Respondent 9 (Certified Offsetter)
Interviewer(s): Me
Interviewee(s): Respondent

Me: So, as you know, the project seeks to elicit stakeholder perceptions to biodiversity offsetting in the UK. I choose to study because it is something that is in quite rapid policy development at the moment, but quite early theoretical development, especially in the UK and EU. I have also done a bit of work on corporate responsibility and corporate reporting on no net loss goals so I'm quite interested in the role of business within conservation. I was particularly interested in your insight because you have worked at the interface of science, policy and business - especially in the case of Australia. So, you can probably give a global insight into the emergence of offsetting. So to start, perhaps the most divisive question, in the UK do you think biodiversity offsets are likely to lead to tighter or less stringent regulations around infrastructure development?

Respondent: I had a quick look at the questions this morning. I guess I wasn't sure what you meant by infrastructure. You weren't referring to national infrastructure or all infrastructure.

Me: National and also private. So heavy impact industries, like oil extraction, fracking etc.

Respondent: Typically, I do not come across oil and those things. We deal mostly with housing developers basically who have an actual footprint on the land/an area of land they are impacting. We have a bit to do with the minerals industries and the larger infrastructure projects such as HS2 and some of the highways, but it is mostly housing. Is that therefore not relevant to the subject you are looking at?

Me: No, it's still highly relevant. Probably across any infrastructure projects, so housing would be a great example if you are putting down the footprint of a house.

Respondent: So if you just keep that in mind. We do deal with large infrastructure projects, but not really with oil, just to put it into context. So, on that basis, I think the offset system as a mechanism and metric itself will definitely be a tighter and more stringent than currently. We have seen a lot of evidence through our dealings with authorities, that the current system isn't working and in fact there are not many restrictions placed on developers - they aren't actually properly compensating or receiving permission for their developments. So, I think a system like this can only be an improvement - if alone, simply for the metric, in being able to properly evaluate impacts and be able to give the planning authorities a tool to go into discussions with developers about what is appropriate in terms of not necessarily an offset. I think some of the terminology upfront just to make it clear in this country about offsets and offset mechanisms is kind of a bit deceiving. It is not actually about the offset, that is the end product, it is about the accounting and metrics. People have got deep into this offset terminology and we have as well. You may very well have developers that apply the metric and do not make an offset if their development does receive approval.

Me: And was that the kind of consensus - did you attend the conference in London - was that the kind of consensus that offsetting can be beneficial and create greater adherence to the mitigation hierarchy?

Respondent: Yes, definitely, there were quite a few experienced consultants who were dealing with some international projects and systems such as South Africa - a consultant there was talking about the way the mitigation hierarchy has not been well enough applied and in fact the metric alone in this system asked for that hierarchy to be much clearer and actually drive developers back up the hierarchy to work through it and there is an offset. The conference was also varied, because it was a BBOP conference there was a lot of discussion around bespoke larger projects that impacted priority sized, important sites. So, some of those learnings are not always easily transferable down to the UK system where we are dealing with a lot of lower level impacts across larger areas, but the sort of cumulative impacts on lower quality areas that aren't protected areas that are currently not being accounted for. So, there was a little bit of a mismatch in what we could take home from some of those larger bespoke project where they have different systems for each country etc.

Me: And do you think it's quite difficult to extrapolate from one country like a case study from one country to the UK?

Respondent: To a point, I think there are lots of similarities and there have been loads of learnings brought across from Australia and in terms of the way in which the mechanism can work in a streamlined way so that sites can be banked and credits can be sold to a number of small developers that aren't having quite small impacts and how you get quite big gains in that way. So, there are quite a few learnings. But there is also quite a lot about the context or baseline of where a country starts. So, if you have a country and I guess Australia is an example where you have a higher baseline of what is being expected of a developer, so regulations are a bit stricter.

Me: Sorry, do you think that is because it is administered in the public sector as opposed to the private sector?

Respondent: In a mandatory way?

Me: Yes

Respondent: Yes, to a degree, it is also about what the framework is already for preventing habitat loss and then you add this tool, this mechanism and this kind of... this way to properly assess the impact and to properly broker offsets then you find yes - it can be a kind of streamlined system. Here, where actually we are going from a system where impacts are largely ignored actually, to something that is quite a big step up. So, where your starting point it, I think that's what people struggle with - in comparing the differences between different countries. So that's the long answer.

Me: That's very interesting. So, going onto the next question which you already delved into. Based on your experience, do you think offsetting should be mandatory?

Respondent: Yes I do, I come from that mandatory system in Victoria in Australia and I can see how it really means there is a level playing field, there is accreditation of assessors who are doing their calculations and there is accreditation for the brokers such as us. So, the standards are brought up because of that mandatory system. Developers welcome being treated the same across the country and welcome being treated the same as other developers are. We speak to a number of developers here who are very concerned by a system where they are made to pay more than they have before, but at the same time they really do welcome standards and they will budget for those additional costs if they upfront know what the rules are and they are treated equally. So, it also allows landowners that want to put forward offsets confidence that there is a market that is there to sell it - that there is going to be demand for their supply.

