Respondent 5 (Local Planning Authority)
Interviewer(s): Me
Interviewee(s): Respondent

Me: The best place to start is probably the license to trash rhetoric that biodiversity offsetting receives. I was wondering what your opinion is on the effect of biodiversity offsetting on the planning system and whether you think it is likely to lead to tighter or less stringent regulations around infrastructure ?

Respondent: Urm... I think there is a lot of myths about biodiversity offsetting going around - the license to trash is one of them I think. Second, my view on biodiversity offsetting is it is slightly different from everybody elses so... I see it as a metric to evaluate a site rather than as part of the mitigation hierarchy for example. We have had sort of issues with this with Natural England where I have been doing HRAs for them, but they don't like the word biodiversity offsetting in the HRAs. At least locally recording have to have an evaluation procedure rather than biodiversity offsetting, as per the wildlife service.

Me: Do you think the current mitigation hierarchy protects biodiversity in its current state?

Respondent: It should do, but it's often not the case.

Me: Where do the conflicts arise? Is it in the planning system?

Respondent: It is within the planning system, there is not enough forward planning for biodiversity. There is one thing I'm trying to promote for biodiversity in the planning system using biodiversity offsetting for site allocations and going through the mitigation hierarchy at the pre-site allocation stage of the plan do that any sensitive sites are knocked out before they even get in to the system for the development

Me: Is there a conflict between the change of UK policy and the integration of EU environmental policy in reference to the Natura 2000 network and different networks that deserve higher priority than other protected habitats. I was wondering if there is any conflict between biodiversity offsetting and the protection of those habitats?

Respondent: No, I don't think so, well if you take it to be a metric to evaluate a site, there is no conflict. I've been using offsetting since 2009 in the Habitat Regulation Assessment - the current metric has evolved from that. I started looking at habitat suitability indices for species back in 2003 and mainly for GAP analysis with the environment records centre, but we realised that it can be used for offsetting impacts. We had a south-west regional spatial strategy which is no more, there was a potential for development north of Tauton, but Natural England where in two minds about it, one officer was saying because of the impacts on the bat colony, it has to ... another which said yes you can do it but you can enhance the habitat out the development.

Me: Is this the DEFRA metric, or is this a separate metric?

Respondent: It is a separate metric, before Defra even thought about it. So, when Defra came along with the habitat metric we were a bit alarmed.

Me: Is there also a problem if different ecologists are using different metrics to consider biodiversity offsetting?

Respondent: Urm, not really.

Me: I mean, is one more simplistic than the other?

Respondent: yes - definitely. The Defra habitat metric is too simplistic and inadequate for what it should do.

Me: At the moment its a voluntary process. But from your experience should it be made mandatory for any kind of infrastructure projects?

Respondent: Yes, I don't see why it can't be.

Me: It is usually referred to no net loss or net gain but should there be a different goal, or does no net loss summarise what we should be aiming for in terms of halting biodiversity loss?

Respondent: We should be aiming for a net gain, but if we can't get net gain, we should be aiming for no net loss.

Me: At the moment it's just focussed on biodiversity, but do you think there is any scope to include ecosystem services, when you're assessing the habitat? There are two sides, ecological compensation, but also a social side, if you're translocating a habitat, you might have the ecological compensation, but if the services provided aren't the same, then there might be a loss.

Respondent: We're using species based, we need to make sure its accessible to that species still. The offset has to be in the same local as it is coming out of development. So, it's then possible, it's got to be accessible to the population affected, preferably on an ecological network. But, in the same sort of, if it's in the same local, the recreated habitat should be perhaps still accessible to the residents affected.

Me: When undertaking offsets, do you think compensating the affected communities is always necessary? And is it always practical?

Respondent: I don't know. It's not always practical, in most cases, the amount of offset it usually accommodated on the development site, it is only a few cases where I've needed to go offsite. Where we have had to go offsite, in that case, there would be no link to the community at all because they are completely separate.

Me: You can consider biodiversity offsetting in terms of the planning system or in terms of an ecosystem market. I was just wondering what your perspective is on valuing ecosystems and how amenable they are to economic value?

Respondent: I have no idea at this moment. I work entirely within the planning system.

Me: Do you think there is scope for it to develop in to a full-scale - in the same way we have carbon offsetting - do you think there is scope for there to be a habitat offsetting market?

Respondent: Possibly, yeah, it would just take more methods how to do it.

Me: Next to focus on the agenda building capacity - I think the best thing about this kind of like human-centered or ecosystem services approach is that it raised concern about the environment to the forefront of policy and market based instruments are being seen as the principal tool to halt biodiversity loss. I was wondering your perspective of, what role do you think they play in meeting EU targets for biodiversity loss or gain?

Respondent: I have no experience of that, all my offsets have been arranged between a developer and a landowner, without a market being involved at all

Me: Do you think the inclusion of a market could complicate things, or could it potentially ...

Respondent: Potentially complicate things and lead to biodiversity loss. Because if you're looking at a market-based offset, your offset is being directed to somewhere where it might not benefit the species population affected for example.

Me: Yes - that is what I meant: trading down, trading up, trading between offsets, so having a store of offsets then trading them financially.

Respondent: Yes I have got concerns about that.

Me: I suppose that covers the next question on the increasing emphasis on market based instruments, but what role do you think biodiversity offsetting will play either as a market based instrument or as a planning tool in realising the goals of the Natura 2000 network or reversing biodiversity loss?

Respondent: In the planning system, I can see it being a useful tool for evaluate sites where development is occurring. Currently we're just using a subjective approach to what that site is worth to a species. It provides more certainty for the developer.

Me: Is there any kind of limit to like-for-like offsets, in terms of an ancient woodland, or something that requires a long restoration period.

Respondent: Yes - we wouldn't touch them at all, they should have been eliminated in the pre- allocation stage if there is a site like that.

Me: After speaking to one of the offsetters, ancient woodlands have been included in the HS2 high speed rail and I was wondering how you think that got through the planning system?

Respondent: They have drawn it on a map and it's there and they're not going to shift

Me: Then, maybe a last point, is the mitigation hierarchy a well-recognised framework by businesses when they engage in mitigating biodiversity?

Respondent: I'm sure their ecological consultants are aware of it, I don't know if the developers are.

Me: Do you think it's useful for developers or do you think it adds more or less red tape around development

Respondent: Well, it shouldn't add red tape, they should be aware of it. looking at sites pre- allocation.

Me: From a council perspective, after speaking to a few people about the cuts the council is receiving, biodiversity offsetting can leverage a lot of private sector money towards conservation and supplement the government provision of conservation. Which could be great for meeting goals, but what are the risks of private sector engagement in conservation? Perhaps if biodiversity offsetting was integrated into a market system and you had brokers that were selling offsetters and developers that were buying them.

Respondent: No, I don't. Because the location of the offsets in relation to the development for a start. I haven't come across a need for doing it and I have been doing them since 2009.

Me: So should all offsets be geographically bound?

Respondent: Yes - otherwise you're gonna get biodiversity loss.

Me: What factors should determine the compensation, ecological compensation.

Respondent: It should be based on the receptors on the development side, you need to replace the habitat within accessible range with that population.

Me: Do the community receive informed consent of what is happening, or is there enough stakeholder engagement?

Respondent: People?

Me: Tes - is there enough stakeholder engagement?

Respondent: We haven't had any involvement.

Me: Should there be more engagement of stakeholders?

Respondent: Not really, they don't have any ecological expertise so... generally... we do have some professors.

Me: If the communities are affected by the development, would they be consulted by the developers?

Respondent: They would be on the development and the offsetting.