Respondent 3 (Certified Offsetter)
Interviewer(s): Me
Interviewee(s): Respondent

Me: As you know from our email communications the project seeks to elicit stakeholder perceptions to biodiversity offsetting in the UK. And I chose to study biodiversity offsetting because it's received relatively low scholarship and there hasn't really yet been that much exploration into stakeholder perceptions particularly focusing on the UK. I also recently launched a project with Stockholm Environment Institute on sustainable construction so I'm quite interested in the role of businesses and particularly interested in your insight because you've worked at the interface of policy and decision making and business as well. So, if we could maybe start on probably the 'License to trash' rhetoric that is often associated with biodiversity offsetting and I was just wondering your opinion on whether biodiversity offsetting is likely to lead to more stringent or less stringent regulations around infrastructure projects?

Respondent: Yeah, sure. I mean to be honest in my opinion the whole license to trash thing is not true and it's pretty much rubbish. It's ill-informed people not understanding the system properly because at the end of the day biodiversity offsetting doesn't affect any existing protections and habitats such as SSSIs are out of scope of offsetting, so we wouldn't expect a developer to be able to build on an SSSI then offset somewhere else - we would say that doesn't come under offsetting, you can't use that site. For me, the offsetting process is about truly valuing the environment and a lot of the environment that is getting built on at the moment is farmland or brownfield sites and they're not actually taken into account, whereas a brownfield site has actually got a high distinctiveness within the DEFRA matrix. So, it would make it very expensive to have an offset of a brownfield site and these sites that are high distinctiveness, because they are, they could be very difficult to offset and therefore the management plan that would need to be delivered could be quite expensive. High value habitats could actually make developments un-viable and stop development on high-value habitats instead of encouraging it because urm... from all the work that I've been doing we have actually found that biodiversity offsetting tends to add more than has been asked for, so we're actually asking developers to deliver a long-term management plan which is really quite expensive.

Me: What's been the reception of businesses to biodiversity offsetting extending the mitigation hierarchy?

Respondent: Well... the reception that I've had when I've been speaking to them has been really quite positive, because the last thing a developer wants is an ongoing obligation to manage a site in a case where you've got to go back every year for the next 10-20 years and y'know deliver a management plan or to deliver monitoring. With offsetting it can be delivered by a condition and they can actually just discharge that condition and have nothing more to do with the site and that's actually really quite attractive to them and although there is definitely a cost associated with biodiversity offsetting, it can be built into the cost that comes from the residual land value. So, a farmer's field jumps by X amount of money depending on where you are in the UK. So, say it was worth - I'm sorry I don't know the exact figures for Essex - it is something like £5000 per hectare and jumps to £100000 per ha. So, I've got x,y and z to do as part of my development and biodiversity offsetting could be one of those things. So the developers want to reduce the price he pays to the farmer, in order to deliver his management plan and make sure offsetting can actually happen without affecting the viability of the developments.

Me: And at the moment it's voluntary, but would you like to see it made mandatory for all infrastructure developments?

Respondent: Yes, I think the only way to deliver offsetting fairly would be to make it mandatory and to have everybody doing it. At the moment because it's voluntary people tend to choose not to.

Me: And at the moment, obviously, the optimal kind of policy goal is net-gain, but by definition it is no net loss. Should there be an over-arching goal of net-positive impact or what should that goal be, given the state of biodiversity in the EU?

Respondent: Well, I think the currently system is definitely delivering a loss and...I think we need to take a step forward and biodiversity offsetting could deliver that step forward to net-gain. Hopefully, in the future once we're delivering net-loss - sorry no net loss - we could then move towards delivering net-gain. I don't think biodiversity offsetting is a perfect system, but it is certainly better than what is being delivered at the moment. So, I think it's a process and everybody needs to recognise we need to do something and we need to do it now and strive for perfection in the future. Y'know don't by any means stop moving forward, but at least start moving forward right now.

Me: Have you had any businesses that want to aim for that net-positive impact?