Me: So, do you think the uptake will be higher across the board?

Respondent: Yes, definitely, many many landowners are waiting to see what will happen with the system at government level before they really come forward.

Me: So is there quite an interest from landowners leasing their land for offsets?

Respondent: You mean farmers...

Me: Yes

Respondent: There are many many landowners that would do, would revert from farming or even just manage their non-productive areas far far better if they had the appropriate funding, the financial incentives. We have definitely got a large number of landowners that would be interested.

Me: Yes, the point on the landowners probably brings me quite well onto the next question on equity considerations, which is, if I could ask: When undertaking offsets do you think compensating affected communities is always necessary and practical? Perhaps in the context of access to nature between the development site and the offset site;.

Respondent: Yes, it's a big issue in this country as well because you do have a lot of local communities with small areas remaining and nature nearby. So, certainly, it's important to make sure those local wildlife sites are really recognised in the planning system when impacts are being assessed. So, for example in our Essex pilot local wildlife sites are scored the highest, as high as priority habitats, even if they don't contain priority habitats because of that important. So, those sort of tweeks to the metric can be applied for local communities or at least local wildlife sites. We try to get local offsets for local losses. So, within local authority boundaries that is a requirement usually with the authority anyone and as close to the development as possible. So, even if, ideally adjacent, linked, but it could still be 10km away. We tend to be asked to find something within a radius from the development, so hopefully there is going to still be some access to that new site for local communities but you can never, obviously when you are removing something we are losing, we can't already get it right on site or adjacent within the same local community. I think if you asked how to compensate them - I don't know how financially how that would work and have not really come across that. There may be ways...

Me: And having worked globally within the offsetting profession do you think social compensation within the context of biodiversity offsetting is something that is being considered?

Respondent: I think it is similar to the way all other ecosystem services are not really being captured in the current metric and I think, that was brought up quick frequently at that London conference - how do we incorporate all of these other considerations about a site into that evaluation, into that impact assessment. It is currently not done, so I guess there is potential the metric could be designed to integrate the kind of social impacts, but, it is really is pretty important to keep it simple, to devise a metric that is so complex that tries to capture everything, you can lose some of the ease-of-use, some of that streamlined kind of quick application. And I think that is really important when you are dealing with local authorities that are really under-resourced, where there is low ecological knowledge in-house. So they need something that they will be able to apply quickly and hopefully the metric can be conservative enough to scale up and cover your bases in some way. I mean, it's crude, but... so you do get larger sites that do hopefully encompass as much of what you have lost as possible, even if it is not all fully valued.

Me: So can you see social compensation being fully/explicitly represented in the UK context, or more implicit, as you do it, as you conduct an offset, but it does not count as a formal requirement.

Respondent: Yes, not necessarily a formal requirement, but it is kind of understood and it has been part of the... and it has always been considered in every offset we have so far been dealing with. So, it is yeah just implicit, it is not actually fully quantified. So it could be, but you do risk kind of making... I think the beauty of the system is that is really does concentrate on biodiversity and in some cases actually locking away a site without the public access, actually letting it restore for the sake of biodiversity. So, the community side of things, may in some cases be better dealt with separately. So, green-space is always incorporated into the design of a development or nearby so access to green areas is crucial. That is actually dealt with separately to this. This is about biodiversity and that I think is a reasonable thing to be dealt with separately personally.

Me: To what extent do you think the benefits derived from ecosystems, if biodiversity offsetting does encourage kind of economic evaluations of biodiversity? To what extent do you think ecosystems are amenable to economic evaluation to capture the benefits they provide.

Respondent: I think that you can never really value biodiversity. So, I think we have got to think up innovative tools to stop the decline. I don't think we have much of a choice when we are dealing with developers who are driven economically and they basically need to be valuing the impacts they have on the ecosystems as they would any other resource that they are using. So, as much as we really struggle to put a value on that and we don't actually, in this system value grassland habitats, we are actually talking about what is the cost of a farmer down the road recreating that. So, it's not about valuing the ecosystem, it's about the cost of having to replace it. I think we have to talk this language, I don't think we have much of a choice because we are dealing with an industry or industries that speak the language of the economy.

Me: Yes, definitely - and do you think the increasing emphasis on market based instruments as biodiversity offsetting is referred to will have an impact on conservation objectives at the UK or EU level? Will it improve goal setting, or will it change the goal posts?

Respondent: I've written here, about the agenda-building capacity, I think that mainstreaming conservation and making it attractive does mean that there can be some landscape scale kind of projects and that can only be useful towards those kind of bigger objectives. It also does mean that the mitigation hierarchy can be better applied and developers will actually work their way through it. I think what we have got to keep in mind, at this stage, we are dealing with relatively small potential cover of land across the country. It is not like there is going to be such huge housing demand that we will be needing massive offsets where farmers are completely handing over entire properties etc. We are talking about less productive land that might be moved into offsets - hopefully larger bank sites but definitely get some real outcomes that can start meeting those EU objectives. But I in these early stages it's kind of... we need to be realistic. But, I think there is potential because a system like this does allow for that kind of banking of credits.

