive for the decline to continue.

RESPONSES:

Director  - "In a recent interview, the Opposition environment spokesperson Greg Hunt promised to reverse biodiversity decline in five years if the Coalition wins the forthcoming election." What an insult to anyone with a background in biology and ecology, considering the policies of the conservative side. We only have to look at Campbell Newman's policies in Queensland to see that there is more destruction to come with an Abbott government - and no amount of spin and hype will change that.Read more

Thanks for this piece - the emergence of offsets, like some papal dispensation, is extremely worrying. You have pointed out the locking in of decline - but there are other problems with offsets. Offset policy (federal and Qld) allows indirect offsets - meaning you simply pay for the damage to an authority, which will use it in ways that offset the damage. Offsets are frequently developed after approvals are given - with no certainty that they will work (see for instance the Federal approval for the Alpha mine). Some offsets are just inane. How about this one from Townsville - an offset for damage to marine habitat was the building of a boat ramp. Or from the Marine Park Authority - the offset for destroying sea grass beds was for the proponent to protect sea grass beds...They are already in theory protected, so the Authority says they will be 'better' protected - again the detail doesn't exist yet. Finally, there is a giant black hole in the whole offsets sham - offsets aren't currently registered, monitored or assessed...In fact, it would be reasonable to conclude that offsets have been created in order to allow all developments to proceed behind a patina of conservation that simply won't bear scrutiny.

In reality, there is no such thing as an offset. Destroying habitat by protecting other unprotected habitat is still a loss. It is impossible to recreate the original biologically diverse habitat as well. Replanting can never reinstate the complexity, associations and the interdependencies of a natural vegetation community. Offsets are an excuse for business as usual.

31 October 2013, 12.15am AEST

Biodiversity offsets may drive growth, but duck the problem

By Carlos Ferreira, University of Manchester

Carlos Ferreira received funding from the University of Manchester's Sustainable Consumption Institute to undertake a PhD on the topic of biodiversity offsets. This PhD is now finished and has been submitted.

The idea behind biodiversity offsets is to develop a new way of preserving nature that more accurately accounts for the value to us of the natural world.

The abundance and diversity of plants and animals, and their role in ecosystems – known as biodiversity – can be damaged or destroyed by building and development. But this is what economic growth generally involves: roads, houses, offices and industrial plants have to go somewhere, and sometimes the environment is damaged or destroyed as a consequence.

Ideally, it would be possible to generate economic growth in a way that avoids biodiversity loss and preserves nature. One way this could be achieved is biodiversity offsets. This mechanism would require developers to provide compensation for the damages which result from their actions.

For example, destroying a wood to make way for new houses would mean the developer would have to provide another wood somewhere else to replace it, or pay a third party to do so. These offsets, proponents argue, should result in “no net loss” of biodiversity from development.

The concept of biodiversity offsets is being discussed by the UK Parliament’s Environmental Audit Committee. If proposals are taken forward, biodiversity offsets could become one of the most important changes to how decisions affecting the environment are made in Britain.

Supporters claim this would create a better way of making decisions. Modern societies appear to have a broken economic compass: we don’t value nature enough compared to development and economic growth. Biodiversity offsets would put a price on nature, and force developers to pay for the damage they inflict. This would make development more expensive and conservation more appealing.

Offsets and planning

There are other ways of choosing between development or conservation. In Britain this is governed by the need for planning permission, which is granted or denied, or granted with conditions, by local authorities. One of the aspects they must consider is impact on biodiversity, and through conditions known as Section 107 agreements they have the power require compensation in cases where a project would have a negative impact on nature.

The Department for the Environment, Food and Rural Affairs commissioned the Ecosystem Markets Task Force (EMTF), to examine this and other market mechanisms that affected the environment. The EMTF identified biodiversity offsets as the most promising in terms of promoting economic growth, with the potential to simplify the planning process, and reduce the time it takes to obtain planning permission. These comments were echoed by the secretary of state, Owen Patterson, who said it would allow the economy to grow, while protecting nature. But it is not clear how the biodiversity offset mechanism would be integrated into the existing planning system.

