With the adop­tion of its 2020 Bio­di­ver­sity Strat­egy the EU has made a com­mit­ment to halt “the loss of bio­di­ver­sity and the degra­da­tion of ecosys­tem ser­vices in the EU by 2020, and restor­ing them in so far as fea­si­ble”. To reach this goal the Euro­pean Com­mis­sion works towards an ini­tia­tive to ensure there is no net loss of ecosys­tems and their ser­vices (e.g. through com­pen­sa­tion or off­set­ting schemes) by 2015. This action is accom­pa­nied by a pub­lic con­sul­ta­tion on the planned No Net Loss Ini­tia­tive (see my pre­vi­ous post for more details). The dis­cus­sion on the intro­duc­tion of bio­di­ver­sity off­sets as part of this ini­tia­tive is very lively and con­tro­ver­sial: some expect a Euro­pean legal frame­work on bio­di­ver­sity off­sets would set min­i­mum stan­dards to pro­tect and restore  the nor­mal land­scape out­side pro­tected areas, oth­ers fear that this would fos­ter even more devel­op­ment and envi­ron­men­tal degradation.

This post is the sec­ond in a short-run series on the Bio­di­ver­sity Off­set Blog encour­ag­ing you to have your say on the con­sul­ta­tion on the EU No Net Loss Ini­tia­tive until Fri­day, October17 (con­sul­ta­tion closes) and to help you to make an informed decision. 

Argu­ments against bio­di­ver­sity off­sets as part of the EU No Net Loss Ini­tia­tive from Finance & Trade Watch

The fol­low­ing argu­ments where extracted from a fact sheet on bio­di­ver­sity off­sets (Finance and Trade Watch Fact Sheet Biodiversitäts-Offsets, in Ger­man lan­guage) pre­pared in Sep­tem­ber 2014 by ECA Watch Aus­tria and Finance & Trade Watch.

1. Bio­di­ver­sity off­sets fos­ter the illu­sion that we can con­tinue our exces­sive land-take
2. Through the finan­cial­iza­tion nature is becom­ing a trad­able commodity
3. Nature and bio­di­ver­sity can’t be mea­sured and quan­ti­fied (in money or units) and thus is not exchangeable
4. Bio­di­ver­sity off­sets can’t guar­an­tee to com­pen­sate all bio­di­ver­sity loss, because nat­ural sys­tems are too com­plex and may take long to recover
5. Nature con­ser­va­tion mea­sures as part of bio­di­ver­sity off­sets only occur if nature degra­da­tion takes place first.
6. Bio­di­ver­sity off­sets will most likely result in mar­ket based approaches that bear a higher risk of fraud with regard to addi­tion­al­ity and per­pe­tu­ity as well as qual­ity of the measures.
7. Cur­rent prac­tice shows that the mit­i­ga­tion hier­ar­chy is not always prop­erly enforced, i.e. projects are approved BECAUSE bio­di­ver­sity off­sets are pro­posed for the neg­a­tive impacts.
8. Bio­di­ver­sity off­sets are worse than noth­ing – they are a license to trash nature and legit­imize the exces­sive over-consumption of nature.

Argu­ments against bio­di­ver­sity off­sets as part of the EU No Net Loss Ini­tia­tive from FERN

He fol­low­ing argu­ments and pic­tures were taken from two brief­ing notes on bio­di­ver­sity off­sets pre­pared by the NGO FERN (FERN Brief­ing note 2 What is bio­di­ver­sity off­set­ting and why is it prob­lem­atic, FERN Brief­ing note 3 Bio­di­ver­sity off­set­ting in prac­tice).