Me: So, would it encourage greater measurement and accounting on national and corporate levels of natural capital and that sort of thing?

Respondent: I would like to think so - in the kind of supply line, there might be companies that incorporate this sort of system. I guess, we deal mostly with the housing developers that have an actual impact and we can apply the metric to that area. At a level of private companies they could definitely incorporate this into their supply chain or make those kinds of investments into credits - it's a bit like the carbon credits system in that way that voluntary credit system work. We have not really scoped out how that would really work.

Me: And on the parallels between carbon offsetting and biodiversity offsetting - in the context of carbon offsetting there is in some cases rogue trading or offsetting where there are uncertified offsetters. I was just going to ask, what opportunities and what risks do you think are posed by the private sector provision of offsetting?

Respondent: There are similar risks in terms of the regulation of the system but I think the risks would almost be lower than what we have got currently in terms of the way the planning system is being applied - it adds far more rigour, simply the introduction of guidance within a framework for applying this alone requires planners and ecologists and local planning authorities to begin asking for evidence that the mitigation hierarchy is being appropriately applied when it hasn't before. I think the risks are lower - there is always that risk of the license to trash obviously, but I think that when you introduce a system such as this when there is all of a sudden a whole new level of transparency you actually give communities and local authorities and even developers as well that require justification rather than simply negotiations around what is deemed appropriate and what isn't. So, there are probably some risks in terms of investing in credits potentially with corporations that see rare habitats, credits, i.e. lowland meadow creation perhaps over time becomes a rarer thing and the price of those credits perhaps goes up and people are investing in them and they sell them on at a higher price. There are some risks around that in any potential market, but I think that can also create all sort of habitat creation projects where the impacts have not even happened yet. We could be getting up front banks created before we even see the impacts. So, I personally think that any incentive to get larger habitat creation, be it because there is a market potential there, it seems great to me.

Me: That's interesting - this is a general question about, if you had the offset metric in your hand what kind of parameters would you introduce or take out of the current proposals, across ecological, social, economic. What would you want to include... obviously proximity is included - I don't know if this is formally or informally included.

Respondent: In the current metric it is a pretty simple metric currently. Have you had a look at it yet?

Me: Yes, I have had a look at some of the parameters, but I am unclear which have been formalised.

Respondent: I guess they are not really formalised - they were formalised somewhat for the pilots in that they were given to the pilot projects and we were told to apply this metric and test it and let us know how you get on. However, it is still based on a similar metric we have in Australia and internationally. It is the area times the habitat type times the condition. So, it is rather simple, which is useful. The improvements that are needed and the government is well aware from the pilot evaluation already - the background assessment information for condition in particular needs to be more robust so there is less guess work around some habitat types such are arable land which isn't even in the current kind of assessment at all. So, some of the rigor around how to assess habitats or their condition and adding potentially more categories can actually make it quicker or easier to apply because you actually... there is a bit less guesswork if you can put it into a more specific category. It doesn't incorporate any social aspects or ecosystem services or anything like that.

Me: Do you think it should incorporate ecosystem services as ecosystem processes?

Respondent: I think sometimes habitats is quite a good way to cover quite a few... If you are creating a new lowland meadow close by you would hopefully assume that it would have the same ecosystem resources available as the site that was lost and then you could actually start to look at whether that is happening or not.

Me: Do you think measuring ecosystem function between the two sites is a bit too sophisticated.

Respondent: I think that would be interesting on test cases to see what is going on at the two sites particularly...The way the metric works we are often getting a trade up I think there is actually some bigger gains to be had in this country to other countries because we are dealing with impacts on lower quality sites - so we are dealing with a lot of developments on arable land or on improved grasslands or semi-improved grasslands 80-90% of the time that are currently being ignored completely. You apply the metric to those areas and you are asking - you are never going to create an offset that is arable or improved, you're always trading up to lowland meadow or something more interesting, so you are getting gains by trading up through the metric. So in that way you are kind of almost always getting an improvement. Probably the only consideration would be perhaps something around social... if you are losing a local site the community might lose even if it is improved grassland you might be getting lowland meadow that is not as accessible.

Me: And this is just a last point - do you think some kind of clause, whether it be a parameter should be introduced that stipulates there should be no net loss in access to nature or something like that between the two sites. Or at the moment, do you think it should remain an ecological compensation tool?

Respondent: I struggle with the access issue a little bit. I completely understand, moreso in this country that the local access is really key. In Australia we had offsets that were locked away for biodiversity. So, it depends on the site and the access. But, every case we are dealing with we are being asked by the authority, who are driving this, who are the ones making the decisions on where offsets should be. An offset strategy is really important and we have one for all of the pilots and we essentially come up with a strategy each time we look at an offset outside of those pilots. For example, a local authority were are dealing with has said we want it as close to the site so the community still have access so they have given us a radius and we want it within the conservation target areas so that we are actually meeting some of our local objectives in terms of where we want our greening to go. So, they can set some of those parameters for us and they do and it really has not been the case where we have not been asked to do that. So, what the government may come out with, the metric may potentially be simple, yet the system is so locally driven at the moment that you do have authorities setting the parameters every time.