Licence to trash

Despite these claimed advantages, environmental activists and NGOs have raised concerns about the feasibility and potential consequences of biodiversity offsets.

Biodiversity is complex and biologists have generally been critical of claims that biodiversity can be easily measured and quantified in a single location, let alone then usefully compared to biodiversity elsewhere. It is not possible to assure that biodiversity in two locations is the same, or qualitatively equivalent. And without this, the principle of ensuring no net loss of biodiversity collapses.

The displacement of damages also raises problems, as it allows the possibility of damages in an area with high land prices, such as London and the South East, to be offset in an area where land prices are much lower, such as the North East of England. This would lead to an unfair and uneven distribution of damages and biodiversity, and again would not ensure no net loss of biodiversity in any meaningful way.

A final question raised is about power. Critics of offsetting suspect that it would render the planning process toothless, allowing rich and powerful companies to simply buy their way out of the proper planning process. Biodiversity offsetting, could easily become a licence to trash.

Questions remain

The idea underpinning offsets is appealing, and could at least be used to spark debate about the value - the literal, economic worth - of nature and the need to conserve it. But the rules and regulations parliament is considering must ensure that the maximum distance between damage and offset is limited and that the limits to measuring biodiversity are compensated for. And, most importantly, biodiversity offsetting must work as a part of the existing planning regulations, not supersede it.

Biodiversity offsetting has the potential to change the way we think of nature in Britain. It should be discussed and analysed by the public before becoming compulsory. But it should not be allowed to become the main way by which we, as a society, govern nature.
 

Justified and ancient: our best woodland is irreplaceable

By Keith Kirby, University of Oxford

The threat to Britain’s ancient woodland has been much discussed recently, the suggestion being that where they are lost to housing development they might be replaced with new woods through biodiversity…

The National Planning Policy Framework includes a stronger statement against development than for most other habitats:

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. 

An amphibian-eye-view of environmental offsetting

By David Lesbarrères, Laurentian University

In its report published last week, the UK Parliament’s green watchdog, the Environmental Audit Committee, was far from convinced by the government’s proposed policy of biodiversity offsetting. The committee’s…

England’s green and pleasant land: will biodiversity offsetting help or hinder it? England’s green and pleasant land: will biodiversity offsetting help or hinder it? Gareth Fuller/PA

 

In many other instances newly manufactured habitats have not met Lavoisier’s principle and wildlife populations, species diversity and even whole ecosystems have been lost. In fact, in this business, and despite being under-reported, failures are as abundant as successes. This is especially the case for wetland habitats, one of the more common ecosystems brought under tentative offsetting. For instance, one study showed that of 31 mitigation sites in Indiana, 71% of forested sites, 87% of wet meadow areas, and 42% of shrub areas failed.

But, if the policy is used as a fig leaf by developers as a means to an end, and if failing to achieve the goal of “no net loss” brings no consequences or penalties, then one has to consider who offsetting really benefits. And, more broadly, the question must be asked as to whether such a policy is acceptable at all, at a time when biodiversity is under unprecedented pressure.

 

Biodiversity offsets: solving the habitat-saving equation

By Ascelin Gordon, RMIT University

Biodiversity offsets are touted as a new tool for protecting our natural environment. While they have the potential to deliver real gains, understanding the possible consequences of these polices over…

Can we continue to grow while still protecting our natural heritage? Can we continue to grow while still protecting our natural heritage?

Biodiversity offsets are touted as a new tool for protecting our natural environment. While they have the potential to deliver real gains, understanding the possible consequences of these polices over the long-term raises many challenges.

These policies aim to balance biodiversity loss arising from habitat destruction at one location by enhancing and/or protecting similar but separate habitat at another location.

Many countries around the world are embracing biodiversity offset policies. In Australia, the Commonwealth Government and most state governments have either implemented or are in the process of implementing biodiversity offset policies.