1. Exist­ing bio­di­ver­sity off­set sys­tems (like in the US or Aus­tralia) haven’t proven to be a success.
2. Bio­di­ver­sity off­sets mean mea­sur­ing the unmeasurable.
3. Off­sets lead to a net loss of bio­di­ver­sity, i.e. most off­set sites have less bio­di­ver­sity than the sites that were destroyed.
4. Whereas bio­di­ver­sity losses are guar­an­teed, future gains may be real­ized late or not at all, i.e. ‘time lag’ of off­sets (the gap between the devel­op­ment occur­ring and the offset’s ben­e­fits accru­ing) also means there can be a seri­ous ‘interim’ loss of biodiversity.
5. Pub­lic author­i­ties do not have the resources — nor the will — to bring penal­ties when off­sets do not meet their requirements.
6. Bio­di­ver­sity off­sets can be a license to trash, i.e. off­set­ting is used to green­wash plan­ning appli­ca­tions and speed them through the plan­ning sys­tem, with no con­sid­er­a­tion for avoid­ance and mitigation
7. On first impres­sions, the NNLI appears to be a pos­i­tive com­mit­ment, but its impli­ca­tion that bio­di­ver­sity loss does not need to be reversed but kept sta­ble is worrying.
8. It also over­sim­pli­fies a com­plex issue. Biodiversity’s com­plex­ity and inter­con­nect­ed­ness make imple­ment­ing bio­di­ver­sity off­set­ting schemes problematic.
9. To be cred­i­ble, large amounts of data have to be gath­ered and ana­lyzed on var­i­ous sites and then val­ued. This demands a high level of exper­tise – and would involve con­sid­er­able expenditure.
10. The devel­oper would have con­sid­er­able power and influ­ence over the process. This might mean the envi­ron­men­tal impact of a project might be underestimated.
11. Those involved in bio­di­ver­sity off­set­ting talk in terms of tar­gets for replaced bio­di­ver­sity rather than of cer­tain­ties. The trou­ble is that if the tar­get is not achieved, an area’s bio­di­ver­sity is lost, never to be regained.
12. Strong gov­er­nance is vital in bio­di­ver­sity off­set­ting: once a scheme is imple­mented, it has to be prop­erly — and inde­pen­dently — mon­i­tored in the long term. Given the dif­fer­ent gov­er­nance regimes within the EU and the fact that exper­tise and the nec­es­sary man­power is likely to be lack­ing in many areas this can’t be assured.
13. To date, bio­di­ver­sity off­set­ting has focused only on the bar­ter­ing or swap­ping of var­i­ous sites of bio­di­ver­sity: it has not attempted to deal with the con­sid­er­able social value bio­di­ver­sity pro­vides to com­mu­ni­ties on a recre­ational, spir­i­tual and cul­tural level, i.e. com­mu­ni­ties lose access to nature.
14. Bio­di­ver­sity off­set­ting also ignores the other ben­e­fits nature pro­vides to a com­mu­nity, i.e. it can also have neg­a­tive eco­nomic con­se­quences, bring­ing down the value of nearby hous­ing and gen­er­ally less­en­ing the attrac­tive­ness of the neighborhood.

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Argu­ments against bio­di­ver­sity off­sets as part of the EU No Net Loss Ini­tia­tive from the ”No to Bio­di­ver­sity Off­set­ting!” Initiative

The fol­low­ing argu­ments were extracted from the state­ment “No to Bio­di­ver­sity Off­set­ting!” on the web­site of the initiative.

1. Bio­di­ver­sity off­sets could lead to an increase in dam­age, but even more con­cern­ing is that it com­mod­i­fies nature.
2. Bio­di­ver­sity off­set­ting relies on ‘experts’ to cre­ate dubi­ous cal­cu­la­tions that claim to make one piece of the earth equal to another. It pre­tends you can trade places.
3. The intro­duc­tion of bio­di­ver­sity off­set­ting allows, or even encour­ages, envi­ron­men­tal destruc­tion with the promise that the habi­tat can be recre­ated elsewhere.
4. With bio­di­ver­sity off­sets the com­pa­nies doing the dam­age can present them­selves as a com­pany that invests in envi­ron­men­tal pro­tec­tion, thereby green-washing its prod­ucts and services.
5. Investors want to profit from so called ‘nat­ural cap­i­tal’. “Nat­ural cap­i­tal” is an arti­fi­cial con­cept based on ques­tion­able eco­nomic assump­tions rather than eco­log­i­cal values.
6. Prop­erty rights over ele­ments of nature such as bio­di­ver­sity can be trans­ferred to cor­po­ra­tions and banks.
7. Bio­di­ver­sity off­set­ting won’t pre­vent bio­di­ver­sity loss, because it is impos­si­ble to fully mea­sure bio­di­ver­sity, so sug­ges­tions that equiv­a­lent nat­ural areas can be found is a fallacy.
8. Bio­di­ver­sity off­set­ting will harm com­mu­ni­ties, because bio­di­ver­sity off­set­ting means envi­ron­men­tal pro­tec­tion becomes a mere by-product of a com­mer­cial project, mar­gin­al­is­ing com­mu­ni­ties and threat­en­ing their right to life. Bio­di­ver­sity off­set­ting attempts to sep­a­rate peo­ple from the envi­ron­ment in which they live.
9. Past cases of bio­di­ver­sity off­set­ting show how it opens up nat­ural resources to fur­ther exploita­tion, and under­mines com­mu­ni­ties’ rights to be able to man­age and pro­tect the nat­ural commons.

More from the short-run series on the con­sul­ta­tion on the EU No Net Loss Initiative

The short-run series on the Bio­di­ver­sity Off­sets Blog on the con­sul­ta­tion on the EU No Net Loss Ini­tia­tive includes the fol­low­ing posts:

1. Con­sul­ta­tion on the EU No Net Loss Ini­tia­tive: Bio­di­ver­sity off­set­ting can, under cer­tain cir­cum­stances, improve nature and bio­di­ver­sity con­ser­va­tion — a com­ment by Heidi Wittmer

2. Why would you say NO to the EU No Net Loss ini­tia­tive? (this post)

3. Why would you say YES to the EU No Net Loss initiative?

4. Have your say – even if it’s a MAYBE: Con­sul­ta­tion on the EU No Net Loss Ini­tia­tive closes today!