Respondent: Urm... not as yet. We are talking about several projects which are still ... confidential so I can't actually give you any details. But we are talking about several projects where developers want to do offsetting and... they, some of these are on farmland sites where a developer wouldn't have delivered any compensation in the past. Now they are willing to try offsetting and see how it works. So it would be no-net loss and I don't think anyone has gone: I want to do some extra... just as yet... but like I said, steps in a process.

Me: That's interesting... and when you are undertaking the biodiversity offsets, obviously biodiversity offsetting concerns ecological remuneration or compensation, but how do you think the communities and society can be remunerated, in terms of their loss in access to environmental amenities or in the lag that comes between building the offset site and fulfilling or completing the offset?

Respondent: This is actually two very different things and it gets confused with biodiversity offsetting quite often. So there is green infrastructure for developers and they already put that in and then there is actually compensating for the environmental impact... and, quite often having people sort of walk their dog or something like that on the site could cause a lot of disturbance and be contrary to achieving a good habitat if you understand what I mean. Sometimes having these sites away from people is actually the best management for them. It is not necessarily always a great thing for there to be a lot of people because y'know some species won't development, some species won't colonise, some flora won't y'know.

Me: So are there perhaps parallels between REDD+ and carbon offsetting, which has sometimes been criticised for the fact that communities might lose access to any environmental amenity because it is being used as a carbon offset and they won't gain access back. Do you also have to consider the actual societal aspect of it?

Respondent: Mhmm... I think with offsetting it's important that green infrastructure is developed alongside these sites: What people want - perhaps a nice park with close clip grassland - is not necessarily what biodiversity wants and I think that there are two very much seperate things and it's important to make sure that people have got access to green space and nice parks with daffodils and things like that but it's also very important to ensure that what was there originally - I can't really use the word natural, because there is no natural habitat in the UK anymore, it's all be touched by human-hands at some point - but the slightly more messy, rough habitats are actually what biodiversity needs. Particularly in Essex because a lot of the sites are brownfield and we have a brownfield SSSI and y'know kind of bare ground and scrub and messy grasses are perhaps not what people want, but that's a wonderful vertebrate habitat.

Me: So, do you go through that consultation process with local people or recognising the stakeholders in the process?

Respondent: I'd say that we haven't really recognised stakeholders in the process because we think that our main stakeholder is the environment and it's biodiversity and there are already represented through other mechanisms: green infrastructure would deliver open space within the development for the people.

Me: So it is kind of a separate thing?

Respondent: Yeah

Me: So, leading on from this. one of the points on the myth-busting fact-sheet you gave me mentioned that offsetting does not seek to put a monetary value on nature but it creates a market by ascribing a cost. I just wanted to ask: what do you think the differences between implicitly valuing an ecosystem and explicitly putting a price on nature or to what extent do you think the benefits derived from ecosystems can be valued?

Respondent: I think it's very very difficult to look at an ecosystem as a whole and identify all of the costs associated with it. My previous role - [confidential] - and a lot of the different things that say a tree could deliver, I mean you couldn't even get into a tree and count every insect, bird, whatever is living in that tree, let alone count them all and then look at the carbon capture and storage urm... water storage, shading, what personal values would somebody put on a tree? It depends on the age of a tree, the size of a tree... it gets so complicated so quickly and... with offsetting what we aim to do is always about delivering a management plan... So on a site there would be an impact on biodiversity in credits and then we would go and find a management plan to deliver that number of credits and that management plan could cost a wide range... Urm… the person might be using volunteers, they might be [unknown word] the land, they might have capital costs, so obviously something like planting trees or bringing in rubble or scrapping the ground which is what we do for invertebrates or different seed mixes and planting; is it going to need to be grazed by cattle being brought on site and it often so... It is all about identifying those management plans that can deliver that uplift and it's nothing to do with what that management plan costs, it's all about what the management plan is able to deliver and then the developer pays for the management plan as opposed to just walking up to a site and saying, right, there's six trees here, that's going to cost this... it's very different.

Me: Are you more interested in the process or the outcome in terms of credits, or are you interested in the process of engaging people and building the offset, rather than the credits per se at the end of the process?