Defining our terms

Two important questions come up when designing these policies:

·         What do we want the policy to achieve?

·         How will we know if the policy has achieved its objectives?

Many biodiversity offset policies have a stated aim of delivering a “net gain” or “no net loss” in environmental values. These values can include native vegetation, species habitat or ecosystem services. While this is certainly a worthy objective, in practice it may be difficult to achieve for a whole raft of reasons that are beyond the scope of this article.

Regarding the second question, it can be a huge challenge to actually establish whether an offset policy is meeting its objectives.

The first task is to determine how to measure losses and gains - the “currency” the offsets will deal in. We mostly don’t know the full extent of biodiversity lost at one site, or gained at another. Thus we have to use surrogate measures that we hope will be good indicators of the real things we are trying to preserve.

Is it possible to balance habitat lost and habitat gained? 

In Australia the area and condition of native vegetation is a commonly used surrogate. Gains from an offset are measured in changes to the condition and area of the native vegetation contained in the offset.

Other subtle issues arise once we have chosen our “currency”. For example, at some point in the future, do we count the gains from an offset site relative to what was there originally, or relative to what would have been there at if the offset had not been created. In other words, from what baseline do we measure gains?

Doing the maths

A simple example can be useful to illustrate these issues. Assume a single site is developed and all vegetation is cleared. Simultaneously, an offset is implemented. Here we will assume the “score” of a site is calculated from its area multiplied by a measure of its native vegetation condition.

The development and offset sites have scores of D and O just before these actions occur. After some years of management the offset has, or is expected to have, a new (hopefully higher) score of O’.

To achieve a net gain using the current condition as the baseline would require O’ > O + D. This means the condition of the offset site has improved so its score is now greater than the initial scores of the offset and development sites. This could be interpreted as a real gain relative to what we have now.

To achieve a net gain using the status quo as the baseline is a little more complicated. We introduce O” and D” which represent the score that the offset and development sites that would have if no development or offsetting had occurred. Now we instead require O’ > O” + D”.

If we assume that the condition of the vegetation on the offset and development site would have been degrading without any sort of intervention (a reasonable assumption in many parts of Australia) then O’ > O” + D” might still hold even if the offset site has no change in condition (O = O’). This is because O” and D” are now smaller than O and D and the offset can be seen to deliver a net gain though avoiding degradation that would have otherwise occurred at the offset site.

What would have happened if the environmental values hadn’t been destroyed in the first place? brewbooks

Finally, the least stringent requirement is that the offset delivers a net gain relative to what we could call a worst case scenario. Using this baseline assumes that development will occur with or without the offset and that the offset policy should only deliver a gain relative to development without the offset policy.

In this situation we would only require O’ > O or O’ > O” which potentially delivers the smallest gain compared to the other two baselines.

Choosing a baseli
There are some practical considerations in choosing the baseline from which to measure policy performance. For example, using a baseline other than the current condition involves predicting what would have happened without the offset (and development) occurring. This adds some “fuzziness”, as we can never be completely sure of what would have happened without these actions being implemented
The most important driver in our choice of baselines is our values. Requiring an offset policy to deliver “no net loss” using the worst-case baseline would result in a very different outcome compared to using the current conditio
There is no right or wrong answer to which baseline we use, but the choice should in part be driven by how we value retaining our biodiversity relative to economic development.

Whatever our values, we should at least be transparent about what we want our policy to achieve and how we will go about measuring this. This involves clearly articulating the baseline we are measuring from and the assumptions this implies.

The recently released draft biodiversity offset policy from the Commonwealth Government outlines how offsets would be used under the Environment Protection and Biodiversity Conservation Act 1999. Although not stated in the draft policy document, the Department has clearly stated that the goal of their policy is to maintain or improve compared to what is likely to have occurred under the status quo. Thus it looks like we will be stuck with the inherent uncertainty associated with using this baseline to evaluate the performance of the EPBC Act offset policy.