Respondent: Well, within [organisation name] we actually act as the fund holder, so the developer would give us the money and we would put it in to a trust fund basically and we would be involved with the land manager and we would give them annual payments and we would check up on what they're doing and making sure they're delivering that management plan and if they're not, we stop paying them. It's a case - we've got all the legal documentations and we're ready to go - so they can sign up to delivering an offset. But then we're very interested in making sure we do that and that's kind of half of our job - making sure that once offsets are actually applied, they do get delivered and they do deliver the required benefits. But y'know it is going to be about being pragmatic, if the landowner has difficulties to cite, we want to work with them so they can still do the best possible thing.

Me: When you've tried to find landowners that are willing to participate in this scheme, has there been a cultural barrier - maybe with farmers particularly - that, they are a bit resistant to adopt different land use policies or strategies or rather do farming because traditionally, they're used to that and that's what they've been doing for a long-time?

Respondent: I mean... it very much depends on the farmer. I've spoken to some farmers who are very much: I am a crop grower and that is what I want to do and I will always only ever do that. Urm... I've spoken to other farmers who are really interested and want to know about offsetting and... I mean we're not talking about monocultures for biodiversity. We don't want to turn their whole farm over to offsetting, because it's just not sensible. We want that dingy field in the corner of the farm - that floods every year - that's what we're looking for. We want those bits of the farm that perhaps aren't as productive because low nutrient soils are better for the kind of projects we're delivering, so it's kind of - we want the bad bits of the farm anyway. So once they get their head around the process - and also - I think once the market develops. At the moment this is so... embryonic... but once the market develops they will realise they can get payed for delivering these things and realise that it's going to be good for them.

Me: Do you think - on the point that you made about the market - in general using market based instruments play a central role in achieving the goals of the EU Habitats Directive or securing conservation objectives?

Respondent: Well it's difficult to say, I mean, in a perfect world, money wouldn't make the world go round. I think having a market based system is very much a reflection of the society that we live in and delivering this through that sort of system is going to be one of the easiest ways. I mean we're a long way off from this in England, but in Australia where offsetting has been going on for a while there are some types of - I mean it's a different system - but they call them native vegetation credits in Australia. There are some types of credits that are so rare that a developer is pretty much wanting to pay anything to get those credits if you've got that habitat on their site. Because obviously the rarest things are the most expensive things. But it will get to a point, if there is no more of that habitat available, they can't build there.

Me: It's quite interesting, I've heard the two sides of it working. In the way, more expensive offsets won't be pursued but then it's interesting you've said, because they're not being pursued, the development won't even be allowed.

Respondent: It depends on the system, if there's I dunno, something like woodland credits and somebody selling them for half the price than somebody elses, then of course the developers are gonna go for the ones that are half the price. So the more expensive ones won't be.

Me: What are the risks posed by the private sector provision of offsetting, if they're going to kind of be those cost competitions involved?

Respondent: sorry, what are the..?

Me: If there are going to be cost competition between the offset providers, are there going to be cutting costs on the habitats that they kind of package as offsets do you think?

Respondent: See, that's a worry within the [organisation name], because we have quite a strict process of getting the management plan written and what can be included in the management plan. We would never say to somebody your credits are too expensive but we would say you can't deliver that management plan with that amount of funding. Under a broker system, where the [organisation name] understands this than that's OK, but it could be a case that you get random organisations that deliver offsets.

Me: the rogue traders of the offsetting world?

Respondent: Yes exactly - very much like what happened with carbon offsetting. Y'know we're gonna hand out a few light bulbs in Somalia and that will offset your carbon

Me: So should there be a kind of base-line price or should there be regulations over that?

Respondent: I think there should be accreditation and accredited brokers or accredited offset delivery bodies - how the government would work that system I have no idea, but within the green papers they mentioned Natural England as maybe having some role in that.

Me: What kind of factors when you're determining the location of the offset... what kind of factors determine the location of the offset with respect to the affected communities?