David Low Project Manager - The Weed's Networ
The offset discussion would benefit from a thorough examination of the concept of irreversibility. There is an excellent paper on the topic by Perrings & Brock (2009), see:
http://www.public.asu.edu/~cperring/Perrings%20and%20Brock,%20ARRE%20%282009%29.pdf


Ben Carr Landscape EcologisA good article Ascelin - there is a dearth of analysis of biodiversity offset policy and practice.
A few comments that follow some of the issues you raise.
Firstly there is very little published review and analysis of the outcomes of offsets programs. Hopefully this will change as the various state based and EPBC programs develop and mature over coming years.
Secondly and this related to irreversibility - the losses causes by development are generally complete and permanent while the required gains…Read more
A good article Ascelin - there is a dearth of analysis of biodiversity offset policy and practice.
A few comments that follow some of the issues you raise.
Firstly there is very little published review and analysis of the outcomes of offsets programs. Hopefully this will change as the various state based and EPBC programs develop and mature over coming years.
Secondly and this related to irreversibility - the losses causes by development are generally complete and permanent while the required gains are promised i.e. developers don't have to demonstrate actual gain, just enter into an agreement that is intended to produce the required gain. I suggest that real gains ie outcomes on sites that have been produced, measured and verified should also be used and possibly required in some instances. A requirement for real gains will result in more certainty that no net loss or even net gain has occurred.
Thirdly I suggest that the gains should be measured using an outcome based approach, rather than just assuming that if certain outputs are carried out the gains will occur. This would involve measuring the final outcomes at an offset site and only once the offset site actually meets the required level is the offset approved as being completed and the developers obligation met.

Ascelin Gordon  Research Fellow, Global Studies, Social Science & Planning at RMIT University  In reply to Ben CarrHi Ben,Thanks for you comment. I agree with the points you have raised.While there has been little published analysis of offset program outcomes, I'm optimistic that this will gradually improve (though not necessarily about what such studies might find!).Regarding your second point, I agree that a key issue with biodiversity offsetting (as it's currently implemented) is that permanent immediate losses are traded for uncertain future gains. We have undertaken some modelling to start to…Read more
Thanks for you comment. I agree with the points you have raised.While there has been little published analysis of offset program outcomes, I'm optimistic that this will gradually improve (though not necessarily about what such studies might find!).Regarding your second point, I agree that a key issue with biodiversity offsetting (as it's currently implemented) is that permanent immediate losses are traded for uncertain future gains. We have undertaken some modelling to start to explore this issue (Gordon et al., 2011) and plan further work on this topic. A requirement demonstrating real gains have been achieved before a development occurred would be ideal and would certainly increase the likelihood that a real "net gain" had been achieved (this point has also been argued by colleagues of mine (Bekessy et al., 2010)). Though there might be considerable resistance to such requirements due to the time and expense of achieving gains before development (which in itself says something important).Regarding your third point, I agree and think there are some interesting issues around whether a policy should be paying/stipulating for inputs or outputs. This is really about who owns the risk if required gains fall short. I know that in Victoria the Department of Sustainability and Environment has been trialling an outcomes based approach with their BushTender program (which pays landholders to mange native vegetation on their land, see http://www.marketbasedinstruments.gov.au/MBIsinaction/Currentcasestudies/BushTendertriallingoutcomebasedcontracts/tabid/379/Default.aspx). Finally I was pleased to see the draft EPBC biodiversity offset policy states "proponents, or their contractors, must report on the success of the offsets so that conditions of approval can be varied if the offsets are not delivering the desired outcome." It also states that there will be a monitoring, compliance and audit program for each offset with the information being publicly available on the department’s website.Papers citedBekessy S, Wintle B, Lindenmayer DB, Mccarthy M, Colyvan M, Burgman M (2010) The biodiversity bank cannot be a lending bank. Conservation Letters 3: 151-158.Gordon A, Langford WT, Todd JA, White MD, Mullerworth DW, Bekessy SA (2011) Assessing the impacts of biodiversity offset policies. Environmental Modelling and Software 144: 558–566.
 

A tree for a tree: can biodiversity offsets balance destruction and restoration?