Respondent: Well, in Essex, we are going for a strategy where it is delivered within the same local authority area, so it will always be delivered within the particular district or burough of Essex. Then, we're using the Nature Improvement Area for the greater-temp marshes improvement area and the Wildlife Trust Living Landscapes. Urm and we've said we would like the offset to be in the nearest landscape because it's about landscape scale and ecology and we're sort of trying to address the fragmented environment we have in Essex.

Me: So is proximity quite important to the location... the kind of offset... or the quality of the offset?

Respondent: Yeah... It's more about trying to make sure it's in the right place for wildlife again, because it's separate to the green infrastructure debate. So, we want it in the best place for the habitat and the wildlife and that may not be across the road from the developers. So, it's a case of, I mean my kind of dream for Essex is we have a big site in each of the districts in Essex and then sort of several smaller ones all around... and the kind of low-level impacts of developments - so where a couple of fields of farmland are being lost, perhaps it's five credits or something, they could feed into making the large site bigger and then small projects around the district when there is a bigger or higher impact development, so you could kind of get those kind of areas replaced. I'm not there yet, I have about 40 sites registered, I mean, on the environmental markets exchange.

Me: That's interesting and do you think like-for-like you can trade these sites, because by creating a market and comparing sites by their units of biodiversity do you think it's OK to replace a grassland with a heathland or some habitat with a completely different habitat, as long as they have the same societal or ecological value.

Respondent: It depends what the metric says really. A high distinctiveness habitat - a heathland, a bat biodiversity action plan on a brownfield site are high distinctiveness. So they can only do a place like-for-like. Somewhere like farmland is lower down so that's a low distinctiveness, so you you can trade like-for-like or trade up. Personally I would rather have some lowland meadow than farmland, because it's of more value to biodiversity, but it's very much within the matrix, what we're allowed to trade up, or not. I think the matrix got it about right, if I'm honest.

Me: That's interesting. Have you spoken to environmental groups or local campaigning groups and have they raised any concerns and what kind of concerns have they raised or what's their receptiveness to it?

Respondent: We have the RSPB, the Wildlife Trust on our local steering group for the Essex pilot, urm, we also have partners nationally with the [company name], lots of different partners in conservation and various other groups. Urm... the Woodland Trust has stepped back from offsetting, so they're no longer part of our steering group and I think most of the NGOs, they feel that offsetting could be fraught with difficulties and they're kind of waiting for DEFRA to come out with a position of how it's going to work, but most of the people that I've spoken to are quite welcoming of offsetting and they can understand that it's just needed and it's better than the current system. I think that's the underlying thing, once people understand what the current system is like and how bad the current system is, they're all for offsetting.

Me: So, what are the kind of failures in the current system, why is it not working?

Respondent: So, the current system, urm... Can I... I'll send you a link to three reports that were done by DEFRA and they are called [unknown word] reports. Basically, they look at planning and the delivery of environmental schemes under TTSI, which is the old system. Basically it's quite scary, 40% of locations didn't receive any expert ecological advice, 30% of mitigation schemes got delivered, the others didn't. The figures are really quite clear that biodiversity in generally is quite undervalued within the system. It is just seen as this blocker to developments all the time. The amount of time developers say Oh god, I've got newts... It's the sky falling down... I've got newts, Oh no! What am I gonna do now. Basically, offsetting it doesn't deal with protected species and isn't gonna solve that issues as of yet, but they're so used to biodiversity being a bad thing within the planning system, it would actually be nice if it could be a little bit simpler for them.

Me: Is it kind of empowering businesses then?

Respondent: Yeah... It's talking to developers and getting on the same page as developers. A lot of the ecologists that I've been dealing with, when ecology comes up, it's a case of, what can we get out of a developer, how much do you think they'll pay for this, how much do you think we can get and spend... and with offsetting it's very much about, this is your impact, this is what you need to pay to the management plan, that's the number of credits it will create and that's how it works y'know. There's a lot of horse-trading that goes on within the current system y'know, it's a case of: Oh, do you think we could ask for another couple of hectares of creation, or do you think we could do this, or could we do that... and it should be a lot more transparent under offsetting.

Me: That's really interesting and you've given me a really good insight. Unless you want to say anything else I will stop the recording.