By Philip Gibbons, Australian National University

When my children are my age they will be living in a country with an economy that’s three times larger, and a population that’s twice as large as today. And, on current trends, my children will be living…

When my children are my age they will be living in a country with an economy that’s three times larger, and a population that’s twice as large as today.

And, on current trends, my children will be living in a country with around 10 million hectares less of native bushland.

So, how can we stem the loss of our distinctive natural heritage in the face of continuing economic growth?

The Federal Government is currently seeking public comment on a controversial solution to this problem.

Their plan is to nationalise “biodiversity offsets” to halt the loss of our significant biodiversity. Biodiversity offsets are actions at one site that compensate for losses at another.

Natural bushland needs to be protected. _tom_

For example, a company might destroy native habitat to create an open cut mine and offset this impact by planting vegetation in another area.

On face value this seems to be a win-win outcome, which probably explains why governments around the world are embracing biodiversity offsets.

But will biodiversity offsets halt the loss of biodiversity?

Not according to most ecologists.

The key criticism of biodiversity offsets is that there is only a narrow range of circumstances in which impacts on biodiversity can be offset with any kind of certainty.

An ecologist named Keith Bradby put it nicely in a documentary called “A Million Acres a Year” when he said, while looking over a piece of Western Australian bushland: “We can put a man on the moon, but we can’t recreate that.”

Another problem with the policy proposed by the Australian Government is that biodiversity offsets are not established before the impacts occur.

It can take 200 years before an offset will replace a nest tree for Carnaby’s Black-Cockatoo, a species threatened by urban development. We should be establishing offsets well in advance of impacts on our biodiversity.

The fault with many offset programs, including the Australian Government’s recent offering, is they promote the protection of high quality habitats as suitable offsets. If you think about it, a site that is already in good condition has little scope for improvement. So, this strategy actually results in a net loss of bushland.

Carnaby’s Black-Cockatoos are threatened by urban development. Ralphs photographs

Despite these issues, I offer guarded support for biodiversity offsets for the same reason I believe we should place a price on carbon to reduce greenhouse gas emissions.

Biodiversity offsets effectively place an economic value on biodiversity, thus discouraging its destruction in the first place. This is because offsets represent an economic impost to developers: it takes considerable resources to identify, establish and manage an offset.

This was demonstrated in New South Wales where the number of approvals to clear native vegetation dropped by about 80% after the introduction of offsets.

So, while offsets will not stop the loss of biodiversity, they might reduce the rate of loss.

That said, the Australian Government’s proposed policy will subvert this market effect. This is because the policy is riddled with exemptions. “Minor” losses, “non-signficant impacts”, and “economic and social factors” are all reasons a project can proceed without offsets under the current proposal.

At at time when mining industries have significant clout, when governments are doing everything in their power to maintain economic growth and when we have a rapidly growing population coupled with a housing shortage, you can bet these exemptions will be like cracks in a dam wall.

Meeting environmental and economic needs is a tough balancing act. James Jordan

This was demonstrated recently in New South Wales. While the number of approvals to clear native vegetation dropped by about 80% after the introduction of biodiversity offsets, the area of clearing only decreased by 30%.

Exemptions in the legislation discouraged developers from finding alternatives to clearing.

And this takes us to the nub of the problem with land clearing policy. The current proposal from the Australian Government, like others before it, seeks to minimise the impacts of development on biodiversity, while making no attempt to address the causes.

We keep trying to plug the cracks in the dam rather than drain the water.

If we really want to stem the erosion of our natural heritage we must divorce economic growth from its attendant impacts on biodiversity.

That is, we need to de-couple food security from land clearing, achieve population growth without urban expansion, find transport solutions without widening roads and supply utilities without clearing easements.

Only then can we pursue economic growth without continuing to erode Australia’s distinctive natural heritage.

And only then are our children likely to enjoy the same natural heritage that we did.

RESPONSES:

Greg Hay Science and Teaching stude
Biodiversity offsets are better than nothing but often only 'replacements' on paper, one hectare for another. The inherent complexity in any ecosystem and food web interactions therein mean plant communities are far more than an account of the obvious species present. A true forest is more than the trees and to think we can offset a loss by planting some species in an area is somewhat fanciful. And that is without considering the complesities required by animals.
We have to accept these losses or change acceptable protocols for relevant industries. Decoupling, as the article suggests, seems the only viable long term solution, but that probably means 'Building Farms' and 'fake meat' potentially, and not everyone is ready for that.

Megan Evans  PhD Candidate in Environmental Policy & Economics at Australian National University

Thanks for this article. I'd be interested in your thoughts on the role of financial contributions made to an offset fund either additional to or in lieu of finding a suitable biodiversity offset, as is the case in Queensland. I've yet to read the Federal draft offset policy, but it would be interesting to see what degree of security is placed on offsets - for example, whether an offset itself may be subject to future development (and whether an offset it required for this).I am a bit skeptical about the possibility of absolute decoupling of economic growth from environmental impact. There's evidence of relative decoupling – that is, efficiency gains in converting natural resources to GDP – but this can be swamped by resulting increases in absolute consumption. Given that it's not possible to make something out of nothing, and that there are limits to efficiency, is it a realistic expectation to maintain continuous economic growth while also improving biodiversity protectionHi Phil,Thanks for this article. I'd be interested in your thoughts on the role of financial contributions made to an offset fund either additional to or in lieu of finding a suitable biodiversity offset, as is the case in Queensland. I've yet to read the Federal draft offset policy, but it would be interesting to see what degree of security is placed on offsets - for example, whether an offset itself may be subject to future development (and whether an offset it required for this).I am a bit skeptical about the possibility of absolute decoupling of economic growth from environmental impact. There's evidence of relative decoupling – that is, efficiency gains in converting natural resources to GDP – but this can be swamped by resulting increases in absolute consumption. Given that it's not possible to make something out of nothing, and that there are limits to efficiency, is it a realistic expectation to maintain continuous economic growth while also improving biodiversity protection?.over 2 years ago report

Tom Barrett Research Fellow, Landscape Ecologist at University of New Englan
Hi Phil, There's another issue here.. The old adage that 'the whole is greater than the sum of the parts' is ignored in most biodiversity offset schemes. These schemes usually treat each 'loss' and 'offset' as two islands without consideration of the any of the processes that may be operating at larger scales including interactions between the proposed loss and surrounding ecosystems. We are now seeing the impacts of ignoring these larger scale processes with continuing declines in many bird populations in fragmented landscapes (extinction lag), increased salinity in our rivers, declines in rainfall, loss of soil fertility etc. I believe there is a need for more 'holistic' planning at landscape scales in recognition of the processes that operate at these scales. The following UNEP report sums this up by stating:“..This means shifting from a focus on the protection of discrete ecosystems to management of larger landscapes—addressing them in bundles of interlinked services, including those that support food production.” (Boelee et.al., 2011).Keep up the good work!

Reference:Boelee E., Chiramba T. and Khaka E. (eds) 2011. An ecosystem services approach to water and food security. Nairobi: United Nations Environment Programme; Colombo: International Water Management InstitutHi Phil,
There's another issue here.. The old adage that 'the whole is greater than the sum of the parts' is ignored in most biodiversity offset schemes. These schemes usually treat each 'loss' and 'offset' as two islands without consideration of the any of the processes that may be operating at larger scales including interactions between the proposed loss and surrounding ecosystems. We are now seeing the impacts of ignoring these larger scale processes with continuing declines in many bird populations in fragmented landscapes (extinction lag), increased salinity in our rivers, declines in rainfall, loss of soil fertility etc. I believe there is a need for more 'holistic' planning at landscape scales in recognition of the processes that operate at these scales. The following UNEP report sums this up by stating:
e.“..This means shifting from a focus on the protection of discrete ecosystems to management of larger landscapes—addressing them in bundles of interlinked services, including those that support food production.” (Boelee et.al., 2011).Keep up the good work!Reference:Boelee E., Chiramba T. and Khaka E. (eds) 2011. An ecosystem services approach to water and food security. Nairobi: United Nations Environment Programme; Colombo: International Water Management Institute.over 2 years ago report

Ben Carr Landscape Ecologist
Thanks Phil, That's a good article and covers many of the issues that offset policy and programs raise for me. The key underlying issues are spatial and temporal conditions of the impact and offset areas. In regards to the spatial issues the offset site/s are often some distance away from the impact sites and will have different landscape contexts. Often the technical assessment criteria for offset calculation do not adequately deal with this complexity and the landscape context that Tom raises is not considered or lost in trying to develop a 'workable' set of offset criteria ( That workable in the view of the development industry).The temporal issues are more important in many ways and are in my view the single biggest failing of current offset programs in Australia. In general terms the losses are allowed well before any of the supposed commensurate gains have been achieved and often with no or very little capacity for redress if the gains actually can't be produced. hence permanent and total loss of habitat values is permitted based on very little security that the required gain will every be achieved and these losses are allowed well before ant of the gains are achieved . ie the losses are assures while the gains are promised. In financial terms it's like establishing a loan that is immediately and fully drawn down without having to prove that you can repay. The net effect of all of these withdrawals from the habitat pool is continued loss.
I'd like to see actual real habitat gains be given greater value that the promised gained and that offsets be required to be met with a mixture of some achieved gains as well as promised gain. Now that would stimulate the landscape reconstruction / restoration industry! The various 'like for like' or 'like for better' criteria that have been developed are generally good but not comprehensive when it comes to considering the cumulative picture of offsetting. It will soon be time to undertake a detailed and independent review of those offset schemes that have been operating longest in Australia and to learn from this - perhaps before designing a national scheme. I also believe that there needs to be greater provision for ongoing funding from the beneficiaries of the loss ie the developers for the long term management of the offset sites. Current schemes have been allowed to develop with short term ie 10 year funding often due to the intense lobbing campaign of the development industry.There is also the fallacy that has been allow to develop that increasing the security of the underlying land tenure somehow produces a habitat gain. This is often done through placing conservation covenants over habitats or added them to the public protected area system.Increasing the underlying land security in itself does not result in any changes to habitat quality and its should not be allowed to count towards gain alone. Increasing security should only be allowed to be considered as part of a package that includes long term management and requirement to demonstrate that habitat quality has been increased to the necessary amount. Any gain that arise from increasing security should also contribute small amount to any habitat gain scoring system ie less that 10 % of the overall score as a maximum.
Cheers Ben Carr

Philip Gibbons Senior Lecturer at Australian National University In reply to Ben Carr

Thanks Ben. Some really good points you've raised and difficult to disagree with any of them. You should be raising these issues with the Australian Govt. I feel as though we handled the regional and landscape issues reasonably well in the NSW NV Act, whereby site, landscape and regional values had to be offset separately (no trading between them) for the offset to be approved (see Gibbons et al. 2009. An operational method to assess impacts of land clearing on terrestrial biodiversity. Ecological Indicators, 9, 26-40). I'm not saying it's perfect though. You will also note in this paper that we permitted offsets in only a restricted set of circumstances, which I think is important (see Gibbons and Lindenmayer 2007. Offsets for land clearing: no net loss or the tail wagging the dog? Ecological Management and Restoration, 8, 26-31).  Regards, Phil

Tackling the moving-target problem - Can biodiversity offsets capture moving-conservation targets

Intro:  How do we conserve something when it won’t stand still? It’s a question we are only just beginning to grapple with in conservation science. Fixed protected areas are an example of a classic conservation tool, but traditional interventions like these can be ineffective for ‘moving targets’: for instance, a species that is so mobile that it doesn’t stay within a reserve. Biodiversity offsets, despite the suspicion they are often treated with by conservationists, may provide some answers to this question.

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E-mail

j.bull10@imperial.ac.uk

 

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